AGAINST HUMANITY AND INTERNATIONAL LAW

268/95

B E L G R A D E

1.1.1. To the northwest of Konjic, the municipality to which it belongs, on the Sarajevo-Mostar road and by the railway line, some 5,5 kilometers in the direction of Jablanica from Konjic, is the place of ČELEBIĆI (15 degrees and 30 minutes east geographical longitude, 43 degrees and 41 minutes north geographical latitude and 286 m. above sea level).

1.2.1. On April 20, 1992, at 24.00 hrs. sharp, Muslims and Croats attacked this building in which there were 14 JNA soldiers and took it.

The next day a meeting was held between representatives of the SDS, the SDA and the HDZ from Čelebići and it was agreed that Serbian women and children could leave the place; Croatian women had already left earlier. Thus on April 22, 1992, at 12.00 hrs. a convoy of three trucks and around 20 passenger cars with women and children aboard set out escorted by Muslim armed forces and went to Serb territory - Borke.

1.2.2. This military facility was turned into a camp for Serbs in which they went through untold suffering.

1.2.3. In the beginning this camp was run jointly by Croats and Muslims. The first warden was RASIM MIŠUNOVIĆ, a Muslim, who, before the beginning of June 1992 was apparently promoted and the Croat ZDRAVKO MUCIĆ was appointed the new warden.

1.2.4. When in the first half of June 1992 misunderstandings started between the Croats and the Muslims, according to some witnesses, the camp passed into Muslim hands.

Be that as it may, one thing is certain: the Muslims were by far more cruel than the Croats.

1.3.1. After the attack by Croats and Muslims and the seizure of Serb villages, the inhabitants:

1.3.2. The majority of the inmates were brought to the camp directly, after a shorter or longer journey. In some instances they were taken to other camps (a larger group was first taken to the sports hall at Musala in Konjic, the Secretariat of the Interior of Konjic, and a smaller group was taken to Trnovo, etc.) but later they would end up in this camp. A number of the people captured had been in other, Croatian camps: Ljubuški - the old prison, Grude - the school, in "Lora" in Split, and others.

1.3.3. It is characteristic in all instances that immediately after a village was taken the houses would be set to fire and people would be killed; captured Serbs would be severely beaten on the spot. Many were killed immediately after capture.

1.3.4. On May 9, 1992, the Muslims attacked the village of Idbar with the objective of capturing the men who had remained, as the majority had previously left for Bradina to get together with other people and mount a defence. They surrounded a house in which there were a number of people, women and children. MITHAD PIRKIĆ shot at random around the house and some less valuable things were also seized. They caught 8 men and a women, M., and took them to Čelebići that same evening. The next day they took the men to the sports hall at Musala and returned them after 21 days; M. remained at Čelebići all the time.

Proof: Witness 221/4-2.

1.3.5. The witness 454/95-19, together with his wife and two children, was arrested on May 13,1992 in Konjic by Muslims in fatigues with HVO insignia. They were taken to Čelebići. They spent a night in the camp and were then released but ordered to stay at Brdjani. The witness was arrested again on June 16,1992 and again brought to this camp. Of all the camp inmates who have been interrogated, this witness was the first to have been detained in Čelebići. For the time being it has not been ascertained whether people had been brought to this camp before this case.

1.3.6. Donje Selo was attacked on May 20,1992. Two days after that, on May 22, 1992, it was taken. ŠEFKO HODŽIĆ, who led the attack, addressed Serbs through a megaphone telling them to surrender. Then the Muslims called individual Serbs by telephone trying to talk them into surrendering and promising that nothing would happen to them. Under immense pressure the Serbs decided to surrender. Thirty of them, bearing a white flag, descended to the road to Konjic and surrendered to members of the HVO and the Muslim TD. After they had been ordered to lay down their arms they were transferred in groups of ten to the sports hall at Musala. On the morrow, May 25,1992, three of them were moved to Čelebići.

Proof: Witness 688/94-7.

Proof: Witness 221/94-1.

Proof: Witness 594/94-19.

1.3.9. After their attack on Bradina on May 25,1992 and the raid of the village on May 26, Croats and Muslims surrounded the houses, drove the Serbs out of their houses, looted and set fire to the houses and other buildings and captured the inhabitants, mainly women, children and elderly men and took them to "Mića’s cafe”. They beat them up on the spot and seized their valuables. Then they took them to the centre of Bradina, ordered them to strip all their clothes but their underwear. Then they had to run the gauntlet composed of soldiers who beat them. Those who fell fared the worst - they were trampled upon. Then the men were transferred by truck to Čelebići or to the sports hall in Konjic, and the women and children to the elementary school at Bradina where they were kept for several days.

Proof: Witness 234/95-12 and 607/94.

Proof: Witness 234/95-3, 292/3-95 and 380/94.

1.3.11. A characteristic account is the one given by the witness 260/94: On the morning of May 26, 1995, Croats and Muslims surrounded the house in which he was with his family, relatives and neighbours. They drove them all to a clearing in front of the cafe of MITAR KULJANIN and there they separated the men from the women and children. They beat them immediately. They beat them for a full hour with rifle butts, boots, pieces of wood and other objects. The witness saw REDŽA BALIĆ beating his son-in-law B.M. with a cable. G.V. and G.M. were beaten up. The two of them were forced to swallow half a page of the daily “Oslobođenje” each with a picture of Draža Mihajlović. At a certain moment two airplanes flew over the place and then they were beaten even more. After the beating they were taken to the cafe of PERO MRKAJIĆ and on the way they were stripped of all their gold, money, documents and other belongings. Their documents were burned immediately. At the cafe all of them had to run the gauntlet and were beaten up before they boarded the lorry. M., alias “K” and K.B. sustained grave injuries. There were about 80 of them. All of them were transferred to the Čelebići camp. En route they came across Muslims who spat at them, swore at them and showered various abuse at them.

1.3.12. In Bradina that day and in the days that followed a number of arrests were made of people who were in hiding.

Proof: Witness 234/95-11, 488/94-1 and 221/4-7.

1.3.13. An interesting case is that of the witness 148/95, who, after Bradina was taken, was in the trenches with his neighbours, defending the village:

"My son ZDRAVKO, 13 years old, was a pupil of the seventh grade of elementary school. They took him out of the house in the village of Bradina, and, driving him in front of them, they forced him to call me to get out of the trench and surrender. As they were behind him with a weapon pointed at his back, you can imagine what the child went through; and not only him, but me myself, seeing my boy walking in front of them with their gun barrels against his back and fearing that they might kill him any moment. To save my boy’s life and prevent them from killing him, I came out of the trench and I surrendered."

Immediately thereafter the witness was beaten up and transferred to the Čelebići camp.

1.3.14. After Bradina was taken, a group of 40-50 Serbs surrendered on May 27, 1992 in order to save the lives of their families, which had remained in the village, in view of the fact that the attackers started killing people and setting fire to houses right away. After that other groups and individuals surrendered. All those who were caught or surrendered were divided into three groups: those who had arms, those without arms and women and children. Of men there were a total of 84-88.

The moment they laid down their arms, they were lined up against the supporting wall of the cutting below which passes the tunnel Ivan-Sedlo, 3 kilometers long, which is near the centre of Bradina. Having forced them to remove their upper clothes, they took all their effects and documents from them. Thus they took from the witness 243/95-4 his watch and his gold wedding ring. They had them all climb a lorry and then beat them up in it. Whoever managed to climb faster fared better so that the older and feebler ones got beaten more. They were beaten with rifle butts, metal sticks, boots, and other objects. Some fainted. Some suffocated in the tarpaulin-covered lorry as it was hot outside.

They shoved a rifle barrel up the mouth of the witness 86/1-95 and pierced his head and he was unconscious most of the time. He has a hazy recollection of having been taken to Čelebići by truck. They rocked the truck so as to overturn it. They arrived in Čelebići on that same day between 11 and 11.30 a.m.

Proof: Witness 243/95-6, 86/1-95, 274/95 and 488/94-2.

1.3.15. On May 26, 1992 a group of 18 Serbs surrendered to the Croats and Muslims near the railway station in Bradina.

Proof: Witness 100/94.

1.3.16. On the evening of May 26 a group of 100 Serbs was taken to the sports hall at Musala in Konjic and transferred to Čelebići the next day.

Proof: Witness 236/94.

1.3.17. The Croats and Muslims attacked Donje Selo for the first time on May 20,1992 around 3.30 p.m. The attack lasted till evening. G. was working in her garden and she saw five cars from which men in uniforms disembarked and immediately surrounded the house of J.A., a policeman. G. fled in the direction of her mother-in-law’s house. She saw them surrounding her own house and they started shooting immediately. A number of people fled the area. They took to the forest and hid. The witness went out of the forest in the evening and saw her house as well as the houses of A.J., Ć.P., Ć.M., Ć.O, S.M and others burning.

At dawn, on May 21,1992 the shelling of the village started. The shells landed in the forest and in the village itself. That evening 11 villagers hid in a cave near the house of G’s mother- in-law and the house on M.Ć., some 16 square metres in area, in front of the entrance to which there was a rock so that the entrance was shielded. There they hid until May 24. Afterwards they went to the house of Ć.T.

On May 26, when there was a renewed attack, about 200 Muslims and Croats surrounded that house. The people inside were driven out. While they searched the house SADIK TELETOVIĆ killed MIŠA ĆEĆEZ. The killing was witnessed by N.Ć. and T.Ć. The brother of the killed MIŠA was beaten up. Then they were all taken to the Cooperative Centre, from which he and G. were transferred to Čelebići in a vehicle.

Proof: Witness 221/4-3.

1.3.18. Around 9 a.m. on May 27,1992 a group of 86 Serbs came to the centre of the village of Gornja Bradina and surrendered to Territorial Defence units from Konjic.

Proof: Witness 236/94.

Proof: Witness 147/95.

Proof: Witness 243/95-12 and 488/94-7.

1.3.21. After the attack on Bradina, on May 25,1992, a number of women hid in the forest for five days. Afterwards they returned to the village where they were caught by the Croats and Muslims and locked up in the school. PERO BARUNČIĆ came that same evening and asked M. where her husband was. She said that she did not know. They singled her out together with M.D. and Dj. and transferred them to Čelebići where they arrived on May 29,1992 about 4 p.m.

Proof: Witness 412/94-27, 412/94-16 and 412/94-27.

1.3.22. A group of 12 Serbs was captured on Mt. Bjelašnica. They were beaten and tortured en route, at the hotel "Mrazište" on Mt.Igman and in other places. After spending one night in Tarčin they were taken to Čelebići on May 30,1992. After having been accorded the “standard welcome “, they were placed in “No.6”. This group included: PERO MRKAJIĆ, caterer, who was later killed, Dj.Dj., M.R., Dj.M. Dj.Z., the witness and others.

Proof: Witness 283/94.

1.3.23. After Bradina had been taken, RAJKO DJORDJIĆ was retreating with his group towards Kalinovik planning to cross over to Serb territory. Another five men joined them on the way. After spending several days in the forest, in the rain, mud and cold, they surrendered on May 30,1992 near the village of Ljuta. They would not have done so had they not been deceived. The Muslims had promised to let them go the moment they surrendered their arms. But they did not set them free but bound their hands on their backs with wire and took them to the school in the village of Ljuta. HOS members beat them in the school.

They beat RAJKO DJORDJIĆ especially hard, slashed with a knife and tore the JNA uniform that he was wearing. All their money and valuables were seized. They spent the night there. On the following day they were driven, tied, to the village of Šabići, to the school, where they were also subjected to maltreatment. From that point other soldiers took them to the "Famos" hotel on Mt. Igman. There were HOS members, HVO members, "Lilies" and members of the Muslim Territorial Defence there. At the hotel they had to identify themselves and then were beaten and insulted. After an hour or so they had to run the gauntlet composed of soldiers who beat them all the way from the entrance to the hotel to the "Tam" van which was to transport them further. En route they were moved from this vehicle into a lorry. When the lorry came, the guard fired a burst and killed DRAGAN VUJIČIĆ, wounded K.Dj. in the stomach, K.Dj. in the head driving one of his eyes out, and Ž.R. in the arm. No medical assistance was extended to anyone. They passed through the villages of Vrdolje, Džepi and Živašnica. They stayed a while in each and the assembled Muslims showered abuse at them, spat at them and threw various objects at them. Eventually they arrived in Konjic. There they stopped near the Community Centre and then in front of the building of the Secretariat of the Interior. Their escorts beat them and insulted them and were joined by the crowd which had gathered. They forced RAJKO DJORDJIĆ to stand although he had been badly beaten up and unconscious for a while, showing him around as a captured "Chetnik duke". In front of the police department they ordered him to kiss their emblems, and, as he refused, they beat him some more and forced him to kiss a wild boar which they had caught on Mt. Bjelašnica and loaded onto the lorry. From the Police Department they went to the motel and home of ZEJNIL DELALIĆ, who had worked in Austria and held a high office in their army. There they unloaded the boar and continued their journey, with a strong armed escort and police cars with their rotary lights on. RAJKO DJORDJIĆ continued to be on show as a “Chetnik duke” and was constantly beaten.

1.3.24. In the evening of June 15, 1992, the Croats and Muslims surrounded a house in Idbar and then searched it looking for arms and a radio station. They shot at random around the house and arrested M. They also arrested Lj. and other villagers and transferred them all to Čelebići on that same day.

Proof: Witness 221/4-2.

1.3.25. In the evening of July 12,1992 REDŽO BALIĆ and SALKO LJEVO came to the house of R. in the village of Zukići and took her to a car and then brought other Serbs to the spot: Dj.S., S., his wife, JELENKO and his wife ANDJA DJORDJIĆ, who were later killed, Dj.Va. and Dj.Ve., their sons, M., their aunt J.G. and B. (13 years old), their daughters G. and B. (14 years old) and her son. HAMO NIKŠIĆ was at the wheel. They were all transferred to the camp in Čelebići.

Proof: Witness 221/4-4.

Proof: Witness 178/94 and 440/94-1.

1.3.28. Other arrests, captures or the surrendering of groups and individuals in different places are described by the witnesses: 243/95-8, 221/4-6 and 445/95-22.

1.4.1. The first camp inmates in Čelebići were registered after May 10,1992, when this facility started to be operated as a camp. The camp existed until December 9,1992 when the last group of 32 "inveterate Chetniks" was transferred to the sports hall at Musala in Konjic.

1.4.2. Very few people were released directly from this camp. They were gradually transferred to Konjic and from there either exchanged or, in a smaller number of cases, released.

1.4.3. A group of 28 Serbs from Cerići was in the camp for one day and right away, on May 23, transferred to Musala. Then they were transferred in groups: 20 on June 5; On June 17; a group of 50 on August 13; On August 21; a large group (over 80) from Bradina in late August; in the beginning of September; on October 5 - 17 of them; at the end of the same month - 30 people and on December 1 all the camp inmates except for 32 whom they moved on December 9 so that nobody remained.

The staff was also transferred and the Čelebići camp was dismantled.

1.4.4. Only seldom and only few people were actually released. The only exceptions were on August 31 when 20 detainees were released and on November 17 when several of the inmates were set free. As for individual releases they took place on: May 28 (released by DELIĆ); on May 30 (an elderly man released after interrogation); on June 10 and 15; on July 22 (a doctor but required to report to the camp for regular duty); and on August 19 and 31 (individual inmates released by DELIĆ). On August 31 a larger group was released, consisting of 20 inmates, as attested to by the witness 509/94-5. On October 16,1992 another doctor was set free. ZDRAVKO MUCIĆ personally released one Serb towards the end of October and another one on November 18,1992.

All of the released prisoners were given a written decision to that effect. Only one of the detainees escaped while working outside the camp. There may have been other cases but we have no such knowledge to date.

1.4.5. The inmates were placed in "the ward", then in "hangar No.6." and "tunnel No.9". The "ward" was vacated and reserved for the gravely injured.

After representatives of the International Red Cross (IRC) came on August 31,1992, all the camp inmates were moved from "No.9" to "No.6." so that no one remained in the "tunnel". After most of the Serbs had left, the group in the "ward" stayed till the end.

Attesting to this are witnesses 147/95, 274/95, 100/94, 221/94-1, 221/94-3, 234/95-11, 234/95-12, 243/95-12, 243/95-6, 243/95-7, 260/94, 412/94-15, 412/94-23, 440/94-1, 488/94-2, 607/94, 630/1-9 4, 243/95-4, 221/4-6, 148/95 and 594/94-20. (The testimonies of these persons also confirm the data given in the previous two chapters).

1.4.6. The witness 221/4-7 was incarcerated with a group of 20 Serbs in tunnel "No.9" from May 26 to around May 31, 1992, when they were shifted to hangar "No.6" as "No.9" was needed for the "more dangerous Chetniks".

1.4.7. The first camp inmates locked up in hangar "No.6" comprised a group of between 84 and 88 Serbs, which was brought there from Bradina on May 27,1992. The next day another 9 persons were brought from the Secretariat of the Interior in Konjic.

Proof: Witness 236/94.

1.4.8. The witness 688/94-7 was in ward "No.22" from May 25,1992. He was brought there from Musala where he had spent one night. He had surrendered in Donje Selo. There were about 70 people there. They slept on the floor for some ten days, and others were brought in so that their number eventually reached 106. Therefore HAZIM DELIĆ, deputy camp warden, transferred them all to hangar "No.6" where there already were around a hundred souls. The witness was in the camp for three months. He was transferred to Musala on August 20,1992 and released on August 30,1992. This is also confirmed by witness 221/94-1.

1.4.9. After a visit by the IRC, a group was moved from tunnel "No.9" to hangar "No.6". The group of fifteen who had remained in the tunnel were moved from it ten days later - on August 31, 1992. Witness 221/4-5 believes that this was on the occasion of the birthday of the commander ZDRAVKO MUCIĆ. Around November 20, 32 camp inmates were transferred to the ward in which they stayed until December 9,1992.

Proof: Witness 488/94-6, 488/94-4, 65/1-95, 221/4-5, 488/94-7, 488/94-1, 488/94-5, 243/95-8 and 488/94-3.

1.4.10. On May 31, 1992, a Commission consisting of Dr. RUSMIR HADŽIHUSEINOVIĆ, specialist of urology and Dr. AHMED JUSUFBEGOVIĆ, specialist of internal medicine, singled out Dr. M.R. and Dr. G.P. and another 10 worst beaten up inmates and transferred them to the “3 mart" elementary school in Konjic where there was a "ward for captured Chetniks". Then, between June 10 and 12, they returned them (13 camp inmates including the doctors) and put them in "No.22" which was empty then. They brought 12 ordinary hospital beds and a cot from the hospital. When there were not enough beds, the inmates slept on the floor.

Proof: Witness 236/94, 292/3-95, 488/94-5, 380/94 and 234/95-3.

1.4.11. All the camp inmates from Čelebići were either directly exchanged from the camp at Musala in Konjic or were released, brought in again and then exchanged. There were both official and “off the record” exchanges, one by one. In a large scale, general exchange organized on October 6,1994 on the "Srpskih junaka" (Serb heroes) bridge at Grbavica in Sarajevo, the last inmates - 81 of them - from this camp crossed over to Serb territory.

Proof: Witness 445/95-22, 412/94-15, 221/4-7, 147/95, 234/95-11 and 488/94-6.

1.4.12. Almost all the Serbs, both those released from camps and those who had never been in camps, together with their families crossed over to Serb territory, as a rule by bribing someone or paying the Croats who enabled them to pass through their territory. Consequently, in Konjic and in the Muslim-controlled part of the commune there are now less than a tenth of the previous number of Serbs. Apart from that, in many villages, such as for instance Bradina, there is not a single Serb left, and all their houses and other property have been plundered and destroyed.

1.5.1. People from Konjic and the nearby villages were brought to Čelebići. Most of them were from Bradina. They were all Serbs (except for one Muslim who was with them for a while). Some of them had organized themselves to defend the lives of their families and their own, their property and other valuables because for a long time the threat of an armed attack by Muslims and Croats against the Serbs had been in evidence. It proved true. In April and May 1992 Muslims and Croats attacked villages and sections of villages inhabited by Serbs. Serbs were killed and banished and their property was plundered and set on fire, so that a large number of them flocked to Bradina, the largest purely Serb village, where the villagers had organized themselves to mount a defence. When Bradina was taken, the defenders retreated in the direction of Serb territory. Some were captured and some surrendered. They were people in their prime and the breadwinners of their families. A large number of people who did not fight also ended up in the camp, mostly elderly people and instances of children inmates have also been registered.

1.5.2. Although the majority of the camp prisoners had secondary school qualifications, there were also doctors, professors, engineers and other highly qualified professionals among them. Most of them had worked in Konjic and many of them were employed in the various plants of the "Igman" military factory.

1.5.3. According to the accounts of the camp inmates who have given testimonies as witnesses and on the basis of the data collected by the Red Cross, from Borac - the Serb commune of Konjic and by the Committee, a list of 369 men and 16 women has been drawn up. It is estimated that this is not the definitive number and that over 400 people had been incarcerated in this camp, and the figures are being constantly updated. The names of 19 Serbs who were in ward "No.22" and of 77 who were in tunnel "No.9" have been registered.

1.6.1. The kind of "reception" that everybody was accorded immediately upon arrival was vicious beating, and several people were killed. If it had not been done before, their money and valuables were seized on arrival. Some were interrogated. Characteristic in terms of brutality were the events on May 27, when a large group from Bradina came and on May 31, when the group including RAJKO DJORDJIĆ was brought in.

1.6.2. A large group of captured Serbs, between 84 and 88 it is estimated, came to the camp around 11 a.m. on May 27, 1992. As the lorry entered the camp compound they were immediately beaten: in the lorry, as they disembarked and thereafter. They were lined up against a supporting wall about 100 metres long, facing the wall. Probably about 30-40 military policemen beat them for 6 or 7 hours on end. They came in groups behind the prisoners’ backs and beat up each and every one of them. All the while they asked them about their personal particulars and about weapons and similar. They were all beaten up. HAZIM DELIĆ who had a crutch as he had been wounded, was in charge of the beating. The Serbs were hit with iron bars, baseball and other bats, rifle butts, hoe handles and other objects.

One of the witnesses, 243/95-4, was forced to lie down and kiss the ground while one of them kept hitting him with a hoe handle until it broke. Seeing that their victim was still conscious, they swore at him and asked him what his back was made of since he was able to endure all that beating. The witness replied that they could continue to hit him as much as they could seeing that they had where.

On that occasion were killed PETKO GLIGOREVIĆ, the father of witness 243/95-4, GOJKO MILJANIĆ and MIROSLAV VUJIČIĆ, the brother of witness 236/94. They beat ZDRAVKO GLIGORIJEVIĆ the most and later he was taken away from the camp and, probably, killed. All the while they were forced to keep saying the "Allahu ekber" (Allah the Almighty) prayer and "Ready for the Fatherland!"

The witness was hit on the kidneys, on the back, the muscles of his legs and arms, on the loins, and kicked in the testicles. He saw many others faint. As K.S., a deaf-mute, could not hear what was being asked of him to do, they beat him thinking that he was feigning. Some people were taken out of the file, ordered to lie down and then beaten. MIROSLAV VUJIČIĆ, for instance, before they killed him, and G.N.

When K. N. asked for a drink of water, the guard JAPALAK ordered everybody to take off their socks and throw them into a canal. Then he ordered them to urinate into that canal, and then everyone was ordered to drink urine from that same canal. The witness had to do it also. JAPALAK came looking for two Serbs with the surname T. from Tarčin. Then they were beaten up an thrown into hangar “No.6” with the others. The witness 86/1-95 was in a grave condition and was transferred the next morning to the “hospital for Chetniks”. All this was observed by a group of camp inmates that had been brought in the previous day, as they were actually lined up so as to watch it. The inmates were beaten by: ŠEFIK ČAMAGA, RAMIZ ĆIBO, ESAD MACIĆ, called “MAKARON”, his brother “MACA”, and others.

1.6.3. The witness 260/94 says, that after they were put in the hangar, G.D. was ordered to take the body of GOJKO MILJANIĆ out in a wheelbarrow, and Dj. D. to take out the father and son T. whose arms and legs had been broken in another wheelbarrow. The day after they came, HAZIM DELIĆ came and designated a seating place for every one, ordering everybody to face the floor with their backs bent. In so doing he swore at them cursing their Chetnik mothers and threatened to kill anyone not obeying orders.

1.6.4. A group of 12 Serbs from Bradina, which had been captured on Mt. Bjelašnica (taken over Mt. Igman and spent the night at Tarčin), on arriving at Čelebići on May 30, 1992, were beaten up an placed in “No.6.”. They were beaten by PAJAZIT, a certain Albanian, and DELIĆ was present.

Proof: Witness 283/94.

1.6.5. A group captured near Ljuta arrived, on May 31, 1992 between 3 and 4 p.m., escorted by Dr. RUSMIR HADŽIHUSEINOVIĆ, the mayor of Konjic, JASMIN GUSKA, the head of the Secretariat of the Interior, and others, who escorted them through the city. When the group entered the compound, guards climbed onto the lorry and beat them. The people brought in were lined up against the wall of “No.9”, beaten up and stripped of their belongings and articles of clothing leaving them in only their undershirts and trousers, barefoot. Then they were interrogated. Afterwards DELIĆ took about 70 inmates out of "No.9" and lined them up against the new arrivals. The newcomers could see that those people were all beaten up, smeared with blood and generally in a sorry condition. There were elderly people among them. They were lined up facing each other.

PAVO MUCIĆ, the camp warden, had the witness 221/94-3/1 and RAJKO DJORDJIĆ come out in front of the line and addressed the witness telling him that RAJKO was to blame for their fate calling him names in the process in order to provoke them to condemn RAJKO. None of the camp inmates did so, and DJORDJIĆ himself stood upright, soldierly, his head high and his posture proud. Mucić asked the witness if he knew RAJKO, and the witness replied that he did, that he had been his commander. Hearing that, MUCIĆ kicked him in the chest and then left. Then DELIĆ said that RAJKO DJORDJIĆ was a “Chetnik duke” and that those who had been brought with him were members of his special units, that they had killed Muslims and burned their villages. All this while other guards kept beating them. They hit them with rifle butts, kicked them with their booted feet, and hit them with various other objects. The beating lasted for a full two hours. Many fainted. The witness 221/4-5, who had already been molested en route, was hit by a person, who the witness knows is from the village of Džepi, by a metal rod at one end of which there was a spring and on it a metal ball. The witness lost consciousness. The witness 243/95-7 fainted on and off and has a hazy recollection of all the things that had befallen him and the others. Then, all those who were taken out of "No.9" were taken to hangar "No.6" and the new arrivals were put in "No.9".

Proof: Witness 488/94-5, 488/94-4, 65/1-95, and 509/94-5.

1.6.6. All Serb men from Brdjani, 64 of them, were brought to the camp on June 15 and 16, 1992. They were beaten up and placed in a number of manholes.

Proof: Witness 178/94.

1.6.7. Other witnesses describe in much the same way their first moments at the camp: the witness 295/94-4 was beaten up so badly that he was unconscious for three days. The witness 243/95-8 was knocked out unconscious by a blow of a rifle butt in the forehead. The witness 147/95 was immediately placed, with some other people, in a manhole. He adduces the names of some who had been so badly beaten up that they had to be carried into the hangar. In addition to the mentioned, they were also beaten by EDO DŽAJIĆ, alias “MUF”, “ZENGA” and others.

1.7.1. Money and valuables, as well as better pieces of clothing and footwear were seized on the spot, at the moment of capture or en route during transport, so that on arrival in the camp there was hardly anything of value left to take. This notwithstanding, everyone was routinely searched and any valuables that they might still have had were taken. The witnesses say that all their documents, money, watches, wedding rings, clothing articles, were routinely seized.

No one was ever given a receipt for their things seized.

No one ever got back the things seized from them.

Proof: Witness 412/94-23 and 488/94-1.

1.7.2. A helmet was put in tunnel "No.9" in which all the inmates had to put their money, watches, golden objects and all other valuables. The witness 221/44-7 was forced to take off the gold chain he had on his neck and to put it in the helmet.

1.7.3. The guard SALKO HEBIBOVIĆ forced the camp inmates, threatening them with death, to collect 100 German marks each for him, as well as gold and rings.

Proof: Witness 147/95.

1.8.1. The interrogations were carried out in an unsystematic manner and the impression is that they were more in the service of torture and abuse than aimed at clarifying an even or collecting data. Sometimes, before and after being taken for interrogation, Serbs were tortured in a special way (lengthy exposure to the sun,keeping in manholes and similar), and during the interrogations themselves most were beaten up. In a smaller number of cases they were only humiliated and insulted. Some were blindfolded. On occasions like these it was often impressed upon the Serbs that they should have lived "nicely" with the Muslims and Croats, that they should not have defended themselves, that they did wrong to listen to their leadership, etc. They were regularly asked where their weapons were, where other Serbs were hiding, where they were hiding their weapons, whether they were members of the SDS and similar. They were interrogated by interrogators from the Konjic Secretariat of the Interior or court staff, but there were also others. The camp staff also attended and participated in the interrogations, HAZIM DELIĆ in particular. The camp inmates were interrogated and beaten in front of other inmates or after having been taken out. This was done by DELIĆ, “ZENGA” and other guards. Characteristic in this regard is the case of the killing of SLAVKO ŠUŠIĆ. He was interrogated by: MIROSLAV STENEK, ŠEFKO NIKŠIĆ, SMAJO PREVLJAK and others. Some signed their statements and some did not.

Proof: Witness 412/94-23, 488/94-4, 221/4-7, 594/94-20, 243/95-12, 243/95-6, 221/94-3/1 and 292/3-95.

1.8.2. No one was ever tried by a court in Čelebići, nor were any proceedings instituted.

There were trials later, after they had been transferred to the sports hall at Musala in Konjic. Individuals would be taken to Butrović polje where the proceedings were conducted before the military court, but for the time being no reliable data is available in this regard.

1.8.3. On June 10,1992, the witness 488/94-6 was taken out of the hangar together with a group of inmates. DELIĆ tightly handcuffed him. Then they all stood in the sun for hours. Out of exhaustion (earlier beatings, hunger, etc.) and because of the scorching sun, the witness fainted three times. After this he was taken for interrogation to MLADEN ZOVKO called "KUHAR". MASLEŠA was also there. They asked him about his political affiliation, what Karadžić thought about various issues, etc. When he was to sign the record, they took off the handcuffs. He dropped the pencil for his hand was so weak after that tight grip that he could not hold it. After that DELIĆ put them in a manhole. On June 12 the witness was again taken for interrogation, attended by, among others, MIRO STENEK, JERKO KOSTIĆ and RAMIĆ. They asked him the same questions as before and then DELIĆ returned him to the manhole.

1.8.4. The witness 594/94-19 was led blindfolded out of "No.22" for interrogation. He was blindfolded throughout the interrogation. They asked him about arms, where other Serbs were, and other things. They fell upon him at once and beat him all the while. Two held him and the others beat him. Who and how many people exactly beat him the witness does not know as he could not see them. He was beaten also as they returned him to the cell. On that occasion two of his upper teeth were knocked out and two ribs broken and he was bruised all over.

1.8.5. The day after he had been brought to the camp, on May 26,1992, the witness 688/94-7 was taken to be interrogated by ALIKADIĆ, called “BATO”. He asked the witness who had killed two Muslims during the attack on Donje Selo. The witness replied that he had not done it. Then “BATO” grabbed a beer bottle and hit him on the head. The bottle broke. As the witness again gave the same answer he kept hitting him on the head until he had broken 20 bottles against his head. Then he forced the witness to kneel and kicked him in the head 25-30 times. He did the same to K.M. who was also there for interrogation at that time. Then the witness was returned to "No.22".

1.8.6. The witness 221/4-5 was interrogated by MLADEN ZOVKO, called "KUVAR" in the administrative building. The witness was tied and the interrogator would not untie his hands although he was in much pain. He asked the witness about everything that had happened in Bradina: who had arms, where certain people were, why had they not remained to live together with Croats and Muslims. He assigned every interrogated camp inmate to a category and the witness was classified under category "A", like all others placed in tunnel "No.9". That meant that they were to be executed by firing squad. He was not interrogated again while in the camp.

1.8.7. Immediately upon arrival at the camp, the witness 221/4-5 was interrogated by MIRO STENEK and MUSTAFA HALILHODŽIĆ, who had gone to school with the witness. HALILHODŽIĆ gave all the witness’ documents that had remained in his house to STENEK, and the latter took out from the batch the membership card of the karate club of which the witness was a member, showed it to him and said that they too had karateists and that they would break all of his bones.

1.8.8. The judge GORAN LOKAS, a Croat working in the court in Konjic, was brought to the camp to interrogate the detainees. When he saw the condition that they were in, he refused to do it. Later the witness learned that this judge had been in a "fixed" traffic accident.

Proof: Witness 100/94.

1.8.9. According to some criteria of theirs, all the camp inmates were categorized either during interrogation or before it, into one of 9 categories. Those falling under categories 1 and 2 were either sentenced to death or to 20 years of imprisonment and those from categories 3 to 9 were to be exchanged or released.

Proof: Witness 86/1-95.

1.9.0. The witnesses describe the camp in the following way:

Proof: Witness 630/1-94, 236/94, 221/94-3/1 and 243/95-13.

Proof: Witness 236/94, 380/94 and 221/94-1.

Proof: Witness 221/4-3 and 412/94-27.

1.10.1. The food and water, which were scant, were of poor quality and often they were not given any. A frequent punishment was deprivation of food altogether. Such punishment was meted out as "revenge" during Orthodox feasts. No food or water were dispensed in e.g. the following situations: When 9 Muslims were killed on St. Peter’s Day, or before IRC representatives came, or during their first days at the camp, as was the case with those captured at Ljuta, etc.

1.10.2. There were one or two meals a day. A meal or a whole day’s ration as a rule consisted of a 600-700 g. loaf of bread, to be divided among 17-18 persons so that each of them only got a tiny piece. Often that was all they got for days. The woman witness 221/4-3 stated that for 42 days they had only received a slice of bread each and for three days after that they received nothing.

Some of the women inmates fell into a coma from the hunger, not having had any food or water for days. The witness 607/94 as well as many others fainted from starvation. Sometimes they would be given warm meals: soup, macaroni, rice, beans and similar - several spoonfuls a day. They all ate with four or five spoons, and there were 250 of them at the minimum. The food had often gone bad so that they developed digestive disorders. Several times they got a small tin of meat paste to be shared between 3 - 8 inmates or a tin of fish containing 99 grams. That too was divided between 6 inmates. An egg would be divided between 8 people. When their food was brought in, the pot would be placed next to the slop bucket into which the inmates defecated and there they hastily ate in groups of five.

There was not enough water either. The daily ration for 8 people was one litre. They were given water either every second day or every third or fourth day. Serbs from Bradina got less than the others.

Proof: Witness 260/94, 412/94-27, 234/95-12, 221/94-1, 221/4-6, 65/1-95, 236/94, 243/95-7, 630/1-9 4 and 274/95.

1.10.3.When some of the large group of people rounded up in Bradina were brought to the camp and asked for a drink of water, they had to drink waste water from the sewage. Many of them did.

Proof: Witness 243/95-4.

1.10.4. When rice or beans were given, each of them could only take three spoonfuls. Anyone who tried to take more would be whacked. Dj.M. once tried to take a fourth spoonful, and DELIĆ beat him up in front of everybody.

Proof: Witness 488/94-2.

1.10.6. From July 15-17 - for 56 hours - they were given no food at all. After that they were given a tin of meat paste and a thick slice of bread each and forced to eat it all quickly, so that most developed stomach troubles. Drinking water was limited, and often they were punished by being given no water at all. After one such occasion the witness 488/94-1 was constipated for 19 days, and some were constipated for as long as 45 days.

1.10.7. On July 15, 16, and 17, 1992 they were given no food at all and then when they ate all had stomach disorders and pains.

Proof: Witness 488/94-6.

1.10.8. When the group taken prisoner at Ljuta, led by RAJKO DJORDJIĆ, was imprisoned at the camp, they were given no food for two days. In fact, from May 30, when they were captured, they got no food. Then some food was brought and placed in front of the door. The camp inmates were afraid to take it, and when witness 488/94-5 went out to get it, the moment he appeared at the door a guard kicked him with his booted foot between the legs so hard that the witness fell down. He managed to get up and bring the food inside. There was only a slice of bread for every person, i.e. 16 of them had to share a 600-gram loaf.

They were given no food for 90 hours before the arrival of the IRC. Then they were given food so that all had stomach pains.

Until June 5, 1992 the food was meager, but they received it almost regularly. Afterwards the meals were scantier and reduced in number so that the inmates were starving.

They calculated that over the following four months every inmate received a total of three and a half 600-gram loaves of bread.

There was very little water and what there was of it was dirty so that of necessity they went thirsty.

1.10.9. For the first three days, no food was given. One loaf weighing between 600 and 700 grams would be shared by 14-18 camp inmates. That would be all for the whole day. Sometimes they would be given some broth which had gone sour and was unfit for human consumption. They would pour it into the mess kit lid so that five camp inmates had to eat simultaneously. No one could get more than a couple of spoonfuls. When one group finished eating they handed their spoons to the next group as there were only about 5 spoons for about 250 of them and they all had to use the same spoons.

After July 13, 1992, when a group of 9 Muslims was killed, for which they accused the Serbs, the regimen became even stricter. Because of that they were given even less food and water, and for the first three days after this had happened they got none of either. The daily ration of water for 10 inmates was one litre. They were all constipated, and the witness was constipated for 25 days. During the three days that followed July 13, they were not allowed to lie down at all either during the day or in the night.

On Orthodox - Serb holidays - St. Vitus’ Day, St. Peter’s Day and St. Elias’ Day - they would be given no food, not even a slice of bread for three days.

Proof: Witness 100/94.

1.10.10. As of June 15,1992 it was allowed for the inmates’ food, change of underwear, etc. to be brought to them. Thus one day the woman witness 221/4-2 brought her brother and other relatives some food and underwear. These were received by the guard MAŠIĆ, but neither her brother nor the others got it all. The guards kept the best things for themselves.

Proof: Witness 440/94-1.

1.11.1. Not even an elementary human standard of hygiene could be maintained at the camp. The treatment in this respect constituted a specific form of torture and erosion of humaneness and caused bodily and mental decay. It fit into the overall pattern of the treatment of detainees and the overall system designed in pursuit of the basic objective of destroying the Serb national being.

1.11.2. In hangar "No.6", the detainees relieved themselves in a bucket in the corner, which was not large, so that they as often as not did it on the concrete floor. In fact, they hardly needed to empty their bowels, as, e.g. the witness 243/95-4 was constipated for a full 48 days. There were some who were constipated for two months. Although that spot would be cleaned in the morning, it would as a rule remain filthy for there was no water or cleaning agents. During the day their food was brought to and served in that same spot.

They all ate using just five spoons, from a single bowl, and the dishes were never washed, so that almost all of them had dysentery or some other stomach disease.

During the day the inmates would be taken out to relieve themselves in a canal that had been dug by the younger inmates. They would be lined up in the hangar, and at DELIĆ’s command they had to run to the trench, urinate, rush back and take their place in the line. Anyone who failed to perform this within the short time allotted - 10 to 40 seconds according to the inmates’ estimates - would be punished. The guards would hit him with sticks and other objects, and DELIĆ would hit them with a baseball bat. On his first visit to the camp, IRC representative MICHEL watched this and measured the time.

Proof: Witness 243/95-12, 221/94-1, 221/4-7, 440/94-1, 488/94-1, 221/4-5, 274/95, 221/94-3/1, 243/95-7, 100/94 and 412/94-23.

1.11.3. The detainees relieved themselves in the hangar itself near the door. Their food was brought to that same spot. In the beginning they were allowed to urinate twice a day outside the hangar. After July 13, this was particularly insisted on. They would be lined up in groups of 50 in the hangar, and given the signal, they had to run out, urinate and run back to the hangar and to their assigned places. This had to be done in a matter of 40 seconds. DELIĆ took the time with a stopwatch, and, brandishing a baseball bat, hit all those who were late. Out of fear that DELIĆ would whack them or that they would not make it in time, many were unable to pass water. All this was seen by the delegate of the IRC, who was in the camp for the first time on August 12, 1992. Taking the time, he ascertained that the camp inmates had to perform this whole operation in a mere 40 seconds. The man was flabbergasted and rendered speechless.

Proof: Witness 100/94.

1.11.4. The witness 243/95-8 remembers that MICHEL from the IRC measured the time allotted for urination and established that 350 of them, divided into groups, had done it in three minutes.

1.11.5. When T.Dj. asked him to let him out to urinate, DELIĆ, laying down the law, lined all the camp inmates in the hangar in four columns of 20 men each and ordered every one of them to run to the canal, relieve themselves, and return to their places in 40 seconds. All the while the guards kept beating them. As for defecation, they all had to do it always in a bucket in the hangar, near the door. That is also where they were given their food. Every morning two camp inmates would take those buckets outside.

Proof: Witness 260/94.

1.11.6. As in tunnel "No.9", the inmates relieved themselves in its lower end, they suffocated in the stench, for, apart from a small iron grid above the door, there was no ventilation.

Proof: Witness 221/94-3, 630/1-94, and 65/1-95.

1.11.7. One could not wash at all, not even the face. Once a month only, on the average, would the inmates be sprayed with a hose.

Proof: Witness 488/94-6, 236/94, 100/94, 243/95-7, and 100/94.

1.11.8. The witness 488/94-5 did not wet his hands for two months, let alone wash himself, as there was no water to be had. Sometimes they were sprayed by hoses and returned drenching to the "tunnel" in which it was always cold. That was the only time when the ventilators would be turned on so as to cool them off even more, so that hopefully the inmates would fall ill.

1.11.9. They were unable to maintain any hygiene. At times all those in the hangar would shave with one or two blades. As they had to shave "dry", without any shaving foam, it was more of a flaying than of a shave.

Proof: Witness 488/94-1.

1.11.10. DELIĆ, a day before the arrival of the International Red Cross, brought a single razor and demanded that all the prisoners shave themselves in the morning without water and soap. That was very painful and difficult, because all of them had been unshaven long since.

Proof: Witness 221/4-5.

1.12.1. There were two Serb doctors in the camp, camp inmates Dr. G.P. and Dr. M.R. For a while the dentist Dr. Ž.M. was also there. As these doctors had to take care of a number of injured people (sick people were not entitled to any assistance), and as they had almost no medicines or medical supplies and equipment, the effects of their work were minimal. They were placed in the so-called "ward" or in "No.22". The camp inmates lay in beds, if any were available, and their food was slightly better.

1.12.2. Medical assistance was not extended. DELIĆ would beat up the inmates and then ask whether anyone wanted to see a doctor. No one dared report. When B.D., after his shinbones had been burnt, asked to see a doctor, he was not allowed to see one so that his wounds might be bandaged, and he was told: "You definitely are to die. You need no doctor".

Proof: Witness 100/94.

1.12.3. The witness 488/94-3, after a mass beating, on the occasion of the visit of an IRC representative, was in the "ward" for 8 days. Dr. M.R. ascertained that two of his ribs were broken and other injuries. Also present was the orderly B.G. They could help him only a little for they had nothing of the necessary means. The food there was better, and the patients had beds to lie on.

1.12.4. On arrival at the camp, the prisoners were beaten up and then taken to see a doctor and for a check-up. But, only those that had been beaten up the worst got their wounds dressed. The others were not bandaged, nor was the witness.

Proof: Witness 221/4-7.

1.12.5. The witness 221/4-6 stated that the doctors treated them to the best of their ability.

1.12.6. All of them had stomach disorders due to poor nutrition and inadequate food. These disorders were at times caused deliberately.

1.12.7. The witness 445/95-22, his brother and K.J. got scabies in the hangar and were cured only after they had been transferred to the sports hall at Musala in Konjic.

1.13.1. The camp inmates were occasionally forced to work. They unloaded humanitarian relief supplies from trucks (sacks with flour etc.), weapons, uniforms, footwear and similar. They had to chop wood, dig trenches and similar.

Proof: Witness 221/4-5 and 488/94-2.

1.13.2. For three days towards the end of July 1992 the inmates had to unload weapons and ammunition which had been shipped into the country aboard vessels. In the camp there was a depot for weapons and military equipment of the Muslim army.

Proof: Witness 283/94.

1.13.3. After a mass beating (around December 1,1992), 18 camp inmates lay crumpled down all beaten up. The next day, 20 inmates, among whom 15 of those who had been beaten up, had to unload 100 tons of flour in 50 kg. sacks from a lorry.

Proof: Witness 488/94-4.

1.13.4. The witness 488/94-5, emaciated and beaten up, was forced, like the others, to chop wood, load it, and perform other difficult physical work. They had to work between 12 and 17 hours a day. The witness was taken to the Secretariat of the Interior in Konjic to repair a TV set and other things. When one prisoner escaped, they ordered that prisoners be taken out for work no more. Therefore, only a group of about 20 camp inmates worked outside the camp as of then.

1.14.1.01. The invariable, most massive, the gravest and most deleterious form of torture was the beating up of Serb camp inmates every day.

They were beaten on whatever occasion. They would be beaten up individually, in groups or en masse. Every conceivable object would be used for this purpose: baseball bats, pieces of wooden planks - pronged rods (especially brought for that purpose from the "Drvorezbarstvo" (Timber Plant) in Konjic), hoe handles and the handles of other tools as well as various sticks. There were even custom-made metal sticks, and metal pipes, lengths of cable, rifle butts and other objects. The prisoners would be trampled underfoot, by men wearing heavy soldiers’ boots and pounded by fists.

Various reasons would be invoked to beat the prisoners: accusing individuals that they had done this or that, or because the prisoners would not give satisfactory answers to the questions they were asked or would not confess to the crimes they were being accused of, or even to take revenge on them because some Serb somewhere had done something they did not like or simply because the conduct of the inmates was not to their liking.

In respect of some there was a specific reason, while others were beaten just for being Serbs. In fact, that was the basic motive - the mover of all their actions. In some cases they sought to extract confessions for some accusations which they could not get because the accusations were sham. That only made them beat the inmates even more viciously.

The consequences of this were grave bodily injuries and a number of killings. The prisoners were beaten by all guards, by members of the Military Police, members of the army, as well as by civilians who came to the camp for that specific purpose or happened to be there. At times there was an "audience" watching all this.

In very few cases did the witnesses state that their torturers had been under the influence of alcohol.

1.14.1.0.2. We shall first describe the mass beatings and then the individual ones as well as the other significant elements of this form of destruction of members of the Serbian nation, to the extent this subject matter is at all possible to systematize.

Proof: Witness 488/94-1, 488/94-4, 488/94-6, and243/95-8.

Proof: Witness 412/94-23.

Proof: Witness 221/94-1.

Proof: Witness 147/95.

1.14.2.1.3. "ZENGA" was in the habit of going around the hangar and pricking the inmates in various parts of the body with a PAP rifle knife.

1.14.2.1.4. The witness thinks that DELIĆ nailed, with a small nail, a cockade to the forehead of a young man whose surname was probably D. That youth had worn a cockade before the war. He is still alive.

Proof: Witness 445/95-22.

1.14.2.1.5. The wife of the witness Dj.S. told the woman witness 221/4-3 that they had cut her husband’s ear off. The woman witness later saw him in the camp with one ear cut off. Other witnesses also confirm this. It seems that REDŽO BALIĆ did this.

Proof: Witness 380/94, 260/94 and 292/3-95.

1.14.2.2.1. One of the cruelest forms of torture was keeping the inmates in manholes for long periods which was practiced in various situations.

1.14.2.2.2. The following had been in manholes: RAJKO DJORDJIĆ, Ž.Ž., K.J., K.R., ŽELJKO MILOŠEVIĆ, before they killed him, M.B., M.D., M.R., M.V., M.R.,S.N. and many others. Many of them had been in manholes a number of times.

1.14.2.2.3. This form of torture was applied by : PAVO MUCIĆ, HAZIM DELIĆ, ESAD LANDŽO - “ZENGA”, the two brothers MACIĆ, OSMO DEDIĆ, “ŠEKI”, “RAMBO” and others.

1.14.2.2.4. Around June 0, 1992, after interrogation, all the camp inmates from "No.9" were divided into two groups. There were probably 17 inmates in the first and 18 in the second group. The first one, with RAJKO DJORDJIĆ, being beaten all the while, was packed into a concrete manhole. The opening of the manhole was some two meters above ground, it was 2-2.5 x 2-2.5 m. in length and width and its depth was approximately the same. Then they closed the lid of the manhole and blocked the ventilation openings. Due to the lack of oxygen some of the inmates soon started to suffocate and panic. They opened the manhole after 9 hours, dragged out RAJKO DJORDJIĆ, beat him up and brought him back. They threw some food into the manhole and shut it again. After another 3-4 hours had passed they opened the manhole again. All the inmates were unconscious. They dragged them out, beat them up, and, when they regained consciousness, lined them up.

Around them were guards with their rifles pointed at them. DELIĆ had ordered when they were being put in the manhole that that area be enclosed by wire and that machine guns be mounted, telling them that they would all be executed. Then PAVO MUCIĆ came who took out RAJKO DJORDJIĆ and another 6 inmates. He told them that they should not have done what they had done and that they would be executed because of that after the others who were in the manhole with them. Then a man drove up in a black “Golf” and told them not to do what they were planning to do. They beat up the prisoners and returned them to the “tunnel” and another group was packed into the manhole, which again included RAJKO DJORDJIĆ. After this group was taken out of the manhole they first ordered RAJKO DJORDJIĆ and M.D. to take their clothes off and then put them in a manhole with water. As the water level was above their heads they could not reach the bottom with their feet but had to stand on the iron steps. After that they put them out in the strong sun - "to sunbathe". After two or three days they took M.D. and M.R. to the manhole again and M.R. tried to commit suicide with a razor blade he had hidden.

Proof: Witness 488/94-5, 488/94-3, 221/4-5, 65/1-95, 412/94-23, 488/94-4 and 509/94-5

1.14.2.2.5. RAJKO DJORDJIĆ, a renowned figure in Konjic and the vicinity, one of the worst humiliated and tortured Serbs in the camp, described their ordeal in the manholes in this way: “After the interrogation which took place on June 10,1992, DELIĆ put me with a group of about 16 Serbs in a manhole around 3 metres deep and cca. 2.5 x 2.5 m. in size. They blocked the ventilation openings. We suffocated and some started to panic and they shouted and asked for the manhole to be opened. Thereby they only increased the consumption of oxygen so that we suffocated even more. The lid was removed only briefly only three times. When we came out, we were all stunned and some were unconscious. Afterwards we were all beaten up. I was beaten up by the guard "RAMBO", who hit me on the back, head and other parts of the body with a hoe handle. In front of the manhole the second group had been lined up. They put me at the head of that group and took back the rest to "No.9". Then the second group was put in the manhole in which I was again..."

"... I was shut in that same manhole with this second group that whole day, the whole night and the next day, when they carried us out. On this occasion, already dazed, I fainted, I was desperate and I wished I was dead. The ordeal and suffering I went through defy description. In order to make things easier for myself, probably instinctively, I took off all my clothes so that I was without any on when they took us out of the manhole. They beat us as we were being taken out and then they returned us to "No.9"..."

On June 12, after interrogation, DELIĆ put Djordjić in a manhole again, this time smaller than the first one had been and filled with water. He tried to stand on the metal rungs of the ladder, but a guard kept kicking him into the depth of the manhole. He tried to hold on to the steps but they kept pushing him into the water. Then they moved him to another manhole, into which they first threw M.D. and then Ž.Ž. and M.R. who was utterly dejected. He tried to slash his wrists but the witness prevented him and encouraged him. While the witness had been in the manhole with only M.D. the guards would remove the lid and urinate on them. "...I encouraged myself to withstand all this torture, I knew that they wanted to torture me to death and I was resolved to endure it all and survive". There he stayed for two nights and two days.

When on June 15,1992 they pulled them out of the manhole, PAVO MUCIĆ told them lined up by the manhole that the Serbs had shelled the sports hall at Musala killing 13 Serbs. Then they were returned to “No.9”. (There is every indication that this was done by the Muslims).

1.14.2.2.6.The witness 243/95-12 remembers that they were put in manholes on June 11,1992. There were a total of 17 inmates, including the witness, in the manhole. The ventilation openings were blocked so that they suffocated. Later they held him in a manhole again for three days. There he was with RAJKO DJORDJIĆ for two days. Then he was one day and one night with M.R. and still later with ŽELJKO MILOŠEVIĆ who was later killed.

1.14.2.2.7. A group of 63 Serbs from Brdjani, which was brought to the camp on June 15,1992, was put that same day, after their things were seized, into 6 manholes. The witness 440/94-1 was shut in one with another five men. In one of the manholes there were 18 men. The manholes had metal lids, secured with padlocks and the ventilation openings were deliberately blocked. The prisoners soon started to suffocate for lack of air. They kept them thus for two hours and then took everyone out except the group in which the witness was. They kept the group with the witness in the manhole for 24 hours. He fainted and when he came to he saw the guard “KRAVAR” pouring water on him. The guard was swearing at him cursing his Chetnik mother and asked him where his gusle (folk musical instrument), which the witness played, was. Then ZIJA LANDŽO called “ZENGA” hit him with a pickax handle on the left shin peeling off skin and injuring the bone so that the witness could not stand for two months. One of the present guards whacked him in the head, above the left ear, with a brick. In addition to the named, HAZIM DELIĆ also participated in everything. The witness 178/94 was brought the following day and put in a manhole together with the rest.

1.14.2.2.8. Immediately upon arrival, around June 15, the witness 147/95 and others were placed in manholes. With him there were a total of five inmates in a manhole 1.5 m x 1.5 m in size. The water was knee-deep. They kept him in this manhole for five hours. Some were kept inside longer. There were larger manholes also, in which they kept more people as well. From there they threw them into "No.6".

1.14.2.2.9. The witness 630/1-9 4 was shut in a manhole filled with water up to his throat, for hours.

1.14.2.2.10. As he was being pulled out of a manhole, somebody hit the witness 440/94-1 in the head with a brick.

1.14.2.3.1. A form of intimidation was "execution".

At night DELIĆ would take out five or six inmates and put them in front of a vehicle so that they had to look at the headlights which were on. He asked each one what his last wish was. People would say what their last wishes were. Then he would command the lined guards:"Load!" "Take aim!" "Fire!" The guards would shoot above the prisoners’ heads. This would be repeated sometimes.

"ZENGA" did similar things and took out and intimidated Dj.M. in this way.

1.14.2.3.2 The witness 260/94 vividly describes a similar case: "One night around 11 p.m. DELIĆ ordered 5 inmates outside, including myself. He ordered us to look at the burning headlights of the “Fiat 600” with which he had come. He lined up 6 guards with rifles in front of us and ordered them to charge their rifles. He asked each one of us what his last wish was. Some said that they would like to see their children, others said other things and I kept silent. DELIĆ put the barrel of his pistol to my forehead and again demanded that I tell him my last wish. As I still kept my silence he ordered the guards to shoot us. The guards fired above our heads. He again put the barrel of his gun to my temple and asked me: "Were you scared shitless?"

1.4.2.4.1. They would take the bullet out of the cartridge, place the barrel to the forehead and shoot. One never knew whether the cartridge was loaded or empty and one always got burnt by powder gases.

Proof: Witness 100/94, 86/1-95, 236/94 and 260/94.

1.14.2.5.1. They would take the inmates out, threaten to slaughter them, draw knives across their throats etc.

Proof: Witness 488/94-6.

1.14.2.5.2. One night they first took "T." outside, and then also the witness 221/4-5. He saw “T.” lying on the ground. “FOČAK” asked the witness: Why did you kill “T.”? The witness replied that he had not killed him. Then they made him kneel and put his hands to the ground. OSMAN DEDIĆ mounted him and drew the blunt edge of the knife blade across his throat while “FOČAK” thrust a rifle barrel into his mouth. After that they ordered him to call Dj.N. and Dj.M. and the two of them carried “T.” into the hangar and then they realized that he was all beaten up, but alive. In addition to these two, other guards also took part in everything. Although they had socks pulled over their faces, the witness could recognize them by their voices, gait, bodies etc.

1.14.2.5.3. The third witness, 488/94-5, describes a similar situation: "The first four nights after we had been shifted to "No.6" in mid-September, they started taking people out one by one and beating them up. They would take out me, Dj.M., Dj.Z., K.A. and K.R. This was done by the guards ZAJKO ČAMDŽIĆ, OSMAN DEDIĆ AND KEMAL MUDERIZOVIĆ. On the fourth night I saw that I.D. was lying in a pool of some liquid and I thought that he had been slaughtered. I told the guards KEMO and OSMAN to end his misery and kill him. They pointed their bayonets at his throat, threatening to slit it. Then they forced him to lie down and pretend that he was dead. Then they took out K.A. and K.R. and threatened them also with slaughter. They demanded that I and I.D. beat them. We would not. When they were returning us to the hangar, ČAMDŽIĆ poked me in the ribs with a gun barrel so fiercely that I could not stand for the next 20 days.”

1.14.2.6.1. All the camp inmates would be lined up by the canal and had to urinate. After that they would single out one of them and force him to drink urine. There were other situations also in which they did the same thing.

Proof: Witness 221/4-5 and 234/95-12.

1.14.2.7.1. The speciality of ESAD LANDŽO, called “ZENGA” was to tie a “cord” on the camp inmates, as a slow-burning fuse is called in those parts. He tortured in that way M.V. and V.R., tying the “cord” around their waists, between the legs and around the genitals and putting one end in their anuses. Then he would have them put on their trousers and he would set the other, outside end of the fuse on fire.

The wretched people whom he tormented in this way ran around screaming in excruciating pain. They would be burned badly and sometimes the flesh would be scorched. The wound healed slowly. Ex camp-inmates who have been tortured in this way still bear the scars. "ZENGA" did this in front of the other inmates, and some of them he took out. He would even beat some of them up after this. He tortured in this way Dj.Ve., Dj.V., B.D., SLAVKO ŠUŠIĆ before he was killed, and others.

Proof: Witness 243/95-8, 260/94, 488/94-2, 412/94-15, 243/95-7, 380/94, 221/4-5, 221/94-1, 688/94-7, 147/95, 243/95-4, 86/1-95, 100/94 and 454/95-19.

1.14.2.7.2. The witness 688/94-7 said: "...the pain was so horrendous that even now I shudder when I remember the howls of those unfortunate chaps to whom he did this...."

1.14.2.7.3. The witness 630/1-9 4 said that apart from tying burning fuses around the body, they would also apply glue on the inmate’s body and then pour gunpowder on it and set it alight.

1.14.2.7.4. They stuffed gunpowder up the anus of the witness 234/95-12 and then set it on fire.

1.14.2.8.1. "ZENGA" would pour gasoline on the trousers of B.D. and then set it on fire. The trousers went up in flames and he was extensively and badly burned. B.D. had such burns that his shinbones were exposed to view. D.N., B.M., M.S, S. from Cerići and some others were burned in the same way.

Proof: Witness 100/94, 243/95-4, 147/95, 488/94-1, 221/4-6, 688/94-7, 243/95-8, 221/94-1, 260/94, 274/95, 283/94, and 454/95-19.

1.14.2.8.2. "ZENGA" poured gasoline on people, forced them to drink gasoline and burned them setting fire to their mouths, arms, legs and other parts of the body. He tortured Dj.M., M.V. and B.D. in this way.

Proof: Witness 412/94-23.

1.14.2.8.3. The witness 412/94-15 stated that "ZENGA" took him outside, poured gasoline on his shins and set them on fire. The scars on his right leg are still visible.

1.14.2.9.1. ESAD LANDŽO, called “ZENGA” seared with a red-hot knife the tongue and ears of Dj.M. and inserted red-hot tweezers into his ears, and forced K.M. to hold a red-hot knife in his hands and he was badly burnt. Then he had him take off his trousers and burnt him on other parts of the body also. He would heat up a knife or tweezers on a hot plate or above an open gasoline flame, which he would pour out and set to fire himself, and sometimes he heat them up over a fire built by the guards. They would heat up cables and force the inmates to hold them in their hands. They burnt the soles of their feet.

Proof: Witness 86/1-95, 243/95-4, 488/94-1, 234/95-11, 488/94-7, 221/94-1, 260/94, 221/4-6, 100/94, 274/95 and 283/94.

1.14.2.9.2. The witness 243/95-8 says that one day in July 1992, "ZENGA" poured gasoline on the floor of the hangar and set it on fire. Over it he heated a tweezers until it was red-hot and seared with it the witness’ tongue, lips, nose and both ears. He pushed the red-hot tweezers inside his ears and pierced the left eardrum. The witness has been hard of hearing since. Before this he burnt K.M. on the arms and D.N. on the legs with a red-hot bayonet.

1.14.2.9.3. With a red-hot knife "ZENGA" burnt the insides of both forearms and the shins of the witness 221/94-3/1.

1.14.2.9.4. They would heat large scissors red-hot and then squeeze the inmates around the neck with it. The witness 380/94 saw that G.M., who had also been in a manhole, had injuries of precisely that kind.

1.14.2.9.5. "ZENGA" seared parts of the body of B.D. with a red- hot bayonet.

Proof: Witness 243/95-7.

1.14.2.10.1. HAZIM DELIĆ used a device serving to drive cattle on board lorries to administer electric shocks to the inmates. They suffered horrendously. He did this repeatedly to the witness 221/4-5 and to others. The witness 100/94 saw when he tortured the former policeman D. in this way.

Proof: Witness 65/1-95 and 509/94-5.

1.14.2.11.1. They would put gas masks on the inmates’ faces and seal off the air intake so that they choked and fainted within minutes.

Proof: Witness 100/94.

1.14.2.11.2. "ZENGA" took the witness 488/94-1 and an inmate with the surname G. outside the hangar. He put gas masks on their faces, screwed them on tight and gagged the filter. He pushed the witness into the hangar and ordered him not to take off the gas mask until he called him. The witness somehow managed to move the facepiece and get some air. "ZENGA" took the gas mask off his face after five minutes.

1.14.2.11.3. On one occasion, in front of everybody in the hangar, DELIĆ and “ZENGA” put a gas mask on the face of the witness 412/94-15 and beat him. The witness believes that he fainted after around three hours. He was revived by T.D. who found some water and poured it on him.

1.14.3.1. They forced the inmates to do push-ups, although all the prisoners were in very poor condition. Whoever was unable to do push-ups would be kicked with pointed boots in the stomach, the chest, head and other parts of the body. The inmates would faint from the blows. Then "ZENGA", who took the lead in this, would order such inmates to spread their legs far apart and he would hit them in the testicles. In the process he cursed their Chetnik mothers and threatened to fix them up so that none of them would be able to have children.

Proof: Witness 260/94, 100/94, 147/95 and 221/4-6.

1.14.3.2. The Serbs in the camp would often be forced to sing Muslim songs for hours on end. Anyone who refused would be beaten up.

Proof: Witness 412/94-23, 221/4-6, 221/4-3, 243/95-7, 243/95-12 and 221/4-5.

1.14.3.3. Sometimes they would take all the inmates outside, order them to strip to the waist, sit down on the concrete in the scorching heat and, repeating aloud after one of the guards, chant Muslim prayers in the Arabic language, "Allah ekber" and others. They had to say prayers on other occasions also. It went on for hours and was a frequent practice.

Proof: Witness 147/95, 243/95-7, 488/94-7, 234/95-12 and 221/4-5.

1.14.3.4. The camp inmates would be lined up facing one another and then forced to hit each other with all their might. Anyone failing to hit hard enough would be beaten by the guards.

Proof: Witness 221/4-5.

1.14.3.5. "ZENGA" would force a brother to beat a brother or a father his son. He would force brothers to slap each other in the face.

Proof: Witness 147/95, 86/1-95, 488/94-7 and 412/94-23.

1.14.3.6. HAZIM DELIĆ would get M.V. and M. Ž. forcibly drunk and make them imitate a car. Around them stood the guards, some civilians and some girls whom they brought in to watch the “show”. They laughed and beat the two inmates. This happened often to M.V. He would be forced to down a litre of cognac or brandy in a very short time and then to “drive” following DELIĆ’s commands: change gears, apply the brakes, step on the gas, imitate the sound of the engine, etc. The inmates from “No.9” also attended this. The organizers were ZDRAVKO MUCIĆ and HAZIM DELIĆ. MUCIĆ filmed the “show” with a video camera.

Proof: Witness 243/95-8, 412/94-23, 221/4-6, 221/4-5, and 236/94.

1.14.3.7. The witness 221/94-3/1 testified that DELIĆ forced him to drink a litre of brandy in one minute and fifteen seconds and then he made him imitate a car driving around. The witness had to run around the compound, around the freight scale and to pretend he was holding the steering wheel, changing gears and to imitate the sound of the engine. There were guards standing around who would hit him whenever he passed by them. They entertained themselves in this way every day and M.V. always "took part" in it, whom they only got drunken twice. Civilians also came to watch these "shows".

1.14.3.8. HAZIM DELIĆ forced M. to strip naked and to go around the hangar in that state and sing (epic) folk songs sung to the gusle (folk instrument) as he was a singer accompanying himself with this instrument.

Proof: Witness 488/94-5 and 221/4-6.

1.14.3.9. The witness 688/94-7 says that "ZENGA" forced them to graze grass and to eat sheep dung.

1.14.3.11. The witness 412/94-15 was also forced to graze grass and to swallow it.

1.14.3.12. One day "ZENGA" took out the witness 221/4-6 twice and beat him up. He forced him to graze on that occasion, seeing to that that the witness indeed swallowed the grass. This humiliated the witness immensely and was harder to take than the beating.

1.14.3.13. DELIĆ and “ZENGA” forced M.V. to drink urine and to graze grass.

Proof: Witness 243/95-8 and 488/94-7.

1.14.3.14. The witness 380/94, a doctor, was not beaten, but JASMIN GUSKA maltreated him by forcing him to stand facing the wall or to sit on the floor for hours. Once he broke the witness’ glasses. They would line up the inmates at night and deliver lectures to them telling them how the Serbs must move out of Bosnia and Herzegovina. In the process they threatened them, swore at them, etc.

1.14.3.15. The inmates would be tied bells around their necks, like sheep. Then they had to run so that the sound was heard as of cowbells clanging.

Proof: Witness 234/95-12.

1.14.3.16. They would often push a hose up some inmate’s mouth and then turn pressurized water on.

Proof: Witness 380/94.

1.14.3.17. When some of the inmates asked for a drink of water, they forced them to stand in front of a faucet that was turned off and to request the water to come out. This they had to do for hours.

They demanded from some to curry favour with a tree - a fir three which grew in the yard.

Proof: Witness 221/4-5.

1.14.3.18. As they put ground glass in the inmates’ soup, all had stomach pains and dysentery.

Proof: Witness 607/94.

1.14.3.19. HAZIM DELIĆ repeatedly fired an automatic rifle in the hangar shooting up in the air in order to frighten the inmates. Fragments of the ceiling fell and injured some of the inmates.

Proof: Witness 243/95-7.

1.14.3.20. "ZENGA" brought a dog into the hangar a number of times and set him on the inmates, frightening them.

Proof: Witness 243/95-7.

1.14.3.21. The inmates were insulted, sworn at and humiliated in various ways every day. They would have to sit in a specified spot and were not allowed to move. This would last for hours and days and was extremely distressful.

Proof: Witness 243/95-7.

1.14.3.22. The woman witness 412/94-27 saw men being taken out in front of the hangar, stripped naked, hosed with a water hose and beaten up and then taken back all wet.

1.14.3.23. The woman witness 221/4-3, who was in the gate post, also speaks about this type of torture. She stated that on a number of occasions she had seen them take out the inmates, force them to run around in circles and imitate cars. While they were doing this, they would be beaten. DELIĆ commanded them how to “drive”. She remembered that they had done this many times with M.V. DELIĆ forced him to sing as if accompanied by gusle (folk instrument) and to praise him. She saw inmates being taken out of “No.9” and how they stood in the rain for hours and were then returned to the "tunnel". She also saw how the inmates had to urinate in a matter of seconds.

1.14.4.1. ESAD LANDŽO, called “ZENGA” forced many times the brothers Dj. to do “blow jobs” to one another or “suck off" each others’ penises as witnesses say. While they did this he would beat them. The two of them were so wasted and beaten up that their minds were completely altered. The arm of one of them had been broken also. They first confessed to having taken part in the killing of Moslems and later were beaten up for lying. Their parents were slaughtered in the village Z.

Proof: Witness 488/94-1, 147/95, 274/95, 86/1-95, 100/94, 221/94- 3/1, 243/95-8, 412/94-23, 260/94, 243/95-7 and 283/94.

1.14.4.2. Here is what the witness 488/94-5, a relative of theirs, says about the fate of these two. They were mentally retarded. They were brought to the camp on July 13 and accused of having taken part in the killing of 9 Muslims, who fell into an ambush and were killed. They were subjected to horrendous torture. As a consequence of beating their arms were broken and their teeth were knocked out. "ZENGA" poured gasoline on their legs and set it on fire, tied the "cord" around their bodies and set it alight. He forced them to oral sex with one another. Under torture they confessed to having participated in the killing of those Muslims and that afterwards they had been in hiding with a woman relation of the witness. On the basis of their "confession" the mother of the witness R.S. and Dj.S., husband and wife, and the parents were brought to the camp.

After leaving the camp, SOFIJA, JELENKO and ANDJA DJORDJIĆ were killed and also MARA DJORDJIĆ who had not been in the camp. They were all over 50 years of age. Their house was set on fire and R. managed to get out of the burning house and save herself.

1.14.4.3. Z., a technician from Bradina was forced to sexual perversions with his brother.

Proof: Witness 380/94.

Proof: Witness 221/4-7.

1. SLOBODAN BABIĆ. He was in a coma. He had a gaping wound in his palate from a rifle barrel which penetrated into the brain. He died on the fourth day after his arrival in the presence of the witness 380/94, in the "hospital for Chetniks" at the "3.mart" elementary school in Konjic.

2. V. R. had fractures of both forearms and an injured spine.

3. G.M. was hit in the leg by a firearm projectile while being transported by truck to the camp.

4. G.S. from Podorašac. Due to an eye injury which he sustained during a beating up, he lost the eye. His forearm was also fractured.

5. Dj.M.’s ears and tongue were are burnt having been seared with a red-hot knife.

6. They cut off one ear of Dj.S. while he was in the camp.

7. Ž.R. from Bradina was hit in the arms by a firearm projectile while being transported by truck to the camp.

9. K.Dj. was hit in the eye by a firearm projectile while being transported by truck to the camp and lost the eye.

11. M.M. had a hip fracture.

12. The witness 274/95 sustained injuries during beatings and three of his right ribs were broken.

13. The witness 65/1-95 has four broken ribs.

14. The witness 100/94 had several ribs broken on the first night upon arrival and beating, a cut in the head from a rifle and his nose was broken by a fist punch and is still deformed. He was hit especially hard in the back of the head and fainted many times on account of that. When he would regain consciousness they would order him to get up and then they beat him again. He had severe pains in the back of the head because of that for a long time. When he came to the camp he weighed 80 kilograms. He lost 20 kilograms in the camp.

15. The witness 221/4-5 has traces of stabs in the left shin and fractures of a number of ribs. The X-ray shows that they have mended irregularly. His shoulders are dislocated. The internal organs in the stomach are also damaged as well as his kidneys and lungs. From the large number of blows to his head he has a constant headache and his memory is failing him. He also suffers from a series of mental disorders; he is often flooded with fear, so that despite medical treatment, he has nightmares. He has lost 46 kilograms. Due to exhaustion he contracted tuberculosis and was treated for a very long time.

16. The witness 221/4-6 has fractured ribs on the left side, which have healed irregularly which is clearly visible and palpable. His cheekbone is broken, which is also plainly perceptible. He has mental disorders. He has not seen a doctor.

17. The witness 221/4-7 received many blows when he ran the gauntlet after they had been brought to the camp and he had numerous bruises on his body and chest and a still visible cut on the head, under his hair, at the level of the top of the earlobe.

18. The witness 221/94-1 had three fractured ribs on the right and two on the left side, scars from bayonet cuts in the head and a hernia which developed because of the blows he had received in the genitals. This was found by Dr. P.G. when he examined him in the camp.

19. The witness 221/94-3/1 has scars from injuries inflicted by burning with a red-hot knife on both forearms, especially on the left, and on both lower legs.

20. The witness 234/95-12 has the following injuries: burns from the burning of powder in his anus, all ribs on the left side fractured, broken bones on the outer side of the right arm, fractured sternum, injured spine, etc.

21. The witness 236/94 has the following injuries: 1. fractured bone of the left lower leg with severely damaged tissue on account of sepsis; 2. ruptured right upper arm muscle; fractured bones of the right arm above the wrist; fractures of the 5^th and 7^th ribs on the left side; 5. damaged fifth lumbar vertebra; 6. injured fingers and hands, and hematomata all over the body; and 7; severe mental disorders. He has medical documentation.

22. The witness 243/95-12 has fractured ribs and a fractured jaw.

23. The witness 243/95-4 was constipated for 48 days and there were some who had been constipated for as long as two months.

24. The witness 243/95-8 had his eardrum pierced by red-hot tweezers. He has burns on the tongue, lips and nose. One of his ribs is fractured and he has sustained numerous other injuries as well and his health has generally deteriorated. After a beating, around June 10, 1992, when he received over 200 blows with a baseball bat, the witness could not get up on his feet for 20 days. The witness is 184 centimeters tall. When he left the camp he weighed 45 kilograms. He had lost about 35 kilograms.

25. The witness 412/94-15 has visible scars on his lower legs from gasoline burns.

26. The witness 440/94-1 has skin peeled off and the bone of his lower left leg injured. The scars were visible also at the time when the witness was giving his testimony. He had been hit with a brick above the left ear.

27. The witness 488/94-2 has fractures of the right shoulder bones.

28. The witness 488/94-5. Still has a bump on his head which developed after he had been thrown down the stairs and hit his head against the metal threshold of "No.9". Two or three of his ribs were broken, his liver was ruptured, other internal organs injured and he had a swelling on the chest which receded only

after two months.

29. The witness 509/94-5 had testicle injuries from the blows and had to have surgery. He also sustained injuries to the left eye, the blood vessels burst from the beating and he no longer can see with the left eye. He also has scars from bayonet stabs in the left knee and back and his left arm is paralyzed.

31. The witness 607/94 weighed 95 kg. and went down to 45-50 kilograms.

32. The witness 630/1-94 entered the camp weighing 97 and returned with 72 kilograms. Three fractured ribs and other injuries were established and confirmed with medical documentation.

33. The woman witness 221/4-3 has mental alterations and she lost 35 kilograms on account of starvation and torture.

1.16.01. Eighteen killings are said to have been committed in this camp. Here are described 17 killings, of which one, most probably is not a case of killing (ČEDO AVRAMOVIĆ), and another one probably did not take place in this camp (ILIJA MRKAJIĆ). The killing of PERKO MRKAJIĆ is being reported, whereas in fact it was PETAR MRKAJIĆ, who was killed in the sports hall at Musala. As some include disappearances in killings, the number of crimes is about 18.

1.16.02. In the majority of cases it is not known what became of the bodies of the victims.

1.16.03. The following were killed:

Proof: Witness 412/94-15, 100/94, 236/94, 221/94-1 and 380/94.

1.16.9.1. PERO MRKAJIĆ, father Djordje, born in 1928 in Bradina, owner of the restaurant “Žare” from Bradina. Wife D. and sons Ž. and D. He was captured on Mt. Bjelašnica. He was beaten up at the hotel on Mt. Igman. In the camp itself he would be taken out of the hangar and beaten. He was beaten by KEMO, “ZENGA”, MIRALEM MACANOVIĆ called “MACA” and a Shqipetar. “ZENGA” beat him in front of everybody at the place where he was sitting. He suffered excruciating pain. He just lay there for about 10-15 days and then they transferred him to the ward, in which he died. He received no medical treatment. As one of the witnesses remembers, he died around July 17, 1992. According to the statement of another, his body may have been thrown into the lake near Čelebići.

Proof: Witness 221/4-6, 236/94, 488/94-7, 221/94-1, 221/94-3/1, 380/94, 260/94, 100/94, 243/95-4, 274/95, 234/95-11, 454/95, 283/94.

1.16.9.2. One of the witnesses thinks that his name was PETKO. There is also a PETAR MRKAJIĆ, sometimes referred to as PERKO, father Djoka, born in 1941. He was beaten up running the gauntlet when a group was brought to the sports hall at Musala. This is remarked to avoid any confusion.

Proof: Witness 236/94.

Proof: Witness 221/4-5, 488/94-5, 380/94, 4881/94-4 and 100/94.

1.16.14.1. BOŠKO SAMOUKOVIĆ, father Nedeljko, born in 1933 in Bradina, retired railway worker from Bradina. Wife G. and children G., M. and N.

1.16.15.1. ŠĆEPAN, ŠĆEPO, MRKAJIĆ, father Risto, born in 1930 in Bradina, retired road maintenance worker from Bradina. Wife K. and a daughter.

Proof: Witness 260/94, 100/94 and 221/4-6.

1.16.16.1. ILIJA MRKAJIĆ, father Mirko, born in 1933 in Bradina. Wife ZORA, children B. and B. Retired railway worker from Bradina, had a heart condition and diabetes, had a brain stroke.

Proof: Witness 100/94 and 380/94.

He was maltreated and the witness 380/94 claims that he was beaten. He was in grave mental crisis. Some believe that he died out of fear that he would be beaten and tortured because he was a YPA reserve corps captain. Others think that he died of a heart condition, because Dr. M.R. examined him and said that that had been the cause of death.

Proof: Witness 243/95-8, 100/94, 221/94-3/1 and 283/94.

1.16.17.2. The witness 243/95-4 noticed that he was terrified and lost. He was put next to the witness. The witness tried to comfort him. In the morning, when the witness woke up, he saw that one of the cables which hung below the ceiling had been ripped off and that ČEDO was lying on the floor. He was naked to the waist and there was a black stain in the area of his heart. The witness does not know what ČEDO died of. The guards blamed his death on the inmates.

1.16.17.3. According to the accounts of some witnesses, in particular the witness 243/95-4, it could have been an electric shock. Most probably he was not killed directly. For the time being the exact cause of death cannot be established, but it is certain that his stay at the camp and his and his fellow inmates’ treatment there contributed to it.

1.17.0. It has been established on the basis of the statements of witnesses that some camp inmates disappeared, and the assumption is that they were, most probably, killed.

1.17.1.-2. ZDRAVKO GLIGOREVIĆ, nicknamed “BRACA”, father Jelenko, born in 1951 in Bradina, Faculty of Law baccalaureate, lived and worked in Sarajevo. Wife N. and son N.

He came to the camp to visit his father, who was in "No.6", and they held him there. Because of his beard, which he had always had, he was proclaimed a dangerous Chetnik in front of everybody. They beat him up, accusing him that he had come to the camp to organize a struggle against the Muslims. They beat him incessantly for two days. Some special unit members from Sarajevo came to the camp on May 28,1992 and beat ZDRAVKO as well as MILOŠ HRNJEZ, born in 1936 in Gacko, resident of Ilidža. MILOŠ HRNJEZ had likewise been imprisoned when he came to visit someone in the camp. Then both of them were taken away from the camp. The inmates heard that they had been killed on Mt. Igman or at the sports grounds at Hrasnica in Sarajevo.

Proof: Witness 236/94, 243/95-4 and 260/94.

1.18.0. As data regarding the manner, time and place of their arrest have been previously given and the general conditions in the camp previously described, they are not repeated here. Only some specific instances in respect of women at the camp are given.

1.19.1. When the representatives of the International Red Cross came to the camp for the first time, they stayed for two days - between August 12 and 14, 1992. Afterwards they came on another two occasions. The team comprised: MICHEL from Sion, a Swiss, blond, bespectacled; another person, whose name may have been MARK or NIKOLA; and two women - translators, the name of one was ALEKSANDRA NIKŠIĆ. When they entered the “tunnel No.9”, one of the women fainted from the stench and the oppressive air. On the first day the inmates told what was happening, described individual killings, etc. The following day they kept silent, for they had been beaten up and forbidden to speak, and they only waved their heads. However, IRC representatives could plainly see what state they were in and what had happened to them. MICHEL measured the time allotted for their urination and he was appalled. When they took the temperature in the rooms, the reading in the hangar was 60 degrees Centigrade. They took their names and distributed identity cards the following day. After their visit, there were no more killings of inmates, and the witness 221/4-5 believes that after that their situation improved somewhat.

Proof: Witness 243/95-4, 488/94-1, 488/94-5, 488/94-6 , 274/95

and 260/94.

1.19.2. DELIĆ tried to hide the women, but did not succeed so that the ICR representatives registered them too and issued them identity cards on August 12. They told the ICR how they were being treated and what they had to go through. Ten days later the ICR visited them again and were surprised that nothing had changed.

Proof: Witness 221/4-2 and 221/4-3.

1.20.1. A TV crew from an Arab country, at least that is what the inmates concluded on the basis of their language and appearance, visited the camp. They filmed in front of the entrance to tunnel "No.9". According to the witness 100/94, DELIĆ first appeared in front of the cameras and said: “A good Serb is only a dead Serb, and three meters under the ground at that”. Then he would put an inmate in front of the cameras, stand behind him and order him what to say. This was done with ŽELJKO MILOŠEVIĆ from the village of Ovčari, who was later killed. DELIĆ ordered him to say that he had raped Muslim women. Since he would not comply, DELIĆ immediately pushed him back among the others. He demanded that the inmates say that they had raped Muslim women, set fire to Muslim houses, forced Muslims to rape their own daughters, etc.

M.B. said in front of the cameras that the Muslims had attacked Bradina, so he got a beating in front of the TV crew. G.D. had to say that he was a volunteer Chetnik, that he had destroyed Mostar, killed Muslim men, raped Muslim women, to admit to being a criminal and to say that he repented. G.R, M.S. and G.R. had to make similar statements. The inmates were also beaten by members of the TV crew, and all that was filmed.

After the filming DELIĆ kicked the inmates and hit them with nightsticks in the hangar. Then they had to clean the compound and finally they were forced to take off their clothes and “ZENGA” doused them with a strong jet of water from a fire hose.

Proof: Witness 221/4-5, 488/94-5, 488/94-1,260/94, 488/94-3, 147/95, 100/94 and 509/94-5.

1.20.2. The witness 221/94-3/1 describes how he was taken in front of the cameras: “...”FOČAK” led me out of “No.6” and started interrogating me in front of everyone, demanding that I tell him where my weapons were. I replied that I had none. Then “FOČAK” said that he would beat me every day and cut piece after piece of my flesh off until I told him. Then I said that I would not tell him if I had thousands of weapons. This made him mad and he forced me to do push-ups while the TV crew counted and filmed all that. He was beating me all the while. He tried to force me to say in front of the cameras that Chetniks had slaughtered Muslims, and I would not because it is not true. He also wanted me to say that I had thrown grenades on mosques and raped Muslim women, and I would not because I had not done that".

1.21.1. In connection with releases from the camp, the female witness 221/4-2 says that PAVO MUCIĆ released the women from the village of Bradina and took them to the village. They had to remain there. DŽAJIĆ called “DŽAJA” drove them. On their release the decisions were signed by PAVO MUCIĆ, GORAN LOKAS, the investigating judge and ŠEFIK DELALIĆ. It said in the decisions that they had been arrested because they were aggressors and had collaborated with the Chetniks. The place of their forced detention was also stated in the decisions.

Proof: Witness 412/94-27 and 412/94-22.

1.21.2. The female witness 221/4-3 was held hostage because they were searching for her husband and son "because they had already been marked for being killed". They were issued their decisions by PAVO MUCIĆ who then drove them home.

1.22.1. During his forced stay in Konjic, after being released from the camp, the witness 292/3-95 was told by Dr. ZIJO RAMIĆ that the Command of the Muslim Army had decided that only 1% of the total number of arrested Serbs could be released from the camp, "and that all the others had to be imprisoned". (Probably a typing error. Perhaps the others had to be killed, eliminated or similar. This makes no sense, but attests to readiness to destroy the Serbs).

1.22.2. It seems that there was a rift between the Croats and the Muslims at the beginning of June 1992, because after that time no more Croats appeared in the camp, says a witness. (In fact ZDRAVKO MUCIĆ remained the commander. There were also some Croat guards but the camp seems to have been in the competence and under the command of Muslims).

At that time an Ustasha between 35 and 40 years of age, almost 2 meters tall, of athletic build, with black curly shoulder length hair was brought among the inmates. He was dressed in black, with a black hat with a large letter "U"on his head. He also had two pistols, a knife, a nightstick and handcuffs on his belt. He promised medical aid to the inmates and also promised that they would all be exchanged for his brethren from Kupres. That however, did not come to pass, which supports views on a split between the Muslims and the Croats.

Proof: Witness 221/94-3/1.

1.22.3. Since the main arsenal was located in the camp, at the end of July 1992 the inmates unloaded weapons and ammunition, which had arrived by ship, for three days.The witness 283/94 states that ALIJA IZETBEGOVIĆ was in the camp at that time, but they did not see him. The witness does not reveal the source of this information.

1.22.4. On December 1, 1992, after the inmates were massively beaten, DELIĆ was arrested. OSMAN DEDIĆ and “ZENGA” were arrested the following day, because they had been strangling a Muslim by the nickname of HODŽA”, who would not join the army.

Proof: Witness 488/94-6.

1.22.5. The III Report of the USA Government of November 10,1992 also mentions the camp at Čelebići. It contains the statement of an inmate of this camp according to which the “prisoners” in the camp, mainly younger men, are beaten with the wooden handles of agricultural implements or metal sticks. He states that he witnessed 15 or 16 Serbs being so brutally beaten that they succumbed. The witness was able to identify the camp commander and the cruelest guards".

2.1. Somewhere around June 1, 1992, a Commission including Dr. RUSMIR HADŽIHUSEINOVIĆ, a specialist of urology, president of the Muslim commune of Konjic and Dr. AHMED JUSUFBEGOVIĆ examined the inmates at Čelebići. They separated those with the gravest injuries from tunnel “9” and transferred them, together with Dr. G.P., Dr. M.R. and the dentist Dr. Ž.M. to the “3.mart” elementary school in Konjic, to the “hospital for Chetniks” as they called it.

They were put into a classroom into which 12 beds had been brought. Between June 10 and 12 of the same year, the doctors and 10 injured men were returned to Čelebići. All of them were accommodated at the “dispensary” - a fire fighting storehouse, called “No.22”. They lay on beds brought from the school.

Forty-six gravely injured Serb inmates passed through this "hospital". At times it held as many as 39 inmates so that several had to share the same bed or sleep on the floor.

They got almost no food. The doctors extended what aid they could. They immobilized broken bones with what they had at hand.

The guards did not beat them, but they did maltreat, curse and insult them. They would have to stand at attention for a whole hour, including the wounded. The "hospital" was visited by Muslim soldiers, civilians and girls from high school who, according to the witness 86/1-95, insulted them, the girls spat on them, they called them Chetniks and told them it served them right.

Proof: Witness 380/94, 86/1-95, 234/95-3 and 235/94.

2.2. The Serbs who were at this "hospital"

3.1. The list of perpetrators of criminal acts in the camp and the description of the crimes they committed has been made, exclusively on the basis of the testimonies of inmates. The identification data are based on the criminal charges of the Center of Public Security of Trebinje from the cases of the Basic Court in Nevesinje, which has been indicated (KP Nevesinje). In cases of discrepancies between the data an attempt was made to establish the exact identity, if possible, or the discrepancy has been indicated.

3.2. The perpetrators of these criminal acts are Muslims and Croats, almost on the whole, from the territory of the commune of Konjic. A small number come from other areas. Previous criminal activity could not be established as there is no access to appropriate records. Most of them, in all likelihood did not previously have police records. Among the perpetrators the cruelest were "inveterate" Muslim nationalists.

3.3. They are of different ages (from young men under 20 years of age to middle aged people), of different educational qualifications and social backgrounds. They include doctors and other highly educated professionals, and women.

3.4. The perpetrators of criminal acts were the neighbours of their victims. Most of them knew each other from before, and in a number of cases they had had very good relationships, as neighbours or colleagues at work.

3.5. Data on the witnesses (under Committee numbers) proving the described acts are given in the text or at the end.

3.6. Only those criminal acts committed in the camp are described here. This was the main "field of operations" of most of the perpetrators, but there are those who committed grave crimes elsewhere, even so grave as to render the ones committed in the camp almost insignificant in comparison.

3.7. ALPHABETICAL LIST OF THE PERPETRATORS:

Proof: Witness 147/95 and 488/94-7.

Proof: Witness 488/94-5, 100/94 and 85/95.

Proof: Witness 283/94.

Proof: Witness 243/95-4, 260/94 .