The International Criminal Tribunal tor the fonner Yugoslavia
Case Prosecutor v. Gotovina et al., IT-060-90
Trans cri pts
Witness: General Andrew Brook Leslie
(Chief of Staff of the UNCRO Sector South)
22 April 2008
Pagel929
WITNESS: ANDREW LESLIE
~~=-===~dHE~...w.I='!c-~ThOESS· 1 solemnl;y, swearthatl will speak tbetruth, tj1e whole truth and D<:)thing
but the truth.
JUDGE ORlE: Thank you. Please proceed.
[ ... ]
Page 1930
Examination by Mr. Tieger:
Question: Sir, can we begin simply by having you state your name for the record, please.
Answer: My name is Andrew Brook Leslie.
Q. And what is your current profession and position?
A. lam a professional soldier in the Canadian Armed Forces. My cuiTent position is the
Chief of Land Staff or the Commander of Canada's Army.
Q. And your cutTent ranlc?
A. l'rn a Lieutenant-General.
[ ... ]
Page 1937
[ ... ]
Question: Let me ask you quickly about the demographies of the town. Had the size of
the population of Knin changed in the period sbortly preceding Operation Storm?
Answer: When I first arrived in Knin in March, and tbese are only estimates and not
meant to sound as ifthey're definitive numbers, but the population ofKnin was probably
somewhere in the order of20.000 to 25.000. As tensions mounted, and it became fairly
obvious that imminent hostilities were looming. the population ofKnin bad swollen to
somewhere around 35.000 in the days immediately preceding the events of the 4th
and 5th of August.
Q. Who -- where bad the people who had increased the size of Knin come from? Who
were those people?
A. ln the main, I believe they were the families of those who were concerned that their
villages and towns were close to the zone or cl oser to the zone of separation and,
therefore, had a higher pro babil ity of ris k. So the town, immediately prior to the 4th and
5th of August, was populated by mainly the elderly, women, and children, as the vast
majority of tïghting-aged males had been essentially mobilised and deployed into the
zone of separation in a variety of defensive positions.
[ ... ]
'
1
Page /939
[ ... ]
Q. Now, you've described the increase in the size of the civilian population in Knin in the
period preceding Operation Stonn. Did you observe whether any of the population of
Knin had left the area in the days immediately preceding Storm, that is, immediately
before August 4th, 1995?
A. There were some elements of the local population that had left in roughly the week
prior to the 4th and 5th of August. How many, I don't know. It did not appear to make a
sizeable reduction in the mass of people that 1 would see in and around the streets of
Knin. We were aware anecdotally that a variety of Serbian refugees or Serbs from Knin
had tried to get across the border into the Serb-controJ.l.ed areas of Bosnia bllt bad been
turned around and sent back ta Knin. But this is anecdote; it is· not based on observation.
Q. General Leslie. how and when did you tirst leam that qperation Storm would take
place or would commence? . . -
A. The first confirmed indication we had was at roughly 20 minutes after 3.00 on the 4th
of August when the Sector South headquarters received an indication from UNCRO
headquarters, our superior headquarters
Page 1940
in Zagreb, that an attack by the Croatian Forces to recapture the Krajina was imminent.
Over the course of the subsequent hours, there were many such reports from different
sources.
[ ... ]
Page 1942
Q, Y ou say consistent shell tire after describing the rough timing that you did. Can you
a1so give the Co mt any indication of the relative intensity of that consistent shell fire?
~~ I would say the intensity was high between roughly 5.00 in the moming of the 4th
~i,hil approximately 7.00 in tenus of the total number of explosions, though there would
Be variances between when those explosions occurred. So, .in the first initial salvo,.all the
i:&plosions occtmed almost at the same time. As the first l~o~r or two wore on~ thei-e were
t~e same relative number of explosions over time, but it wasn't as controlled.
Q. You indicated that, at approximately 7.00, there was a change in the intensity of the
snell tire. Can you describe for the Court the nature of the change that occurred after
approximately the tirst of couple of hours?
A. At approximately 7.00, or around approximately 7.00, the tire diminished markedly;
and instead of having explosions ali over the city of a consistent nature, the explqsions
and shell tire was grouped across specifie regions of the city which varied, wherein you'd
have a shell detonating, a minute or two or three would go by, another shell detonating
200 to 300 meters away from where the first one went off. That process would be
repeated severa! times. Then you'd have four. five, or six shells landing fairly tightly
grouped together. This process would be repeated essentially throughout most of the day
at. a lessened intensity as compared ta what happened between 5.00 and
li
!'
Page /943
7.00 in the morning.
[ ... ]
Page 1964
A. At close range, right by Sector South headquarters, there was a wide range of vehicles,
mainly trucks carrying people. We call thèm putt-putt tractors. Those are essentially large
farm implements with a wooden cargo can·ying compmtment on the back, caiTying
people. The occasional tank would grind its way back, very rare, covered in soldiers, but
not many; and also people on foot walking 6y the Fieaâquarters heaâing Clown towarâs
Knin.
[ ... ]
Page 1966
[ ... ]
Q. Did you leave the Sector South headquarters compound on the morning of the 5th?
A. I did.
Q. And for what purpose?
A. We had been asked by a Serbian physician to assist in the evacuation of approximately
30 to 40 critical patients at the Knin hospital, and I had volunteered to assemble a team of
initially six vehicles to proceed to the hospital to assist in that evacuation. We first
became aware of this request around 7.00, ?:30 in the morning, and
Page 1967
we left the compound about an hour and a half later.
Q. During the course of that trip frori1 the Sector South headquarters ta the hospital and
qack, can yo.u tell the Cmut wh at. if anything, you saw or experienced?
A. The journey was -- took approximately 15 to 20 minutes. We stmted with six vehicles. We were -- initially, my vehicle was goi1ig to lead, but at son}~ point th~;:·serbian
~~1bulance· eut in front, I thilik during one of the moments of shell fi re. The re were two
~ignificant periods of shell fi re en route. One was in the area of the train yards before y ou
got ta the main' ti·affic circle, quite close ta the vehicles, ta the extent that they were
i·ocked by the blast. The second, which was in the area of-- or prior ta the
north Dalmatian corps headquarters, after the traftic circle. En route to the town, the town
appeared to be, from what I could see, essentially deserted. There were dead along the
route, numbering somewhere in the arder of 15 ta 20 scattered hither and yon, along that
main route, occasionally up the side street. There was an enormous debris field along that
rdute of baggage and suit cases and even furniture until we got to the turn-off which left
Ki1in ta the north and west, at which point the route became relatively clear. q; Y ou mentioned seeing dead along the route ta the hospital. Did you see any bodies or
i1~jured persans upon arrivai at the hospital?
~~! r;,
'="Ir'
1 !_
A. On anival at the hospital, there were large quantities of dead, men, women, and
children, stacked in the hospital corridors in a pile. A makeshift room on the back rear
floor was being used as a morgue. There
Page 1968
was no power, and the medical staff had departed with the exception of one male nurse
who had obviously stayed there while the Serbian physician came and got us.
There were approximately 30 to 40 patients ofwhich 25 orso were in absolutely critical
condition, a mi x of the eider! y women, occasional fighting-age male, and -- yea:h.
Q. While --
JUDGE ORlE: Mr. Tieger, could we ask the witness "large quantities of dead, men,
-c-========c;;wmo""m~enëF,-=<ain"nâ-clulâren, staclceâ-m-tlï.e-nospital ... " What do I have to unâerstanâ
approximately by large q1:1antities? Where you are saying "30 to 40 patients, 25 in
absolutely critical condition," what about the dead bodies.
THE WITNESS: Sir, it's very difficult to estimate. l would say the number was no lower
than 30 and probably no higher than 50 or 60.
[ ... ]
Page1972
[ ... ]
Q. And just to be clear on the exchange of points ofview, did you demand on behalf of
UNCRO that UNCRO personnel be permitted to leave the compound?
A. Yes.
Q. And did you explain for what purpose UNCRO wanted to leave the compound?
A. Yes.
Q. And what was that pm·pose? 1· To ensure that the laws of war were being respected, to ens ure that no humanitarian
v.~.Olations were being perpetrated, to allow us access and visibility asper the United
~·~tions Security Council resolutions which granted us such, and I also mentioned that we
1~re willing to accept the responsibility and risk in doing so.
~ Oka y. If y ou recall, wh at response did y ou receive to the demand
ta· leave the compound?
A. Endless repetitio.ns· of no.
Q. How long did -- for how long did the tank remain there and how long was UNCRO
personnel prevented from leaving the camp?
Page 1973
A. We were prevented from leaving the camp up until the 9th of August, where 1 believe
1 jwas one of the first outside of the camp. There had been other minor exceptions, and I
iÇls escorted by a Captain of Marine Lukovic from Sector South headquarters out of the
àJea of operations to take up my new duties of Chief of Staff UNCRO. The tank
r~rmained in place for severa! hours. 1 cannat recall when it left. I was not there when it
1·
'1.as withdrawn. By then we bad received orders from UNCRO telling us that we were to
stay in the camp until a variety ofhigher-level discussions were conducted between
UNPF, UNCRO, and the various authorities.
Q. Although unable to leave the compound, were you able to hear anything that was
happening outside the compound during the period oftime you were prevented from
leaving?
A. Y es. There were occasional flurries of shots, occasional grenade detonation; a modest,
very few number of buildings were in flames; and much mechanised noise of tanks
grinding by our headquarters to the north on that raad; and Croatian forces streaming into
the town from that raad just outside Sec tor South headquarters.
[ ... ]
Page 1979
Q.So, first of aiL with respect to the initial barrage that took place on August 4th, what
was it about tli.af initial barrage, if anything, that led to the conclusions you drew in the
August 12th report? ·
A. The initial barrage on the 4th of August from approximately 5.00 to approximately
7.00 in the morning did not have any concentration offire and no discernible pattern that
corresponded to any obvious point of aim of military value. The fi re was, to put it in
layman's terms, ali over the place.
[ ... ]
Page 1980
g1
General Leslie, you also indicated that during the course of the shelling that took pl~ce
OJ~ A:1gust 4th and August 5th, you observed corrected fire or target group procedures; IS
tf.lat nght?
À. That is correct.
<Q. Would that indicate that there was -- would that reflect, based on your observations
f:nd your experience, that was an effort to hit particular targets?
~- Yes.
~- First of ali, where did you see those target group procedures or corrected fi re? Where
~as it directed~ · · ·
A~· In the main, from the vantage points which [ enjoyed which were either the balcony or
perhaps more specifically the region of the helipad, the vast majority of the target grid
procedure centre ofmass impact were in and amongst residential structures. There were
sorne exceptions to this, and l do not know ifyou wish me togo into the
Page 1981
detail at this point.
Q. Sure. What were the exceptions to this, do you wish to let.us know?
A. The exceptions to this were- and this is not an exhaustive list because I would like to
refer to my notes to provide such - the air defence battery which was located 400 to 600
metres to the south and east of Sector South headquatters, which was -- which was weil
and truly covered by fire by Croatian attillery systems; the south-east p01tion of
the train yards; and what was known as the factory complex, the roof of which you could
see from the helipad. Those were the only three that immediately spring to mind that I
ç:ould see fi:om where I was in Sector South helipad.
[ ... )
Page 1990
[ ... )
A. The best descriptor between the periods 5.00 and 7.00 in the morning on the 4th and
5th of August was the fire was ali over the place, and there was no apparent target grid
procedure that 1 could discern, and that in the periods on bath days from 7.00 until when
the fire stopped,
Page /991
the target grid procedure, sorne ofwhich was fired at sorne ofthe targets which 1 believed
to be legitimate military targets, the vast majority which was not.
[ ... ]
A. We had the Serbian doctor, whose name I cannat recall; we had two Canadian M-113
annoured persmmel carriers; two Jordanian M-113 armoured personnel catTiers; and two
Czech armoured personnel carriers.
Q. General, do you know the name of anyone who was with you?
A. Y es, actually now I do. Sergeant Marcotte, who was the Canadian sergeant,
accompanied me on the trip; and for that specifie sequence of events, he was awarded the
meritorious service medal.
Page 1992
[ ... ) .
JUDGE ORIE: Then my next question would be: Y ou described that you saw dead
people when you were on the road to the hospital. Did you observe anything which would
give a clue to whether their status was civilian or military?
A. Y es, sir, I did.
JUDGE ORIE: Could you please explain what you observed.
A. There were - it was long ago - but I believe that there were a
Page !993
1
t€w dead children --weil, there were certainly sorne, very young. There were women
Hl·essed in skirts. There were tighting-aged males as weil, dressed with the sott of unique
collection of clothing that the Serbian militia wore at that time. There were a few elderly.
Most of the dead, though, were essentially shapeless bundles of rags with the
occasional limb protruding or other unpleasantness.
JUDGE ORIE: Y es. Do 1 understand were your answer that you're not able to give any
more precise prop01tions of the categories y ou just mentioned?
A. No, sir, I cannat.
JUDGE ORIE: Then you told us about soldiers on the wooden cargo pallets behind the
tractors. Y ou said that you saw, together with women and elderly people, you saw also
soldiers. Could you be more precise as what soldiers of what armed forces, if you are able
to make any distinction in that respect? Could you tell us a bit more about these soldiers?
A. Y es, sir, I can. Starting in the afternoon ofthe 4th, the soldiers were Serbian soldiers
and it started slowly, this column ofvehicles. But within a couple of hours, it was very
constant and steady where you'd have trucks can·ying two or three soldiers, five or six
women and children; followed by a putt-putt, which is this tractor pulling this wooden
cargo flat rack, that might have ali soldiers; followed by a normal tractor pulling a hay
wagon that would have ali women and children. So it was truly a chaotic melange of
people driving by Sector South headqumters.
[ ... ]
Page 2011
[ ... ]
Q. And when you were in this parti cul ar, I guess, convoy" of vehicles, I mean, where weJ;"e
y ou?
A. I was in, originally, the lead vehicle, but then the Serbian doctor, very brave, took the
lead, so 1 was in the first vehicle.
Q. And where were you in this vehicle, sir?
A. I was standing in the cargo hatch which was open.
[ ... ]
Page 2015
[ ... ]
Q. Let's explore that. So what you're saying is that Operation Storm was conducted with a
high degree of expertise; is that right?
A. I, as a military professional, would agree that cetiain elements of Operation Storn1
were conducted with a high degree of expe1tise. 1 f the aim was to ens ure th at the local
population was cleansed from the region.
[ ... ]
Page 2046
[ ... ]
23 Apri 1 2008
Q. WeiL let us go to this particular tape and this is a BBC tape and as we see it is 7.04 on
tJ1e morning of the 4th, London ti me which of course would be 8.00 a. m. Zagreb/Knin
f!\IPe?
~· Okay.
MR. KEHOE: And we could play this.
[Videotape played]
Page 2047
Ht •• 1
"Short time ago we spoke to the UNPROFOR spokesman in Knin, Lieutenant Colonel
·Andrew Les lie, he described how the offensive there be gan.
"At 0500 this mo ming, Knin, the capital of the Krajina was hit by artillery and rocket
shells. lt was dark at that ti me, of course, the center or the main point of impact appeared
to be the center of Knin, after 300 detonations we've !ost count. Repmts from our
battalions indicate that essentially every large urban center in the Krajina has been hit by
shell fi.re, starting between 5 and 5.30. As weil the Croats have launched their strikes on
the town of Gracac. There's a lot of shell fi re. There has not been yet a lot of movement
into the zone, so we don't really have a clear picture on what the Croatian ground forces
are doing now but they certainly pounded the Serbian communities.
"There's two or three pillars of fi re and smoke in the centre of Knin. We unfortunately
had some of our people still sleeping downtown when this haQQ~en~e~d~an~d.~. , _,. ~ci'-"v""il~ia.,n""s"=====·-=----=---=--=---=-====l=l
inostly, and we sel1tol1r àml.oured\lehÎclesto coilect them. The-term-contro!Ied''chao-S,'1
from our view, applies. The damage? It is very hard to assess, I mean, there's bouses that
are destroyed, there's craters in the roads, it is not terribly pleasant."
[ ... ]
i
1
~age 2081
~l· .. ] ./
:ti Q. Let me stay withjust this pa1ticular incident. I mean, you testified for us that you
il·
IJ'l:ought patients to the UN? 4. Yes.
Q.. Were they soldiers?
]ô;.j I don't know. Most of them were -- hmm. Most of them were in no state to identify
thèir profession. The ambulatory ones, no. To the best of my recollection and it has been
a long time, l don't believe any of the ambulatory patients were soldiers. Some ofthose
wpo were unconscious might have been.
QI;'So 1 mean those individuals that might have been you were taking them from a
hdspital and bringing them to the UN compound? ·
A. That's correct.
Q. Why were you doing that, sir?
k.; '0fe had been appro.ache~ that morning by a Serbi~n doctor who worked ·at the . .
\19spital, and he bad indicated that there was no power,'· there was no light, no supplies,
~nd essentially that the staff had left, and he and a male nurse were those that remained.
He had left the male
L
fl~ge 2082
1 !j
n_brse at the hospital. He came to our compound to ask for assistance. As the attending
P,hysician to move his patients to Sector South military tàcilities and the area commander
n1ade the decision to -- to go ahead.
Q. Was it within the UN mandate to move soldiers in any fashion?
A). Sir, I have not actually stated that these personnel were soldiers. Have I said that I
d8;1't know if any were soldiers.
[ ... ]
.. j '
Page 21!9
[ ... ]
Q. Secondly, the August 7th report from Mr. Stoltenberg to the Secretary-General that
was refetTed to a few moments ago, in particular the potiion on page 2, involving a
discussion with Mr. Granic, in that
Page 2120
repmi as pointed out to you by the Defence, Mr. Granic was pressed to explain the
shelling of civilian areas in Knin. He said that most of the civilians had already fied the
August, was that accurate or inaccurate?
A· Sir, based on my observ.~tions of the region of Knin, the City of Knin, his observation
is inaccurate.
Q. M.r. Granic also said there had been thr'ee military barracks ii1 Knin. Did.you observe
that the shelling of Knin was directed at only the three military barracks in Knin?
A. No, sir.
[ ... ]
Page 2121
[.~. . ]
Q. Now, you have told the Comi that the shelling that you observed reflected either a
d'eliberate attempt to shell civilian structures and areas, or the indiscriminate shelling of
sù.ch structures and areas?
A. Yes.
[ ... ]
),i
;t;
1 ,! .1;
~ 1
11t':1
! t·:·'
l!'i. t:,.
:·:
Written testimony of Witness Andrew Brook Leslie *