In this May 18, 1995 motion, the prosecution requests protective measures to ensure the anonymity of the victims and witnesses in the case against Dusko Tadic.

THE INTERNATIONAL CRIMINAL TRIBUNE FOR THE FORMER YUGOSLAVIA

IN THE TRIAL CHAMBER

Before:

Judge McDonald, Presiding Judge Deschenes Judge Vohrah

Date Filed: 18 May 1995

 THE PROSECUTOR

v.

DUSAN TADIC a/k/a "DULE"

Case No. IT-94-1-I

MOTION AND SUPPORTING BRIEF REQUESTING PROTECTIVE MEASURES FOR VICTIMS
AND WITNESSES

 The Office of the Prosecutor

 Counsel for the Accused:

Professor Michael Wladimiroff Mr. Milan Vujin Mr. Krstan Simic

 THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

THE PROSECUTOR OF THE TRIBUNAL

DUSAN TADIC a/k/a DULE CASE NO IT-94-1-I

 MOTION ON BEHALF OF THE OFFICE OF THE PROSECUTOR FOR ORDERS FOR AND
WITNESSES OF CRIMES ALLEGED IN CHARGES 4, 5 AND 11 AND FOR GENERAL
PROTECTIVE MEASURES FOR VICTIMS CONFLICT IN FORMER YUGOSLAVIA

 Pursuant to Rule of Procedure and Evidence, "Rule", 72, the
Prosecutor requests that this Trial Chamber issue an order continuing
the non-disclosure of the names of the victims and witnesses given
pseudonyms in the indictment and in the evidence supporting the
indictment. These victims and witnesses are relevant to the crimes
alleged in Charges 4.1 through 4.4, 5.1, and 5.29 through 5.34 of the
Indictment In addition, we request that the Trial Chamber order the
non-disclosure of the identity of two additional witnesses relevant to
Charge 11, and that the Trial Chamber order general protective
measures for all witnesses who are victims of the conflict in former
Yugoslavia.

 RELIEF REQUESTED

The Prosecutor requests the Trial Chamber to grant orders in the
following terms:

(1) That the names, addresses, whereabouts, and other identifying data
concerning persons given pseudonyms A, F, G, H, I, victims and/or
witnesses of the crimes alleged in Charges 4.1 through 4.4, 5.1, and
5.29 through 5.34 of Indictment No IT- 94-1-I shall not be disclosed
to the public or to the media.

(2) That the names, addresses, whereabouts, and other identifying data
concerning persons given pseudonyms J and K, witnesses who will
testify concerning Charge 11, shall not be disclosed to the public or
to the media.

(3) That all hearings discussing the testimony of A, F, G, H, I, J,
and K, or otherwise making reference to these victims and witnesses,
shall be held in closed session.

(4) That the names, addresses, and whereabouts of, and identifying
information concerning, A, F, G, H, I, J, and K shall be sealed and
not included in any of the Tribunal's public records.

(5) That, to the extent the names of, or other identifying data
concerning, any of these victims or witnesses are contained in
existing public documents of the Tribunal, those names and other
identifying data shall be expunged from those documents.

(6) That Tribunal documents identifying these witnesses shall not be
disclosed to the public or the media.

(7) That testimony of these witnesses shall be given by one way closed
circuit television.

(8) That testimony of these witnesses may be given using voice and
image altering devices or by not transmitting the image to the accused
and the defence.

(9) That the testimony of these witnesses shall be heard in closed
session.

(10) That pseudonyms A, F, G, H, 1, J, and K shall be used whenever
referring to these witnesses in Tribunal proceedings, and in
discussions among parties to the trial.

(11) That the Prosecutor shall disclose the names and the unredacted
statements of the protected witnesses to the defence in sufficient
time to allow the defence to prepare for trial, but no earlier than
one month in advance of the firm trial date.

(12) That the accused, the defence attorneys, and their
representatives who are acting pursuant to their instructions or
requests shall not disclose the names of these victims or witnesses or
other identifying data concerning these witnesses to the public or to
the media, except to the limited extent such disclosure to members of
the public is necessary to adequately investigate the witnesses
Further order that such necessary disclosure be done in such a way as
to minimize the risk of the victims' and witnesses' names being
divulged to the public at large or to the media.

(13) That the accused, the defence counsel, and their representatives
who are acting pursuant to their instructions or requests, shall
notify the Office of the Prosecutor of any requested contact with
prosecution witnesses or the relatives of such witnesses, and that the
Office of the Prosecutor shall make arrangements for such contact.

(14) That the public and the media shall not photograph, video record,
or sketch witnesses who are victims of the conflict in former
Yugoslavia when these witnesses are entering the Tribunal building,
exiting from the Tribunal building, or while they are in the Tribunal
building.

/s/Grant Niemann Senior Trial Attorney

/s/Brenda J. Hollis Trial Attorney