Tribunal Criminal Tribunal for the Former Yugoslavia

Page 6208

1 Tuesday, 20 January 2004

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.07 a.m.

5 JUDGE LIU: Call the case, please, Mr. Court Deputy.

6 THE REGISTRAR: Good morning, Your Honours. This is Case Number

7 IT-02-60-T, the Prosecutor versus Vidoje Blagojevic and Dragan Jokic.

8 JUDGE LIU: Thank you very much. Before we start with the

9 witness, I think there's a procedural matter that we have to deal with.

10 And yesterday Mr. Karnavas promised me to have some feedback concerning

11 one witness.

12 Mr. Karnavas, are you ready?

13 MR. KARNAVAS: I am, Your Honour. I apologise for -- thank you,

14 Your Honour, and thank you for giving us the extra time to make a more

15 comprehensive argument, though I must say getting ready for Mr. Deronjic,

16 my argument is going to be crude and perhaps not as eloquent as I would

17 like it to be.

18 In any event, if I can work backwards with respect to the

19 pleadings with this particular witness. The Prosecution on 5 December,

20 2003, filed a motion and attached to the motion in the very last page with

21 respect to this particular witness, it notes that her testimony, and I

22 quote here: "Does not relate to any elements of the crimes charged."

23 And then it states: "In view of this and in the interest of

24 expedience and efficiency, the Prosecution submits that this witness's

25 testimony should be admitted under 92 bis with no cross-examination."

Page 6209

1 So that was the very latest that we heard from the Prosecution.

2 Then if we were to go, for instance, to the Prosecutor's notice -- the

3 summary of the witnesses. On page 32, it would be paragraph 78. This was

4 a motion that was filed or a pleading that was filed on 4 November, 2003,

5 titled Prosecution's notice for filing revised witness list and motion to

6 remove additional witnesses from witness list. And I quote with respect

7 to this particular witness the Prosecution states there in a somewhat

8 contradictory form to what we just heard: "This evidence is relevant to

9 all paragraphs and all counts of the indictment."

10 That's paragraph 78, page 32 of that particular motion. Then if

11 you were to go, Your Honours, to 8 November, 2002, to the Prosecution's --

12 this was filed under seal. The Prosecution's filing of amended pre-trial

13 brief pursuant to Rule 65 ter and list of exhibits pursuant to Rule 65 ter

14 (E)(v) [sic]. On page 78, there is an argument with respect to the issue

15 of genocide. I don't want to go into it, but nonetheless I think it can

16 be found on paragraph 203 on page 78 -- I mean, 85. And if you look at

17 that paragraph and the following paragraph, it talks about the particular

18 argument that the Prosecution wishes to put forward with respect to the

19 issue of genocide.

20 Lastly, I was -- we were in a bit of a rush, but nonetheless we

21 did manage to look at the trial testimony of this particular witness

22 during the Krstic trial. And there was a very pointed question that was

23 put by Judge Riad who was the President of the Trial Chamber at that time.

24 And I'm quoting from page 5.855 where Judge Riad says, and this, it begins

25 on line 21, Ms., Ms. -- I can't pronounce the name: "In fact my question

Page 6210

1 is based on some of the answers you gave to my colleagues, my very eminent

2 Judge colleagues which touch on a very basic problem, a very basic issue

3 and this is the planning for the future and the continuation of life for

4 this community because some communities could not rise up again after

5 destruction and history. Some continents even."

6 And it goes on. And the answer to that question that was posed,

7 which can be found on page 5.857, and I'm quoting from line 4, this is her

8 answer: "I think that would be a very interesting to see in what way the

9 role of the woman will change in these patriarchal Islamic families. This

10 concerns the rule areas to a greater extent because in-town women have

11 their jobs, their professions, and they are unable to live on their own."

12 And it goes on and on.

13 Now, I think given the answer where she says, "It would be

14 interesting to see in what way," we have as part of our preparation and

15 defence for Mr. Blagojevic, we have begun to look into this issue. And we

16 do know that there are some statistics that are being gathered by the

17 international community, and I believe we are hoping to have some more

18 concrete figures perhaps from the office of the high representative which

19 is currently working in Bosnia and Herzegovina. Now, naturally these

20 statistics would go to the returnees and the return of abandoned property.

21 That's not an exact scientific measure, because at least in my experience

22 and having worked for OHR in Bosnia, it seems that many refugees or

23 displaced persons would prefer to sell their properties as to -- versus

24 returning to their village or their town. But nonetheless, there is a

25 mechanism for them to get their property back and have the option to live

Page 6211

1 wherever they wish to live pursuant to the constitution of the BiH.

2 The statistics show, and I don't want to be nailed down on this,

3 but it's my understanding and I say this as an officer of the court, that

4 the statistics so far show that perhaps we are in a figure of 90 per cent.

5 Now I will try to get more concrete figures. And the expectation is that

6 within some point there will be 100 per cent returnees to the area of

7 Bosnia and Herzegovina. That's one measuring stick. The other measuring

8 stick, I think, for this particular witness is given her own answer in

9 this particular case, I think it would be vital to have her and I would

10 suggest to the Prosecution that perhaps they could ask her to do some

11 updated research because she's not polemical in her testimony. She's

12 not -- and when I say polemical she's not hostile. She's not -- she

13 doesn't seem to be taking a subjective position so -- and that's

14 welcoming. And I think it might be worth for the Prosecution to ask her

15 to do an updated survey, an updated report. But I do think, I do think,

16 that her testimony is vital in this case. She is a psychologist. I think

17 this was a vital question that was posed in the Krstic case. I think it

18 remains a vital issue in this case. It goes to the heart of the issue of

19 genocide. I think that the Prosecution initially had asserted that her

20 testimony goes to all counts of the entire indictment. They then modified

21 it. I don't know why. I suspect they have good reasons. But nonetheless

22 I would request that she be brought in. I don't think that her entire

23 testimony would take more than a day, a day and a half at most.

24 So I hope, you know, my long-winded explanation, as a result of

25 lack of preparation, is sufficient to answer this particular question.

Page 6212

1 JUDGE LIU: Well, is there any response from the Prosecution?

2 Yes, Mr. McCloskey.

3 MR. McCLOSKEY: Yes, Mr. President. The last thing Mr. Karnavas

4 had read about the -- it didn't have anything to do with the elements

5 is -- I'm not sure what that was based on and that is not correct. This

6 testimony is -- was placed before the Krstic Court and this Court to show

7 the impact on the victims of the female community, the surviving -- some

8 of the surviving males and females. This witness had treated and

9 interviewed many, many Srebrenica women, and she was basically testifying

10 about the abject misery of the community as victim impact evidence, which

11 we, as you know, since we do not have sentencing hearings in this case,

12 it's incumbent upon the Prosecution to put on any victim impact evidence

13 that it has in its case in-chief.

14 Now, as this evidence came on in -- as victim impact in the Krstic

15 trial, it was also evident that the -- as the Court reviewed whether or

16 not Muslims in Eastern Bosnia had suffered destruction or part

17 destruction, they looked as you can tell from the questions of the Judge

18 and from the arguments into whether or not the evidence she provided was

19 evidence of the -- relating to the destruction of the group. So that is

20 another point that we would like the Court to look at. She has testified

21 in Krstic. She has been fully cross-examined in Krstic. Nothing she says

22 goes to the acts or conducts of this accused. She really testifies about

23 the misery and the living conditions and the horror that the people who

24 survived this without their men have lived there. That will not change.

25 It is difficult for her to testify on these subjects. It's difficult for

Page 6213

1 her to come back. She will not fundamentally change her perspective on

2 that, I am sure. And she does not provide any statistics or any survey or

3 anything like that. She's just talked to the women and she's seen where

4 they lived, and she told the Court about it. This is precisely the kind

5 of evidence that 92 bis is most appropriate for. It would be difficult

6 for her to come back and have to relive the nightmare of the women that

7 she has spoken to. And, so we would request this Court to consider 92 bis

8 and allow her Krstic testimony to come in. Thank you very much.

9 MR. KARNAVAS: Just a brief --

10 JUDGE LIU: Very, very brief response.

11 MR. KARNAVAS: Very brief, Your Honour. Very brief. First, I was

12 quoting from the pleadings that were submitted by the Prosecutor. I

13 quoted verbatim. The first quote came from tab A of their motion. So I

14 don't think I'm out of line on that.

15 Secondly, victim impact is an element in genocide, not just for

16 sentencing but also in whether the atrocities and the crimes were of such

17 nature that we can say that there was a permanent effect on the community,

18 either in part or in whole.

19 Thirdly, there was no cross-examination of this witness in the

20 Krstic case, so there was no confrontation. I don't know what the reasons

21 were. They obviously have their own tactics.

22 Fourthly, they brought her in in essence as an expert, as an

23 expert psychologist. So she was not just an observer, an eyewitness or a

24 survivor. She was an expert. Naturally, she was doing that as part of

25 her job. So she placed herself into that nightmarish situation, because

Page 6214

1 that's part of her job, just as a physician places himself in a hospital

2 to deal with individuals that are in a dying -- are in dying conditions.

3 Somebody has to do that work. I think I would agree that it's traumatic

4 to testify regarding these events, but nonetheless we have certain rights

5 in this case. And I don't think that Mr. McCloskey's argument is very

6 persuasive at all. I do think it's necessary for her to come in and

7 testify. If she doesn't want to testify, then she should not -- then this

8 Court should not accept her testimony at all, period. End of story. They

9 can find somebody else.

10 If the Prosecutor, if the Prosecutor, is saying today that she is

11 unavailable for cross-examination, then she's unavailable for direct

12 examination, Your Honour. That's the way it should work, because we have

13 rights as well. And he hasn't -- and Mr. Blagojevic hasn't been

14 convicted. And so he's saying this is for sentencing purposes; and I'm

15 saying, well, if you're going to use this for sentencing purposes, let us

16 cross-examine. She should have more data. If her own answers are that,

17 it would be interesting to see. She's had more time. So I don't think

18 the Prosecutor should get a freebie on this one. They get to put on

19 evidence and we don't get to. Because I'm still left with the option of

20 calling her as my own witness.

21 I find it -- I don't want to notch it up at this level, but I find

22 it supremely ironic that one month they say that she goes -- she's

23 involved in the entire indictment, and then later when it suits them,

24 well, nema problema, we don't need to have her. Not important. Which one

25 is it, Your Honour? And again I don't mean to get confrontational on

Page 6215

1 this, but I think either she's in or she's out, not half way.

2 [Trial Chamber confers]

3 JUDGE LIU: Well, after the consultations with my colleagues and

4 after hearing the submissions from both parties, we believe that this

5 witness is indeed a victim impact witness. And we go through her

6 testimony in another case. It is true that nothing she says goes to the

7 acts and the conducts of the accused in this case, the Blagojevic case.

8 As for the matter of the genocide, pending the decisions of the

9 Appeals Chamber on another case, at this moment we would like to say that

10 the genocide happened during the Srebrenica incidents. But this is not

11 the question in our case. In our case we have to find out the linkage

12 between the genocide and Mr. Karnavas's client, the accused. This is the

13 most important matter.

14 As for the filings of the Prosecution, we believe that we should

15 rely on the latest filings from the Prosecution, because along with the

16 proceedings of this case both parties as well as the Bench could have a

17 better understanding of the case. So at this stage, we will not make a

18 decision whether to hear this witness live or admit his testimony or

19 statement into the evidence. We would like to ask the Defence counsel to

20 submit whatever their objections or concrete reasons for the

21 cross-examination in the written form. This witness could be a rebuttal

22 witness in the future but not now. At this moment, we are not going to

23 make any decisions concerning this matter. It is so decided.

24 Well, having said that, could we have the witness, please.

25 [The witness entered court]

Page 6216

1 JUDGE LIU: Good morning, Witness.

2 THE WITNESS: [Interpretation] Good morning, Your Honours.

3 JUDGE LIU: Did you have a good rest yesterday?

4 THE WITNESS: [Interpretation] Yes.

5 JUDGE LIU: Are you ready to start?

6 THE WITNESS: [Interpretation] Of course, Your Honour.

7 JUDGE LIU: Thank you very much.

8 Mr. Karnavas.

9 MR. KARNAVAS: Thank you, Mr. President and Your Honours.


11 [Witness answered through interpreter]

12 Cross-examined by Mr. Karnavas [Continued]

13 Q. Good morning, Mr. Deronjic?

14 A. Good morning, Mr. Karnavas.

15 Q. Perhaps we could pick up where we left off yesterday. Yesterday I

16 believe we were discussing the issue of the declaration that was signed by

17 the representatives of the Muslim community and by you back on 17 July

18 1995. Do you recall that's where we left off?

19 A. Yes, of course I remember.

20 Q. I take it you had the opportunity to review your records overnight

21 and perhaps even look at this document?

22 A. Yes, that is correct.

23 MR. KARNAVAS: And for the record, Your Honour, this document was

24 introduced by the Prosecution in two versions, 36.1 and 36.2/A. I believe

25 the Prosecution's official translated version was 36.2/A.

Page 6217

1 Q. Now, I believe yesterday we were discussing whether this document

2 represented a true reflection of the situation as it was occurring and as

3 it had occurred between July 12th, 1995, and July 17, 1995. And if I'm

4 not mistaken, it was your understanding that this was a truthful

5 representation of the situation. Do you still maintain that or was I

6 mistaken?

7 A. Mr. Karnavas, I think that this was the question where we broke

8 off yesterday. I wanted to have a look at the transcript with respect to

9 this question. The way you posed your question implied that you believed

10 that this document was not accurate. And I said no, which means, since

11 you were discussing the issue of semantics, you must be aware of the fact

12 that I am also aware of the broader issue. And you were implying that I

13 believed that the entire document was not accurate. Which is what I

14 indicated yesterday. I do not have any other answer to provide at this

15 point. I let you finish your point, your argument, and it was my

16 intention to give a comment on the issue once you've completed your

17 argument.

18 In my statement before the Prosecutor, which has been recorded, I

19 asked -- I was asked whether the document was entirely truthful, and I

20 denied it and said, no, which means that certain portions of the document

21 were accurate and others were not. I made a note in the original

22 transcript, which is much broader than the summarised version that the

23 Court has, the part where I mention this particular document, and if you

24 want me to, I can read out the exact wording of the question and my

25 answer. And this other document in the summarised version, the redacted

Page 6218

1 version, I also made a note of the exact part of the document where the

2 issue is discussed.

3 Now, I don't want to waste your time on reading the document, but

4 the issue was whether the statement that Muslims were able to remain in

5 Srebrenica, that they could choose whether to stay or to leave, whether

6 this statement would be considered to be truthful and whether it

7 corresponded to the situation as it was on the ground. And I responded to

8 the question, I said that my opinion is and was at the time that this was

9 not possible, that it was my belief that Muslims could not remain in

10 Srebrenica, even if they had expressed such a wish because the actual

11 circumstances did not allow for that possibility. And I went on to

12 enumerate the reasons that made this option impossible. It is true that

13 on the meeting of the 12th, I did offer this possibility pursuant to the

14 order of President Karadzic. I spelled it out. It was within those three

15 options that the president wanted me to convey to the Muslim

16 representatives at the Fontana Hotel.

17 So I did mention this particular option, but I believed that due

18 to the circumstances on the ground after the takeover of Srebrenica by the

19 members of the Serbian army did not allow for the possibility of Muslims

20 to remain in Srebrenica. I did not question the entire wording of the

21 document when I said that. The document also contains the issue of

22 transport of civilians, women and children, from Potocari and the way it

23 was carried out, escorted by UNPROFOR and the police and so on and so

24 forth. And we agreed, all the three parties, that this was -- this

25 transport was done in a correct manner, in light of the circumstances as

Page 6219

1 they were at the time.

2 So I did not comment on the entirety of the document. In response

3 to the question dealing with segments of this document, I said that they

4 were not accurate. Likewise, I indicated that the document did not

5 contain all of the events taking place at the time. I drafted it with the

6 purpose of having a confirmation of what was my responsibility, namely the

7 transport of the civilians. I agree that it should have been dealt with

8 more extensively. And it is true that on the 17th I was already familiar

9 with some of the crimes that had taken place, the Kravica incident, but I

10 did not believe it to be necessary to be part of this document.

11 So therefore, you were hasty in your conclusion that I consider

12 the entire document to be inaccurate.

13 Q. Okay. Are you finished, Mr. Deronjic?

14 A. Yes.

15 Q. And I notice that you have in front of you in tabs your prior

16 testimony from previous hearings. So I take it you had a chance to review

17 what you said so you could be correct today. Mr. Deronjic --

18 A. No. I apologise, really. This is my last testimony. I don't

19 have any of my other previous statements.

20 Q. All right. Now, Mr. Deronjic, before we get to this document, you

21 indicate -- let's talk about one issue that you raised on your own. It

22 wasn't part of my question, we were going to get to it, but you raised it

23 nonetheless and let's deal with it at this point. And that is the issue

24 of whether -- had the Muslims expressed an interest to remain in

25 Srebrenica, whether that was feasible, given the circumstances. And I

Page 6220

1 understand your answer is, no, that was not feasible.

2 Now, am I -- are we correct in assuming that one of the reasons

3 that wasn't feasible was because it would have been difficult, if not

4 impossible, to provide security for those Muslims during that period of

5 time?

6 A. Yes, I agree. That is one of the reasons why I believed this was

7 not possible.

8 Q. After they had left Srebrenica, it would have also been rather

9 difficult to move them back into Srebrenica and provide them protection

10 while at the same time keeping out the Muslim military, which the UN

11 apparently was reluctant or unable or unwilling to do pursuant to their

12 mandate as it was required by them?

13 A. These are assertions. I don't know what the question is.

14 Q. Well -- okay. Let's not play games.

15 Srebrenica, before it fell, was it demilitarised?

16 A. As far as the information that I have - and I'm not an expert; I

17 never seriously dealt with it - but military information states that

18 Srebrenica was not completely demilitarised. And of course there certain

19 evidence of that also.

20 Q. Well, you know for a fact that it wasn't demilitarised,

21 Mr. Deronjic. You were the number one person for Karadzic on the ground,

22 and you had access to information. So you know for a fact that it wasn't

23 demilitarised. Correct?

24 A. I've just said that I did not directly deal with that. I didn't

25 any contacts with UNPROFOR during their stay in Srebrenica, no contact at

Page 6221

1 all. But I did hear from military sources that Srebrenica was not

2 demilitarised. And I could establish that also, based on the fact that

3 Muslims very frequently carried out military actions from that allegedly

4 demilitarised zone. So are you satisfied with the answer?

5 Q. So I take it it was a rumour that you heard. You had no real

6 substantial basis for that; it was just a rumour. Because that's an

7 absurdity if that's what you're alleging right now --

8 MR. McCLOSKEY: Objection. This is argumentive, Your Honour. And

9 we'll just go downhill from there. It's not helpful.

10 JUDGE LIU: Yes. Please withdraw the question.

11 MR. KARNAVAS: I'll withdraw the question, Your Honour.

12 Q. Let's look at the last paragraph of this document. Now, in the

13 last paragraph it indicates that: "No incidents were provoked by any side

14 during the evacuation and the Serbian side observed all the regulations of

15 the Geneva Conventions and the international law of war."

16 You put that statement in there, did you not, Mr. Deronjic?

17 A. Yes. I wrote the text, with the help of a Judge. I explained

18 that, but I authored the text.

19 Q. And you made sure that that paragraph was in there?

20 A. Yes.

21 Q. Because it was important, at least to show to the international

22 community, that your evacuation process - since you had been tasked with

23 that by President Karadzic - had been conducted in a lawful manner?

24 A. It was important for me that I have that assurance or

25 confirmation.

Page 6222

1 Q. All right. And then at some point the Dutch representatives

2 insisted on inserting a certain text with that. Right?

3 A. That's correct.

4 Q. Now, let's leave aside what the Dutch have inserted. Could you

5 verify for us whether that statement that you insisted on putting in and

6 that we now know was drafted with the assistance of a trained jurist, was

7 that truthful? Yes or no will do, but then you can give your explanation.

8 A. There can be no answer like that, just like that. Partially it is

9 true, otherwise in another part it's not. Please, Mr. Karnavas, how is it

10 possible to respond to such a question with a yes or no?

11 Q. All right. Well, you said "partially." Tell me which part is

12 correct.

13 A. If you allow me to look at the document, then I can quote so that

14 I don't have to just speak off the top of my head. I said that -- I told

15 you which part was incorrect, and that was --

16 Q. Mr. Deronjic, I'm looking at the last paragraph. We can put it on

17 the ELMO. We also have a copy in Serbian, and I know that you read

18 English as well. So -- now I'm just focusing on that last paragraph.

19 A. You're talking about this part after the agreement was concluded,

20 the civilian population -- is that what you're talking about, the

21 evacuation of the Srebrenica population was conducted correctly and

22 everything that we had agreed on in relation to the evacuation was carried

23 out.

24 THE INTERPRETER: The interpreters do not see the original of the

25 text.

Page 6223


2 Q. Let me just -- I don't want to go over every inch of this

3 document. I just want to go over the last paragraph. The last paragraph,

4 the very last paragraph reads, and you can follow along with me.

5 "No incidents were provoked by any side during the evacuation and

6 the Serbian side observed all the regulations of the Geneva Conventions

7 and the International Law of War."

8 And then other -- some text was also injected in there by the

9 Dutch which said: "As far as the convoys escorted by UN forces were

10 concerned."

11 MR. McCLOSKEY: I'm sorry. There is another exhibit that has that

12 written in there. The one on the ELMO doesn't have that. So if he's

13 going to be questioned on that, it would be better to have the full,

14 proper text.

15 JUDGE LIU: Yes.

16 MR. KARNAVAS: I believe we provided all of the documents. I have

17 an extra copy in Srpski if you would like to see it.

18 Q. Mr. Deronjic, you've looked at this document, correct, recently?

19 A. Yes, yes.

20 Q. And I would suspect you even looked at it last night, knowing you

21 were going to be questioned first thing in the morning?

22 A. No. I don't have it with me. No.

23 Q. Okay. Now, if you could look at the very last paragraph; look at

24 it, read it, study it.

25 A. Yes, I've read it.

Page 6224

1 Q. Now, earlier I asked you a question with respect to this

2 paragraph, and I asked for a yes or no answer. And you indicated that it

3 was very difficult because part of it is true, part of it is false or

4 incorrect, however you wish to characterise it. So which part of this

5 paragraph do you find to be truthful? And then, I guess by process of

6 elimination, we can determine that the rest obviously is either false or

7 incorrect.

8 A. First in your previous question you asked about the complete

9 document, what do I think. And I think that could be correct of you to

10 say that. Secondly, as far as this paragraph is concerned, if I can talk

11 about it in its entirety, and I will tell you it is not correct. Because

12 those convoys that were leaving for Kladanj, people were being separated,

13 even though this was an order of President Karadzic, his order related to

14 the people about whom our intelligence services had information that they

15 had committed war crimes. And we know today that this separation of

16 people was systematic, meaning that all the men were taken from the

17 convoys. And we know of their fate later. That is why this paragraph is

18 not correct.

19 Q. Okay. Now, are you suggesting today that at that time you were

20 unaware of the separation and that it is only now, after the fact, that

21 you have concluded that this paragraph, which you had special assistance

22 of a jurist help you draft and inject the Geneva Conventions in there, are

23 you suggesting that it was only after the fact that you realised that this

24 was wrong and incorrect?

25 A. You've asked the question whether I knew about this separation at

Page 6225

1 the time. I did know and I did react about that, and I said that in all

2 of my reports and I said through whom I reacted as well. What I did not

3 know is I did not know the scale of this separation and the manner in

4 which this was done. In the last days, when I was giving my statement, I

5 wasn't aware whether all the men were separated or not. But I was

6 provided with a lot of evidence that all men were separated from the

7 convoys. I know about some of the fates of those people; for the others I

8 don't know, but I know what was happening with them. And this convinced

9 me that this part was not correct. At the time when I was drafting this

10 document, I did know about certain separations, but I did not know whether

11 it was systematic or not systematic or whether this was done on the

12 recommendations of the president or whether these people were separated in

13 some other way.

14 Q. Let me be concrete. When you were drafting this paragraph, is it

15 not a fact that you knew that this was false, that this was incorrect?

16 A. No, that is not a correct interpretation. This was drafted on the

17 16th. On the 16th I did not have correct information about who was

18 separated and how many people were separated, as well as the manner in

19 which the separation was being carried out. What I know now is

20 information that I got later. It was something that I compiled later.

21 Q. All right. Let me jump ahead a little bit, and in timewise I'm

22 going to go back. I'm jumping ahead in my cross.

23 On the 13th, you met with Mr. Beara, right, you had contact with

24 him?

25 A. Correct.

Page 6226

1 Q. And at that time, according to your testimony, Mr. Beara indicated

2 that he was there to kill all of the Muslims that were there being

3 warehoused in schools and in buses. Correct?

4 A. That's correct.

5 Q. Okay. Now, how is it possible then on three days later when you

6 draft this document, and how is it possible for you to stand here, after

7 having taken an oath, and say that when you drafted this you thought that

8 there had been no incidents and that everything that had been conducted

9 was correct and lawful?

10 A. Mr. Karnavas, you are constructing your own theories, and I agree

11 with that; you are doing your job. But I will explain it to you very

12 simply. On the 13th when Beara came to my office I said literally what he

13 conveyed to me. You know how I acted; this is described in my interview.

14 Up until that time in Bratunac, there was no systematic killing of people,

15 except a major crime, an event, which happened in Kravica Oka about which

16 I received an interpretation from Ljubisa Borovcanin and he told me what

17 caused this massacre, how it took place, and what were the causes for all

18 the consequences that occurred.

19 On the 13th in the evening, or the 14th in the morning, prevented

20 Mr. Beara from committing any kind of killings, even systematic ones in

21 Bratunac. According to the instructions of Karadzic the way I interpreted

22 it. The detainees were taken from Bratunac to Zvornik. So a large number

23 of prisoners were alive on the 14th and they were transported to Zvornik.

24 On the 14th in the morning, I went to see Karadzic - I think you will come

25 to those questions - and I convoyed Mr. Beara's intentions the way he told

Page 6227

1 them to Mr. Karadzic. Mr. Karadzic reacted, please allow me finish, you

2 have stated a very large accusation. So allow me to explain that. Mr.

3 Karadzic reacted the way he did and I got the impression he was going to

4 do something, and I returned to Bratunac. I did not have any particular

5 information over those few days from Zvornik. Of course some information

6 was arriving and it was possible to conclude that some unforeseeable

7 events were happening there, some things which were not foreseen in terms

8 of killing people and so on.

9 On the 16th, I drafted this document. I don't have complete

10 information about what happened in Zvornik or Bratunac. So I'm telling

11 you -- unless -- I did not have any information about any systematic

12 murders nor did I know at the time that they had occurred. I went to the

13 UNPROFOR base, aware that there had been some incidents, I had spoken

14 about that. Aware that there had been some killings, I already had some

15 information about the killings in the school, in the Konjevic Polje road

16 and about this one at Kravica. So this document did not encompass those

17 incidents, but the systematic killing and the fate of those people was not

18 something that anybody had any information about. I don't know, I'm not

19 claiming so, but I don't believe they were all killed on the 16th. I

20 don't have information to that effect to this very day.

21 Q. Mr. Deronjic, by your own admission today, by the 16th you had

22 learned from Borovcanin, who was a close personal friend of yours, someone

23 that was from Bratunac, albeit wasn't working in Bratunac but was there

24 during that period of time, you had learned about the incident in Kravica

25 that happened on the 13th. Correct?

Page 6228

1 A. Correct. And I said that. You have that. That's already

2 described.

3 Q. Would that not be an incident?

4 A. Would that not be an incident? I don't understand what you're

5 saying. It's a crime.

6 Q. Okay. It's a crime. Thank you. That was the -- I wanted you to

7 fill in the blanks. So you knew of one particular crime. Right?

8 A. Yes.

9 Q. And you also knew that there were other crimes, though you say you

10 didn't know that they were "systematic." But nonetheless, those would be

11 incidents, would they not?

12 A. Yes, I have said that.

13 Q. So now -- at least with even your very limited knowledge which you

14 claim to have had at that time, it would appear, it would appear, would it

15 not, that this paragraph here, as was drafted by you with the help of a

16 jurist, was utterly and completely false?

17 A. You are talking about limited knowledge, and you're talking about

18 it in an ironic way. This is the only knowledge of it I had at the time,

19 and these were the only incidents or crimes, whatever you like, which had

20 taken place at that point in time. But that -- they do not reflect the

21 essence of the tragedy which took place later. You know and we all know

22 today that about 7.000 people were systematically killed. Are you

23 claiming that this was happening in Bratunac in the same way this was

24 happening in Zvornik. If you have that information, fine; but I don't

25 have that information. So I knew that there were individual killings as

Page 6229

1 well as major killings at the time when I was drafting the documents. But

2 we're talking about the separation of men from the group of civilians in

3 Potocari. In this paragraph, that should also be contained. And this is

4 why I'm saying that this is not a correct document, or rather, the

5 paragraph as part of this document is not correct.

6 Q. Okay. If we could just move on now, go back to the rest of your

7 statement. We're still on 16th December 1997. So I'm going back to the

8 same document that we were looking at yesterday, and that's D92/1 for

9 identification purposes. That is your first encounter with the Office of

10 the Prosecution. You were then asked -- you then indicate that the

11 treatment of Muslims employed by UNPROFOR was also your job, and you say:

12 "I was ordered by Radovan Karadzic that Muslims in the forces of UNPROFOR

13 have amnesty and can go in any direction."

14 Was that a truthful statement, yes or no?

15 A. Yes.

16 Q. Okay. So you granted them amnesty and you allowed them to go

17 wherever they wished?

18 A. Yes. They asked me at the UNPROFOR base what would be their fate.

19 I called President Karadzic. We discussed it, and he said they could go

20 freely wherever they wanted. And the majority of them, as far as I know,

21 opted to go with UNPROFOR.

22 Q. All right. Further down in your statement you were asked about,

23 from Mr. Ruez -- you were asked a question by Mr. Ralston. This is on

24 paragraph 5. I don't have the exact -- paragraph 5, I believe, page 3.

25 You were asked: "You say you escorted 10.000 of a population of 60 to

Page 6230

1 70.000 people from Srebrenica. What happened to the rest?"

2 Then you give this rather convoluted answer, where you basically

3 don't answer the question. Could you look at that and tell me whether

4 your answer that you gave is correct. If you could just read it, and then

5 we'll go over it.

6 MR. McCLOSKEY: Objection. Argumentative, Your Honour. It's

7 unnecessary to throw-in adjectives of what he thinks of the answer. It's

8 just going to create more problems.

9 JUDGE LIU: Well, maybe you could rephrase your question,

10 Mr. Karnavas.


12 Q. If you could look at the -- look at your answer.

13 A. I have read it.

14 Q. Okay. Now, is that a truthful answer as far as what happened to

15 the rest of those people?

16 A. I was in possession of all of this information at that moment, and

17 I think that what I said here is accurate. I was referring to the

18 movement of the soldiers from Srebrenica towards Tuzla. I had information

19 that elements of the Muslim army had surrendered to the Serbian army,

20 elements managed to break through to Gorazde. The fact that I mentioned

21 Ms. Rehn, this is also correct. At one point she paid a visit to her

22 brother, I think it was in the autumn of 1995. And she expressly asked to

23 be taken there and to learn how many people had been killed in the field.

24 She wanted to see it for herself, and I personally was present in the

25 field with her. So this information is also accurate. With your

Page 6231

1 permission, I should like to comment the question of Mr. Ruez. He's

2 talking about 50 to 60.000 --

3 Q. Excuse me. If you could just answer my question, and if the

4 Prosecutor wishes to ask you to expound on your answers with respect to

5 Mr. Ruez, you'll have an opportunity. But my question here is directly:

6 Are you stating that in 1997 -- as of 1997, you did not know about the

7 massacres?

8 MR. McCLOSKEY: Excuse me. Just to clarify, which is some

9 confusion that may add to the confusion. The JR in this particular

10 interview is John Ralston. I think that maybe could cause some more

11 confusion.

12 JUDGE LIU: Thank you.


14 Q. I'm particularly interested to know, Mr. Deronjic, that when you

15 gave the statement back on December 16th, 1997, two years after the

16 incidents in Srebrenica, as of that time you were still unaware of what

17 had happened to all the people that had disappeared?

18 A. No. That is not correct. I was aware of quite a few things.

19 Q. Okay. Were you aware that there had been instances of systematic

20 killings?

21 A. Yes, yes.

22 Q. Okay. So why -- may I ask, or why was it that you could just not

23 tell him that I heard that they were systematically killed? Why not be

24 straight instead of saying some fell in the hands of the Yugoslav army,

25 there were -- others were fighting, and then go on about going to see the

Page 6232

1 dead in the fields, and then asking the International Community to help

2 dig up graves. Why go through all of that and not just say, you know

3 what, there was a -- they were massacred, there were systematic killings,

4 I wasn't involved. I heard about it. Why not say that?

5 A. Yesterday I tried to answer this question. Of course today you're

6 talking about it in a courtroom and you are forgetting a simple fact that

7 this took place in 1997. Today if I were to live in Bratunac with four

8 children, I don't know if I would be able -- I would dare to say that. In

9 particular in view of the circumstances at the time. I mean the general

10 climate was hysterical when it came to the Tribunal. And this can still

11 be felt in some parts of Yugoslavia Bosnia and Herzegovina. At the time

12 to say that would mean to expose oneself to a great risk, a great danger.

13 The Prime Minister Djindjic was assassinated by a group of people who were

14 attempting to prevent, to obstruct cooperation with the Tribunal. And now

15 you're asking me how it was that I did not say that in 1997.

16 And yesterday I expressly told you that I had not said everything.

17 Let me please finish. There is a much more important motive that I had in

18 mind at the time, and that was to remain alive and for my family to remain

19 alive, hoping and knowing that one day I would have an opportunity.

20 Because as soon as I was summoned, I realised that I would have an

21 opportunity to talk about these events in the manner that I described --

22 in the manner that I did in my last interview. Do you need more examples

23 of that?

24 I mean, yesterday I talked about it. I told you that I have been

25 followed, that I had threats from various sides, that I had been warned

Page 6233

1 directly as to what I should be saying. These are not just stories. I

2 can provide hard evidence to support this. I'm not going to waste any

3 more of your time for that. I will just state once again that for reasons

4 of security, my own security, and the security of my family, I did not

5 dare to address the most sensitive issue.

6 And just one other thing. Not even today the government -- is the

7 government of Republika Srpska capable or willing to investigate or to

8 disclose the entire truth about Srebrenica. Not long ago, I read a report

9 that was composed on behalf of Republika Srpska upon request of Mr. Petric

10 [phoen] which report is full of misinformation and false --

11 Q. Mr. Deronjic, you met with the Office of the Prosecution on

12 February 4, 1998. You met with them on 21 October 1995. You met with

13 them before that on July 1, 1998. You met with them --

14 A. 1995 you say?

15 Q. I'm sorry. You met with them on February 4, 1998. You met with

16 them on July 1, 1998.

17 A. You said 1995 --

18 Q. I apologise. You met with them on October 21, 1999. You met with

19 them on 12 March 2001. On any of those occasions -- during any of those

20 occasions were you truthful about the knowledge in your own participation

21 about the events in Srebrenica, yes or no? Did you disclose, I know about

22 the massacres, I know what happened? Did you ever say that?

23 A. No, no, I did not tell the entire truth.

24 Q. Now, when you say you did not tell the entire truth, let's not

25 quibble over semantics. You were giving false information, right? Half

Page 6234

1 a truth is equal to half a lie, is it not?

2 A. You can call it the way you like.

3 Q. Okay. Now, if we go on to this statement, because we're using

4 this as the context for what happens later. You were asked specifically

5 if you observed male population being separated from the female

6 population. And you say, and I'm going to -- I'll read the answer and

7 then we're going to talk about it: "They had some access in one convoy

8 because the military police tried to separate some people they recognised.

9 One representative of local parliament of Srebrenica. We did not have

10 enough force to stop separation. The commander of the army refused. He

11 with some others were in the hands of the army. For this single person, I

12 know he was exchanged for a Serb commander, who was in the hands of the

13 Muslims. As far as I know, one of these -- for others you have to check

14 with the army."

15 Then you go and state: "On my intervention and the intervention

16 of UNPROFOR, after that such things didn't happen. UNPROFOR said they

17 wouldn't participate in the evacuation if that happened. The destiny of

18 the other people is unknown to me. You will have to ask the army. It was

19 a small number of people."

20 Mr. Deronjic, were you being truthful when you said that you had

21 an -- that you intervened?

22 A. Yes, yes.

23 Q. Okay. And when you say that you intervened, with whom did you

24 intervene?

25 A. I said in the interview, in the last interview, you can find it

Page 6235

1 there, then the information had been conveyed to me by Vasic. I wanted

2 him to go and fetch Mladic and tell him not to do that. In the meantime,

3 and you have just reminded me of this. From the UNPROFOR headquarters I

4 received a phone call in my office, they told me that separations were

5 taking place. And this is exactly what they said, they intervened -- and

6 actually they wanted me to intervene. And I told Vasic, Mr. Vasic, please

7 go and find Mladic. Because I myself did not go to Potocari. Go find

8 Mr. Mladic and tell him not to do that, which you can find in my last

9 statement, in my last transcript.

10 Q. Given your position as the president of the SDS, you had access to

11 a vehicle, did you not?

12 A. Yes, I did.

13 Q. And in fact you even had a driver, did you not?

14 A. Yes. At that time I did. However, during the war I did not have

15 a driver.

16 Q. During that period of time, you had a driver. We're talking about

17 those days. Work with me, on those days?

18 A. Yes.

19 Q. And given your position, you had access to gasoline to put in the

20 car, should you wish to go someplace. Right?

21 A. Yes, of course.

22 Q. Now, Bratunac to Potocari is approximately 5 kilometres, is it

23 not?

24 A. Correct, 5 kilometres.

25 Q. Okay. And when you heard that this incident was going on, the

Page 6236

1 incidents that men were being separated indiscriminately from their loved

2 ones, you never made an effort to do anything about it, other than,

3 according to you, tell Vasic, who was from Zvornik, to talk to Mladic.

4 Correct?

5 A. Correct.

6 Q. Yet, according to your mandate, pursuant to you being appointed by

7 the president, you were responsible for all civilian -- for all the

8 civilians there. Correct?

9 A. Correct.

10 Q. And that included also the men that were of military age.

11 Correct?

12 A. Apart from those in respect of whom our services had information

13 that they had committed crimes. Would you agree?

14 Q. I would agree with you that there was -- a wish had been expressed

15 that those war criminals known should be separated to be questioned.

16 A. Excuse me. It's not that a wish had been expressed. It was an

17 order issued by the president, an order that I conveyed to the meeting at

18 Fontana. It was not anybody's wish.

19 Q. Thank you for correcting me. So in other words, you were ordered.

20 And then, given your mandate, you were supposed to be ordering. Correct?

21 A. I was supposed to convey this information to the meeting at

22 Fontana. Those were orders issued by Karadzic and not by myself. You're

23 deliberately altering the semantics, and then you get angry with me for

24 providing additional comments. You said yourself that we should not play

25 games. I am fully aware of these issues. I know the problems. Please

Page 6237

1 bear that in mind.

2 Q. So based on that, am I to conclude that you were merely a conduit,

3 like somebody on -- doing duty. You know, he was somebody who was just

4 there to pass a message, like a duty officer. He's just passing the

5 message. Somebody's saying, do this, and then just passing on the

6 message. Is that how you were?

7 A. Well, you can draw any conclusion that you want. I was precise in

8 my description as to what I did. You may draw any conclusion that you

9 like.

10 Q. All right. Later on on that page --

11 JUDGE LIU: Well, Mr. Karnavas, it's time for a break.

12 MR. KARNAVAS: I apologise. I got lost in my questions.

13 JUDGE LIU: We'll resume at 10 minutes to 11.00.

14 --- Recess taken at 10.20 a.m.

15 --- On resuming at 10.51 a.m.

16 JUDGE LIU: Yes, Mr. Karnavas. Please continue.

17 MR. KARNAVAS: Thank you, Mr. President.

18 Q. Now, just to conclude, Mr. Deronjic, this first statement that you

19 gave. At the end of page 4 in your version you state here -- or it's

20 rather unclear, but I believe it's your statement that in fact: "Before

21 the fall of Srebrenica they," that is the Muslims, "had a 24-hour

22 guarantee by Mladic for those not fighting would be allowed to leave

23 freely, but only a small number of Muslims of Muslim military accepted

24 this proposal."

25 According to this document, this is what you told Mr. Ralston back

Page 6238

1 on 16th December, 1997. Did you, in fact, make that statement, yes or no?

2 A. Excuse me. Are you referring to the same document? What page,

3 please.

4 Q. Page 4, last paragraph -- it should be paragraph 11 by our count,

5 on that page.

6 A. I cannot find it, but I believe that those are my true words. I

7 do not wish to waste too much time looking for it, but it's true that I

8 stated that.

9 Q. Okay. Now, was that -- was that an accurate statement, that

10 Mladic had given a 24-hour guarantee?

11 A. Yes. That is an accurate statement. At the meeting held at

12 Fontana on the 12th. This is what he offered to the Muslims.

13 Q. Okay. And I think we established yesterday that you were not at

14 that meeting when that was offered?

15 A. No, I was present. We're talking about the 12th. This is what he

16 presented to the Muslims on the 12th at the meeting which I attended.

17 Q. So that would have been around the noon of the -- midday on the

18 12th. That was the only meeting that you attended and it's your

19 recollection that's when Mladic made that offer?

20 A. That was the only meeting of that kind, yes. And it was at that

21 time that Mladic made that offer.

22 Q. Now, have you had an opportunity to review or to view the video

23 that was prepared of that meeting? I believe there is some video footage

24 of that, is there not?

25 A. Yes. I've been told that there is a video footage. I have not

Page 6239

1 had an opportunity to see it, but I did see portions of the transcript

2 from that meeting.

3 Q. Portions of the transcript of the meeting. I'm a little confused

4 now. Was somebody taking minutes of that meeting, notes, and then

5 formulated a transcript as a result of that?

6 A. No. I'm referring to the transcript of the video footage of the

7 meeting.

8 Q. And was that provided to you as part of the disclosure material,

9 or was that information that you gathered through your sources, be they at

10 the Detention Unit, from other detainees, or in the field as you were

11 doing your own investigation trying figure out what really happened?

12 A. No. I was never in possession of that document, nor did I find it

13 as part of any investigation. I was merely shown the document, not long

14 ago, actually, two or three days ago, as part of the disclosure.

15 Q. You were shown by the Office of the Prosecution or by --

16 A. Correct.

17 Q. Okay. All right.

18 A. To be precise, I wanted to know whether such a document existed.

19 I wanted to know what exists on paper to that effect, and the Prosecutor

20 provided me with this material. I just wanted to check whether I was

21 correct in my interpretation of what was said at the meeting. This, like

22 I said, took place two or three days ago.

23 Q. Okay. That's rather interesting. I read the proofing notes. I

24 don't see - and I might be wrong, I might have missed it - anywhere where

25 it states that this was provided to you by the Office of the Prosecution

Page 6240

1 for you to review. Was that -- I could be wrong, but --

2 JUDGE LIU: Yes, Mr. McCloskey.

3 MR. McCLOSKEY: I'm pretty sure it's in there. If he doesn't

4 know --

5 MR. KARNAVAS: That's fine.

6 MR. McCLOSKEY: I'll take a look.

7 JUDGE LIU: Thank you.

8 MR. KARNAVAS: I'll accept Mr. McCloskey's word for it.

9 Q. All right, if we could move on to the next statement that you

10 gave, this was on February 4, 1998. This was approximately three months

11 after your first encounter with someone from the Office of the

12 Prosecution. Correct?

13 A. I'm sorry. I didn't hear your question.

14 Q. Three months after your initial meeting with someone from the

15 Office of the Prosecution, you had your second meeting, this time with

16 Mr. Ruez. Correct? And for the record, I'm referring to D93 --

17 A. Yes. February the 4th, 1998. Yes, I've just got the transcript

18 of the interview.

19 Q. Okay. Now, at that point in time -- by that point in time, you

20 had -- you were aware of the areas in which the Office of the Prosecution

21 were interested in with respect to you, that is. Correct?

22 A. Partially correct. I was aware of the main topics that were to be

23 discussed -- that had already been discussed, actually.

24 Q. Right. And in fact, the main topic was Srebrenica, not Glogova,

25 for which you were ultimately indicted for. Correct?

Page 6241

1 A. Yes. In this particular interview, the following one, the main

2 topic was Srebrenica. But I have to say in the practice of the Tribunal

3 and their investigation teams, there is no procedure whereby I would have

4 been informed in advance about what would be discussed. So the issue of

5 Glogova could have also been included and everything else that was

6 interesting for them.

7 Q. I understand that. But by this point in time you had three months

8 at least to gather your thoughts and prepare yourself, at least mentally,

9 for the interview with Mr. Ruez. Correct?

10 A. Yes. Three months had gone by between those meetings; that is

11 correct.

12 Q. And Mr. Ruez did not show up unannounced. You were informed in

13 advance of when he would be coming to have an interview with you?

14 A. Correct. But that does not leave much room. You usually get

15 about five or six days prior to the meeting.

16 Q. Right. Now, Mr. Ruez began the interview by informing you - and

17 this is on page 1 of the English transcript, and it's also on page 1, line

18 14 to 15, in the Srpski version - that your statement would be recorded

19 and, I quote, "might eventually be used as evidence during the proceedings

20 at The Hague Tribunal."

21 A. Correct.

22 Q. And -- so at least at the beginning of that particular interview,

23 which is your second encounter, you knew for a fact that what you were

24 saying would eventually or could eventually be used in a legal proceeding.

25 Right?

Page 6242

1 A. Correct. You can see that I said "proceedings against whom," but

2 I was a little surprised. But I understood what it was all about.

3 Q. Right. And I would suspect that you also understood the

4 importance of being truthful, honest, and complete in your answers, now

5 that you had been forewarned by Mr. Ruez that anything you had said, even

6 though you were still under the title of witness, might be used in a legal

7 proceeding. Correct?

8 A. Correct.

9 Q. All right. Now, the interview begins by you describing your

10 various positions in your background in politics. That's on the second

11 page, but we will skip that because we're going to deal with it later on,

12 if that's okay with you. So we're rather focused now -- our attention on

13 page 3, and we're going to go back to some of the information that we've

14 already covered. On this occasion, and I'm reading -- in your version it

15 would be page 3, lines 14 all the way into page 4, line 4. In the English

16 version, it begins at line 22, page 3. You say: "I have learned about a

17 decision taken by President Karadzic through the mass media. Some of my

18 friends heard that news on the radio and they told me about it. At that

19 very moment, I was staying at the front line, together with the soldiers.

20 I asked permission to leave and to go to the command in order to get in

21 contact" --

22 A. Excuse me. It does not say -- it does not say: "I asked

23 permission," but it just said: "I decided to go to the command. Who

24 should I ask the permission from."

25 Q. Well, let me read the English version and then we will see. It

Page 6243

1 states here: "I asked permission to leave and to go to the command in

2 order to get in contact with President Karadzic and we had a telephone

3 conversation."

4 Now, I don't know whether there's a mistranslation, but it's fair

5 to say that you didn't need to ask anyone for permission because you were

6 the highest authority in Bratunac at that time. Correct?

7 A. No, no, that's not correct. Allow me to go back to something that

8 you keep repeating; it's an assertion. It's very important. Please allow

9 me -- it's very important for me to explain this to you. You, sir, you

10 keep using an assertion, and I am patiently waiting for the moment to

11 respond with my counter arguments. You're suggesting my power, you're

12 attaching important to the function I was carrying out at the time in

13 Bratunac. I will be very brief and I really do not want to be malicious

14 in the least at this point. You are an educated man, and we know we can

15 discuss the phenomenon of power until tomorrow. You know that it is the

16 subject of various scientific research, so let's not talk about it. There

17 are serious studies about this phenomenon. Please allow me to explain.

18 Allow me to explain. You are saying --

19 JUDGE LIU: Mr. Karnavas, give the opportunity to the witness to

20 explain.

21 MR. KARNAVAS: I will, Your Honour, I merely wanted to say in the

22 next segment we will be covering his background in the greatest of

23 details, specifically as to his powers. Now, I don't mind the

24 explanation, we're just going to have to do it again all over later. So

25 we will get to it.

Page 6244

1 THE WITNESS: [Interpretation] I agree. I absolutely agree, I

2 would just like to have this opportunity. I'm patiently waiting for such

3 an opportunity. I'm just afraid that I will not be given the chance, but

4 please continue. I apologise.


6 Q. We will cover it. I have a whole line of questions on that.

7 In any event, based on this particular statement that I just read,

8 it would appear that you had to ask permission. Now, you were questioned

9 by Mr. Milosevic not too long ago. Do you recall that occasion?

10 A. Of course. I remember that he questioned me. I don't remember

11 each detail. I didn't have the opportunity to look at the transcript.

12 Q. I have the official transcript here, and I want to quote the

13 question and answer. And this can be found on page 29.682 -- no, 29.682.

14 So that's 29.682. This was on Wednesday, 26 November 2003. And I'm

15 reading from line 19 where Mr. Milosevic asks you: "You say that

16 Vidoje Blagojevic, commander of the Bratunac Brigade, ordered to you to go

17 into Srebrenica. That is in paragraph 184 - on the 11th of July." And

18 incidentally I'm told for the record this should be marked as P692 or this

19 is marked as P692 for identification.

20 And your answer to that question was: "Yes."

21 Now, we'll get to paragraph 184 of your statement. But from this

22 answer, it would appear that you're suggesting that Mr. Blagojevic ordered

23 you to go into Srebrenica. And since this is part of the record that's

24 coming in, all these documents, I would like a clear answer. The fact is

25 Mr. Blagojevic never ordered you to go into Srebrenica; isn't that a fact?

Page 6245

1 A. Allow me, please, if you have this version in Serbian, then I

2 would like it to read it in the context. I'm not sure whether the

3 translation is correct or whether what you're reading is quite correct.

4 So if I may be given the opportunity to look at the transcript in Serbian

5 and I will reply, just to be sure whether everything is as it is.

6 Q. Regretfully the Tribunal, for whatever reason, doesn't do a

7 Serbian version of the proceedings. We have the English version, so this

8 is from the actual transcript. Now, I do -- I can provide you with

9 paragraph 198 [sic] of your statement, but the question that Mr. Milosevic

10 posed to you, and I'll read it in context. You say that: "Vidoje

11 Blagojevic, commander of the Bratunac Brigade, ordered to you to go into

12 Srebrenica - that is in paragraph 184 - on the 11th of July.

13 "A. Yes.

14 "Q. But you found out on your way to Srebrenica that Karadzic was

15 looking for you?

16 "A. Yes.

17 "Q. That's why you didn't go into Srebrenica, you returned to

18 Bratunac instead?

19 "A. Yes."

20 Now, if we -- that was your answer, your answer was, yes,

21 Vidoje Blagojevic ordered you. So we have a clear understanding.

22 A. Yes. I can't comment on that. I'm not sure whether the

23 interpretation is correct or perhaps I did not understand Mr. Milosevic's

24 question very well. It's possible that there's a mistake there. In the

25 transcript -- I mean in my interview to the Prosecution, I described that

Page 6246

1 encounter on the 11th as just a chance encounter with Mr. Blagojevic. And

2 I said that I had heard from him that there was an order to enter

3 Srebrenica, not that he had ordered me. That is not true at all. And

4 perhaps if I had understood Milosevic's question wrongly, I would like to

5 correct myself. It's possible that there's also a mistake in the

6 interpretation. Perhaps we can establish that at some other time.

7 So I did meet with Mr. Blagojevic, just by chance, during the

8 entry to Srebrenica in the area of Pribicevac. And he said that there was

9 an order issued to enter Srebrenica, but this order did not refer to me.

10 And the time I was not a member of his units. We just briefly commented

11 on that and set out practically together towards Srebrenica. That is the

12 correct answer. I really don't know how this came about. Perhaps I had

13 made a mistake in relation to Milosevic's question, or perhaps it's a

14 translation mistake.

15 Q. Okay. Well, I wanted to clarify that, because in paragraph 19 --

16 184 of the -- of your statement called Witness Statement, it's dated the

17 26th of November, 2003, you do state, in fact, that: "Vidoje Blagojevic,

18 commander of the Bratunac Brigade, was there and advised us that the order

19 had been given to enter Srebrenica."

20 So I just wanted to clarify that, that at no point in time

21 Mr. Blagojevic had ordered you to --

22 A. I agree, yes.

23 JUDGE LIU: Mr. Karnavas, I think this is a very important piece

24 of the evidence, but I believe that the witness and you have some disputes

25 concerning with the translation of that paragraph. So in this way I would

Page 6247

1 like to ask the Registrar to inform the translation unit to check both the

2 English and the B/C/S translations in the Milosevic case on that section.

3 MR. KARNAVAS: That's fine, Your Honour. And for the record, I

4 believe I was just quoting from what has been marked as P693.

5 Q. Okay. We clarified that issue. Now, if we were to go further

6 down on that same page, you state: "Since it was already the nighttime

7 when I learned about this, I've asked him to meet," meaning Karadzic,

8 "I've asked him to meet me in the course of the following day so I can get

9 some closer instructions in relation to my new function and my new

10 obligations. In the course of the following day, I had a meeting with

11 Mr. Karadzic in the building of the Presidency in Pale."

12 And then you go on to explain what had occurred, you know, the

13 instructions that you were given, which we've already talked about. So

14 here it seems that you're stating that you did not, in fact, go to Pale on

15 the 11th, but rather in the course of the following day.

16 A. We explained yesterday that there was a confusion about the dates

17 and that this is not correct. I said that. I did not go the next day

18 either, but in later checks I determined that I actually went on the 14th.

19 I can describe to you exactly how I came to this information that I was at

20 Pale on the 14th. So if you're interested, I can explain that.

21 Q. We're going to get to the 14th, because that relates to the events

22 of the 13th. But if you did not go to Pale on the 11th, then you must

23 have been in Bratunac on the 11th. Correct?

24 A. On the 11th I was at Pribicevac; that is correct. On the 11th in

25 the afternoon, I found out that I had been appointed to some function in

Page 6248

1 Srebrenica. On the 11th in the evening, I was at the command and I spoke

2 with Karadzic. This is the correct information.

3 Q. And the command post is located in Bratunac, in the city of

4 Bratunac?

5 A. The brigade command was in Bratunac.

6 Q. Okay. And so you would have been in Bratunac that evening,

7 afternoon and evening. Correct?

8 A. Correct.

9 Q. Now, your office, the office that is of the party of the SDS, was

10 also in Bratunac, was it not?

11 A. Correct.

12 Q. In fact, it was in the centre, in the heart, of Bratunac?

13 A. Everything is in the centre there, because there is nothing beyond

14 that. Yes, that's correct.

15 Q. Exactly. And the Hotel Fontana is also in the centre?

16 A. Correct.

17 Q. How long would it take you to go from your office to the Hotel

18 Fontana?

19 A. Ten -- five minutes.

20 Q. Five minutes. And I take it your office, being the president of

21 such an important party, probably had windows?

22 A. Yes.

23 Q. So you could look out, see what's going on?

24 A. I could not see at the Fontana -- I mean, there is no -- it's not

25 possible -- there was no view out on that part of the street, but you

Page 6249

1 could see on to the street, yes.

2 Q. But my question wasn't whether you could see the Hotel Fontana, my

3 question was whether you could look out and see. Right?

4 A. Yes.

5 Q. Now, on that particular evening -- afternoon/evening, there were

6 two meetings in the Hotel Fontana. Correct?

7 A. I don't know that. I have some information about that, but I

8 don't know how much and with whom these meetings on the 11th in the

9 evening were held.

10 Q. Well, I'm not asking you if you knew back then; I'm asking you if

11 you know now. We'll get to what you knew back then.

12 A. It seems like I had the opportunity to see later. It was

13 determined unequivocally that there were meetings at the Fontana on the

14 11th in the evening.

15 Q. Okay. And during that period of time you had Mladic in Bratunac.

16 Correct?

17 A. He was in Bratunac.

18 Q. Okay. And his fairly large and quite visible entourage?

19 A. Yes.

20 Q. And you also had General Zivanovic?

21 A. I don't know that really. I did see him at Pribicevac, but I

22 don't know whether he was in Bratunac at that point.

23 Q. At that point in time, he was nonetheless - as far as you knew -

24 the commander of the Drina Corps?

25 A. That information is unclear. To this day it's not clear to me

Page 6250

1 whether he was de facto or de jure replaced and when Krstic was appointed.

2 But it's clear to me that he was at this important post.

3 Q. Well, I'm talking about de jure, because in that we can see with

4 some clarity that we don't have a decision from Karadzic until, I believe,

5 it's the 12th or the 13th. But on this particular day, on the 11th, he's

6 still the commander, is he not?

7 MR. McCLOSKEY: I'm sorry --


9 MR. McCLOSKEY: That's inaccurate. The order from Karadzic was

10 not on those days, just to clear up the record.

11 MR. KARNAVAS: It was actually later, but that's fine. I'm giving

12 him some leeway. I'm erring on the side of caution, Your Honour.

13 Q. He was, right?

14 Now, also there was General Krstic. Right?

15 A. I said I had no information about whether they were in Bratunac or

16 not. Both of the people we are talking about, I knew they were at

17 Pribicevac. I saw Zivanovic only at one point, to be more precise, and

18 Mr. Krstic was at Pribicevac. Whether on the 12th or the 11th in the

19 evening he was at Bratunac, I didn't have any information to that effect

20 at the time.

21 Q. Would it be fair to say, Mr. Deronjic, that on that particular

22 afternoon and evening, Bratunac was swarming with members of the VRS, and

23 I'm talking about VIP members, officers from the Main Staff, officers from

24 the Drina Corps? And they were quite visible.

25 A. I don't know whether they were at certain points in time. Of

Page 6251

1 course I know -- I know today precisely that they were all there somewhere

2 nearby, but whether that afternoon or that evening and at what time they

3 were in Srebrenica, you know that Mladic entered Srebrenica. I assume

4 that a certain number of officers were with him in Srebrenica, that they

5 had some sort of speech up there, that this was taped, that there was some

6 kind of ceremony conducted up there. I assume that they spent some time

7 at the UNPROFOR base. At what time they came to Bratunac, entered the

8 Fontana, left the Fontana, that I don't know because it's not possible to

9 see from my office because the building on the side is completely shielded

10 and the entrance to the Fontana, to the parking, is from a side street

11 which is not visible at all from my office.

12 Q. So while all of this was going on in Bratunac - and I might add,

13 it was quite a festive occasion, the fall of Srebrenica - you were holed

14 up in your office, totally secluded from what was going on in this town

15 which you described as small, and almost the entire town is the centre?

16 A. Absolutely correct. I was in my office. The rest of the evening

17 I spent in my office, not alone of course, but in the presence of my close

18 associates from the municipality, including some people from the police.

19 I cannot remember exactly who was there in my office on that evening.

20 Q. And I take it had you known, had you known that Mladic was going

21 to be meeting with representatives of UNPROFOR and then later on with

22 representatives from both UNPROFOR and the Muslim community that was in

23 Potocari, you as president of the SDS would have at least made a cameo

24 visit, presence, in those meetings?

25 A. No, I would not. I would not have appeared unless Mladic invited

Page 6252

1 me.

2 Q. Okay. But you already had spoken to Karadzic and you already knew

3 your function and you already knew that based on the orders from the

4 president, who was also the supreme commander of the VRS at the same time,

5 that part of your duties, part of your mandate, was the security and well

6 being of all of those that were in Potocari. Correct?

7 A. Correct.

8 Q. So in spite of that heavy burden that had been placed upon you by

9 none other than the president and the supreme commander, as you sit here

10 today you're stating that even had you known that a meeting was taking

11 place five steps away from your office, you would not have attended. That

12 is your testimony?

13 A. Yes.

14 Q. Okay. Now, if we could fast forward a little bit, but you may --

15 A. Wait, wait. I am expecting you to continue so that we can clarify

16 that. In a conversation with Karadzic on the 11th in the evening, I

17 suggested to the president to convey to Mr. Mladic that he should get in

18 touch with me because it seemed really impolite to me, and I was not in a

19 position to find him or to get in touch with him or to oblige him for any

20 kind of meeting, which Karadzic to a certain degree accepted and said,

21 very well, we'll see about that. I did not return to the office to waste

22 my time there for no reason, but we were trying to have a meeting at the

23 office with the people who happened to be there. I already said that I

24 was trying to get in touch with Mladic. At that point in time, it was

25 difficult to find where he is and to get in touch with him. So I

Page 6253

1 concluded that he would -- in any case, he would call me, that he would

2 get in touch with me regarding the orders that I had from Karadzic, and

3 this happened on the 12th, in the morning.

4 Q. Okay.

5 A. I just expanded on this because you are simplifying this, just so

6 that you would have a more complete picture about it all.

7 Q. I'm going step by step, Mr. Deronjic. We're going to get to that.

8 But I just want to fast forward to another statement regarding the same

9 issue here. And this is your statement that was given to you on

10 21 October 1999, which I believe is marked for identification purposes as

11 692.

12 Now, before I make reference to the particular section, let us

13 remind ourselves that in between the interview that you had with Mr. Ruez

14 on February 4, 1998, and this interview on October 21, 1999, there was an

15 attempt by Mr. Ruez to have another statement from you back on July 1,

16 1998. And that -- I'm referring to what has been marked for

17 identification purposes as D94/1. Do you remember that encounter? That

18 was the one time you were informed that you were a suspect. Right?

19 A. I remember most of those meetings, more or less, but I cannot say

20 that I remember the contents without the transcript. I didn't really

21 study them at any point, so if you can provide me with a statement, yes, I

22 can comment on it.

23 Q. But yesterday we did establish that when you met Mr. Ruez for the

24 second time and you learned that you were a suspect, you made particular

25 inquiries as to what specific portions of your previous statement, what

Page 6254

1 elements of that previous statement, were responsible for the changing of

2 your status. Correct?

3 A. Yes, it was naive of me to ask.

4 Q. It couldn't hurt, right? Who knows, maybe another investigator

5 might have been willing. But as a good investigator, he did not. And

6 you, wanting to protect your own rights, not knowing what might be lurking

7 out there, what dangers you might be placing yourself into, decided not to

8 give a statement, as was your right. Correct?

9 A. Yes. I think that is correct. I should perhaps like to refresh

10 my memory with respect to that, but in principle I agree with what you

11 say.

12 Q. Okay. So the next encounter after July 1st, 1998, is October 21,

13 1999. And I take it during that period of time, knowing now that your

14 status had changed from witness to suspect, surely you must have taken

15 some steps to learn as much information as you could so that in the next

16 encounter, might there be one, you would be able to provide explanations

17 that would somehow lift this burden from you, that is the status of

18 suspect. Correct?

19 A. If my memory serves me right - and you've just reminded me of me

20 that - I undertook a number of steps. One of them being cancelling the

21 power of attorney of my lawyers. I informed Mr. Ruez of this formal

22 cancellation, and I told him that I would give the next statement alone,

23 on my own. I'm not going to give you the reasons. I assume there is

24 information circulating around to that effect, but that's not important.

25 Second, I decided not to give any interviews in any official

Page 6255

1 offices, official premises, which I suspected of being taped, and I

2 suggested that the next interview be held in Bratunac, which Mr. Ruez

3 accepted. I wanted to be sure that the meeting would not be taped and that

4 information would not leak from that meeting. So this is the next step

5 that I took, if we are talking about the same meeting, and I think we are.

6 And Mr. Ruez agreed with me because I had drawn his attention to the issue

7 of security during the breaks and to the information, which in my opinion

8 had to remain protected. So I did whatever I could in order to learn as

9 much as possible regarding those events, but I have to say that this was

10 not easy. It's not even easy today, let alone at that time. But mainly,

11 for reasons of security, I made an effort to learn as much as possible.

12 To what extent I was successful, I don't know.

13 Q. Okay. And in fact when Mr. Ruez begins the interview, after the

14 initial formalities - and I'm quoting from page 2, lines 6 to 7 in the

15 Srpski version; lines I believe it's 9 to 11 in the English version -

16 Mr. Ruez begins by asking you or by stating: "I assume you studied it."

17 Okay. Let me wait. And in fact, I'm going to go back up a couple of

18 lines. Page 2, if you could -- I'm going to start with line 2 to 3. And

19 in the English version it would be line 6, page 2 -- line 5.

20 Mr. Ruez says: "Perfect. So it's now 1.26 hours and we are going

21 to start our interview. I don't intend ask you at this point questions.

22 I provided you last time the transcript -- the draft transcript of the

23 first interview that we had together."

24 And then he goes on to state -- apparently he's shown you or

25 you've shown him the transcript.

Page 6256

1 "Yes, this one. I assume you've studied it attentively and maybe

2 now you want to make some comments on what you said at that time. Feel

3 free to discuss whatever you want about the content what you have already

4 said to me."

5 Do you recall Mr. Ruez making that comment to you?

6 A. Yes.

7 Q. And I take it at that point in time when you were having this

8 interview you had indeed studied attentively your previous statement in

9 order -- in preparation for this particular interview. Correct?

10 A. How it worked in practice was that he was supposed to bring this

11 with him. I don't know exactly when it was I received the transcript, but

12 yes, I agree with your statement.

13 Q. I want to make sure that Mr. Ruez was fair with you. And it would

14 appear to me from reading this that he was indeed very fair. Because in

15 advance he gave you, as he had promised from before, a full translated

16 transcript of your interview so you could look at it, study it, maybe even

17 conduct some investigation, so on the next encounter you could be as

18 precise and as truthful as honest and as complete as you could be. Right?

19 A. Yes.

20 Q. And of course you knew now even more importantly than before,

21 since now you were a suspect, that everything that you said might be used

22 at The Hague at some later point, if not against you, perhaps against

23 somebody else. Right?

24 A. Yes.

25 Q. And if we are to go on into page 3 of your statement, you

Page 6257

1 indicate - and I'm referring to a portion, it's around line 21 to 26. In

2 the English version it's around 21. I'm not going to quote it completely,

3 but if you look at it it states that you began to formulate a chronology

4 of the events. Correct?

5 A. Page 3?

6 Q. Page 3. I believe it should be on line 21 to 26. You state, and

7 I'll read the English version. "Actually, what I warned you last time,

8 expressed you last time we have a meeting, that I was unprepared for that

9 meeting in the sense of dates and chronology of the events, because I

10 never dealt with any kind of writing of the chronology during the time in

11 question, but after, following our talks, I took it more seriously and

12 more seriously I checked certain dates, but I have to say people are very

13 much unwilling to talk about this. It is very hard to check such things

14 in the archives of the police or the army. So I mainly used some friendly

15 connections, and based on the recollections of those people, we made a

16 chronology, a certain chronology, of the events."

17 Do you recall making that statement?

18 A. Would you kindly read on, please. If anything is not 100 per cent

19 sure, I should like this to be admitted as well. But I think --

20 THE INTERPRETER: The interpreters cannot find the portion that

21 the witness is reading.


23 Q. Mr. Deronjic, I will get to that. I'm just trying to lock you

24 into your position step by step, korak po korak, to use your language.

25 Step by step we're going to get there --

Page 6258

1 A. But please --

2 Q. Mr. Deronjic, did you make that statement that you and your

3 friends made a chronology, yes or no? That's what I'm interested in.

4 A. You cannot take a sentence out of the context of the entire

5 passage and have it have the same meaning. I hope that this chronology

6 would be clear one day and that we would have an opportunity to issue --

7 to state our position with respect of that. So I think that I was in a

8 position to state the chronology of the events at the time. But you must

9 admit, it was difficult for me because I had relied upon the contacts with

10 some friends who were willing to provide me with assistance of this.

11 Q. Mr. Deronjic --

12 A. And I may add one more point, the following sentence also. What

13 would be absolutely right are the allegations concerning segments of the

14 events. I think that this is more important now than the precise

15 chronology itself, and so on and so forth.

16 Q. Okay. Mr. Deronjic, I would grant you the right to be off on some

17 dates. You can have that, but that wasn't the purpose of my question.

18 Okay? Whether the allegations are more important than the chronology,

19 that's for others to decide. But for right now I just want a clear

20 answer. Did you and other people, your friends, your friendly

21 connections, get together in order to make a chronology for this momentous

22 occasion, that is the giving of a formal statement as a suspect to

23 Mr. Ruez, yes or no?

24 A. I talked to some people. So in regard to that, the answer is

25 affirmative.

Page 6259

1 Q. Okay. Now, may I ask, because I don't think it was asked by

2 Mr. Ruez: Who are these friendly connections? Who are these individuals,

3 and what, in fact, were they able to provide you, either in documents or

4 through their memories?

5 A. This refers to my close associates and ordinary people who were

6 able to help me at the time. First of all, Mr. Simic, Davidovic, Vasic,

7 whom I asked at one point about the chronology of these events. I did not

8 recall other people whom I asked for this assistance at the time. But

9 those were the individuals I had in mind, plus Josipovic, for instance,

10 and a number of other people from Srebrenica.

11 Q. Now, the names you just provided us, those are your close and

12 personal associates, all members of and participants in SDS politics at

13 that period of time. Correct?

14 MR. McCLOSKEY: I just want to clarify which period the interview

15 or the 1995. I think I know what you mean, but the record doesn't.

16 JUDGE LIU: Yes.


18 Q. They were your close assistants during the period of Srebrenica.

19 Correct?

20 A. Yes, I would agree with that.

21 Q. In fact, they're probably -- if I'm not wrong, they're probably

22 your boyhood friends, you grew up together?

23 A. No. No.

24 Q. All right. Were they still involved in SDS politics during that

25 period of time when you gave this interview?

Page 6260

1 A. I stated names of a number of people. I don't know who you have

2 in mind. President Simic, I don't know -- I don't think he was president

3 of the municipality any longer, nor was Mr. Davidovic. Vasic, I think,

4 was still the chief of the centre, but Kopalovic [phoen] from Srebrenica,

5 for instance, I think was no longer holder of the same office as during

6 the war. I don't know. Ask me the precise -- the specific question, and

7 I will try to respond as best as I can, if this is important at all.

8 Q. Okay. Nonetheless, these people whose names you mention, and they

9 crop up during the interviews, were prominent - and I underscore the word

10 "prominent" - members of the SDS party during the events surrounding

11 Srebrenica, the fall of Srebrenica. Correct?

12 A. No. This is not correct nor were they all members of the SDS. To

13 what extent they are prominent, I don't know; some are and some are not.

14 Q. Were they members of the War Presidency at any point?

15 A. See, I've given the names of a number of people; some were not,

16 and some were members.

17 Q. Were some of those people members of the Crisis Staff? See, I

18 adjusted my question.

19 A. You mean in Bratunac, in 1992? In 1992, the only member of the

20 Crisis Staff from the people you've mentioned was Mr. Simic. The others

21 whom I mentioned were not members of the Crisis Staff.

22 Q. During your meetings with the Prosecution, the Office of the

23 Prosecution, is it not correct that on occasion with respect to events or

24 chronology, you would ask the investigator to check with those people with

25 respect to dates, because they might be able to be more helpful. Right?

Page 6261

1 MR. McCLOSKEY: I'm going to object to vagueness at this point.


3 MR. McCLOSKEY: There's been a lot of people mentioned --

4 MR. KARNAVAS: Your Honour, I object to this --

5 MR. McCLOSKEY: People mentioned.

6 MR. KARNAVAS: -- I object. The gentleman can, can -- understood

7 the question. I'm surprised and shocked that the Prosecutor would want to

8 withhold the truth in this case. I am shocked.

9 JUDGE LIU: Mr. Karnavas, you have to allow the Prosecutor to

10 finish his objections.

11 MR. KARNAVAS: If the witness, Your Honour, says that -- which

12 ones, I would then go ahead and give him the specific information. The

13 Prosecutor, had he read these documents, would know that this gentleman on

14 occasion says, Go check with Mr. Davidovic, go check with Mr. Simic.

15 These are the people that he's mentioned.

16 JUDGE LIU: Let Mr. McCloskey finish his objection first.

17 MR. McCLOSKEY: Your Honour, Mr. Karnavas is correct in that, as I

18 recall, Mr. Deronjic did during his many, many interviews sometimes refer

19 investigators back to speaking to specific individuals. There was a

20 number of those individuals. He has recently listed off a whole number of

21 individuals, and a question that is that vague without giving some --

22 reining in the names or at least with the groupings is too vague for the

23 answer to make any sense and it's an unfair question to be able to ask the

24 witness. If he can make it more specific, I agree with Mr. Karnavas,

25 Mr. Deronjic did say these things. If he can make it more specific to the

Page 6262

1 names, I have no objection. But the question as it is framed is really

2 impossible to answer.

3 MR. KARNAVAS: I will rephrase, Your Honour.

4 Q. Is it not a fact, Mr. Deronjic, that on several occasions during

5 many of your meetings with the Prosecution you have referred to some of

6 these friendly connections, the ones that you talked about, you referred

7 the Prosecution to your friendly connections to double check the

8 chronology of the events?

9 A. That is correct. I talked about it a number of times. I don't

10 know exactly when. I don't know exactly with respect to whom, but I did

11 state names of individuals likely who were able to provide that kind of

12 information. I cannot tell you exactly when, at what time, and which

13 specific individuals. I would have to be reminded of that.

14 Q. But assuming, as you state here, that you met with these friendly

15 connections and based on your collective recollections, we, being all of

16 you, made a chronology, a certain chronology, of events, would it not

17 stand to reason that part of the purpose for you referring the Office of

18 the Prosecution to these friendly connections would be so that they would

19 vouch for your chronology or your participation. Correct?

20 A. Yes. I refer the Prosecutor to those individuals if they wanted

21 to learn more and in more detail with respect to the things which I could

22 not remember or was not familiar with.

23 Q. Now, at some point in time, as I understand it from reading from

24 your testimony, documents were destroyed relating to certain events.

25 Correct?

Page 6263

1 A. Yes. Yes. I once stated that I don't remember exactly when, that

2 is that portion of that documentation that had been destroyed.

3 Q. And in fact, you have also indicated that you had learned from

4 Mr. Momir Nikolic that he, on his own initiative, had destroyed documents

5 as well. Correct?

6 A. Yes, that is correct.

7 Q. Now, with respect to the documents that were destroyed that were

8 in the possession of the civilian authorities, would it not be fair to

9 characterise them as members of this group of friendly connections, not

10 all but some?

11 A. Members of what?

12 Q. Well, some of the members that you had consulted, your friendly

13 connections. Okay. Are they also not the same -- some of the same

14 individuals that were involved in intentionally destroying documents so

15 they would never fall into the hands of the Prosecution?

16 A. No. Let me explain. In the SDS in late 1995, changes took place.

17 I resigned to the position of the SDS president. A new leadership was

18 elected. At the time, recommendation from higher levels was received to

19 the effect that the documentation should be destroyed. And then from

20 Sarajevo Vidomir Banduka was the president of the SDS. I don't know if he

21 was the one who destroyed the documentation, but I had managed to find it.

22 It is here. This is the complete documentation, so it has not been

23 destroyed.

24 For the military -- the municipal part, I don't know. I don't

25 know because the people I enumerated, such as Mr. Davidovic, were not

Page 6264

1 there at the municipality, nor did they have any function within the

2 military at the time. So I don't know. And I don't know what the

3 situation was with the military, except for what Mr. Nikolic told me. But

4 this can all be checked. Who were the people who held positions within

5 the SDS at the time this recommendation or order came.

6 Q. Okay. All right. Let's move on to your -- to the next segment of

7 your statement. And again, we're going over the same material. You state

8 on page 4, line 8 to 13, this is in the Srpski version. And it's page 4,

9 line -- it starts with line 8. It states -- you begin by saying: "In

10 that sense I want to begin by the contact I had with Karadzic. Physical

11 contact that began after the fall of Srebrenica. Actually, the moment

12 that I have heard about my being appointed for the civil commissioner

13 through the radio -- on the radio. So I went -- following that, I went to

14 the headquarters of the local brigade to get in telephone contact with

15 Mr. Karadzic."

16 Now, further down you state on line 20 to 22 in your version, page

17 4. And it starts with line 21 in the English version.

18 "I asked him to send me in written form, and then he agreed on my

19 urgent, you know, trip to Pale, that very day. So in the night between

20 the 11th and 12th, I was on Pale -- in Pale. I met with

21 President Karadzic in the Presidency palace."

22 Now, do you see that in the Srpski version?

23 A. Yes, yes, I follow.

24 Q. Now, it would seem to me that now that you've had an opportunity

25 to meet with your friendly connections and to come up with a chronology -

Page 6265

1 an opportunity that had not presented itself the first time you met with

2 the Office of the Prosecution - now the chronology is that in fact on the

3 night between 11th and 12th, based on your urgent requests wanting to know

4 exactly what your role and function was, you went to Pale and you met with

5 President Karadzic. That's what you told Mr. Ruez back then. Correct?

6 A. Yes, that is correct that I stated that.

7 Q. Now, I take it before stating that, you had time to reflect to

8 make sure that at least with this particular aspect you were going to be

9 as complete as you could be. Correct?

10 A. Correct.

11 Q. And the trip between Bratunac and Pale is I think around 140

12 kilometres, give or take a kilometre or a bump here and there. Right?

13 A. [No interpretation].

14 Q. In those days it would have been a -- I don't want to say a

15 lengthy journey but a significant journey. It's not like going to

16 Potocari which is only 5 kilometres away, you would actually have to be in

17 the car for a couple of hours. Correct?

18 A. Correct.

19 Q. And of course during that period of time, given your status, and

20 now with your special status, I would suspect - and correct me if I'm

21 wrong - that you had a driver to take you there?

22 A. We're talking about the 11th, and we have already established that

23 this is not the correct date. When I went to see Karadzic, which was on

24 the 14th, a piece of information I was able to establish later on, I had a

25 driver, an escort. And I believe I've already provided a detailed

Page 6266

1 description of that.

2 Q. Did you have a driver available to you on July 11th, 1995, yes or

3 no?

4 A. Yes. I had my local driver who drove me, but it wasn't an

5 official driver or anything. I just asked him to be available for me over

6 those few days.

7 Q. Okay. And if we were to go on to the next page, it says that --

8 I'm reading here now from page 5. And in your version it would be lines 5

9 to 10, which apparently correspond with the English version. I'm going to

10 read the English version as it's stated here. There might be an omission,

11 and so please bear with me. I will insert it.

12 "In our assessments, the president and myself, we relied on the

13 good will of the army and police, you know, to carry out the task."

14 I'm told in the Srpski version it also includes: "Of course we

15 did not have instruments for ordering relationships."

16 Is that in your version?

17 A. "Of course we didn't have any instruments for any kind of order

18 issuing relationship," this is what I said.

19 Q. Okay. That's not in the transcript. Thank you. Now we have an

20 official translation. And then you go on to say: "I had no authorisation

21 to order anything to them. You can clearly see from the paragraph 5

22 because his decision are actually obliged to be carried out just by

23 civilian authorities and that they were obliged to follow my decision, to

24 act according to my decisions."

25 Do you recall making that statement?

Page 6267

1 A. That's what it states.

2 Q. Well, I know it states that here, but I'm asking you whether you

3 recall making that statement.

4 A. Yes.

5 Q. Now, when you made that statement, was that a honest statement,

6 yes or no?

7 A. I will answer to the question correct or not correct. What does

8 it mean "honest"? It was an incorrect statement.

9 Q. Okay.

10 A. Please allow me to --

11 Q. I apologise. I apologise, Mr. Deronjic. I'm trying to move it

12 along so I can get you off the stand in five days, but go ahead.

13 A. To finish in five days? Look, we are constantly discussing the

14 11th. I am trying, and I hope you understand that, but it seems to me

15 like you are repeating your mistake. I am saying that that is not the

16 correct date when I went to Pale. Since you are asking me, I will now --

17 Q. Mr. Deronjic. I'm sorry. I don't mean to cut you off. We're not

18 discussing whether now you think you didn't go on the 11th or not. I'm

19 talking about this particular statement that you made. Okay? We've

20 already heard your explanation. In your statement here you state: "In

21 our assessment, the president and myself, we relied on the good will of

22 the army and the police, you know, to carry out our tasks."

23 And then you say because you did not have any instruments to order

24 these relationships. Was that a correct statement, yes or no?

25 A. In this context that this was happening on the 11th in Pale that

Page 6268

1 we were personally talking about, that is an incorrect statement.

2 President Karadzic and I spoke on the telephone on the 11th in the evening

3 and discussed these things over the telephone. So it means that I am not

4 questioning the contents of what I said, but it is incorrect that I

5 discussed that directly with him at Pale on the 11th. A part of these

6 discussions were also conducted on the 14th when I was in Pale about the

7 duties regarding Srebrenica, about how I should proceed, carry out my

8 duties, things relating to UNPROFOR, the means that they had at their

9 disposal, the evacuation of UNPROFOR, the workers of UNPROFOR, and so on.

10 Q. Mr. Deronjic, you've told us all of that. That's not in dispute.

11 But here you're stating that you and the president, the commander and

12 chief of the military, and also the president for the civilian -- the

13 entire country, right, relied on the good will. In other words, he was

14 not in a position, neither he nor you, to order the military, to order the

15 army or the police, but it was basically you had to supplicate to them,

16 beg them to cooperate. Is that what you're trying to suggest to Mr. Ruez

17 that was happening at that period of time? Is that your suggestion?

18 A. No, not that the president had to beg them because he wasn't even

19 able to do that. He wasn't out on the ground and didn't have the

20 opportunity to get in touch with them. I am saying again I was not in a

21 position to issue orders; this is clear to the president. Also that I did

22 not have the instruments nor the order-issuing relationship neither did

23 anyone authorise me to issue orders to the military. This is what I'm

24 talking about. And when we're talking about my function, we are aware,

25 both the president and myself, that I do not have an order-issuing

Page 6269

1 function to the military and the police, but it is implied, it is

2 understood, that they would listen to the constructive proposals that I

3 would put forth in particular because they came from the president.

4 Q. Okay. First of all, let's get one thing straight, the police fall

5 under the civilian side, do they not?

6 A. Yes. In all states, that they belong to the appropriate ministry.

7 Q. The Ministry of the Interior?

8 A. Correct.

9 Q. On paragraph 5 it says here: "Decisions by the civilian

10 commissioner shall be binding for all civilian authority organs."

11 And that would include, would it not, the police, that you had the

12 power to order the police, including the special police. Does it not --

13 is it not implied in this particular decision, yes or no?

14 A. No.

15 Q. Okay. Now, you say that you didn't -- you were not in a position

16 to order the military, and I believe you are quite correct, at least if we

17 are to look at this that there's nothing in here that gives you, grants

18 you, that right. Paragraph 5, I'm referring again to exhibit P687. This

19 is the decision of your appointment as civilian commissioner. I grant you

20 that.

21 On the other hand, if we go back to paragraph 4, it is clear that

22 you have an overriding obligation, responsibility, and the authority from

23 the president for the well being of everyone. And that's not in dispute,

24 is it, Mr. Deronjic?

25 A. First of all, I did not have that decision in front of me when the

Page 6270

1 president and I were talking or the next day, so I don't know what it

2 states. That is why I asked the president to send it to me in writing.

3 And as for whether the president can order me to order the police, that

4 would mean the violation of the regulations and the constitution of

5 Republika Srpska, especially the police, in particular the special police

6 which had had its own command structure.

7 Q. Okay. Well, we won't get into the legalities of that right now,

8 but let me fast forward a few days past this period --

9 JUDGE LIU: Well, since you are changing the subject, can we have

10 our break now?

11 MR. KARNAVAS: It's a quite inopportune time, Your Honour. But

12 nonetheless if it's time for the break, it's time from the break.

13 JUDGE LIU: Let's resume at 20 minutes to 1.00.

14 --- Recess taken at 12.10 p.m.

15 --- On resuming at 12.42 p.m.

16 JUDGE LIU: Yes, Mr. Karnavas.

17 MR. KARNAVAS: Thank you, Your Honour.

18 Q. Mr. Deronjic, before we left off before the break, we were talking

19 about your powers, in particular to order be it the police or the

20 military. And I believe that we established that you did have, in fact,

21 the power to order civilian organs, not necessarily the military organ.

22 Correct?

23 A. Not correct. I will give you another example, it relates to the

24 police --

25 Q. If the answer is you cannot, that's fine.

Page 6271

1 MR. KARNAVAS: I don't want examples, Your Honour. If his answer

2 is that he had no authority to order the civilian authorities, the police

3 being one of them, I accept that answer. There's no need for examples.

4 JUDGE LIU: Well, maybe that example is related to what

5 Mr. Deronjic is going to tell us.

6 MR. KARNAVAS: Okay. Very well, Your Honour.

7 JUDGE LIU: Please continue, Mr. Deronjic.

8 THE WITNESS: [Interpretation] The example refers to this assertion

9 whether I had the authority or not to command the police. I will give one

10 example which shows clearly what my powers were and in which way I was

11 contacting the police.

12 From the transcript of my interview, my last interview to the

13 Prosecution, I am talking about the conversation between myself and

14 Karadzic after the Fontana meeting on the 12th of July. So after this

15 meeting was finished, I went to my office and I called President Karadzic

16 in order to inform him about the Fontana meeting and I also told him about

17 my intentions, what I wanted to do once it was possible for me and my

18 associates to enter Srebrenica, expecting the civilian transports to

19 finish on that or the next day. I gave my statement about that to the

20 Prosecution. So I am telling him of my intentions. Amongst other things,

21 I told him about my intention to form a police cell, which would urgently

22 enter Srebrenica, and then later this unit, this small unit, which I

23 wished to form, would be expanded and then would link up to the Interior

24 Ministry.

25 These plans of mine that the president approved, he, President

Page 6272

1 Karadzic, issues an order to the Minister of Internal Affairs, Tomislav, I

2 can't remember his last name right now. He issued an order to Mr. Vasic

3 to get in touch with me and to act in accordance with his order. So he

4 was giving the authority to the chief of the Zvornik security centre,

5 Mr. Vasic, who at the time was in Bratunac, to get in touch with me.

6 And of course there is also a document which testifies to this

7 fact, and that is a report by Mr. Vasic which I also had the opportunity

8 to see recently from the Prosecution where he informs about receiving the

9 order and acting in accordance with the order and getting in touch with

10 the civilian commissioner with the intention of forming a police unit

11 which would enter Srebrenica. This shows without doubt in which way I

12 could issue orders to the police. So I would contact the president,

13 President Karadzic. President Karadzic, if he agreed with my suggestion

14 would issue an order to the minister, to the minister to the security

15 services' centre, to chief and then the chief would contact me.

16 So what Mr. Karnavas is trying to suggest, that I could issue

17 direct orders to the police, then why would I go this other way? I could

18 simply say, Mr. Vasic, I am ordering you to come to my office and that we

19 could form a police unit. So it's obvious in this example how de facto

20 and de jure also, this institution functioned which was established for

21 the first time in our area, the function of the civilian commissioner.

22 And that is how I acted and I also think that I acted in accordance with

23 the law as well as with my de facto authorities and powers. I think this

24 is a very obvious example and this is why I insisted on telling you about

25 it.

Page 6273

1 Q. Okay. We'll stick with that for a second. Earlier you had

2 indicated that when you learned that there were separations going on at

3 Potocari, you asked Vasic to contact Mladic because you were too busy or

4 unwilling to go into Potocari and find Mladic. And you asked Vasic to

5 tell Mladic that this should stop. Correct?

6 A. Correct.

7 Q. Okay. Now, how is it that you asked Vasic on that occasion and

8 you did not pick up the phone to call Karadzic, with whom you had a very,

9 very close relationship with and with whom you could visit even

10 unannounced. Why didn't you call him then and say, Mr. President, contact

11 Mladic and tell him to stop. Why did you go through Vasic on that

12 occasion, where killings are going on?

13 A. Yes. I see that you are trying to be very suggestive. First,

14 if -- I'm not saying that this is a minor thing, but for any intention of

15 mine I had to pick up the phone and call the president, I would not put

16 the phone down ever. These were some things that were resolved as we went

17 along. I suggest to Vasic; I did not order anything to him. And he

18 listens to me. How could I tell President Karadzic from my office quite

19 openly, you know, Mr. Karadzic your, or our army in Srebrenica and in

20 Potocari is violating the conventions relating to the conduct of war and

21 so on. Do you think that this is possible? Of course it can be done that

22 way as well, but I prefer not do it that way. I think there's no need for

23 me to tell you what my reasons are. I think it is absolutely clear.

24 Q. We are clear on that.

25 A. I would just like to mention, I did not have sufficient

Page 6274

1 information in order to be able to say, Yes, it is true that they are

2 violating customs or war. But it is true that I did say, Could you ask

3 Mladic to stop. And later he informed me that he did convey that to

4 Mladic.

5 Q. Mr. Deronjic, since you were so insistent on giving us an example

6 about de facto and de jure, might I put an example to you and perhaps you

7 might be able to assist us. We're not going to go into the greatest of

8 detail at this point, but I would like to refer to you of the evening of

9 the 13th. And we're going to discuss that in the greatest of detail, but

10 just as a way of example. You have testified on previous occasions, and

11 there are some conflicting views, but you have testified nonetheless that

12 you had had this meeting with Colonel Beara. Correct?

13 A. Yes, of course it's correct.

14 Q. And you have said that Colonel Beara came there and said that he

15 was going to kill all of the prisoners in Bratunac. Correct?

16 A. Correct.

17 Q. And you were able to exercise your authority to ensure that those

18 killings did not take place in Bratunac. Isn't that a fact?

19 A. Correct.

20 Q. And you, according to your testimony - if we are to believe your

21 testimony - you were able to say, I have an order from President Karadzic,

22 and I'm telling you, Colonel Beara, that there's not going to be any

23 killings. Correct?

24 A. Correct.

25 Q. And on the evening of the 13th before you went to bed in your safe

Page 6275

1 and sound environment at home, you were under the impression that

2 Colonel Beara had accepted the order that you had given him. Correct?

3 A. Yes. But don't be ironic when you're talking about my safe home.

4 Please, could you skip that. My home was as safe as all the other homes

5 were safe at that time.

6 Q. All right. You weren't boxed up in some warehouse, were you?

7 A. No.

8 Q. All right. Now, on the morning of the 14th, you wake up or

9 somebody wakes you up and you learn, according to your testimony, that

10 Colonel Beara is searching for the brick factory in order to put some

11 prisoners over there. Correct?

12 A. Correct, correct.

13 Q. And the brick factory happens to be in the Bratunac or within the

14 Bratunac municipality?

15 A. Yes.

16 Q. Once again we see your de facto, if not de jure, powers, where you

17 have a confrontation with Beara and you order him out of Bratunac, that

18 there shall be no killings in Bratunac. Correct?

19 A. Correct.

20 Q. Now, Beara, from what I understand, I've never met the gentleman,

21 but I understand he's a tall man --

22 MR. McCLOSKEY: Your Honour, I have to object to the question. It

23 was compound --

24 MR. KARNAVAS: He answered the question, Your Honour --

25 JUDGE LIU: Listen to the objections from the Prosecution.

Page 6276

1 MR. McCLOSKEY: This is the danger of a compound question. It had

2 two parts. One, you ordered him out of Bratunac; two, you ordered that

3 there be no killing. Mr. Deronjic naturally, I believe, answered the

4 second part of the question, but we are left with the record that he has

5 ordered Mr. Beara out of Bratunac. And perhaps -- I don't think there's

6 anything in the record. That's why I object to that, and I know

7 Mr. Karnavas understands what the facts are. But now we are left with

8 that on the record. Which is why I decided to stand up.

9 JUDGE LIU: Yes, that might be important.

10 MR. KARNAVAS: Your Honour, I can assure you -- and I thank my

11 learned colleague. But I assure you we were going to get to that. We go

12 from the general to the specific. And we're going to -- this is going to

13 be -- we are going to discuss this. But I thank and appreciate the

14 Prosecution's concern.

15 Q. But let me first describe Beara so we can all have this general

16 description. He's not a small guy like me. He's a pretty big fellow,

17 isn't he?

18 A. Yes. Yes.

19 Q. And he has a pretty formidable appearance, does he not?

20 A. I wouldn't agree for that, but I allow for perhaps you feeling

21 that way.

22 Q. He was the head of the security sector for the Main Staff, was he

23 not?

24 A. Yes.

25 Q. And he also had a reputation during the war -- a reputation that

Page 6277

1 follows him all the way here to The Hague, did he not?

2 A. No. No. Please, please, listen to me --

3 Q. I accept your answer. You did not know anything about Mr. Beara.

4 A. Correct, he probably did have a reputation that you are speaking

5 about. But I said that I never heard about Mr. Beara in my life, nor did

6 I see him before the time he actually came into my office. So I hope that

7 you also -- that this is now clear. And I hope that you also would like

8 to hear the truth come out and for everything to be clear.

9 Q. Okay. I accept that, that you in your position had never heard of

10 Beara. Fine. Now, you were able to have this confrontation, because it

11 was somewhat confrontational, with Mr. Beara on the 14th of July, the head

12 of a security organ of the VRS army. And you were able to order him not

13 to have any killings in Bratunac. Correct?

14 A. Correct.

15 Q. You were able to order him that those prisoners were not going to

16 go into a facility that was within the Bratunac municipality. Correct?

17 A. You are repeating the question. Yes, correct.

18 Q. All right. And in fact that is exactly what Beara did. He left

19 angrily, according to you, to your prior testimony. Right?

20 A. Yes.

21 Q. So in spite of him being a military man and despite all orders

22 that he had, presumably from his superior, which would have been Mladic,

23 an order which he had to carry out, at least in his own mind, you,

24 Deronjic, as commissioner and as head of the SDS party were able to

25 exercise your control and order him out of Bratunac. Correct?

Page 6278

1 A. Yes. I said that I would not allow for those killings to be

2 committed in Bratunac, that I had orders that were different from

3 President Karadzic. But I have one addition. Based on that example, you

4 are trying to construct this idea of some power that I had at that time.

5 There are situations in which a person does not even think of their own

6 powers or the consequences. This was one of such situations. I can tell

7 you any number of situations during the war in which I acted outside of my

8 reasonable powers that I had at the time, but I will not burden you with

9 that.

10 At the time when I found out he was intending to do that,

11 regardless of the fact that I'm not sure who ordered him to do this, I

12 said, Mr. Beara, you cannot do this. This was just a human gesture. At

13 that point, I was not thinking of my powers, reacting early in the morning

14 when I found out. Even though we had reached some kind of an agreement

15 about that, I got the impression that he would not do anything else with

16 the prisoners anymore in Bratunac but would act upon orders of

17 President Karadzic, in the way I conveyed them to Beara. I find out that

18 again he was going over there to see something. So I was very angry at

19 that moment. I got into the car, I got there and I said, Sir, did we not

20 discuss this situation last night? This is out of the question, there can

21 be no detention of people, no killings and please act in accordance with

22 that. At that moment he was there with his security. He could have shot

23 at me. It was possible for him to do that. I was by myself. He could

24 have killed me. But at that point I did not think about that at all.

25 Based on just that one moment, you cannot draw the conclusion that

Page 6279

1 I had some kind of absolute power and that I could also go to Mladic and

2 tell him everything to his face, listen you can do this or you cannot do

3 that or that I'm ordering you to do such-and-such. I think that you are

4 trying to suggest something like, something like a wrong conclusion the

5 way you are going about it.

6 Q. I was merely pointing an example, just as you did earlier,

7 Mr. Deronjic, but you would agree with me that as a result of your

8 intervention, at least those prisoners of whom you were still responsible

9 for were not killed in Bratunac. Correct?

10 A. You're now throwing in that we can discuss it, whether I was

11 responsible or not. You should not be simply asserting that. But it's

12 true that Beara acted in an angry manner, that he left the premises. I

13 waited for a while and I realised that convoys were heading out to

14 Zvornik. Whether he had consulted anyone, well, it is my assumption that

15 he had. He must have asked someone. But again these are just

16 assumptions. He may have said, Yes, take these people to Zvornik, but I

17 cannot know that.

18 Q. Okay. We're going to discuss more on that evening, what happened

19 on that evening. But I want to get back to where we were, because the

20 chronology is somewhat in dispute, and we still haven't figured this one

21 out.

22 Now, if I can go back to your statement of February 4, 1998, and

23 that's -- and I'm referring for the record to D93/1. At some point you

24 say -- you've indicated in this particular interview, you indicate that in

25 the course of the following day, we've already established this that you

Page 6280

1 stated this, in the course of the following day you had a meeting with

2 Karadzic, that would have been the 12th, if your chronology was correct.

3 And I'm saying if; I'm qualifying that.

4 Now, on the next page, on page, it would be page 4 in the English

5 version. It would be page 3 in your version. You state --

6 A. Sorry, where?

7 Q. Page 3, line 28. And I'm going to be reading down from there.

8 Actually, let me go further up. Let me start with line 26. In the

9 English version it would be page 4, line 3. One of your tasks, you

10 indicate, and I quote: "I was told to establish contact urgently with all

11 representatives from these three respective formations. With an

12 instruction to inform them on the president's decision to appoint me as

13 someone who should take care about the civilian population in war

14 conditions."

15 You then go on to state, this is line -- it's -- this would be

16 line 28 in your version. "Of course" --

17 A. What page, please?

18 Q. Page 3, sir. We're still on page 3. So I just read from line 26

19 to line 28. And now you state: "Of course I was requested by President

20 to respect all the conventions established about proper treatment of the

21 civilian population in war conditions."

22 You then go on to state: "Upon my return to the region of

23 Srebrenica, I have asked for an urgent meeting with a Commander Mladic,

24 who was staying there on spot. In addition to a meeting with Mr. Vasic,

25 who was the head of the local police, meaning the centre of public

Page 6281

1 security. I had also invited a commander of the local brigade, of the

2 Bratunac Brigade, to attend at this meeting."

3 And then you go on to state that: "In addition to a local head of

4 the police station, there Mr. Josipovic; Mr. Simic, who was the president

5 of the municipality there; and local president of the municipality

6 government, Mr. Davidovic. So I have informed them with the contents of

7 the order given by Mr. President, by which I was appointed."

8 Now, according to this statement, according to this statement, it

9 states, if we follow your chronology as it was on February 4, before you

10 had the opportunity to meet with your friendly advisors, you're stating

11 that you went to see President Karadzic on the morning of the 12th and

12 then -- or on the 12th. And then sometime later is when you asked to meet

13 with all these representatives in order to convey to them specifically

14 president -- the president's order that all conventions are respected and

15 that proper treatment of civilian population in war conditions. That

16 today we know is not a correct date. Correct? This assessment of yours,

17 this chronology.

18 A. Correct.

19 Q. All right. Now, there is -- and for the first time here we also

20 see that you asked to see Mladic, who is of the Main Staff. There is no

21 mentioning of you asking of the Drina Corps commander, either Zivanovic or

22 Krstic, whoever might have been in charge at the time, but instead you

23 state here that you're asked that the commander of the Bratunac Brigade

24 attend this meeting.

25 Now, how was this invitation extended to Colonel Blagojevic? Was

Page 6282

1 it by phone? Was it by fax? Was it by courier? Was it by chance

2 meeting? Or is there another option which I have failed to come up with?

3 A. On the way back -- now we are discussing firm facts, not what I

4 said here because the dates are not accurate. After my conversation with

5 Karadzic on the 11th in the evening, I acted the way it is described here.

6 I tried to gather as many relevant individuals as possible, including

7 political and military individuals, in order to convey to them what

8 Mr. Karadzic had told me over the telephone. I think here that this

9 was -- this had been conveyed to me in person, and this is how I describe

10 it. I also state here all of the individuals that I managed to find. I

11 had contacted the secretary and asked her to try and get in touch with all

12 these people.

13 If you go on on page 5, you will see that I expand on this

14 information, questioned by Mr. Ruez. I state commander Blagojevic once

15 again and say that his competences at the moment were not very large. He

16 was not present at the meeting. Today I know for sure he was not present

17 at the meeting. Furthermore, I was not able to find Mr. Mladic. I know

18 that Commander Krstic was the commander of the operation, but I believed

19 at the time that he was somewhere out in the field, so I wasn't even try

20 to find him. This is all explained in this passage.

21 Those people I was able to find had gathered in my office. And I

22 assume this is what is interesting for you. Today I know for sure that

23 despite the fact that I asked the secretary to find Mr. Blagojevic, he did

24 not attend this meeting. I was able to check this subsequently, and I

25 have firm evidence to prove that he had not attended this meeting. The

Page 6283

1 secretary probably was not able to find him. But at that moment, he was

2 not so important for me, as I state here, because of the presence of a

3 large number of officers at the meeting.

4 Q. Okay. Well, we were going to get to that, but now since we are on

5 to Mr. Blagojevic with respect to this meeting, you -- it is correct -- as

6 I -- since we're on to Mr. Blagojevic, it is my understanding that you

7 viewed him as someone who was not terribly important. Correct?

8 A. Correct. I believed that he was not necessary with respect of

9 what I had to tell the people.

10 Q. Bratunac -- the Bratunac Brigade had been going through commanders

11 left and right. Correct?

12 A. Correct.

13 Q. And Blagojevic was just the newest commander for the brigade?

14 A. Yes.

15 Q. He had just arrived only a few weeks earlier?

16 A. I agree with you, but I don't know the exact date of the

17 appointment. But I think this is correct, based on information.

18 Q. And unlike his, for instance, head of security, Momir Nikolic, he

19 was not the commander of the Territorial Defence during the -- in 1992.

20 Correct?

21 A. No, not in Bratunac. I'm not aware that he was anywhere else.

22 Q. And it's also fair to say that you, by this point in time in

23 history of the events in and around Srebrenica, Bratunac, and what have

24 you, you had solidified your position, which was relatively important,

25 that is that of a -- the head of the SDS party. Correct?

Page 6284

1 A. I'm sorry. I really don't understand what you mean when you say

2 "solidified my position."

3 Q. Well, you -- we're going to get to your background, but you had

4 moved up the party rank rather rapidly, and once you got to be president,

5 you stayed president. Correct?

6 A. President of the Bratunac SDS, but where did I go from there? I

7 became and I remained president --

8 Q. Well, that was your little fiefdom and we're going to get to that.

9 But what I'm trying to establish is that for several years you had been

10 the president of the SDS. Correct?

11 A. The president of the municipal branch of the SDS, to avoid

12 confusion. I don't want anyone to think I was the president of the SDS of

13 Republika Srpska.

14 Q. I'm not suggesting that, but you did have the ear of the president

15 of the SDS of Republika Srpska. Correct?

16 A. Either I'm not receiving the right interpretation or I simply

17 cannot believe that I had the ear of the president.

18 Q. Well, we'll get to that --

19 A. He had my ear.

20 Q. Okay. We'll get to that. In any event, at this point in time, as

21 you indicate here, given the various VRS units that were located in

22 Bratunac, on the scale of hierarchy, Blagojevic was way down, with Mladic,

23 Zivanovic, Krstic being above him. Right?

24 A. Yes.

25 Q. Okay. All right. Now that we clarified that, let me go back to

Page 6285

1 what I was doing, because I want to go back. Now I want to see what you

2 said in relation to this meeting on 21 October 1999, because this is the

3 version that you give months later after you had an opportunity --

4 JUDGE LIU: Yes, Mr. McCloskey.

5 MR. McCLOSKEY: Just an objection. Foundation. I'm not really

6 sure it's been established that there was a meeting.

7 MR. KARNAVAS: What meeting?

8 MR. McCLOSKEY: The meeting you're talking about. It hasn't been

9 established that there was a meeting. The direct examination said that

10 that part you just read hasn't happened. And you haven't come to a

11 meeting, so there's no foundation. It's a little confusing.

12 JUDGE LIU: Yes.

13 Maybe you could clarify for us.

14 MR. KARNAVAS: I will.

15 Q. At some point did you meet with Mladic -- well, in fact, you did

16 meet with Mladic. You had a breakfast meeting with him. He's eating

17 there and he's sort of disrespecting you and the president of the

18 Republika Srpska. We covered that yesterday. Right? There was a meeting

19 on the 12th, the morning of the 12th, before the official meeting with the

20 Muslim representatives and UNPROFOR in the Hotel Fontana. We covered that

21 yesterday. Correct?

22 A. I think we will really have to slow down. I hear incredible

23 things from the interpreters. You're saying that the president of

24 Republika Srpska was at the Fontana Hotel. We really have to correct

25 this. Could you please repeat your question slowly so that I can receive

Page 6286

1 accurate information.

2 Q. On the morning of the 12th, there was a meeting at the Hotel

3 Fontana, a breakfast meeting, that was being hosted by General Mladic.

4 You were there. And that was the meeting we talked about where Mladic was

5 disrespecting President Karadzic and you. He was making disparaging

6 [Realtime transcript read in error "^"] remarks, unkind remarks, perhaps

7 even unfounded?

8 A. Yes.

9 Q. Okay. At that meeting, Colonel Blagojevic wasn't there, was he?

10 A. No.

11 Q. Okay. And in fact at no time during that period was there ever a

12 meeting where Colonel Blagojevic was present. Isn't that a fact?

13 MR. KARNAVAS: Let me rephrase, Your Honour. I know the

14 objection.

15 JUDGE LIU: Yes, yes. Especially the caret.

16 MR. KARNAVAS: Yes, yes, I know the objection. I stand corrected

17 Q. At no time during the period -- you find it amusing, Mr. Deronjic.

18 Okay. During the time of July 11th and say the 17th when you meet

19 with the representatives of the Muslims. Okay? You are not -- at no time

20 was Mr. Blagojevic in any meeting at which you were present.

21 MR. KARNAVAS: I believe that was Mr. McCloskey's objection or he

22 wanted some clarification.

23 Q. Correct? I need to have a record. Right?

24 A. Interpretation. I'm waiting for the interpretation. I'm sorry,

25 Mr. Karnavas, but you have to bear in mind that when you finish, the

Page 6287

1 interpreters are still continuing with the interpretation. And one other

2 thing, please do not interject things like: You find it amusing,

3 Mr. Deronjic. I smart because an objection was going to be raised and I

4 myself wanted to say this with respect to your question. That is to say,

5 at no meeting that I attended was Mr. Blagojevic present during that

6 period of time, during those days.

7 Q. Okay. Now, you did indicate, going back to your statement of 21

8 October 1999, that was the one you had subsequent to your meeting with

9 your friendly connections where you worked on the chronology. And that

10 one, we've established, you had told Mr. Ruez - although we can disagree

11 on whether you were correct or not - but nonetheless you told him then

12 that you went to Pale to meet with President Karadzic on the 11th of July.

13 Do you recall that, having said that?

14 A. Yes, I remember.

15 Q. Okay. Now, it indicates here that on your return -- you could

16 find this on page 6 of your transcript. But we learn -- you indicate that

17 upon your return you learn that General Mladic held a short meeting in the

18 headquarters of the brigade. It's page 6, line 12 to 22. Your version,

19 it's page 6, lines 11 through 18. This is the area I'm covering.

20 A. Just a second. Please let me find it. From line 12, this is

21 where it starts in my text.

22 Q. Yes. Yes. Yes. It says that -- it says: "What time, it was

23 precisely, I wouldn't know. It was after midnight, the very same night."

24 In the previous page, you indicate you had gone that very same

25 day. So we're talking about the night of the 11th going into the 12th.

Page 6288

1 And you state: "The very same night in Bratunac, General Mladic held a

2 sort meeting in the headquarters of the brigade. I did not take part in

3 that meeting simply because I was just in Pale. Last time we talked, I

4 didn't know about this meeting, but following that meeting I inquired

5 about that meeting and I learned about that meeting. From my talks with

6 the president of the municipality, president of the executive board, and

7 some police officials, I learned about meeting, and that's a small

8 alteration to the original."

9 And that I've just read for the record from page 6, lines 11

10 through 18. And this is from what has been marked for identification as

11 P692. Now, it would seem from this version that you did, in fact, go to

12 Pale on that night, which perhaps may explain why you were not at the

13 meetings in the Fontana on that particular evening. And it also is clear

14 that after you had consulted with your friendly connections, some of whom

15 you've mentioned here who were at that meeting, or at least had informed

16 you of those meetings, you came to the conclusion that you were not at the

17 Hotel Fontana because you were still in Pale.

18 A. What is your question, please?

19 Q. Well, my question is -- the question is: I'm trying to -- the

20 chronology is important and it seems that initially you stated that it was

21 the day after the fall of Srebrenica, being the 12th, that you went to

22 Karadzic. That was at a point in time when you were not clear on the

23 dates. You are then informed that you are a suspect. You are then given

24 an opportunity to meet and caucus with your friendly connections. And

25 after that, you give a statement where you say that you were in Pale the

Page 6289

1 night of the 11th, which is why you could not be there for the meetings

2 that took place at the Hotel Fontana on the night of the 11th. And you

3 also tell us that you learned of these meetings through various folks,

4 some of whom you have today told us are your friendly connections that

5 helped you come up with this chronology.

6 So my question to you is: Are you still maintaining that you did

7 not go to Pale on that -- on the 11th?

8 A. Yes, I'm still maintaining that.

9 MR. KARNAVAS: For the record, I'm told that, I guess, apparently

10 this document has two numbers. This is "tehnicki" stuff. It's D95/1.

11 This is for the identification of the document.

12 Q. So I don't want to confuse you. Okay. So your understanding is

13 that you maintain your position. All right.

14 Now, if we go on, if we go on, to page 13 of this same document,

15 one would get the impression that what you're saying -- I'll make

16 references to the particular segment, but please listen to the question

17 first. It appears that what you're telling Mr. Ruez is that you were

18 totally unaware of the attack on Srebrenica. This was something that was

19 arranged at the highest levels. And you say, in fact, "Belgrade,

20 Sarajevo, Pale." If you were to look at page 12, around lines 22 to 26,

21 you would find that.

22 A. I found it.

23 Q. Okay. And then you say: "I didn't know anything about it." This

24 is line 10 in the English version, page 13. "I didn't know anything about

25 it. Why I didn't know anything about it? As the operation officially

Page 6290

1 started, the Srebrenica operation, I simply went to the front line. I

2 spent all the time with soldiers on the front line. I thought that it

3 concerned some operations that are related with adjustments to the

4 boundaries between Skelani and Milici. And that was a subject we talked

5 about. Many soldiers witnessed -- who witnessed that I spent in their

6 bunker constructions."

7 Now, Mr. Deronjic, do you maintain that when Srebrenica -- the

8 attack on Srebrenica occurred, that you were in a total dark and that you

9 thought that this must be some operation related with adjustments of the

10 boundaries between Skelani and Milici?

11 A. I maintain today, as I did in my last interview that, with respect

12 to the intentions of the operation to be carried out in and around

13 Srebrenica, I learned about it in mid-May. I didn't know what the

14 objective of the Srebrenica operation was. I talked about the

15 conversation with Karadzic that I had, which I described in my statement.

16 I went to the front line at the very beginning. At the time, preparations

17 were still underway. I do not recall the exact date when I went to

18 Pribicevac. Up until the 8th or the 9th of May, I'm not sure about the

19 date, when I went to Pale to talk to Mr. Karadzic about it, I did not know

20 what exactly the objective of the Srebrenica operation was. I had some

21 assumptions, judging on the situation on the ground, but I did not have

22 any reliable information as to the objective of the Srebrenica operation.

23 Q. Okay. We're going to get to that at some point, I hope.

24 Now, if we go back to the previous page, just to finish one point.

25 On page -- it would be page -- well, it should be the same page for you,

Page 6291

1 page 12, 1 through 13. You state there that: "Last time I expressed

2 thesis -- I told you this thesis, and I think it's correct. No one of the

3 local authorities in Bratunac knew that there would be an operation in

4 Srebrenica."

5 I've just read, for the record, lines 16 to 18. Okay.

6 "No one of the local authorities in Bratunac knew that there would

7 be an operation in Srebrenica."

8 No one, that would mean you as well, would it not, or you did not

9 consider yourself a local authority or a member of the local authority in

10 Bratunac?

11 A. You can take it however you like. It's known what I said.

12 Q. Okay. And then you go on to say: "The reason is that it was a

13 surprise for me, even though I performed the highest functions position at

14 that time. For instance, the president of the municipality at that first

15 day of fall of Srebrenica was in Nis city, for instance, because many

16 troops gathered in Bratunac. So before his departure, he asked me whether

17 it is advisable to go to Nis and what I expected -- what I expect

18 concerning Srebrenica. I told him that there was no reason for him not to

19 go there, because I expect nothing to happen in Srebrenica. Had I known

20 that something would happen, I would never let him go."

21 And then you go on to say: "Luckily he heard about it, he heard

22 about the fall of Srebrenica, and he hurried back."

23 I take it you maintain that this was a truthful and honest

24 statement at the time that you made it and as you stand here today?

25 A. What was the last thing you said, that it was a truthful

Page 6292

1 statement --

2 Q. An honest statement --

3 A. Is that what you said.

4 Q. -- At the time that you made it. And do you still maintain that

5 it is still today?

6 A. It's correct that Ljubisav Simic did not know about the operation

7 or about how it would proceed in Srebrenica. And I couldn't assume when

8 they would enter Srebrenica and all the things that would happen in

9 Srebrenica. It was a possibility, but I never mentioned that or discussed

10 that with Ljubisav Simic at all. Particularly in the early stages when I

11 didn't know what the objective of the Srebrenica operation was. He asked

12 me, could he go to Nis. And I said, yes, of course, just do your job, not

13 expecting that anything would happen.

14 Q. All right. So in other words he asked you permission if he could

15 leave?

16 MR. McCLOSKEY: Your Honour.

17 JUDGE LIU: Yes.

18 MR. McCLOSKEY: I'm going to object to this point. This has been

19 -- this was gone over in depth yesterday, and you may recall there was --

20 about Mr. Simic going to Nice which has now been cleared as Nis, but this

21 is -- we're going over and over, and if we're talking about all these days

22 here, I would object that we would not go over old ground. This is old

23 ground.

24 JUDGE LIU: Yes.

25 MR. KARNAVAS: Your Honour, if I may be heard. Yesterday there

Page 6293

1 was some equivocation with respect to whether he suggested or whether he

2 ordered. And I want to make sure that we're crystal clear and that the

3 record is clear. This is a topic that is dear to Mr. McCloskey's heart

4 and I want to make sure there's no misunderstandings in the record. And

5 that's why I'm asking him now that we have concretely the wording where he

6 says I would have never let him go. I wanted him to be very specific.

7 Q. So the question I asked, based on his answer was: So President

8 Simic had to ask your permission to go to Nis, correct, based on what you

9 stated here?

10 A. No, it's not correct. I didn't understand your question. And I'm

11 telling you I'm having difficulty following the continuity in what you are

12 saying because you are skipping from topic to topic. So I don't know what

13 the emphasis is in your questions. It's not correct what is stated

14 stating here and I think you are delving into the semantics too much.

15 Here it states he asked me whether he could go for the trip, but I wasn't

16 paying attention to every word in the interview.

17 In order to explain this, Mr. Karnavas, so that you have a sense

18 of this. I used to go to these meetings by myself. Sometimes there would

19 be five people, sometimes three, sometimes two would be questioning me at

20 the same time. So you can imagine that at that time I would not be paying

21 attention to every single phrase, every single word. So of course it's

22 normal that there are some mistakes, perhaps words that are too forceful,

23 used imprecisely. I agree it's important, that we need to clarify that,

24 and I thank you because you are making it possible for me to clarify what

25 I meant and what I did not mean. If you want to draw certain conclusions

Page 6294

1 from that, tell me which ones and I can tell you whether that is correct

2 or not, whether that corresponds to the truth or not.

3 Q. Do you recall having -- do you recall being questioned by

4 Mr. Milosevic, do you not?

5 A. Yes, I do.

6 Q. And at one point, getting back to your conversations, the ones

7 that you indicate occurred sometime on the 9th of July - we haven't gotten

8 to that yet - where you had gone to Pale and -- because you were concerned

9 that the operation with respect to Srebrenica wasn't going well. Do you

10 recall that line of questioning by Mr. Milosevic?

11 A. I assume that that is correct. I cannot remember everything, but

12 I have no reason to doubt that that is so.

13 Q. Let me give you some more clues. Do you recall where you had

14 indicated at some point during this conversation that you were having with

15 Mr. Karadzic, I believe it was a tete-a-tete, four ears, four eyes, nobody

16 else around to verify whether it happened or not. But on that occasion,

17 you spoke with Mr. -- President Karadzic because you wanted to know one --

18 one of the issues that you wanted to know was what was the real intention

19 with respect to the attack on Srebrenica and at which point

20 President Karadzic told you that there were two options, one of those

21 options being the complete takeover of Srebrenica. Do you recall that

22 exchange?

23 A. Yes, of course I remember all of that. But I -- again, you are

24 cuing me. You said at one point that nobody was there, suggesting, of

25 course, that I was making it up, while I precisely that said next to us a

Page 6295

1 few steps away there were Mr. Stanisic and Mr. Krajisnik. These people

2 are still alive. One of them even confirmed that to me. I can talk about

3 that when I testify in some other cases.

4 Q. Okay. But as far as I read your testimony, at no place in time do

5 you state that they were there having this conversation with you, because

6 as I read your testimony, and we'll get to the specifics, but as I read

7 it, you have indicated that when you went there unannounced to Pale, you

8 took President Karadzic aside or he came -- you walked away and you had a

9 one-on-one conversation with the president. Correct?

10 A. Not correct. It's not correct. Allow me to explain. You

11 really --

12 Q. We will discuss that?

13 A. You really --

14 JUDGE LIU: Well, well.

15 MR. KARNAVAS: Your Honour, I'm entitled to conduct my

16 cross-examination in the order in which I -- in the order of which -- in

17 the order I wish. Now, I indicated to the gentleman we will discuss that

18 incident in great detail.

19 JUDGE LIU: But do not be argumentative with this witness. You

20 are to allow this witness to answer your question, we have to go step by

21 step.

22 MR. KARNAVAS: Very well, Your Honour.

23 MR. McCLOSKEY: Your Honour.

24 JUDGE LIU: Yes.

25 MR. McCLOSKEY: I would ask, and I know it's getting to that late

Page 6296

1 hour. But if Mr. Karnavas could lower his voice somewhat. I think that

2 tends to create some of the tension.

3 MR. KARNAVAS: Yes. Very well.

4 JUDGE LIU: May I remind you, we have five minutes.

5 MR. KARNAVAS: Yes, Your Honour, I apologise. I guess when I see

6 the time, I tend to get a little more anxious in trying to squeeze in as

7 much as I can.

8 Q. We will get to that. Now if you want to discuss the issue right

9 now, Mr. Deronjic, I will not prevent you. But I assure you tomorrow

10 morning, first thing, we'll hit that topic, your meeting on the 9th with

11 President Karadzic. Okay.

12 A. No, no, Mr. Karnavas. Last time you promised me, I wrote it down

13 that you promised that you would allow me to discuss an idea of yours but

14 I do not -- and then the chance never came. I will not allow that to

15 happen this time.

16 You said that I stated that I took President Karadzic aside, took

17 his hand. But I said precisely, coming to Pale, I encountered the

18 president in the company of Krajisnik and Mr. Jovica Stanisic. The

19 president introduced me. You obviously do not want to bring that out or

20 you didn't read it. He introduced me to Mr. Stanisic. He said this is

21 one of our guys from down there. We spoke for a few minutes and then he

22 said, Is it anything urgent? And I said I can wait. And then he said,

23 Well if it's not too long, then he took me aside and said, Well, we can

24 discuss this, just the two of us, and then we finished our business

25 quickly. What you are saying is completely the opposite and what you are

Page 6297

1 suggesting to the Trial Chamber and trying to draw the conclusion that I

2 took the president by the arm and that took him aside and that I met him

3 alone which is absolutely not true. Do you at least agree with me?

4 Q. Well, not in the fashion as you put it. But as I read your

5 testimony here you indicated that upon seeing you, naturally he made the

6 introductions, but at some point the two of you walked away and had a

7 private conversation. Okay. I'm not suggesting that you grabbed him, but

8 you had a private conversation a few steps away from the others. Correct?

9 A. That is correct.

10 Q. Right. But my real point was not really to get into this issue.

11 What I really wanted to get into was at some point there is a conversation

12 between you and President Karadzic with respect to what might happen to

13 these people. Correct? And without going into great details,

14 President Karadzic asked you what you will do, and he used I believe the

15 plural which is, one, a polite way of addressing someone, correct, but

16 also it could be plural meaning you and the other members of the

17 government. Correct?

18 A. Correct.

19 Q. The point I'm trying to make now is that during that exchange, he

20 reminded -- Mr. Milosevic, and I'm quoting here from 29.675, that's the

21 number of the page. On line 5 you say: "But you forget the fact, and

22 perhaps you don't even know it, I'm a language teacher, I can feel the

23 finesse, the nuance, and expressions."

24 And this is my -- the driving point that I'm trying to make. You

25 had this meeting after preparing yourself for Mr. Ruez. You're a language

Page 6298

1 teacher, and in fact you took great pride in pointing this out to

2 Mr. Milosevic. So obviously can we not conclude, Mr. Deronjic, that when

3 you speak - and as we see you can speak in pages, not just sentences or

4 paragraphs - but when you speak, you are very careful in your choice of

5 words?

6 A. Practically all of the things you have just stated are not true.

7 First of all, you said that I took great pride in saying this to

8 President Milosevic and that I kind of boasted about having higher

9 education. I think this is very malicious, and I cannot just forgive that

10 and discount that. I respect everybody, and I don't think there are any

11 problems about whether somebody has a lower or a higher education.

12 The other thing is that Mr. Milosevic was constantly saying this

13 is not true. He said that the word"vi," the polite term is the way

14 Mr. Karadzic was addressing you. And I said yes, that is true. He was

15 using the "vous" form,"vi". But this difference was a little bit

16 confusing to me on the way back in the car to Bratunac. I talked about

17 that, I was wondering, what did he mean when he used the term"vi". And I

18 thought about it and I believe that this is not really a crucial question

19 that we need to discuss here. Semantics is a field in which we could

20 really talk about for a long time, you and me. But the key question here,

21 Mr. Karnavas, is that there are 7.000 people who are no longer with us.

22 However, you are doing your job in a little -- in a different way. So you

23 should proceed as you see fit.

24 Q. Suffice it to say, Mr. Deronjic, suffice it to say, you're not

25 disputing the fact that you are quite an articulate speaker of the Serbian

Page 6299

1 language?

2 A. I'm not denying it; I'm not asserting it.

3 Q. As a teacher of the Serbian language, as you pointed out, I would

4 suspect that you understand the meanings of words and you choose words

5 quite appropriately, especially when you are a suspect and especially when

6 you have had a chance to caucus with your friends and come up with a

7 chronology of events?

8 A. Allow me to respond with an example that is so obvious that you

9 will see that you are not right. My last interview which I have here in

10 the original the way I gave it on some over 200 pages is so illiterate

11 that I was really ashamed when I was reading it, how illiterate sound it

12 is. So the last one, even with the assistance of all the lawyers that

13 were there is quite illiterate sounding and I as a teacher should be quite

14 ashamed of that, and believe me, I am. The atmosphere in which I'm doing

15 these interviews, and I'm not much of a speaker anyway. So this

16 atmosphere this pressure and the attempt to provide as many details as

17 possible, which many people warned me is not good. But as I said I have

18 no experiences with any courts. I am participating in a court proceeding

19 like this for the first time in my life. So I cannot be too exact, I am

20 afraid that I would miss something, so I am making digressions and the

21 least of my worries is semantics or the meanings of certain words.

22 So if you are insisting, since you are mentioning the term all the

23 time, and as you are malicious sometimes, I'm telling you, please define

24 in what sense are you talking about semantics, as a discipline of

25 linguistics or as semiotics. So you are a lawyer. When we are talking, I

Page 6300

1 am constantly confused about what you are talking about.

2 Q. Mr. Milosevic -- I mean, Mr. Deronjic we are out of time.

3 JUDGE LIU: Mr. Karnavas, today we are also five minutes past our

4 time. And we will resume tomorrow morning at 9.00. The hearing is

5 adjourned.

6 --- Whereupon the hearing adjourned

7 at 1.50 p.m., to be reconvened on Wednesday,

8 the 21st day of January, 2004, at 9.00 a.m.