Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4131

 1                           Friday, 8 May 2009

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.04 a.m.

 5                           [The witness takes the stand]

 6             JUDGE PARKER:  Good morning.  The affirmation you made at the

 7     beginning of your evidence to tell the truth still applies, and I think

 8     Mr. Hannis is continuing.

 9             MR. HANNIS:  Thank you, Your Honour.

10                           WITNESS:  ZARKO BRAKOVIC [Resumed]

11                           [Witness answered through interpreter]

12                           Examination by Mr. Hannis: [Continued]

13        Q.   Good morning, General.

14        A.   Good morning to everybody.

15        Q.   First I would like to have you take a look at tab 24 in your

16     binder.  This is document 65 ter number 01591.  General, I believe this

17     is a phone list that looks like some sort of internal phone list for, I

18     think, your SUP in Pristina.  Do you recognise that?

19        A.   Yes, I do.

20        Q.   Do you know what time-period this would be applicable to?

21     Because I see the chief is listed as Djordje Keric, and I'm not sure when

22     he was chief of your SUP.  Do you know what year this would pertain to?

23        A.   Well, I couldn't really say what year with complete certainty,

24     but I know that the Pristina -- chief of the Pristina Secretariat of the

25     Interior, Djordje Keric, who is listed here, he served in that capacity

Page 4132

 1     from 1994 until 1997, but I'm not quite sure what time-period.

 2        Q.   Okay.  And I see, I think, the fifth -- or the fourth name down

 3     is your name as department chief for the police department, and that was

 4     a position you held at that time; right?

 5        A.   Yes.

 6        Q.   I see to the far right of your name in the last column there's a

 7     UKF call-sign.  I take it that's your radio call-sign, Grmija 1 -- or

 8     Grmija 3, I guess?

 9        A.   That was the -- that was my call-sign in a time-period, and after

10     that it was changed, and I think it was Sitnica 101, if I'm not

11     mistaken -- actually, I apologise.  Let me just look at this.  Yes, I

12     think it was the way I just told you.

13        Q.   Okay.  And that second call-sign you mentioned Sitnica 1.  When

14     was that used?

15        A.   Sitnica 101.  I think that the call-signs were changed for

16     everyone at a certain point in time and that everybody was assigned

17     different call-signs, but again with the caveat if my memory serves me

18     right.

19        Q.   Do you recall when that change took place, what year?

20        A.   Well, I think it was sometime in 1996 or maybe 1997.

21        Q.   Okay.  Was that still in use in 1998 and 1999?

22        A.   If my memory serves me right, I don't think so.  I don't think

23     so, but let me tell you once again, I think it was changed at one point,

24     as I've already indicated.

25        Q.   Do you recall what your radio call-sign was in 1998 and/or 1999?

Page 4133

 1        A.   I think it was Sitnica 101.

 2        Q.   Thank you.  Going down the column, number 26 the position is

 3     described as police station -- SM, which I think means police station,

 4     commander for, and then there's an acronym or an abbreviation which in

 5     English is translated as DiI.  Can you tell me what that stands for, if

 6     you know?  It's the position for V. Petrovic.

 7        A.   Of course that acronym -- this means the commander of the police

 8     station for duty and interventions, so this is probably the period before

 9     1996 because I think that in 1996 that got changed.  It was no longer

10     Stanica milicija but policija, because the name of the organisation

11     changed from milicija to policija, and I believe that it happened in

12     1996.

13        Q.   Okay.  Thank you.  The last question on this document, number 28,

14     two down from the column we were just looking at, there is an assistant

15     commander named G. Djordjevic.  Do you know who that was?

16        A.   I assume it was Goran Djordjevic, that's my assumption.  I'm not

17     sure about that.

18        Q.   And do you know if he was related to General Vlastimir

19     Djordjevic?

20        A.   Well, I can't be certain, but if Goran Djordjevic -- well, I know

21     that he was a police officer in the Podujevo police station at the time

22     when I was the commander, and I know that he hails from Nis, and he never

23     mentioned anything.  So if it is the same man, I do know him quite well,

24     and he never mentioned that at all.

25        Q.   I don't know if he is or not.  I was just asking if you knew.

Page 4134

 1             MR. HANNIS:  Your Honours, I'd like to tender 1591 at this time.

 2             JUDGE PARKER:  It will be received.

 3             THE REGISTRAR:  That will be assigned P00763, Your Honours.

 4             MR. HANNIS:  Thank you.

 5        Q.   General, next I'd like to direct your attention to Exhibit P133.

 6     This is tab 15 in your binder.  I don't know if this one of the documents

 7     that Mr. Stamp showed you or not.  Have you seen this particular before?

 8     It's dated the 28th July, 1998, and it appears to be a MUP dispatch

 9     assigning or deploying certain PJP detachments to Kosovo.

10        A.   I saw this document a couple of days ago.  Mr. Stamp showed it to

11     me.

12        Q.   Did you see this document in 1998, if you recall?

13        A.   I don't think so.

14        Q.   Did you see documents like this in 1998 or 1999?  And I'm

15     referring to dispatches from the ministry sending or deploying PJP units

16     to Kosovo.

17        A.   Well, I must have seen a dispatch of this kind, but they did not

18     pertain to me.  So I cannot rule out the possibility that I saw it, but I

19     can't remember specifically because it was not addressed to me, attention

20     to me.  I may have seen it in passing on somebody else's desk, but I

21     can't remember that.

22        Q.   This one makes reference to certain detachments to be deployed,

23     and you'll see that the 66th Detachment was to be deployed to Pristina.

24     Do you recall in July 1998 whether the 66th Detachment of the PJP arrived

25     in Pristina?

Page 4135

 1        A.   I don't think so.

 2        Q.   You don't think it arrived?

 3        A.   No, I don't remember.

 4        Q.   Oh, okay.  Did you ever have any dealings with that particular

 5     PJP detachment?

 6        A.   No.

 7        Q.   Thank you.  Let me show you next tab number 17.  This is

 8     Exhibit P356.  This is a dispatch dated the 18th of February, 1999, from

 9     General Djordjevic.  Going to, among others, all the SUP chiefs, to the

10     ministry staff in Pristina, to the border police stations.  I see it's

11     not addressed to you, but I have a couple questions that you may be able

12     to help us with.  Item number 1 calls upon the addressees to update the

13     defence plan, and in particular update establishment lists of active and

14     reserve policemen, recruit to full capacity the 21st to the

15     87th Detachments in the PJPs, carry out a troop review, et cetera.

16             Can you recall now what the defence plan was that was in place

17     for the MUP in February of 1999, in general?

18        A.   Well, I can't really be certain, but I assume that it was a plan

19     for the defence of the facilities or installations of the MUP, the key,

20     vital facilities.  I assume that that is what it's all about.

21        Q.   And do you know whether this action was carried out, that is,

22     updating and recruiting to full capacity for the 21st through the

23     87th PJP Detachments?

24        A.   Well, I assume yes.  But when the lists were updated the staff --

25     for the staffing level from the 21st and to the 88th PJP Detachments, I

Page 4136

 1     can say only for the two companies and the 124th Intervention Brigade

 2     because as the department chief they were under my aegis as regards the

 3     staffing levels.  I was in charge of that, so I can only speak about

 4     those.

 5        Q.   And what can you say about those of yours?

 6        A.   For the two companies you mean?

 7        Q.   Yes.

 8        A.   I can say that if the companies were not at full strength, then

 9     new personnel would be brought in; they would be reinforced.  And that's

10     probably what was done.

11        Q.   Do you recall if that was done in February 1999, about a month

12     before the NATO bombing began?

13        A.   Well, I really can't recall if it was done, but in light of the

14     dispatch and the orders contained therein, I assumed that it was the

15     case.  But I can't now remember with complete certainty whether it was

16     done and how it was done, in what way.

17        Q.   All right.  Could you turn to item number 7 in that dispatch.

18     And my English translation has that as directing:

19             "Through intensified intelligence and other measures and actions,

20     carry out the necessary checks, compile lists, and establish complete

21     control over volunteer and paramilitary units and their members."

22             In February 1999 were you aware of the existence in Kosovo of

23     paramilitary units or volunteer units?

24        A.   I was not aware of it.

25        Q.   At any time in 1998 or 1999, were you personally aware of the

Page 4137

 1     existence of such units?

 2        A.   No.

 3        Q.   Do you know why General Djordjevic would be directing that that

 4     kind of activity be carried out, unless there were such units in Kosovo?

 5             MR. HANNIS:  I see Mr. Djurdjic on his feet.

 6             JUDGE PARKER:  Yes.

 7             MR. DJURDJIC: [Interpretation] Your Honour, I have to intervene

 8     because I believe that this is a leading question because you can see

 9     from the title that this dispatch was sent to all Secretariats of the

10     Interior from 1 through 33, not only in Kosovo and Metohija, so it's a

11     tendentious question.  This pertains to the entire territory of the

12     Republic of Serbia.

13             JUDGE PARKER:  Thank you.

14             MR. HANNIS:

15        Q.   General, if I rephrase my question, do you know why

16     General Djordjevic would be directing that kind of activity be carried

17     out unless there was such units in Serbia in 1998 or 1999?

18        A.   Well, I couldn't really tell you what the reasons were behind

19     this dispatch.  What I know about the territory covered by the

20     secretariat where I worked, there were no paramilitary or volunteer

21     units.  Maybe there was some knowledge or perhaps some concern that in

22     some areas of the republic there might be or would be such units, I can't

23     really tell you, or indeed that there were some units somewhere, I can't

24     tell you that.

25        Q.   All right.  Let me show you next item 22 -- tab 22 in the binder.

Page 4138

 1     This is 65 ter number 01989.  And these are described as the minutes of a

 2     meeting with senior police officials in Kosovo and Metohija, 4th of

 3     April, 1999.  Have you seen this document before?

 4        A.   Yes, during my proofing for my testimony here.

 5        Q.   Okay.  I know that under the agenda, the three agenda items, it

 6     says that the meeting was held by General Stevanovic and General Lukic,

 7     and it was attended by the chiefs of all secretariats, PJP detachment

 8     commanders, the SAJ commander, and the JSO commander, among others.  As

 9     brigade commander of the 124th, did you attend this meeting?  I don't see

10     you listed as speaking, but the it says "detachment commanders."  Do you

11     recall if you were there or not?

12        A.   Well, I can't really tell you with complete certainty, but in all

13     likelihood, yes, I was there.

14        Q.   And among those speaking were the SAJ commander Zivko Trajkovic.

15     I think you told us yesterday that you knew him.  When would you see

16     Commander Trajkovic in Kosovo?  Would it be at meetings like this, or did

17     you have any other dealings with him in your position as brigade

18     commander for the PJP?

19        A.   Well, I would usually see him at meetings, but sometimes it would

20     happen, admittedly not often, that we would run into each other in the

21     field.  Now I'm primarily talking about 1998 not 1999.

22        Q.   And the JSO commander is listed, he's the second speaker after

23     Trajkovic.  And the name mentioned is Milorad Jankovic.  Did you know a

24     Milorad Jankovic?

25        A.   No, I don't know Milorad Jankovic.  I assume there is an error

Page 4139

 1     here.

 2        Q.   That's what I was curious about, because I know yesterday we

 3     looked at Exhibit P57, which was the 16 June 1998 decision by the

 4     minister establishing a staff for the suppression of terrorism, and it

 5     listed the JSO commander as being Milorad Lukovic.  Is that the person

 6     you knew to be the JSO commander in April of 1999 in Kosovo?

 7        A.   Yes.

 8        Q.   So I think that's probably a typographical error.

 9        A.   Obviously it is.

10        Q.   And your -- what dealings, if any, did you have with a

11     Milorad Lukovic in Kosovo in 1998 or 1999, other than seeing him at a

12     meeting like this?  Did you have any other occasion to work with him?

13        A.   I don't think so.

14        Q.   Okay.  And his nickname was Legija; is that correct?

15        A.   Yes.

16        Q.   Thank you.  Now I want to ask you about --

17             MR. HANNIS:  I'm sorry.  Could I tender that before I move on,

18     Your Honour?

19             JUDGE PARKER:  It will be received.

20             THE REGISTRAR:  That will be assigned P00764, Your Honours,

21     that's for document ID 65 ter 01989.

22             MR. HANNIS:  Thank you.

23        Q.   General, if you could turn next to tab 23 in your binder.  Now,

24     this is -- this is a VJ document and the number --

25             MR. HANNIS:  The 65 ter number of this one, Your Honours, is

Page 4140

 1     02821.

 2        Q.   It's dated the 19th of May, 1999, from Colonel Bozidar Delic at

 3     the -- who was the commander of the 549th Motorised Brigade.  Did you see

 4     this document when you were being prepared to testify by Mr. Stamp?

 5        A.   Yes, I did.

 6        Q.   Was that the first time you ever saw it?

 7        A.   Yes.

 8        Q.   I would like to ask you about item number 3.  I think it's on

 9     page 1 of your document.  It says:

10             "The 5/124th OdPJP in coordinated action with other defence

11     forces shall carry out combat control of the territory ..."

12             And then it describes the location.  Can you tell me what that

13     stands for.  Is that the 5th Company of your brigade?

14        A.   It's the 5th Company of the 124th Detachment, and I'm quoting as

15     it says.

16        Q.   Okay.

17        A.   So it's not a brigade but a PJP detachment.

18        Q.   Was there 124th PJP Detachment that was something distinct,

19     separate, from your 124th Intervention Brigade?

20        A.   No.  Such a thing did not exist.  I suppose that what it's meant

21     here is the 5th Company of the 124th Intervention Brigade.

22        Q.   Okay.

23        A.   However, this is probably a typo or an error.

24        Q.   Or it could be that Colonel Delic wasn't all that familiar with

25     the MUP designations, and since most of the others were detachments, he

Page 4141

 1     assumed the 124th was a detachment as well?

 2        A.   That may well be the case.

 3        Q.   Did any of the other detachments have as many as five companies

 4     within them?

 5        A.   I believe that every detachment had five or more companies.

 6        Q.   Do you know if in May -- on or about May 19th, 1999, the

 7     5th Company of your brigade was involved in a coordinated action with the

 8     VJ in the area of Pirane, Landovica, and Novaki villages in Kosovo?

 9        A.   No, I don't know that.

10        Q.   Do you know who the commander of your 5th company was at that

11     time?

12        A.   Of course I do.  It was Lieutenant-Colonel Veljko Radenovic.

13        Q.   Thank you.  And could you look at number 9 in this order, the

14     last item.  It says:

15             "Detachments commands of the PJP shall issue orders regulating

16     all other issues within their domain related to the units life and

17     operations.  That will be done according to positive rules in force in

18     our previous orders."

19             I know in your statement you've talked a little bit about how

20     these joint operations with the VJ worked.  Is what's written here

21     consistent with your experience in real life in these joint operations

22     about how a command worked within the MUP when you were working jointly

23     in combat operations with the VJ?

24        A.   I would kindly ask you to repeat your question because I'm not

25     entirely sure that I understood your question properly the first time

Page 4142

 1     around.

 2        Q.   Well, maybe I should rephrase it because I'm not trying to put

 3     words in your mouth.  But could you describe --

 4        A.   That would be good.

 5        Q.   Could you describe for us how the coordination worked with the VJ

 6     when these joint combat actions or operations were carried out.  Who was

 7     in command of the MUP units for which purposes, if you will?  Can you

 8     elaborate on that for us?

 9        A.   [No interpretation]

10             [Interpretation] As you can see in the document, the order was

11     signed by commander Colonel Delic.  I assume that -- just a moment.

12     Could you please bear with me.

13        Q.   Sure.

14        A.   If you're asking me very concretely about this particular order,

15     this order applies more to the deployment of units which were in charge

16     of the combat control of the territory.  This means that they were

17     supposed to be in a certain territory, and they were supposed not to

18     allow terrorist groups or anybody else to appear that might have posed a

19     threat to security.  And you can see that some tasks were issued, which

20     wings, which flanks, which units, which roads to be very precise in terms

21     of this document, as far as this document is concerned.  I don't think

22     that this is an order for the execution of a concrete task or action.

23     This is an order regarding the control of a territory following an action

24     or an operation or a territory that has to be placed under control, as it

25     were.

Page 4143

 1        Q.   Okay.  I take your point.  We'll look at -- in a minute or two at

 2     some more specific combat-related action orders.

 3             MR. HANNIS:  Your Honour, I'd like to tender that now before I go

 4     to the next one.

 5             JUDGE PARKER:  It will be received.

 6             THE REGISTRAR:  65 ter number 02821, Your Honours, will be

 7     assigned P00765.

 8             MR. HANNIS:  Thank you.

 9        Q.   General, if you turn next to tab 47 in your binder, and this is

10     65 ter number 04057.  It's dated the 9th of April, 1999, from

11     General Lazarevic of the Pristina Corps command.  I don't know, did

12     Mr. Stamp show you this document when he proofed you?

13        A.   I think so, yes.

14        Q.   You see the -- and it is an internal VJ document, but -- and you

15     may be able to help us with some of this.  The second paragraph says:

16             "The staff of the Serbian MUP for Kosovo and Metohija has issued

17     an order to all secretariats to commence planning actions to crush the

18     terrorist groups that remained in the respective zones of

19     responsibility."

20             Do you recall that having been done, that the secretariats had an

21     order to plan actions, anti-terrorist actions, within their own zones on

22     or about the 9th of April, 1999?

23        A.   I don't remember any such order having been issued.

24        Q.   Do you recall whether or not anti-terrorist actions were planned

25     within your Pristina SUP in April 1999?  Do you recollect any?

Page 4144

 1        A.   No, I don't think so.

 2        Q.   If you'll continue down on that document General Lazarevic is

 3     directing his subordinates to:

 4             " ...  coordinate actions with MUP units in crushing the Siptar

 5     terrorist forces, immediately establish contact with SUP chiefs

 6     concerning the following ..."

 7             And then item number 1 is for the Pristina SUP, and it lists

 8     three different actions, the first being in the Kosmac Donje Obrinje

 9     area, second in Kacanik area, and the third in Orlane apparently and

10     specifying the VJ units that were going to participate.  Do any of those

11     look familiar to you as actions that the Pristina SUP or your brigade

12     assisted or cooperated with the VJ on in April of 1999?

13        A.   I don't remember any of that as having happened and having

14     involved MUP forces.  I'm not excluding others, but those that I worked

15     with, I don't think so.  And I believe that here under 1 or 2, Kacanik

16     action, this is not part of the territory of the Pristina secretariat but

17     rather of the Urosevac secretariat.

18        Q.   Okay.  Did any members of your 124th Intervention Brigade

19     participate in joint combat actions with any of these VJ units, the

20     15th Armoured Brigade, the 37th Motorised Brigade, the 354th Infantry

21     Brigade, or the 211th Armoured Brigade in April of 1999?

22        A.   I've just said that I don't think so, at least not to my

23     knowledge.  Maybe some other units were engaged in that way, but I was

24     not involved.  I was not part of that.

25        Q.   All right.  Let me move then to tab 57, and tab 57 is 65 ter

Page 4145

 1     number 01971.  This is a Joint Command order dated the 13th of April,

 2     1999.

 3             JUDGE PARKER:  Everybody is concerned you haven't sought to

 4     tender this, Mr. Hannis, and I suspect I know that you've decided not to.

 5             MR. HANNIS:  Well, Your Honour, I don't feel comfortable in doing

 6     that.  Given his answers about the document and given that it's a VJ

 7     document, I think it's more appropriate to do it later with someone else.

 8     Thank you.

 9                           [Trial Chamber confers]

10             MR. HANNIS:  And I appreciate the concern of my colleagues to

11     keep me on track.

12        Q.   This is dated the 13th of April, 1999, and it's for -- it's an

13     order on routing and destroying Siptar terrorist forces in the area of

14     Zegovac.  I understood from the notes I got from Mr. Stamp that he talked

15     or showed this -- showed this one to you, and this was a joint action

16     that you were familiar with.  Is that right?

17        A.   Yes, I am familiar with this operation.

18        Q.   [Microphone not activated] And the VJ units involved in this

19     action were the 252nd Tactical Group which included our battalion and the

20     175th Intervention Brigade.  Do you recall which units assisted in this

21     action?

22        A.   If I can recall properly, I believe that parts of several

23     companies from the 124th Intervention Brigade participated, also some of

24     the units of the 36th Detachment, and I believe that SAJ as well was

25     involved.

Page 4146

 1        Q.   Now, this particular order itself, did you see orders like this

 2     in 1998 or 1999 coming from a body called the Joint Command for Kosovo

 3     and Metohija?

 4        A.   I did see similar orders similar to this one, but I must be

 5     honest and admit that at that time I believe that all orders had been

 6     issued by the corps command, the corps command of the military.  Judging

 7     by the content and everything else, that's what they looked like.  I did

 8     not pay too much attention to the heading of these orders.

 9        Q.   Okay.  I agree with you.  The number and the format all seem to

10     be consistent with Pristina Corps documents at the time, and I think

11     that's what General Lazarevic would say as well.  So I'm not trying to

12     mislead you or trick you on anything here, but that is what it says on

13     the document.  But how would you see these orders?  How did you come to

14     see a copy?  Did someone deliver it to you, or did you pick it up from

15     someone?  How would you see them?

16        A.   Somebody would submit them, or I would go to a meeting where it

17     was agreed to carry out preparations for an action including

18     reconnoitring of the area of the future action, and I would receive a

19     document similar to this one.  It would be an order for the execution of

20     a task.  And I would also be given a map which we called a decision for

21     the execution of task, and we would receive the topical excerpt and

22     concerned the task of my units as it were.  Whatever is contained in the

23     order would be also transferred on to the map.  So when you receive an

24     order, when you receive a map, and having been familiarised with certain

25     items of the order, it happened very rarely that you look at the order

Page 4147

 1     with a lot of attention because you look at the decision, a map with the

 2     deployment of all units depicted there, you look at the ground and all

 3     the neighbouring units.  If you only read the order, you can't gain a

 4     similar impression, such a detailed impression.  For us the main document

 5     was that decision on the map, and this was what governed us in the

 6     execution of the task.

 7        Q.   Well, that makes sense to me that the map showing the positions

 8     of the units and the enemy and the directions of movement, et cetera,

 9     would be more important to you in carrying out a task like that; is that

10     fair?

11        A.   Yes, more or less that would be the case.

12        Q.   And as brigade commander did you actually go out in the field on

13     some of these joint VJ/MUP anti-terrorist actions in 1998 and 1999?

14        A.   Well, this is implied.

15        Q.   Okay.  I just wanted to be sure it was the correct interpretation

16     of what you did, and I think in your statement you indicated that --

17     sorry.

18        A.   I apologise.  Let me just add that applied to actions where I as

19     a unit commander participated with parts of my unit and not to all the

20     preparations for the action that involved some other parts, some other

21     companies, which cooperated with other units.  In that latter case I

22     wouldn't go, but when I was engaged as a unit commander with parts of my

23     unit, that was implied.

24        Q.   Okay.  I understand.  Thank you.  And when you got copies of

25     these orders and the decision maps as I would refer to them, who did you

Page 4148

 1     actually physically get that from?  Was that somebody in the MUP or

 2     somebody in the VJ or did it -- did it change from time to time who you

 3     got it from?

 4        A.   If I'm not mistaken, when that happened in the field I believe

 5     that we received this from our colleagues -- from our colleagues in the

 6     military.  And when this happened in some rooms, on some premises, then

 7     this would be delivered to us at times in envelopes, or it would be

 8     handed over to us in envelopes.  I believe that this was done by people

 9     from the MUP staff.  I'm sure that the envelopes were delivered to us.

10        Q.   Do you know who in the MUP staff was primarily responsible for

11     coordination or liaising with the VJ for purposes of joint VJ/MUP combat

12     activities?  Was there a particular person?

13        A.   It probably existed, but I don't know who it was.  This was

14     command superior to me, a higher command, so I can't say with any degree

15     of certainty who that person was.

16        Q.   Do you know if, first name, Dusko Adamovic ever performed that

17     function?

18        A.   I can only assume, knowing that he was a member of the staff, but

19     I can't say with certainty that he was the one who did it because I did

20     not have an occasion to see him in action, as it were.

21        Q.   Okay.  Did you ever receive any of these orders or decision maps

22     from him?

23        A.   I'm -- I suppose so, most probably yes.

24        Q.   How about in the VJ, did you ever -- no, apart from in the field,

25     where you might have met face-to-face with a VJ field commander, but did

Page 4149

 1     you have any dealings concerning these decision maps or the orders for

 2     joint actions?  Did you receive any from anybody in the VJ, from the

 3     Pristina Corps, if you recall?

 4        A.   I believe so.  I just said that if we received that in the field

 5     directly during meetings concerning the execution of a concrete task of

 6     reconnoitring, then the answer is yes.

 7        Q.   Okay.  Did you ever meet or deal with a VJ officer named

 8     Radojko Stefanovic in connection with these kind of coordinating

 9     activities?

10        A.   When it comes to coordinating activities, if I'm not mistaken,

11     the answer's no.  And as for Radojko Stefanovic, I was with him, if I'm

12     not mistaken, in the last action before the signing of the

13     Kumanovo Agreement.  I can't remember the exact title of the action now,

14     but I know that it was in the territory of a place called Berisa.  He was

15     present there on behalf of the corps command.

16        Q.   Okay.  Thank you.

17             MR. HANNIS:  I'd like to tender that one now, if I may,

18     Your Honours.

19             JUDGE PARKER:  It will be received.

20             THE REGISTRAR:  65 ter number 01971, Your Honours, will be

21     assigned P00766.

22             MR. HANNIS:  Thank you.

23        Q.   And if you could go to the next tab in your binder, it's tab 58,

24     General.  This is a similar Joint Command order dated the 15th of April,

25     1999, and it's an order for the routing and destroying of the Siptar

Page 4150

 1     terrorist forces in the area of Jezerce.  Were you shown this document

 2     when you were being proofed?  And I should indicate this is 65 ter number

 3     01976 -- I'm sorry --

 4        A.   Yes.

 5        Q.   And I think this is an action that you were familiar with; right?

 6        A.   I did participate directly in this action.

 7        Q.   And which of your subordinate PJP companies took part, if you

 8     remember?

 9        A.   It is evident that this action was a somewhat broader action, and

10     it comprised a number of units of the military and a number of police

11     units as well.  I was directly engaged in one part of the terrain

12     together with, if I'm not mistaken, four PJP companies.  From the

13     strength of my unit I coordinated their work, and I was in charge of

14     their work on the Urosevac - Gornje and Donje Nerodimlje - and Stojkovici

15     axis.  I believe those were the names of the villages.  Our task within

16     the overall mission was to take some of the evelations [as interpreted]

17     which are known as the Jezersko mountain range.  We accomplished the task

18     in the course of the first day.  There was one part of the task which we

19     could not objectively carry out because of the other participating units.

20     Once the conditions were in place, we managed to accomplish those tasks

21     as well.  Generally speaking, it was one of the easier tasks that I

22     participated in, in terms of the speed.  However, the whole thing lasted

23     quite a long time, and the conditions were very difficult for the men who

24     participated in the operation.

25        Q.   Do you recall which specific VJ units you worked with on that

Page 4151

 1     occasion?  Those listed in the order included the 252nd Tactical Group,

 2     the 243rd Mechanised Brigade and the 549th.  Do you recall which ones you

 3     might have worked most closely with?

 4        A.   With the 252nd, that's the Tactical Group 252.

 5        Q.   Okay.

 6        A.   Because even in the task TG 525, it says set up a blockade on the

 7     line Stimlje-Kosare-Gornje Nerodimlje; that's what I said.  That's the

 8     axis that we had as our designated axis.

 9             MR. HANNIS:  Thank you.

10             Your Honours, I would like to tender that one.

11             JUDGE PARKER:  It will be received.

12             THE REGISTRAR:  It will be assigned P00767, Your Honours.

13             MR. HANNIS:

14        Q.   And related to that I'd next like to show you tab 21.  This

15     document is 65 ter number 03081.  This is a war diary of the

16     549th Motorised Brigade.  And I just want to ask you about an entry in

17     there if you can help clarify something for me.  I think it's page 53 of

18     the B/C/S under tab 21.  It's a very thick document.  Do you find that?

19     It's the fattest document in your binder, I believe.  And we're looking

20     at page 33 in the English.  I'll tell you this is part of an entry for

21     the 26th of April, 1999.  And I don't know if you can find -- in the

22     upper right-hand corner there may be a page number 53 written.  Do you

23     see any numbers?

24             JUDGE PARKER:  This is page 55.

25             MR. HANNIS:  Ah, okay.

Page 4152

 1        Q.   And it's in e-court as well.  It may be on the screen.  I think

 2     that tab there indicates the page actually.  And you see there's a

 3     reference to --

 4        A.   I think I've been able to find it.

 5        Q.   The entry says:

 6             "In the course of the day, MUP units supported by parts of the

 7     brigade's units continued destroying the Siptar terrorist forces in

 8     Budakovo and the village of Jezerce.  During the course of the day the

 9     total number of units grew by two detachments of MUP special police and

10     of Pristina SAJ ..."

11             What was the Pristina SAJ?  Did the Pristina SUP have a SAJ unit

12     within it or was the -- can you tell us what that refers to, if you know?

13        A.   The special anti-terrorist unit, the name itself tells you that

14     this is a unit for special anti-terrorist tasks, so it was not part of

15     the Pristina SUP.

16        Q.   Okay.  Was it based in Pristina?

17        A.   It was based in a place near Pristina, Ajvalija.

18        Q.   Okay.  Yes, I've heard that.  Thank you.  And the MUP special

19     police, the PJP, would have been assisting the 549th Brigade in this

20     area.  Do you know which company or which detachments those were?

21        A.   As indicated in this document, it says the Budakovo-Jezerce

22     village axis.  So that is the axis that goes in the opposite direction

23     from the axis where I was, so that I really don't know what units took

24     part, MUP or military units.  But one can conclude that it was part of

25     the 400 -- 549th Brigade of the military of the Yugoslav Army because

Page 4153

 1     that was their area, but I really don't know.  I assume that the distance

 2     as the crow flies was maybe some 20 kilometres or more because

 3     Budakovo -- well, I never went there, but Budakovo is further down from

 4     Suva Reka, and if you go towards the Jezersko mountains.  I was never in

 5     that area so I can't really tell you.  That's just my assumption.

 6        Q.   Thank you.  Now, I want to turn to your statement.  In

 7     paragraph 16 you make reference to having heard about the existence of

 8     the Joint Command, and you said you'd thought you'd heard of it by the

 9     second half of 1998.  You --

10             MR. HANNIS:  And I don't want to tender that diary at this point

11     in time, Your Honours.  I think it's premature.

12        Q.   You said that you also became more aware generally of the

13     existence of the Joint Command after the war when you came across a

14     reference to it in a book on compliance with the Laws of War published by

15     the VJ.  I want to show you a document, and I ask you if this is the book

16     you're referring to.  This would be document 65 ter number 01011.  You

17     don't have a hard copy in your binder so you'll have to look on the

18     screen with me.  I see the English version.  I don't know if you see a

19     B/C/S version on your screen.

20             MR. HANNIS:  And I see Mr. Djurdjic on his feet.

21             JUDGE PARKER:  Mr. Djurdjic.

22             MR. DJURDJIC: [Interpretation] Thank you, Your Honour.  Well, in

23     advance, since we are now about to address a new topic in this trial,

24     what is the status of some books that were read after the relevant period

25     and the evidence of the witness regarding something he read afterwards?

Page 4154

 1     Just so I could be guided by the precedence, so that I could deal with

 2     the same issues in the course of my Defence case.

 3             JUDGE PARKER:  There is no short or general answer to your

 4     question, Mr. Djurdjic.  Among other things, we would look at the nature

 5     of the authorship, the responsibility of any office held by the author,

 6     whether it was an article purporting to reflect the activity, for

 7     example, of the Yugoslav Army at a particular time written by a member of

 8     that army or whether it was some other study.  All of those things would

 9     determine for the Chamber what relevance and assistance a book written

10     after the event might be.  We start with the question that you are

11     posing.  This is something after the event; therefore, how is it

12     relevant?  Unless there's a clear answer to that, a positive answer, then

13     it would not be admitted.  But we will look more at this work as it is

14     unfolded and see what we make of it.

15             MR. HANNIS:  Thank you, Your Honour.

16        Q.   I'm just trying to establish, is this the book that you were

17     referring to your statement?  Can you tell by looking at the cover?

18        A.   Well, I think so.  I was not in a position to take this book into

19     my hands and read it to the end.  I remember seeing it somewhere, but I

20     don't know where.  And as I leafed through it I saw what I've just told

21     you.  It is not a book that I had in my possession; it is not at a book

22     that I read or studied.  It's simply a book that I happened upon, and I

23     leafed through it and saw those elements.

24        Q.   Okay.  Let me show you a specific page and see if that will help.

25     I think it's page 51 of the B/C/S in e-court, and page in English is

Page 4155

 1     page 72.

 2             I'm going to show you a page in this book that makes a reference

 3     to Joint Command, and maybe when you see it in your B/C/S version -- on

 4     the right you'll see -- in the right column you'll see a document that

 5     looks like a cover page of a document, and there are a couple of circled

 6     portions of excerpts from that document.  And I think the title of that

 7     is Joint Command for KM, Kosovo and Metohija, and it's a report and

 8     conclusions on the implementation of the plan for stamping out terrorism

 9     in Kosovo and Metohija.

10             Does that help you remember whether or not this may have been the

11     book that was the source of your post-war additional information about

12     the Joint Command?

13        A.   Well, I couldn't confirm on the basis of the front page, but on

14     the basis of the details from the book.

15        Q.   You'll see -- we may have to show you the entire B/C/S page, but

16     the English translation, paragraph related to this cover page says:

17             "In the report and conclusions on the implementation of the plan

18     on stamping out terrorism in Kosovo and Metohija of November [sic] 1998

19     signed by the Joint Command for Kosovo and Metohija, the course and

20     consequences of operations by the Yugoslav Army and MUP units between 25

21     and 29 September 1998 are analysed in detail."

22             And it goes on.  Does that ring any bells?  I'm just trying to

23     find out if this is the document you're talking about in your statement,

24     or if there's another one I should be trying to find.

25             If you remember or you don't remember, just let me know and I'll

Page 4156

 1     move on.

 2        A.   Well, I can't remember the details, the specific details, from

 3     the book, but this is the book where I saw it.  Now, as to what details

 4     are actually -- I actually saw, a long time has passed, and I never have

 5     seen them again.  But I think that more or less this is the book.

 6        Q.   Okay.  Thank you.  I don't have any other questions about that

 7     then.  I want to go back to your statement.  In paragraph 19 of your

 8     statement you mention that after combat operations PJP personnel were

 9     required to account for spent ammunition.  How was that done?  Did each

10     soldier count the number of bullets he had used and then report that to a

11     commander, who gave you a report?  How was that reported?  Orally?

12     Written?

13        A.   Well, when the war started the consumption of ammunition was

14     justified unit by unit because to get re-supplied with ammunition that

15     you needed for your next mission, you had to write a report indicating

16     that in such and such action you expended a certain quantity of

17     ammunition and that, therefore, you needed additional quantities of

18     ammunition.  And this is what you quoted back to me from my statement

19     refers to.  So it would be only logical for it to be determined from the

20     level of the individual up to the level of the unit.  Right.

21        Q.   Okay.  And that written report concerning the use of ammunition,

22     did it have any other report about the action in which the ammunition was

23     used?  Or did it only report on quantities used with no further detail

24     about where, how, why?

25        A.   Well, I really can't remember those details.

Page 4157

 1        Q.   Did -- during 1998 and 1999 as brigade commander, did you ever

 2     prepare written reports concerning combat actions or anti-terrorist

 3     actions carried out by your subordinate units?

 4        A.   It was my duty to draft in the second half of 1999 a report, but

 5     we didn't do reports for every single action.  It was, I assume, done by

 6     the military unit that took part in the same task together with us.

 7        Q.   Okay.  You said it was your duty to draft in the second half of

 8     1999 a report.  What kind of report?  Was that a report about all the

 9     actions of your unit prior to that date or during the war?  What was that

10     report?  A summary of all those actions?

11        A.   Yes.

12        Q.   Okay.  And --

13        A.   So it's a comprehensive report for 1998 and 1999, if I'm not

14     mistaken.

15        Q.   And to whom was that report sent?

16        A.   I think it was sent to the police administration.

17        Q.   In MUP headquarters at the republic level?

18        A.   Yes, the police administration within the ministry.

19        Q.   And who was the head of that administration at that time, if you

20     remember?

21        A.   If my memory serves me right, I don't think that there was a

22     chief in that administration at that time.  That's what I think.  There

23     was only the deputy chief.

24        Q.   Okay.  And was the assistant minister in charge of that

25     administration Obrad Stevanovic?

Page 4158

 1        A.   Well, I don't know whether that was his duty, but Ljuba Aleksic

 2     was the deputy chief of the administration, so I assume that he performed

 3     the duties of the administration chief because when the administration

 4     chief is not there, then it's the deputy chief who acts in his stead.

 5        Q.   And I don't think I've ever seen that report.  Do you have a

 6     copy?

 7        A.   Unfortunately, no.

 8        Q.   Were there any other copies sent by you to anyone else other than

 9     to the police administration in the ministry?

10        A.   Only to the police administration and the ministry; that was the

11     order.

12        Q.   Who did the order come from?

13        A.   Well, I couldn't really tell you with complete certainty who it

14     came from.

15        Q.   You don't know the name or the title or the organ from which the

16     order came to write this report?

17        A.   Well, I simply can't remember what organ actually sent it.  It

18     may have been the police administration, for instance, but as I said I

19     can't remember so I'm not sure if that was the case.

20        Q.   Do you remember approximately when you received the order to do

21     that?

22        A.   Well, if I'm not mistaken it was sometime in the second half of

23     1999.  I can't give you the month because I don't remember.

24        Q.   Well, how long a report was this?  You're talking about a one- or

25     two-page report, or was it 40 or 50 pages?  Do you recall?

Page 4159

 1        A.   My report?

 2        Q.   Yes.

 3        A.   Well, it had several pages.  I don't know how many pages but

 4     several because it contained quite a lot of other details.  It was not

 5     just a report about the specific missions.  It had to do with equipment,

 6     weapons.  So quite a lot of things were covered in it, and those things

 7     took up more space in the report than the actual reports about the

 8     missions.

 9        Q.   Well, you'll understand my interest in this report because it was

10     written by you shortly after the events when things were fresh in your

11     mind, and you, yourself, have indicated how difficult it is sometimes to

12     remember now, ten years later.  What odd document -- what documents did

13     you use to create your report at that time?  Or did you just write it

14     based on what was in your head?

15        A.   Well, the report as such was not drafted by myself.  It was

16     actually drafted by my associates.  It was their duty to do that, and

17     they were drafted on the basis of the reports from the company commanders

18     that we received from them, so we simply put all this together.

19        Q.   Okay.  And I take it these are written reports from company

20     commanders; right?

21        A.   Yes, you're right.

22        Q.   Do you know where those written reports from PJP company

23     commanders would be today?

24        A.   Well, let me tell you, at the time when this report was drafted,

25     I was headquartered in the Secretariat of the Interior in Pristina, and

Page 4160

 1     the headquarters was relocated to Niska Banja in a building that had just

 2     a couple of rooms, and that's where the report was drafted.  And since

 3     this report is classified as confidential or strictly confidential, I had

 4     to produce just one copy and then submit it.  And the reports from the

 5     company commanders that I received, since I didn't have the wherewithal

 6     to keep them in the manner that was prescribed, I was forced to return

 7     them to the company commanders for their safe keeping because I didn't

 8     want to have any problems because that might have led to the disclosure

 9     of state secrets, and that would have engendered a number of problems.

10     And that's why I produced just one copy and returned back the originals

11     to them, thinking that I would be able to consult them if necessary later

12     on.

13        Q.   Okay.  Can you give us the names of your colleagues who helped

14     you prepare this report?

15        A.   Well, I can, but I don't want to leave anyone out.  I think that

16     Dragan Simic took part, and I think Nebojsa Sindic, I think that some

17     other people also helped out, the late Dimitrijevic.  I really can't give

18     you all of the names, but those people for the most part drafted the

19     report.

20        Q.   And you haven't seen that document since you prepared it and sent

21     it on in 1999; is that right?

22        A.   Yes.

23        Q.   You told us about how when you prepared for coming here to

24     testify that you requested some documents, and that's when you got to

25     see, I think for the first time, Exhibit P57, the decision by

Page 4161

 1     Minister Stojiljkovic creating the MUP staff for suppression of

 2     terrorism.  At that time did you request to see your report, because that

 3     seems like that would have been one of the most useful things for you to

 4     have to prepare for your testimony here?  Did you ask to get a copy of it

 5     then?

 6        A.   In the archive that I stated was at my disposal, all the

 7     documents are listed there.  So what I was interested in was to find this

 8     report, but among the documents I didn't see this report as existing --

 9     listed as existing in the archive.

10        Q.   And when you didn't see it on the list, did you ask if someone

11     could search for it?

12        A.   Well, I wasn't asking around because a while ago, maybe two years

13     ago, something like that, I was asked the same question that you're now

14     asking me about this report, and I gave the same answer.  And I realised

15     from discussing it with my colleague that there is a problem because

16     those reports are missing.  That is the impression I got.  I don't know

17     whether it's just my report, but I, at any rate, was made aware of the

18     fact that there was a problem there.

19        Q.   Do you recall who made you aware of the problem, the name of that

20     person?

21        A.   You mean who came to me with this request?

22        Q.   Well, who was the person that made you aware that some of these

23     reports were missing and that there was a problem there?

24        A.   Well, certainly.  I think that it is Goran Markovic, I think

25     that's his name, in the ministry.  He is part of the service for the

Page 4162

 1     detection of crimes, one of the departments dealing with the Tribunal, if

 2     my memory serves me right.

 3        Q.   Okay.  Thank you.

 4             MR. HANNIS:  Your Honours, I know I'm at the limit of what I said

 5     I thought I was going to take today, but it's taking me longer.  I think

 6     this witness is a very important witness for us.  I -- the only thing I

 7     think I have left to do with him is I want to talk about some MUP staff

 8     meetings in 1999.  There are about six or seven of those meetings, and

 9     then I would be done, but I would ask leave to do that after the break.

10             JUDGE PARKER:  Continue after the break --

11             MR. HANNIS:  Thank you.

12             JUDGE PARKER:  -- Mr. Hannis.

13             We will have the first break now and resume at 11.00.

14                           --- Recess taken at 10.30 a.m.

15                           --- On resuming at 11.03 a.m.

16             JUDGE PARKER:  Yes, Mr. Hannis.

17             MR. HANNIS:  Thank you.

18        Q.   Sir, before I go to some meetings of the MUP staff in 1998 and

19     1999, I wanted to ask you about your current position.  What is your

20     current position, you're still with the MUP?

21        A.   Yes.

22        Q.   What's your title and generally your duties?

23        A.   I am an advisor in the police direction.

24        Q.   I'm not sure --

25        A.   Rather, administration.

Page 4163

 1        Q.   And what kind of duties do you have as advisor?

 2        A.   Whatever I'm given to do, whatever tasks I'm given to do.  I

 3     don't have any strict orders.

 4        Q.   Okay.  All right.  Let me show you first tab 27.  This is 65 ter

 5     number 04151.  I believe Mr. Stamp may have shown you most of these MUP

 6     meetings.  This one is dated the 22nd of July, 1998, and among the

 7     attendees listed along with General Djordjevic, Stevanovic, and Lukic, it

 8     mentions all commanders of PJP detachments.

 9             Do you recall having seen this document before?

10        A.   No, not before.  Not before I was shown the document by your

11     colleague, Mr. Stamp.

12        Q.   Okay.  Do you recall if you attended this meeting?

13        A.   I'm not sure; however, if my name's there then I suppose I did.

14        Q.   Okay.  You see under the agenda items, item number 3 says:

15             "Defining task in the implementation of the global plan and the

16     following task ..."

17             Do you remember what the global plan was, what that referred to

18     in July 1998?

19        A.   Yesterday at the very outset I said that I did not have my own

20     notes.  They had been destroyed, so I did not have any -- anything to jog

21     my memory as to that meeting were my possible notes that would provide

22     any suggestions.  From what I could read in the minutes, I really can't

23     remember what the meeting was all about.  It says here that chiefs of the

24     SUP provide their briefings and nothing else which doesn't help me to

25     remember what the meeting was all about.  If I saw any of the documents

Page 4164

 1     elaborating on items two or three, maybe that would help.

 2        Q.   Okay.  Let me ask you this:  Did you ever hear the term used in

 3     1998, the term "plan for combatting terrorism in Kosovo" or "plan for

 4     suppressing terrorism or fighting terrorism in Kosovo"?  Did you hear of

 5     that plan?

 6        A.   I heard of particular individual actions.  I really didn't know

 7     that there was a general plan.  I suppose that this is down to my level,

 8     the strength of my forces, all that restricted my access to information,

 9     I would say.  There may have been such a plan, but I wouldn't know, I

10     didn't know of any such plan.  From where I stood, there were concrete

11     plans for concrete tasks and missions, and that's what I knew.

12        Q.   Okay.  And you didn't hear the term -- here it's in capital

13     letters "global plan" discussed either in this meeting or among other MUP

14     colleagues in July 1998?

15        A.   I really can't remember any such thing.

16        Q.   Did you hear any complaints among the senior staff of the MUP

17     about the VJ or General Pavkovic coming up with this overall plan for

18     fighting terrorism that was going to require a lot of extra work by the

19     MUP?

20        A.   At my level I did not hear that.  As for the levels above me, I

21     really don't know.

22        Q.   Let me --

23             MR. HANNIS:  Well, I'd like to tender that if I may,

24     Your Honours.

25             JUDGE PARKER:  It will be received.

Page 4165

 1             THE REGISTRAR:  And that will be assigned P00768, Your Honours.

 2             MR. HANNIS:  Thank you.

 3        Q.   If you could go to the next tab, General, tab 28, this is at 65

 4     ter number 04152.  This is dated the 26th of October, 1998.  Attendees

 5     include commanders of the PJP.  Did you see this document with Mr. Stamp?

 6        A.   Yes, I did.

 7        Q.   Do you recall whether or not you might have attended this

 8     particular meeting?

 9        A.   I remember that I attended this particular meeting.

10        Q.   Okay.  And General Stevanovic is informing the group about the

11     agreement with the OSCE, and could you look at item number 13, that's the

12     last one.  It says:

13             "Reinforce Serb villages with reservists as required ...  "

14             Do you know if that was done at this time?

15        A.   I can't remember.  If it's written in there, then I suppose it's

16     correct; however, I can't give you any more detail because I simply can't

17     remember.

18        Q.   Okay.  Do you remember that part of the agreement, the

19     Milosevic-Holbrooke Agreement in late October 1998 called for a reduction

20     of the number of policemen in Kosovo, I think something on the level of

21     4.000 men or so were supposed to be taken out of Kosovo and returned to

22     Serbia proper.  Were you aware of that?

23        A.   I remember this meeting very well for two reasons, the first one

24     being the fact that we waited several hours for the meeting to begin

25     because General [indiscernible] came directly from Belgrade after the

Page 4166

 1     signing of the agreement.  I can't remember the details, but I believe

 2     that it was about the reduction of the MUP strength, and I also know that

 3     the police was given a task to - if I'm not mistaken - the routes that

 4     had been defined by the agreements, that the police could stay there as

 5     well as in some observation posts.  I believe that the number of the

 6     observation posts was also defined.  It was a long time ago so I can't

 7     remember the details very clearly, but the meeting was important because

 8     it was about the implementation, and that is very clear still in my

 9     memory.

10        Q.   Okay.  You'll see on the first page item number 1 it says that:

11             "A plan needs to be made and the number of engaged units reduced

12     by 4.500 members of the police force."

13             Do you remember that being discussed at the meeting?

14        A.   Yes, that was discussed, but I would not be able to give you any

15     concrete numbers.  I believe that what is written here, I will allow the

16     possibility that that's how it was.

17        Q.   I'm trying to figure out how item 13 about reinforcing the Serb

18     villages with reservists ties in to that reduction of force by 4.5 00.

19     Was that a way to try to make up for the reduction in the regular force,

20     if you know?

21        A.   I said that I didn't know that --

22        Q.   Okay.

23        A.   Within the same number of men, within the same strength, you can

24     move people in order to focus on a certain task, and I'm saying this in

25     more general terms, not in any ...

Page 4167

 1        Q.   Thank you.

 2             MR. HANNIS:  Could we tender that one, please, Your Honour.

 3             JUDGE PARKER:  It will be received.

 4             THE REGISTRAR:

 5             MR. HANNIS:  Thank you.

 6             THE REGISTRAR:  That will be assigned P00769, Your Honours.

 7             MR. HANNIS:

 8        Q.   The next one is tab 29.  This is Exhibit P690 already in

 9     evidence.  This is a meeting on the 3rd of November, 1998 -- well,

10     actually it's conclusions about the meeting.  Did you ever see this

11     document?

12        A.   I'm not sure.

13        Q.   Okay.  It says -- this is conclusions from a meeting on -- that

14     was held on the 2nd of November, 1998, with secretariat chiefs and police

15     detachment commanders.  Do you recall if you attended such a meeting?

16        A.   I wouldn't be able to say with any degree of certainty; however,

17     if you can read it in the document, then, yes, as I did indeed attend

18     most of the meeting.

19        Q.   Okay.  Thank you.  I want to ask you about some of the

20     conclusions from that meeting, see if you recall those events.  Item

21     number 6 -- and this is in connection with the OSCE agreement.

22             "Armoured vehicles and weapons of a calibre larger than

23     7.9 millimetre must not be used, engaged, or moved without agreement and

24     permission from the Staff."

25             Do you recall, was that placed in effect at that time?  Did you

Page 4168

 1     have to get permission to use those larger-calibre weapons?

 2        A.   I wouldn't be able to remember, but if we can read it in the

 3     document, then I believe that that was the case and that it was observed.

 4        Q.   Okay.  Look at item number 8.  I think this relates to the last

 5     one we looked at where it talked about reinforcing the Serb villages with

 6     reserves.  I'll read part of it to you.

 7             "In villages with Serbian inhabitants, take additional protection

 8     measures ..."

 9             And the next sentence goes on to say:

10             "Make sure that Serbs and members of the RPO," which is

11     translated as reserve police squads, "do not misuse weapons, let off guns

12     at weddings," et cetera, "do not carry weapons or show them in public the

13     presence of members of the mission.  When on guard duty, use one weapon

14     and prevent individuals from bringing in the weapon they have been

15     issued.  Tell them not to state the fact that Serbs are armed and to

16     explain this fact, if they must, using the excuse that it is only members

17     of the guard who are armed."

18             First of all, do you remember that being discussed or concluded

19     at this meeting in November 1998?

20        A.   I really don't.

21        Q.   You were aware, though, that the Serbs in Kosovo had been issued

22     weapons?

23        A.   I knew that arms were distributed to the population -- to the

24     population in the villages with mixed populations.  That was to help them

25     protect themselves from terrorists who were numerous at the time, and

Page 4169

 1     that was the main objective of the exercise.

 2        Q.   But wasn't it only that the Serbs who were issued the weapons,

 3     not Albanians, not Kosovo Albanians?

 4        A.   Serbs were issued weapons in the villages with mixed populations

 5     or predominantly inhabited by the Serbs, and I told you what the reason

 6     for that was, in order to help them protect themselves from terrorist

 7     attacks.  At the time there were a lot of terrorists around.  I suppose

 8     that there were no terrorist attacks against Albanians, which makes me

 9     conclude that weapons were not issued to them also.  But as far as I

10     know, some Albanians were also issued weapons if they were under

11     terrorist threats whose houses had come under attack.  And also the Roma

12     population was issued weapons.  So that would be that.

13        Q.   What Albanians do you know of that were issued weapons by the

14     Serb authorities?  Can you tell me a village or any particular

15     individuals in 1998 or 1999 that got issued weapons by the Serb VJ or the

16     MUP?

17        A.   I really wouldn't be able to give you any names, but I know that

18     there were such cases.  This was not my main area of concern, so I

19     wouldn't be able to give you any individual names.  But from experience

20     and from what my colleagues told me and from what I heard on TV, I know

21     there were villages where people of Albanian ethnicity were given weapons

22     for their personal protection.

23        Q.   Okay.  Thank you.  Let's move to item number 10.  It says:

24             "The MUP staff in Pristina will now take on the role of planning,

25     and the Secretariats will have greater independence in carrying out their

Page 4170

 1     regular duties ..."

 2             And then the last sentence says:

 3             "Commanders and deputy-commanders will take command of the

 4     dispatched units - 'A' units of the PJP - and all units come under the

 5     Secretariats."

 6             First of all, can you tell me what's the difference between an A

 7     unit and a B unit of the PJP?

 8        A.   There were the so-called A formation detachments that we have

 9     already mentioned, and there were also the so-called B formation

10     detachments.  I don't know their numerical designations, but I believe

11     that those were the 72nd, 73rd, 85th, 86th, 87th.  If I'm not mistaken,

12     the difference lay in the fact that the A formation detachments were

13     composed of better-trained police members.

14        Q.   I've heard one explanation that the A units were considered the

15     manoeuvre units, the ones who actually went out in the field and did

16     combat; and B units were reserve units who kind of stuck closer to home

17     and did duties like, I don't know, setting a blockade or setting a

18     perimeter, et cetera.  Is that accurate?

19        A.   Well, yes, more or less.

20        Q.   Let me move on, then, to tab 30.  This is 65 ter number 02805,

21     dated the 5th of November, 1998.  A meeting that was attended by

22     President Milutinovic and the Minister of the Interior Stojiljkovic,

23     General Djordjevic, and others, as well as the commanders of the PJP.

24     The meeting was chaired by General Lukic, according to the minutes, which

25     were taken by Desimir Slovic.

Page 4171

 1             Have you seen this document before?

 2        A.   I did see it with Mr. Stamp.

 3        Q.   Okay.  Do you recall being present at this meeting?

 4        A.   Well, I should recall.

 5        Q.   Well, it would be unusual for the president to be there, so it

 6     seems like that would be a meeting you would remember if you were at.  I

 7     see you shaking your head yes, you agree.  You'll have to answer out

 8     loud.

 9        A.   I agree, but when it comes to the meetings in 1998, at that time

10     I had some personal problems.  My mother was seriously and lethally ill,

11     so I had a lot of commitments with this regard.  I was in Pristina.  She

12     was in hospital in Belgrade.  I had to travel a lot for that reason, so

13     that's why I'm saying that there is a possibility that I did not attend

14     some of the meetings which was always justified with the knowledge of my

15     superiors who -- excuse me, that's why I'm saying with a reservation

16     there's no doubt about the fact that I attended a lot of the meetings.  I

17     probably attended this one as well.

18        Q.   You don't have any reason to doubt that this is an accurate or

19     authentic document?

20        A.   Absolutely.

21        Q.   You mean you absolutely don't have a doubt?

22        A.   You're absolutely right.

23        Q.   Okay.  Thank you.  The one thing I had wanted to ask you about

24     was something that President Milutinovic is recorded as having said.

25     You'll see where he's speaking and, I don't know, it's -- I'm not sure

Page 4172

 1     where it is on your page.  I think it may be marked in orange to help

 2     guide you to it.  And he's saying -- he's talking about a meeting that

 3     was held I think just a few days before, on the 29th of October, 1998,

 4     and he says:

 5             "With regard to the Yugoslav army and police everything will stay

 6     the same as it has been up to now, a Joint Command, VJ units will not

 7     withdraw, and police forces have only been reduced by the number that has

 8     already been withdrawn."

 9             Does that refresh your memory about whether or not you may have

10     been at this meeting, because there's a reference to the Joint Command?

11        A.   Based on only that detail, I don't think so, but I know that

12     there was a meeting which was attended by President Milutinovic.

13        Q.   Okay.

14             MR. HANNIS:  Your Honours, I'd like to tender that exhibit at

15     this time.

16             JUDGE PARKER:  It will be received.

17             THE REGISTRAR:  That will be assigned P00770, Your Honours.

18             MR. HANNIS:  Thank you.

19        Q.   General, next I would like to show you tab 31.  This is exhibit

20     in evidence P689, dated 2 December 1998, minutes of a meeting of MUP

21     staff, SUP chiefs, and commanders of PJP units.  Did Mr. Stamp show you

22     this one?

23        A.   I'm not sure, actually.  Maybe yes, but I'm not sure.

24        Q.   Okay.  I know that page 5 in my English and I think on page 5 of

25     your copy, there's a note that the commanders of the detachments did not

Page 4173

 1     speak, so there's no indication that you or any other PJP commander spoke

 2     at the meeting.  But I want to ask you about something on the last page.

 3     Coming up from the bottom you'll see a list of items number 1 through 8,

 4     and above that there are some bullet points.  It's the fifth one up.  It

 5     says:

 6             "Commanders of detachments are members of the collegium of the

 7     chief of the SUP and should be linked up daily with the chief of the SUP

 8     for purposes of work and control."

 9             Do you know, did that happen in your SUP?  Were you linked up

10     daily with the chief of the SUP as a detachment or a brigade commander of

11     the PJP?

12        A.   I was not liaising with the chief of the SUP in that capacity,

13     but in the capacity as the chief of the police.

14        Q.   In your capacity as brigade commander, who would you liaise with

15     if not the chief of the SUP?

16        A.   Well, I said yesterday I think that I was linked up at the time

17     when the brigade would receive specific tasks to carry out some kind of

18     an anti-terrorist action.  Here we're talking about regular duties,

19     regular work, and the brigade was not involved in it in a number that

20     would require my participation.  So I was not part of that communication,

21     but as the chief of the police department, definitely I was, of the OUP.

22        Q.   Okay.  Thank you.  Let's move to the next one, tab 32 in your

23     binder, this is exhibit in evidence P85, 085.  This one, General, is

24     dated the 17th of February, 1999, Pristina MUP staff meeting.  This one

25     was attended by the Minister of the Interior, General Djordjevic,

Page 4174

 1     General Stevanovic, some others.  It says the PJP commanders are present.

 2     Did Mr. Stamp show you this one?

 3        A.   Yes.

 4        Q.   Do you recall whether or not you were present for this meeting?

 5        A.   I think so.

 6        Q.   Okay.  General Lukic is the first speaker, and one of the things

 7     he's talking about is reserve police stations.  At the bottom of your

 8     page 1, two or three lines up from the bottom it says:

 9             "A plan of the RJB, public security department, has been worked

10     out to prevent and thwart the entry of NATO troops into our territory.

11     The staff plans, when it is ordered, to carry out three mopping up

12     operations in the Podujevo, Dragobilje, and Drenica areas and has

13     allotted around 4.000 policemen" some OPG policemen and some reserves.

14             Do you recall that being discussed at the meeting?

15        A.   Well, I can't recall the details of the meeting, but if that's

16     what it says here, there's no reason for me to doubt that this was

17     actually how it happened.

18        Q.   Okay.  And it continues on to the next page, and it says:

19             "On Saturday 20 February 1999 a meeting of the staff will be held

20     with all police unit detachment commanders for further consultations

21     about their engagement."

22             Was that meeting held and did you attend?

23        A.   Well, I couldn't really say with any certainty whether I was

24     present there or not.

25        Q.   Okay.  And again it mentions meetings being held with the reserve

Page 4175

 1     police stations.  Under whose command were the reserve police stations?

 2     Do you know what the structure was there of the hierarchy?

 3        A.   Well, the reserve police sections were set up -- well, we have

 4     already explained that they had their commanders and the commanders were

 5     in contact with one of the commanding officers in the police stations,

 6     informing them about all of the incidents, any changes, and any needs

 7     that arose for any assistance, if there was an attack, things of that

 8     nature.  But the task of those reserve police departments or sections was

 9     exclusively to defend the inhabited area against any kind of defence or

10     any threat, and also to protect some infrastructural facilities,

11     transformer stations, water-supply systems, whatever was key or vital in

12     those places.

13        Q.   And was it a regular policeman or police officer, then, who would

14     be in charge to those reserve police contingents?

15        A.   I don't think so.  I think when you say "regular," the commanders

16     of those reserve police departments, that they were probably reserve

17     police officers from those locations.  And it was their duty to be in

18     touch with some of the commanding officers in the police station that

19     covered that area in order to coordinate all those things that had to be

20     coordinated in order for them to get any assistance when it was needed.

21        Q.   All right.  Thank you.  Well, let me take you to the next one.

22     This is tab 33 in your binder, General, 65 ter number 01996, minutes of a

23     MUP staff meeting on 7 May 1999 in Pristina attended by Deputy Prime

24     Minister Mr. Sainovic, General Obrad Stevanovic, some of the MUP staff,

25     chiefs of SUP.  I can't tell if PJP officers attended or not; they're not

Page 4176

 1     listed.  Did Mr. Stamp show you this document?

 2        A.   Yes.

 3        Q.   Do you recall whether or not you attended such a meeting?

 4        A.   I don't think so.

 5        Q.   Okay.  Let me take you to -- I think it's the next-to-the-last

 6     page, page 9 in the B/C/S or in the Serbian version, it's page 11 in the

 7     English.  You might be able to help us with some of the things that were

 8     mentioned there.  This is General Stevanovic talking, and item number 2

 9     says:  "Anti-terrorist actions ..." do you find that?

10        A.   Yes.

11        Q.   He says:

12             "After the end of some of the larger actions such as

13     Budakovo-Jezerce, each SUP will be expected to work independently on

14     organising anti-terrorist actions in their own areas.  The plan must be

15     approved by the staff and will be carried out together with manoeuvre

16     detachments ..."

17             Do you recall after that big operation in Budakovo-Jezerce, was

18     this done?  Did each SUP make their own plans for anti-terrorist actions

19     in their area or in your area, in Pristina SUP area?

20        A.   As far as I know, no, and I don't think that any independent

21     actions were actually carried out.

22        Q.   Do you know if any were planned but not carried out?

23        A.   Not with me, and I don't think that that was the case in fact.

24        Q.   Okay.  Let me take you to item number 4:

25             "Defence from ground attacks ..."

Page 4177

 1             The second bullet point says:

 2             "It is very likely that, apart from the 124th," here it says,

 3     "Special Police Detachment, our PJP manoeuvre detachments will

 4     participate in the defence against any ground attacks ..."

 5             First of all, it says "OPJP."  Is that special police detachment

 6     like we saw before but it probably should be brigade?  Because I think

 7     you told me there was no 124th PJP Detachment.

 8        A.   Yes, that's how it is.  But what I'm reading here is not clear to

 9     me.  I couldn't really --

10        Q.   I'm sorry to hear that.  I was hoping you could help me because

11     it's not clear to me either.  I'm trying to figure out why would the

12     124th not be involved in participating in the defence against ground

13     attacks?  Was the 124th Brigade being reserved for some other tasks, some

14     more important tasks, some special or different task?  Do you know?

15        A.   Well, this is really the first time that I see it.  Please take

16     my word for it.

17        Q.   Okay.  And after this date of the 7th of May, 1999, was anything

18     different being done with regard to how your intervention brigade was

19     being used?

20        A.   As far as I know, under the same conditions as were valid before.

21        Q.   Okay.  If you will go then farther down two paragraphs, my

22     English says:

23             "In the organisation of work, the Secretariat of the Interior

24     must ensure that in Kosovo and Metohija the organisation is such that all

25     special police detachments are subordinated to the Chief of the

Page 4178

 1     Secretariat ..."

 2             Was that done, to your knowledge?

 3        A.   I don't know.

 4        Q.   And then beyond that one paragraph it says:

 5             "Set up supervisory control with special authorisations within

 6     the 124th ...  so that they can take very specific measures to keep in

 7     check the conduct of the police ..."

 8             What do you know about that?  In some ways that sounds like the

 9     124th is being tasked to be especially in charge in checking on the

10     conduct of all the rest of the police.  Did that happen?  Do you know

11     anything about what that's talking about?

12        A.   Well, really, this is the first that I see or hear of it so I

13     couldn't really tell you what was meant here.

14        Q.   Nobody -- nobody talked to you as brigade commander about doing

15     something like that on or after the 7th of May, 1999?

16        A.   As far as I can recall, well I don't think so.

17        Q.   All right.  If you could go to the very end of the document, I

18     think it's the next-to-the-last bullet point, it talks about members of

19     the reserve police stations.  It says:

20             "They may not wear police uniforms, and this has to be prohibited

21     immediately except when they've been engaged according to the plan ..."

22             Up to this point had there been a problem with reserve police

23     officers wearing military uniforms and basically going around acting like

24     they were regular, full-time police officers?  Do you know why this was

25     brought up at the meeting?

Page 4179

 1        A.   Well, I don't know exactly.  I said that I did not attend the

 2     meeting, and now I don't know how useful an interpretation that I could

 3     give you would be.

 4        Q.   Okay.  Well, I don't think you had to be at the meeting to be

 5     able to help us with this.  Right above that bullet point you see it

 6     says:

 7             "Urgently set up checks of those wearing police uniforms;

 8     uniforms may only be worn by members of the police with a 'P' status and

 9     the reserve police when it's engaged and no one else.  The green uniform

10     may only be worn in anti-terrorist actions ..."

11             So it sounds like before now there's been a problem with people

12     wearing the police uniforms when maybe they weren't supposed to be.  Do

13     you have any knowledge or experience about that happening in Kosovo

14     before May 1999?

15        A.   Well, there is a possibility here that some people were observed

16     wearing a uniform at times when they were not in service -- well, our

17     people down there like uniforms, and then they like wearing uniforms even

18     when they shouldn't be wearing uniforms.  Sometimes it would happen that

19     a man who was not in the service at all would go to a shop and buy a

20     uniform there.  It's not even good that such shops existed.  So I can't

21     really see what else this could be, something along those lines, that

22     there were some individuals who were wearing uniforms when they were not

23     in active service.  They were wearing uniforms in their villages, in

24     cafes, while -- when they were out drinking, and that's not proper

25     conduct.  And this is the only way in which I can actually interpret

Page 4180

 1     this.

 2        Q.   Okay.  And some of those people who liked to do that and were

 3     doing that were also carrying the weapons that had been issued to them;

 4     right?

 5        A.   Well, probably not.

 6        Q.   Oh, come now, really.  The ones who liked to dress up like

 7     policemen or wear their police uniforms when they weren't entitled to

 8     didn't also like to carry the weapons while they were doing it?  Is that

 9     what you're telling me?

10             MR. HANNIS:  I see Mr. Djurdjic on his feet.

11             JUDGE PARKER:  Yes, Mr. Djurdjic, that sounded like

12     cross-examination to me.

13             MR. DJURDJIC: [Interpretation] Well, I don't want to get

14     involved, but I don't really see any mention of weapons in this text.  I

15     see uniforms being mentioned and now my learned friend, Mr. Hannis, has

16     come to weapons.  I may be mistaken -- well, if I am, then please by all

17     means let us continue.

18             JUDGE PARKER:  Mr. Hannis, with good humour we've come to the

19     point of correcting you.

20             MR. HANNIS:  Yes, Your Honour, I appreciate that, and your point

21     is well taken.  I apologise.  I think it's been two years since I've did

22     direct examination.  I've only done cross in the past year or so, so I'm

23     a little rusty.  But I take your point, and I will return to the

24     appropriate form of asking the questions.

25             JUDGE PARKER:  With the rust well rubbed away I hope.

Page 4181

 1             MR. HANNIS:  I hope so, too, Your Honour.

 2        Q.   General, I'll withdraw that question.

 3             Let me take you to the next exhibit which is tab 34 in your

 4     binder, and this is Exhibit P345 in evidence.  This is a meeting of the

 5     MUP staff on the 11th of May, 1999.  I'm sorry --

 6             MR. HANNIS:  Could I tender the last exhibit before I continue to

 7     talk about this one.

 8             JUDGE PARKER:  It will be received.

 9             THE REGISTRAR:  65 ter number 01996 would be assigned P00771,

10     Your Honours.

11             MR. HANNIS:  Thank you.

12        Q.   At this 11 May meeting you're listed specifically by name as

13     having attended.  Did you see this document with Mr. Stamp, and can you

14     tell us if you recall having been present for this meeting?

15        A.   Yes.

16        Q.   Okay.  And I want to ask you in particular about a couple things

17     that you said.  If you could go to item number 7; it's where you're

18     listed as speaking.  It's on page 4 of the English.  I think it's at the

19     bottom of page 3 in yours and the top of page 4.  You mentioned some of

20     the operations that you had been involved in, and then on page 4 you

21     mention that morale is high, although the men have been in the woods in

22     the cold and rain for 13 days continually.  Is that in connection with

23     the Jezerce operation?

24        A.   I think so.

25        Q.   Okay.  I think you told us before that, that was a long and

Page 4182

 1     difficult action.  Do you recall, were there any SAJ units or reserve SAJ

 2     involved in the Jezerce operation?

 3        A.   I think that SAJ took part in the Jezerce operation.  I don't

 4     know what the composition of their unit was because they were not

 5     deployed there with me for me to know that, but I know that SAJ did take

 6     part in it.

 7        Q.   Okay.  You also reported on your relations with the VJ, and you

 8     said they are without problems when we communicate with senior VJ

 9     officers whom we know well, but then you mentioned a problem with a

10     particular colonel, Jovanovic.  Who are the senior VJ officers who you

11     knew well and had good cooperation with from the VJ, if you know?  By

12     name.

13        A.   Well, I don't know if I'll be able to remember all of them.

14     Primarily, there was Colonel Cirkovic.  I mostly took part in those

15     operations with him.  Colonel Jelic, as he was at the time.  I don't know

16     if I also was -- participated with Colonel Zivanovic -- well, that would

17     be more or less it.  So for the most part I took part with

18     Colonel Cirkovic and Colonel Jelic.

19        Q.   Okay.  Do you recall now which brigades or VJ units they were

20     with by number and designator?

21        A.   The 15th Armoured Brigade was the unit that was under the command

22     of Colonel Cirkovic.  He was colonel at the time, and I think that the

23     243rd Motorised or Mechanised Brigade - I'm not sure there - was the unit

24     that was under the command of Colonel Jelic.

25        Q.   I think that's right.  And Zivanovic, was he the 125th?

Page 4183

 1        A.   125th, but I'm not sure whether I took part in any of the actions

 2     with him, but for the other two units I'm absolutely sure.

 3        Q.   Okay.  A few more questions about some of your colleagues'

 4     comments.  Number 8, Colonel Prljevic commented, and the next-to-last

 5     point he mentioned:

 6             "We had to work on some points again with Sigma and Jastreb and

 7     defend positions held by others ..."

 8             Are Sigma and Jastreb some kind of aeroplanes?

 9        A.   No.  These are call-signs for some of the units.

10        Q.   Oh, okay.  And do you know who they referred to or what units

11     they referred to?

12        A.   Well, I assume that the code-names of the units changed with

13     time, but as far as I can recall at this point in time it appears to me

14     that Sigma was the Novi Sad detachment, the 23rd Detachment, and it seems

15     to me, but with this caveat that I'm not really sure, that Jastreb was

16     the 36th Detachment.

17        Q.   Okay.

18        A.   But don't take my word for it because the names changed at some

19     point in time, so it's possible that the same code-name was used for two

20     different units in two different time-periods.

21        Q.   Okay.  Thank you.  If you can look at number 10, the 37th PJP

22     Detachment commander, Colonel Mitrovic.  And it's the -- I think the

23     sixth bullet point under his name.  It's on page 6 of the English.  I'm

24     not sure if it's page 4 or 5 for you.  Do you see that reference?  It

25     says:

Page 4184

 1             "The leadership of legija in the final operations was felt,

 2     particularly when some equipment was used which helped us a lot."

 3             Do you know what "Legija" refers to there?  That's the nickname

 4     of the JSO commander, isn't it?

 5        A.   Well, I couldn't really tell you.  It's logical to assume that

 6     this is the case, but I'm not sure whether it is a reference to that.

 7        Q.   All right.  Numbers 11, 12, and 13 are brigade company

 8     commanders.  Did you know all those commanders?  Were they under you?

 9        A.   Yes, those were the company commanders from Djakovica, Prizren,

10     and Pec.

11        Q.   Okay.  And number 12, Colic is from Djakovica?

12        A.   Yes.

13        Q.   The last bullet point under his name he talks about the people

14     and refugees in town being treated correctly, but says:

15             " ...  however, after all the operations VJ reservists burned

16     houses and went into them; we informed VJ commanders in order to prevent

17     these incidents."

18             Were you aware of that situation in Djakovica before this

19     meeting?

20        A.   No, I wasn't.

21        Q.   Okay.  Upon learning of this information at the meeting, did you

22     have any obligation to report to anybody about it, or was it any

23     obligation for you to do anything?

24        A.   I did not have an obligation to do anything with this regard.

25     There was the chief of the secretariat in Djakovica, and I suppose that

Page 4185

 1     Colic, who was also the chief of the police department, had informed the

 2     chief of the secretariat, and he, in turn, informed the army unit.  The

 3     fact that he was the commander of the company does not mean that he was

 4     subordinated to me but to his superior in the secretariat when it came to

 5     his regular duties.

 6        Q.   Okay.  Let's go to number 13, Krsto Djurcic.  Number 2, the

 7     bullet point number 2 he says:

 8             "We did not have any losses except for Salipur who was killed

 9     while undertaking measures without our approval."

10             Do you know who Salipur was?

11        A.   He was a police officer affiliated with the secretariat in Pec.

12        Q.   Did you know him personally?  Did you ever meet him before he

13     died?

14        A.   The name rings a bell, but I never spoke to him.  I knew him by

15     sight.

16        Q.   Okay.  Can I show you a photograph, then, that is 65 ter number

17     03111.  We'll put it up on the screen.  I don't have it in your binder.

18     Do you have the picture on your monitor now?

19        A.   Yes, I do.

20        Q.   And do you recognise any of the people in that photograph; and if

21     so, can you tell us where they are situated and who they are?

22        A.   On the right-hand side or going from the right-hand side, I

23     believe that I can see the policeman sitting down at the far right.  I

24     believe that his family name is Martinovic.

25        Q.   Okay.

Page 4186

 1        A.   Left to him is Goran Radosavljevic.

 2        Q.   And who was he?

 3        A.   At the time he was the assistant commander of the MUP staff in

 4     Pristina, at the time when he was in Kosmet, I mean.  I don't know the

 5     other two.  The one standing on the left with receding hair is

 6     Mileta Novakovic.  To the right of him, I can't see too well.  It could

 7     be Salipur, but I'm really not sure.  It would have to be blown up a

 8     little.  I didn't know him that well.  It does look like him, though.  I

 9     believe that he was a bit heavier than depicted in this photo, more

10     heavily built.  It looks like him, but I can't be sure.  And the man at

11     the very right of the photo, I don't know him.

12        Q.   Okay.  Do you know what unit these men were associated with in

13     1998 and/or 1999?

14        A.   No, I don't.

15        Q.   Okay.  Were they special -- were they PJP at any time?

16        A.   I think so, but I know that in 1999 he was -- I don't know

17     whether he was before that; it is possible.  I don't know these people.

18     I don't know these members.

19        Q.   But apparently Salipur was a PJP because he's reported on by the

20     company commander as having been killed.

21        A.   Well, it seems to me that he was in 1999.  And in the minutes you

22     can see that this was indeed the case if my interpretation is correct.

23     Whether he was there before that, I don't know.  By the logic of the

24     matter, it would be really unrealistic for me to know everybody.  I knew

25     some officers, some other people that I'd known before, but there were

Page 4187

 1     simply too many people for me to know everybody.  It would be unrealistic

 2     to expect that from me.  I can't tell you exactly who was where and when.

 3     There is a strong possibility that he was there.  I mean, it's obvious

 4     that he was there in 1999.  It's pretty clear.

 5        Q.   Did you ever hear of a group called Munja, a unit called Munja,

 6     in Pec in 1998 or 1999?

 7        A.   Yes, I did.

 8        Q.   What can you tell us about that?  When did you hear about it?

 9     What did you hear about it?

10        A.   I really can't tell you when I heard of them first; however, from

11     what I did hear it was composed of police members, and their task was to

12     carry out some more complex tasks in 1998, if I'm not mistaken, in the

13     very town.  This could have been sometime in mid-1998.

14        Q.   And do you know who created this special unit?

15        A.   No.  I believe that they were composed of police members, or at

16     least that was my impression.  I really can't talk in any more detail

17     because I just have a vague idea.

18        Q.   It -- but it's unusual, isn't it, for a police unit to be called

19     Munja?  Wouldn't it have a designation like a PJP detachment or a police

20     company from Pec SUP?  Am I misunderstanding it?  What kind of unit is

21     this?  Is this an operational sweep group with a nickname?  I don't

22     understand.

23        A.   Well, you know, if somebody wants to call themselves Munja, it's

24     an internal name.  It's not an official name of any unit.  For example,

25     there is a platoon that want to call themselves Dusan [indiscernible].  I

Page 4188

 1     don't know; it's something that doesn't say anything in principle.  That

 2     was not an official name, if you will.

 3        Q.   Okay.  At one of the meetings we talked about earlier, the

 4     17 February 1999 meeting in Exhibit P85, the last -- one of the last

 5     things said by Mr. Stojiljkovic at that meeting, if you could look at

 6     tab 32 for just a second.  On the last page, the second bullet point from

 7     the bottom, the minister says:

 8             "Raise discipline, behaviour, and appearance of policemen to a

 9     high level.  Do away with Rambo-style caps and bandannas ..."

10             Isn't that related to the kinds of problems that are associated

11     with a police group calling itself Munja?  Isn't that the same kind of

12     problem?  Is there a lack of discipline if you start going around and

13     wearing other than official police gear and calling yourselves by special

14     names like "Lightning" or "Munja," wasn't that a problem within the MUP?

15        A.   If there was, it was a marginal problem.  I suppose that there

16     were individuals who decided to wear hats or bandannas, but it was not a

17     widespread phenomenon, and you can see that in what you have just read.

18        Q.   Okay.

19             MR. HANNIS:  Your Honours, I'd like to tender the photograph,

20     3111.

21             JUDGE PARKER:  It will be received.

22             THE REGISTRAR:  And that will be assigned P00772, Your Honours.

23             JUDGE PARKER:  Mr. Djurdjic.

24             MR. DJURDJIC: [Interpretation] Your Honours, maybe somebody knows

25     people in this photo, but I don't know who it is.  The witness did say

Page 4189

 1     whom he recognised, but nobody actually told us who the people are.  I

 2     don't know whether you are aware of somebody having done that.

 3             JUDGE PARKER:  I've heard several names listed from the evidence,

 4     and I believe the witness himself was second from the right in the front,

 5     but that is yet to be confirmed.

 6             MR. HANNIS:  I'll clear that up, Your Honour.

 7        Q.   If we can go back to the photograph, I think, if I read the

 8     transcript right, you told us the person on the front row, second from

 9     the right, was Guri Radosavljevic; is that correct?

10             MR. HANNIS:  I see Mr. Djurdjic on his feet.

11             JUDGE PARKER:  Mr. Djurdjic.

12             MR. DJURDJIC: [Interpretation] It's all good and well -- can we

13     just have the identification of the persons to see who's standing, who is

14     in the photo.  The witness said, I believe that this is so and so, but

15     why can't we see the caption under the photo to see who actually is in

16     the photo?  Does that exist or not?  I don't know whether I'm making

17     myself clear.  The witness described everything.  He says, I think this

18     is so and so, but nobody ever confirmed to us the true names and who

19     these people are.

20             I want to know the origin of the photo, the chain of custody, and

21     how the identity of the persons in the photo was established irrespective

22     of what a witness has to tell us about them.

23             JUDGE PARKER:  Well, I'm sorry, Mr. Djurdjic, we're not going to

24     spend time going into all of that.  The witness identified some of the

25     people in this photograph, and the Prosecution sees the photograph as

Page 4190

 1     relevant to its case, so it will be received.

 2             But you are clearing up the identity of one person, Mr. Hannis.

 3             MR. HANNIS:  Yes, Your Honour.

 4        Q.   I don't know if you answered that.  Can you tell us who the

 5     person is who's second from the right on the front row in the photograph?

 6        A.   Second?

 7        Q.   Second from the right on the front row.

 8        A.   In the middle there are three people there --

 9        Q.   No, in the front row the people kneeling, second from the right.

10        A.   Second from the right looks like Goran Radosavljevic to me.

11        Q.   And you told us he was a deputy on the MUP staff?

12        A.   I believe that he was at the time an assistant to the commander

13     in the MUP staff.

14        Q.   General Sreten Lukic?

15        A.   Yes.

16        Q.   His nickname is Guri; isn't that correct?

17        A.   Yes, that's correct.

18             MR. HANNIS:  And I think the witness did indicate where the other

19     people were in the photograph in terms of their position, so I'm

20     satisfied that we know who's who and where they are to the best of his

21     ability.  With that, Your Honours, I don't have any further questions.

22     Thank you.

23             JUDGE PARKER:  Thank you, Mr. Hannis.

24             Mr. Djurdjic, do you cross-examine?

25             MR. DJURDJIC: [Interpretation] I apologise, Your Honours.  I did

Page 4191

 1     not realise that Mr. Hannis had completed his examination-in-chief.  Yes,

 2     I will cross-examine the witness.

 3                           Cross-examination by Mr. Djurdjic:

 4        Q.   [Interpretation] Good afternoon, Mr. Brakovic.  The Defence team

 5     of the accused, General Djordjevic, consists of Ms. Marie O'Leary, my

 6     legal assistant; and myself, Veljko Djurdjic.

 7        A.   Good afternoon.

 8        Q.   I hope you're in good health and that we can continue, you're

 9     feeling well?

10        A.   Be my guest.

11        Q.   Mr. Brakovic, before I proceed and start putting my questions to

12     you, since we're speaking the same language, in order to facilitate the

13     work of the people who interpret and are in charge of the transcript,

14     please speak slowly and wait for my question to be interpreted before you

15     start providing your answer.  If we proceed in that way, everything will

16     be okay.

17        A.   I'll do my best.

18        Q.   It seems that Mr. Stamp has forgotten to provide Mr. Hannis with

19     the notes -- the proofing notes from your proofing session on the 3rd of

20     May, 2009, with regard to the corrections of the statement that was

21     previously provided by yourself.  In your binder you have your statement.

22     Could you please go to that statement.  That was a statement that you

23     provided in 2004.  And in the notes provided to me by Mr. Stamp, P7P9 [as

24     interpreted] is the statement number.  It says that Mr. Brakovic wanted

25     to clarify paragraph 26.  Could you please look at the paragraph, read it

Page 4192

 1     for yourself, and could you please tell us after that what is it that you

 2     wanted to clarify?

 3        A.   In paragraph 26?

 4        Q.   Yes.

 5        A.   It says that General Vlastimir Djordjevic and Obrad Stevanovic,

 6     assistant minister, during 1999 regularly visited Kosovo.  I don't know

 7     any concrete details with regard to their roles in Kosovo, but I assume

 8     that they were there to check the situation and carry out their regular

 9     duties in keeping with their positions.  I'm not sure whether Dragan Ilic

10     was ever in Kosovo or what his role could be over there.  In a

11     conversation that I had at the request of the Tribunal in Pristina -- or

12     rather, I apologise, in Belgrade in the special prosecutor's office,

13     there was a lot of insistence on this paragraph.  They asked me to

14     explain who was in Kosovo and when.  I suggested that Mr. Stamp and I

15     look at it and he did not object to that, but I believe that this would

16     be a topic of my examination yesterday and here today and that there will

17     be plenty of opportunities to provide further explanations, and that's

18     what my request was about.  Would you like me to go over that paragraph

19     again and tell you what I actually meant?

20             The fact is that Generals Vlastimir Djordjevic and

21     Obrad Stevanovic did frequently visit Kosovo.  My position at the

22     time - and you could draw your conclusion as to what it was, I was the

23     chief of the department of the police and the commander of the

24     124th Intervention Brigade - I could see the generals either in the field

25     or at various meetings.  And in that sense I said that I saw them very

Page 4193

 1     frequently because at every meeting I attended was attended by one of

 2     them.  As we went through all the meetings just a little while ago, we

 3     saw who was there and at what time.  So you can actually draw your own

 4     conclusions as to who was in Kosovo and when.

 5             As for my seeing them in the field, I have to say that I saw

 6     General Obrad Stevanovic several times.  Sometime at the beginning of the

 7     war when the post office in Pristina was bombarded, he was present there,

 8     I was present there, we were trying to save some civilians who were

 9     stranded in their homes.  And during the anti-terrorist operations,

10     during the period after that, I didn't see either General Djordjevic or

11     General Obrad Stevanovic, which means that in that sense I said what I

12     did upon the insistence during the interview in Belgrade.  And in that

13     sense, I, bearing in mind that there was a lot of insistence upon that, I

14     thought that I was speaking in general terms, and I wanted to clarify

15     what I said.

16        Q.   Thank you, Mr. Brakovic.  Is it true what I'm reading now under

17     item 10?  You said that you saw General Vlastimir Djordjevic on the 10th

18     of June in Pristina after the signing of the Kumanovo Agreement at the

19     ministerial meeting there?

20        A.   Yes, I believe that General Djordjevic was at the meeting in

21     Pristina upon the signing of the Kumanovo Agreement, and the meeting was

22     about the implementation of the agreement in the upcoming period, and for

23     that reason I believe that he was present, if I'm not mistaken, if my

24     memory serves me right.

25        Q.   Thank you very much.

Page 4194

 1             MR. DJURDJIC: [Interpretation] Your Honours, may I have a

 2     request.  I don't know whether this would be a good time for a technical

 3     break, or maybe you would like to use the five remaining minutes and then

 4     make a break.  It would suit me to have a break now in order to continue

 5     my cross-examination after the break.

 6                           [Trial Chamber confers]

 7             JUDGE PARKER:  We will take the second break now, Mr. Djurdjic,

 8     to assist you, and we will resume at five minutes to 1.00.

 9                           --- Recess taken at 12.25 p.m.

10                           --- On resuming at 12.58 p.m.

11             JUDGE PARKER:  Yes, Mr. Djurdjic.

12             MR. DJURDJIC: [Interpretation] Thank you, Your Honour.  I would

13     like the Court Deputy to put on our screens P57.

14        Q.   Mr. Brakovic, I would like to ask you if you find that easier to

15     look at the decision establishing the ministry staff of the 16th of June,

16     1996 -- 1998?

17        A.   Well, if somebody could tell me which document that is.

18        Q.   Yes, I can see it now -- can you see it now on your screen?

19        A.   Yes, I can see it.

20        Q.   Yeah, I immediately started making mistakes.  I will try and make

21     pauses as much as I can.

22             Mr. Hannis showed you this decision of the 16th of June, 1998.

23     It was issued by the Minister of the Interior, Mr. Stojiljkovic, and you

24     told us that you knew David Gajic.  Could you please tell me where did

25     Mr. Gajic work, in what department of the MUP?

Page 4195

 1        A.   Mr. David Gajic, the late Mr. David Gajic, worked in the state

 2     security department as far as I know.

 3        Q.   Thank you.  And am I right that Mr. David Gajic was appointed the

 4     deputy head of the staff, the head being General Sreten Lukic?

 5        A.   Yes, that's what it says here in this decision.

 6        Q.   Thank you.  Now I would like us to look at the other assistant

 7     for special operations, is this Milorad Lukovic?

 8        A.   Yes, that's what it says in the decision.

 9        Q.   Do you know what was Mr. Milorad Lukovic's function and what part

10     of the MUP did he work at that time?

11        A.   As far as I know, he worked in the state security department, I

12     think, as a commander of the unit for special operations, JSO.

13        Q.   Thank you, Mr. Brakovic.

14             As for Mr. Zivko Trajkovic, we've already noted that he was the

15     assistant for special anti-terrorist units, SAJs, and can you tell us

16     what function he had in addition to his function in the SAJ?

17        A.   As far as I know he was the commander of the special

18     anti-terrorist unit, the SAJ.

19        Q.   Thank you.

20             MR. DJURDJIC: [Interpretation] And could we now move to page 2 --

21     or just in the Serbian version.  You can leave the English version where

22     it is.

23        Q.   Mr. Brakovic, am I right if I say that after the personnel

24     decisions, the appointments as outlined here in this decision, the

25     members of the staff in its extended compositions include also the chiefs

Page 4196

 1     of the secretariats of the interior, the RDB departments in the AP Kosovo

 2     and Metohija, the autonomous province?

 3        A.   Yes, absolutely, that's what it says here in this decision.

 4        Q.   Thank you.  Mr. Brakovic, as a long-time employee in the MUP, is

 5     it true that members of one department cannot issue tasks to personnel in

 6     the other department within the Ministry of the Interior?

 7        A.   Could you please repeat your question.

 8        Q.   Am I right that the personnel - let me give you an example - in

 9     the public security department cannot assign tasks to the personnel in

10     the state security department and vice versa in regular work?

11        A.   Yes, you are right, it is not possible.

12        Q.   Thank you.  And am I right that the minister of the interior does

13     have the right in light of the fact that he is in charge of both the

14     public and state security departments to set up some bodies that would

15     involve personnel from both departments?

16        A.   Yes, he does have this discretionary power.

17        Q.   In the decision that we are looking at now, does it cover both

18     personnel of the state security department and of the public security

19     department?

20        A.   Yes, on the basis of what we've seen, that would be the case.

21        Q.   Pursuant to this decision, is General Sreten Lukic appointed the

22     head of the staff and he was in the public security department?

23        A.   Yes.

24        Q.   And his deputy is a man who belonged to the state security

25     department, Mr. Gajic?

Page 4197

 1        A.   Yes.

 2        Q.   Thank you.  Now, Mr. Brakovic, I would like us to look at Roman

 3     numeral II in this decision, it's on the same page in the Serbian

 4     version, and in the English version we remain on the same page too.  Am I

 5     right, Mr. Brakovic, that this decision of the minister tasks the staff

 6     with planning, organising, and leading the work of the organisational

 7     units of the ministry and any units seconded or attached to it in

 8     suppressing terrorism in the territory of the autonomous province of

 9     Kosovo and Metohija?

10        A.   Yes, that's what it says in the decision.

11        Q.   In paragraph 2 of this item, the staff is also authorised to

12     carry out more complex special security tasks?

13        A.   Yes.

14        Q.   Am I right when I say --

15             MR. DJURDJIC: [Interpretation] Now we move on to page 3.  Could

16     we please have --

17             THE INTERPRETER:  Interpreter's correction:  Paragraph 3.

18             MR. DJURDJIC: [Interpretation] Could we please have page 2 of the

19     English version.  You can keep the B/C/S version on the same page.

20        Q.   Mr. Brakovic, in this decision the minister decided, did he not,

21     that for his work, the work of the staff, and the security situation

22     within the framework of the work of the staff the head of the staff shall

23     be responsible only to him, to the minister?

24        A.   Yes.

25        Q.   Am I right that the minister ordered that the head of the staff

Page 4198

 1     should inform him about any security incidents, any measures taken, and

 2     the results of those measures?

 3        A.   Yes.

 4        Q.   Thank you.

 5             MR. DJURDJIC: [Interpretation] Now I would like us to move to the

 6     last page of this decision in B/C/S.

 7        Q.   Mr. Brakovic, could you please look at paragraph 6.  Mr. Hannis

 8     discussed it at length with you yesterday.  And could you please look at

 9     the decisions 1206/98 of the 15th of May, 1998, and this decision of 1206

10     of the 12th of June, 1998.  Now I want to ask you whether I'm correct

11     that all those decisions that are listed here in paragraph 6 are no

12     longer valid as of the entry into force of this decision?

13        A.   Yes, this is what it says here, with the coming into force of

14     this decision the following shall cease to be valid and that includes the

15     documents that you listed.

16             MR. DJURDJIC: [Interpretation] Could we please look at page 1 of

17     both of these documents.

18        Q.   Mr. Brakovic, am I right that the minister by this decision

19     establishes a staff for the Ministry of the Interior of the Republic of

20     Serbia to suppress terrorism in the territory of the AP of Kosovo and

21     Metohija, that this was the name of the staff as it is indicated at

22     paragraph 1 of this decision?

23        A.   Yes.

24        Q.   Thank you.

25             MR. DJURDJIC: [Interpretation] I would now like to ask -- I would

Page 4199

 1     like to ask the Court Deputy to put on our screens Exhibit D001-6229.

 2        Q.   While we're waiting for this document to come up on our screens,

 3     Mr. Brakovic, do you know Major-General Momcilo Stojanovic?

 4        A.   Yes, I do.

 5        Q.   Do you know that he was appointed a member of the staff of the

 6     MUP in Pristina in 1998?

 7        A.   He was a member of the staff, but I don't know -- well, he's not

 8     listed here in the decision, but he was on the staff.  He did take care

 9     of some tasks.

10        Q.   Mr. Brakovic, do you see this decision, the one that you can see

11     here in Serbo-Croatian, it's dated the 2nd of October, 1998?

12        A.   Yes, I can see it.

13        Q.   Am I right that this is a decision to appoint a member of the

14     ministry staff for the suppression of terrorism, Mr. -- that's

15     Major-General Momcilo Stojanovic?

16        A.   Just a moment.  Yes, with the tasks that I don't want to go into

17     now.

18             MR. DJURDJIC: [Interpretation] Could we please have page 2 of

19     this decision in both versions.

20        Q.   Mr. Brakovic, in paragraph marked with the Roman numeral III, am

21     I correct if I say that the minister decided that General Stojanovic

22     should be responsible for his work to the head of the staff and the

23     minister?

24        A.   Yes, that's what it says here.

25        Q.   Thank you.

Page 4200

 1             MR. DJURDJIC: [Interpretation] Now I would like tender this

 2     document into evidence.

 3             JUDGE PARKER:  It will be received.

 4             THE REGISTRAR:  That will be assigned D00099, Your Honours.

 5             MR. DJURDJIC: [Interpretation] Thank you.

 6             Now I would like to ask the Court Deputy if we could have on our

 7     screens document -- it's a 65 ter 0448.  I apologise, I may have

 8     misspoken, 65 ter 4478.

 9        Q.   Mr. Brakovic, did you know Mr. Dragan Bozovic?

10        A.   Yes, I did.

11        Q.   Am I right if I say that he was also, or rather, did you know

12     that he was also a member of the MUP staff for the suppression of

13     terrorism in Kosovo and Metohija for a while?

14        A.   Yes, I do know that.

15        Q.   Thank you.  This decision of the 21st of May, 1999, is this a

16     decision to appoint deputy head of the ministry staff for the suppression

17     of terrorism in Kosovo and Metohija and the person appointed here is

18     Mr. Dragan Bozovic?

19        A.   Yes.

20        Q.   Thank you.

21             MR. DJURDJIC: [Interpretation] Could we please look at page 2 of

22     this document, or rather -- yes, that is the page.

23        Q.   Mr. Brakovic, who issued this decision?

24        A.   The minister, Vlajko Stojiljkovic.

25        Q.   Vlajko Stojiljkovic.  Thank you, Mr. Brakovic.

Page 4201

 1             MR. DJURDJIC: [Interpretation] Your Honours, this decision that

 2     we're looking at now was issued -- is this -- I'm sorry, is this P259 --

 3     yes, I do apologise, it's already admitted into evidence.  It's an

 4     exhibit and the number is P259 so I don't have to tender it, and I

 5     apologise.

 6             Could we please have document, it's a 65 ter document, 01251.

 7        Q.   Mr. Brakovic, I'm right if I say that you're not familiar with

 8     this decision?

 9        A.   Is this the decision that we looked at yesterday?

10        Q.   No.  The decision that we looked at yesterday follows after this,

11     but this decision was not shown to you yesterday.  Mr. Brakovic, that's

12     why I told you to look in particular at the end of the 16th of June

13     decision.  This is the decision number 1206/98 which was invalidated by

14     the decision.  And am I right if I say that this is the decision on the

15     formation of the staff of the ministry in Pristina?

16        A.   Yes.

17        Q.   Okay, let's take it one thing at a time.

18             THE INTERPRETER:  Interpreter's note:  The counsel and witness

19     are kindly asked to make pauses between questions and answers.

20             JUDGE PARKER:  You heard that request, Mr. Djurdjic?  Thank you.

21             MR. DJURDJIC: [Interpretation] I'm doing my best, but it seems

22     that it's not good enough.

23        Q.   Mr. Brakovic, am I right when I say that paragraph 2 of this

24     decision establishing the staff of the ministry in Pristina stipulates

25     that it should plan, organise, and direct the work of the Secretariats of

Page 4202

 1     the Interior and the border police stations in the territory of Kosovo

 2     and Metohija in the execution of more complex and major tasks; is that

 3     correct?

 4        A.   Yes, that's what it says here.

 5        Q.   Okay.  Now we have A, B, V -- A, B, C, D.  Now it says

 6     suppression of civil unrest, terrorism, and armed insurgency.  Am I right

 7     that this element that is listed under A is the reason why the PJP units

 8     could be engaged in accordance with the decision that we saw yesterday

 9     that Mr. Hannis showed you about 124th Intervention Brigade, that this

10     was the legal basis?

11        A.   Could you please repeat your question.

12        Q.   The wording in subparagraph A, so major and more complex tasks

13     that are listed here under A, B, C, and so on, under A we have

14     suppression of civil unrest, terrorism, and armed rebellion.  Now I'm

15     asking you is this, what we see here under A, the basis for the

16     establishment of the 124th Brigade stemming from the decision to

17     establish PJPs for the engagement of the PJPs on specific tasks?  This is

18     the decision that we saw yesterday?

19        A.   Yes, I think so.

20        Q.   Thank you.  Before we move on, and I wouldn't go quoting

21     everything from this decision, and we see here under 4, am I right, that

22     the composition of the staff, the head of the staff and its members shall

23     be decided by a special decision?  And I'm now interested in item 5.  Am

24     I right, that for their work, the work of the staff and situation of

25     security within the purview of the staff in the territory of Kosovo and

Page 4203

 1     Metohija, the head of the staff shall be responsible to the chief of the

 2     sector for security?

 3        A.   I can't see it.

 4        Q.   I apologise.

 5             MR. DJURDJIC: [Interpretation] Let's move on to the following

 6     page.  And in the English version as well, can I ask for the following

 7     page to be put on the screen.

 8             THE WITNESS:  Could you now repeat, please.

 9             MR.  DJURDJIC: [Interpretation]

10        Q.   Mr. Brakovic, item number 5.

11        A.   I've read it.

12        Q.   The staff leader is responsible to the chief of the public

13     security department for his own work, the work of the staff, and the

14     state of public security.  Is that true?

15        A.   Yes, that's what is written here.

16        Q.   And under 6 the staff leader informs the chief of the public

17     security.

18        A.   Yes.

19        Q.   Am I right that this decision was issued on the 15th of May,

20     1998, and that it was signed by Colonel-General Vlastimir Djordjevic, the

21     assistant minister?

22        A.   Yes.

23        Q.   At that time he was also the chief of the public security

24     department; am I right?

25        A.   Yes.

Page 4204

 1        Q.   Thank you.

 2             MR. DJURDJIC: [Interpretation] Can this document please be

 3     admitted into evidence, Your Honours.

 4             JUDGE PARKER:  Yes, it will be received.

 5             THE REGISTRAR:  And what would be assigned D00100, Your Honours.

 6             MR. DJURDJIC: [Interpretation]

 7        Q.   And now I would like to go back to Exhibit P -- P760 or P6760 [as

 8     interpreted].

 9             THE INTERPRETER:  Could the counsel please repeat the number.

10             MR. DJURDJIC: [Interpretation] We admitted the document

11     yesterday.  It is the decision that we talked about where the date, the

12     12th of June, was not clear.

13        Q.   Mr. Brakovic, Mr. Hannis showed you this decision, did he not?

14        A.   Yes, he did.

15        Q.   And could you please look at the personnel composition in this

16     decision who were the members of the staff, General Lukic, wasn't he, as

17     the head?

18        A.   Yes.

19        Q.   Then there's Mr. Djinovic as a deputy?

20        A.   Yes.

21        Q.   Goran Radosavljevic follows?

22        A.   Yes.

23        Q.   And then you, yourself, Mr. Vukovic, and so on and so forth until

24     the very end.  And now I would kindly ask you to look at the following

25     page of this decision.

Page 4205

 1             Mr. Brakovic, please look at the decision and tell me if I'm

 2     right in thinking that all the appointed persons who are members of the

 3     department of public security.

 4        A.   Yes.

 5        Q.   There's no single person from the state security department?

 6        A.   You're correct.

 7        Q.   Thank you, Mr. Brakovic.  And now could you please look at the

 8     Roman II.  Does this paragraph -- appoints the chiefs of the secretariats

 9     of the interior in the territory of the AP Kosovo and Metohija as members

10     of the expanded staff?

11        A.   Yes.

12        Q.   And do you agree with me that the minister annulled the decision

13     that was passed on the 16th of June and another decision passed by the

14     chief of the [indiscernible], both the one passed in May and June?

15        A.   Yes, that's true; that's what's written here.

16        Q.   And do you agree with me, or let's affirm that the decision that

17     was issued by the minister, he encompassed members of both departments or

18     the SUP chiefs in Kosovo and Metohija and chiefs of the centres and

19     departments of the state security?

20        A.   Yes.

21        Q.   Thank you very much, Mr. Brakovic.

22             MR. DJURDJIC: [Interpretation] And now I would kindly ask the

23     court to produce 01507, this is a 65 ter document.  We already have a

24     number, it's P58, which means that it has been admitted.

25        Q.   Mr. Brakovic, am I right in thinking that this is a decision on

Page 4206

 1     the establishment of special police units?

 2        A.   You are right.

 3        Q.   Could you now please tell me under item 2 of this decision what

 4     are the tasks and duties of the special police units?

 5        A.   I can read that from the decision.

 6        Q.   Go on then.

 7        A.   "The tasks and duties of the PJM are to perform as necessary

 8     certain duties falling within the responsibility of the Ministry of the

 9     Interior ... relating to the protection of the security of the republic

10     and its citizens."

11        Q.   Thank you very much, Mr. Brakovic.  I want to ask you this:  The

12     origins of the special units of the police, did they exist already after

13     the insurgence of Ustasha terrorists on Mount Radusa in 1972 the PJMs

14     were not established after the events on Kosovo and Metohija?

15        A.   As far as I know, from various books that I have perused, that

16     statement of yours would be correct.  After Radusa there were efforts in

17     that sense.

18        Q.   Thank you.  And we're also going to see later on when this

19     decision was issued.  Am I right in saying, Mr. Brakovic, that under

20     paragraph 2 of item 2, it is prescribed that bringing into readiness,

21     mobilising, and engaging the PJM on performing tasks defined in

22     paragraph 1 of this item shall be done on orders from the minister ..."

23        A.   Yes, I can read that.

24        Q.   And when approved by the minister, Mr. Brakovic, this can also be

25     done by the chief of the public security department; is that correct?

Page 4207

 1        A.   Yes, I can read it.

 2        Q.   Mr. Brakovic, am I right in saying that the chief of department

 3     is not authorised to independently issue a decision on bringing into

 4     readiness, mobilising, and engaging the PJMs?

 5        A.   I'm not a lawyer by profession, but as I'm interpreting this item

 6     I believe that you're right.

 7        Q.   Thank you very much, Mr. Brakovic.  Mr. Brakovic am I right in

 8     saying the following, members of the PJMs will remain deployed and will

 9     perform tasks during the time when they're not engaged as members of the

10     PJM, and they are entitled to the rights stemming from their employment

11     in keeping with the decision on their deployment?

12        A.   Yes.

13        Q.   Am I right in saying that the PJPs were established as the MUP

14     forces to carry out special security tasks which are relative to the

15     protection of the security of the republic and its citizens?

16        A.   I believe that we have already established that just a minute

17     ago.

18        Q.   Am I right in saying that - and I'm drawing conclusions - that

19     the maintenance of public order and security relates to public

20     gatherings?

21        A.   Yes.

22        Q.   Establishing public law and order when this has been impaired to

23     a large extent?

24        A.   Yes.

25        Q.   Deprivation of freedom of hardened criminals?

Page 4208

 1        A.   Yes.

 2        Q.   Detection, capturing, and destruction of insurgents and insurgent

 3     groups and others, sabotage and terrorist groups and individuals?

 4        A.   Yes.

 5        Q.   And whenever the interests of public law and order of the

 6     republic and its citizens so demand, including combat tasks?

 7        A.   I believe so.

 8        Q.   Thank you.  I'm interested in one thing, and I would move to the

 9     topic of the operational sweep groups.  What is the official title

10     operational sweep group or operational pursuit group?

11        A.   The way I understand this term is the operational sweep group.

12        Q.   Sweep group.  Okay.  Am I right in saying that within the

13     framework of every company of a PJP, one unit was established of the

14     members who were the fittest and the most capable, and they represented

15     that operational sweep group?

16        A.   You mean from all the detachments?

17        Q.   Yes.

18        A.   Yes.

19        Q.   And then they underwent special training in order to attain the

20     necessary level of capabilities?

21        A.   Yes.

22        Q.   Let me just go back to one thing.  Am I right in saying that the

23     tasks of the PJP applied to the entire territory of the Republic of

24     Serbia?

25        A.   Yes, that's what I'm reading in the decision.

Page 4209

 1        Q.   Thank you.  Am I right in saying that when in the same area or on

 2     the same task there are several units intervening and belonging to a PJP,

 3     the unification of the function of command, control, and coordination is

 4     regulated by a special order?

 5        A.   I don't know what situation are you referring to.  Are you

 6     talking in general terms, or are you talking about the territory of

 7     Kosovo and Metohija?

 8        Q.   Not in the territory of Kosovo and Metohija.  I'm going to give

 9     you an example.  We're talking about demonstrations in 1996 and 1997 in

10     Belgrade, for example.

11        A.   Yes.

12        Q.   Units were sent there to intervene during the demonstrations in

13     Belgrade?

14        A.   Yes.  And what's your question?

15        Q.   Am I right in saying that an order as to be issued in order to

16     establish - since the men come from different units - who would be in

17     command of all those units?

18        A.   I suppose that that would be the case, but as I've already said,

19     this went beyond my level.

20        Q.   Have you ever been to Belgrade?

21        A.   Yes.

22        Q.   Am I right in saying that those units were commanded by the chief

23     of the SUP of the city of Belgrade to whom the units were addressed?

24        A.   Yes, absolutely you're right.

25        Q.   Thank you.  Am I right in saying - and now we're talking about

Page 4210

 1     the years 1998 and 1999 - that the MUP staff in order to suppress

 2     terrorism in Kosovo and Metohija commanded all the units addressed and

 3     subordinated to them pursuant to the decision of the minister dated

 4     16 June 1998?

 5        A.   Yes, that's the -- arises from the decision.

 6        Q.   Am I right in saying that the planning of anti-terrorist actions

 7     on -- came in 1998 and 1999 was done by the Army of Yugoslavia?

 8        A.   I suppose so, yes.

 9        Q.   Thank you.  Am I right in saying that the plans in question which

10     were drafted by the army you received via the MUP staff for the

11     suppression of terrorism on Kosovo and Metohija?

12        A.   In one of the answers I already said that partly yes and partly

13     those plans went directly, so I suppose that everything went through the

14     staff at the end of the day.  There were periods when we received those

15     through the secretariat, but I believe that that also went through the

16     staff.

17        Q.   Am I right in saying that the administrative and logistics tasks

18     with regard to the training, equipping, and sending of the PJP units was

19     carried out by the administration of the ministry police?

20        A.   Yes.

21        Q.   Am I right that in the course of 1998 and 1999 via the MUP staff

22     in Pristina there were efforts to supply, equip, and everything else that

23     was necessary for the work of the PJP units in Kosovo with regard to the

24     police administration in the ministry?

25        A.   Could you please repeat your question.  It was not clear.

Page 4211

 1        Q.   The MUP staff in Pristina in 1998 and 1999, did they submit to

 2     the police administration their request for the supply of equipment and

 3     all the other necessary means for all units that were deployed on Kosovo

 4     and Metohija?

 5        A.   I suppose that you are right, but I was not in a position to know

 6     that.  I never dealt with that, but I suppose that was the case because

 7     it could only be logical question.

 8        Q.   Thank you very much.  Mr. Brakovic, when you look at the decision

 9     that we have in front of us on the establishment of the PJPs of the

10     police --

11             MR. DJURDJIC: [Interpretation] Can we now look at Exhibit P257.

12        Q.   In essence the contents of this decision establishing the 124th

13     Intervention Brigade in addition to it being mentioned in here, in all

14     other aspects is it identical with the decision to establish the special

15     units of the milicija that we've seen just a little while ago?

16        A.   Yes, I think that I answered this question yesterday.

17        Q.   And that all the accompanying documents are the ones that are

18     envisaged in the decision establishing the PJMs of the milicija?

19        A.   Yes.

20        Q.   Thank you.  And this is something that we said yesterday, that

21     the decision to establish the 124th Brigade was issued by minister of the

22     interior.  Do you agree that the dispatch sent by the chief of the

23     department with this decision establishing the PJP in its attachment was

24     instructive in its character?  It was just by way of information,

25     notification?

Page 4212

 1        A.   Yes, you could say that.  So please find attached a decision and

 2     it is specified that there are some obligations pertaining to

 3     record-keeping.  I don't think -- well, it's not up on the screen.  I

 4     can't really remember all of that.

 5        Q.   Thank you.  Lets clear one thing up.  I think that it has to be

 6     cleared up.  When you were appointed the commander of the

 7     124th Intervention Brigade, or rather, when you were doing that job, you

 8     were not doing the job of the chief of the department of the interior in

 9     the Secretariat of the Interior in Pristina?

10        A.   Yes, that's right.  It was my deputy who did that job.

11        Q.   And when you were doing your job as commander of the 124th

12     Brigade, the chief of the SUP was not our superior?

13        A.   Yes.

14        Q.   Thank you.  And while you did the job of the commander you did

15     not submit reports to the SUP chief?

16        A.   I did not.

17        Q.   Except, unfortunately, if there are any injuries or casualties of

18     any sort, then you have to inform the secretariat, the original

19     secretariat, from which the casualty -- where the casualty worked?

20        A.   Yes, we called that informing or notification, not reporting.

21        Q.   Notification and not reporting.  Thank you.  Am I right, or

22     rather, I am right because I already asked this question.  We can go on.

23             MR. DJURDJIC: [Interpretation] Could we please look at P537 --

24     P357.  Just a moment.  Let me check.  No, I do apologise, my error.  It's

25     P75.

Page 4213

 1        Q.   Mr. Brakovic, this is a decision appointing Mr. Bosko Petric as

 2     the chief of the SUP in Pristina; am I right?

 3        A.   Yes, that's what it looks like.

 4        Q.   And we can see the date is the 4th of June, 1997.

 5             MR. DJURDJIC: [Interpretation] If we could scroll up a little

 6     bit -- scroll down, please, so that we can see the signature.

 7        Q.   Am I right that the decision was issued by minister

 8     Vlajko Stojiljkovic?

 9        A.   As far as I can see, yes, although the Serbian version is a

10     little bit dark.

11        Q.   Well, you can look at the English version, it's much clearer

12     there.

13        A.   Yes, that's what it says there.

14        Q.   So let's clear this up.  We can see that -- well, there was an

15     exhibit that pertained to telephones where Mr. Djoka [as interpreted]

16     Keric was mentioned.  So this was before Mr. Petric came to be the chief,

17     and we can see that it was in 1997.  So it predates that period; is that

18     correct, Mr. Brakovic?

19        A.   Yes, I think that when the Prosecutor asked me that, that's what

20     I responded.

21        Q.   Yes, but now we know for sure.  Thank you.

22             MR. DJURDJIC: [Interpretation] Your Honours, I'm about to embark

23     on a new topic, and our time is running out.  I think it would be

24     appropriate for me to end now for today.

25             JUDGE PARKER:  Very well, Mr. Djurdjic.  We will adjourn now, and

Page 4214

 1     we resume on Monday -- I believe it will be in the morning of Monday at

 2     9.00.

 3             I'm afraid, Mr. Brakovic, we must ask you to return again on

 4     Monday.  As you can readily see, your evidence is not concluded.  The

 5     court officer will make arrangements with you for your continued stay,

 6     and we continue your evidence on Monday.

 7             We now adjourn.

 8                           --- Whereupon the hearing adjourned at 1.46 p.m.,

 9                           to be reconvened on Monday, the 11th day of

10                           May, 2009, at 9.00 a.m.