1 Friday, 1 June 2007

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.01 a.m.

6 JUDGE ROBINSON: Mr. Tapuskovic, you're to continue.

7 WITNESS: MILORAD KATIC [Resumed]

8 [Witness answered through interpreter]

9 MR. TAPUSKOVIC: [Interpretation] Thank you. Thank you, Your

10 Honours.

11 Examination by Mr. Tapuskovic: [Continued]

12 Q. [Interpretation], Mr. Katic, yesterday we started your

13 examination.

14 At the moment, when we finished yesterday, you were talking about

15 the position of Grbavica. However, tell me one more thing: You mentioned

16 high-rise buildings. These high-rise buildings, if you compare them,

17 which ones were dominant there in that area. I don't want to lead you in

18 any way.

19 A. The high-rises on the other side of the Miljacka river, in

20 relation to the high-rise buildings on Grbavica, they're higher,

21 especially the high-rise building in the street of Bratstvo-Jedinstvo.

22 That's what it was called then, on the other side of the Miljacka river.

23 Q. Did any of these high-rise buildings have their own names,

24 something like that?

25 A. Well, they did. How should I put this? There were the Unis

1 buildings, Unis sky-scrapers at Marindvor. They are much higher. Then

2 there was the Assembly building, which is also taller than the buildings

3 on the Miljacka. And now I cannot remember exactly. Now, what do we call

4 this? This building with a lot of balconies by the Bridge of Brotherhood

5 and Unity, "Bratstvo I Jedinstvo." I cannot remember exactly now. I

6 cannot remember its exact name.

7 Q. Thank you. Could we deal with another problem now. Grbavica is

8 where it is, as you explained. What is referred to is the existence of a

9 blockade of Sarajevo. Can you say something about that? As far as your

10 very own feeling there, you were there, at Grbavica?

11 A. I cannot understand at all, or rather, I cannot say that we had

12 blockaded Sarajevo, or rather, this feeling of a blockade. As I look at

13 Grbavica itself, I think that at Grbavica, I was in a three quarters

14 blockade, if I can put it that way. Blocked from three sides practically.

15 There were these geographic positions, as I already said: On one

16 side Debelo Brdo; on the other side, Mojmilo; and on the third side,

17 high-rise buildings and also the hill of Zuc behind Pofalici. Also, when

18 I look at the municipality of Novo Sarajevo and from Grbavica, the other

19 part of Novo Sarajevo municipality, you could only go along one street,

20 Zagrebacka Street, which went from Grbavica to Vraca to Bijelo Poljska

21 street then to Lukavica.

22 And Lukavica was exposed to fire, infantry fire, from the Mojmilo

23 hill and also parts of Dobrinja, 1 and 4, or rather, that part of the

24 neighbourhood of Dobrinja where the separation line was; although,

25 geographically speaking, this did not belong to the municipality of Novo

1 Sarajevo then.

2 Q. Thank you. Now I would like to show you a document, which I got

3 from the Prosecution, and that the Prosecution will use --

4 JUDGE ROBINSON: Just a minute.

5 MR. TAPUSKOVIC: [Interpretation] I beg your pardon.

6 JUDGE ROBINSON: I'm trying to understand the witness's evidence.

7 Your evidence, then, is that it is not only the Muslims, the ABiH,

8 who were blocked in, that the Serbs were also blocked in, at least in some

9 areas?

10 THE WITNESS: [Interpretation] Exactly, Your Honour. I am just

11 talking about parts of the municipality of Serb New Sarajevo, and that is

12 Grbavica, as I said yesterday. As for the rest of the city of Sarajevo,

13 geographically speaking, it was in it like a kidney in a body. And from

14 the point of view of the altitude involved, the population was exposed to

15 attacks. And if I can put it this way, we just had this narrow

16 passageway, down Zagrebacka Street, from Grbavica via Vraca to Lukavica,

17 and further on the territory of the municipality of Novo Sarajevo.

18 JUDGE ROBINSON: Thank you.

19 So, Mr. Tapuskovic, I'm still trying to understand the Defence

20 case. Would it be correct to say that your case, then, is that the whole

21 situation in Sarajevo, including the history, the background, the

22 geographical positions of the various forces, was completely different

23 from that which was outlined in the Prosecution's case, and, in fact,

24 makes implausible the Prosecution case and, therefore, less credible the

25 allegations made of terror and of the crimes with which the accused has

1 been charged?

2 You are presenting to the Chamber a completely different picture,

3 which renders implausible the Prosecution's case.

4 MR. TAPUSKOVIC: [Interpretation] Your Honours, Your Honour,

5 Mr. President, Judge Robinson, of course, although, I was in a position

6 here several times to make my final arguments; nevertheless, I think that

7 this is something that I shall specify at the end of the proceedings.

8 Now, through this witness, I'm trying to ascertain what the

9 factual situation was in different parts of Sarajevo. At this moment,

10 what we are discussing is Grbavica, but we are going to call other

11 witnesses and we are going to prove precisely that, through the case of

12 individual municipalities; that is to say, that the dominant points in

13 Sarajevo were in the hands of the army of Bosnia-Herzegovina and that the

14 Serb positions were always at the foot of these hills, and that it was

15 very difficult to have a proper separation, especially Grbavica, Hrasno,

16 Nedzarici, Ilidza. Ilidza is a spot that is part of town.

17 So all these areas, in our belief and in terms of the case we want

18 to prove, were so intertwined, that if we look at the Prosecution case as

19 charged in the indictment, that cannot be proven at all.

20 So this is what we intend to show through our own case. That

21 situations were quite different from those referred to in the indictment.

22 This witness is just speaking about one very important segment of these

23 positions, the Serb positions that were within the heart of the city; that

24 is to say, in the area of responsibility of the Sarajevo-Romanija Corps.

25 When I say in the heart of the city, it was mixed. One river-bank was in

1 the hands of one army and the other side of the Miljacka was in the hands

2 of the other army. No one was in a blockade there.

3 This was an urban clash, a war conflict in the heart of a city,

4 the dominant features in this area in 80 percent of all the cases

5 involved. I categorically state that it has already been proven through

6 the evidence that we have heard. In my view and in the view of the

7 Defence, it was quite obvious who was on these hills in -- it is my belief

8 and my conviction that as we heard the Prosecution case, we did see who

9 held Mojmilo, Debelo Brdo, Stup Brdo, Zuc, Grdonj, not to mention all the

10 hills now. Of course, there are other areas now that are yet to be

11 discussed.

12 JUDGE ROBINSON: Thank you. Please move on.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. Mr. Katic, as for the blockade, now when I show you a document,

15 the 65 ter number is 03179. This is a Prosecution document. It is a

16 newspaper article from 1994. I would just like to draw your attention to

17 two paragraphs in order to explain what this blockade looked like.

18 Please, in addition to this physical blockade -- yes, see, the

19 text is here. Can you recognise the text? What newspaper is this? It

20 says at the bottom.

21 A. Srpska Vojska.

22 JUDGE ROBINSON: Is there an English translation for this.

23 MR. TAPUSKOVIC: [Interpretation] This is a Prosecution exhibit

24 that was tendered after the witness took the solemn declaration. I don't

25 know if there is a translation. I didn't receive one, but this is a

1 Prosecution document. It is a document that the Prosecutor wants to use.

2 I looked for a translation, but I couldn't find one.

3 JUDGE ROBINSON: Is this a Prosecution exhibit?

4 MR. DOCHERTY: It's on our list, Your Honour, that we have sent

5 over to the Defence. Whether we will actually use it or not, we don't

6 know at this point. Translation is pending.

7 JUDGE ROBINSON: Yes. But if you wish to use it, then you should

8 she that there is a translation, Mr. Tapuskovic.

9 Well, let us see. You wish to -- yes, Mr. Docherty.

10 MR. DOCHERTY: Excuse me, Your Honour. Ms. Bosnjakovic did a

11 little more checking and has found the English translation. It was just

12 recently done, so can we get just get. One minute.

13 JUDGE ROBINSON: All right. We'll wait.

14 MR. TAPUSKOVIC: [Interpretation] Your Honours, had I had just one

15 day, I would have had this translated, for sure, through a translator that

16 I would have engaged, but I got this only yesterday.

17 JUDGE ROBINSON: I believe we should move ahead and come back to

18 it.

19 Go ahead and then return to it when the translation is available.

20 MR. DOCHERTY: The translation is there now, Your Honour.

21 JUDGE ROBINSON: Oh, the translation is there now. Okay.

22 MR. TAPUSKOVIC: [Interpretation]

23 Q. Mr. Katic, you talked about this blockade a few moments ago, as

24 you saw it from Grbavica. Since we are discussing the blockade now, I

25 would like to draw your attention to the one-but-last paragraph of this

1 text. You told a journalist about something, and what it says here, does

2 that correspond to what you think and what you experienced while you were

3 there? It's the one-but last paragraph. Can you read that?

4 A. Yes. Yes, I can.

5 Q. Could you read it out loud.

6 A. "Sarajevo is under a blockade."

7 THE INTERPRETER: Interpreter's note: Could we have page 2 of the

8 translation. Thank you.

9 A. "Sarajevo is under a blockade but not of our forces, rather,

10 'several Muslim armies,'" quote/unquote. "Everyone has his own army and

11 his own quarter. These private companies do not allow anyone to leave the

12 town, and there are so many people who would like to get out, more than

13 50.000 Serbs for sure. While an HVO unit was in front of us, Serbs used

14 to cross the Miljacka river every day. However, Muslims no longer trust

15 Croatian soldiers. They are controlling them rigorously, so they cannot

16 close their eyes any longer."

17 Q. Thank you. Is that something that was dominant at that point in

18 time?

19 A. Yes.

20 Q. While you were president of the municipality, as a president of

21 the municipality, were you able to make a decision sometimes concerning

22 crossings over from one side to the other? Did you undertake any actions

23 in that respect?

24 A. I couldn't do anything or stop people from leaving from Grbavica

25 to the other side. However, on the 21st of March, or rather, on the 24th

1 of March, 1994, with the approval of UNPROFOR and both sides, the

2 Brotherhood and Unity Bridge was opened, enabling citizens from both sides

3 of the river Miljacka to cross over. That was done in cooperation the

4 civilian authorities of both sides, as well as with representatives of

5 UNPROFOR, so to speak, and the police from both sides. This was, in a

6 way, a crossing without any blockades at the time.

7 Q. In order not to go back again to this article concerning the

8 shooting that you mentioned yesterday, can you add some more information

9 about the issue of sniping?

10 A. Yesterday, I said that I know what a sniper rifle was, but I

11 didn't see any of them on either side. There was gun-fire from infantry

12 weapons, and I can freely say that Grbavica was an area covered with lots

13 of blankets, sheets, concrete blocks, and other material in order to

14 create passages for civilians across certain streets in Grbavica.

15 As I said, the separation lines were in Grbavica at about 30

16 metres. Soldiers would come to their trenches and their posts; and in

17 order to do that, they had to protect themselves on the incoming route

18 with various concrete tubes and canvas sheets in order not to be hit from

19 the other side.

20 Q. Thank you. Since we still have the document on this screen, I'm

21 going to show you some photographs. But can you please look at paragraph

22 3 of this article, and if you can read it out loud. Is this consistent

23 with what you were just telling us? Please read it out loud, if possible.

24 A. It starts: "This is..." --

25 THE INTERPRETER: Interpreter's note: That the proper page is not

1 on the screen.

2 JUDGE ROBINSON: Just a minute, please.

3 May we have the correct page on the screen.

4 THE INTERPRETER: Interpreter's note: It's there.

5 JUDGE ROBINSON: It's there now.

6 MR. TAPUSKOVIC: [Interpretation]

7 Q. Can you please read it now, because the Judges now can look for

8 themselves.

9 A. From the beginning?

10 Q. Yes.

11 A. "This is the most forward part of the front line of Republika

12 Srpska and the most dangerous one. We are more than happy, but at the

13 same time we feel uncomfortable if the day ends without victims,

14 uncomfortable because something is not right."

15 Q. Thank you. The rest is something written by the journalist, and

16 it doesn't have anything to do with your evidence.

17 Is that how it was?

18 A. Yes.

19 JUDGE ROBINSON: Witness, can you tell us something more about

20 this newspaper, about the publication? What kind of newspaper is this,

21 its orientation?

22 THE WITNESS: [Interpretation] Mr. President, I really don't know

23 what kind of presentation is in this newspaper. I know that I gave

24 statements and interviews. What I said and read here, I stand by it, but

25 I can also say right away that I hadn't read this before or seen this

1 newspaper.

2 JUDGE ROBINSON: Very well. Thank you. I shan't pursue any

3 further on that.

4 Yes, Mr. Tapuskovic.

5 MR. TAPUSKOVIC: [Interpretation] Your Honours, you are right, but

6 I would, nevertheless, insist for the witness to take a look so that we

7 know.

8 Q. It is written underneath this whole article. There's an

9 indication there. It's the name of the newspaper.

10 A. Srpska Vojska. But I didn't receive this newspaper in my office.

11 I didn't read it.

12 Q. Thank you.

13 MR. TAPUSKOVIC: [Interpretation] Your Honours, can this document

14 please be admitted as a Defence exhibit.

15 JUDGE ROBINSON: Yes.

16 THE REGISTRAR: As D198, Your Honours.

17 MR. TAPUSKOVIC: [Interpretation]

18 Q. Mr. Katic, yesterday, you talked about you becoming president of

19 the assembly of Novo Sarajevo on the 13th of March, 1993; is that correct?

20 A. Yes, it is.

21 Q. After that date, until the end of the war, what did your duties

22 involve?

23 A. I was exclusively involved in civilian duties. Immediately at the

24 very outset of my duties of the president of the municipality and on the

25 basis of the statute, I changed --

1 Q. Please, can you first answer directly my question. What kind of

2 duties did you discharge? Can you just tell me briefly in what kind of

3 duties were you involved from that point until the end of the war?

4 A. I was involved exclusively in civilian affairs and nothing other

5 than that.

6 Q. Thank you. Speaking about the highest international officials,

7 who were you in contact with at one point in time at the very end?

8 A. I am exceptionally honoured to say this, but I cannot remember all

9 the high representatives from all over the world. Towards the very end of

10 the war, the premises of the Novo Sarajevo municipality were visited by

11 Mr. Kofi Annan, who was later elected president of the United Nations.

12 Q. Thank you. I'm going to show you a Prosecution Exhibit, 65 ter

13 03174.

14 It will take too much -- actually, it won't take too much time to

15 read it because it is a short document. I kindly ask you to read it as

16 fast as possible, and then I will pose just one question to you, or

17 perhaps two questions.

18 A. Please go ahead.

19 Q. Does this have to do with your civilian function? In what

20 capacity did you receive him at the time?

21 A. In the capacity of the president of Novo Sarajevo municipality.

22 Q. What was the problem that arose a few days after -- if you look at

23 this date, at that time? That's 28 of November, 1995.

24 MR. TAPUSKOVIC: [Interpretation] That goes by five days beyond the

25 framework of the indictment, and I would ask the Trial Chamber, their

1 leave to put this question to the witness.

2 Q. But can you answer it, please?

3 A. It is not clear to me, 28th November 1995, that's the date; and on

4 the 21st of November, 1995, the Dayton Peace Accords were signed.

5 Q. Yes. But look at the last -- or the end of the last sentence in

6 the first paragraph.

7 A. The signatures of the three leaders in the Dayton carry certain

8 weight. There were no -- and no changes were envisaged in the agreement

9 itself.

10 Q. I was not referring to this. What was happening with the Serbian

11 population at that time in the territory of your municipality? That was

12 what my question was about.

13 A. Well, I can say that each municipality in the Serbian town of

14 Sarajevo was scheduled for the implementation of the Dayton Accord. The

15 Novo Sarajevo municipality, or rather, Grbavica was supposed to have it

16 implemented as part of Bosnia-Herzegovina on the 18th of March, 1996.

17 Q. Thank you. I'm not asking you -- I'm not asking you about

18 political connotations. I'm asking you about how the people, the

19 residents of that municipality, were behaving. What was it that they

20 started doing after that?

21 A. The people were already thinking where to move from Grbavica.

22 Many of them left in January for other parts of Republika Srpska, from

23 Pale, Visegrad, Brcko, Teslic, all the way to Banja Luka.

24 Q. So were those the problems already existing at the time when you

25 met with Kofi Annan?

1 A. As far as I can remember, these problems did not exist at the time

2 that we discussed them on the 28th of November, 1995.

3 JUDGE ROBINSON: What led to the Serbs leaving Grbavica and the

4 other parts that you mentioned?

5 THE WITNESS: [Interpretation] Your Honour, there had been a war

6 going on there for four years. There was no love there. People were

7 dying. There was no trust on any side. Serbs went to the territories

8 that in accordance with the Dayton Peace Accord belonged to Republika

9 Srpska; and Muslims, or Bosniaks, and Croats, went to the territory that,

10 again under the Dayton Accords, remained as part of the Republic of Bosnia

11 and Herzegovina.

12 JUDGE ROBINSON: Thank you.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. How many Serbs remained in Novo Sarajevo after the war?

15 A. After the war, about 10.000 inhabitants remained in the territory

16 of Novo Sarajevo municipality, in the part that, under the Dayton Peace

17 Accords, was part of Republika Srpska.

18 Q. And at the time when it was still controlled by the Republika

19 Srpska army, how many of them were there? How many inhabitants?

20 A. During the war, around 25.000 people lived in Novo Sarajevo

21 municipality, in Grbavica, and in other areas that were part of the

22 Serbian municipality of Novo Sarajevo.

23 Q. Thank you. Now we have to go back to the very beginning. Did you

24 have any duties? Did you hold any posts in the leadership of the Serbian

25 Democratic Party, apart from what you have just told us that you were a

1 deputy in the municipal assembly?

2 A. I never held any other posts in the Serbian Democratic Party,

3 except, of course, for being a deputy. I never was a member of the main

4 board of the Serbian Democratic Party. I was not even on the municipal

5 board, and I don't think that I was in the local commune board either.

6 Q. But you spoke at length yesterday about how it all began. You

7 said that Pofalici incident happened, Mojmilo incident happened, in May

8 and June respectively. Did it dawn on you at that point what was actually

9 going on? I don't want to lead you.

10 A. Well, those things that happened, happened. And when I became the

11 president --

12 Q. No, no, no. That's the time-period that I'm yet to question you

13 about. I'm asking you immediately after the Pofalici incident and the

14 Mojmilo incident; that would be the summer of 1992.

15 A. We had a problem with the routes.

16 Q. At that stage, did you become a member of a body, after those

17 conflicts broke out?

18 A. Yes. Yes, I did. I became a member of the commission of the

19 Serbian municipality of Novo Sarajevo as a representative of the deputies

20 of the Serbian Democratic Party, or rather, I represented all the deputies

21 in the municipal assembly. And I have to say that because at that time I

22 was the only person with a university degree, I was nominated as a member

23 of this commission for the Novo Sarajevo municipality, and this commission

24 was set up by Mr. Karadzic, the president of the republic.

25 Q. Let me now show you a 65 ter document, 03172.

1 Well, you can see -- this document that you have now before you,

2 does this accurately depict the situation, this account that you have just

3 given us?

4 A. Yes, it does. And as I've already said, this document was signed

5 by the president of the Republic, Mr. Karadzic. He, in fact, nominated

6 the members too. And if I may say so, I saw this document three years

7 ago, I think, when I was interviewed by the investigators of the ICTY.

8 And if I may add, the person under number 1, the republican commissioner,

9 was the Minister, the deputy in the Republika Srpska assembly, Mr. Petko

10 Cancar.

11 Q. Could you please tell me -- I have already put it to that you the

12 incidents at Pofalici and Mojmilo had already happened. Can you please

13 look at the date on this document and the first paragraph of this

14 document. What were the circumstances in which this decision was taken?

15 MR. TAPUSKOVIC: [Interpretation] Your Honours, the accused has

16 warned me that the English translation is not identical to the original,

17 and he is right because the date is the 17th of July, and in B/C/S you can

18 see that the date is the 21st of July, 1992.

19 THE WITNESS: [Interpretation] Completely different dates.

20 MR. TAPUSKOVIC: [Interpretation] Yes. The accused indeed was

21 right and he has a really good eye, because you can see here that I didn't

22 see that the dates were different on the two versions.

23 JUDGE ROBINSON: So does that mean that this is not the correct

24 document? It appears that this is not the correct document. The numbers

25 not the same either, so could we find the correct document.

1 We're grateful to the accused for that.

2 MR. TAPUSKOVIC: [Interpretation] It is possible that it is the

3 same document, but this may -- no, no. Everything is different.

4 THE WITNESS: [Interpretation] The names are different.

5 MR. TAPUSKOVIC: [Interpretation] You can see that Katic, the name

6 Katic is not mentioned here at all, and in the original you can see Katic.

7 Well, if it hadn't been for the accused, I, for one, would not

8 have noticed this.

9 JUDGE ROBINSON: Are we able to locate the correct document?

10 MR. TAPUSKOVIC: [Interpretation] Could this document be admitted

11 as a Defence exhibit in B/C/S; and once we've found the translation, then

12 can we at least have it marked for identification and then admitted later.

13 JUDGE ROBINSON: Yes.

14 MR. TAPUSKOVIC: [Interpretation] Can I at least conclude the

15 examination of this witness now, because he doesn't need the translation

16 and then we can get the translation later.

17 JUDGE ROBINSON: Yes. Go head.

18 THE REGISTRAR: This will be marked for identification as D199,

19 Your Honours.

20 MR. TAPUSKOVIC: [Interpretation] Of course, that is until we've

21 received a translation. So now have I to -- I have to repeat my question.

22 I will not go back to what happened at Pofalici and Mojmilo, so I will not

23 be repeating this.

24 Q. But could you please now read the first paragraph, and then tell

25 us whether this has anything to do -- whether these two things are in fact

1 related?

2 A. Well, on the basis of this preamble --

3 MR. TAPUSKOVIC: [Interpretation] Your Honours, now we have the

4 translation on our screens.

5 JUDGE ROBINSON: Very well.

6 THE WITNESS: [Interpretation] On the basis of the first preamble,

7 and in view of what had happened at Pofalici and Mojmilo, there was an

8 imminent threat of war. And a commission was established, not only for

9 the Novo Sarajevo municipality. Such commissions were established in

10 other municipalities. And as I stated three years ago, I was shown this

11 piece of paper, but this commission never met with the members that are

12 listed here throughout the war.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. What I would like to ask you -- you've explained to us that you

15 had spent some time in the trenches, but I want to ask you whether you

16 made any decisions that had to do with military activities.

17 A. We, in the local authorities, and that goes for all

18 municipalities, we could never make any decisions or exercise command over

19 military structures.

20 MR. TAPUSKOVIC: [Interpretation] Your Honours, could we have this

21 document admitted into evidence as a Defence exhibit now.

22 JUDGE ROBINSON: Yes.

23 THE REGISTRAR: Your Honours, this will be admitted as D199.

24 MR. TAPUSKOVIC: [Interpretation]

25 Q. And now, incidentally, I would like to show you Exhibit P496.

1 Did the Prosecution show you this document several years ago, or

2 whenever? I don't know.

3 A. I'm familiar with this document. It was shown to me last year,

4 again by the investigators in Sarajevo. So I am familiar with it.

5 Q. Could you please read the first chapter in this document? You can

6 first see the date. You can see who signed this order. So could you

7 please tell the Judges.

8 A. Could we please have this enlarged a little bit.

9 I can say that I see here, "I have information that on 5th of

10 November, 1994, a meeting took place between local leaders in Vogosca ...

11 where a decision was made to block UNPROFOR, to confiscate heavy equipment

12 under UNPROFOR control, and to shell civilians targets in Sarajevo with

13 heavy weapons," lest I should now read everything.

14 Q. Could you please read everything.

15 A. "Bearing in mind that such a decision can have a long-term

16 negative consequences for the Serbian people, and that these combat

17 activities are being planned without my knowledge."

18 Q. Mr. Katic, please, could you read the first part of this document,

19 before it says "I order."

20 A. "I have information that on the 5th of November, 1994, a meeting

21 took place between the -- of the local Serb leaders of Serbian Sarajevo in

22 Vogosca, which was attended also by the commander of the Sarajevo-Romanija

23 Corps, where a decision was made it block UNPROFOR, to confiscate heavy

24 equipment under UNPROFOR control, and to shell civilian targets in

25 Sarajevo with heavy weapons, bearing in mind that such decisions can have

1 long-term negative consequences for the Serbian people, and that these

2 combat activities are being planned without my knowledge."

3 Q. Thank you. Please stop.

4 A. I stopped.

5 Q. Can you please tell me who signed this decision. Who is behind

6 this document?

7 A. Commander, Lieutenant-Colonel Milorad Sehovac.

8 Q. Yes, but on the left-hand side?

9 A. Commander, Colonel-General Ratko Mladic.

10 Q. My first question to you is: As the president of a municipality,

11 did you ever attend any such meeting? It says here that Mladic gained

12 information, that some meetings were held between General Milosevic and

13 the representatives of the civilian authorities. Did you ever attend any

14 such meetings?

15 A. No, Your Honours, and that is what I stated to the prosecutors in

16 Sarajevo. I say that I never attended such meetings as president of the

17 municipality.

18 According to what I saw here, the civilian authorities issue

19 orders to a corps commander. I assert that I never attended such

20 meetings.

21 Q. And do you know that any civilian official ever took part or could

22 take part in the bringing of such a decision?

23 A. Not a single civilian, or rather, the representative of the

24 civilian authorities at local level could take part in making such a

25 decision.

1 Q. Have you ever heard from anyone that General Milosevic at some

2 gathering with the representatives of the civilian authorities decided to

3 bomb Sarajevo?

4 A. I've already said that I have not heard that, and I was not never

5 present and never heard orders from General Milosevic that he would be

6 hitting Sarajevo.

7 Q. Thank you. Now, as you said a few moments ago, I have

8 information, et cetera --

9 JUDGE ROBINSON: May I ask the witness whether, if such a meeting

10 did take place between General Milosevic and the local Serb leaders, is it

11 likely that he would have been one of those present?

12 THE WITNESS: [Interpretation] Your Honour, from this place now, I

13 cannot claim that a meeting was held, when I was not there, when I was not

14 present. However, on the basis of my knowledge, I think that such a

15 meeting had not been held, because if all the presidents of the

16 municipalities of the city of the Serb Sarajevo, it would have been

17 logical for me to have been invited as well. However, I had not been

18 invited and I had not attended such a meetings, even if such a meeting had

19 been held per chance, but I don't think that such a meeting was ever held.

20 JUDGE ROBINSON: Thank you.

21 MR. TAPUSKOVIC: [Interpretation] Thank you.

22 [Trial Chamber confers]

23 JUDGE HARHOFF: Mr. Witness, why then would General Mladic issue

24 such an order? What is the background for this order?

25 THE WITNESS: [Interpretation] I really do not understand, for this

1 kind of document to come from General Mladic. On the other hand, I see

2 that it is signed and sent on by Lieutenant-Colonel Milorad Sehovac. I

3 think there were different stories going about, jealousy among officers,

4 different calculations, so I do not believe that such an order and such an

5 agreement could have been reached in the municipality of Vogosca, as

6 stated here.

7 JUDGE HARHOFF: Do you suggest that General Mladic was

8 misinformed?

9 THE WITNESS: [Interpretation] Probably.

10 JUDGE HARHOFF: Thank you.

11 [Trial Chamber confers]

12 JUDGE ROBINSON: Yes, Mr. Tapuskovic.

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. Can you tell the Judges, well, as briefly as possible right now,

15 so that we don't dwell on this document much longer. You, as a civilian

16 representative of the people, if I can put it that way, when you met with

17 General Milosevic, what were the dominant subjects of your talks?

18 A. I did meet with General Milosevic when he became commander of the

19 Sarajevo-Romanija Corps. The dominant subjects that we discussed were

20 humanitarian aid, the protection of civilians at Grbavica, the protection

21 of roads through Lukavica towards the Kasindol hospital, obtaining

22 firewood.

23 After large-scale fighting in the territory of Bjelasnica, Igman,

24 further up north, the Nisic plateau, where the forces of the army of

25 Republika Srpska were losing positions every day, if I can put it that

1 way, and we had many fatalities among the soldiers, the General intervened

2 through the civilian authorities, through me specifically, to have coffins

3 obtained.

4 When I talked about humanitarian aid, it was necessary to ensure

5 as much food as possible, as well as fuel, and we did all of that through

6 the civilian authorities. These were specifically my talks with General

7 Milosevic and with other commanders of brigades that were within the

8 corps, or rather, in charge of safeguarding the borders of the Serb

9 municipality of Novo Sarajevo.

10 Q. Would that be the reason when he would go elsewhere, Ilidza,

11 Rajlovac, Nedzarici, anywhere, when he would go to the representatives of

12 the civilian authorities? Vogosca, for instance.

13 A. Knowing what was discussed with me, I assume that the same thing

14 was discussed with other presidents of municipalities, or rather,

15 presidents of the Executive Boards of these mini-governments in different

16 municipalities.

17 JUDGE ROBINSON: Mr. Docherty.

18 MR. DOCHERTY: When the question was asked, I assumed that the

19 witness would have personal knowledge of these meetings with other

20 presidents of other municipality assemblies, but the witness has just

21 stated that he has to make an assumption that is an extrapolation from the

22 conversations he himself had with the accused. And so for reasons of lack

23 of foundation, I'll object to the witness continuing with this answer,

24 unless a proper foundation can be laid.

25 JUDGE ROBINSON: Yes. He can't really help us with that

1 information, Mr. Tapuskovic.

2 MR. TAPUSKOVIC: [Interpretation] Your Honours, I'll rephrase my

3 question and, well, I will have to deal with the subject one way or the

4 other.

5 Q. Yours was the municipality of Novo Sarajevo. Was there an

6 assembly of all the municipalities within the area of responsibility of

7 the Sarajevo-Romanija Corps?

8 A. In 1994, the city of the Serb Sarajevo was established consisting

9 of six municipalities; namely, the Serb New Sarajevo; Pale; Stari Grad,

10 the old city; the Serb municipality of the centre, Centar; Vogosca,

11 Rajlovac; and Ilidza. And in 1994, the seat of this city was in the

12 municipality of Vogosca.

13 Q. Thank you. When you would meet, what did the meetings look like?

14 Who would come to attend these meetings?

15 A. Only presidents of Executive Boards of municipalities came to

16 attend these meetings, as well as the presidents of the municipalities;

17 that is to say, two persons respectively.

18 Q. Thank you. Now, these meetings, when you would all get together,

19 what was the dominant topic?

20 A. Since this was already 1994, what would happen was that the

21 economy was not functioning. We would, say, look at an organisation to

22 see how the economy could be stepped up, how people could find employment

23 in these companies, how to organise the public utilities, the water works

24 at city level, the power company at city level, then also sewage, garbage

25 at city level.

1 If not possible, then every municipality should set up its own

2 mini-locations as garbage dumps. Because I can say that during 1994, from

3 the point of view of the municipality of Novo Sarajevo, there was less

4 military activity. Sometimes gun-fire was heard from one side or the

5 other, if I can put it that way, but there was a sort of a cease-fire.

6 So these were the talks that dominated; that is to say, the

7 functioning of joint companies and the economy as such, or rather,

8 providing humanitarian aid and how to assist the representatives of the

9 military in terms of food and fuel supplies.

10 Q. Thank you. Let's look at the document again for a moment; and if

11 we look at what it says here, when the General learned this - let's not go

12 into it in any greater detail - what happened then? In the first

13 paragraph. Let's not go any further. Let's just get this over with.

14 A. "Without my explicit order or approval, I forbid undertaking any

15 activities in connection with the blockade of UNPROFOR and confiscation

16 ever heavy weaponry under its supervision without my explicit order and

17 consent."

18 Q. Can you just tell me what the time span was between the date when

19 he learned of this and the date of the order itself? Can you see this in

20 the document?

21 A. It is almost impossible.

22 Q. Please. Look at the letterhead.

23 A. The 7th of November, and the meeting was held on the 5th of

24 November.

25 Q. How many days is that?

1 A. Two days.

2 Q. Thank you. Since you mentioned now this assembly where all the

3 representatives of all the municipalities left -- or rather, took part.

4 MR. TAPUSKOVIC: [Interpretation] With the permission of the Court,

5 well, I did not put on my 65 ter list at all the map that we started using

6 from the very outset, the UNPROFOR map that we showed practically all our

7 witnesses. The document number is 289 -- no, 298.

8 Could we have a look at this map, and can we use it in the future

9 too? I have been using it practically every day.

10 JUDGE ROBINSON: Yes.

11 MR. TAPUSKOVIC: [Interpretation] Not that map, the UNPROFOR map.

12 Q. Could you show the place where the assembly of the entire area

13 was, rather, where all the municipalities were together, that assembly?

14 A. In Vogosca.

15 Q. Could you mark that with a letter V.

16 A. [Marks]

17 Q. Could you now put a small dot where the building of the

18 municipality was; that is to say, the municipality where you were

19 president.

20 A. I have done that.

21 Q. Is that practically at the separation line itself, between the two

22 sides?

23 A. Well, yesterday, I said how far away the municipality was from the

24 residence of Mr. Izetbegovic, 300 metres, so the municipality building was

25 practically at the separation line.

1 Q. Can you mark it with a letter G, please.

2 A. [Marks]

3 Q. Can you now draw a line of your route. How often did you attend

4 these municipal assembly meetings every month?

5 A. Approximately, once a month, sometimes once in 20 days; but let me

6 say, once a month we had meetings in Vogosca and sometimes in the

7 municipality of Ilidza in Ilidza.

8 Q. Please mark Ilidza --

9 A. [Marks]

10 Q. -- with a letter I.

11 A. I did that.

12 Q. Now, can you please draw the line of the route that you had to

13 take in order to get to these meetings concerning the problems that were

14 at hand; and can you also describe, while you're drawing this line, what

15 kind of problems you encountered?

16 A. I first have to say that while I was president of the

17 municipality, I didn't have either a driver or a personal escort. I went

18 on my own, and I drove the car myself.

19 I would set from Grbavica down the road towards Trebevic, exit

20 Vraca, and then via Trebevic.

21 Q. Now, please, can you stop for a second?

22 A. Yes, I can.

23 Q. This line, what does it represent, approximately? What is the

24 location?

25 A. This is the location when you exit at Vraca, a to Trebevic via

1 Miljevici and Zlatiste.

2 Q. Please, please. What is the size of the area at Zlatiste from

3 which perhaps one could see part of the city of Sarajevo?

4 A. The road at Zlatiste, the passage leading to Osmice from which one

5 can see Sarajevo, is about 150 metres long. The rest of the road goes

6 through a forest and via Trebevic.

7 Q. Thank you. Can you please use another pen, another colour. While

8 you were -- while you were a fighter, can you show and indicate the line

9 where you were as a fighter. So next to this blue line, can you indicate

10 the area where you were as a fighter?

11 A. [Marks]

12 Q. Can you now show us where Debelo Brdo is?

13 A. Here it is.

14 Q. Can you tell the Court who held the dominant elevation at Debelo

15 Brdo?

16 A. Throughout the war, from 1992 until the end of the conflict, the

17 Debelo Brdo elevation was held by the forces of the army of

18 Bosnia-Herzegovina; and I can say that while I was a soldier in 1992, from

19 the positions near our houses, we always had Debelo Brdo in front of us,

20 and we couldn't see Sarajevo.

21 Q. Tell me, the positions that you held, how far were they from

22 Zlatiste?

23 A. The positions where I was to the peak of Zlatiste, the distance

24 was about 200 metres.

25 Q. Tell me, from your positions, could you see at all -- I mean, I'm

1 not going to lead you. What were you able to see? Can you explain that

2 to the Judges?

3 A. From the positions where I was in 1992, I could see parts of

4 Grbavica, or virtually the whole of Grbavica, and perhaps a small part of

5 Kovacici.

6 As far as the city was concerned, I could only see Velesici and

7 Pofalici on the other side, and that is much further from the river

8 Miljacka.

9 Q. Can you please mark Debelo Brdo on the map with a letter D.

10 A. [Marks]

11 JUDGE ROBINSON: And there we must stop, Mr. Tapuskovic.

12 We'll take the break now.

13 --- Recess taken at 10.31 a.m.

14 --- On resuming at 10.54 a.m.

15 JUDGE ROBINSON: We have a small technical problem relating to the

16 markings which the witness made on the map. We have lost them, so I'm

17 going to ask the witness to remark the map so we can have it in evidence.

18 MR. TAPUSKOVIC: [Interpretation] Can I have the floor, please?

19 JUDGE ROBINSON: Yes.

20 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours.

21 Q. Mr. Katic, you have to mark again the place where Novo Sarajevo

22 municipality was, just like you did last time, with a dot.

23 A. [Marks]

24 Q. And put a letter G?

25 A. [Marks]

1 Q. You have to mark again Vogosca with a circle that you put before

2 and put -- yes. Thank you. And the place where Ilidza is and put a

3 letter I.

4 A. [Marks]

5 Q. Thank you. If you could now continue your movement on the map,

6 after Zlatiste, what was the first place that you came across?

7 A. As soon as I left Zlatiste, the road leads on to Trebevic. I

8 would come to Osmice where the separation line was at about 40, 50 metres.

9 That was the so-called Andja's house, as everybody used to call it. On

10 this section, and due to the geographical terrain, the vehicle have to

11 slow down, and this poses a great danger to traffic at this particular

12 spot.

13 If we move on --

14 Q. What was around the road on this location?

15 A. From the lower side is a wood and rocks immediately after you

16 leave Zlatiste. There were rocks on both sides of the road, like a sort

17 of a canyon.

18 Q. How big is the forest there?

19 A. As soon as you pass through these rocks on the other side, the

20 wood is on both sides of the road in the direction of Trebevic.

21 Q. Can you please now continue drawing the line and stop at the point

22 where the forest ended. How big is this distance? Please continue

23 drawing the line.

24 A. This is a fork on the road.

25 Q. Thank you. Thank you. While you are passing through the wood, do

1 you have any view from that point of the inner-city of Sarajevo? Could

2 you see Grbavica, Bascarsija?

3 A. From the road which I used to take, the forest blocked the view.

4 These are big evergreen trees, and one cannot see parts of Sarajevo,

5 including Bascarsija. These are very tall trees in this for rest.

6 Q. So if you proceed further on, and keep drawing the line, which

7 direction would you take?

8 A. There's a detour from the separation line towards Pale.

9 Q. Thank you. And then from Pale, how can you go back to this map

10 again?

11 A. Returning from Pale, I would set off towards --

12 Q. Draw it. Draw it.

13 A. Sumbolovac; that is to say, Hresa and Vucja Luka.

14 Q. Please keep drawing the line.

15 A. And here --

16 Q. Can you please stop for a moment.

17 Now, while you were going down this road, did you encounter any

18 problems?

19 A. As soon as I arrived with my vehicle to Hresa --

20 Q. Mark it.

21 A. It's about here.

22 Q. Put a letter H. And then when you proceeded, what happened on the

23 road?

24 A. As it is shown on the map, there are the lines here, and they're

25 so close. One had to pass by Spicasta Stijena where, if I drove a car, I

1 could only hear shots because that was a macadam and you couldn't drive

2 fast. At one point, I would be in a position that I didn't know who was

3 shooting and from where. The only important thing is to pass that section

4 without being shot or without experiencing something else.

5 Q. So in what direction did you then proceed?

6 A. I would go --

7 Q. Please mark -- please put an S. No, no, no, no. Spicasta

8 Stijena.

9 A. [Marks]

10 Q. Very well. Where you put the letter S, is that Spicasta Stijena?

11 A. No, not where the letter S is.

12 Q. Well, put an S.

13 A. You want me to put an S where Spicasta Stijena is?

14 Q. Yes.

15 A. It's somewhere here.

16 Q. Very well. Tell me, in geographical terms, what is Spicasta

17 Stijena? Geographically speaking, was that --

18 A. Geographically speaking, that was one of the higher elevations in

19 this area.

20 Q. And it was part of which hill?

21 A. As far as I know, and I used to pass there once in a month or once

22 in 20 days, I think that it is part of Grdonj, or rather, these --

23 Q. Thank you. Now, tell me, where did you go next, and what happened

24 in the subsequent areas or sections of the road?

25 A. I'm going to draw the road, and then I'm going to describe it for

1 you.

2 Once I passed Grdonj and Spicasta Stijena, I would go down through

3 Mrkovici village and reach Radava.

4 Q. Please put a letter R for Radava.

5 A. Somewhere here.

6 Q. Was something happening there?

7 A. Well, the separation lines were close to each -- one another also,

8 so that both Radava, which belonged to the centre municipality, and the

9 road and this area could have been shot at or fired at from the Grdonj

10 hill.

11 Q. Yes, quite. So while you were passing down these roads, were you

12 able at all to see Sarajevo from these points, any part of Sarajevo, and

13 where could it stop, if you can show us?

14 A. Well, from these areas that I just indicated where you pass,

15 through here, it is impossible to see Sarajevo from any part until you

16 move closer to the village of Poljane, further away from Radava.

17 Q. Could you please mark it?

18 A. Well, this is where it is, approximately.

19 Q. And what can you see from that point?

20 A. From Poljane, you can see parts of Kosovo, Bare, in Sarajevo, that

21 area, that is not as densely inhabited as the rest of Sarajevo, but parts

22 of Bare, Kosovo, the Kosovo hill, and so on. And you can also see Hum and

23 Kobilja Glava at Hum, and other places such as that, from this area if you

24 look in this direction.

25 Q. This is precisely what I'm asking. From Hum and from Zuc, what is

1 your position in relation to Hum and Zuc?

2 A. Well, I am in a subordinate position because from Hum, Zuc, and

3 Kobilja Glava, you can actually target those areas here at Poljane.

4 Q. Could you please tell me, as you move on to Vogosca, where is this

5 line that you just drew, and the red line? But first draw the line to

6 Vogosca?

7 A. Well, here it is.

8 Q. And what is the position of these two lines, the red and the blue

9 line?

10 A. Well, these are more or less the separation lines where the road

11 goes through those uninhabited, almost completely uninhabited areas

12 entering the Pretis factory, going through it.

13 Q. Thank you. What I'm asking you is: Those lines, in relation to

14 the geographic positions of these areas, who is now in more favourable

15 position if you look at those two lines, the red line, the blue line, and

16 even the yellow line? Who has the dominating position over those areas?

17 A. Well, from the opposite side, here, there is the Hum hill; and

18 from the positions there, this line can be targeted and is under threat

19 from those positions. I think that -- that Hum is dominant; it's

20 dominating these areas here.

21 Q. Can you now please quickly draw there line all the way down to

22 Ilidza.

23 A. Well, I'm not quite sure. This is how we went, more or less.

24 This is where we actually diverge. I can say, since I didn't say that

25 before, this road, the entire road, from the old town municipality, Hresa

1 all the way up to Vogosca, this is a macadam road. You could not do more

2 than 20 or 30 kilometres per hour. Our journalists sometimes referred to

3 this road as the Road of Sun. I often used to say that for the

4 inhabitants of Ilidza, Vogosca, and Rajlovac, this was the Road of

5 Salvation. Because as the road was being made, and I know something about

6 that, more than 20 per cent -- the slope is -- the gradient can more than

7 20 per cent. It was impossible to move there in winter, in particular, if

8 the road was targeted, if there was fire, and the road traffic would be

9 blocked for hours, not even ambulances could pass. If there was some

10 seriously wounded or sick people, they could not be transported to Pale.

11 As regards the road to Rajlovac, the Ilidza municipality, in other

12 words, this entire road from Vogosca to Rajlovac was in a very precarious

13 position because of the BH army positions. Because particularly near

14 Rajlovac there were those dominating hills above Zobrezje, Sokolje, and

15 other slopes leading to Rajlovac, where the inhabitants of Rajlovac were

16 on the low ground and were daily exposed to fire from those areas that

17 dominated this area. And there where the road diverged from Rajlovac and

18 from the separation lines, this was a little bit safer.

19 Q. Do you mean the Vogosca-Ilidza road?

20 A. I was talking about the road from Vogosca to Rajlovac, how danger

21 it was; and then, and only when you pass the Rajlovac, there was a section

22 in the direction of Ilidza that was a little bit safer because it diverged

23 from the separation lines, from the positions.

24 Q. Thank you. You said the Road of Salvation. What happened on that

25 route, if the prevailing circumstances were as you just described them?

1 A. Well, if a vehicle passing through would be hit, and if there were

2 in the casualties, some civilians or whoever was in the car, they were

3 wounded, going from Ilidza, Vogosca, Rajlovac to Pale, then traffic would

4 be blocked.

5 Q. Well, you already said that. Could you please tell me, all those

6 lines that you just described for us, were there any consequences for the

7 human lives, both civilians and soldiers?

8 A. Yes, for sure, because I would come across some vehicles that

9 would be hit. They would be giving a lift to a civilian or soldier who

10 had been wounded; and as I already described, this is quite a long route,

11 maybe 50 kilometres, and there some critical points at several places,

12 very exposed to fire from BH army, and, quite naturally, both soldiers and

13 civilians alike would be -- there would be civilian and military

14 casualties.

15 Q. And can you tell me, why didn't you go straight to Grbavica when

16 you got there from Ilidza using some other route. Was there any other

17 route to Grbavica from Ilidza except this one?

18 A. Until June 1992, members of the Republika Srpska army and

19 civilians used the airport as a route between Ilidza and the Serbian

20 municipality of Novo Sarajevo; and then in June 1992, the airport came

21 under -- under UNPROFOR control, and UNPROFOR had control over it.

22 Q. And at the time of Dragomir Milosevic, were there any additional

23 circumstances that made it easier for the people in Sarajevo to live, in

24 relation to what you just said about the airport? I don't want to lead

25 you on this.

1 A. I'm sorry. I didn't quite understand your question.

2 Q. Well, what was there underneath -- what was there at the airport?

3 Could you please answer.

4 A. Well, underneath the airport, a tunnel had been dug. It was used

5 by the BH army to move from Sarajevo to other areas, other parts of

6 Bosnia-Herzegovina that were controlled by the Bosnia-Herzegovina army.

7 Q. But, first, answer to this question: How long did it take you to

8 get from your assembly, if the session was in Ilidza, to get back home?

9 How long did it take you?

10 A. Well, if I headed out from Grbavica, and if the meeting was at

11 Ilidza, it would take me about five or six hours because it's about 100

12 kilometres. When I had to travel from Grbavica to Ilidza via Pale, and if

13 the meeting was scheduled for 10.00, I would start at 5.00 a.m., and I

14 would come back at 10.00 p.m. That's when I would come home.

15 Q. And, in winter, we know what Sarajevo is. Everybody knows what

16 Sarajevo is. What was it like in winter?

17 A. Well, in winter time, it was much, much tougher. First of all,

18 this road that had been made during the war did not comply with any

19 standards for macadam roads that could actually meet the demands of this

20 kind of traffic; and then in the fall, there would be mud, and then in

21 winter, if you didn't have good tires, if you didn't have snow chains, you

22 couldn't even pass in many areas.

23 Q. Thank you. Thank you. How long did it take for civilians or

24 soldiers from those areas that were in the area of responsibility of the

25 BH army to get to Igman, for instance, or Hrasnica?

1 A. Well, I think if you used the tunnel and the road through Dobrinja

2 from Sarajevo to the airport, I think -- I never took the route through

3 the tunnel, not evenly after the war. I don't think it would take you

4 more than two hours.

5 MR. DOCHERTY: Mr. President.

6 JUDGE ROBINSON: Yes, Mr. Docherty.

7 MR. DOCHERTY: If he has never taken the route through the tunnel,

8 then I don't think he can of an opinion as to how long it takes to transit

9 it.

10 JUDGE ROBINSON: As to how long it takes to transit it?

11 MR. DOCHERTY: He was describing a route, and he said in his

12 answer says, "I never took the route through the tunnel, not even after

13 the war," and then proceeded to offer an opinion as to the duration,

14 anyway.

15 JUDGE ROBINSON: Well, he might have been told by somebody who had

16 transited the tunnel.

17 What would be the basis for the information that you are giving,

18 as to the length of time that it would take to go through the tunnel?

19 THE WITNESS: [Interpretation] Your Honour, based on my knowledge

20 of the streets of Sarajevo now and before the war, you could get to the

21 tunnel from any part in half an hour. And no matter what conditions there

22 were in the tunnel, and on the basis of what I know about the length of

23 the tunnel, it would not take you more than an hour to pass through the

24 tunnel; so that's an hour and a half, and then half an hour to get to

25 Hrasnica. So these are the arguments that I use; and in my current post,

1 the chief of traffic department, I can confirm that and I can actually

2 state this.

3 JUDGE ROBINSON: Let's move on.

4 MR. TAPUSKOVIC: [Interpretation]

5 Q. Well, in order for us to include this last piece of information on

6 this map, could you please draw the line from the part of Dobrinja that

7 was under the control of the BH army in the direction of the tunnel, and

8 then on to the edge of this map. Could you please draw this line.

9 Your Honours -- in fact, Witness, could you please mark it with

10 letter A.

11 A. [Marks]

12 Q. But could you please draw the line out. This is Dobrinja?

13 A. Yes. This is Dobrinja.

14 Q. Okay. Thank you. Thank you.

15 So could this document please be given a number as a Defence

16 exhibit.

17 JUDGE ROBINSON: Yes.

18 THE REGISTRAR: Your Honours, this will be admitted as D200.

19 MR. TAPUSKOVIC: [Interpretation]

20 Q. Could you please tell us, or maybe you can't, how many -- what was

21 the distance in kilometres from Grbavica to Ilidza where you would finally

22 reach your destination and then on the way back at the time of the events?

23 A. Well, I can tell that you Grbavica to Pale is 30 kilometres across

24 the Trebevic; and from Pale to Ilidza, if you use this road, it's about 60

25 kilometres. So 90 to 100 kilometres, that's the distance between Grbavica

1 and Ilidza, thereabouts.

2 Q. And do you know -- there was a hospital in Ilidza. What was it

3 called?

4 A. The Zica hospital.

5 Q. Do you know when it became operational?

6 A. I know that it was not in 1992. I think that it was in 1993.

7 Q. And what happened to the wounded people, civilians or fighters, at

8 the time -- at that time, 1992/1993? What happened to these people?

9 Where did they have to go in order to get to the hospital?

10 A. In 1992, there was no hospital in Ilidza. The wounded persons,

11 regardless of whether they were civilians or soldiers, had to be taken to

12 the Pale municipality where there was a hospital at Pale, and I also said

13 what difficulties were involved. From Ilidza, a vehicle transporting the

14 wounded person would take a minimum of three or four hours, even if the

15 traffic was not blocked.

16 Q. Throughout the war, was the Zica hospital equipped for the most

17 complex intraventions that had to be performed during the time of

18 conflict?

19 A. I'm not a doctor, and I assume that I will give only a partial

20 answer to your question. Not a single hospital in Serb Sarajevo or in

21 Kasindol or in Pale, and that probably includes Zica as well, did not have

22 all the necessary instruments or equipment required of a modern hospital.

23 Q. Again, what had to be done with the seriously wounded, the

24 seriously ill?

25 A. The wounded who were hospitalised in these hospitals then had to

1 be transferred to hospitals in the Federal Republic of Yugoslavia, to

2 Belgrade, and this was done by helicopter if approved by UNPROFOR, or by

3 some other rapid means of transportation.

4 Q. If it was not approved, where did they have to go, which way, I

5 mean?

6 A. The road that I drew, to get to the Pale hospital. There was no

7 other way to go.

8 Q. Thank you.

9 MR. TAPUSKOVIC: [Interpretation] Your Honours, I am really mindful

10 of the time because I know this is part of the Defence time. However, I

11 have to keep the witness a bit longer. I will try to keep things as short

12 as possible, but I know that I am within the limits of Defence time. I

13 will do my best to cut things short, but I do ask you kindly to give me a

14 bit more time to complete my questions for this witness.

15 [Trial Chamber confers]

16 [Trial Chamber and registrar confer]

17 [Trial Chamber and legal officer confer]

18 JUDGE ROBINSON: Well, Mr. Tapuskovic, five hours had been

19 allocated, I think, based on your estimate for the totality of this

20 witness's evidence, and you have already used up about three hours and 20

21 minutes, which would leave the Prosecutor with two hours and -- no, less

22 than two hours.

23 MR. TAPUSKOVIC: [Interpretation] Your Honours, what can we do?

24 Let it even be at our own expense, but I'm compelled to do this. Your

25 Honour, for example, Mr. Docherty -- let me explain this, Your Honours,

1 please.

2 JUDGE ROBINSON: How much longer will you take?

3 MR. TAPUSKOVIC: [Interpretation] I'll hurry up. I really will.

4 I'm not aware of this. Well, you see, I got this document which was

5 wrong, and it is only now that I see this. The document is 03187 and it

6 was wrongly submitted to me, and I don't know even know what this document

7 is. I still don't have it in my hands.

8 JUDGE ROBINSON: I see. It means that we will not even be able to

9 start the other witness who was scheduled to testify today, but, proceed.

10 And after this witness, I'm going to be much, much more strict with the

11 times of both parties.

12 But I have always believed that counsel should have some leave,

13 some freedom, in examination-in-chief. It's his case, after all.

14 So proceed.

15 MR. TAPUSKOVIC: [Interpretation]

16 Q. Mr. Katic, can you tell me what the main problems were that you

17 had in your work in Grbavica, you as president of the municipality?

18 Please try to focus on the most important things, and particularly on the

19 period for which General Dragomir Milosevic was indicted.

20 A. This is how I'm going to start: In the municipality of Novo

21 Sarajevo, the population was about 25.000. Throughout the war, in

22 Grbavica, there were about 1.500 non-Serbs. The duty of the civilian

23 authorities was to see how humanitarian aid would be distributed so that

24 all the citizens would be satisfied.

25 I ordered the secretary of the Red Cross of the municipality of

1 Novo Sarajevo straight away to check out exactly how the aid was being

2 distributed. I talked about this yesterday, what the situation was like

3 in 1992, and we agreed that all the inhabitants of the municipality of

4 Novo Sarajevo should receive humanitarian aid equally, irrespective of

5 ethnicity. I even suggested that in buildings, Muslims or Croats should

6 be commissioners in charge of the distribution of this humanitarian aid.

7 I had yet another obligation; namely, that all citizens who were

8 entitled to a pension had to receive one.

9 Q. Just a moment. Judge Harhoff wanted to ask you something.

10 JUDGE HARHOFF: Thank you.

11 Witness, I just wanted to clarify who was responsible for the

12 distribution of humanitarian aid? Was that the ICRC or was it the

13 municipal authorities?

14 THE WITNESS: [Interpretation] Your Honour, the International Red

15 Cross brought in certain quantities of humanitarian aid to the area of

16 Grbavica; and then on the basis of a list made by the secretary of the Red

17 Cross, this list consisted of inhabitants of Grbavica and then exact

18 quantities of food were allocated, so that all of the citizens of the

19 municipality of Novo Sarajevo would receive the same amount of food; that

20 is to say, that we received food from international institutions, but the

21 secretary of the Red Cross of the municipality of Novo Sarajevo

22 distributed it on the basis of lists of inhabitants. That is how the food

23 was distributed. The members of the International Red Cross never

24 distributed the food themselves.

25 JUDGE HARHOFF: So who was responsible for the unequal

1 distribution of humanitarian aid, which you referred to just a while ago?

2 THE WITNESS: [Interpretation] Well, that was in 1992, when the

3 assemblymen, because the authorities did not function properly in 1992,

4 asked for a change of all the civilian authority in the municipality of

5 Novo Sarajevo. They were held responsible because they did not distribute

6 food equally, if you understand me, Your Honour.

7 JUDGE HARHOFF: Thank you. Thank you very much.

8 JUDGE MINDUA: [Interpretation] Witness, please, after this

9 question from my colleague, I have a follow-up question.

10 What was the place of the High Commissioner for Refugees, what was

11 his role in relation to the ICRC?

12 THE WITNESS: [Interpretation] I don't know.

13 JUDGE MINDUA: [Interpretation] The High Commissioner to the

14 Refugees was not represented in your municipality; is that it? Were there

15 any refugees or displaced people in your municipality?

16 THE WITNESS: [Interpretation] There were displaced persons from

17 other areas, other parts of the town of Sarajevo. I don't know who was

18 the High Commissioner for Refugees and Displaced Persons, but probably

19 they visited the office of the Red Cross from time to time and checked to

20 see what the distribution was like. I really did not have any meetings

21 with the representatives of -- I mean, the representatives who were in

22 charge of refugees.

23 JUDGE MINDUA: [Interpretation] Thank you.

24 MR. TAPUSKOVIC: [Interpretation]

25 Q. However, what was the situation like in your time, as regards

1 humanitarian aid?

2 A. I have already said that at the time, while I was president,

3 everything functioned properly as far as the distribution of humanitarian

4 aid was concerned.

5 Q. Thank you. But a few moments ago, before Judge Harhoff put his

6 question, you talked about pensions and what the situation was like in

7 that respect. I would like to show you a document.

8 MR. TAPUSKOVIC: [Interpretation] Its 65 ter number is 03180; it's

9 a Prosecution document. There's a translation, too.

10 Q. Please look at the date first, look at who issued this document,

11 and just have a look at the heading, to see what it pertains to.

12 Do you see the date? What is the date?

13 A. The 11th of April, 1993.

14 Q. What is stated in this document?

15 A. "The Republic of Bosnia-Herzegovina, Ministry of the Interior,

16 Security Services Centre, Sarajevo."

17 Q. Thank you. And what is the heading?

18 A. "Record."

19 Q. And what comes then? What is this big part all about?

20 A. "The March Barricade."

21 Q. No, no. It says, "Record," and what does it say after the big

22 paragraph, underneath "Record"?

23 A. There is a text.

24 Q. What is this text? Is this a statement, please?

25 A. Well, let me just have a look.

1 Q. But I'm asking you, what is this? Can you see what is stated in

2 big letters, the biggest letters after it stays "Record"?

3 A. "Statement."

4 Q. Thank you. Now, please pay attention to the text. You mentioned

5 pensions a while ago, and now look at the middle of the text. Please look

6 at the middle of the text, and now look at this word. It says,

7 "Familiar." Could you read that part of the text? Read it out loud,

8 please.

9 A. From the middle of the text?

10 Q. From the word "poznato."

11 A. "I know that the Muslim pensioners did not receive their pensions

12 from the beginning of the war till about a month ago when a certain Katic,

13 for whom it was being said around Grbavica that he was a good man, became

14 the president of the so-called Serb municipality of Novo Sarajevo. That

15 is when all the pensions were paid out retroactively, although they were

16 not more than symbolic amounts. This move of paying out the pensions was

17 commented upon among the Muslim residents, who remained in Grbavica, as a

18 way of establishing the exact numbers of the Muslims left in Grbavica."

19 I have to say that --

20 Q. Slowly, slowly.

21 A. I have to say that all that time the Croat pensioners were

22 receiving their pensions.

23 Q. Please go on now.

24 A. "I have not heard that any of my neighbours were killed or abused

25 in any way by the members of the aggressor's army."

1 Q. Thank you. Now look at name, name of the citizen, the lady who

2 made this statement?

3 A. Citizen Muvedeta Tanovic; maiden name, Arslanagic. You want me

4 to read all of it?

5 Q. No, no. Thank you.

6 MR. TAPUSKOVIC: [Interpretation] Could this document please be

7 admitted as a Defence exhibit.

8 JUDGE ROBINSON: We admit it.

9 THE REGISTRAR: As D201, Your Honours.

10 MR. TAPUSKOVIC: [Interpretation]

11 Q. Can you explain just very briefly what it was like with regard to

12 other matters that have to do with life in a certain environment. I don't

13 want to be leading at all.

14 A. The main thing that we bore in mind and that we dealt with in the

15 municipality, especially at Grbavica, was the functioning of public

16 utilities, whether there was electricity, water, and gas.

17 I have to tell you that I had a very good cooperation with the

18 members of G5 of the French Battalion who helped our companies in

19 eliminating waste products to the dumps.

20 Q. Please. Can we talk about the basics, the essentials. What was

21 the situation like in your area, and what was it like in other areas?

22 A. As far as gas supplies were concerned, I can say --

23 Q. Water, too; everything else as well.

24 A. All right. First, I will talk about gas and then water and then

25 electricity.

1 First of all, there no problems with gas. Throughout the

2 conflict, there was gas in Sarajevo at Grbavica and elsewhere; and if

3 there would be a leak somewhere in the pipes, then there would be a

4 meeting between the representatives of companies on -- from both sides.

5 So repairmen went out from both sides, and then they would repair what had

6 to be repaired.

7 As far as water was concerned, citizens stood in lines, like

8 elsewhere in Sarajevo, in buildings that had more than three or four

9 storeys. There wasn't any water there.

10 And as far as electricity was concerned, also together with

11 UNPROFOR, they dealt with the repairs, repairmen from both sides together

12 with UNPROFOR, so that no one would get hurt during the intervention. It

13 is only natural that when there is gun-fire, there is conflict, some

14 transmission line would get damaged, but then there would be joint

15 interventions in order to repair this.

16 As things were in Sarajevo, they were in Grbavica, too. Proof of

17 that is --

18 Q. Just a moment. What are you trying to say by it was the same in

19 Sarajevo as in Grbavica?

20 A. Concerning water, the citizens of Grbavica also stood in queues in

21 order to pour water in their jerrycans and other vessels. I watched on TV

22 that the same situation prevailed in other parts of Sarajevo.

23 Q. My question is: If there is no water in Grbavica -- no, excuse

24 me. If there was no water somewhere in the area of responsibility of the

25 BH army, what was the situation in your area?

1 A. Only with local water supplies, like in Miljevici and Petrovici,

2 water was available; but in Grbavica, there was not enough water as was

3 the case in other parts of Sarajevo. The situation was totally identical.

4 Q. Can you tell me now - you already talked something about it - your

5 contacts with military authorities, with whom did you meet most often from

6 the military authorities, and can you please give me a quick answer?

7 A. I most often met with the commander of the 1st Sarajevo Brigade

8 because it was their area of responsibility in Novo Sarajevo municipality,

9 and we exclusively discussed the issues of ensuring the best food supplies

10 for the army, how to provide firewood for the soldiers who were killed

11 because the winter was coming, and how to improve the quality of food.

12 Q. Thank you. Did you communicate with liaison officers; and if you

13 did, how did that look like?

14 A. I most often communicated with UNPROFOR liaison officers, the two

15 officers in the corps command, if I needed any assistance from UNPROFOR.

16 And we had a very good cooperation, as I said, with representatives of the

17 GP French Battalion, with Medecins Sans Frontieres, and many others who

18 were bringing aid, and we maintained all these contacts through the

19 UNPROFOR liaison officers.

20 Q. You already explained how you had contacts with General Milosevic,

21 but did he come to Grbavica; and if he came, what did you discuss with

22 him?

23 A. General Milosevic used to come to Grbavica when he wanted to

24 inspect the position. He would always, as a rule, drop by my office where

25 I was sitting as the president. We would have coffee, and we would, of

1 course, talk about the situation on the lines and what was most needed for

2 the army in terms of clothes, uniforms, oil, food, and other things.

3 I said earlier that the General took due care about how people

4 living in Grbavica could move freely and safely.

5 Q. Can you explain to the Court what these photographs depict? I'm

6 going to show to you two documents and each of them contains four

7 photographs. We managed to obtain them.

8 MR. TAPUSKOVIC: [Interpretation] It's document DD00-3335, page 21.

9 No.

10 Yes.

11 Q. All right. What is this? Does this correspond to what you were

12 just talking about? What does this represent?

13 A. In the first photograph, in the left-hand corner, you can see

14 passages constructed and they were used by citizens, civilians, and

15 soldiers, and these passages provided protection from gun-fire. You can

16 see canvass sheets on the other photograph -- on the photograph next to it

17 and blankets, which also provided passage for the people down the street.

18 They couldn't physically protect people from gunshots, but they

19 provided visual protection of the -- for the inhabitants of Grbavica. All

20 these photographs are more or less identical.

21 I explained that the area of Grbavica, and you probably could see,

22 it's in the media, was a town with so many bricks, blankets, pipes of

23 large diameter, et cetera.

24 Q. Thank you. Was that situation approximately the same before this

25 period?

1 A. Well, we started putting these up in the 1994, in order to provide

2 the protection for the people passing by, the protection for civilian, and

3 automatically the soldiers on their way to their positions.

4 MR. TAPUSKOVIC: [Interpretation] Can we please have this admitted

5 as a Defence exhibit, these photographs, because it's a part of a larger

6 document.

7 [Trial Chamber confers]

8 JUDGE ROBINSON: Mr. Tapuskovic, we assume that you only want the

9 pages admitted, the pages on the screen, because it's a huge document, I

10 understand.

11 MR. TAPUSKOVIC: [Interpretation] Yes.

12 JUDGE ROBINSON: Very well.

13 THE REGISTRAR: Your Honours, this will be admitted as D202.

14 MR. TAPUSKOVIC: [Interpretation]

15 Q. Let us just take a look at another photograph, and can you tell me

16 does that correspond to what you just said?

17 MR. TAPUSKOVIC: [Interpretation] DD00-3335, page 25.

18 Q. Just tell me whether this is consistent with what you have just

19 described.

20 A. It's completely identical, only it depicts different positions;

21 other parts of Grbavica, that is to say.

22 MR. TAPUSKOVIC: [Interpretation] Can we also have this document

23 admitted as a Defence exhibit, please.

24 [Trial Chamber confers]

25 [Trial Chamber and registrar confer]

1 JUDGE ROBINSON: Yes, this can be admitted.

2 THE REGISTRAR: As D203, Your Honours.

3 MR. TAPUSKOVIC: [Interpretation] I'd like now to move to something

4 that relates to military developments in the area of responsibility of the

5 Sarajevo-Romanija Corps and the 1st Corps of the BH army.

6 Q. Do you remember that at one point a decision was taken with regard

7 to heavy weaponry?

8 A. I remember. On the 5th of February, 1994, the Markale incident

9 took place; immediately thereafter, a contingent of the Russian Battalion

10 came to the former school of MUP in Vraca. And I think that in April or

11 May, a decision was taken to relocate heavy weaponry from the Sarajevo

12 area somewhere 20 kilometres away from Sarajevo. I remember that, and I

13 think that it was done. Actually, I don't think; I know, and I assert

14 that this was done.

15 Q. Thank you. Thank you. Did you go to the field as a

16 representative of Sarajevo municipality; and if you did, what was the

17 reason for your going?

18 A. I did, and one of the reasons was this incident. I wanted to see

19 whether the weapons were removed. I went, together with representatives

20 of UNPROFOR, to the village of Petrovici and Tvrdemici. This is all deep

21 into the territory of Novo Sarajevo municipality where heavy weapons,

22 tanks, mortars, 120-millimetre, and Howitzers were moved and covered with

23 nets, and next to these weapons were members of the army of Republika

24 Srpska and members of UNPROFOR, and they were guarding these weapons.

25 I'm talking about the area of Novo Sarajevo municipality, but I

1 also heard that in other areas the weapons were moved as well to some 20

2 kilometres away from Sarajevo.

3 Q. Tell me, do you know when General Milosevic, approximately, became

4 commander of the Sarajevo-Romanija Corps? At least, approximately.

5 A. I know it was sometime in mid-August 1994.

6 Q. Thank you. Can you please tell me very briefly, because you did

7 the job that you did, what did you know about the events involving combat

8 activities between August and the end of 1994? What did you know about

9 what was happening, generally speaking?

10 A. Well, looking at Novo Sarajevo municipality, what can I say? In

11 the area of Grbavica, or rather, in a broad area, including Lukavica,

12 there were no significant combat activities. There was intermittent fire

13 from both sides, and that would be approximately fire from infantry

14 weapons. When I was in my office, I wasn't able to hear anything else.

15 Q. Thank you. But did you know about events elsewhere, and how was

16 that happening in general terms?

17 A. Well, I knew about major conflicts in the area of Bjelasnica and

18 in the area of Nisici plateau. I knew about that because many of my

19 neighbours and other residents, including my brother, were often in those

20 areas. I can say that those were very difficult combat periods and

21 moments for the army of Republika Srpska. Many soldiers were killed or

22 wounded.

23 In some earlier statements, I said that I had talks with the

24 general about the provision of coffins.

25 Q. Can you tell me very briefly something about the events in the

1 period between the end of 1994 and May? Do you know -- well, let me not

2 push this further.

3 A. You mean 1995?

4 Q. In 1995?

5 A. Well, in the winter of 1994 and 1995, the winter was very harsh.

6 There was a lot of snow, which means that there were no major combat

7 activities in Grbavica. It was almost a truce, and I think it is very

8 important to underline that open air market was functional. There were

9 some incidents, and one of the most important incidents, at least in the

10 eyes of us as civilian authorities, as well as for the residents, took

11 place on the 11th of March, 1995, when two young girls were killed. They

12 were about 10 years of age. They were playing in the park at Soping and

13 were killed there from rifle fire.

14 Q. Thank you. Let me ask you about this particular incident. But

15 before that, I will show you document, 65 ter 03175. That's a Prosecution

16 document.

17 Let us look at it first and everywhere, and let us just look at

18 the few last paragraphs.

19 THE INTERPRETER: Interpreter's correction: The document is

20 03178.

21 MR. TAPUSKOVIC: [Interpretation]

22 Q. Could you please tell us what is this, what is the date, and could

23 you please tell us what kind of a document is it?

24 A. It's a record of a statement.

25 Q. Do you see whose statement?

1 A. Yes.

2 Q. Could you please read out the name?

3 A. Elvedin Bajrovic.

4 MR. TAPUSKOVIC: [Interpretation] Your Honours, can we please look

5 at the last page of this document. It's a fairly long document.

6 Q. Could you please look. There are some parts that are underlined

7 here. They were not underlined by the Defence, but could you please read

8 what it says here, where it starts with "I learned from Amir Tahirovic."

9 Could you read it out loud?

10 A. "I learned from Amir Tahirovic, a member of the work platoon, that

11 members of the SPF had killed a person called Zlatko in retaliation in for

12 the killing of two girls in Grbavica PZT. My neighbour, Selma, who lives

13 at Zagrebacka Number 77, told me that the soldiers of the so-called

14 Republika Srpska had killed Behko Ganic."

15 Q. Well, you were the president of the municipality. This woman here

16 says that had heard about that from someone. Did you hear about anything

17 like that? Do you know anything about what is written here?

18 A. No. I didn't hear about this, and I didn't know anything about

19 that.

20 Q. And since you were the president of the municipality, would it be

21 possible for two murders to occur without you being aware of them?

22 A. That would be impossible because, as the president, I had a

23 briefing every morning with MUP chief in eastern Novo Sarajevo

24 municipality, and he would have reported this to me. I don't know

25 anything about this case, and I was not informed about it.

1 Q. Could you please look at the previous page, the last paragraph.

2 MR. TAPUSKOVIC: [Interpretation] If we can move back, one page

3 back. So this is the previous paragraph. I think that in English, it's

4 fine. Okay. There it is.

5 Q. Could you please read what this women says in her statement, the

6 last paragraph on this page?

7 A. "On the 26th of April, 1995, we received an invitation which said

8 that we should report to Sojic and fill out requests, which we did. We

9 prepared two suitcases and two bags of clothes and crossed into the city

10 on the 27th of April, 1995, taking up temporary residence at our Uncle

11 Osman's place."

12 Q. Thank you. And did this thing that this woman stated in her

13 statement happen to other people, too, that they were allowed to go

14 wherever they pleased?

15 A. Yes. This functioned, and people crossed the Brotherhood and

16 Unity bridge from one side to the other.

17 Q. Thank you.

18 MR. TAPUSKOVIC: [Interpretation] Could we please have this

19 document admitted into evidence as a Defence exhibit.

20 JUDGE ROBINSON: Yes, we admit it.

21 THE REGISTRAR: As D204, Your Honours.

22 MR. TAPUSKOVIC: [Interpretation]

23 Q. Could you please tell me now, so this bridge was made and it is

24 possible to cross it, under whose control was it?

25 A. Well, it was primarily under UNPROFOR control. As we say, they

1 were the chief Pope.

2 Q. Could you please tell me, if somebody wanted to cross to some

3 other place at Grbavica, what would happen?

4 A. Well, if anybody attempted to cross at any other place, that

5 person would be shot at and could be killed or wounded.

6 Q. Which side would fire at such a person?

7 A. Well, the BH army side.

8 Q. Did the Serb side of open fire at civilian who is attempted to do

9 something like that?

10 A. No.

11 MR. TAPUSKOVIC: [Interpretation] Your Honours, I would like

12 Defence Exhibit DD00-3211 to be shown to the witness. I had only one

13 short portion of this document translated by the translator that I hired,

14 and I would like the witness, once this document is up on the screen, to

15 explain what it says in the heading and the underlined portions of it.

16 And the Defence did not underline this. This was the original of the

17 document, in the original.

18 Q. So could you please look up. It's not typed out. It's

19 actually -- it is handwritten. Could you please see who actually issued

20 this document, and what is it, in fact?

21 A. "Army of the Republic of Bosnia-Herzegovina, the command of 101st

22 Brigade, 7th of April, 1995, daily combat report."

23 Q. Could you please read this part in the middle that is underlined.

24 Please make an effort, you have to read it.

25 A. "Last night at around 1930 hours, our fighters at Loris, mortally

1 wounded an elderly person, a woman, who wanted to cross to the other side.

2 She was pulled out to our side with UNPROFOR assistance. The identity of

3 this person is not known."

4 Q. Yes.

5 A. "We didn't have," something or other.

6 Q. And the last part that is also underlined, "UNPROFOR activities"?

7 A. "UNPROFOR activities, apart from the activities related to the

8 pulling out of the dead -- the person who was killed in the Loris area,

9 there were no other activities."

10 Q. Thank you. So does this document clearly show what happened to

11 this woman in the end?

12 A. Well, the poor woman tried to cross not using the bridge from

13 Sarajevo to the Serbian Novo Sarajevo side and she was killed.

14 Q. And could you please tell us what is Loris?

15 A. Loris is a building where the BH army soldiers were deployed.

16 Q. Thank you very much.

17 MR. TAPUSKOVIC: [Interpretation] I would like to have this

18 document admitted as a Defence exhibit.

19 JUDGE ROBINSON: Yes.

20 THE REGISTRAR: As D205, Your Honours.

21 MR. TAPUSKOVIC: [Interpretation] Your Honours, perhaps that would

22 be a convenient time for a break?

23 JUDGE ROBINSON: Yes. We will take it normally at 20 past, but we

24 can take it now. It's just two minutes away.

25 We'll adjourn.

1 --- Recess taken at 12.17 p.m.

2 --- On resuming at 12.42 p.m.

3 JUDGE ROBINSON: Mr. Tapuskovic.

4 MR. TAPUSKOVIC: [Interpretation].

5 Q. Mr. Katic, I would like to us be as concise as possible. I have

6 now come to the end.

7 Regarding this incident with the two girls, what happened

8 afterward. This was in March. So what happened until May? What was

9 going on at the separation lines?

10 A. Well, as for the conflicts and things like that, in the period

11 between March and May, there were no major clashes at Grbavica, just some

12 sporadic rifle fire from the two sides, but no major clashes.

13 Q. And what started to happen in May, and when did this reach this

14 level of a larger scale conflict?

15 A. In May, the weapons from, in particular, the BH army side, became

16 more intense, and we all felt it. We all heard it. We heard the fire.

17 And in May, again, there were mostly rifles, no major shelling. But from

18 day to day, we felt that the fire, more intense fire was opened on the

19 positions of the Republika Srpska army, and I can say that this

20 intensified even further in June with constant attacks on all the lines in

21 the Grbavica territory and, in fact, in the broader region, which was in

22 the area of responsibility of the 1st Sarajevo Brigade; in other words, on

23 the entire side of the Novo Sarajevo municipality.

24 Looking from the -- from my post, some larger calibre shells

25 started hitting Grbavica. I was not able to determine whether this is

1 cannon ammunition, shells, bombs. I couldn't determine the calibre, but

2 it was constant, and this fire intensified day after day.

3 Q. And when did it culminate in June?

4 A. I don't know the exact date, but I think it was on the 20th of

5 June. This was the culmination of the conflict between the

6 Bosnia-Herzegovina army and Republika Srpska army.

7 Q. I will show you two documents, and then I would like to ask you to

8 look if they correspond to what was happening in the area that you were

9 quite familiar with. So this is document DD00-3315.

10 MR. TAPUSKOVIC: [Interpretation] Your Honours, this document does

11 not have a translation, just partially translated, but I would just like

12 to ask the witness if he remembers on what axis were those combat

13 activities most intense.

14 JUDGE HARHOFF: What is it that you are showing to the witness?

15 MR. TAPUSKOVIC: [Interpretation] I've given up on this document.

16 I'm not going to be using it, but I will show the witness another

17 document. I wanted to show him a document that would indicate what was

18 happening in those very first days when this offensive, the biggest

19 offensive, was actually launched.

20 Q. So, Witness, could you tell us, what was happening in those days?

21 A. Well, I can tell you that a large-scale offensive was launched by

22 the BH army on all positions in the area of responsibility of the 1st

23 Sarajevo Brigade in the territory of Novo Sarajevo municipality. And,

24 actually, the lines in Djukica Potok were broken through from the

25 direction of Osrenska and the Mojmilo hill. Four our five of our soldiers

1 were killed there and several were wounded.

2 The second breakthrough was above Zlatiste at the famous Andja's

3 house that I mentioned in my previous evidence, and four soldiers of the

4 army of the Republika Srpska army were killed there.

5 Q. To cut a long story short, in this offensive and in all those

6 conflicts, as far as you knew, did you have any information as to the

7 number of civilians and soldiers who were killed at Grbavica, if you can

8 give us this figure?

9 A. Six to eight soldiers were killed in the 1st Sarajevo Brigade --

10 THE INTERPRETER: Interpreter's note: Could the witness please

11 repeat his answer.

12 JUDGE ROBINSON: Witness, the interpreter is asking to you repeat

13 the answer you just gave.

14 THE WITNESS: [Interpretation] In the Novo Sarajevo municipality

15 area, in the 1st Sarajevo Brigade, because this was its area of

16 responsibility, 608 soldiers were killed, around 460 of them were locals

17 from the municipality; and around 650 civilians.

18 I think that we are the municipality in Republika Srpska that

19 suffered the worst casualties in relation to the overall number of people

20 living there.

21 MR. TAPUSKOVIC: [Interpretation]

22 Q. If we were in a position to document that, are there appropriate

23 documents for each and every one of these deaths?

24 A. As for all people who lost their lives in Grbavica, or rather, the

25 municipality of Novo Sarajevo, there are appropriate documents. And this

1 refers to the period from 1992 until the end of the war, and it also

2 pertains to all burials.

3 Q. Now that you mention burials, could you tell me under what

4 conditions people were buried, regardless of their faith or ethnicity, in

5 the area of Grbavica.

6 JUDGE ROBINSON: What would be the relevance of that?

7 MR. TAPUSKOVIC: [Interpretation] Well, Your Honours, during the

8 day -- well, the I beg your pardon. At some points in time, it was

9 impossible to have burials because there would be intensified fighting,

10 and then people got killed again.

11 JUDGE ROBINSON: Marginal, but go ahead.

12 THE INTERPRETER: Microphone for the Judge, please.

13 JUDGE MINDUA: [Interpretation] Mr. Tapuskovic, could you ask the

14 witness this, because we're dealing with figures. Here we have a figure

15 of 608 soldiers who were killed and 650 civilians, but are we talking

16 about soldiers of Serbian army or are they soldiers from all parties or

17 armies?

18 MR. TAPUSKOVIC: [Interpretation]

19 Q. Mr. Katic, you heard -- you've heard the question of His Honour

20 Judge Mindua. Can you answer?

21 A. Yes. 608 soldiers of the army of Republika Srpska from the 1st

22 Sarajevo Brigade, and there are accurate figures on that.

23 JUDGE MINDUA: [Interpretation] So you are providing us with some

24 figures, and this is compared to figures from the opposite side, from the

25 ABiH, is it, or did you do this for another reason? I'm seeking to

1 understand the relevance as well, the relevance of the figures.

2 MR. TAPUSKOVIC: [Interpretation] I have already spoken about that

3 several times, and I will say again this was the period of time when there

4 was the largest number of casualties. These were combat activities,

5 especially in Grbavica. But also in all other cases, at the time relevant

6 to the indictment, there were responses to these combat activities when

7 absolutely necessary. The only reason why there was occasional firing,

8 especially in this case, was extreme military necessity; and then in such

9 a clash there would be civilian victims, too, and soldiers were among the

10 casualties as well, especially in this situation.

11 I do not want to go into other things included in the indictment,

12 such as deliberate targeting in order to kill someone. I should speak

13 about that only when I analyse each and every individual case, and when we

14 look at this period of time to see whether there were cases when civilians

15 were the only target.

16 That is one of the matters that the indictment deals with, in

17 addition to the questions as to who was on the hills, who was firing from

18 the hills. And in relation to that, have I one more question for the

19 witness.

20 The last document that have I to show him, I'd like him to tell me

21 what it says to him.

22 [Trial Chamber confers]

23 JUDGE MINDUA: [Interpretation] Thank you very much. Please

24 proceed.

25 MR. TAPUSKOVIC: [Interpretation]

1 Q. Mr. Katic, would you please look at this document, DD00-3448.

2 It was translated in part. Could you please explain what the

3 letterhead says?

4 MR. TAPUSKOVIC: [Interpretation] Your Honours, I don't know how

5 come there is no translation. I have the translation, but would it be

6 possible for the witness just to read paragraph 2, because there is a

7 combat report of the command of the 12th Division. I have the

8 translation. I certainly do, but I don't know what happened now. Could

9 at least be marked for identification?

10 JUDGE ROBINSON: Let him jest read paragraph 2. It's very short.

11 No. You have to read it aloud so we can have the translation.

12 THE WITNESS: [Interpretation] "On all directions, reconnaissance

13 and preparation of unit is taking place for the following combat days.

14 82-millimetre mortars were being fired from in order to carry out jamming

15 and conduct works in the area of Osmice with six mortar shells. From

16 Patmica [phoen] at Mojmilo, a Chetnik truck was hit at the road between

17 Vraca and Lukavica, which remained on the road. After the truck was hit,

18 the PAM crew continued firing at the truck."

19 MR. TAPUSKOVIC: [Interpretation]

20 Q. Thank you. I think that will do. Now I can put my question.

21 At this point in time, in June, was this characteristic of what

22 was going on? From Mojmilo, as it says here, where was most of the firing

23 coming from? Actually, it was coming from Mojmilo, but they were firing

24 at what?

25 A. Well, it is obvious from this report that from the hill of

1 Mojmilo, it was the road that was targeted all the time between Vraca and

2 Lukavica, Bijelo Polje, and that was the main road for civilians and

3 soldiers, and ambulances, too, when they transported the seriously

4 wounded, or women in labour, all the way to the hospital in Kasindol.

5 Q. Thank you.

6 MR. TAPUSKOVIC: [Interpretation] Could this document please be

7 marked for identification as a Defence exhibit, but for identification,

8 until it is translated.

9 JUDGE ROBINSON: Yes.

10 JUDGE HARHOFF: But, Mr. Tapuskovic, could you do us the favour

11 when you bring documents to us that have not been translated to identify

12 the provenance of the document. I assume this is an ABiH combat report.

13 MR. TAPUSKOVIC: [Interpretation] Yes.

14 JUDGE HARHOFF: But it would be helpful if you would assist us so

15 that we don't have to guess. Thank you.

16 THE REGISTRAR: Your Honours, this will be marked for

17 identification as D206.

18 MR. TAPUSKOVIC: [Interpretation]

19 Q. Mr. Witness, I wanted to deal with this. What does the letterhead

20 say? Who is the author of this document? What is this? What does this

21 represent? What is the date?

22 A. "Command of the 12th Division, strictly confidential, number

23 02/2-2-114, Sarajevo, the 20th of June, 1995."

24 Q. Thank you. And this paragraph that explains all of this,

25 paragraph 2, what is its heading?

1 A. "Information about our forces."

2 Q. Yes. Thank you. Can you tell me one more thing. What did this

3 look like until the NATO strikes began?

4 JUDGE HARHOFF: That's fine. Please go on.

5 MR. TAPUSKOVIC: [Interpretation]

6 Q. July, August, what happened in June and July in particular,

7 actually.

8 A. Major combat activities continued at all positions, all positions

9 of the army of Republika Srpska, that is, at Grbavica. Practically

10 everything was on fire. You did not know where all the shells were coming

11 from, where all the gunshots were coming from, and all the explosive

12 devices, different ones. Quite simply, you couldn't get out into the

13 street.

14 At that time, I think it was in June, the Supreme Command declared

15 a state of war in the area of responsibility of the Sarajevo-Romanija

16 Corps.

17 Q. Thank you. Please, at this point, were you in these headquarters?

18 What did you do about this when this was declared?

19 A. As soon as the state of war was declared, the assemblies of

20 municipalities stopped operating; and in accordance with an order of the

21 President of the state, war commissioners offices for municipalities were

22 set up.

23 Q. Thank you. Thank you. You said, when you first started

24 testifying, you talked about an imminent threat of war and then this staff

25 was established. Was that the first declaration of a state of war, during

1 the course of the entire war?

2 A. Yes. In the territory of Republika Srpska, never was a state of

3 war declared; and now, in June, it was only declared in part and only in

4 the area of responsibility of the Sarajevo-Romanija Corps.

5 Q. Can you please tell the Trial Chamber when the NATO airstrikes

6 started?

7 A. I can. This was caused by an incident, if I can put it this way.

8 Markale 2 happened on the 28th of August, 1995; and immediately on the

9 31st of August, the NATO bombing started and the rapid deployment force

10 hit the Slavisa Vajner "Cica" and Slobodan Princip "Seljo" Barracks at

11 Lukavica. Those were the names of the barracks.

12 Q. What about Grbavica?

13 A. NATO airstrikes? No, none at Grbavica.

14 Q. What about strikes coming from someone else?

15 A. Only from the army of Bosnia-Herzegovina.

16 Q. What could be done at that point in time by the army of Republika

17 Srpska, at all?

18 A. Probably they had to take all the weapons from 1994 that was

19 stored on the basis of agreement and decision at certain sites.

20 Q. Thank you. Do you know at all what was going on? Very soon

21 weren't all these weapons actually handed over to NATO, or do you not know

22 about this?

23 A. I don't know.

24 Q. Just one more question. Were there any civilian casualties due to

25 the NATO airstrikes?

1 MR. DOCHERTY: I object to that on the ground of relevancy.

2 JUDGE ROBINSON: Well, explain the relevance, Mr. Tapuskovic.

3 MR. TAPUSKOVIC: [Interpretation] Well, in the entire indictment,

4 there is constant insistence, and I would like to point that out. There

5 is constant insistence on the Serb forces being on the hills, and that

6 their only target was - and that they did not have any other target as the

7 indictment says - but to target civilians, and that was the only thing

8 that the army of Republika Srpska did.

9 If you think that this is not relative, whether these bombs under

10 these conditions killed some civilians, too, then I really think that I

11 don't have to explain anything.

12 Q. I'm interested in the following: In these circumstances - let us

13 disregard this question whether there were any civilian casualties - under

14 these circumstances, do you know what at all what the army of Republika

15 Srpska did?

16 JUDGE ROBINSON: No. No, Mr. Tapuskovic. Don't let me get mad. I

17 have asked you to explain the relevance. I have to rule on it. It's

18 absolutely out of order for to you direct a question to the witness before

19 the Chamber has ruled.

20 I'm going to consider the submission that you have made.

21 [Trial Chamber confers]

22 JUDGE ROBINSON: I understand the submission that you have made to

23 be the following: The Prosecution's case is that the army of the

24 Republika Srpska targeted civilians, but you're saying civilians might

25 also have been killed by NATO airstrikes. In that regard, and for that

1 reason, the Chamber considers the question to be relevant, but you might

2 want to direct the witness to an identification of the civilians who might

3 have been killed by NATO airstrikes, so as to relate those incidents to

4 the indictment, more particularly to the indictment.

5 Do you understand the ruling that I have made?

6 MR. TAPUSKOVIC: [Interpretation] Yes, I do, Your Honours, very

7 much so. I'm not trying to find excuses for me. You have given me a

8 valid -- valid reasons, but one cannot immediately respond to everything.

9 My idea was that under such circumstances, collateral damage was

10 unavoidable caused by any kind of bombs. This was my idea in that

11 context. It wasn't my intention to claim that any fighting was directed

12 purposefully; but that under such circumstances in a clash that could not

13 have been avoided, resulted in collateral damage, including the one that

14 we were just discussing.

15 However, your ruling, it seems to me, is in that spirit. I didn't

16 claim anything else, apart from the fact that collateral damage, under

17 such circumstances, was unavoidable and that the killing of civilians was

18 unavoidable in any clash and that it can be justified.

19 This is what I wanted to say, and this is the position of my team.

20 What you said is also appropriate. I may ask the witness whether he has

21 information about civilian deaths and whether they can be identified.

22 JUDGE ROBINSON: Yes, go ahead.

23 THE WITNESS: [Interpretation] In the area of Novo Sarajevo, during

24 the bombing, the NATO bombing of the Slavisa Vajner "Cica" and Slobodan

25 Princip "Seljo" barracks, not a single civilian was killed, or a soldier,

1 for that matter, in Lukavica, as a result of the bombing. But I did hear

2 that there were people who were killed in Vogosca and in the area of

3 Jahorina. I only heard about that, and I don't know whether those were

4 civilians or soldiers.

5 MR. TAPUSKOVIC: [Interpretation]

6 Q. Thank you, Mr. Katic.

7 MR. TAPUSKOVIC: [Interpretation] With this I have concluded my

8 examination.

9 Your Honours, one procedural matter. During the

10 examination-in-chief, I was informed by my learned friend, the Prosecutor,

11 that a document was erroneously disclosed to us which is on their list of

12 exhibits, and that it has to be replaced with another document.

13 In principle, as you know, we have to raise an objection to this.

14 First of all, I didn't have an opportunity to see this, although the

15 accused, Dragomir Milosevic, is never mentioned there, but I don't think

16 this is permissible for me to learn about the existence of a document in

17 the course of examination-in-chief. And for that reason, I cannot examine

18 the witness with regard to that document because I didn't have a chance to

19 analyse it.

20 JUDGE ROBINSON: Mr. Docherty, do you know what this is all about.

21 MR. DOCHERTY: I do, Your Honour, and it is unfortunate.

22 We released the usual spreadsheet of documents we are go to use in

23 cross-examination when the witness began his direct examination, as -- as

24 protocol requires. This morning I was double-checking those documents and

25 I realised that one of the documents, Minutes of a Crisis Staff meeting

1 were, indeed Minutes of a Crisis Staff meeting, but from the wrong date.

2 I wanted those of a different date. I disclosed the ones of a different

3 date to the Defence at the first break today, apologised for the mistake,

4 asked them if they would object on the grounds of late disclosure,

5 retaining all other possible objections such as relevance and so on, and

6 they said that they indeed would.

7 And I told them that at an appropriate point in the

8 cross-examination, I might, nevertheless, seek to use the document, but

9 would, of course, tell the Chamber what had happened and would tell the

10 Chamber also that the Defence objected on the grounds of late notice.

11 I can tell the Chamber that, in light of the hour, I will not be

12 seeking to use this document today. So there will be the weekend. I also

13 will not object if Mr. Tapuskovic, on Monday morning, wants to reopen his

14 direct examination for the purposes of examining the witness with regard

15 to that one document. I hope that that solves the problem, which was my

16 fault, and I apologise for that.

17 JUDGE ROBINSON: Yes. Well, in all these matters, the essential

18 question is one of proper notice and whether the other party is prejudiced

19 by the lateness; and for the reasons that the Prosecutor has outlined, and

20 if we were to follow the procedure he has suggested, there will no

21 prejudice to Mr. Tapuskovic, to the accused. He will not reach the

22 document today so that you will have, Mr. Tapuskovic, and the accused, the

23 weekend to review it. So no question of prejudice will arise; and if you

24 wish to examine on it, then you will be allowed, either by way of

25 re-examination or by some other procedure.

1 Please begin, Mr. Docherty.

2 Yes, Mr. Tapuskovic.

3 MR. TAPUSKOVIC: [Interpretation] I didn't understand. I could try

4 and handle this in some manner in order not to get back to this. Give me

5 just a moment to consult with my colleague.

6 I didn't understand what you said, but I do agree with what you

7 said.

8 JUDGE ROBINSON: Well, I think the better course for you really is

9 not to attempt to deal with it now, but take the weekend and look at the

10 document, and on Monday, you come back to us and say whether you wish to

11 re-examine on it on whether you wish to reopen your examination-in-chief.

12 MR. TAPUSKOVIC: [Interpretation] Well, that's it. It's all right.

13 Thank you.

14 JUDGE ROBINSON: Mr. Docherty.

15 Cross-examination by Mr. Docherty:

16 Q. Good afternoon, Mr. Katic.

17 I know that you have met with other members of the Prosecution

18 staff, but you and I have not met before; is that correct?

19 A. No.

20 Q. I do have a number of questions for you. If any of my questions

21 are not clear, I'd ask you to please ask me to clear it up, rather than

22 guessing at what I might have meant and trying and answering. Would that

23 be all right?

24 A. Yes.

25 Q. You've testified about several different topics during your direct

1 examination, and you mentioned at one point, you testified at one point,

2 that from the 13th of March, 1993 forwards, your duties were exclusively

3 civilian; is that correct?

4 A. Yes, it is.

5 Q. When you were in the army, in the -- serving as a soldier in the

6 Sarajevo-Romanija Corps, what rank did you have?

7 A. I didn't have a rank. I was a private.

8 Q. And you were, during the time of the indictment period, you were

9 not involved in any way in the day-to-day running of the Sarajevo-Romanija

10 Corps, were you?

11 A. Yes, that's true.

12 Q. And you, therefore, would not know what orders, if any, were given

13 by the accused, General Milosevic, to snipers, would you?

14 A. I cannot know. I couldn't know whether the General gave orders

15 relating to the sniper. I have no information about that.

16 Q. And the same would hold true for artillery and mortar units; is

17 that correct?

18 A. That's correct.

19 Q. You did, at one point, get appointed as what is called a war

20 deputy, did you not? And we saw a document concerning that during your

21 direct examination.

22 A. I was a war commissioner in Novo Sarajevo municipality. That was

23 the title.

24 Q. That was the title, and I believe that you said when you met with

25 members of the Prosecutor's staff, back there 2004, that you never

1 attended any meetings in your capacity as a war commissioner and, indeed,

2 never really did anything as a war commissioner, nor were you ever asked

3 to do anything as a war commissioner. Is that a fair summation, sir?

4 A. Yes, it is. I said that the appointed war commission for Novo

5 Sarajevo municipality never met again in that composition. That's what I

6 said in 2004 as well. That's what I told the investigators.

7 Q. And so even though the title is "war commissioner," the fact that

8 you served as a war commissioner for a period of time, we should not read

9 into that any particular military expertise on your part?

10 A. That's correct.

11 Q. You did as a civilian leader, president of a municipal assembly,

12 have meetings, however, with -- at which military officers were sometimes

13 in attendance; did you not?

14 A. Yes. When the assembly session was convened, someone would

15 describe the situation on behalf of the brigade, among the soldiers, in

16 the brigade itself, and to tell us whether there were any problems in that

17 domain.

18 Q. All right. And when you say that the assembly met, those are the

19 meetings in Vogosca that you were testifying about an hour or so ago and

20 describing your route all the way around the city. Are those the meetings

21 that you are referring to, sir?

22 A. No. I was referring to regular sessions of the municipal assembly

23 of Novo Sarajevo, where only the military situation in the area of

24 Grbavica was discussed, or rather, in Novo Sarajevo municipality. Those

25 were regular monthly assembly meetings.

1 Q. Thank you. I appreciate the clarification. And from time to

2 time, in the course of performing your civilian duties, you did encounter

3 General Dragomir Milosevic; is that correct?

4 A. Yes, it is.

5 Q. He came to Sarajevo or to Grbavica from time to time. I believe

6 you said that in your statement to the Office of the Prosecutor in 2004?

7 A. Yes, he came. Mr. Milosevic used to come to Grbavica; But I

8 think that in 2004, I wasn't asked about General Milosevic, if I remember

9 correctly.

10 Q. And when General Milosevic would come to Grbavica, as far as you

11 could tell, he was there to meet with commanders of subordinate units,

12 brigade commanders and battalion commanders; is that correct, sir?

13 A. Yes. When the general would come to Grbavica, he would meet the

14 battalion commander whose area of responsibility covered Grbavica.

15 Q. And so did it seem to you that General Milosevic was taking steps

16 to keep himself informed fully of what was going on militarily in

17 Grbavica, by meeting with battalion commanders on a regular or perhaps

18 semi-regular basis?

19 A. Yes. He wanted to know what the situation was on the lines,

20 whether the strength and the disposition of soldiers was okay, what was

21 the morale like among the soldiers, whether they lacked anything. So this

22 was what the general and his subordinate officers talked about; and when

23 he came to see me, we talked only about the problems of humanitarian

24 nature, the protection of the population in Grbavica.

25 Q. I know it's been a while, but about how often during 1994 and 1995

1 or how often when he was commander of the corps did General Milosevic come

2 to Grbavica?

3 A. Perhaps once a month. Perhaps even less than that, if -- if

4 you're referring to his meetings with me.

5 Q. Yes. The meetings we've been talking about up until now, when the

6 general would come and meet with his commanders and then would meet with

7 you, are you saying that happened about once a month or maybe a little

8 less?

9 A. Well, the general would meet me, only me, without his subordinate

10 officers, once a month or even less often than that. And I don't know how

11 many times a month the general would meet his subordinate officers. I

12 have no knowledge of that.

13 Q. And also, from your time in the Sarajevo-Romanija Corps - granted

14 as a private soldier - you understood that the corps had radios and field

15 telephones and other methods by which they could keep in -- by which units

16 of the corps could keep in touch with each other and could keep in touch

17 with headquarters at the barracks in Lukavica. Is that correct?

18 A. Yes. Those were the field telephones. They had those traps, and

19 then there would be a wire you would stretch a wire, at least that was in

20 that area where I served as a soldier, and then they were linked with the

21 command of their unit. We did not have any communications of that sort

22 with the Lukavica Barracks, so the line went only to those units, not to

23 the Lukavica Barracks.

24 Q. And so your understanding was the field telephone line went to the

25 next unit and then that went up to the and the next unit next, and

1 eventually somebody is talking to Lukavica Barracks. It's not you, but

2 somebody is?

3 A. Probably that's how it was. In accordance with establishment,

4 somebody had to be in communication with the Lukavica Barracks.

5 Q. And this that is what is known in an army as a chain of command,

6 is that right, Mr. Katic, in which a senior commander gives order to a

7 junior commander and so on and so on down the line, until it reaches the

8 soldiers on the front line.

9 A. Yes.

10 MR. DOCHERTY: Could we see again please Exhibit P 496, the order

11 from General Mladic.

12 Q. Now, Mr. Katic, you were asked some questions about this document

13 on your direct examination, and I just have a few more.

14 First of all, in the first line, that is the document itself and

15 not addresses and so on, I'll reed it out in English. "I have an

16 information that on 5 November 1994, a meeting took place between local

17 Serb leaders of Serbian Sarajevo in Vogosca."

18 Do you see the part that I'm referring to?

19 A. Yes.

20 Q. And Vogosca is the place that you described in your direct

21 examination as the 90-kilometre drive on bad roads to get to where the

22 leadership of all of Serb Sarajevo, and not just Grbavica, would meet; is

23 that correct?

24 A. I said from Grbavica to Ilidza, it's 90 kilometres, and it's maybe

25 15 or 20 kilometres less to Vogosca. So from Lukavica to Vogosca, it's

1 about 70 kilometres.

2 Q. All right. But regardless of the distance, Vogosca is the place

3 where the leadership of all of Serb Sarajevo met from time to time. Am I

4 correct about that?

5 A. Yes.

6 Q. And just as with the meetings that you had in Grbavica, where

7 military officers would attend from time to time as -- if their input was

8 needed, so military officers would attend meetings in Vogosca, if it was

9 relevant for them to be there, if there was something to be discussed that

10 their input was needed on; is that right?

11 A. When the civilian authorities meet, then only the presidents of

12 municipalities, presidents of the Executive Boards, and the appointed

13 president or the mayor of the city of Serbian Sarajevo, and the president

14 of the Executive Board of the city of Serbian Sarajevo would meet. So

15 only the civilian structures, the civilian authority would meet. But if

16 there is an assembly attended by the deputies from all of the

17 municipalities in Serbian Sarajevo, then those sessions would be attended

18 by representatives of the military authorities who would be invited to do

19 so, so only to the sessions of the assembly of Serbian Sarajevo. Just as

20 I said, when the municipal assembly of Novo Sarajevo would meet, then we

21 would invite the commander of the area of responsibility, that included

22 that municipality to attend.

23 Q. Now I want to take a look at what General Mladic's order actually

24 says, and I'm going to read under order number 1: "I forbid undertaking

25 any activities in connection to the blockade of UNPROFOR and confiscation

1 of heavy weaponry under its supervision without my explicit order and

2 consent."

3 Do you see where I have been reading?

4 A. Yes.

5 Q. And that doesn't say that UNPROFOR is not to be blockaded, and it

6 doesn't say that heavy weaponry is not to be confiscated. It just says it

7 is not to be done unless Ratko Mladic says so. Correct?

8 A. Could you please repeat your question.

9 Q. I'd be happy to.

10 My question is about the meaning of subparagraph 1 under "Order,"

11 and I'll ask you just to read it yourself, and my question is: That

12 doesn't really say that confiscating heavy weaponry is forbidden, and it

13 doesn't really say that blockading UNPROFOR is forbidden. What it says it

14 that it is not to be done unless General Ratko Mladic says it is to be

15 done.

16 JUDGE ROBINSON: Mr. Tapuskovic.

17 MR. TAPUSKOVIC: [Interpretation] Your Honours, can this witness be

18 asked to interpreter an order, to interpret an order that is quite

19 explicit? Somebody else should be asked to do so, in particular, the

20 person who actually drafted. But to ask this witness to speculate what

21 the person who ordered it actually meant, this is not permissible. Only

22 Mladic could answer this question.

23 JUDGE ROBINSON: No, I don't agree. It's simply a question of

24 saying whether he agrees with the meaning of the words attributed to them

25 by the Prosecutor. There's no speculation there. It may be a question of

1 language, Mr. Docherty, and maybe it's difficult for the witness to

2 understand the question that you have put.

3 MR. TAPUSKOVIC: [Interpretation] The key word is, "I prohibit."

4 In our language, that means that's the key -- that that Serbian word is

5 the key word. That's the key word, in the first paragraph.

6 JUDGE ROBINSON: I see that that is the key word, but the

7 Prosecutor is asking the witness whether he agrees that the prohibition is

8 not an absolute one. It is simply that these things identified as being

9 prohibited are not to be done without the order and consent of Ratko

10 Mladic.

11 Do you understand the question which was put to you by the

12 Prosecutor?

13 THE WITNESS: [Interpretation] Your Honour, I understand the

14 question and the way the order is phrased. The best thing would be to

15 have the words "I prohibit," anything to be done right at the beginning.

16 In my opinion, this is a very convoluted way of putting things, so that I

17 really couldn't answer this question that Mr. Prosecutor has asked me.

18 JUDGE ROBINSON: Well, I don't know whether Mr. Mladic would be

19 happy to hear your criticism of his language.

20 Mr. Docherty, we are at the time now for the break, and I have an

21 administrative decision to give.

22 I give a decision as to how the Chamber will organise its work on

23 Fridays. On Friday, the 15th of June, there will be no hearing; Friday,

24 the 22nd of June, we will sit from 9.00 a.m. to 5.00 p.m.; Friday, 29th of

25 June, no hearing; Monday, the 2nd of July, no hearing; Friday, the 6th of

1 July, we'll sit from 9.00 to 1.45; Friday, 13th of July, from 9.00 to

2 5.00; Friday, the 20th of July, no hearing; and Friday, the 27th of July,

3 no hearing.

4 This order will be filed with the registrar today.

5 We're adjourned.

6 --- Whereupon the hearing adjourned at 1.47 p.m.,

7 to be reconvened on Monday, the 4th day of June,

8 2007, at 9.00 a.m.

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