Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4255

 1                           Tuesday, 29 June 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 2.16 p.m.

 6             JUDGE KWON:  Good afternoon, everybody.

 7             If you're ready, please continue, Mr. Karadzic.

 8                           WITNESS:  KDZ-185 [Resumed]

 9                           [Witness answered through interpreter]

10             THE ACCUSED: [Interpretation] Good afternoon to everyone.

11                           Cross-examination by Mr. Karadzic: [Continued]

12        Q.   [Interpretation] Witness, sir, at one point, in fact several

13     times, you say that the Muslim side did not have 122- and 150-millimetre

14     artillery; is that so?

15        A.   That is correct.  I said that we had not seen any of those within

16     the city of Sarajevo.

17             THE ACCUSED: [Interpretation] Thank you.

18             May we call up 1D1542 in e-court.  [No interpretation]

19             We'll deal with it briefly.  This is a report from the

20     Sarajevo Romanija Corps Command, dated 31 May.  A cease-fire is in force,

21     and in line 5, if we can scroll down, it says, I'll read it out:

22             "At 10.15, from the direction of Mount Igman, the enemy fired a

23     155-millimetre shell at the sector of Krivoglavaca," et cetera,

24     et cetera.

25             Can we see the next page, please.

Page 4256

 1             Item 6:

 2             "Logistical support from the rear command post --"

 3             JUDGE KWON:  Just a second.  Have you found the English

 4     translation?  Hopefully.

 5             MS. EDGERTON:  Yes, I have, Your Honour.

 6             JUDGE KWON:  Which is ...?  You have a translation photocopied.

 7     Shall we put it on the ELMO?

 8             We have that noise again, Mr. Witness?

 9             THE WITNESS: [Interpretation] It is starting again, indeed.

10             THE ACCUSED: [Interpretation] While we are waiting, let me tell

11     you that the Defence and the Prosecution are engaged in talks to get a

12     full list of all documents, and I believe this will shorten the waiting

13     time in the future.

14             JUDGE KWON:  I appreciate it very much.

15             Very well.  This is the, yes, translation.  What page should

16     we --

17             THE ACCUSED: [Interpretation] If we can see the whole first page.

18     Item 1, we see the cease-fire was violated.  First of all, we need to see

19     the top of the page.  Display the whole page.

20             [In English] Can you lift it a little bit?

21             [Interpretation] Then it must be the second page in English.

22             THE WITNESS: [Interpretation] Your Honour, I can't hear a thing.

23             JUDGE KWON:  Mr. Witness, now are you hearing something?

24             THE WITNESS: [Interpretation] Yes, I do now.

25             JUDGE KWON:  Thank you very much.

Page 4257

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Please look at the paragraph that begins with:  "At 1015 ..."

 3     Does it say about where the shell was fired from and the calibre?  Is it

 4     155?

 5        A.   Is that a question?

 6        Q.   The question is:  Can you see this?  Is it a report about

 7     shelling from a 155-calibre?

 8        A.   Indeed, I can see it was a K-85 -- one K-155 shot from Igman, so

 9     that confirms what I said, and as far as we know, there was no 155 pieces

10     of artillery within the city of Sarajevo because Igman is outside of

11     Sarajevo, and I'm sure everyone knows this by now here.

12        Q.   May I ask you where the fire from Mount Igman is directed?

13        A.   Towards areas that I cannot really ascertain.  One should give me

14     a map so that I can see where that actually fits in.

15        Q.   And if I tell you that the fire from Mount Igman is directed

16     exclusively at the north, towards the Serb neighbourhoods of Sarajevo,

17     does that sound plausible to you?

18        A.   Without a doubt, yes.

19        Q.   Thank you.  Therefore, the artillery at Mount Igman is part of

20     the Sarajevo theatre of war?

21        A.   This was outside my area of responsibility.

22        Q.   The shells were falling into your area of responsibility; didn't

23     they?

24        A.   No, because my area of responsibility was the close proximity of

25     the city of Sarajevo.

Page 4258

 1        Q.   A moment ago, we appeared to have agreed that from Mount Igman,

 2     the fire landed in Dobrinja, Ilidza, Rajlovac, and other Serb

 3     neighbourhoods of Sarajevo and nowhere else.  Why else would this

 4     artillery have been there, except to shoot at the Serb neighbourhoods?

 5     Rajlovac, Ilidza, Vogosca and these neighbourhoods, were they part of

 6     your area of responsibility?

 7        A.   Of course, but I asked for a map to be showed to me to see where

 8     that is, Krivoglavci as well as Sarajevo.  I would like to know what that

 9     means on the ground, because as far as I'm concerned, I don't know

10     whether it is Lukavica, Ilidza, or other places that would have been held

11     by Serbian forces.

12             THE ACCUSED: [Interpretation] All right, we'll show that.

13             Can we see the next page?

14             JUDGE KWON:  If the usher could kindly turn the page.

15             THE ACCUSED: [Interpretation] Item 6 and 7, can you raise the

16     text a bit?

17             MR. KARADZIC: [Interpretation]

18        Q.   Did you see point 6:

19             "There are shortages of food, especially foodstuffs for

20     breakfast, and all calibres of ammunition"?

21             JUDGE KWON:  You are hearing some noise.  My colleague says she's

22     hearing some noise in French.  The same should be true with the witness.

23             Yes, Ms. Edgerton.

24             MS. EDGERTON:  I'm listening to the French channel, and I also

25     hear the feedback.

Page 4259

 1             THE ACCUSED: [Interpretation] In the meantime, can we prepare the

 2     translation of 1D1946.

 3             JUDGE KWON:  But I don't think we can continue.  It's better to

 4     have a break.

 5             I'm sorry again, Mr. Witness, but we need to take a break.  We'll

 6     break for five minutes.  I hope that everything could be resolved.

 7                           --- Recess taken at 2.27 p.m.

 8                           --- On resuming at 2.38 p.m.

 9             JUDGE KWON:  My apologies yet again, Mr. Witness, for the

10     inconveniences.

11             Mr. Karadzic, please continue.

12             MR. KARADZIC: [Interpretation] Thank you.

13        Q.   I hope you noticed on page 1 that it's the 31st of May, 1993.

14     Would you please look at the consequences indicated in item 7, the

15     consequences of this activity during cease-fire.

16             JUDGE KWON:  The bottom of that page is casualties, yes.

17             THE WITNESS: [Interpretation] Yes, I can see that.

18             MR. KARADZIC: [Interpretation]

19        Q.   Do you see there were also civilian casualties, two civilians

20     dead and ten wounded, injured?

21        A.   Yes, I can see it.

22             THE ACCUSED: [Interpretation] [Previous translation continues]...

23     into evidence.

24             JUDGE KWON:  I take it the French/Serbian translation is faster

25     than the English translation, so both of you are somewhat overlapping.

Page 4260

 1             In any event, Ms. Edgerton?

 2             MS. EDGERTON:  No objection.

 3             JUDGE KWON:  They will be admitted.

 4             THE REGISTRAR:  As Exhibit D338, Your Honours.

 5             THE ACCUSED: [Interpretation] Can we get 1D1946.  There is a

 6     translation for that one.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   While we are waiting:  Do you know that Hadzici is a

 9     neighbourhood of Sarajevo?

10        A.   It is part of what is called Greater Sarajevo.

11        Q.   Yes.  Sarajevo has 10 municipalities.  Hadzici is one of them.

12     Do you know that the Serbs controlled Serb parts of Hadzici, which is a

13     small part, whereas Pazaric is a Muslim area that the Serbs did not

14     control?

15        A.   In Hadzici -- you're talking of several areas where there were

16     Muslim areas and Serb areas within Hadzici.

17        Q.   I'm just asking:  Do you know that Hadzici is a municipality of

18     the city and that Hadzici contained an area called Pazarici, which was a

19     Muslim neighbourhood?

20        A.   As far as I'm concerned, Hadzici was under the control of the

21     Bosnian Muslims.  That's what I think.

22        Q.   Yes, you're right, Muslims controlled the largest area.  I just

23     want to tell you that we have a document dated 12 March --

24             JUDGE KWON:  Yes, Ms. Edgerton.

25             MS. EDGERTON:  That's not this document that's on the screen.

Page 4261

 1             THE ACCUSED: [Interpretation] No, it's not.  It's 1D1946.

 2             MS. EDGERTON:  I think, actually, the wrong document might be

 3     linked to that number.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Was Hadzici also in your area of responsibility, Hadzici as a

 6     city area, as a municipality, because your personnel visited that

 7     locality; right?

 8        A.   My area of responsibility went along the front-line as far -- or

 9     I should say that the front-line was surrounding the city as well as the

10     airport.

11             THE ACCUSED: [Interpretation] We should probably put this on the

12     ELMO.  Something's wrong with the number.  The front-line also crossed

13     Hadzici, between the Serbian part of Hadzici and Pazarici.

14             MR. KARADZIC: [Interpretation]

15        Q.   Could you briefly look at this document, where it says they

16     received 1.000 shells of 152 millimetres calibre?  In fact, this is a

17     confirmation of receipt.

18             [In English] It is not on.

19             [Interpretation] Can you see this, Witness?  They're reporting

20     that on the 10th of March, they received 1.000 grenades for a

21     152-millimetre Howitzer.  So can we say, Witness, that the Muslim side

22     was not sincere and frank when it told you what it had disposed of, what

23     it had at its disposal?

24        A.   I would like to reiterate that my main focus was on weapons of

25     the government army, weapons that were within the confines of the city of

Page 4262

 1     Sarajevo.  Earlier on, you said that the front-line in Hadzici was under

 2     my area of responsibility.  I would like to remind you there was a

 3     special setup as far as the airport was concerned.  And because the

 4     front-lines were rather tricky, it was difficult to follow them because

 5     you had a corridor leading towards the outside, towards Butmir, where the

 6     front-lines were no longer joined and they were actually discontinued.

 7     And in that area, my area of responsibility was the outer confines of the

 8     airport, but it seems that you haven't heard that when I first mentioned

 9     it.

10        Q.   Thank you.  My understanding of it is that your area of

11     responsibility was everything that was under the 1st Corps, the area of

12     responsibility of the 1st Corps, and Sarajevo had 10 municipalities.  And

13     what about Ilijas, was that in your area as well; Vogosca, Ilijas, and so

14     on, Pale?

15        A.   No.

16        Q.   All right, that's clear to me now.

17             Now, let me remind you --

18             THE ACCUSED: [Interpretation] Well, I don't suppose you're going

19     to admit this document, are you?

20             JUDGE KWON:  No, you're well familiar with the Rules,

21     Mr. Karadzic.  We'll not admit this.

22             MR. KARADZIC: [Interpretation] Thank you.

23        Q.   Let me remind you.  Yesterday, we displayed 1D1943, where it says

24     that they had a Howitzer battery, 122 millimetres, and a self-propelled

25     Howitzer battery of 152 millimetres in the city, itself, so they didn't

Page 4263

 1     tell you about that.  So I put it to you once again that they weren't

 2     sincere towards you, they weren't frank in what they told you.

 3        A.   Well, it depends on the quality of the information contained in

 4     this document, whether you laid face to it or not.  I believe what I saw,

 5     what my men saw, and during the six months of my tour in Sarajevo, nobody

 6     noticed the presence of any heavy gun in the city of Sarajevo.  I will

 7     maintain what I have said already.

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17        Q.   Thank you.  And can you see there that they have a battery --

18     a mortar battery, self-propelled Howitzer, 122-millimeter, and a

19     Howitzer, 122 millimetres, a Howitzer battery, and that was in town?  And

20     I do believe that the Serb side told you all about all the weapons it

21     had, whereas the Muslim side quite obviously tried to deceive you; right?

22        A.   Well, you are the one who says and claim that this was in the

23     city.  I know it was the area of responsibility of the 1st Corps, but it

24     extended outside the city.  It had units somewhere else as well, not just

25     inside the city.  I don't know the numbers of the brigades, I don't know

Page 4264

 1     where they were located, apart from the 10th Mountain Brigade.  I cannot

 2     tell you whether, indeed, based on this report by the head of the

 3     1st Bosnian Corps, these batteries belonged to units or brigade stations

 4     within the city.

 5             JUDGE KWON:  Just a second, Mr. Karadzic.

 6             Shall we go into private session very briefly.

 7                           [Private session]

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4265

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             JUDGE KWON:  Yes, we are now in open session.

 5             Mr. Karadzic.

 6             THE ACCUSED: [Interpretation] I didn't state the name of any

 7     commander.  It could have been a company commander, for that matter.  I

 8     took care not to, and that's why I didn't ask for private session.

 9             MR. KARADZIC: [Interpretation]

10        Q.   But, anyway, do you see that we're dealing with the

11     3rd Motorised Brigade here?  Now, the 3rd Motorised Brigade, was it in

12     the city of Sarajevo?

13        A.   I have already told you just a few moments ago that I could not

14     remember, apart from the 10th Mountain Brigade, what the numbers were of

15     the other brigades that were stationed within Sarajevo.  I'm saying it

16     again, and it may be the last time I'm telling you.

17        Q.   Thank you.  But I was happy to learn yesterday that you knew

18     everything about Sarajevo, but I see that you just remembered Caco,

19     whereas the other moderates have been forgotten.  But never mind, we'll

20     establish where the area of the 3rd Motorised Brigade was.

21             THE ACCUSED: [Interpretation] But let me tender this into

22     evidence first.  Can it be admitted now, because it's directly related to

23     what the witness was talking about?

24             JUDGE KWON:  I don't see a basis to admit this.

25             Ms. Edgerton.

Page 4266

 1             MS. EDGERTON:  I've actually -- I've done some thinking and

 2     transcript reading about this document overnight, Your Honour, and on

 3     reading the transcript, Dr. Karadzic's intention became clearer.  And now

 4     listening to this today, I actually think the document, as such, does

 5     meet the guide-lines that this Trial Chamber had articulated.  The

 6     guide-lines say, at paragraph 11, that:

 7             "The general principle of admission does not rule out the

 8     possibility of admitting documents that challenge a witness's

 9     credibility, and the fact that the document goes to the witness's

10     credibility may constitute sufficient nexus between the witness and the

11     document for it to be admissible."

12             And as I understand it today, as I understood it after reading

13     the transcript, I think Dr. Karadzic is seeking to tender the documents

14     as evidence that he alleges directly contradicts the testimony of the

15     witness.  And while I don't think it's direct evidence to the effect that

16     the ABiH had weapons of the calibre that they've been discussing in

17     Sarajevo, it looks like a valid attempt to impeach the witness.

18             JUDGE KWON:  Does it mean that you do not oppose to the admission

19     of this document?

20             MS. EDGERTON:  In short, I don't.

21                           [Trial Chamber confers]

22             JUDGE KWON:  While this document was related to the credibility

23     of the witness, the reason why the Chamber couldn't admit it was because

24     we didn't have anything as regards the foundation of this document.  But

25     now that the Prosecution agrees with its admission, there seems to be a

Page 4267

 1     basis for the Chamber to admit it.  As such, this will be admitted.

 2             MS. EDGERTON:  Yes.  We have no objection, obviously, to the

 3     authenticity of the document either.

 4             JUDGE KWON:  Thank you.  But I was informed that there's no full

 5     translation for this document.

 6             MS. EDGERTON:  We can make one available.  We found one overnight

 7     as well, Your Honour.

 8             JUDGE KWON:  Very well.  With that caveat, we'll admit it.

 9             THE REGISTRAR:  As Exhibit D339, Your Honours.

10             JUDGE KWON:  Mr. Karadzic.

11             THE ACCUSED: [Interpretation] Thank you.

12             I don't know where I went wrong and how I deserved such attention

13     from the opposite side.  I don't know if I will be able to repay it.

14             MR. KARADZIC: [Interpretation]

15        Q.   Witness, the previous document that was admitted was dated 31

16     May.  We saw yesterday a couple of documents where the

17     Sarajevo Romanija Corps informs the Main Staff that they are complying

18     with a cease-fire, and now we are on the 1st of June, one of the

19     documents covered in your statement.  It's the Dobrinja football pitch

20     attack.

21             When was the first investigation into this case completed?

22        A.   Can I -- can we move to private session?

23             JUDGE KWON:  By all means.

24          [Private session] [Confidentiality partially lifted by order of Chamber]

25   (redacted)

Page 4268

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14        Q.   What (redacted) about the type of shell, the type of

15     projectiles?

16        A.   Well, the conclusion that was shown to you yesterday.  In other

17     words, on account of the, quote/unquote, "protection" or "obstacle" that

18     was constituted by the buildings that were all around the football pitch,

19     the conclusion was that the shell could only have been fired from

20     a mortar.  Given the crater and the fragments, (redacted) there

21     were, indeed, mortar shell fragments, and because of the other technical

22     data that were recalled yesterday, the only origin could be from the

23     south/south-east of the football pitch, and the front-line was very close

24     to the location of the incident because basically the front-line was on

25     the other side of this building that was the obstacle.  Obviously, it

Page 4269

 1     could only come from Bosnian-Serb-held territory.

 2        Q.   You said something a little different yesterday, but right now

 3     I'm asking you about the calibre.

 4        A.   I can't remember the calibre.  I think we saw this in the

 5     document yesterday.  Was it 82- or 120-millimetre?  I can't remember.

 6     Maybe it was an 82-millimetre calibre.  We'd have to see the document

 7     that we saw again -- that we saw yesterday again.

 8        Q.   We'll get to that document, because we're going to ask for the

 9     whole document to be admitted.

10             Can we now get 1D1543.

11             You said yesterday that General Galic was an excellent officer

12     and he wrote accurate reports on a daily basis about everything going on

13     in his corps; is that correct?

14        A.   I never stated that General Galic was an excellent officer,

15     because I didn't at all agree with his orders.  However, I said that he

16     was a professional officer, because he was a professional serviceman and

17     that he'd been trained to drafting accurate reports that he would send up

18     to his hierarchy.  But please remove the word of "excellent" that you

19     fabricated and which I never uttered.

20        Q.   I think you said "excellent military person," verbatim, although

21     I can't give you the reference to the page.  But I agree with you that he

22     was an excellent military person.  And due to a poor Defence he was

23     sentenced to life, although he didn't even deserve to be charged.  That's

24     what you said spontaneously yesterday, anyway, and I'm just putting that

25     to you.

Page 4270

 1             JUDGE KWON:  Please refrain from making comment, Mr. Karadzic.

 2     What is your question, and do you like to stay in private session,

 3     Mr. Karadzic?

 4             THE ACCUSED: [Interpretation] We don't have to stay in private

 5     session.

 6             Page 57 of yesterday's transcript, I'd just like the witness to

 7     look at it.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   While we're waiting, I don't know if you've seen this page 57.

10             JUDGE KWON:  I'll read it for the witness.  Shall we go back to

11     open session?  It's for you to ask.

12             We'll go back to open session.

13                           [Open session]

14             JUDGE KWON:  It is of transcript page 4.216, and it's from line

15     18.  And there, Mr. Witness, you said:

16             "I uncovered -- or I took during the 2009 hearings that

17     General Galic was an excellent military person."

18             And you give an account of what had happened every evening to his

19     command.

20             Well, I'm not sure whether it was a translation problem or not,

21     but that's what is stated in the transcript.  But that's not a big deal,

22     and let's move on, Mr. Karadzic.

23             THE WITNESS: [Interpretation] There must be a problem with the

24     translation, Mr. President.

25             JUDGE KWON:  CLSS will take a look into the matter.

Page 4271

 1             Move on, Mr. Karadzic.

 2             MR. KARADZIC: [Interpretation] Thank you.

 3        Q.   May I draw your attention to number 1.  I don't know if we have a

 4     translation for this, but I'm going to read out only item 1.  It says:

 5             "In the course of the day --"

 6             And this is dated 1 June:

 7             "In the course of the day, the enemy violated the cease-fire --"

 8             JUDGE KWON:  Ms. Edgerton is helping you a lot today.

 9             MS. EDGERTON:  Thank you, Your Honour, but I apologise that I'm

10     not a bit faster.  It's just a matter of trying to locate the documents,

11     and nothing more than that, but Mr. Reid is indispensable in that regard.

12     I have a translation that could assist you.

13             JUDGE KWON:  Thank you very much.

14             THE ACCUSED: [Interpretation] Thank you very much, once again.

15             MR. KARADZIC: [Interpretation]

16        Q.   May I draw your attention to the date first.  The date is the 1st

17     of June.  The time is 1700 hours.  In paragraph 1, we see who did what.

18             JUDGE KWON:  Just a second.  Let's wait until it functions.

19             THE WITNESS: [Interpretation] Mr. President, I don't think I have

20     the same document as the accused, because he's just said that this was

21     drafted at 16 hours and I have the hour of 17 hours, so it's not the same

22     document or else the accused is wrong.

23             JUDGE KWON:  I'm sorry, I think both documents said "1700 hours."

24     Could the usher kindly take a look at the monitor.

25             THE ACCUSED: [Interpretation] 17, yes, I said "17."  The 1st of

Page 4272

 1     June, 1700 hours.

 2             THE WITNESS: [Interpretation] It may be that I misheard.  Sorry,

 3     but I'm pretty sure I saw what I heard.

 4             JUDGE KWON:  Please put it back.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You remember that incident took place at 10.20 in the morning in

 7     Dobrinja?

 8        A.   Yes, I believe it was at that time.

 9        Q.   We can see it now.  Paragraph 1 says:

10             "In the course of the day, the enemy violated the cease-fire more

11     than once, firing on our defence positions."

12             And then there is a whole list of these violations, and not a

13     single word mentions what happened in Dobrinja.

14             Can we see the rest of the document?

15             We can see that they opened sniper fire in Jezevo [phoen],

16     Orahov Brijeg, the Vogosca factory sectors.

17             We can move one page further, maybe even two pages.

18             [In English] Okay, can we go on paragraph 7 and 8.

19             [Interpretation] I would like to draw everyone's attention to all

20     these elements.  Let me not greet them all.  Two fighting men got serious

21     injuries to lighter injuries.  Number 7 states the losses, and number 8

22     is the conclusion:

23             "The corps forces respected the order on cease-fire in full.

24     There was no response to enemy provocations.  It is to be expected that

25     intense sniper fire on civilian targets by the enemy will continue."

Page 4273

 1             Now, Witness, do you agree that in this document, which is

 2     strictly confidential, by 1700 hours there is not a single word about the

 3     incident that we are discussing?

 4        A.   Indeed, and I can understand that no mention or reference was

 5     made -- had been made.

 6        Q.   But not only that.  It doesn't mention that fire was opened at

 7     all.  In all other reports, we see when they opened fire, how much

 8     ammunition was expended, but here there's not a word about it.  And this

 9     is a confidential report, and a corps commander should not omit anything

10     when reporting to the Main Staff about developments in his area.  Can we

11     see that they never opened fire here?

12        A.   Well, this is what is said in the report, but this may not

13     reflect the reality on the ground.

14        Q.   But we have established, and I think we agreed, that the secret

15     reports to the Main Staff were always exhaustive and accurate, and such

16     an important thing like a case of armed attack in the neighbourhood would

17     certainly have been mentioned there.  Thank you.

18             Can this document be admitted?  It is relevant to the incident in

19     question, and it's an authentic document.

20             JUDGE KWON:  I'm not --

21             THE WITNESS: [Interpretation] That's what you say.

22             JUDGE KWON:  Thank you.

23             Ms. Edgerton.

24             MS. EDGERTON:  I find the document's authentic, Your Honour.  And

25     on that basis, I would have no objection.

Page 4274

 1                           [Trial Chamber confers]

 2             JUDGE KWON:  Likewise, we'll admit it.

 3             THE REGISTRAR:  As Exhibit D340, Your Honour.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Can we now get 1D1933.  We will now review all that anyone said

 6     about this event, to get a full picture.  1D19 -- yeah, that's it.  I

 7     don't know if we have a translation.  My learned friend Ms. Edgerton

 8     maybe knows.

 9             Let me read to you from the heading.  It's the Foreign Ministry,

10     the Secret Service, in other words, the National Security Service, the

11     War Section of Ilidza.  The date is the 1st of June, 1993, and they

12     report -- if we don't have a translation, then let me read out a part:

13             "On the 1st of June, 1993, we received new information from a

14     completely reliability source about today's incident in Dobrinja.  In the

15     communication between two members of the so-called BH Army, one of which

16     stayed in Dobrinja, we found out that one of the commanders of the

17     so-called BH Army led out his units onto the parking-lot in the

18     Vahide Maglajlic Street, in Dobrinja, 3, and that they organised the

19     football match, in the course of which two shells had landed.  According

20     to the statement of the same person, out of the total number of the

21     wounded, 50 members of the so-called BH Army were taken to the Kosevo

22     Hospital, and nine dead are in the morgue in Dobrinja.  The aforesaid

23     person expressed the opinion that that commanding officer should be

24     arrested and executed by firing squad."

25             And then there is a nota bene from the National Security Service.

Page 4275

 1     At the bottom, and it says:

 2             "Through our source, we will continue to follow and look for new

 3     information regarding this incident."

 4             Is it the case that this football match was played by members of

 5     the BH Army, as this report says?

 6        A.   This is what is stated in this report by the Serbian Intelligence

 7     Service.  That's all that I can say.

 8        Q.   Do you know that in Dobrinja, there was a regular unit or regular

 9     units, and that's the place where the units leaving the city to go to

10     Mount Igman assembled?

11        A.   Of course, we mentioned it earlier on.  It was within my area --

12     well, actually, perhaps we should move to private session, Your Honour.

13             JUDGE KWON:  Yes.

14                           [Private session]

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4276











11  Page 4276 redacted. Private session.















Page 4277

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             MR. KARADZIC: [Interpretation] Thank you.

13        Q.   But certainly, Witness, you're not challenging, are you, the fact

14     that the units of the 1st Corps went into the city and exited the city,

15     and that sometimes they would appear at one theatre of war and sometimes

16     in another area; right?

17        A.   I will repeat what I said.  We did not notice that full units

18     were leaving the town through the airport or were entering into the town.

19     We just noticed that soldiers, on an individual basis, left the city or

20     were trying to go inside the city.

21        Q.   Thank you.  Well, we'll be presenting documents in due course

22     where we can see orders to the effect that the units should return -- or,

23     rather, leave Sarajevo and return to Sarajevo.  We'll do that on another

24     occasion, but let's now go back to the incident we were discussing.

25             If you recall, and I think we looked at the document on our

Page 4278

 1     screens yesterday - I don't believe it's admitted - on the 22nd of May,

 2     the Sarajevo Romanija Corps ordered all officers and, if necessary, the

 3     police, to place all weapons larger than 12.7-millimetre calibres, so it

 4     was the document of the 22nd of May which meant there was no shooting

 5     after that date.  Now, at 1020 hours, two shells fell.

 6             Let's look at the document again produced by the Prosecution

 7     yesterday.  11383 is the number, but there's a P number, a new P number,

 8     because it's an exhibit already.

 9             Can somebody help us out?  11383, but it was P1047 or 8, I

10     believe.  Three pages were admitted, but we should like to tender the

11     entire document now, please.  11383 is the number.

12             MS. EDGERTON:  It was P1053.

13             JUDGE KWON:  Thank you.

14             MR. KARADZIC: [Interpretation]

15        Q.   Witness, let me ask you:  On the 1st of June, you had an

16     insight -- well, you investigated on-site, and then on the 2nd of June

17     you issued a caution to the Serb side; right?

18        A.   Probably.

19             THE ACCUSED: [Interpretation] Thank you.

20             Now let's see -- that's not the right document.  Or, yes, let's

21     see the entire document.  Let's have the whole document displayed.  11383

22     is the number.  This is just a part of it which was admitted and tendered

23     by the Prosecution, but we need the whole document.

24             JUDGE KWON:  I was informed that the whole document was numbered,

25     in terms of 65 ter, it is 11383a, small A.  Is that correct?  I think we

Page 4279

 1     are looking at the first page, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] Yes, if we're talking about the

 3     whole document.  But if it is P053, then we just have three pages there.

 4     But the break is coming up now, so shall we leave it until after the

 5     break, perhaps?

 6             JUDGE KWON:  Very well.  We'll resume at 4.00.

 7                           --- Recess taken at 3.29 p.m.

 8                           --- On resuming at 4.04 p.m.

 9             JUDGE KWON:  Mr. Karadzic, we have before us the whole document

10     of the investigation report.  Let's proceed.

11             THE ACCUSED: [Interpretation] Thank you.

12             May we turn to the next page, please.

13             MR. KARADZIC: [Interpretation]

14        Q.   Witness, is this document familiar to you?  Have you seen it

15     before?  Did you take a look at it during the proofing session with the

16     Prosecution, for instance?

17        A.   Yes, I think I'm familiar with it.

18        Q.   Thank you.  I'd like to draw your attention to the first two

19     paragraphs:

20             "On the 28th of June, 1993," and then the people mentioned, "were

21     tasked to conduct an investigation into a mortar attack that happened in

22     the Dobrinja district of Sarajevo on or about the 1st of June."

23             So this is 27 days later; right?

24        A.   Yes.

25        Q.   And number 2, it says that they have received a copy of an

Page 4280

 1     analysis, and you mentioned this, and I'd like to draw your attention to

 2     F, paragraph 2(f), and I'll read it out in English:

 3             [In English] "Due to the fact that both rounds impacted into a

 4     macadam surface, the angle of descent and range cannot be determined."

 5             [Interpretation] So this is from the first investigation that was

 6     carried out by the UN representatives and handed over to this group doing

 7     the investigating; that is to say, that neither the angle of descent nor

 8     the range could be determined.  Right?

 9        A.   This is what is stated in the document.

10        Q.   Thank you.  And we see at the bottom there that it says:

11             [In English] "Attached to the crater analysis report, and that's

12     showing the line of flight, suspected firing locations and points of

13     impact for both rounds."

14             [Interpretation] Now may we turn to the next page, please, and

15     I'd like to remind you of what it says here, "suspected firing

16     locations."  Does it say "suspected"?  Well, we're now on to the next

17     page, but it said "suspected" there, didn't it, previously?

18             Can we show the witness where it says "suspected firing

19     locations."

20             Do you see that, the sentence just before paragraph 3?

21             JUDGE KWON:  It's the sentence beginning with:  "Attached to the

22     crater analysis ..."  Zoom out, yes.

23             THE WITNESS: [Interpretation] I see.

24             THE ACCUSED: [Interpretation] May we now turn to the next page,

25     please.

Page 4281

 1             Lower down on that page, 4(c), let's look at that.  Well, the

 2     whole document is interesting, but point C in particular:

 3             [In English] "There were a lot of people at the game, many of

 4     them young people who were participating and also spectators."

 5             [Interpretation] And towards the bottom there, there's mention

 6     here of Mr. Stekovic, and it says that it was exclusively residential in

 7     nature, the area, Dobrinja, and that they played on the stadium.

 8             Now may we have a look at page 447.  We'll come back to

 9     Mr. Stekovic later, but 447 -- the last digits of the page I'd like us to

10     look at next is 447.  Next page.  Thank you.

11             And I'd like to draw your attention there to paragraph 9.  I'm

12     not going to read the names.  It says:

13             "At approximately 0907 hours on the 2nd of July, accompanied by,"

14     the gentleman whose name is stated there and the others:

15             [In English] "We realised that all investigative materials

16     related to this incident had been forwarded to the main police station in

17     Sarajevo."

18             [Interpretation] So the police station at Dobrinja:

19             "... attended the police station where we met with this man,

20     Kosevac [phoen], and they said that the material relating to this

21     incident had been forwarded to the main police station in Sarajevo.

22             May we turn to the next page now, please.  Just a moment, please.

23             Let's just look at paragraph 10 there.  Let's stay with that

24     page, paragraph 10, please:

25             [In English] "While in attendance at the main police station ..."

Page 4282

 1             [No interpretation]:

 2             [In English] "... was informed by officials there that materials

 3     regarding the mortar attack were not presently available; however, they

 4     could be obtained at the Security Services Centre at 1400 hours, 2nd of

 5     July, 1993."

 6             [Interpretation] And then paragraph 11:

 7             [In English] "About 1405 hours of 2nd of July, 1993, accompanied

 8     by ..."

 9             And you see all that there, all the names:

10             [In English] " ... to the Security Services Centre, where we met

11     with," this guy whose name you see.  "He advised us that there was no

12     investigation conducted into the matter of civil authorities, and that

13     the Bosnian military may have made inquiries into the matter.  He added

14     that his department was currently investigating the organisers of the

15     tournament, and that he understood Bosnian TV may have video footage of

16     the event.  He commented that UNPROFOR authorities had attributed the

17     incident to the Serbian military, and that that was sufficient for his

18     department."

19             [Interpretation] Do you agree that they did not conduct an

20     investigation because it was sufficient -- the fact that the UN had

21     ascribed this to the Serbs was sufficient, as far as they were concerned.

22        A.   This is what is written on the document.

23             THE ACCUSED: [Interpretation] May we move on to the next page

24     now, please.

25             MR. KARADZIC: [Interpretation]

Page 4283

 1        Q.   So neither the local police station or the municipal or regional

 2     police station did anything.  It was enough that the Serbs were accused,

 3     and they investigated who organised the football match, not who did the

 4     shooting.  Is that what it says there in that previous paragraph; right?

 5             Well, the page isn't on our screens, but that's what it said.

 6             Now let's look at paragraph 14.  I'm going to read part of it:

 7             [In English] "About 8.45 [sic] on the 4th of July, 1993, I

 8     received a copy of a map of Dobrinja from UNPROFOR officials, a copy

 9     which is attached as Annex 1.  This map shows that the soccer game was

10     held in a location surrounded on three sides by buildings (west, east and

11     south).  In addition, it was explained that there are Bosnian mortars

12     located outside the hospital approximately 500 metres from the soccer

13     location.  However, these were not observed during our visit to Dobrinja

14     area."

15             [Interpretation] So did you know or notice that 500 metres away

16     from the soccer location, they had their mortar position?

17        A.   I don't have an accurate memory of it, but it is quite possible.

18     I underline that the mortar units, especially with the Bosnians, had this

19     characteristic, that they would move them very often.  They had no fixed

20     position, which accounts for the fact that unlike the Serb artillery

21     positions, we had not ascertained what the permanent locations were of

22     the Bosnian mortar units because such did not exist.  They would move

23     them frequently so as to avoid being located and have a counter-battery

24     fire fired on them.

25        Q.   Thank you.  120 and 82 were probably on trucks.  Now, the

Page 4284

 1     60-millimetre -- a 60-millimetre infantry weapon, it can be carried on

 2     your back; isn't that right?

 3        A.   Yes, or then it was mounted on a vehicle.  But a 60-millimetre

 4     can easily be taken on foot.

 5        Q.   Thank you.  Now let's focus on paragraph 17:

 6             [In English] "At approximately 1014 hours on 5th of July, 1993,

 7     accompanied by Mr. Mocibob," and so on, "I attended Dobrinja.  We were

 8     met with Mr. Dinko Bakal."

 9             [Interpretation] Now let's see what it says under C:

10             [In English] "He heard the detonations and believed that they

11     were caused by 82-millimetre mortars, but later discovered that they

12     were, in fact, 60-millimetres mortar.

13             "D.  He assisted in evacuation of the wounded, most of whom were

14     women, children, and civilian persons."

15             [Interpretation] Now let's move on to the next page, and let's

16     see what it says at the top there:

17             [In English] "Although the site cannot be seen from the

18     confrontation line, he believes that the person responsibility may have

19     had the coordinates."

20             And he says that:

21             "There are no military targets nearby," and so on.

22             [Interpretation] And now paragraph 19 down at the bottom there,

23     19 and 20, towards the end of the page:

24             [In English] "Other investigative steps related to this case may

25     include interviews with Serbian officials, as well as other witnesses."

Page 4285

 1             [Interpretation] And 20:

 2             [In English] "A further report will be submitted.  Therefore,

 3     this report is pending."

 4             [Interpretation] Can we now agree that the report was not

 5     complete or final?

 6        A.   Well, this is up to the investigators.  Indeed, if they say that

 7     they still had to interview Serbian officials, I don't know whether they

 8     did this or not, but apparently this is not part of the report.

 9        Q.   Thank you.  Let's now briefly go through, and I hope we can have

10     yes-and-no answers, through what it says.  We have a cease-fire enforced

11     from at least the 22nd of May.  That's one element.  And we also have the

12     Sarajevo Romanija Corps which is lacking in ammunition and is reporting

13     that it is adhering to the cease-fire.  And we have, on the 1st of June,

14     at 10 -- 22 shells, grenades.  Then we have proof of evidence that the

15     Army of Republika Srpska, from its positions, could not see the area

16     where the soccer game was being held, but that for such precise targeting

17     you needed coordinates or they needed coordinates.  And on the 1st of

18     June, at 1700 hours, the Sarajevo Romanija Corps is reporting, and in its

19     report it makes no mention of any shooting.

20             On the 2nd of June, then without a completed investigation, a

21     warning is being issued, a letter to me from General Morillon, and a

22     caution to the Sarajevo Romanija Corps.  So this is being ascribed to the

23     Serbs.

24             And it was only on the 28th of June that UNPROFOR is giving a

25     group of officers the task of investigating; isn't that right?

Page 4286

 1        A.   Well, I think that the investigation was requested by the highest

 2     echelon of the UN on location.  I can't remember the name of the organ in

 3     charge of prosecuting or investigating into war crimes and the fact that

 4     this, as stated by this report, comes from them.

 5        Q.   Thank you.  Yesterday, we agreed that the best way -- or, rather,

 6     the best time to investigate an incident is straight after the incident

 7     took place, and here this is being done almost after four weeks, so

 8     almost a month was allowed to elapse.  Now let's remind ourselves

 9     further.

10             On the 2nd of July, this team went to the Dobrinja police station

11     to take over the investigation material, and they were told that it was

12     somewhere else.  So they went to this other place, to the Sarajevo Police

13     Station, to take over all the material in the Security Services Centre,

14     and when they arrived there they were told an investigation had not been

15     conducted because there was no need, since it was ascribed to the Serbs.

16             Now, on the 4th of July, information receives UNPROFOR that 500

17     metres from the incident you had the BH Army mortars, and an analysis of

18     the crater showed that there were two possibilities linked to 82- or

19     122-millimetre mines, whereas witnesses interviewed by UNPROFOR confirmed

20     that they were 60-millimetre ones.

21             So the only piece of information from the Serb side -- a document

22     from the Serb side is that the MUP of Ilidza, the State Security, on the

23     1st of June, 1993, learned that two shells had fallen, and that the

24     participants were soldiers, and that they were angry with the commander

25     who organised the soccer game.  And we see that the civilian authorities

Page 4287

 1     investigated the organisers of the soccer game and not the perpetrators

 2     of the crime, itself; isn't that right?

 3        A.   Well, this is what this document you submitted to me says.

 4        Q.   Thank you.  And then further down, it advises that all the

 5     participants, that is to say, Stekovic and the others, were interviewed,

 6     that they were combatants.  So all the names we have were the names of

 7     combatants.

 8             And now I'd like to tender this document into evidence in its

 9     entirety.

10             JUDGE KWON:  What is the practice; we give the same number or --

11                           [Trial Chamber and Registrar confer]

12             JUDGE KWON:  So we'll add that, the remaining part to the

13     already-existing parts, which will be Exhibit -- what number?

14             THE REGISTRAR:  That will be Exhibit P1053, Your Honours.

15             JUDGE KWON:  Thank you.

16             MR. KARADZIC: [Interpretation] Thank you.

17        Q.   Now, Witness, do you accept that Mr. Izetbegovic, on the 21st of

18     March of that same year, was in New York, attending a conference there?

19        A.   Can we move into private session?

20             JUDGE KWON:  Yes.

21             [Private session] [Confidentiality partially lifted by order of Chamber]

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4288

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13             THE ACCUSED: [Interpretation] Thank you.

14             I think that we can now move back into open session.

15             And perhaps already today or by tomorrow we will provide you with

16     media reports which make it clear that we were all in New York at the

17     time already as of the 17th or 18th of March.

18   (redacted)

19   (redacted)

20   (redacted)

21                           [Open session]

22             THE REGISTRAR:  We're back in open session, Your Honour.

23             THE ACCUSED: [Interpretation] This is a very important witness

24     because he knows a lot of things, and he has admitted to that, to knowing

25     the situation well.  We're not going to lose any time by going into this.

Page 4289

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Now, Witness, do you allow for the possibility that the Muslims

 3     from time to time bombed their own territory and their own people and

 4     their own units?

 5        A.   Indeed, on a few occasions we noticed that there were snipers

 6     firing within the city, and perhaps there were also mortar fire, namely,

 7     other weapons, that were rather suspect when we looked at them more

 8     closely.

 9             THE ACCUSED: [Interpretation] 1D1953, please.  We just need to

10     take a short look at a document of the Muslim 1st Corps.  This should not

11     be broadcast.  I would appreciate it.  I don't know if we have a

12     translation.

13             MR. KARADZIC: [Interpretation]

14        Q.   This commander, the undersigned, is writing to UNPROFOR officers,

15     and he says:

16             "The resentment is caused by the claim that the BH Army, from its

17     positions, is firing at the airport where UNPROFOR forces are based, and

18     also at their own wretched people who are trying to leave the town and

19     get to modest quantities of food," et cetera, et cetera.

20             So this is a letter -- a response to the letter by the UNPROFOR,

21     accusing them of shooting their own people?

22        A.   Could we have the translation at least in English?

23             THE ACCUSED: [Interpretation] I'll read it again.  It can be

24     interpreted.

25             Can we go into private session, and then we can read all of it.

Page 4290

 1             JUDGE KWON:  Yes.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4291











11  Page 4291 redacted. Private session.















Page 4292

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6                           [Open session]

 7             JUDGE KWON:  Yes, we are now in open session, Mr. Karadzic.

 8             MR. KARADZIC: [Interpretation] Thank you.

 9        Q.   So this is a document -- a directive that I sent to the

10     Main Staff of the Army of Republika Srpska on the 11th of March, that is,

11     a week before I left for New York to attend a conference.  And I can draw

12     your attention to paragraph 1.  I order that a consignment and safe

13     passage of a shipment be enabled to prohibit any misuse for military

14     purposes of food supplies, crops, plumbing, and drinking water,

15     reservoirs, as well as water dams; to abide by the Geneva Convention for

16     the protection of victims of war, et cetera, et cetera, and to ensure

17     that all army units familiarise themselves with the directive and comply.

18             Do you agree that this is in conformity with the upcoming talks

19     and the hope that we will achieve peace?  Did you know or were you aware

20     that I was issuing directives like this?

21        A.   No, because the Serbian Army was not sending me their internal

22     documents.

23        Q.   But do you accept this is an authentic document issued 10 days

24     before the incident that we are about to shed some light on now?

25        A.   Indeed, if one looks at the date, 11th of March, it was about 10

Page 4293

 1     days before the incident that you are going to talk about.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             Can this document be admitted?

 4             JUDGE KWON:  I think this has already been admitted as

 5     Exhibit D104.

 6             THE ACCUSED: [Interpretation] 1D1976 is the next document I'd

 7     like to look at.  1D1976.  This will be a document of the Muslim army,

 8     their Main Staff, the Main Staff of the Supreme Command of the

 9     Armed Forces of Bosnia-Herzegovina.  How come we were not considered also

10     to be a part of Bosnia-Herzegovina?  Since you don't have the document,

11     let me tell you.

12             On the 16th of March, and we are drawing closer --

13             JUDGE KWON:  Yes, Ms. Edgerton.

14             MS. EDGERTON:  If we could just have your indulgence for a couple

15     of seconds, we can provide a translation.

16             JUDGE KWON:  Thank you very much.

17             MS. EDGERTON:  It's just as fast as technology works,

18     Your Honour.

19             JUDGE KWON:  Still amazing.

20             MS. EDGERTON:  Perhaps I could ask for the ELMO to be turned on

21     again.  Mr. Usher.

22             THE ACCUSED: [Interpretation] Thank you.

23             I would like to draw the parties' attention to the entire

24     document.  It is extremely important for the events that would transpire

25     in Sarajevo in the spring of 1993, but for the moment we are focusing on

Page 4294

 1     Sarajevo.  It's a document from General Halilovic.

 2             Look at paragraph 1:

 3             "Order strictly confidential number 02/398-1, dated 15 March

 4     1993, is null and void and was issued for propaganda purposes."

 5             And the preamble says:

 6             "Referencing the received order strictly confidential number ...

 7     dated 15 March 1993, regarding the cessation of hostilities, I hereby

 8     order:"

 9             And then it says that the order is null and void and was issued

10     for propaganda purposes.  All this would later result in the events

11     around Cerska and Srebrenica in 1995.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you see this, this order by the commander of the Muslim army,

14     and can you contrast it with the orders that I gave?

15        A.   I can see -- I see "Mr. Halilovic," and I can see that he sent to

16     the 2nd Corps.  I believe that it was a corps that was based outside of

17     Sarajevo.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can this document be admitted?

20             The cessation of hostilities was to apply in the entire territory

21     of Bosnia and Herzegovina, and he issues an order like this at the time

22     when we are leaving to attend that conference in New York.  He orders the

23     cancelling of the cessation of hostilities and demands fierce offensive

24     action.

25             JUDGE KWON:  Mr. Karadzic, what question did you ask the witness

Page 4295

 1     about this document?  All he said is that Mr. Halilovic sent this

 2     document to the 2nd Corps.  That's all he said.  What's the point of

 3     putting this document to the witness?

 4             THE ACCUSED: [Interpretation] Here is why it's important:  The

 5     United Nations mainly contributed to --

 6             JUDGE KWON:  No, no.  Put your question to the witness instead of

 7     making a speech.

 8             THE ACCUSED: [Interpretation] All right, a short question.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Do you remember that the cessation of hostilities and the

11     cease-fire applied in the entire territory of Bosnia-Herzegovina?

12        A.   I do not recall precisely this very cease-fire.  If one looks at

13     the document that you have showed me and that you signed, there was

14     probability a cease-fire that had been agreed upon at the highest level,

15     but I do not recall exactly the date of the cease-fire.  Over six months,

16     I experienced so many cease-fires that I don't remember them all by

17     heart.

18        Q.   Do you remember that Mr. Izetbegovic set the condition?  He will

19     go to the conference if a cease-fire is achieved?  Do you remember that?

20     It was made public.

21        A.   I do not remember this because I believe that these were

22     negotiations that were dealing with the entirety of Bosnia-Herzegovina,

23     if I understand correctly, if I look back to the text that you showed us,

24     and these negotiations went far beyond my area of responsibility.

25        Q.   Very well, thank you.  But I want to ask if you knew about this

Page 4296

 1     duplicity, this double-play, that they accept a cease-fire and a

 2     cessation of hostilities, and then the next day send out secret documents

 3     telling people to disregard it.

 4        A.   When I arrived in Bosnia, I soon realised that all the parties

 5     that were there were playing double-play.  So this double-play from the

 6     Muslims does not surprise me, but I also experienced some from the other

 7     parties as well.

 8        Q.   And do you remember confirming that five days after this

 9     document, after this order, there was an attack by the 10th Mountain

10     Brigade against Serb positions and Serb communications, or roads, as you

11     understood it?  Do you recall that?

12        A.   Indeed, we talked about this at length already.  Unfortunately,

13     the document that you're putting forward is addressed to the 2nd Corps,

14     and the 10th Mountain Brigade did not belong to the 2nd Corps.

15        Q.   This violation of the cease-fire applies to the entire territory,

16     obviously, because it was a unit of the 1st Corps that violated the

17     cease-fire on the 21st and also earlier, as you will see later.

18        A.   It may well be.  The one of the 21st was blatant, if there was a

19     cease-fire then.  Since you are saying that, I believe that there was a

20     cease-fire that was underway.

21        Q.   And the 10th Mountain Brigade attacked Serb positions; right?

22        A.   Indeed.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can this document be admitted?

25             JUDGE KWON:  Ms. Edgerton.

Page 4297

 1             MS. EDGERTON:  Your Honour, I still think it's too much of a

 2     stretch.

 3             JUDGE KWON:  As to the so-called double-play on both sides, the

 4     witness confirmed to a certain extent.

 5             MS. EDGERTON:  Peripheral relevance, then, Your Honour.

 6             JUDGE KWON:  And if you're satisfied with the authenticity?

 7             MS. EDGERTON:  In that regard, yes.

 8             JUDGE KWON:  So on that basis, the Chamber will admit it.

 9             THE REGISTRAR:  As Exhibit D343, Your Honours.

10             THE ACCUSED: [Interpretation] Can we now get 1D1511.  1D1511.

11             MR. KARADZIC: [Interpretation]

12        Q.   While we're waiting, let me inform you that it was a report to

13     the Main Staff, the Sarajevo Romanija Corps, dated 19 March, just briefly

14     for you to see the activities of the enemy side, the Muslim side, on the

15     19th of March.

16             JUDGE KWON:  Yes, Ms. Edgerton.

17             MS. EDGERTON:  Translation is coming up, Your Honour.

18             Mr. Usher.

19             THE ACCUSED: [Interpretation] Thank you very, very much.  I hope

20     we, too, will soon get the translations that are available.

21             MS. EDGERTON:  These are all CLSS translations.

22             MR. KARADZIC: [Interpretation] Thank you.

23        Q.   Look at this.  It's the 19th of March to the Main Staff.

24     Paragraph 1:

25             "Over the past period, the enemy launched strong artillery

Page 4298

 1     attacks on the Ilidza sector with 15 mortar shells, the Azici sector with

 2     30 mortar shells, Grbavica with 12 mortar shells, the Ilijas sector with

 3     60 mortar shells, and Lukavica, 7 mortar shells.

 4             "The enemy mounted strong combined infantry and artillery attack

 5     on the positions of the Rajlovac Light Infantry Brigade in the Sokolje

 6     sector."

 7             And if we can see lower down the page -- no, no, paragraph 4:

 8             "This is how Serbs are getting killed during cease-fire.  Losses:

 9     One dead, ten wounded, all from the Rajlovac Brigade; three dead and six

10     wounded civilians from Ilijas."

11             Witness, sir, did you ever hear from Serbs that those cease-fires

12     were very expensive to us, they cost us dearly because we died in greater

13     numbers during cease-fires than during combat?

14        A.   Could we move to private session, please?

15             JUDGE KWON:  Yes.

16           [Private session] [Confidentiality partially lifted by order of Chamber]

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)  Do you agree that the Army of Republika Srpska

Page 4299

 1     responded only after such losses, and they did not respond to threats

 2     before they suffered losses; they observed the cease-fire?

 3        A.   Well, when you retaliated, it means that you were under attack.

 4     So you could only retaliate when you were under attack.  And, indeed, I

 5     do not recall of any specific violation of the cease-fire.  Through those

 6     reports, one can see that there were perhaps no violations on the

 7     cease-fire.  Why not?  But I do not recall everything.  By the same

 8     token, you remind me that there was a violation of the cease-fire by the

 9     BH Army.

10             THE ACCUSED: [Interpretation] Thank you.

11             Can this document be admitted, and can I then call up another

12     one?

13             I think we can move into open session now.

14             JUDGE KWON:  Yes.  While we are going back to open session:

15     Ms. Edgerton, can I see this document, the first page?  What is your

16     observation, Ms. Edgerton?

17             MS. EDGERTON:  Again, on the authenticity of the document, I have

18     no objection.  As to the relevance, I think it's marginal and had little

19     relation to the ultimate question.

20             JUDGE KWON:  Thank you.

21                           [Trial Chamber confers]

22             THE ACCUSED: [Interpretation] If I may, because this is two days

23     before the incident.

24                           [Trial Chamber confers]

25             JUDGE KWON:  The Chamber finds it relevant, and then we'll admit

Page 4300

 1     it.

 2             THE REGISTRAR:  As Exhibit D334, Your Honours.

 3             JUDGE KWON:  Yes, we go back to open session.

 4                           [Open session]

 5             THE ACCUSED: [Interpretation] 1D1929, please.  We will skip a

 6     little and move to the 6th of April, and then we'll go back to the 20th

 7     and 21st of March.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   6 April, this is a letter sent by General Milovanovic, chief of

10     staff of the VRS, to the UNPROFOR in Zagreb and to Kiseljak.

11             Do we have it?  This is it.  We can look at the whole document,

12     but the text in the box is important.  I can read it in English or you

13     can read it for yourselves:

14             [In English] "On the 6th of April, 1993, while we were trying to

15     talk about the establishment of peace, the cease-fire was again violated

16     by Muslim-Croatian forces."

17             [No interpretation]:

18             [In English] "The outcome of today is eight dead, eight lightly

19     and two heavily wounded soldiers.

20             "Snipers were very active, especially in the city of Sarajevo."

21             [No interpretation]:

22             [In English] "Do you think that it can be endured much longer?"

23             [Interpretation] Therefore, the Army of Republika Srpska has

24     instructions to hold out as long as they can, and General Milovanovic is

25     actually reproaching me for asking them to withhold fire, but they can't

Page 4301

 1     stand it much longer because they have great losses, eight dead and eight

 2     wounded -- ten wounded.

 3             Do you agree that this is intolerable?

 4        A.   I think that we were in the midst of a conflict.

 5        Q.   Well, I think the first sentence talks about the restoration of

 6     peace, and it says the cease-fire was again violated, which means that a

 7     cease-fire had been in effect.

 8        A.   But if there was a cease-fire, it was the responsibility of those

 9     who had agreed upon the cease-fire to break it, depending on the

10     situation, but it was up to them.  It was their responsibility, and it

11     was according to their assessment that they should decide.

12        Q.   Do you see these localities in the second paragraph, Sarajevo,

13     Rajlovac, Nedzarici, Dobrinja, Lukavica?  (redacted)

14     (redacted)

15        A.   Could we move to private session, please?

16             JUDGE KWON:  Yes.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4302

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             THE REGISTRAR:  We're now in open session, Your Honours.

13             THE ACCUSED: [Interpretation] May we now have 1D1977, please.

14     And we've come to the 20th of March now, 1993, and the document is from

15     the Muslim army.

16             Yes, that's it, 2774.  We don't seem to have the translation of

17     it; is that right?  Then I'd like to tell you what the document is about,

18     and we'll have it translated:

19             "Republic of Bosnia-Herzegovina armed forces, 1st Corps, Sarajevo

20     Communications Centre."  And then it says "the Command of the Operative

21     Group Igman."  What's that?  Yes, Igman, the 20th of March, 1993.

22     Regular combat report.

23             MR. KARADZIC: [Interpretation]

24        Q.   I can stop there, Witness, and ask you this:  You said that the

25     structure of the Sarajevo Romanija Corps was derived from the JNA, the

Page 4303

 1     model of the JNA, and that's how it functioned.  Do you agree that the

 2     structure of the Muslim Army of BiH was also modelled on the JNA example

 3     and that the officer cadre was from the Yugoslav People's Army and the

 4     army was made up of the former reservists of the JNA?  Do you agree?

 5        A.   I noted, first of all, that there were very few professional

 6     career officers.  And by the way, yesterday you expanded on the case of

 7     the commander of the 10th Mountain Brigade, who was far from being a

 8     professional officer, which you and I both know, so I think they took on

 9     a lot -- a certain number of people who knew how to fight, and apart from

10     them, they would resort to some kind of mobilisation of men to turn them

11     into soldiers after a short training.  But they were not only reservists;

12     they were also people with no prior military experience.

13        Q.   Thank you.  Now, this regular combat report of the 1st Corps,

14     does it remind you of regular combat reports of the

15     Sarajevo Romanija Corps?  It's the same structure.  First of all, you

16     have information about the enemy under number 1 and then under 2, and so

17     on; right?

18        A.   Yes, certainly.  Well, I can't -- I do not read Serbo-Croat, so I

19     don't know whether this is intelligence on the enemy.  But if you say so,

20     I'll gladly believe you.  But I believe that, nevertheless, there was,

21     within the government's army, a number of officers with some military

22     experience and who were able to take on all the formal aspects of a

23     professional army.

24        Q.   Thank you.  And under 1, "Information about the enemy," I'll just

25     read out the first sentence:

Page 4304

 1             "Today, the Chetnik activities --"

 2             They refer to the Serbs with the term "Chetnik," although the

 3     Chetniks were the Royalist Army during World War II and we abolished both

 4     the Chetniks and Partisans, but they referred to us as Chetniks:

 5             "Now today Chetnik activities were of a lesser intensity compared

 6     to the previous day."

 7             And then it goes on to say where the shooting took place, but

 8     what is important is under number 2, information about our own forces:

 9             "Pursuant to an order from the commander of the Operative Group

10     Igman, our artillerymen opened fire from a 130-millimetre cannon with two

11     projectiles, 105-millimetre Howitzers with four projectiles, and a cannon

12     Howitzer, 152 millimetres, with 25 shells, against targets asked for by

13     the commander of the 1st Corps.  The Chetniks returned fire in the area

14     of infantry weapons with four projectiles, MB-82.  We shot at Chetnik

15     positions in the area of Orlovac, where the Chetniks were setting up new

16     firing positions.  Our artillerymen used 82- and 120-millimetre mortars,

17     firing five shells at the village of Vojkovici and the Sumanska [phoen]

18     School.  With rapid intervention from our fighters, we were able to

19     localise a fire that broke out in Lasica," et cetera, "Sabro Haskovic,

20     who was the Chief of Staff of the operative group."

21   (redacted)

22   (redacted)

23   (redacted)

24        A.   Can we move to private session?

25             JUDGE KWON:  Yes.  Yes, we'll go into private session.

Page 4305

 1           [Private session] [Confidentiality partially lifted by order of Chamber]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5             Indeed, this report comes from 1st Corps units, which confirms

 6   (redacted) that the 1st Corps had units also outside of

 7     Sarajevo, because this one is Mount Igman, and actually I didn't know

 8     that there was a Sumanska School in Zenica [as interpreted], but if you

 9     say so, I gladly believe you.  And probably they fired on this school in

10     Ilidza.  And I see that in spite of the cease-fire that had been violated

11     by the Bosnian forces, the Serbian forces fired back.

12             MR. KARADZIC: [Interpretation]

13        Q.   Thank you.  And you can see that they returned fire at their

14     artillery pieces using four projectiles and their firing positions?

15        A.   It may be that their fire was more accurate than the Bosnian

16     fire.  That's what I hope.

17        Q.   Thank you.  But do you agree that Vojkovici was also -- well,

18     that it was between Butmir and Hrasnica, that that's where the location

19     was?

20        A.   Yes.

21             THE ACCUSED: [Interpretation] Thank you.

22             I tender this document into evidence now.

23             JUDGE KWON:  Shall we mark it for identification, unless it is

24     objected to?  Yes, we'll mark it for identification.

25             THE REGISTRAR:  As MFI D346, Your Honour.

Page 4306

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Before we go into open session, let me ask you this:  Would you

10     assess this as being intensive activity, with shells falling on Serb

11     positions?  And this is from their sources, so there can be no doubt;

12     right?

13        A.   What subject would you like to speak about regarding my estimate

14     of this activity, on Bosnian or Croat or Muslim side?

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4307

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             THE REGISTRAR:  We're back in open session, Your Honour.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   I'm now going to put before you a claim.  I'm going to put

 7     something to you.  You might know about it; you might not.  This is what

 8     I state: that Mr. Izetbegovic was against any negotiations, that the

 9     incidents took place either just before some conference or during the

10     conference, itself, and that served his purpose to interrupt the

11     conference.  Do you have any ideas about that?

12        A.   I noticed this, I observed, and I said so in previous reports,

13     that indeed during negotiations there was often disproportionate use of

14     artillery on either side, no matter who had started the artillery fire.

15        Q.   Thank you.  And if I tell you that the Serbs wanted to have

16     agreements signed as soon as possible because they had no further

17     ambitions of taking control of any more territory, would that sound

18     logical to you, would you accept that?

19        A.   It's not for me to assess political statements.

20        Q.   Then we'll leave the political arena and move on.

21             Now, this is already the 21st of March.  1800 hours is the time.

22     We don't seem to have a translation, unless Ms. Edgerton surprises me

23     pleasantly again.  Not this time; very well.  So I'll read it out.

24             This is from the Command of the Sarajevo Romanija Corps, strictly

25     confidential, then the number and date, which is the 21st of March, 1993.

Page 4308

 1     Regular combat report as of 1800 hours, the situation up to 1800 hours.

 2     And the first sentence, it says:

 3             "From the direction of Mojmilo, an 82-millimetre mortar was fired

 4     and multiple rocket-launcher, targeting the Slobodan Princip Seljo

 5     Barracks.  At around 1700 hours, five shells, 82-millimetres, fell in the

 6     area of Pavlovac [phoen], eight fighters wounded," and so on.

 7             May we now move on to paragraph 2.  It says:

 8             "The unit which carried out the attack was open to crossfire from

 9     Igman, Dobrinja, and Mojmilo."

10             And now paragraph 6 next, please:

11             "The rear security," and then it says, "units of the corps need

12     replenishment with ammunition, fuel, and reserve parts, spare parts."

13             Can you see, Witness, that there's not a single word -- no

14     mention at all of shelling in the center of Sarajevo, that General Galic

15     makes no mention of that at all?  Or, rather, this is his deputy.

16     Colonel Marcetic is the name.

17        A.   Well, I could answer your question if I had a translation into

18     English of the text.

19             THE ACCUSED: [Interpretation] Thank you.

20             May we turn to the next page of this document.  I read it out,

21     and the interpreters certainly translated it accurately.  But let's move

22     on to the next page.  This is in addition to the regular combat report,

23     that is to say, after 1800 hours.  Colonel Marcetic received more

24     information about another brigade.

25             May we move down the page, please.  That's right.

Page 4309

 1             And it says:

 2             "During the afternoon --"

 3             Point 1:

 4             "During the afternoon, the positions of the artillery of the

 5     Kosevo Brigade, Nahaversko [phoen] Brdo, was shelled by 14 mortar

 6     grenades and four projectiles fired from a ZIS cannon from the direction

 7     of Kum -- Hum, Zuc, and Orlic.  Inflammatory grenades set fire to a

 8     forest around the firing positions of the artillery.  The Kosevo Brigade

 9     is therefore relocating its artillery pieces and establishing line

10     communications.  Fierce artillery attack was carried out along Elevation

11     703 at Brijeg, with -- a Browning and other weapons were used to shoot

12     from the direction of Hum, Sip, and Kobilja Glava."

13             MR. KARADZIC: [Interpretation]

14        Q.   Not a word there about the shelling of the old city, Witness.

15     And let me remind you that we were in New York, attending the conference.

16             What do you say to that?

17        A.   I only believe the reports from the UNMOs who were then present,

18     spread over a number of observation posts in -- around Sarajevo and in

19     the Greater Sarajevo.

20        Q.   Thank you.  But, Witness, according to these reports, there was

21     heavy fighting, and there is no mention of that in any of the reports.

22     And you'll see a report from the 1st Corps next.  The Muslim report makes

23     no mention of that either.  So do you exclude the possibility of -- well,

24     the translation wasn't correct.

25        A.   Could you please rephrase your question?  I didn't understand it

Page 4310

 1     very well.

 2             JUDGE KWON:  He hasn't finished his question.  But could you

 3     repeat your question, Mr. Karadzic?

 4             MR. KARADZIC: [Interpretation] Yes.

 5        Q.   So according to what is said here about the incident of the 21st

 6     of March, it was heavy fighting with 2.000-odd shells, no mention of that

 7     is made either in the media - we have agency reports - it's not mentioned

 8     by the Sarajevo Romanija Corps, and now you'll see that not even the

 9     1st Corps mentions any of that.  (redacted)

10   (redacted)

11   (redacted)

12        A.   Can we move into private session?

13             JUDGE KWON:  Yes.

14             MS. EDGERTON:  And if I may, Your Honour, a redaction of --

15         [Private session] [Confidentiality partially lifted by order of Chamber]

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22             THE WITNESS: [Interpretation] Let me return to the reliability or

23     credibility of the system of observers that had been set up around and

24     within Sarajevo.

25             As all UN forces, there were people hailing from various

Page 4311

 1     countries.  They were professional servicemen.  They had been trained to

 2     observe artillery fire, incoming fire or outgoing fire, so I totally rule

 3     out any error from them that would concern several thousands of shells.

 4     They may have made mistakes as to a score, or even 200 or 300 shells,

 5     okay, but they could not have reported on 2.400 shells -- they can't have

 6     been wrong throughout and that only 200 or 300 shells had been fired on

 7     that day.  So I really fully believe -- I give credence to all the UNMO

 8     reports, the other reports being, of course, sort of biased reports

 9     because they had been drafted by the warring parties.

10             JUDGE KWON:  Thank you.  We'll go back to open session.

11                           [Open session]

12             JUDGE KWON:  And we'll have a break for 25 minutes.

13                           --- Recess taken at 5.21 p.m.

14                           --- On resuming at 5.50 p.m.

15             JUDGE KWON:  Yes, Mr. Karadzic.

16             THE ACCUSED: [Interpretation] May I ask how we are with time?

17     This is a very precious opportunity for the Trial Chamber to get a full

18     picture of the events in Sarajevo, and we still haven't touched upon many

19     things from the cross-examination, from numerous witness statements, and

20     the work on the maps.  We would need to present a series of maps here so

21     that the Trial Chamber can finally understand what Sarajevo really is and

22     see what was located where.  Can we get more time, perhaps, and finish

23     this nicely tomorrow?

24             JUDGE KWON:  Before I entered the courtroom just now, I was

25     advised that you have had three hours and twenty minutes so far.  So you

Page 4312

 1     have still one hour and forty minutes, and we'll see how -- where we'll

 2     be at the end of the five hours and see.  But how many more hours do you

 3     anticipate in order to finish your cross-examination at this time?

 4             THE ACCUSED: [Interpretation] I was hoping to finish tomorrow,

 5     leaving perhaps some time for redirect by Ms. Edgerton.

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  Mr. Karadzic, we'll see how you get on with the

 8     evidence by the end of today, and we'll consider the matter.

 9             THE ACCUSED: [Interpretation] Thank you.

10             May this document be admitted, the 21st of March report from the

11     Sarajevo Romanija Corps and an appendix to it?  This is the supplement.

12     We can also see the first page again for you to refresh your memory.

13             Let's see the first page.  Thank you.

14             This is a report of the Sarajevo Romanija Corps to the Main Staff

15     on the 21st of March, status at 1800 hours, and the supplement speaks

16     about the events in the Kosevo Brigade.

17             JUDGE KWON:  And the witness wanted to see a map in relation to

18     this report, didn't he?

19             THE ACCUSED: [Interpretation] Absolutely.

20             JUDGE KWON:  Ms. Edgerton.

21             MS. EDGERTON:  I have no objection to this document, Your Honour.

22             JUDGE KWON:  Yes.  We'll mark it -- admit it and be marked for

23     identification.

24             THE REGISTRAR:  As Exhibit MFI D347, Your Honours.

25             THE ACCUSED: [Interpretation] Thank you.

Page 4313

 1             Can we now see 1D1981, 1D1981.

 2             This is a report from the same day, a report by the 1st Corps of

 3     the BH Army.  If the Prosecution does not have a translation, then I will

 4     read aloud the passages that I believe to be important.

 5             JUDGE KWON:  Yes.

 6             MS. EDGERTON:  We do, Your Honours.

 7             JUDGE KWON:  We'll put it on the ELMO.

 8             Yes.  What is your question, Mr. Karadzic?

 9             THE ACCUSED: [Interpretation] Could we see the whole document?

10     Oh, it's on the ELMO.

11             MR. KARADZIC: [Interpretation]

12        Q.   So it's dated 21 March 1993, and in the first paragraph the corps

13     notifies the command of the corps about the fire exchanges on that day,

14     and it says the Chetniks, in fact, the enemy, launched a fierce artillery

15     attack early in the morning on the 4th Motorised Brigade's area of

16     responsibility, and this brigade was outside of Sarajevo.  The enemy

17     fired tanks, carriers and Praga self-propelled anti-aircraft guns from

18     the direction of Gavrica Brdo, Kula, and so on, and sports airfield.

19             There's a mistake here in this translation.  It was actually

20     against the defence area of the 4th Motorised Brigade, not the area of

21     responsibility.  An area of responsibility is wider than a defence area.

22             They claim two shells containing chemical poison landed.  That's

23     not true.  But we see also what kind of movements were executed,

24     et cetera.

25             Can we now see Article 2.

Page 4314

 1             So in the original, it says "defence area."  That means on the

 2     lines.  And then in the middle, it says:

 3             "On request -- at the request of the 1st Corps Command and for

 4     the purpose of supporting our forces in the general areas of Nedzarici,

 5     Stup, Azici, our artillery fired on targets as follows:

 6             "1.  A 152-millimetre Howitzer fired 60 shells on the targets of

 7     TAT, Otes, a railway bridge at Zeljeznica.

 8             "2.  Following authorisation from the 1st Corps Command, a

 9     multiple rocket-launcher, with 107-millimetre calibre, fired seven

10     missiles on the Golo Brdo area.

11             "The Chetniks responded by firing five 105-millimetre Howitzer

12     shells on Malo Polje, with little effect."

13             And then it goes on to say:

14             "In combat so far, we've had 21 injured fighters and four dead."

15             I've finished this quote.

16             Do you see that all this is happening outside the urban area,

17     outside the populated area; it's fire on lines?

18        A.   From what I understood, and if I can recollect vividly what

19     happened, this has to do with the western part of the Greater Sarajevo

20     area.  It's the western side of the airport and, more specifically, west

21     or north-west, in the airport area.

22        Q.   You're right about that.  It's all very close, and the shells

23     were obviously coming from Mount Igman and they were falling, obviously,

24     in the urban part.  And the response was against their defence lines, not

25     their areas of responsibility?

Page 4315

 1        A.   What is the difference between "lines" and "defence lines"?  I

 2     don't quite understand.

 3        Q.   "Defence lines" and "defence areas" are one and the same things,

 4     but it's not the same thing as "area of responsibility."  "Area of

 5     responsibility" is what we have in the English translation here

 6     mistakenly, and it's a much wider area than defence area.  Defence areas

 7     and defence lines are considered to be the same in our terminology.

 8        A.   Well, if you will, all countries do not use the same words, but

 9     I think I understand what you mean.

10        Q.   Would you agree that an area of responsibility is a broader

11     concept than an area of defence?

12        A.   In my country, we do not talk about defence areas.  We talk about

13     front-lines.  Perhaps that's what you're talking about.  The front-line

14     is the line where you are in contact with the opponent, and the area of

15     responsibility, indeed, goes deeper in the friendly setup.

16        Q.   Thank you.  From all these documents, both Serbian and Muslim, is

17     it evident that fire is directed against legitimate targets?

18        A.   Indeed, in the western part of the city this is what had been

19     observed by the UN Military Observers, and this corresponded to combat

20     actions.

21             THE ACCUSED: [Interpretation] Thank you.

22             May this document be admitted?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  As Exhibit D348, Your Honours.

25             THE ACCUSED: [Interpretation] Can I now call up 1D1514.

Page 4316

 1             While we're waiting:  This will be a report from the

 2     Sarajevo Romanija Corps, a regular combat report at 1400 hours, addressed

 3     to the Main Staff, covering the 21st of March.  That is the day after the

 4     incident.

 5             If the Prosecution does not have a translation, shall I go on?

 6             JUDGE KWON:  I think I heard the printing is going on.

 7             MS. EDGERTON:  That's right, and we have the translation.

 8             JUDGE KWON:  Thank you.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Can we now see that this is the 21st of March, 1993, a report to

11     the Main Staff at 1400 hours?  The first paragraph says:

12             "In the course of the day, the enemy continued intensive fire

13     from artillery against Ilidza, which was targeted by about 200

14     projectiles, causing losses among civilians, both dead and wounded."

15             Point 2 -- sorry, point 3:

16             "The status on the territory without major changes.  The safety

17     of citizens is in jeopardy due to intensive fire from enemy artillery

18     against populated areas."

19             But there is nothing in this report firing on the city?

20        A.   No, indeed.  If I translate into military terms

21     paragraph number 2, indeed, the Romanija Corps must have launched an

22     offence operation because it reached lines, and it also says that the

23     Ilidza Brigade is engaged on an offensive operation against Stup or in

24     the direction of Stup.  So there you go.  But you know as well as I do

25     that in this area, there were a lot of urban dwellings, and, as usual,

Page 4317

 1     there must have been a lot of collateral damages.

 2        Q.   But we've heard here from witnesses, beginning with April 1992

 3     and onwards, that attacks at Ilidza are staged from Otes, and finally the

 4     VRS took this Otes and removed this threat.  There were constant attacks

 5     before that, and we have plenty of documentation about that.  But what I

 6     want to underline here is that 200 projectiles fell on Ilidza.  Did this

 7     point find its way into the observers' reports?

 8        A.   I think that as myself, you saw the document that we saw

 9     yesterday, which was very clear, very precise.  And there was the

10     assessment of the sector commander which was also very clear, as we could

11     see it in the document.

12        Q.   Well, I'm afraid the observers did not really remark upon

13     projectiles falling on Serbian neighbourhoods.  But this is a report from

14     the day after.  Two hundred shells fell on this neighbourhood, Ilidza,

15     and I'm sure you would have noticed and reported if those had been

16     Serbian shells.

17        A.   Could you please repeat your question?  I think we're going

18     astray.  I don't quite understand the point of your question.

19        Q.   Well, my main thrust is to see what, in Serbian and Muslim

20     regular combat reports for the 21st of March and around that date, what

21     is contained about fire against civilian targets.  There's nothing of the

22     sort, is there?

23        A.   I see this document for the first time, and I'm trying to read it

24     and to interpret it.  I see that this is a report on a situation that

25     happened at 1400 hours on the 22nd and not on the 21st.  And as far as

Page 4318

 1     I'm concerned, I believe that if the Serbian force procedure was the

 2     same, we are only dealing with what happened on the 22nd.

 3        Q.   Well, the point is there's no trace, either in Serbian or Muslim

 4     regular combat reports, about an event of this magnitude.

 5             Now, Witness, is it the case that in order to put an end to a

 6     peace conference they didn't like, is it possible that Muslims staged an

 7     attack on their own people and their own installations, as they have done

 8     more than once?

 9        A.   I do not want to speculate on manoeuvre plans of the Bosnian

10     side.  What is certain is that the target of their initial attacks,

11     namely, in the area of the 10th Mountain Brigade, when they were firing

12     at the supply route to Pale, they could be assured that there would be a

13     strong response from the Serbian forces, because all military men that

14     were in the area knew full well that the Serbian forces were very good at

15     sustaining --

16             THE INTERPRETER:  Or at applying, correction of the interpreter.

17             THE WITNESS: [Interpretation] -- artillery fire, but they didn't

18     have sufficient infantry to respond through that means.  And we actually

19     realised on several occasions that when the BH Army was launching

20     offensive attacks, the Serbs would mainly respond by launching artillery

21     fire and by pounding, through the artillery, in order to make sure that

22     the BH Army attack would stop.  This is my comment.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can this document be admitted?

25                           [Trial Chamber confers]

Page 4319

 1             JUDGE KWON:  It's not related to 21st of March, and the witness

 2     did not comment on anything about the document.  So I find the Chamber is

 3     not satisfied with its relevance.  As such, we'll not admit this.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Can we get 1D1860.  Oh, sorry, it's D336.  It's already an

 6     exhibit, a document by Colonel Wilson.  I think he later became

 7     brigadier.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   And while we're waiting, let me ask you, Witness:  Do you recall

10     that the incident in the bread line served to put an end to the

11     Lisbon Conference in May 1992, the 27th May 1992?  Do you remember that

12     while we were negotiating in Lisbon, there was an incident in the bread

13     line, and it served as a reason for terminating the conference?

14        A.   You're talking of which year?

15        Q.   1992.  I'm not asking you about your direct knowledge.  I just

16     want to see if you remember, because I want to point out some analogies.

17        A.   No, I do not remember that.  I was not there in person.  I cannot

18     recall, and I'm not in a position to talk about it, given that I have no

19     information whatsoever regarding this incident.

20        Q.   Thank you.  I will show you very soon a document that indicates

21     that you were normally informed about incidents from 1992, and you

22     referred to them later, but, of course, one can't remember everything.

23             Can we see lower in this document?

24             The BH Army overview of military situation.  This is the military

25     situation in Bosnia-Herzegovina and forecasts.

Page 4320

 1             In the middle, it says:

 2             "The BH Army offensive in Sarajevo would appear to remain on

 3     hold."

 4             Can we now get the next page?

 5             Did you notice this was the 21st of January, 1993?

 6        A.   Yes, I've noticed that.

 7        Q.   Thank you.  Let us look at paragraph 6:

 8             [In English] "No major developments --"

 9             [Interpretation] I won't read it aloud.  Everyone can read it.

10             These are forecasts of Serbian objectives and intentions, and it

11     is estimated and forecast that the Bosnian Serb army would remain in a

12     defensive posture and rely on its superiority and indirect fire, as you

13     confirmed a moment ago yourself, to deflect any BH Army offensive; is

14     that correct?

15        A.   Yes, it fits in with what I've just said.

16        Q.   Thank you.  Can we see lower down about the BH Army?  This

17     passage was about the Army of Republika Srpska.

18             Now we see the BH Army at paragraph 9:

19             "BiH Army forces will ..."

20             [In English] "BiH Army forces will, as a priority, continue to

21     apply pressure to disrupt BSA lines of communication and strengthen their

22     links to the Srebrenica and Gorazde pockets in Eastern Bosnia ..."

23             [Interpretation] Further down, it says:

24             [In English] "They would also assist in ensuring BSA compliance

25     with territorial agreement and place BiH Army forces in an advantageous

Page 4321

 1     position for a resumption of hostilities which they probably regard as

 2     inevitable."

 3             [Interpretation] So this was a week before the commencement of a

 4     major combat there began on the 31st of January, and this forecast by

 5     Colonel Wilson, later General Wilson, was pretty much on the ball?

 6        A.   Yes, I think that, in hindsight, it was pretty good.

 7        Q.   Can we see from these last few sentences that I read out that the

 8     Muslim army believed that once territorial agreements are reached, they

 9     will be in a good position to continue hostilities?

10        A.   This is what it says.

11             THE ACCUSED: [Interpretation] Can we see the next page, please.

12             The second paragraph of paragraph 11:

13             "BH Army forces ..."

14             [In English] "BH Army forces may be prepared to launch an

15     offensive using their troops without Croat support.  If they believe

16     their position in peace negotiations is so weak, they must provoke for an

17     intervention."

18             [No interpretation]:

19             "In summary, BH Army forces military objectives are assessed as:"

20             [No interpretation]:

21             "D.  Launch an offensive in the Sarajevo area if they consider

22     their bargaining position in negotiations untenable and intervention is

23     the only resource [sic]."

24             [No interpretation]:

25             [In English] "Continue to re-arm and build up forces and

Page 4322

 1     resources for a resumption of war when they are in a more advantageous

 2     position."

 3             MR. KARADZIC: [Interpretation]

 4        Q.   I won't bother you any more with this document, but it's obvious

 5     that UN analysts estimated quite correctly that the BH Army will be

 6     pushing offensives, and even if a territorial agreement is reached, then

 7     the Serbs withdraw to the provinces assigned to them, they would continue

 8     the war, whereas the Serbian side would opt for defence.  Is that so?

 9        A.   First, I would like to thank you for talking abut how good the UN

10     members were at forecasting events.

11             THE ACCUSED: [Interpretation] Thank you.

12             This document has been admitted.

13             Could we now call up 1D1470.  This comes after the forecast we

14     looked at earlier.  It's a regular combat report from the

15     Sarajevo Romanija Corps, dated 31 January 1993.  I don't know if we have

16     a translation.  Courtesy of Ms. Edgerton, we will get a translation.

17             JUDGE KWON:  I think we have quite a system.  Thank you very

18     much, Ms. Edgerton.

19             THE ACCUSED: [Interpretation] I would like to recall that the OTP

20     and the Defence team are negotiating an exchange of documents that have

21     already been translated, so as to facilitate everyone's work.

22             Let's see what the translation is like.  It says that:

23             "In the afternoon, the enemy carried outer a powerful artillery

24     operation against the Ilidza area with about 40 mortar shells firing from

25     Kovaci and Glavogodine, against the Rajlovac area with 16, 82-millimetre

Page 4323

 1     mortar shells from the Zuc area," et cetera.

 2             And then point 2:

 3             "In a successful counter-attack, units of the 1st Romanija

 4     Infantry Brigade managed to push back the enemy's line of defence in

 5     front of the village of Mrkovici, between 500 and 800 metres."

 6             You can read the rest of it.  However, in paragraph 3.1, it says

 7     a UN member, who I won't mention, protested because the UNMO building at

 8     Brijesce Brdo, which clearly bore the UN flag, had recently been

 9     subjected to artillery fire:

10             "He was told that the SRK Command did not have the locations of

11     their observation posts and asked that they be to submit to them, which

12     would enable us to secure them from our artillery.  (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22             JUDGE KWON:  Just a second.

23             Yes, Ms. Edgerton.

24             MS. EDGERTON:  I may be mistaken, but I think we're in open

25     session.  Aren't we, Your Honours?

Page 4324

 1             THE ACCUSED: [Interpretation] But there's nothing there that

 2     is --

 3             JUDGE KWON:  We'll go into private session.

 4            [Private session] [Confidentiality partially lifted by order of Chamber]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4325

 1     They did not know where the location of the observation posts were, as

 2     it's stated in this document, but all those observation posts had a large

 3     UN flag, so I believe it was not very difficult even if you did not have

 4     the exact coordinates of the observation posts, and I would doubt about

 5     that.  But it was quite easy to know where they were and to shelter them.

 6     So as far as I'm concerned, I should like to say that every time

 7     observation posts were subjected to artillery fire, I would believe that

 8     these were voluntary fire.  And they knew full well what they were doing,

 9     those who were firing.

10             MR. KARADZIC: [Interpretation]

11        Q.   Well, you see this document, which is a secret report to the

12     Main Staff, says the reverse, (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16             But look at point 6.  They insisted that an inspection be allowed

17     of a communications, and they were told that there were sabotage

18     terrorist groups there, which is correct, because I didn't use the road

19     anymore.

20             And then point 7, they particularly insisted that the container

21     be removed because it was obstructing traffic, and their response was to

22     say that the container was set up as a protection from sniper fire.  And

23     in both documents, it says that it will be removed -- or this document

24     says that in point 7:

25             [In English] "They were told that we were not aware of the

Page 4326

 1     agreement with General Gvero.  If it is correct, we will remove the

 2     container to the side of the road or place three metal plates parallel to

 3     the road in order to protect ourselves from the snipers."

 4   (redacted)

 5   (redacted)

 6        A.   May I comment on this?

 7             Firstly, I'm rather surprised, to say the least, as I said this

 8     before -- the Serbian forces were part of a professional army, and I

 9     would be surprised that they would not know where the UNMOs were

10     positioned in their OPs, so that is really quite a doubt in my mind.

11             And, secondly, I recalled to you that if we were so concerned

12     about the container in the Kasindolska Street, it was because it was the

13     very spot where the Bosnian vice-prime minister had been assassinated by

14     a soldier [as interpreted].

15        Q.   Witness, do you agree that regardless of a number of professional

16     officers, it wasn't an office -- well, there weren't enough professional

17     officers in the Sarajevo Romanija Corps; would you agree with that?

18     There were officers, but were there a sufficient numbers of professional

19     officers?

20             THE INTERPRETER:  Interpreter's correction:  By a Serbian

21     soldier.

22             THE WITNESS: [Interpretation] All the officers (redacted)

23     in the Romanija Corps were former JNA officers, and I believe that

24     the JNA was a professional army.  And there seemed to be quite a few of

25     them.  It may be that there were less of them in the combat units.  I

Page 4327

 1     couldn't ascertain that because I could not access the Serbian combat

 2     lines.

 3             MR. KARADZIC: [Interpretation] Thank you.

 4        Q.   But we agreed, did we not, that the Muslim officers came from the

 5     JNA as well; right?  Where was Delic from, Halilovic, Hadzihasanovic,

 6     Hajrulahovic; were they high-ranking officers of the Yugoslav People's

 7     Army?

 8        A.   They were not senior JNA officers.  All the generals in the

 9     Bosnian Serb Army were JNA soldiers.  The generals from the Bosnian Army

10     that (redacted) were former majors or captains of the Serbian Army,

11     but I'm sure that this is not the topic or one of the issues of this

12     trial and that we may be going astray.  I could talk about this at

13     length.

14        Q.   Okay, I agree.

15             THE ACCUSED: [Interpretation] But -- is this document an exhibit

16     already?

17             JUDGE KWON:  I don't think so.  We'll admit it, unless it is

18     objected to.  He talked about the visits.  Yes, we'll admit it.

19             THE REGISTRAR:  As Exhibit D349, Your Honours.

20             THE ACCUSED: [Interpretation] May we now have 1D1940 next,

21     please.

22             MR. KARADZIC: [Interpretation]

23        Q.   And while we're waiting, Witness, let me ask you this:  Do you

24     agree with what other witnesses have stated here, and I think you said it

25     at one place, that the combat composition of Sarajevo Romanija Corps were


Page 4328

 1     ordinary people doing their job, and that they would go up to the lines

 2     in shifts when their turn came; right?

 3        A.   Oh, I think you totally misunderstood me.  I was speaking about

 4     the Bosnian 1st Corps.  As to the Romanija Corps from Lukavica, what I

 5     could see, and especially so when I went to artillery battery positions

 6     without you knowing it being said by the side, I saw that there were

 7     reservists or people doing their military service, but I do not think

 8     that they could go back home because a number of them hailed from

 9     Sarajevo proper.

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             THE REGISTRAR:  We're back in open session, Your Honour.

18             THE ACCUSED: [Interpretation] That's the right document.

19             MR. KARADZIC: [Interpretation]

20        Q.   Now, on the 31st of January, the Sarajevo Romanija Corps asked to

21     be sent the coordinates of observation posts, and they were sent.  And

22     with this document, the Sarajevo Romanija -- the Command of the Sarajevo

23     Romanija Corps on the next day, that is to say, the 1st of February, is

24     sending all brigades of the Sarajevo Romanija Corps, the 4th Mixed

25     Artillery Regiment, and everybody else, this and says:

Page 4329

 1             [In English] "We requested and received the exact coordinates of

 2     UNPROFOR's observation posts, both on our side and the Turk side."

 3             [Interpretation] They're referring to the Muslims as Turks here.

 4             So there we have all the observation posts, and it says at the

 5     bottom:

 6             "After you receive these coordinates, inscribe them on the maps."

 7             [In English] "Familiarise your immediate subordinates, especially

 8     commander of the Artillery Battalion, with their exact location, and

 9     prevent firing against the observation posts, especially prevent

10     artillery fire against them, under any condition, in any way and by

11     anyone's side.

12             "After UN Military Observers' request from any observation post

13     in our zone, i.e., on our side, offer maximum protection and assistance

14     to UN members.

15             "Sites of observation posts coordinates are strictly confidential

16     by its character, and it must not fall in possession of unauthorised

17     persons."

18             [Interpretation] Do you see that the Sarajevo Romanija Corps

19     reacted promptly, straight away?  The next day, it sent out the

20     coordinates and asked that they be introduced onto the maps, and gave

21     strict orders not to open fire?

22        A.   Well, I can only congratulate the Romanija Corps for such an

23     attitude.

24             THE ACCUSED: [Interpretation] Thank you.

25             I'd like to tender this document now, please.

Page 4330

 1                           [Trial Chamber confers]

 2             JUDGE KWON:  Ms. Edgerton, since it is related to the document

 3     which we already admitted, i.e., the Exhibit D349, the Chamber is of the

 4     view that this can be admitted as well.

 5             MS. EDGERTON:  Yes, only on the basis of that link, there's a --

 6     yes.

 7             JUDGE KWON:  Yes, that will be admitted.

 8             THE REGISTRAR:  As Exhibit D350, Your Honours.

 9             THE ACCUSED: [Interpretation] Thank you.

10             May we now have 65 ter 12359, please.  65 ter 12359.

11             And while we're waiting, let me inform you that it is a regular

12     combat report of the 3rd of February, 1993.  That means from the 31st of

13     January -- on the 31st of January, we had that meeting with the colonel,

14     and on the 1st of February the coordinates were inscribed.  On the 3rd of

15     February -- the 3rd of February is this document, and I'd like us to turn

16     to page 3, please.

17             And may we go briefly into private session?

18             JUDGE KWON:  Yes.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 4331











11  Pages 4331-4333 redacted. Private session.















Page 4334

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 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             THE REGISTRAR:  We're back in open session, Your Honours.

11             THE ACCUSED: [Interpretation] May we now have 1D1491, please.

12             While we're waiting, and that's a document dating back to that

13     same period, but let me ask you this in the meantime:

14             MR. KARADZIC: [Interpretation]

15        Q.   Do you know that the Muslim forces used the Marsal Tito Barracks

16     for their firing positions and for opening fire at the Serbs?

17        A.   No.

18        Q.   I mentioned earlier on the protests from General Sidorenko in

19     1992 to General Siber and the demand that they be removed from the radars

20     and Marsal Tito Barracks.  And this is a regular combat report, dated the

21     4th of March, to the Main Staff, sent by the Sarajevo Romanija Corps.

22             Perhaps there's a translation.  Does the Prosecution have it?

23             I really do envy the Prosecution.  They have everything, and we

24     have nothing.

25             [In English] If you can put it a little bit down to see the head.

Page 4335

 1     Okay, then you lift it a little bit.  Okay, that's enough.

 2             THE INTERPRETER:  Microphone, please.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Witness, do you see what it says there:

 5             "During the day, the enemy did not respect the cease-fire and

 6     fired from the Srhinje and Visocica sector at civilian targets in Ilijas

 7     and Podlugovi, firing 15 shells.  Similarly, an enemy 120-millimetre

 8     mortar fired from the Marsal Tito Barracks at civilian targets in

 9     Grbavica.  There was an infantry attack," et cetera, et cetera.

10             So we are claiming that the Marsal Tito Barracks was regularly

11     used as a place from where to fire at our positions from, and you can see

12     that our civilian targets were also shot at.  What do you have to say to

13     that?

14        A.   I have two things to tell you.

15             First thing:  As I said earlier on, the Bosnians were

16     endeavouring to protect their mortars by making them as mobile as

17     possible.  Well, whether they fired them from the vicinity of the

18     Marsal Tito Barracks, that's no surprise at all to me, but that was not a

19     position, a mortar position, all the more so because that's where the

20     Ukrainian Battalion was stationed, and I don't think that they were

21     particularly favourable to the Bosnians.

22             Second thing:  You remind me of the Marsal Tito Barracks, and

23     maybe we could speak about the fact that there were radars, artillery

24     radars, in the barracks, aimed at detecting artillery fire.  As soon as

25     they were set up by the Ukrainian Battalion, they were silenced and

Page 4336

 1     damaged by artillery fire that, no doubt, did not come from the Bosnian

 2     side.

 3             But maybe I'm teaching you something here.

 4        Q.   Well, I can tell you that we have friendly feelings towards

 5     Ukraine, and we can also say that the Serb side would not have any motive

 6     to do them any harm.

 7             But while we're on the subject, let me ask you this:  We had

 8     witnesses here who said that there did exist certain differences in how

 9     the individual nationalities viewed events in Bosnia-Herzegovina. 

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18             JUDGE KWON:  Yes.

19             MS. EDGERTON:  Are we in open session?

20             JUDGE KWON:  Yes, I understood.

21             Let's move on.

22             THE ACCUSED: [Interpretation] Thank you.

23             I'd like to tender this document.  The witness has just confirmed

24     that there was the possibility of them not having permanent but temporary

25     firing positions, and that they moved around and hid behind the barracks.

Page 4337

 1     And that's our experience too.

 2             JUDGE KWON:  The witness didn't confirm anything about the

 3     document.

 4             THE ACCUSED: [Interpretation] Well, he couldn't have known about

 5     this document because it was strictly confidential.  But as a phenomenon

 6     as what was going on, that's something that he confirmed.

 7             JUDGE KWON:  The Chamber will not admit this document.

 8             I note the time, Mr. Karadzic.  You have spent about four hours

 9     twenty minutes so far, a bit more than that, but how much longer would

10     you need tomorrow to conclude your cross-examination?

11             THE ACCUSED: [Interpretation] Two to two and a half sessions.  If

12     not two and a half, then at least two sessions.  And I promise that it

13     will be of interest to the Trial Chamber as well.

14                           [Trial Chamber confers]

15             JUDGE KWON:  It may depend on the remainder of the

16     cross-examination.  But how much -- how long would you expect your

17     redirect examination to be, Ms. Edgerton?

18             MS. EDGERTON:  Twenty minutes at the outside, Your Honour.

19             JUDGE KWON:  Let's try to conclude the witness's evidence by the

20     end of second session tomorrow.  So you will have about two hours, in the

21     region of two hours.

22             So we'll continue, Mr. Witness, tomorrow afternoon.

23             And there's one final administrative matter to discuss, albeit in

24     the presence of the witness.

25             Yesterday, when I informed the parties as to the sitting

Page 4338

 1     schedule, I was mistaken; that on the 15th of July, there's no courtroom

 2     available to sit from the morning.  So the 15th July, we'll rather sit in

 3     the morning -- in the afternoon shift, i.e., from 2.15 to 7.00 p.m.  But

 4     on 8th, 16th, 19th, 20th, and 21st and 22nd of July, there seems to be a

 5     possibility for the Chamber to sit 9.00 to 3.00, so we'll sit -- do so in

 6     that way whenever possible.

 7             THE ACCUSED: [Interpretation] And if I may be allowed to say that

 8     I prefer the afternoon sessions.  But I leave that to --

 9             JUDGE KWON:  Could you tell us why it is so?

10             THE ACCUSED: [Interpretation] It might be my biorhythm, as such.

11     I work better in the afternoon.

12             JUDGE KWON:  Very well, we'll consider the matter tomorrow

13     afternoon.

14             Yes, Mr. Tieger.

15             MR. TIEGER:  Mr. President, it's a matter that didn't need to be

16     dealt with now, but I didn't want to let more time go by before referring

17     to the e-mail I sent on the 17th with respect to the Assembly sessions

18     referenced in Dr. Donia's reports.  So I just didn't -- thought that we

19     shouldn't let that slip off the radar screen for so long since there was

20     an indication that we had intended to address it in the following week.

21     Not something we need to deal with now, but just a reminder.

22             JUDGE KWON:  Thank you.

23             Please have a nice evening.

24                           [The witness stands down]

25                           --- Whereupon the hearing adjourned at 7.02 p.m.,

Page 4339

 1                           to be reconvened on Wednesday, the 30th of June,

 2                           2010, at 2.15 p.m.