Tribunal Criminal Tribunal for the Former Yugoslavia

Page 17393

 1                           Thursday, 18 August 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Mr. Karadzic, you will have for your cross-examination the same

 8     amount of time as what Prosecution had for its examination-in-chief,

 9     which means you will have two hours and 20 minutes for today, since you

10     had spent two hours and half yesterday.

11             THE ACCUSED: [Interpretation] Thank you.  Does this proviso state

12     that if things run smoothly there'll be extra time?

13             JUDGE KWON:  Mr. Karadzic, please continue cross-examination

14     and --

15             THE ACCUSED: [Interpretation] Thank you.

16             Excellency, good morning.  Good morning to everyone.

17                           WITNESS:  KDZ-555 [Resumed]

18                           [Witness answered through interpreter]

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

20        Q.   [Interpretation] Good morning, Mr. Witness.

21        A.   Good morning.

22        Q.   Let me ask you this:  Is there a way of somehow obtaining the

23     video-tape that you mentioned showing the Patriotic League Assembly in

24     Godus, and if so, in what way can we do that?

25        A.   I may provide it either to you or the Prosecution.

Page 17394

 1        Q.   I would be very grateful to you.  Can you tell us the name of the

 2     Muslim author of the book which describes the preparations for the war by

 3     the Muslims in Zvornik?

 4        A.   The book is entitled the -- Zvornik from the elections --

 5             THE INTERPRETER:  Can the witness please repeat clearly the name

 6     of the book.

 7             JUDGE KWON:  Mr. Witness, could you repeat the name of the book.

 8             THE WITNESS: [Interpretation] The title is "Zvornik From the

 9     Elections to the Dayton Agreement."

10             MR. KARADZIC: [Interpretation]

11        Q.   Thank you.  Can we now have in e-court 1D3938.  Yesterday, we

12     discussed the subject relating to the volunteers who came and were

13     accepted and equalised with every other military conscript.  I'm going to

14     ask you now whether that was a customary -- I'm afraid this is not the

15     right document.  It's 1D3938.

16             We're surely going to need this document, but only later because

17     this is a significant Muslim document.  Can we then put the document on

18     the ELMO if it is not uploaded in the e-court, but it should have been.

19     Oh, I apologise.  It's 3998.  I made a mistake.

20             Is this a list of the volunteers in voluntary detachment in the

21     Drina Corps, which show that maximum 10 or 12 of them were assigned to

22     each unit and that care was taken for ensuring their status, and the army

23     did not allow the volunteers to be concentrated in one unit but, rather,

24     distributed them all over their strength?

25        A.   Yes.

Page 17395

 1        Q.   Can we now have the next page.

 2             JUDGE KWON:  Before that, Mr. Witness, could you tell us what

 3     this document is about?

 4             THE WITNESS: [Interpretation] This is a document -- actually, a

 5     list of volunteers assigned to units of the Army of Republika Srpska.

 6             JUDGE KWON:  Who wrote it?

 7             THE WITNESS: [Interpretation] The Drina Corps, but I don't see

 8     any signature.

 9             JUDGE KWON:  Yes.  How do you know that this is written --

10             THE WITNESS: [Interpretation] Although I see it for the first

11     time, I can read in the title that it says the Drina Corps.

12             JUDGE KWON:  Please continue, Mr. Karadzic.

13             THE ACCUSED: [Interpretation] Thank you.

14             MR. KARADZIC: [Interpretation]

15        Q.   Among other things, was this done because of the bad experience

16     that they had with larger units that prompted the Army of

17     Republika Srpska not to allow the volunteers to be in larger units but

18     just merge them in their own units?

19        A.   Yes.  From the very day when the Army of Republika Srpska was

20     established, they took good care of that.

21        Q.   Thank you.

22             THE ACCUSED: [Interpretation] Can this document be admitted?

23             JUDGE KWON:  Yes, Mr. Nicholls.

24             MR. NICHOLLS:  I can't read it.  Does it have a date?  Do we know

25     when this is from?

Page 17396

 1             JUDGE KWON:  Yes.  I'm not satisfied, speaking for myself, as to

 2     its provenance and the date as well.  I don't think the witness is in the

 3     position to tell us about it.  Who wrote it and when was it?

 4             THE WITNESS: [Interpretation] I see it for the first time and I

 5     can only read what it says.  Otherwise I have no detailed knowledge about

 6     it.

 7             JUDGE KWON:  Mr. Karadzic, I don't think this witness is able to

 8     give any provenance about this document, and I -- I don't think it is

 9     appropriate to admit this document through this witness.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   There was something that remained unclear to me.  Is it true

13     that -- that Rade Kostic worked at the MUP of Croatia?  Is it possible

14     that he lost his job there, that he was registered in Serbia, but that,

15     nevertheless, he remained in Serbian Krajina where he had worked before?

16        A.   Yes.  He worked at the Croatian MUP, and he was a police station

17     commander when Croatia was in existence.  When the war broke out, he

18     joined the Republic of Serbian Krajina and discharged the duties of the

19     assistant minister for the interior.  The minister was Mr. Martic, but I

20     don't know in which period that took place.

21        Q.   In other words, he was not an employee of the MUP of Serbia;

22     right?

23        A.   The other day I saw for the first time a document indicating that

24     he was in the MUP of Serbia, but at the time, he wasn't.  He was in the

25     Republic Serbian of Krajina.

Page 17397

 1        Q.   Thank you.  Is it true that Mr. Radmilo Bogdanovic, the then --

 2     or the former minister of the interior was at the time in charge of the

 3     Serbs living outside of Serbia?

 4        A.   Yes.  That's what I said.  He was chairman of the Assembly

 5     committee providing for the Serbs outside of Serbia.

 6        Q.   Did he instruct you to make also links with the TO to co-operate

 7     with the JNA and to co-operate with the Republic of Serbian Krajina with

 8     regard to the procurement of weapons, and did he accept your assessment

 9     of the threat posed by the arming of the Muslims?

10        A.   Well, we did our best to provide as many arguments in that

11     respect as possible, and I think that we provided convincing arguments to

12     the effect that the Muslims were indeed arming themselves, so he

13     instructed us to work closely with the army, and he also referred us to

14     Kostic in the Serbian Republic of Krajina.

15        Q.   Thank you.  Do you know that any relevant person not taking into

16     account anonymous telephone calls like the one we read yesterday, so did

17     any relevant personality inform the party HQ about the procurement of

18     weapons and other developments?

19        A.   No.  Nobody did that.

20             MR. NICHOLLS:  Excuse me, I just wonder what call Mr. Karadzic is

21     referring to if he can talk about yesterday.  The intercept he showed us

22     was not anonymous.  It had the name of each of the caller.

23             JUDGE KWON:  Yes, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Yes, but the witness says that such

25     a person did not exist in Zvornik.  Somebody was probably giving a false

Page 17398

 1     name.  At least such a person did not exist within the authority

 2     structures in Zvornik.  That's what the witness says.

 3             THE WITNESS: [Interpretation] Zvornik is a small town.  We

 4     basically knew everybody else, and I'm not familiar with the person of

 5     that name ever existing in Zvornik.

 6             JUDGE KWON:  Very well.  Let's continue.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Let's wrap up the subject of Arkan.  Is it true that Arkan came

10     to Zvornik twice and stayed for a day or for an hour on each occasion; is

11     that right?  I think I saw it somewhere in the documents?

12        A.   I said that he came twice and that he stayed for an hour on each

13     occasion.

14        Q.   Thank you.  His representative was Major Pejic?

15        A.   Yes.  And he stayed in Zvornik for about seven days.

16        Q.   Is it true that Arkan came to Zvornik as a hero, that he had been

17     highly commended in Bijeljina, that the Muslims invited him to their

18     homes and were grateful to him because he resolved that crisis in a

19     matter of 24 hours?

20        A.   It is true that he came to Bijeljina as a hero, and I know that

21     while he was passing through these places some celebrations were

22     organised.  He came to Zvornik as a hero, too, exactly.

23        Q.   However, the Muslim paper "Oslobodjenje" didn't write about him

24     in complementary terms.

25        A.   Yes.  That's what I was able to read.

Page 17399

 1        Q.   Is it true that you were not always able to distinguish who the

 2     people were who appeared and offered assistance?  Only after you talked

 3     between Marko Pavlovic and General Jankovic, you found out that he was an

 4     influential person?

 5        A.   Since we were, as I said, a state within a state and none of us

 6     had any significant military experience in such situations, the

 7     Crisis Staff behaved as a sort of naive flock of sheep.  Whoever who came

 8     and offered anything, we welcomed that.  Therefore, there were some

 9     contradictory decision taken.  There were some unreasonable moves made,

10     and I think that some of the decisions led to a complete chaos.  The

11     people who came from outside even exacerbated this chaotic situation.

12        Q.   Is it true that Vojislav Jekic mentioned here by another witness

13     also represented himself and pretended to be more important than he was

14     and that you were not aware of his exact position in Serbia?

15        A.   Yes.

16        Q.   Was that the same situation with Zuca, Pivarski, Niski, and all

17     the rest of them who came there just to impress the authorities until

18     they gained power?

19        A.   Yes.  That was the situation at the beginning.  Niski, for

20     example, would go to beat up a whole unit, to force them to take their

21     clothes off and walk through villages, and several units experienced

22     this, in fact.

23        Q.   Are you referring to the Serbian TO soldiers?

24        A.   Yes.  When they became a very strong group, they were really

25     rampaging around and doing what they wanted.

Page 17400

 1        Q.   Do you know that Arkan was not closely related to the MUP of

 2     Serbia but, rather, the federal MUP while the minister was Slovenian

 3     Stane Dolanc, and is it true that he used to come to Zvornik with a car

 4     bearing the licence plate with the number 900 which indicates the federal

 5     MUP property?

 6        A.   Yes.  I said that he came in an official car that had 900 licence

 7     plates, whereas all other republics had their own numbers.  Nine hundred

 8     indicated the federal SUP, which created a terrible confusion among us.

 9     Seeing him coming in this official car with official licence plates, and

10     he was just passing by all the policemen on the ground in that car.

11        Q.   Thank you.  Were you aware that there was an antagonism between

12     the federal MUP and the MUP of Serbia which eventually resulted in the

13     takeover of facilities and nearly an armed conflict between the two?

14        A.   Yes.

15        Q.   Were the rumours and were they founded that some private

16     institutes from Belgrade were the rightful owners of Glinica which

17     exported goods daily, the value amounting to a million dollars and some

18     groups were paid by those owners to protect their investments?

19        A.   That's correct.  And there were some groups that came to the

20     staff and were unwilling to join any TO units.  They were saying that

21     they had been tasked with guarding that property that belonged to the

22     institute of physical chemistry in Belgrade and possibly some other

23     private companies, and they deployed around Glinica and that's where they

24     stayed.

25        Q.   Thank you.  Let us now focus on Kozluk.  Is it correct to say

Page 17401

 1     that the position of Kozluk can be divided into three stages:  The first

 2     one being from the elections till the outbreak of the conflict; the

 3     second from that point till the end of the regular functioning of the

 4     authorities; and the third stage beginning with the moment when the

 5     paramilitaries suspended the regular military authorities?

 6        A.   Yes.

 7        Q.   Could one say that the Muslim population at Kozluk mostly voted

 8     for the SDA, and the Serbian population for the SDS, as in of all of

 9     Bosnia-Herzegovina?

10        A.   Yes.

11        Q.   Could one say that there were no problems in Kozluk during that

12     first stage from the elections until April 1992, that life was mostly

13     normal?

14        A.   Yes.

15        Q.   Was life normal in spite of the fact that there were volunteers

16     from Kozluk and Zvornik in Croatia who fought with the Croatian MUP

17     against the Serbs in Croatia?

18        A.   Yes.

19        Q.   Is it correct that at the beginning of the conflict a

20     considerable number of Muslim youths from Kozluk went to

21     Muslim-controlled territory, that's the territory of today's federation,

22     to fight with the Patriotic League or the BH Army?

23        A.   Yes.

24        Q.   Did the neighbouring village, Sepak, have a unit of the

25     Patriotic League?  Is Sepak the neighbouring village?

Page 17402

 1        A.   Well, Sepak is some 7, 8 kilometres away from Kozluk, but like

 2     all Muslim populated villages, they had a local unit of the

 3     Patriotic League.

 4        Q.   Is it correct that in spite of that, life was normal in Kozluk

 5     and that there were normal relations between Kozluk and the Serbs all

 6     this time?

 7        A.   Yes.

 8        Q.   Now, once conflicts broke out in Zvornik itself, and they lasted

 9     for two or three days, is it correct that after that at some point in

10     time the Muslims from Kozluk got ready, packed their things, and demanded

11     to be transported or allowed to go to the territory around Kalesija and

12     Tuzla, which is the territory that today belongs to the federation?

13        A.   Yes.

14        Q.   You mentioned that.  Is it correct that the authorities, even

15     Arkan and Pejic, were against their departure and that a large meeting

16     was called, a meeting of the most renowned Muslims and Serbs, attended

17     by --

18             THE INTERPRETER:  Could the accused please repeat these names

19     he's now reading out.

20             MR. KARADZIC: [Interpretation]

21        Q.   The municipal authorities, Serbian municipal authorities from

22     Zvornik and even Arkan's Major Pejic, and that they were able to dissuade

23     the Muslims from leaving, and that the Muslims got everything they had

24     demanded as was said before court in Belgrade?

25        A.   Yes.  The Muslims at Kozluk and Sepak and the surrounding

Page 17403

 1     villages.

 2             JUDGE KWON:  Could you note the line 17, 18 by transcript page,

 3     by interpreter's note.  They couldn't follow the names you read out and

 4     missed that.

 5             THE ACCUSED: [Interpretation] Thank you.  The highest ranking

 6     representative of the Serbian Orthodox Church, Bishop Vasilije, who had

 7     arrived from Bijeljina.  He used to live in Bijeljina, but he fled and

 8     went to Bijeljina [as interpreted].  And from the Serbian side, there

 9     were also the municipal authorities, the authorities of the Serbian

10     municipality of Kozluk.  And the Muslims side was represented by Mufti

11     Lugavic from Tuzla.

12             THE WITNESS: [Interpretation] I believe that his real name is

13     Lugonjic.

14             MR. KARADZIC: [Interpretation]

15        Q.   Possible.  Lugonjic from Tuzla.  Then Dr. Muhamed Jelkic, who was

16     a member of both the Serbian and the Muslim Crisis Staff that we spoke

17     about already, and then there was Arkan's Major Pejic.  And at that

18     meeting guarantees were given and the Muslims were persuaded to stay; is

19     that correct?

20        A.   Yes.

21        Q.   Bishop Vasilije.  His bishopric was called the Zvornik-Tuzla

22     bishopric, with its seat in Tuzla.  But he fled and went to Bijeljina; is

23     that correct?

24        A.   Yes.

25        Q.   In line 7, or 6 and 7, I seem not to have been sufficiently

Page 17404

 1     clear.  Tuzla was not recorded again.  So he fled from Tuzla and went to

 2     Bijeljina, and he came to this meeting from Bijeljina which was some

 3     50 kilometres away to persuade the Muslims to stay; correct?

 4        A.   Yes.

 5        Q.   Can you tell us what the Muslims then got for not leaving?

 6   (redacted)

 7        Q.   Please don't mention that.

 8        A.   No problem.

 9        Q.   No problem?  Okay.

10        A.   And then we agreed that for reasons of security and safety joint

11     patrols should be organised with an equal representation of Serbs and

12     Muslims and who should keep law and order at Kozluk and that supplies

13     should be improved, especially food supplies, because there were

14     shortages of food already, and then that there should be an outpatient

15     clinic.  And then we also discussed other forms of co-operation in

16     accordance with their needs, and while I was a member of the Crisis Staff

17     I know that all -- that this agreement was implemented perfectly.

18        Q.   Is it correct that after that, Grujic personally drove sick women

19     and children to Loznica to be treated, and did I understand correctly

20     that a new police station was set up there with both Muslim and Serbian

21     personnel?  Was that -- was it that way?

22        A.   Yes.  After the meeting I remember that Grujic took some people

23     who were in need of medical treatment to Loznica, to the local hospital.

24     And a new station was set up with the proportional representation of

25     Serbs and Muslims for both groups to be safe, and all that functioned

Page 17405

 1     without a single incident.

 2        Q.   Thanks.  (redacted)

 3     (redacted)

 4        A.   Yes.

 5        Q.   I see the word (redacted) but the witness didn't say that.  Okay.

 6     It's all right now.  Were the relations with the Muslim leaders from

 7     Kozluk, such as Fadil Banjanovic and others, fair and regular during

 8     those three months?

 9        A.   Yes.

10        Q.   Was the separation line 2 or 3 kilometres away from Kozluk, the

11     front line, that is, and were the people in Kozluk and Sepak able to hear

12     the shooting from the separation line?  And Vitnica was about 5 or -- 5

13     kilometres away, but the separation line was closer, and Vitnica was a

14     Muslim stronghold even today and the -- in the federation of BiH.

15        A.   Yes, that's correct.

16        Q.   Apart from the fact that the front line was so close, and

17     although wounded people returned from the front line and some people got

18     killed and soldiers went there -- went there to rotate shifts, in a word

19     the situation was not pleasant at all, was there still a feeling of

20     safety while the municipal authorities were functional during those three

21     months while that -- while those people were still in Kozluk?

22        A.   Yes.

23        Q.   Is it correct that through Kozluk and -- through Kozluk a large

24     number of refugees, Serbian refugees, came to Zvornik, who fought -- had

25     fought their way out of Muslim-controlled territory, Zivinice, Tuzla,

Page 17406

 1     Kalesija and that they passed through Kozluk, and that in Zvornik their

 2     there were about 15- to 20.000 of them?

 3        A.   Yes.

 4        Q.   Did that contribute to the rise of tensions, and is it a fact

 5     that while the municipal authorities were functional, in spite of that

 6     they did not ask to be left -- to leave Kozluk?

 7        A.   Yes.

 8        Q.   I'm going to ask you now about similar Serbian inhabited places

 9     in the Muslim-controlled territory.

10             THE INTERPRETER:  Could the accused please repeat the -- his last

11     sentence.

12             JUDGE KWON:  Could you repeat your question.

13             MR. KARADZIC: [Interpretation]

14        Q.   Is Dubnica -- there seem to be problems with our toponyms.  Is

15     Dubnica a similar Serbian settlement in the Kalesija municipality, which

16     is between Zvornik and Tuzla?

17        A.   Yes.

18        Q.   Can you tell the Trial Chamber or -- excuse me.  Were there

19     similar concentrations in the periphery of Tuzla, Simin Han and

20     Zanice [as interpreted]?  Are those Serbian settlements?

21        A.   Yes.

22        Q.   Is Rastosnica a large concentration of Serbian hamlets amounting

23     to 2500 or even 4.000 inhabitants to the north-west of Zvornik?

24        A.   Yes.

25        Q.   Please tell the Trial Chamber what happened to these Serbian

Page 17407

 1     settlements that are comparable to Kozluk, and let us explain immediately

 2     that this is not tu quoque.  We merely want to explain how refugees came

 3     to Zvornik and what their state -- their prevailing state of mind was.

 4     What happened to Serbian settlements in the Muslim-controlled territory?

 5        A.   They were attacked by Muslim armed forces.  Some inhabitants were

 6     killed and others fled to Serbian-controlled territory.  Most of them to

 7     Zvornik, especially all of Rastosnica and a large part of Dubnica,

 8     actually, all of Dubnica and a smaller part of Simin Han and the other

 9     where the church is.

10        Q.   Pozarnica.

11        A.   Yes, Pozarnica.  Pozarnica and Simin Han mostly left in the

12     direction of Bijeljina, whereas Rastosnica and Dubnica [Realtime

13     transcript read in error "Dubrovnik"] in the direction of Zvornik, and

14     their churches were destroyed there and their houses burned, and so on.

15             THE ACCUSED: [Interpretation] Perhaps I can help the

16     court reporter.  It's Dubnica.  It's not Dubrovnik.

17             MR. KARADZIC: [Interpretation]

18        Q.   But Simin Han and Pozarnica are the other two places; is that

19     correct?

20        A.   Yes.

21        Q.   The other locality is Rastosnica with many Serbian hamlets,

22     Rastosnica; right?

23        A.   Yes.

24        Q.   Let us shed some light on the third stage, the final stage in the

25     fate of Kozluk.  Power in Zvornik had been taken over by paramilitaries;

Page 17408

 1     right?

 2        A.   Yes.

 3        Q.   (redacted)

 4     (redacted)  You confirmed that the Muslims in Kozluk at that

 5     moment were in real danger, and that after the three months while the

 6     authorities were functional once the authorities were suspended they

 7     found themselves in real danger; correct?

 8        A.   Yes.

 9        Q.   Did they know that the paramilitaries --

10             JUDGE KWON:  Yes, Mr. Nicholls.

11             MR. NICHOLLS:  I apologise for interrupting.  Can we -- private

12     session for one moment?

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                           [Open session]

25             JUDGE KWON:  Yes, Mr. Karadzic.  Please continue.

Page 17409

 1             THE ACCUSED: [Interpretation] Did I understand correctly that if

 2     I only say 1D and then the number of document and the number of page we

 3     needn't go into private session?  Is that what Mr. Nicholls understood?

 4             JUDGE KWON:  I think that's fair enough.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   So did the Muslims of Kozluk know about the paramilitary units

 8     maltreating members of the authorities that were taking them out to be

 9     shot?  They were beating them and humiliating them.

10        A.   Yes, they did.

11        Q.   Now, was it possible for the Muslims to expect from such badly

12     treated and humiliated authorities to receive any protection during the

13     three months?

14        A.   No, it wasn't.

15        Q.   Was there any plan to have the Serbian areas cleansed from

16     Muslims?  Would the Muslims of Kozluk be retained or would they be

17     allowed to leave the territory immediately?

18        A.   They would have been allowed to leave the territory immediately.

19     However, there was no such plan.

20        Q.   Can one conclude with certainty that nobody in the authority

21     structures or in political parties -- was there at least any wish for the

22     Muslims to leave?  On the contrary, they thought it was desirable for

23     Muslims to stay behind?

24        A.   Yes.

25        Q.   Even nowadays is Kozluk still in Republika Srpska and the

Page 17410

 1     municipality of Zvornik?

 2        A.   Yes, it is.

 3        Q.   Thank you.  Can we say that both in Kozluk and in Divic the huge

 4     majority, if not all of them, returned, and I'm talking about those

 5     people who were refugees at the time?

 6        A.   Yes.

 7        Q.   If you remember, was there ever denial of the right of the

 8     refugees to come back, and was our position always clear to the effect

 9     that everything related to refugees was of a temporary nature, their

10     status and their property?

11        A.   Yes.

12        Q.   Let me remind you now of yesterday's page 19 in the transcript

13     when my learned friend Mr. Nicholls presented to you a portion of

14     Mladic's notebook.  Do you remember that at this meeting Branko Grujic

15     said, We were the most productive in evacuating the Muslims?  This is

16     what was read from that notebook.

17        A.   Yes.  That was what was read, but I was not at that meeting.

18        Q.   All right.  Let us establish this:  A similar sentence was

19     uttered --

20             JUDGE KWON:  Yes, Mr. Nicholls.

21             MR. NICHOLLS:  Just -- this may be of assistance.  I think

22     Mr. Karadzic was referring to what Marko Pavlovic said at the meeting.

23     It was Pavlovic who said, We were most active in evicting Muslims.

24             JUDGE KWON:  Yes, Mr. Karadzic.

25             THE ACCUSED: [Interpretation] I think that that was said by

Page 17411

 1     Mr. Grujic, and I would like, if possible, to have this document so that

 2     we can check it out in e-court.

 3             JUDGE KWON:  Why don't you upload it.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   While we are waiting, I'm going to now tell you a similar

 6     situation.  Dr. Novakovic said a similar sentence in Bijeljina relating

 7     to a certain person, that he was doing this thing best, and later on he

 8     and another group of MPs filed a criminal report.  Is it characteristic

 9     of our mentality to use irony or sarcasm when we say he's doing nothing

10     apart from what he's not supposed to do?  Do you agree, and do you

11     understand that?

12        A.   I am familiar with this first portion that refers to Bijeljina.

13     Everybody in the republic knows that Novakovic and another group of SDS

14     MPs filed a criminal report against the man who was involved in the

15     evictions of Muslims.  I agree with you that it is consistent with our

16     mentality to boast about things that they didn't do.

17        Q.   At this meeting, whether there was lunch involved or not, was

18     Mr. Grujic allowed to raise any objections against Captain Dragan and

19     other things since Mr. Mladic and I --

20             THE INTERPRETER:  Could the speakers please pause between

21     questions and answers.

22             JUDGE KWON:  Just a second.  Interpreters find it very difficult

23     to follow you when you overlap in such a degree.

24             Yes, Mr. Nicholls.  Could you identify the page number of that

25     Exhibit 1478?

Page 17412

 1             MR. NICHOLLS:  It should be 252 and 253 in the English,

 2     Your Honours.  And I believe 249 and 2 --

 3             THE ACCUSED: [Interpretation] Perhaps even 244, if I remember

 4     correctly from yesterday.  Let's try 244, where Grujic is speaking.  The

 5     next one, please.

 6             JUDGE KWON:  It's page 249 where Branko Grujic started speaking,

 7     starting saying, "We have 32.000 Serbs."  249.

 8             THE ACCUSED: [Interpretation] Can we have the Serbian version as

 9     well.

10             JUDGE KWON:  Page 249.  This is 252.  The e-court page 249.  Yes,

11     but e-court page 249.  Is it correct?  Branko Grujic.

12             MR. NICHOLLS:  Yes.  I believe -- well, it actually may be 247 in

13     the B/C/S, 249 in the English.

14             JUDGE KWON:  Next page for English now.  Yes.  We have the

15     identical pages for both languages.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   Here Mr. Grujic says, "We have 32.000 Serbs," and he says:

19             "We have successfully implemented the president's decision to

20     settle Divic and Kozluk with our children."

21             Do you remember that from the highest level an order was

22     publicised for the abandoned property to be considered as temporary, that

23     refugees and such occurrences are normal in a war and that those

24     properties cannot be given for use to the local residents?

25        A.   Yes.

Page 17413

 1        Q.   I will now provide a reference for all the parties involved and

 2     tell -- I'm going to tell you where you confirmed, and that was 1D3987,

 3     page 49.  You confirmed there that no changes occurred in ownership over

 4     immovable property in the municipality throughout the war.

 5        A.   The ownership relations remained unchanged, and I know the local

 6     authorities issued temporary decisions allocating the abandoned property

 7     to the Serbs who had fled from the federation.

 8        Q.   They had the duty of care, and they were obliged to return it

 9     once the time come for that.  Did they return the property to the Muslim

10     of Kozlic and Divic -- Kozluk and Divic?

11        A.   Yes.  That was the decision, and these properties were returned.

12             JUDGE KWON:  Has it been resolved who it was who said that they

13     were productive in evacuating Muslims?

14             MR. NICHOLLS:  I don't believe so, Your Honours.

15             THE ACCUSED: [Interpretation] Well, I think that we cannot talk

16     about expulsion and evacuation, rather, but if we look at the next page,

17     maybe we can find this, and that is actually a continuation of Grujic's

18     speech.  I believe that we need the next pages in both versions.

19             MR. KARADZIC: [Interpretation]

20        Q.   It says here that we didn't have enough officers, and after that,

21     Pavlovic is speaking about the problems with paramilitary.  He mentioned

22     Glinica by saying that there were armed men in Glinica.

23        A.   All of this is being spoken about by Grujic.

24        Q.   Oh, that's right.  So he said there were no other officers except

25     this Pavlovic person.  He's also mentioning Glinica, and he says that, We

Page 17414

 1     had to get rid of Zuca and Captain Dragan, which was his wish.

 2        A.   Yes.  And he says that they burst into the municipal building

 3     again that morning and took them prisoner.

 4             THE ACCUSED: [Interpretation] Can we please have the next page.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   He speaks here about all the industrial facilities grinding to a

 7     halt.  So I cannot find this in this portion, so I'll have to look at

 8     yesterday's transcript.

 9             JUDGE KWON:  Yes, Mr. Nicholls.

10             MR. NICHOLLS:  If we scroll through the next two pages, we'll see

11     the reference I believe he was referring to.

12             THE ACCUSED: [Interpretation] Yes.  That would be fine.

13             MR. NICHOLLS:  Bottom of the page.

14             MR. KARADZIC: [Interpretation]

15        Q.   So he's telling everybody what is not operational in Zvornik.

16     He's also talking about conflicts between the brigades and armed

17     civilians, and it says:

18             "We were most active in evicting the Muslims."

19             So all of this is being spoke be by Grujic; right?

20        A.   No.  These are the words uttered by Pavlovic.

21        Q.   Can we go back so that we can see exactly the beginning of

22     Pavlovic's contribution?

23             JUDGE KWON:  Page 251, e-court page 251 in English.

24             THE ACCUSED: [Interpretation] Ah-ha.  This is correct.  Number 5,

25     this is where it begins.  My mistake.

Page 17415

 1             JUDGE KWON:  Thank you, Mr. Nicholls.

 2             Let's proceed.

 3             THE ACCUSED: [Interpretation] Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Never mind.  So this Pavlovic, who at the time was commander of

 6     the TO, did he talk about the things that were not being done in Zvornik,

 7     and he is being sarcastic about what is being done, and is it true that

 8     the Muslims were not removed while the municipal authorities were

 9     operational, and Pavlovic was part of that authority?

10        A.   Yes.

11             MR. NICHOLLS:  Excuse me.

12             THE WITNESS: [Interpretation] But once the paramilitary were put

13     to prison, Pavlovic was also imprisoned.

14             JUDGE KWON:  Yes, Mr. Nicholls.

15             MR. NICHOLLS:  Yesterday and today there have been a series of

16     huge compound questions being read out to the witness to which the answer

17     is usually one word.  I have not objected up to this point.  For this

18     question, I do object to that much being packaged into one question, and

19     I do wonder how the witness is supposed to know what was being in the

20     mind of Marko Pavlovic when he spoke and whether he was being sarcastic

21     at a meeting he was not present at.

22             JUDGE KWON:  Fair enough.  I agree with you.

23             Bear that in mind, Mr. Karadzic, when putting the questions.

24             Yes, you like to comment on it?  Yes, Mr. Witness.

25             THE WITNESS: [Interpretation] Well, I started my answer by

Page 17416

 1     saying, "Yes," but when these paramilitary units were imprisoned, he was

 2     imprisoned with them, and we were all surprised at that.

 3             JUDGE KWON:  Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   I acknowledge the objection raised by Mr. Nicholls but this is

 6     due to my haste because of shortage of time.  Let us clarify this.  At

 7     the time was Marko Pavlovic participating in the authorities that were

 8     under the pressure of the paramilitary units?  Was he in favour or

 9     against emigration?

10        A.   Yes, he was participating in the authorities that were under the

11     pressure of paramilitary.  Now, speaking about emigration, I don't know

12     who was in favour of what.  All I know, that once two sides engage in

13     war, civilians tend naturally to run towards their respective armies.  If

14     we are talking about Kozluk, quite simply nobody was able to prevent

15     them.  They wanted to join their own ethnic community, and they wanted to

16     flee.  I know that although we reached an agreement, several hundreds of

17     them moved through the forests and joined the army.  We had a list of how

18     many of them were in April 1992 and how many of them left.  While they

19     were moving out in June or July, there were 1.600 of them only.  Where

20     are the remaining 1.200, because Kozluk had between 3- and 4.000 people.

21        Q.   Thank you.  Now I would like us to deal with a different topic.

22     What is repeated often in the indictment is that the Serbs took over many

23     municipalities, so I would like to ask you to help us shed more light on

24     that particular matter.

25             Is it correct, actually, that the elections in 1990 were a kind

Page 17417

 1     of substitute for the census and that the Serbs prevailingly voted for

 2     the SDS, the Croats for the HDZ, and the Muslims for the SDA?

 3        A.   Yes.

 4        Q.   Is it correct that the Serbs won absolute power in 37 out of 109

 5     municipalities and that in another 10 municipalities they won power

 6     relatively and that in the republican government they had more than

 7     one-third?

 8        A.   Yes.

 9        Q.   If we take into account the fact that in four or five Croatian

10     municipalities in Western Herzegovina there was never any Serb

11     population, hence they could not one the elections either, does that mean

12     that in 47 municipalities the Serb Democratic Party on behalf of the Serb

13     people had a majority government, and in the remaining municipalities

14     they had a considerable participation in government?

15        A.   Yes.

16        Q.   One of these 57 municipalities where we did not have absolute

17     power but we had a significant participation or share in government was

18     the municipality of Zvornik; isn't that right?

19        A.   Yes.

20        Q.   Is it correct that in Bijeljina we had absolute government or

21     authority insistently from the elections from 1990 until the present day?

22        A.   Yes.

23        Q.   Do you agree that in Bijeljina we were in power on the 30th and

24     31st of March in 1992, and on the 1st, 2nd, 3rd, and any other April from

25     1992 to the present day?

Page 17418

 1        A.   Yes.

 2        Q.   Do you agree that with the exception of Bijeljina and Sekovici

 3     where they were a prevalent majority, the Serbs controlled, at least

 4     until mid-1993, only their own parts of the remaining municipalities,

 5     whereas Muslim territory was controlled by Muslim forces?

 6        A.   Yes.

 7        Q.   I would now like to ask -- just a moment, please.  I kindly ask

 8     for your understanding.

 9             THE ACCUSED: [Interpretation] 1D14141, please.  14141 is the

10     65 ter number.  It's not in colour, actually, but could we please zoom in

11     a bit more.

12             Could the usher please help the witness by giving him an

13     electronic pen.

14             MR. KARADZIC: [Interpretation]

15        Q.   Please, could you put a circle around the town of Zvornik itself

16     and place number 1 there.

17        A.   [Marks]

18        Q.   Could you now circle Karakaj.

19        A.   [Marks]

20        Q.   And could you put number 2 there.

21        A.   [Marks]

22        Q.   Is it correct that these light areas are parts of the

23     municipality where the Serbs constitute an absolute majority, Jadran,

24     Jovici, Karakaj, Grbavci, Kruglic?  Do you see all of these locations?

25        A.   Yes, yes.

Page 17419

 1        Q.   Are all of these Serb areas?

 2        A.   Yes.

 3        Q.   Who controlled these villages during the first year of the war?

 4     Can you mark the front line for us there approximately?

 5        A.   Towards the end of 1992, roughly.

 6        Q.   Did we control Godus?

 7        A.   No, we did not.  However, I have difficulty finding my way here.

 8     How can I mark this approximately?  Approximately, I tried to do this

 9     very quickly, but I think it is about 90 per cent correct.  We only

10     controlled this area facing the Drina, the white area and this area here

11     towards the Drina.  And we had access to Sekovici.  That is this road

12     here from Karakaj.

13        Q.   To Caparde?

14        A.   Yes, to Caparde.  And that is how we controlled it.  Actually, in

15     1993, more of the municipality was controlled by the Muslims.

16        Q.   Thank you.  Could you please put a circle around Kozluk and place

17     number 3 there.

18        A.   [Marks]

19        Q.   Do you see Vitnica?  It was a Muslim settlement, and it remained

20     under their control.

21             THE INTERPRETER:  Interpreter's note:  We cannot hear the

22     witness.

23             THE WITNESS: [Interpretation] This is Vitnica.

24             MR. KARADZIC: [Interpretation]

25        Q.   Thank you.  These villages, Savici [phoen], Zavrsje, and so on,

Page 17420

 1     these other Serb villages --

 2        A.   No.  Zavrsje, Sajicic [phoen], Cevir [phoen], all of that was

 3     taken by the Muslim army in 1992, and they linked up with Teocak from

 4     here.

 5        Q.   Lazle [phoen], all of that?

 6        A.   All these are Serb villages that the Muslims took in 1992.

 7             JUDGE KWON:  Could you kindly put number 4 for Vitnica for future

 8     reference.

 9             THE WITNESS: [Marks]

10             MR. KARADZIC: [Interpretation]

11        Q.   I'm afraid that we've crippled the transcript.  So the Serb

12     villages to the west of Vitnica, that is to say to the west of the

13     separation line, immediately fell under the control of the Muslims; is

14     that right?

15        A.   That's right.

16        Q.   What happened to these villages and this population?

17        A.   Some of them fell victim and those who did not fall victim fled

18     to Zvornik and had the status of refugees.

19        Q.   How many of them stayed to the west of Vitnica -- or, rather, to

20     the west of the separation line?

21        A.   This has to do with a relocation of, say, 5- to 6.000

22     inhabitants.

23        Q.   And no Serbs stayed there during the war?

24        A.   No.  And I think that to this day it is possible that not more

25     than 100 people live to the west of Vitnica.

Page 17421

 1        Q.   Thank you.  Can you explain this to the Trial Chamber:  To the

 2     south of Zvornik, Snagovo, Milosevici and these other villages, is it

 3     correct that all the way to up to Cerska which is near Vlasenica but

 4     which is close to the border, were they under the control of the Muslim

 5     forces for an entire year?

 6        A.   Yes.  All of them except for this very small part of Drinjaca and

 7     this area along the Drina.  Now, what was the name of this other Serb

 8     village there?  That was not under their control.  All the rest was

 9     controlled by the Muslims, all of it.  So we did not actually have access

10     to Pale and Sarajevo via Ceparde and Sekovici only, and that was partly

11     taken and people were killed there in passing, on trucks, and it was very

12     unsafe.

13        Q.   Thank you.  Can we put number 5 by Drinjaca, and number 6 should

14     mark the road that they controlled for all of one year towards Pale and

15     Milici, from Zvornik towards Milici, Vlasenica and Pale, that is.

16        A.   I cannot see that very well.  I cannot see where Drinjaca is,

17     actually.

18        Q.   Drinjaca, it says A.  You see, Belonasilje [phoen].  It's a Serb

19     settlement because it's white.  Luzani.

20        A.   Luzani.

21        Q.   No, the part that you marked.

22        A.   Yes, yes, by the crossroads, right.  That's number 5.

23        Q.   Number 5, Drinjaca.  You can put number 5 next to the circle.

24        A.   [Marks]

25        Q.   Now, do we see that road that was under their control for a year?

Page 17422

 1        A.   Yes, here it is.  That is the road that links Zvornik with

 2     Sarajevo.

 3        Q.   And Drinjaca between 5 and 1, was that also controlled by them

 4     for a year?

 5        A.   Yes.  Yes.  All the way up to Divic.  Their [as interpreted]

 6     defence line was by the Vidikovac Hotel at Divic.

 7        Q.   Could you please put a circle around Divic and place number 6

 8     next to it.  You don't have to put it inside.  You can put it next to it.

 9        A.   [Marks]

10        Q.   Our defence line was "there," not "theirs," as the transcript

11     says.

12        A.   Well, that's where the separation line was.  We did not control

13     anything beyond that, and they didn't either.  That is roughly that

14     quarry between Zvornik.  That was no man's land.

15        Q.   Thank you.  Could you please put today's date there and KDZ-555.

16        A.   [Marks]

17             THE ACCUSED: [Interpretation] Is this a problem, the fact that it

18     goes beyond -- actually, can it be admitted this way?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1613, Your Honours.

21             THE ACCUSED: [Interpretation] Thank you.  Can we now have 1D4041

22     in e-court.

23             MR. KARADZIC: [Interpretation]

24        Q.   In all of these villages -- actually, maybe we're going to call

25     up the map again.  Oh, sorry.  Beg your pardon.  Can we keep the map for

Page 17423

 1     a moment.  Just mark Godus for us, where that review was of that unit.

 2     Well, we can use this map, yes.  It's a different map, yes.  Right.

 3     Godus.  Godus, that's where the review was.  Did all of these Muslim

 4     villages have their own units?

 5        A.   Yes.  As far as I know, all of them had their units.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Could this be admitted separately, or should we call up the other

 8     one, the previous one, and could we ask for Godus to be marked on that?

 9             JUDGE KWON:  I think that's more convenient.  Shall we upload

10     Exhibit D1613 again.

11             MR. KARADZIC: [Interpretation]

12        Q.   Just Godus, please.

13        A.   [Marks]

14             JUDGE KWON:  Yes.  This --

15             THE ACCUSED: [Interpretation] Thank you.

16             JUDGE KWON:  -- will be saved like this.  Can we save this?  So

17     you marked in red.

18             Yes.  Let us continue, Mr. Karadzic.

19             THE ACCUSED: [Interpretation] Can we now have 1D4041.

20             MR. KARADZIC: [Interpretation]

21        Q.   This is a report of the armed forces of the district of Tuzla.

22     It's the Muslim army, and the date is the 10th of July, 1992.  Could we

23     now please have page 3.  Unfortunately, the translation is coming in

24     late, so I ask for your understanding, but I'm going to read this out.

25             I'd like to draw your attention to the second paragraph where it

Page 17424

 1     says, "Results of combat operations."  So it's the beginning of the month

 2     of June, and it says here:

 3              "From the beginning of the war to this day, the armed forces of

 4     Okrug --"

 5             JUDGE KWON:  Yes, Mr. Nicholls.

 6             MR. NICHOLLS:  Again, sorry to interrupt, but we have a

 7     translation if that will help.

 8             THE ACCUSED: [Interpretation] Thank you very much.

 9             JUDGE KWON:  And in the meantime, I ask the witness to read the

10     passage and then we can put the English on the ELMO, and you can put the

11     question.  What part is the witness supposed to read?

12             THE ACCUSED: [Interpretation] Precisely what he was saying.

13             THE WITNESS: [No interpretation]

14             JUDGE KWON:  No, no.  You don't need to read out aloud.  Just

15     read it for yourself and wait for the --

16             THE WITNESS: [Interpretation] Sorry.

17             JUDGE KWON:  -- question by Mr. Karadzic.

18             MR. KARADZIC: [Interpretation]

19        Q.   Results of combat operations, where it says, "From the beginning

20     of the war until ..."

21             Do you agree that this says from the beginning of the war

22     defensive and offensive operations were conducted and significant results

23     achieved, and that more than 70 per cent of the territory of the district

24     was liberated, whereas only two municipalities were fully occupied and

25     these two were Bijeljina and Sekovici?

Page 17425

 1             JUDGE KWON:  Yes.  Now we have it.  We are on the same page?

 2             THE ACCUSED: [Interpretation] No, no.  Let us see the section

 3     where it says "The result of combat activities."  [In English] Next one.

 4             JUDGE KWON:  Next page.

 5             MR. NICHOLLS:  Page 4.

 6             JUDGE KWON:  Page -- "Results of combat operations," yes.

 7             THE ACCUSED:  [No interpretation]

 8             JUDGE KWON:  Yes, now we can read.  And what is your question,

 9     Mr. Karadzic, to the witness?

10             MR. KARADZIC: [Interpretation]

11        Q.   Witness, is it correct that -- or what they are stating here,

12     that 70 per cent of the district was held by them and that only two

13     municipalities were, as they put it, occupied, these two being Bijeljina

14     and Sekovici, and that most -- the most parts of the territories of 14

15     municipalities were liberated?  And these are listed further down:

16     Lukavica, Ugljevik, Zvornik, and others.

17        A.   Correct.

18        Q.   Thank you.

19             THE ACCUSED: [Interpretation] Could we now get the following

20     page, please.  Let me just check.  The English page may actually remain

21     the same -- or, rather, leave it as it is.

22             Can you see the section where it says -- no, no.  The English

23     page is correct.

24             JUDGE KWON:  Just a second.  Next page for the B/C/S.  Yes.  It's

25     coming, yes.

Page 17426

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Can you see the third paragraph where it says:

 3             "In the past period of the war, and that is the first half of

 4     July, strong Chetnik strongholds were liquidated, Dubnica and Kalesija,

 5     Potpec, Lendici, Avramovina, Cerik," and others.

 6             Are these the settlements that correspond with Kozluk on our

 7     side?

 8        A.   Yes.  These are the major populated places.  Some of them are

 9     bigger than Kozluk.

10        Q.   So they are saying that Chetnik strongholds were liquidated, that

11     they were taken, the population was killed and the villages burned;

12     correct?

13        A.   Yes.

14        Q.   Yes.  In the next paragraph and the following paragraph, it says

15     that over 300 Chetniks were killed and huge loss were is inflicted on the

16     enemy with regard to materiel.  And the next paragraph reads:

17             "Currently, offensive activities are underway or being prepared

18     at the fronts facing Tuzla, Kalesija, Zvornik," and so on; is that

19     correct?

20        A.   Yes.

21        Q.   Witness, was there a single day without combat activity along the

22     separation line between the Serbian and Muslim settlements in the Zvornik

23     municipality?  Could we say that fighting was a daily occurrence?

24        A.   I believe that only on a couple of days when cease-fires were

25     signed there was no fighting.  Apart from that, there was fighting all

Page 17427

 1     the time.

 2        Q.   Thank you.  I'm making mistakes because I'm in a hurry.  Let me

 3     just check.  No, that will do.  I don't want to deal with this document

 4     anymore.

 5             THE ACCUSED: [Interpretation] I seek to tender this document.

 6             JUDGE KWON:  Yes, this will be admitted.

 7             THE REGISTRAR:  As D1614.

 8             JUDGE KWON:  I note the time.  It's time to take a break.

 9             Yes, Mr. Nicholls.

10             MR. NICHOLLS:  Just very briefly, Your Honour.  1D03998, document

11     that Mr. Karadzic called up in the beginning that does not have a date,

12     that comes from the Drina Corps collection.  So I believe the provenance

13     is very solid there.  Where the document came from is clear.

14             JUDGE KWON:  Then you would not object to the admission of the

15     document.

16             MR. NICHOLLS:  No, Your Honour.

17             JUDGE KWON:  Very well.  Then we can admit it.  We will give the

18     number.

19             THE REGISTRAR:  Exhibit D1615, Your Honours.

20             JUDGE KWON:  Thank you.  We will have a break for 20 minutes,

21     after which you will have an hour, Mr. Karadzic, to conclude your

22     cross-examination.  We will resume at 10 to 11.00.

23                           --- Recess taken at 10.27 a.m.

24                           --- On resuming at 10.52 a.m.

25             JUDGE KWON:  Yes, Mr. Karadzic.

Page 17428

 1             THE ACCUSED: [Interpretation] Thank you, Your Excellencies.

 2     Could we please see 1D3940.

 3             JUDGE KWON:  But in relation to the list of volunteers, which is

 4     part of Drina Corps collection, I forgot to mention that it should be

 5     marked for identification pending English translation.

 6             MR. NICHOLLS:  Thank you.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Witness, please look at this report of the Public Security

10     Station Zvornik dated 26 June 1992, that encompasses the period from the

11     beginning of April until the 20th of June.  In the first paragraph, it

12     says that on 5 May, there were combat activities between the Serbian Army

13     and the Muslim-Croat extremists.  Dragomir Mitrovic was taken prisoner.

14             Could we please see the following page.

15             It says here that his eyes were gouged out, his face mutilated,

16     and legs also broken; is that correct?

17        A.   Yes.

18        Q.   Item 4 shows that Bozidar Milic was also taken prisoner, then

19     mistreated and finally killed.

20             And then there were allegations of combat activities in the

21     village of Kamenica on which occasion three members of the SJB were taken

22     prisoner, Slavko Eric and others.  Take a look at that.  And after the

23     body was examined at the Zvornik medical centre, it was established that

24     he was tortured and finally killed; is that correct?

25        A.   Yes.

Page 17429

 1        Q.   Could we please see the following pages in both languages.  So

 2     it's 4 and 5.  These items are about that.  And in Serbian we see that

 3     his left and right shoulder blades were broken, eyes gouged out, and so

 4     on.  Did you know about this maiming and torturing of prisoners before

 5     they were killed?

 6        A.   As is common knowledge, this man, Eric, was assistant commander

 7     for traffic.

 8        Q.   It goes on to say that Nikola Ivanovic was taken prisoner, and

 9     his corpse was also examined.  In other words, whoever was taken prisoner

10     was returned as a corpse.

11        A.   Yes, I've read it.

12        Q.   And in the village of Lipje, Slavko Simic was taken prisoner.

13     That's item 9.  It was established that he was mistreated and tortured

14     and eventually killed.  Then there's mention of Dragomir Milosevic in

15     item 10.  His corpse was taken over.  And item 11 at Panduri,

16     Milovan Tojic [phoen] was taken prisoner.  He was a member of the

17     military police.  His throat was slit.  And this is common knowledge

18     among the people of Zvornik; correct?

19        A.   Yes.

20        Q.   And in spite of that, until that time a considerable number of

21     Muslims lived and worked in Zvornik; correct?

22        A.   Yes.

23             THE ACCUSED: [Interpretation] I seek to tender this document.

24             JUDGE KWON:  Yes.

25             THE REGISTRAR:  Exhibit D1616, Your Honours.

Page 17430

 1             THE ACCUSED: [Interpretation] Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   On the occasion of one of the visits of Ms. Plavsic, who was a

 4     member of the Presidency of Bosnia-Herzegovina, did she then say that the

 5     Muslim civilian population should be protected?

 6        A.   Yes.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] Court's indulgence.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Let us now see what the military situation was like.  Could we

11     please see 1D3938.  1D3938.  This is a document of the Muslim army, arm

12     of the Republic of Bosnia-Herzegovina Municipal Staff of the Zvornik

13     armed forces.  It says:

14             "Report on the situation, organisation, establishment, structure

15     and combat readiness of the Zvornik armed forces units."

16             And it's dated 5 November 1992.

17             Is it correct, then, that the Muslim part of Zvornik municipality

18     was armed and had their armed forces and units rather than being a

19     civilian zone.

20        A.   Yes.  They were equipped, and they had military units.

21        Q.   Thank you.  Can we have page 3.  [No interpretation]

22             [In English] "Successful resistance was based on preparation."

23             [Interpretation] Here it says the basis of the successful

24     resistance was -- were the preparations that started months before the

25     war that were reflected in the activity of many activists, organised

Page 17431

 1     armament, and resolution to resist at any cost.  What is particularly

 2     important is the arrival of Captain Hajrudin Mesic.  Is that that captain

 3     Hajro?

 4        A.   Yes.

 5        Q.   Who together with Hodzic Mehdin Senad and a smaller number of

 6     organisers of the resistance managed to create an awareness of necessity

 7     of armed resistance.

 8             Mr. Witness, does that mean that they had to try to persuade the

 9     Muslims to fight the Serbs?

10        A.   Yes.

11        Q.   Please look at the top of this page where it says:  Staffs of

12     units were in Vlasenica, Bratunac, Srebrenica, in the

13     Kamenica-Cerska-Srebrenica triangle.  Settlements in that area were held

14     independently.  The Mali Zvornik, Ljubovija and Zvornik-Drinjaca roads

15     were controlled and also spectacular operation was carried out to free

16     hostages in Lipje.  The road between Mali Zvornik and Ljubovija, is that

17     on the territory of Serbia, and did they keep it under their own fire

18     control successfully, nevertheless?

19        A.   Yes.

20        Q.   Please look at this page and try to find the paragraph where it

21     says that they tried to bring groups in.  Nazif, Himzo, and others headed

22     these groups.  They got into our territory and they successfully got

23     7.500 civilians out from mid-July to mid-August.

24             So they got their own civilians out to Tuzla; right?

25        A.   Yes.

Page 17432

 1        Q.   And later on they tried to portray that as our ethnic cleansing;

 2     right?

 3        A.   Well, that's what I said about the number of inhabitants they had

 4     and about the number of inhabitants that left.  In April when they

 5     reached an agreement with us, they had 4.000 inhabitants, whereas

 6     afterwards 1.600.

 7        Q.   Thank you.  Can we go back one page.  In Serbian too.  It refers

 8     to Zvornik, doesn't it, the first paragraph?  Then the second paragraph

 9     that Defence preparations started considerably earlier.  And in the

10     fourth paragraph it says -- or, rather, they recognise that the defence

11     of Kula Grad was carried out when the JNA were still the legal armed

12     force in the general Tuzla area; is that right?

13        A.   Yes.

14        Q.   And then it says that in that period Kula Grad was synonymous

15     with the BH resistance to aggression.  Kula Grad showed that resistance

16     was possible even in encirclement, and so on and so forth; is that right?

17        A.   Yes.

18        Q.   You confirmed to us that the Serb side had not intended to take

19     Kula Grad had it not been this constant firing at civilians in Zvornik

20     from Kula Grad?

21        A.   Yes.

22        Q.   Can we move two pages ahead now.  I'd like to ask you to look at

23     the beginning where operations are listed, operations that were carried

24     out by these Muslim armed forces in Zvornik.  And there's a reference to

25     Sapna and Gaj and then the fight for Zaseok.  They call it Zaseok.  We

Page 17433

 1     call it Zaselia [phoen].  Then Brdjane, Odzacine, and then Boskovici, and

 2     so on.  And you see down there cutting off a road and incursions by

 3     combatants in our rear, Noriso Grupa [phoen], Sekovici.  The liberation

 4     of Rastosnica.  Who did they liberate it from?  It was only the Serbs who

 5     lived there.

 6        A.   Yes.  That was a village populated by Serbs 100 per cent.  Also

 7     Boskovici, Odzacine, all those places are 100 per cent Serb, their

 8     population is.

 9        Q.   These locations that are referred to in this paragraph, the first

10     paragraph, are you familiar with them?  Are most of them Serb settlements

11     that they attacked?

12        A.   Yes, with the exception of Sapna and Gaj all the rest are Serb.

13        Q.   Can you have a look at what it says in the penultimate paragraph

14     that the armed forces of Zvornik operated as part of the units of the

15     district staff of Tuzla, and that it was the Presidency of the

16     Municipal Assembly that finances the logistics, and so on and so forth.

17             Can we have the next page now?  No.  Beg your pardon.  Let's have

18     a look at what it says here in English.  What were the goals?  We see

19     that in English here.  Enlarging the units, replenishing units with

20     officers -- actually we need the next page in Serbian now.

21             You see what it says here, forming and equipping a multipurpose

22     police company then manoeuvre units, and so on.  And now can we have the

23     next page in English too.  You see where there are units, and you see how

24     many interventions these units had, Godus, and that is a company, and

25     then by this date they had 23 interventions?

Page 17434

 1        A.   I think that this refers to intervention platoons, and then you

 2     see that there is a total at the end.  I think that that involves their

 3     number of personnel, actually.

 4        Q.   Ah-ha.  Can this document be admitted?

 5             JUDGE KWON:  Mr. Nicholls, I take it no objection from you.  That

 6     will be admitted.

 7             THE REGISTRAR:  Exhibit D1617, Your Honours.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Can we briefly have a look at 1D4026.  We are going to place the

10     translation on the ELMO, with your leave, and we're going to see that the

11     Serb side is beseeching the Muslim side to have an exchange carried out,

12     and the Muslim side is returning mutilated corpses.

13             Can we please have this enlarged a bit.  Could the usher please

14     place the translation on the ELMO.

15             This is the 5th of May, 1992.  These are requests, pleas, for

16     exchanges.  Can you have a look at this.  There is a reference to Zaseok,

17     Sestici, imprisoned persons.

18        A.   Yes.

19        Q.   It says here that the previous precondition had been met.  The

20     Muslims had made this a precondition.  Our people actually did

21     accommodate them, and is this not a plea?  Is this not a cry for treating

22     captured persons in a humane way?

23        A.   Yes.

24             THE ACCUSED: [Interpretation] Can this document be admitted?

25             JUDGE KWON:  Yes.

Page 17435

 1             THE REGISTRAR:  Exhibit D1618, Your Honours.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   1D3997.  Could we now have that, please.  Unfortunately, the

 4     translation has not arrived yet, but are these your local communes?  It

 5     says, "Local commune of Donje Kamenica, Gornja Kamenica, Lipje, Novo Selo

 6     and Snagovo."  Are these local communities Muslim villages within the

 7     municipality of Zvornik?

 8        A.   Yes.

 9        Q.   As for these four local communes -- five local communes, are they

10     asking Tuzla, the War Presidency of the municipality of Zvornik, to

11     enhance the combat capacity?  Can you actually have a look at this entire

12     text?

13        A.   Yes.  They are asking for an increase in combat readiness, and

14     they're asking for more resources, equipment.

15        Q.   Can we have the next page now, because there is actually an

16     explanation of this.

17             JUDGE KWON:  Yes, Mr. Nicholls.

18             MR. NICHOLLS:  Sorry.  No objection, just what are we looking at

19     actually?  I may have missed it in the transcript, but where is this

20     document -- what type of document is this?  Where is it from?

21             JUDGE KWON:  Can you go back to the first page.

22             THE ACCUSED: [Interpretation] With your leave, I'd like to read

23     this out.  These local communes are writing, and the subject is the

24     situation in the free territory --

25             JUDGE KWON:  You're not giving evidence.  I think Mr. Witness can

Page 17436

 1     tell us what this document is about in a brief way.

 2             THE WITNESS: [Interpretation] This is information about the

 3     situation in the free territory of the mentioned local communes.  These

 4     are local communities from Donja Kamenica, Gornja Kamenica, Lipje

 5     Novo Selo and Snagovo.  They are from the municipality of Zvornik.

 6             JUDGE KWON:  Can you go to the last page, page 3.  And who wrote

 7     this information?

 8             THE WITNESS: [Interpretation] What is written here is just the

 9     local communes of the mentioned areas.  However, this does not show

10     exactly who wrote this up.

11             MR. KARADZIC: [Interpretation]

12        Q.   Was this not written up in Tuzla on the 12th of September, 1992?

13        A.   Yes.

14        Q.   Can we have page 2.  The one in the middle.  I would like to draw

15     your attention to subparagraph 2.  Can you tell us what they say about

16     the population here?

17        A.   They say that during the first month they had about 15.000 people

18     there, and that today that only half is left together with the members of

19     the armed forces.  They don't have a single doctor, and because of

20     inadequate medical care civilians are dying on a large scale, pregnant

21     women as they're trying to deliver their babies, soldiers who have been

22     lightly wounded, et cetera.  And also, when attempting to save lives when

23     they were wounded, combatants often have the situation to try to help

24     others in a makeshift way even by removing certain parts of their bodies,

25     in parentheses, limbs.

Page 17437

 1        Q.   [Overlapping speakers]

 2             THE INTERPRETER:  Interpreter's note:  We did not hear the

 3     question at all.

 4             JUDGE KWON:  Restart asking your question.  They did not hear

 5     that.

 6             THE ACCUSED: [Interpretation] I apologise.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   They say here that they had 15.000 people here and that only a

 9     half were left.  Is that half -- that half that the previous document

10     refers to when they say that they successfully managed to get them out?

11     Did they get them out or did we expel them?

12        A.   They mostly tried to get women, children, and men who were not of

13     military age to Tuzla, whereas military-age men stayed on.

14             THE ACCUSED: [Interpretation] Can this be marked for

15     identification?

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  MFI D1619, Your Honours.

18             MR. KARADZIC: [Interpretation]

19        Q.   1D3941.  I believe that there is a translation.

20             Is this a dispatch of the MUP of Bijeljina where information is

21     provided?  That is the encircled part here, where information is provided

22     about the Zvornik front line, and it says that it's peaceful, and Muslims

23     from Vitnica and Zaseok, they fired at the Serbian villages of Petkovci

24     and Sestici.  The Muslim forces are trying to smuggle saboteurs into the

25     free territory with the aim of spreading anxiety and killing civilians.

Page 17438

 1     These are specially trained saboteurs, trained in Sibenik and elsewhere

 2     in the Republic of Croatia.  They call themselves the Mosque Doves.  Did

 3     you know about that?

 4        A.   Yes.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] Could this be admitted?  I believe

 7     there's another page in the English version.

 8                           [Trial Chamber confers]

 9             JUDGE KWON:  Mr. Karadzic, all you did in relation -- in relation

10     to this document is to read out some parts and then witness confirmed

11     that it is written there as you read out.  What's the point of putting

12     these documents to the -- to the witness?  You could have asked those

13     questions without having to rely on this document.  Can I hear from you

14     on this point.

15             THE ACCUSED: [Interpretation] I would kindly ask Mr. Robinson to

16     explain.

17             JUDGE KWON:  Yes, Mr. Robinson.

18             MR. ROBINSON:  Yes, Your Honour.  I think the question that he

19     asked the witness was, "Did you know about that?"  So the witness is

20     confirming the events, not simply reconfirming that the text is appearing

21     in the document.  It's the same thing as asking the witness to confirm,

22     "Is this consistent with your knowledge of those events."  And I think

23     the purpose of doing this is to corroborate the witness's testimony so

24     that at the end of the day you're not being asked to simply take the

25     witness's word for these events but we have corroborating documentation

Page 17439

 1     for it and that we think that would be an important element when the

 2     Chamber considers the credibility of the witness.

 3                           [Trial Chamber confers]

 4             JUDGE KWON:  The Chamber finds the explanation by Mr. Robinson

 5     understandable.  We'll admit this.

 6             THE REGISTRAR:  As Exhibit D1620, Your Honours.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Can we now have 1D3942.  While we are waiting, Mr. Witness, you

10     mentioned in the examination of chief the name of Semsudin Muminovic, who

11     unwillingly was the last to desert from the JNA, but he did desert

12     eventually in early April; is that right?

13        A.   Yes, it is.

14        Q.   Can you please look at the order written by

15     Mr. Semsudin Muminovic on the 16th of December, 1992.  Instead of my

16     reading it, can you please look at what kind of reorganisation in the

17     Zvornik area is being ordered to be implemented by him.  Can you look in

18     all these villages such as Vitnica, Sapna, et cetera?  Are you familiar

19     with all of this, and is this a respectable military force that is being

20     surrounded by unit -- units?  Is this area surrounded by so many units?

21        A.   Yes.

22        Q.   Kovacevici, Kiseljak, Padjine, Sepak, Karakaj, Sapna, all of this

23     is being reckoned by him to be his territory, and he has units in each of

24     those places.

25        A.   He kept the whole territory between Teocak all the way to Tuzla

Page 17440

 1     and Kalesija.

 2        Q.   Under item 2, he says the battalion shall be responsible for the

 3     following part of free territory:  Zaseok to the left and Jefta.

 4   (redacted)

 5   (redacted)

 6        Q.   So I'm not going to read all of these places, but anyway, he has

 7     troops deployed in all of them.  Do you agree that this entire area,

 8     i.e., the Muslim part of Zvornik, was completely militarised?

 9        A.   Yes.  And that supports the map in which I made my markings and

10     that is consistent with what he is saying here.

11        Q.   Can we have the next page in both versions, please.  We have here

12     Sutafar Tihir [phoen] company and Mosque Pigeons company, then some axes

13     are being mentioned to be reconnoitered by Mosque Pigeons, Rozanj and

14     Spasojevici, Djulici, Boskovici, Djakici [phoen], Klisa, et cetera.

15             Does this indicate that the entire Muslim territory of Zvornik

16     municipality was covered by military units that had very precise tasks?

17        A.   Yes.

18        Q.   We see that this was signed by Semsudin Muminovic, although the

19     translators were unable to read it; is that right?

20        A.   Yes, that is the signature of Semsudin Muminovic.

21        Q.   Thank you.

22             THE ACCUSED: [Interpretation] Can this be admitted.

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1621, Your Honours.

25             THE ACCUSED: [Interpretation] Can we now have 65 ter 00621.

Page 17441

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Is it true that you stated earlier and is it true that the

 3     Serbian authorities in Zvornik municipality called upon both the Muslims

 4     and the Serbs to go back to work and to come to live again in Zvornik?

 5        A.   Yes.

 6             JUDGE KWON:  Yes, Mr. Nicholls.

 7             MR. NICHOLLS:  Can we get a time-frame?

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Is it true that immediately from the very beginning, i.e.,

10     in mid-April, the Serbian authorities called upon the people to go back

11     to work, both the Muslims and the Serbs, and to come back to live in

12     their own houses?

13        A.   Yes, that was in early April.

14        Q.   In other words, you're trying to say that while the authorities

15     were operational, that's what they did?

16        A.   Yes.  After that, it made no sense, because the Muslims and the

17     Serbs separated and they each had their pure -- ethnically pure

18     territories.

19        Q.   Can you please now focus on what -- on the 8th of May.  The

20     authorities of the Muslim municipality of Zvornik announced as a

21     declaration for the population against the return.  In order for me not

22     to read everything, can you just say that what they say here is that they

23     should take to arms to go to the forest.  They are not to be placed --

24     not to place themselves at the disposal of the Territorial Defence,

25     et cetera.

Page 17442

 1        A.   Yes.  This is the essence of their declaration.  Instead of going

 2     to the places under the Serb control, they are invited to go to the

 3     forest and put up resistance.

 4        Q.   Is this also consistent with the fact that it was necessary to

 5     persuade the Muslims to fight?

 6        A.   Yes.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] Can this be admitted?

 9             JUDGE KWON:  Has the 65 ter number of this document been

10     notified?  What's the 65 ter number of this?

11             THE ACCUSED: [Interpretation] 621.  That's how I called it, as

12     621.

13             JUDGE KWON:  No.  That has been not reflected in the transcript,

14     so that's why I asked the question.  Yes.  This will be admitted.

15             THE REGISTRAR:  As Exhibit D1622, Your Honours.

16             THE ACCUSED: [Interpretation] Quite briefly, can we -- one -- at

17     1D1596.  It's been admitted and MFI'd.

18             MR. KARADZIC: [Interpretation]

19        Q.   Since this has been admitted, I won't spend too much time on

20     this.  Can you see that on the 10th of July it's being ordered to link up

21     the Muslim territory in Podrinje through armed combat?  Can you see that?

22        A.   Yes.

23        Q.   And also mentioned, there are Kamenica and other parts of other

24     municipalities.  Does this include Zvornik, Bratunac, Srebrenica, and

25     Vlasenica municipalities?

Page 17443

 1        A.   Yes.

 2        Q.   Can we briefly look briefly at 65 ter 16061.

 3             JUDGE KWON:  At this moment, we can fully admit the previous

 4     document without having to mark it for identification since we have the

 5     full translation.  That will be done.

 6             THE ACCUSED: [Interpretation] It bears the same number; right?

 7             JUDGE KWON:  Yes.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Can you please look at this document.  Is it true that in

10     paragraph II it is said that here we have the commissioner's office --

11     or, rather, the commissioner Dragan Djokanovic.  He says that due to the

12     specific situation, the shortage of personnel, they failed to resolve the

13     issue of the chief of the public security station and are therefore

14     seeking help.

15        A.   Yes.

16        Q.   For security reasons, armed civilians and soldiers should be

17     prohibited in the town, except for police, military police, and persons

18     with special authorisation; right?

19        A.   Yes.

20        Q.   That was in the beginning of July, and the [indiscernible] took

21     place in late 1992.  Dragan Djokanovic was making an inference here about

22     the people who were subsequently arrested; is that correct?

23        A.   Yes.

24             THE ACCUSED: [Interpretation] Could this be admitted?

25             JUDGE KWON:  Yes.

Page 17444

 1             THE REGISTRAR:  As Exhibit D1623, Your Honours.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Can we now look at 65 ter 16062 briefly.  It shouldn't be

 4     broadcast, please.

 5             Please look at this document.  This is the session of the

 6     Serbian Assembly of Zvornik.  (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)  Can we now have page 4 in the

11     Serbian, and I believe it's the same page in the English as well.  It

12     starts with item 9.

13             Does it say here that the Assembly adopted the proposal and gave

14     its support to the decision of the Serbian people to have the rule of law

15     and to -- on the establish of war offices and disbanding of Crisis Staff,

16     and that the Assembly insists on order to be resumed and to rectify all

17     the irregularities, to evict all the people who were --

18             THE INTERPRETER:  Could the accused please tell where he's

19     reading from.

20             JUDGE KWON:  Interpreters cannot follow you.

21             THE ACCUSED: [Interpretation] That's because I'm in a hurry.  I

22     quite understand.  Can we have the next page in English.

23             MR. KARADZIC: [Interpretation]

24        Q.   Do you remember this session, and do you remember that these

25     conclusions were adopted, and do you remember that a huge number of

Page 17445

 1     enactments were adopted in order to introduce the rule of law?

 2   (redacted)

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] Can this be admitted?

 5             JUDGE KWON:  Yes.  Just a second.  Shall we go into private

 6     session.

 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 17446

 1                           [Open session]

 2             JUDGE KWON:  Yes.  We'll admit this.

 3             THE REGISTRAR:  As Exhibit D1624, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Can we now look at 65 ter 18397.  There's a translation of this

 6     document available.  Please focus on this document, which is actually a

 7     report on the work of the public security station relating to July,

 8     August, and September.  As a citizen and as the person who participated

 9     in the work of the Assembly, you were able to be informed about the

10     situation.

11             Now, look at paragraph 2.  What kind of problems was this station

12     facing, because it seems that paramilitary formations were the main

13     problem.

14        A.   Yes.

15        Q.   Let us go to the following page in English.  It's also the second

16     paragraph in English.  The difficulties are stated that made impossible

17     the work of the station but also that of other state bodies.  The

18     activities of the paramilitaries contributed to a creation of an

19     atmosphere of fear and uncertainty with the citizens and made possible

20     theft and so on.  Do you agree that these paramilitary groups took over

21     policing without authorisation, set up check appointments where they took

22     away cars and other goods from citizens without any authorisation to do

23     so?

24        A.   Yes.

25        Q.   And it goes on to say that the MUP special unit in late July

Page 17447

 1     routed the paramilitaries and enabled the station to assume its legal

 2     function again; is that correct?

 3        A.   Yes.

 4        Q.   In the examination-in-chief, Mr. Nicholls very skilfully tried to

 5     create the impression, or, perhaps that's how I understand it, that the

 6     arrest of these paramilitaries only came about because they maltreated

 7     the minister.  Is it correct that these groups were arrested because of

 8     what we can read in this document or because they arrested the minister?

 9        A.   They engaged in lots of activities and the minister was only one.

10     It was mostly because of the situation in Zvornik and because they

11     harassed the Crisis Staff, the transitional government, because they took

12     away people for executions and so on.

13        Q.   Is it correct, and I would like to refrain from using the name of

14     the late minister, they made him to eat grass and he wouldn't, and he

15     almost got killed because of that?

16        A.   Yes.  That's common knowledge.

17        Q.   And it says here that only on the 18th of September, with the

18     assistance of military organs, the collection centre at Divic where there

19     were 90 persons, mostly women, elderly persons, and children was

20     disbanded; whereas in prison, there were 56 more persons.  In Divic, we

21     can conclude that there were mostly women, elderly persons and children.

22     And is that what Grujic meant when he said that children were

23     accommodated in abandoned facilities?

24        A.   Probably.

25             MR. NICHOLLS:  Yeah.  Just I don't think he can say what

Page 17448

 1     another -- what Mr. Grujic meant.

 2             JUDGE KWON:  I agree, Mr. Nicholls.

 3             Mr. Karadzic.

 4             THE ACCUSED: [Interpretation] Can we see the following page in

 5     Serbian.  I believe it's also found -- page in English.  And there it

 6     says that a special difficulty in the work of the station was the

 7     impossibility to communicate with the Sarajevo CSBs by telephone which

 8     negatively affected the efficient tackling of some issues.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Is that in line with what you know?  It's the third paragraph.

11        A.   Yes.

12        Q.   Thank you.  Can we see the following page.  I hope that you have

13     understanding with regard to the English page.  Does it say here that the

14     police station in its daily work encounters many problems among which

15     there are insufficient personnel strength, insufficient training level,

16     and the shortage of pistols, only 20 per cent have pistols, the shortage

17     of cuffs.  There were no off-road vehicles.  The existing rolling stock

18     that is nine vehicles have gasoline engines.  And at that time policing

19     is done by paramilitaries who have no authorisation to do that.  And they

20     have made stockpiles of Golf vehicles in their yards; correct?

21        A.   Yes.

22        Q.   Can we see the following page.  In English, it's section B.  We

23     see that 102 criminal offences reported, of which 55 were solved.  And

24     there's a break-up of these offences, and then they go on to say that

25     because the court and the municipal prosecutor's office are not

Page 17449

 1     functional --

 2             THE INTERPRETER:  We didn't hear the end of the question -- or,

 3     rather, the question that the accused put.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   The last part of the question was not recorded right.  We should

 6     go to the following page in English.  It says that because the court and

 7     the district prosecutor's office are not functional, 31 criminal reports

 8     were not submitted.  What is meant is probably 31 more reports; correct?

 9        A.   Yes.

10        Q.   To your mind, these 52 per cent or so of solved crimes under the

11     circumstances is a considerable success?

12        A.   Yes.

13        Q.   Thank you.

14             THE ACCUSED: [Interpretation] I seek to tender this document.

15             JUDGE KWON:  Yes.

16             THE REGISTRAR:  As Exhibit D1625, Your Honours.

17             THE ACCUSED: [Interpretation] Can I get a discount, as it were,

18     to show some more documents and a video that will -- that will contribute

19     to a better understanding of the relations on the part of the

20     Trial Chamber?

21             Is it my turn?

22             JUDGE KWON:  Yes.  I didn't follow what you meant by "discount."

23             THE ACCUSED: [Interpretation] I asked for some additional time.

24             JUDGE KWON:  I think you have around five minutes to conclude.

25             And can I ask you for planning purpose how much time would you

Page 17450

 1     need for your redirect, Mr. Nicholls?

 2             MR. NICHOLLS:  We have less than half an hour, Your Honour.

 3             JUDGE KWON:  Conclude before -- by 12.00, when we can have a

 4     break.  You have 10 minutes, 10 or 12 minutes.

 5             THE ACCUSED: [Interpretation] Thank you.  Can we take a look at

 6     65 ter -- or was this one admitted?  Does it have a new number?  Let's

 7     then look at 65 ter 12158.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Do you agree that this is an official note of the

10     Crime Prevention Administration at Pale, that is the MUP headquarters?

11     And here on page 1, 18 names of arrested persons are listed.  These are

12     mostly persons born in Zvornik, but there are also two Hungarians from

13     Vrsac, number 13 and 14; correct?

14        A.   Yes.

15        Q.   And the -- the others are all born in Zvornik, more or less.

16             THE ACCUSED: [Interpretation] Can we see the following page --

17     or, rather, page 3 since it contains the authentication.

18             [In English] Is it admitted already, no?

19             MR. NICHOLLS:  My question was --

20             JUDGE KWON:  Yes, Mr. Nicholls.

21             MR. NICHOLLS:  Sorry.  Just my question was is this on the list?

22     I can't seem to find it in what we got.

23             THE ACCUSED: [Interpretation] On the list -- well, possibly we

24     omitted to put it on the list in time, but I kindly ask for

25     understanding.

Page 17451

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Can we see the following names in the signature block,

 3     Ljubomir Kovac, Sasa Blagojevic, and Dejan Vaskovic?  And do we see 21

 4     names, and among them Pivarski.  Stojan Pivarski is number 17 on page 1.

 5     And let me ask you, on the seventh line from the bottom, some of them who

 6     used to be under the command of Vojin Vuckovic joined this unit several

 7     days prior to being arrested and had not participated in the current

 8     activities of combat operations.  Is that the reason why they were not

 9     detained but instead sent to regular units?

10        A.   Yes.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] I seek to tender this document,

13     after which I would like to show some very short video-clips that will

14     illustrate the relationship between Kula Grad and Zvornik, and so on.

15     Can this be admitted?

16             JUDGE KWON:  These are interviews --

17             THE ACCUSED: [Interpretation] This is an official report about

18     the arrest of 21 persons.  It's the MUP headquarters submitting the

19     report.

20             JUDGE KWON:  Not interviews themselves.

21             Mr. Nicholls?

22             MR. NICHOLLS:  No objection.

23             JUDGE KWON:  Very well.  This will be admitted.

24             THE REGISTRAR:  As Exhibit D1626, Your Honours.

25             THE ACCUSED: [Interpretation] Thank you, Excellencies.  I called

Page 17452

 1     up this document most of all to show why not everybody was arrested.

 2     This document shows that there wasn't a reason for some persons --

 3             MR. NICHOLLS:  Objection, argument.

 4             JUDGE KWON:  This is not the time for your statement or

 5     submission.  You have five minutes to --

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Let us take a look at 1D389.  This should be a video-clip.  It

 8     should be the view of Zvornik from Kula Grad.

 9                           [Video-clip played]

10             MR. KARADZIC: [Interpretation]

11        Q.   Was Zvornik named after the -- a church or belfry from olden

12     times, and was there a very old Christian church from the 12th or 13th

13     century?

14        A.   Yes.  That is how the town was named.  The church was built at

15     the time of Djuradj Brankovic.

16        Q.   Is this the view of Zvornik from Kula Grad, and were civilians

17     shot at from this location?

18        A.   Yes.

19             THE ACCUSED: [Interpretation] Can this be admitted?

20             JUDGE KWON:  Yes.  Yes, Mr. Nicholls.

21             MR. NICHOLLS:  No objection, but just for the record is this

22     created -- a recent video; is that correct?

23             JUDGE KWON:  Yes.

24             MR. NICHOLLS:  All right.  Thank you.

25             JUDGE KWON:  With that understanding, we will admit it.

Page 17453

 1             THE REGISTRAR:  Exhibit D1627, Your Honours.

 2             THE ACCUSED: [Interpretation] Can we get 1D3990.  It's also a

 3     view of both Zvornik and Mali Zvornik.

 4                           [Video-clip played]

 5             THE ACCUSED: [Interpretation] And let me explain that

 6     Mali Zvornik is a part of town that is in Serbia and it is now and has

 7     always been a separate municipality.

 8             THE WITNESS: [Interpretation] Yes.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Is this Mali Zvornik, as seen from Kula Grad?

11        A.   Yes.

12             THE ACCUSED: [Interpretation] Can this be admitted?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1628, Your Honours.

15             THE ACCUSED: [Interpretation] Can we see 1D3992.  We'll skip one

16     because there isn't time.

17                           [Video-clip played]

18             MR. KARADZIC: [Interpretation]

19        Q.   This is Kula Grad, the fort; correct?

20        A.   Yes.

21        Q.   Can Divic be seen from here?  And the peninsula, is that Divic?

22        A.   Yes, it can clearly be seen.

23        Q.   And this is the dam, and Divic is in the upper part; correct?

24        A.   Yes.

25        Q.   And Divic has a mosque, as we can see here, and that was a Muslim

Page 17454

 1     settlement?

 2        A.   Yes, predominantly Muslim.

 3             THE ACCUSED: [Interpretation] Can this be admitted?

 4             MR. KARADZIC: [Interpretation]

 5        Q.   So from Kula, they were able to shoot at any house and any

 6     street; correct?

 7        A.   Yes.

 8             JUDGE KWON:  With the same understanding, we'll admit this as

 9     Exhibit D1629.

10             THE ACCUSED: [Interpretation] Can we see one last thing, 1D3995.

11                           [Video-clip played]

12             MR. KARADZIC: [Interpretation]

13        Q.   This is Kula Grad as seen from Zvornik.

14        A.   Yes.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can this be admitted.

17             JUDGE KWON:  Exhibit D1630.

18             Your last question, Mr. Karadzic.

19             MR. KARADZIC: [Interpretation]

20        Q.   Witness, did you ever know of any bad intentions or wicked plan

21     on the part of the regular authorities with regard to any individual

22     group in your municipality?

23        A.   No.

24        Q.   Thank you for your evidence and for your patience.  I was in a

25     hurry, and it may not all have been very clear, but thank you for

Page 17455

 1     understanding.

 2        A.   You're welcome.

 3             JUDGE KWON:  Mr. Nicholls, I told you that we would have a break

 4     before your redirect, but if you could conclude, as you indicated, in

 5     less than half an hour, we can continue before the break and start with

 6     the next witness in the next session.  Yes, Mr. Nicholls.

 7             MR. NICHOLLS:  Thank you.  Just one moment.

 8                           Re-examination by Mr. Nicholls:

 9        Q.   Now, sir, you were asked a lot of questions today about military

10     formations of the Muslim units, Muslim paramilitaries, when they took

11     certain towns, where they were -- where they were based, how they were

12     armed.  Do you remember answering all those questions?

13        A.   Yes, I did answer those questions.

14        Q.   And at the period we're talking about, at no time were you a

15     member of -- or you tell me, were you a member with the TO or the VRS up

16     to the end of 1992?

17        A.   Well, I was mobilised for about two or three months, not more

18     than that.  I held these positions in the business community.

19        Q.   Yeah.  So while you had the position you told us about, you were

20     also mobilised.  For which months?

21        A.   Well, I'm for the sure.  I think it was sometime in May, and then

22     as we were directors from various firms, the army would mobilise us

23     during holidays when people did not work for a few days, and then we went

24     to help out the regular army, just to give them a break of a few days.

25     But on the whole in 1992, it wasn't more than 60 to 80 days.

Page 17456

 1        Q.   Thank you.  Could I have 65 ter 22022, please.  It's a map.

 2             All right, sir.  This is a map entitled -- military map,

 3     obviously, entitled "Operation Priboj."  We can see it's from January

 4     1993, from the command of the Drina Corps.  It's hard to read in this

 5     size, but it's in the translation at the top left.

 6             MR. NICHOLLS:  Can blow up the map a little bit so that we can

 7     see clearer the area within the blue lines.  All right.

 8        Q.   Sir, now, from your military experience, and it's basic knowledge

 9     for those of us who work in this Tribunal, the red lines are -- is the

10     outline of the Serb side's positions, trenches; correct?

11        A.   Yes.

12        Q.   And then the area inside would indicate the area held at this

13     point by the ABiH or Muslim forces; correct?

14        A.   Yes.

15        Q.   Okay.  Using that electronic pen which you've seen -- you've used

16     before, could you please mark where Konjevic Polje is on this map.

17        A.   [Marks]

18        Q.   Thank you.  Can we put a 1 by that?

19        A.   [Marks]

20        Q.   And could you please mark Udrc -- or, sorry, I have trouble

21     pronouncing this, Udrc to the left.  I can spell it:  U-r-d-ch [sic].

22        A.   I can't see it.  It's somewhere between Drinjaca and

23     Konjevic Polje here.

24             JUDGE KWON:  Which bears the number 1042?

25             THE ACCUSED: [No interpretation]

Page 17457

 1             JUDGE KWON:  I didn't hear your words through interpretation,

 2     Mr. Karadzic.

 3             THE ACCUSED: [Interpretation] Does Mr. Nicholls mean 1402 on the

 4     left-hand side?

 5             MR. NICHOLLS:  [Microphone not activated]... thank you.

 6        Q.   Well, sir, I don't think you'll mind me leading here.  If you

 7     look to the west and north and look up, you'll see that mountainous

 8     region with 1042 on it.

 9        A.   Yes, yes.  Sorry.

10        Q.   Mark that with a 2, please.

11        A.   [Marks]

12        Q.   And just a couple more.  Paljevine.

13        A.   I lived on the other end of the municipality, so I have heard of

14     all of these villages, but I'm not sure whether I can actually find my

15     way.

16        Q.   Well, this one, I think, we can skip that.  We can skip that.

17     Kamenica and Snagovo.  You know where those are, I'm sure.

18        A.   Yes.

19             MR. NICHOLLS:  We may need to pull the map down a bit, please, so

20     that he can see higher on the map.

21             JUDGE KWON:  It's difficult.  After having made these markings,

22     we can -- or we can zoom out and then do the exercise again.

23             MR. NICHOLLS:  Well, you know, to save time, I'll keep moving,

24     Your Honours.  If we can just mark this, I think we all know where

25     Kamenica is.

Page 17458

 1             JUDGE KWON:  Yes.  We -- we have a mark in Kamenica.  Shall we

 2     put number 3 for that?

 3             MR. NICHOLLS:  Thank you.

 4             THE WITNESS:  [Marks]

 5             MR. NICHOLLS:  And if we can save this and then we can just move

 6     out and see where Snagovo is.

 7             JUDGE KWON:  Could you put the date and your signature.

 8             MR. NICHOLLS:  KDZ.

 9             JUDGE KWON:  Your number.

10             THE WITNESS: [Marks]

11             JUDGE KWON:  Shall we delete that, and you need to sign as your

12     number, which is KDZ-555.

13             MR. NICHOLLS:  And I omitted one other point just before we have

14     the witness -- before we save it.

15        Q.   And, sir, before --

16             JUDGE KWON:  555, yes.  Thank you.

17             MR. NICHOLLS:  Thank you.

18        Q.   And before we save that, could you also please mark Cerska.

19        A.   I've never been there, but I can see it's there on the map.  I've

20     never heard of it until the UN resolution was passed.

21             JUDGE KWON:  And number 4.

22             THE WITNESS: [Marks]

23             MR. NICHOLLS:

24        Q.   Okay.  So you grew up in this region, spent time there as an

25     adult, worked in the occupation we've heard about, and you never heard of

Page 17459

 1     Cerska?  Just making sure that's --

 2        A.   Never.  Believe me.  Half of the people of Zvornik -- believe me,

 3     before the UN resolution on Cerska was passed, I had never heard of it,

 4     and I hadn't known that it was in the area of the municipality of

 5     Zvornik.  If you were to ask half of the people from Zvornik whether they

 6     had heard of Cerska before that, they hadn't.

 7        Q.   All right.

 8             MR. NICHOLLS:  We can save that please.  And we've seen now the

 9     area, the front lines in the beginning of 1993, the very beginning.

10             JUDGE KWON:  We'll give the next Prosecution exhibit number.

11             THE REGISTRAR:  That will be Exhibit Number P3160.

12             JUDGE KWON:  So what was the question in relation to these

13     places?

14             MR. NICHOLLS:

15        Q.   Well, just, Witness, we can see -- you agree with me that these

16     areas you've marked are either inside the Muslim-controlled region or

17     just on the edge?

18        A.   Well, it depends on the period we're talking about.  If we're

19     talking about the end of 1992, they were under the control of the

20     Muslims.

21        Q.   I'm talking about January 1993.

22        A.   January 1993?  Under the control of the Muslims.

23        Q.   Thank you.  Now, could I bring up P2085, please.  All right,

24     Witness, you know who Miljenka Ivanovic is; correct?

25        A.   Yes.  He was commander of the Drina Corps.

Page 17460

 1        Q.   All right let's look at this order of his from 24th November

 2     1992, a couple of days of Mr. Karadzic visited Zvornik.  Because of time,

 3     I want to just look at this very urgent decision for further operations.

 4     Under paragraph 1, if you look in your language you'll see what the order

 5     is -- what the decision is:

 6             "Launch an attack using the main body of troops and major

 7     equipment to inflict on the enemy the highest possible losses, exhaust

 8     them, break them up and force them to surrender, and force the Muslim

 9     local population to abandoned the area of Cerska, Zepa, Srebrenica and

10     Gorazde."

11             And then it continues.  Did you read that?

12        A.   Yes.

13        Q.   Can we go to the next page.  And go down to the portion -- to

14     point 3(c) so that can be read.

15        A.   In the Serbian version I don't have it.  There's only 3(a).

16        Q.   [Microphone not activated]... yeah, here we have it.  This is:

17             "Moral and psychological preparations:  Before initiating any

18     kind of operation, inform the unit members about the important aim of

19     that operation and underline that the outcome of minor actions and of the

20     whole operation is of a crucial importance for the realisation of the aim

21     of the Serbian people, namely, the creation and establishment of a

22     Serbian state in these areas."

23             So, Witness, you testified -- Witness, you testified today on

24     cross-examination about your understandings of the object of the Serbian

25     people and any questions from Mr. Karadzic and about Muslim operations.

Page 17461

 1     Let me ask you, this operation --

 2             JUDGE KWON:  Mr. Nicholls.

 3             THE WITNESS: [Interpretation] Yes.

 4             JUDGE KWON:  Is English channel working okay?  It's now working,

 5     but -- I think the witness has been following you, as well as the

 6     transcript.  Let's move on.

 7             MR. NICHOLLS:

 8        Q.   So you were aware of this operation to remove the Muslim

 9     population -- Muslim population from the area we saw on that map, some of

10     the places?

11        A.   Yes, we as citizens understood that the aim was to link up the

12     territory.  They were holding some territory and split our forces into

13     two parts, and we didn't have -- we couldn't communicate with half of the

14     Republika Srpska.  The objective was to open the road through

15     Konjevic Polje and it was also economically significant because ore could

16     be brought to Zvornik.

17             MR. NICHOLLS:  Could I now have 65 ter 21955.

18        Q.   Sir, you're familiar with the officer named Svetozar Andric?

19        A.   Yes.

20        Q.   Just very quickly, following up on the map we saw and the order

21     from General Zivanovic, I'd like you to look under paragraph 3 here,

22     which -- we need to go to the next page in the Serbian.  Thank you.

23             And here we see Andric reporting to the Drina Corps command, to

24     Zivanovic.  Shortly after that order we saw:

25             "In the course of the day, special units of the 1st Birac Light

Page 17462

 1     Infantry Brigade took and destroyed the village of Gobelji thus fleeing

 2     -- freeing up the left flank of the main forces in the attack on Cerska."

 3             And if I could look at now, and then the last question, 08265.

 4     The 2nd of March, another report to the Drina Corps command by Andric.

 5     If you look at paragraph 2:

 6              "Our forces which are moving in the wider area of Kamenica,

 7     Gajici and Grobici worked according to the plan without major problems.

 8     The village of Gobelji has been burnt and tomorrow the plan is to do

 9     Paljevine."

10             Signed again, Andric.

11        A.   Yes.  It says Paljevine, but I believe it's the village of

12     Paljevici so it doesn't signify that anything was burned.

13        Q.   No, to burn Paljevine, which is a region; correct?

14        A.   He said the plan for tomorrow is to do Paljevine, but I believe

15     that it's the village of Paljevici, and it says that the village of

16     Gobelji has been burnt.

17        Q.   Yes.  And it says the plan tomorrow is to do Paljevine.  Now my

18     question is:  You showed a lot of knowledge answering yes to these very

19     long questions by Mr. Karadzic about containing many, many facts of

20     Muslim military operations.  Is this correct that same knowledge you had

21     at the time, that these operations were undertaken, these villages were

22     burnt in order to create a Serbian state in this region?

23             THE ACCUSED: [Interpretation] I have an objection.  Can I state

24     it?  The question implies something that was not said.

25             JUDGE KWON:  Yes.  It has the nature of a leading question.

Page 17463

 1     Could you reformulate it, Mr. Nicholls.

 2             MR. NICHOLLS:  All right.

 3        Q.   Witness, what do these, from your knowledge, and I've shown you

 4     these documents -- what was the aim of these military operations we have

 5     just looked at?  And how did they tie into the plan of the Serb people,

 6     desires of the Serb people at that time?

 7        A.   At the time, and we're talking about 1993, I had an official

 8     position in the municipality of Zvornik.  I was aware of this operation,

 9     and I understood it this way:  That its objective was to reach a line at

10     Divici, which is 2 kilometres from Zvornik, and thus put an end to

11     constant attacks.  The second goal was to liberate the road that connects

12     the eastern part of Republika Srpska with the rest, and it has a great

13     economic significance because the largest factory had its supply road

14     from Milici that way.  And --

15             THE INTERPRETER:  Could the witness please repeat what he said

16     about Konjevic Polje.

17             JUDGE KWON:  Mr. Witness, could you repeat what you said about

18     Konjevic Polje.  The interpreters couldn't hear that part.

19             THE WITNESS: [Interpretation] Without that road through

20     Konjevic Polje, the Republika Srpska was divided into two parts.

21             MR. NICHOLLS:  Could I have 02955, please.

22             JUDGE KWON:  Did you mind to tender those two documents?

23             MR. NICHOLLS:  Yes, Your Honour.  Thank you.

24             JUDGE KWON:  [Overlapping speakers]... Mr. Andric.  We'll admit

25     them each.

Page 17464

 1             THE REGISTRAR:  As Exhibits P3161 and 3162 respectively.

 2             MR. NICHOLLS:  This is not 02955, unless I have my -- unless my

 3     number is correct.  Exhibit number, sorry, 02955.  I should have said P.

 4        Q.   Now, a little bit earlier, December 1992, Witness, I'd like you

 5     to look at the third paragraph here.  This ties into what we were talking

 6     about, as well as your testimony today about paramilitaries, and I'll

 7     read it out.  This is another Drina Corps document:

 8             "With the arrival of paramilitary organisations to the Zvornik

 9     municipality, particularly the arrival of Arkan and his people, this

10     territory was liberated from the Turks.  Turks made up 60 per cent of the

11     municipality's population and now it has been cleansed and replaced with

12     an ethnically pure Serb population."

13             Do you see that, sir?

14        A.   Yes.

15        Q.   And this is signed by the chief of the organ for operations and

16     training, Miladin Prstojevic.  Did you know him?

17        A.   No.

18        Q.   Can you reconcile that assessment with some of what -- the yes

19     answers we've been hearing from you today?  If you could explain it.

20        A.   Well, these are both correct.  Most of the municipality of

21     Zvornik in late 1992 was controlled by Muslim units, which can be seen

22     from the map that you also showed, and it's also true that this report

23     written on the 17th of December, 1992, that the part controlled by the

24     Serbs was ethnically pure.  There was an insignificant number of Muslims

25     and Croats who left behind, maybe a hundred or not more.  Everything else

Page 17465

 1     was ethnically -- ethnically pure.  I mean, if that's the gist.  Because

 2     the passage under that says that a large number of Serbs was brought in

 3     and settled here and that corroborates this story.

 4        Q.   So if I understand, you agree that this assessment is accurate.

 5             THE ACCUSED: [Interpretation] Objection.  The witness did not

 6     agree.

 7             THE WITNESS: [Interpretation] I said that he writes here -- or

 8     can you analyse it if you want.  The Zvornik municipality was liberated

 9     by the Turks, which means that it's ethnically clean, and it's much less

10     than one-half of the municipality where the Serbs lived.  And in December

11     1992, it was almost -- almost ethnically pure because a negligible number

12     of Muslims and Croats lived there.  And it goes on to say that their

13     [indiscernible] Arkan and his people, this territory was liberated from

14     the Turks.  The Turks made up 60 per cent of the municipality's

15     population.  It has been cleansed and replaced with an ethnically pure

16     Serb population.  Well, this is not correct.  No Serb soldiers went

17     beyond Sapna.  Major Jago Dus [phoen] and so on.  Then there's Zaseok,

18     Nezuk, and the other villages, Zuje Carci [phoen] and many more.  There

19     were no combat activities there ever because the Muslims were always the

20     majority there and they controlled that all the time.  Even now they

21     belong to the federation of BH according to the ethnic division.

22             MR. NICHOLLS:  Your Honours, I'm sorry, I would need about five

23     more, minutes if I may, for one small discrete --

24             JUDGE KWON:  I have to inquire of the technical booth whether we

25     have tape for the five minutes.

Page 17466

 1                           [Trial Chamber and Registrar confer]

 2             JUDGE KWON:  I think we can go for five minutes more.

 3             MR. NICHOLLS:  Thank you.

 4        Q.   Very quickly, sir, and be as quick as you can, do you know where

 5     the village of -- or small hamlet of Scemlija is, just a little bit to

 6     the west of Zvornik, close by Zvornik.

 7        A.   Scemlija.

 8        Q.   Okay.  How far is that from Zvornik?  What is the distance from

 9     Zvornik?

10        A.   Scemlija is not even two kilometres away from Zvornik.

11        Q.   All right.  Could I have D1610, please.  This is the intercept.

12     And if I could go to the last two pages, please.  We've already seen

13     this.  Second to last page of the English.

14             All right.  Now, you've testified that there was no person such

15     as Milorad Bogicevic in Zvornik, to your knowledge; correct?

16        A.   Yes.

17        Q.   Let's look quickly because we didn't go through it in much detail

18     when Mr. Karadzic brought it what is said about the weapons.  On page 4

19     of the English:

20             "Karadzic:  Hubre [phoen] handed out weapons.

21             "Bogicevic:  He fuck it.

22             "Karadzic:  That's not true.  Don't fuck with me.  Why do you but

23     bullshit over the phones?  It's not true that anybody from the party has

24     something to do with the distribution of weapons.  Are you mad?

25             "Bogicevic:  Fuck it.

Page 17467

 1             "Karadzic:  Fuck what?  One of you fuck it a little.

 2             "Bogicevic:  Here at our place."

 3             On the next page in English.

 4             "Karadzic:  Where at your place?  Don't give me this bullshit

 5     over the phone.  Bye.

 6             "Bogicevic:  Have a nice day."

 7             Again this was from suggest 1991.  Again, you've never heard of

 8     this man, Bogicevic?

 9        A.   The family name of Bogicevic is present in the Zvornik

10     municipality.  I believe they live around the Drinjaca, but I've never

11     heard of Milorad Bogicevic, nor was there such a person in any structure.

12        Q.   So you haven't hear of him.  P2872, please.  This is a payroll of

13     TO members of the Serbian municipality of Zvornik for the month of May,

14     1992.  Could we go to the next page in B/C/S and the next page in

15     English.  That's the correct page of the English.  Could we keep going

16     through the B/C/S, to the last page of the B/C/S.  Excuse me.

17             All right.  This is a 10th of June, 1992, receipt to confirm that

18     Stojan Pivarski has received money for the special purpose unit.  Now

19     very quickly, Stojan Pivarski was a volunteer or paramilitary leader;

20     correct?

21        A.   Yes.

22        Q.   Okay.  What's the first name on the list of men for the May

23     payroll for the Pivarski special unit?  Read it out.

24        A.   Milorad Bogicevic from Scemlija.

25        Q.   So now do you still think that that phone call was from an

Page 17468

 1     anonymous person?

 2        A.   I don't know if this man, Milorad Bogicevic, existed.  Because,

 3     you know, a man in Zvornik whom I don't know, and you can check whether

 4     anybody else knows it, it's unlikely that he would call up the president

 5     or the political party.  I mean, I don't know.  But I still claim I don't

 6     know Milorad Bogicevic, and I doubt that there is such a person in

 7     Scemlija because there is nobody with that last name at Scemlija (redacted)

 8     (redacted)  People from Vercevici [phoen], Baljkovica,

 9     Zevalje [phoen], Setici, and so on, are mentioned here.  So I'm not sure

10     if this might not be a Milorad Bogicevic who is a volunteer, because this

11     is in the context of Pivarski.

12             MR. NICHOLLS:  Thank you, Your Honours, very much, for the extra

13     time.

14             THE ACCUSED: [Interpretation] I have just a minute or half a

15     minute?

16             JUDGE KWON:  In relation to this document?

17             THE ACCUSED: [Interpretation] No, in relation to Cerska and that

18     area.  I only need half a minute, not more.

19                           [Trial Chamber confers]

20             JUDGE KWON:  Yes, just one question, Mr. Karadzic.

21                           Further Cross-examination by Mr. Karadzic:

22        Q.   [Interpretation] Just to make it easier for you, Cerska belongs

23     to Vlasenica.  That's why I didn't know it.  Please, can you confirm that

24     the concentration of Kamenica and Rudic, and so on, were places that we

25     left alone for a year.  When we asked them not to fight us, whereas they

Page 17469

 1     did fight us every day, and there was a military justification.  And --

 2     and they fought in civilian clothes.  Can you confirm that?

 3        A.   Yes.  Slavkovic was killed when he went to Kamenica to negotiate.

 4        Q.   You mean the negotiator [Realtime transcript read in error,

 5     negotiate"] was killed?

 6        A.   Yes.

 7             JUDGE KWON:  Thank you, Mr. Witness.  That concludes your

 8     evidence at the Tribunal.  On behalf of the Tribunal and the Bench, I

 9     would like to thank you for your coming to The Hague to give it.  So now

10     you're free to go, but please wait until the curtain is prepared.

11             THE ACCUSED:  "Negotiator."  I would like to intervene in the

12     transcript.  "The negotiator was killed."

13             JUDGE KWON:  We'll have a break for half an hour and resume at 10

14     past 1.00.

15                           --- Recess taken at 12.37 p.m.

16                           --- On resuming at 1.13 p.m.

17             JUDGE KWON:  Yes, Mr. Tieger.

18             MR. TIEGER:  Thank you, Mr. President.  As you know, we'll have

19     to move into private session for the next witness.  I wanted to do that

20     quickly now, because I have two unrelated matters that need to be raised

21     in private session as well, and I thought it best to do that before the

22     witness entered.

23             JUDGE KWON:  Yes.  We go back -- go to private session briefly.

24                           [Private session]

25   (redacted)

Page 17470











11  Page 17470 redacted. Private session.















Page 17471

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             JUDGE KWON:  Yes.  We are in open session.

 5             It's about the witness after next, KDZ-029.  I noted that a file

 6     has been -- a motion has been filed, and I follow that you understand

 7     what it is about.

 8             MR. TIEGER:  Yes, Your Honour.

 9             JUDGE KWON:  I wonder whether Prosecution can orally respond to

10     that motion tomorrow morning at the beginning of tomorrow morning's

11     hearing, and I -- I hope that in the response the Prosecution should

12     identify why that one page proofing note referred to in the motion was

13     not disclosed earlier.

14             MR. TIEGER:  Your Honour, I think we're in the process of

15     expediting a written response as well.  I understand the Court's interest

16     is in getting a response as quickly as possible for very understandable

17     reasons.  I take it that if we are able to complete the written

18     submission in the same period of time the Court would also welcome that.

19             JUDGE KWON:  Very well.  Let's bring in the witness.

20             We go to private session -- or we don't have to.

21                           [The witness entered court]

22             JUDGE KWON:  Good afternoon, sir.  If you could take the solemn

23     declaration, please.

24             THE WITNESS: [Interpretation] I solemnly declare that I will

25     speak the truth, the whole truth, and nothing but the truth.

Page 17472

 1                           WITNESS:  KDZ-340

 2                           [Witness answered through interpreter]

 3             JUDGE KWON:  Thank you, sir.  Please make yourself comfortable.

 4     Please be seated.

 5             Yes, Mr. Tieger.

 6             MR. TIEGER:  Mr. President, I didn't know if the Court wished

 7     to -- I note it has in the past occasionally described the nature of the

 8     protective measures.  I don't insist the Court do so, I just didn't know

 9     if that was something the Court intentionally omitted or not.

10             JUDGE KWON:  Sir, I take it you received explanation as to the

11     nature of the protective measures which has been allowed to you, but you

12     will be addressed as a specific number, which is KDZ-340, without naming

13     your real name, and whenever we -- why don't we show him the image which

14     is being broadcast.  And you will not be seen by anybody other than those

15     in the courtroom, and your image will show like this.  So you will not be

16     identified by anyone outside the courtroom.  So whenever we deal with

17     some confidential information which may reveal the identity of yourself,

18     we will go into private session, which means nobody can follow what we

19     are discussing inside the courtroom.  And the transcript as well of those

20     parts will not be disclosed to anybody other than the parties of this

21     case.

22             Do you follow?  Do you understand that, Mr. Witness?

23             THE WITNESS: [Interpretation] Yes.

24             JUDGE KWON:  Yes, Mr. Tieger.

25             MR. TIEGER:  Thank you, Mr. President.

Page 17473

 1             JUDGE KWON:  Please bear in mind we have to rise exactly before

 2     quarter to 2.00.  Yesterday the other hearing has to be delayed by five

 3     minutes because of us.

 4             MR. TIEGER:  Understood, Your Honour.

 5             JUDGE KWON:  Thank you.

 6                           Examination by Mr. Tieger:

 7        Q.   Good afternoon, Witness.

 8        A.   Thank you.  Good afternoon.

 9        Q.   Witness, I'd first like to call up a document that is designated

10     as 65 ter 90259.  This won't be broadcast.  We are in private session.

11     And I'd like you to confirm by simply indicating yes or no whether or not

12     this accurately indicates your name and date of birth -- or your name.

13     Excuse me.

14        A.   Yes.

15        Q.   Thank you.

16             MR. TIEGER:  And I'd tender that, Your Honour, under seal.

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Exhibit P3164 under seal, Your Honours.

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 17474











11  Page 17474 redacted.















Page 17475

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12             JUDGE KWON:  Thank you.  We go to private session.

13                           [Private session]

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 17476











11  Page 17476 redacted. Private session.















Page 17477

 1   (redacted)

 2                           [Open session]

 3             JUDGE KWON:  Yes.  Please continue.

 4             MR. TIEGER:  Thank you, Mr. President.

 5        Q.   Two additional matters quickly, Mr. Witness:  At page 7 of your

 6     amalgamated statement, you state that Aco Sekanic was part of the TO

 7     staff, and you think he was the assistant commander or something like

 8     that but you're not a hundred per cent sure.  Do you know whether or

 9     not -- well, I understood you wanted to clarify that in connection with

10     whether or not you knew that Mr. Sekanic was an assistant commander.

11        A.   Aco Sekanic, since there were several assistant commanders in the

12     staff for logistics for operations and so on and so forth, he was a type

13     of assistant commander of his.  Now, which function he had in the staff,

14     I really cannot say.

15        Q.   Okay.  Thank you.  And finally at page 5 of your statement, you

16     refer to a Mr. Sejfudin Hadziefendic and I understood that you wanted to

17     correct that name to Hadziavdic?

18        A.   That is right.  His real name is Sejfudin Hadziavdic.

19        Q.   And, Mr. Witness, with those clarifications can you confirm that

20     the testimony and statements in the Krajisnik and Stanisic cases which

21     have been incorporated into the amalgamated statement accurately reflect

22     your information and statement at the time, and if asked about the same

23     issues again, you would provide the same information and that that

24     information is truthful?

25        A.   Yes, I'd give the same answer.

Page 17478

 1        Q.   Thank you, Witness.

 2             MR. TIEGER:  I'd tender 90258, Mr. President.

 3             JUDGE KWON:  That will be admitted.

 4             THE REGISTRAR:  As Exhibit P3165 under seal, Your Honours.

 5             MR. TIEGER:

 6        Q.   Mr. Witness, I have not too many follow-up questions.  I don't

 7     know if we can address them in the time remaining, but we'll do our best.

 8             First of all, at page 2 of your amalgamated statement, you

 9     referred to Zvornik city being taken over on the 9th of April.  Can you

10     tell us which forces took over Zvornik city on the 9th of April?

11        A.   Up until the 9th of April, Zvornik was under the control of the

12     Muslim staff of the TO and their police.  They controlled Zvornik from

13     Metaris [phoen] to Karakaj, and over here in Zvornik towards Kula it was

14     the Muslim forces that exercised control.  After Zvornik was liberated

15     from the Muslim forces on the 9th of April, it is the Serb forces that

16     took control over of it.

17        Q.   Mr. Witness, at page 5 of your statement as indicated a moment

18     ago, you provided information about your contact with Mr. Hadziavdic,

19     Sejfudin Hadziavdic.  He was the Muslim man who had been taken to the

20     Crisis Staff and about whom you said was a good man and should be

21     released.  So a couple of questions in connection with that.

22             You said that you reported to the Crisis Staff at page 2 to 3 of

23     your statement on the 13th of April.  Was that the first occasion on

24     which you reported to the Crisis Staff the occasion on which you saw

25     Mr. Hadziavdic, or did that occur on another occasion?

Page 17479

 1        A.   That happened on another occasion, because on the 9th of April,

 2     in the afternoon, I left Zvornik and I went to visit my family.  On the

 3     13th of April, I returned to Zvornik, and I reported to the Crisis Staff.

 4     On that occasion, I did not see Hadziavdic.  However, afterwards, when I

 5     came to report to the Crisis Staff, on one occasion, I cannot remember

 6     the exact date or time, it was sometime in the evening.  He was brought

 7     to the Crisis Staff with his son and the men who were there, I don't know

 8     who brought him, I asked -- they asked whether I knew him because he saw

 9     me from the car and he said he knew me.  I know him.  He was an

10     exceptionally honest and honorable man.  When the war was on in Croatia,

11     he wanted to help there as well.  He sent help via the Red Cross from

12     Mali Zvornik.  So if it is that way, take the man home, apologise to him,

13     that's what they did, and I don't know what happened to him and his son

14     after that.

15        Q.   And how often did you report to or appear at the Crisis Staff and

16     for what reasons?

17        A.   I reported to the Crisis Staff sometimes once and sometimes twice

18     a day.  Sometimes once in two days, because there was duty service in the

19     streets, because above Zvornik, up until the 27th of April, Kula Grad

20     which dominates over Zvornik was controlled by Muslim forces, so it was

21     necessary to patrol the area because it's about a kilometre or a

22     kilometre and a half from Zvornik to Kula Grad.  However, as the crow

23     flies, it is only a few hundred metres or even less than that to the

24     first houses in Zvornik and that is why we had this duty service.

25        Q.   Did you or others report to the Crisis Staff for such purposes as

Page 17480

 1     getting movement passes?

 2        A.   Passes were given for free movement through the town itself and

 3     also in order to get to Serbia.  That's the kind of passes that were

 4     issued by the Crisis Staff.  Sometimes I reported for this and sometimes

 5     for that, but it depended on what was necessary.  So when I was on duty

 6     in the street, I was even on duty with Muslims so that was no problem.

 7        Q.   Let me ask a couple of questions about the patrol duty you

 8     referred to.  First of all, was that in your own neighbourhood?

 9        A.   Yes.  Yes, in my neighbourhood, because that's where I know

10     people, who they are, what they do.  I know everyone.  So we had that

11     duty service there.

12        Q.   And was primarily a Muslim or a Serb area?

13        A.   In that neighbourhood, there were a few Serb houses but there

14     were also quite a few Muslim houses, so practically all the houses

15     opposite my house were Muslim houses.  There were only one or two houses

16     in my immediate neighbourhood that were Serb houses.

17        Q.   Did you have weapons for patrol or while you were on patrol?

18        A.   During these patrols and walkabouts, we did not have any weapons.

19     And once when some volunteers came by, and I didn't know them, they gave

20     me and my Muslim neighbour a hand grenade each.  They said, You shouldn't

21     walk around just like that.  You never know who you are going to come

22     across.  So on that occasion that neighbour of mine also got this hand

23     grenade.  When we finished our duty, then he gave me this hand grenade

24     that he had.  And he said, If they search for them I don't want to have

25     one on me because if that were to happen, we don't know what would

Page 17481

 1     follow.

 2        Q.   This man that you referred to that you patrolled with was -- when

 3     you had earlier stressed what a good man Mr. Hadziavdic was, what can you

 4     say about this man you were patrolling with?

 5        A.   Well, I cannot say that my neighbours were bad people, although

 6     before there were clashes in the town of Zvornik many of them went out

 7     into the streets with weapons, automatic weapons, long barrelled ones.

 8     They had these weapons they received from the police and I cannot say

 9     how, so they had long barrelled weapons and they went out into the

10     streets.  I don't know why, either because they were afraid of us or I

11     don't know why, but otherwise I can say that they were rather honest

12     people, most of them that is.

13        Q.   And this man in particular that you were patrolling with?

14        A.   Also an exceptionally honest boy because he's younger than I am.

15        Q.   Is he still in Zvornik?

16        A.   No.  I think that he now lives in Tuzla.

17        Q.   And did you learn what happened to him such that he left Zvornik?

18        A.   Well, because of this exchange that took place, because some

19     soldiers had been arrested and taken to Kula, they brought him into

20     custody.  When he went to report it, the company that he worked in, in

21     Glinica, they brought him in.  They brought him to the police, and I

22     heard that he was beaten up and so on and so forth.  But for the sake of

23     this exchange, to give Muslims for Serbs who had been captured.  What

24     happened after that I don't know, but I do know that both he and his

25     family left Zvornik.

Page 17482

 1        Q.   Witness, at page -- I think we have to move into private session

 2     for this matter, Your Honour.

 3             JUDGE KWON:  Yes.

 4                           [Private session]

 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                           [Open session]

25             JUDGE KWON:  We'll rise for today and continue tomorrow morning

Page 17483

 1     at 9.00.

 2             Mr. Witness, you must have been told, but you are not supposed to

 3     discuss with anybody about your testimony you're giving.  Do you

 4     understand that?

 5             THE WITNESS: [Interpretation] Yes, I understand that.

 6             JUDGE KWON:  Tomorrow, 9.00.

 7                           --- Whereupon the hearing adjourned at 1.44 p.m.,

 8                           to be reconvened on Friday, the 19th day

 9                           of August, 2011, at 9.00 a.m.