Tribunal Criminal Tribunal for the Former Yugoslavia

Page 19525

 1                           Wednesday, 28 September 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 2.18 p.m.

 6             JUDGE KWON:  Ms. Edgerton, before we begin today, there is an

 7     oral ruling the Chamber wishes to make.

 8             With respect to the accused's motion to postpone the evidence of

 9     witness KDZ 492, filed on 27th of September 2011, the Chamber has

10     considered both the arguments raised in the motion and the Prosecution's

11     response provided orally on the same day.  While mindful of the fact that

12     the witness is already here, the Chamber has decided to grant the motion

13     and postpone his evidence to the week of 17th of October.

14             In reaching its decision, the Chamber took into account the fact

15     that the evidence of KDZ 492 and KDZ 532 may overlap to some extent,

16     meaning that the evidence of KDZ 532 may be of relevance to the accused's

17     preparation for the evidence of KDZ 492.  The Chamber also took into

18     account that both KDZ 492 and KDZ 532 are delayed disclosure witnesses,

19     whose relatively voluminous evidence was disclosed to the accused only

20     recently.  In that respect, it is of significance that the materials

21     relating to KDZ 532 were disclosed to the accused in a piecemeal fashion

22     and that, while the transcript of his interviews were disclosed on 21st

23     of September, the related Rule 68 material was disclosed only yesterday,

24     as was the Rule 66(B) material.

25             While the Chamber agrees with the accused could have discovered

Page 19526

 1     the connection between the two witnesses already on 21st of September,

 2     when KDZ 532's identity was disclosed to him, the Chamber is also mindful

 3     that not all of the material relating to KDZ 532 - and thus potentially

 4     relevant to KDZ 492 - was disclosed to the accused on that day.  For that

 5     reason, the Chamber has decided to grant the motion.

 6             So in this regard, Mr. Tieger, given this ruling and for the

 7     purpose of the smooth running of this trial in the future, the

 8     Prosecution may wish to consider scheduling the delayed disclosure

 9     witnesses in such a way that allows the accused time to prepare for them,

10     in particular in cases where they may be related to each other.

11             That said, sir, if you could stand and take the solemn

12     declaration, please.

13             THE WITNESS: [Interpretation] I solemnly declare that I will

14     speak the truth, the whole truth and nothing but the truth.

15                           WITNESS:  NUSRET SIVAC

16                           [Witness answered through interpreter]

17             JUDGE KWON:  Thank you, sir.  Please be seated and make yourself

18     comfortable.  Yes, Ms. Edgerton.

19             MS. EDGERTON:  Thank you.

20                           Examination by Ms. Edgerton:

21        Q.   Good afternoon, Mr. Witness.  Do you hear me in a language you

22     understand?

23        A.   Yes, I do.

24        Q.   Could you tell us your full name, please, then?

25        A.   My name is Nusret Sivac, born 19 August 19947 in Prijedor.

Page 19527

 1        Q.   Thank you, Mr. Sivac.  Now, Mr. Sivac, did you testify here at

 2     this Tribunal in the case against Milomir Stakic on July 29, 30, and 31,

 3     and the 1st of August 2002, and then again on 13 January 2003?

 4        A.   Yes, I did.

 5        Q.   In preparing to give evidence here today, did you have a chance

 6     to listen to a recording of that testimony from 2002 and 2003?

 7        A.   Yes, I had that opportunity.

 8        Q.   And as far as you recall, was it accurate?

 9        A.   For the most part, everything was correct, accurate.

10        Q.   Now, if I was to ask you the same questions you were asked at

11     that time, would you give the same answers?

12        A.   Well, yes, I would give almost the same answers, although I would

13     add to some of them.

14        Q.   With respect to the addition you've just referred to, was that in

15     regard to the members of a delegation that you described as visiting

16     Omarska at pages 6639 to 6647 of your transcript?

17        A.   Yes.

18        Q.   Well, maybe we will just turn to that very quickly, then.  In

19     your transcript, you describe the visit of Serbian officials to Omarska

20     while you were held prisoner there, and you mentioned seeing a number of

21     people or recognising a number of people within that delegation; Simo

22     Drljaca, Milorad Vukic, Radoslav Brdjanin, Mico Kovacevic,

23     Milomir Stakic, Srjdo Srdic, Simo Miskovic, Milan Andzic,

24     Radmilo Zeljaja, and Dusan Kovacevic [sic].

25             Now, in addition to the names that I've just listed, did you see

Page 19528

 1     anyone else in the delegation you recognised?

 2        A.   Well, yes.  In that evidence at that trial, I was answering a

 3     specific question from the Prosecutor, namely which high-ranking

 4     politicians and officials visited the Omarska camp.  I said it was

 5     Radoslav Brdjanin.  And then the next question focused on local Prijedor

 6     politicians who were part of that visit, so I left unsaid who from that

 7     political delegation from Banja Luka was there and I will say that now:

 8     Along with Radoslav Brdjanin, who was the highest ranking official to

 9     ever visit Omarska camp, at that time he was at the head of the

10     Autonomous Province of Bosnian Krajina, there was Radislav Vukic also

11     known as Rade the monster.

12        Q.   Now, Mr. Sivac, I've just given you those names and I'll repeat

13     them again for you, the names that you gave in your previous testimony,

14     and then I'll give you my question again.  You said in the Stakic

15     proceedings that you saw Brdjanin, Vukic, Drljaca, Kovacevic, Stakic,

16     Srdic, Miskovic, Milan Andzic, Radmilo Zeljaja and Dusan Kovacevic [sic].

17             In addition to those people, was there anyone else in the

18     delegation you recognised?

19        A.   In your first enumeration, there is a mistake.  It's not

20     Milorad Vukic but it's Milorad Vokic.  He was always accompanying

21     Brdjanin in Prijedor.  You should correct Vukic to Vokic.  But that

22     political delegation from Banja Luka included along with Brdjanin,

23     Radoslav Vukic, the president of the Serbian Democratic Party in Banja

24     Luka, then Radic who was at the head of the Banja Luka municipality, and

25     Stojan Zupljanin.  Those were the political officers who came directly

Page 19529

 1     from Banja Luka.

 2        Q.   Thank you.  And actually, I have only one other question related

 3     to your evidence in the Stakic case.  I saw that at page 10270, my former

 4     colleague referred you to an incident on a day in late July when 12

 5     buses, late July 1992, when 12 buses of men from the Brdo region arrived

 6     in the Omarska camp.  Do you remember that incident?

 7        A.   Yes, I do.  Sometime after the 20th of July, we heard that there

 8     was ethnic cleansing on the left bank of the Sana river, where a series

 9     of Muslim villages were situated, Zecovi, Carakovo, Biscani, near

10     Srdica -- Srdica --

11             THE INTERPRETER:  The interpreter missed the first three or four.

12             THE WITNESS:  And the next day, the very next day, buses started

13     arriving at Omarska.  Since I was in a room with Burho and Mujo, the

14     detainees who were being brought from Brdo were being lined up and they

15     were very badly treated.  We called that very thin wall the Wailing Wall

16     or the wall of tears.  Only in those two days, according to Berko and

17     Mujo who used to go in and out of that room, along with a group of other

18     inmates to clear the blood stains and other traces of mistreatment on

19     that wall, to the horrible yelling of the guards at those people who were

20     brought from Brdo, they were very badly, inhumanely treated.

21             Some people who were brought from Brdo were killed immediately

22     during that admission process, as the guards called it.  The guards would

23     come and make inmates use firefighters' hoses to try to get those blood

24     stains off the wall.  They said, those inmates, that 12 buses full of

25     people had arrived and there were large numbers of people killed and they

Page 19530

 1     were all lying on the ground.  And one day he came with a big stick and

 2     I asked him, "What is that?"  And he said, "This is the stick -- the

 3     staff that belonged to my neighbour, Zenkic.  He won't need it any more

 4     because he's lying there dead next to the house."

 5        Q.   Mr. Sivac, if we can just go back to the very beginning of your

 6     answer for a couple of minutes, I have a couple of additional questions

 7     for you, all right?  First of all, you talked about -- you said sometime

 8     after 20 July we heard there was ethnic cleansing on the left bank of the

 9     Sana river where a series of Muslim villages were situated, but you were

10     speaking the names of those villages too quickly for my colleagues in the

11     booth to interpret them.  Could you just repeat only those village names,

12     please?

13        A.   We in Prijedor called these villages Brdo as a group.  They were

14     in one line.  That's Zecovi, Carakovo, Hambarine, Rakovcani, Rizvanovici,

15     Biscani, and Sredica.

16        Q.   Thank you.  Now, Mr. Witness, you talked about buses arriving at

17     Omarska and referred to detainees being brought from Brdo, lined up, and

18     being badly treated.  Can you just clarify who was on the buses?

19        A.   Well, the villagers from the villages I just enumerated.

20        Q.   And how do you know they were on the buses?

21        A.   Well, we heard that from the guards, and also a few days later,

22     when they appeared in the lines for food distribution, and we recognised

23     some of -- old acquaintances from Prijedor.

24        Q.   Thank you very much, Mr. Witness.  I have no further questions.

25             MS. EDGERTON:  Oh, sorry, moving at too great a pace, Your

Page 19531

 1     Honour.  I'll like to tender the 92 ter transcript of this witness, which

 2     is 65 ter number 22701, please, as a Prosecution exhibit, and I should

 3     note that there is a small bit of that testimony that was recorded in

 4     private session, and we've prepared a redacted version.  We have

 5     accordingly prepared a redacted version, 65 ter number 22701B is the

 6     public redacted version.

 7             JUDGE KWON:  Both versions will be admitted.

 8             THE REGISTRAR:  Your Honour 65 ter 22701 shall be given

 9     Exhibit P3477 under seal.  And 22701B shall be given Exhibit P3478 and is

10     admitted publicly.  Thank you.

11             JUDGE KWON:  Thank you.  Then we come to the associated exhibits.

12             MS. EDGERTON:  Yes, would Your Honour like me to read the

13     associated exhibit numbers out or shall I deal with that with my

14     colleague?

15             JUDGE KWON:  I'd prefer to follow the latter suggestion, but I

16     have a question in relation to four documents which are -- have been

17     allegedly tendered for reference only.  If you could clarify the meaning?

18             MS. EDGERTON:  As I was reading the transcript, Your Honour,

19     I saw that the president at that time had asked for colour versions of

20     the exhibit numbers previously admitted, and those were accordingly given

21     separate -- those versions, which are in any other -- in all other ways

22     identical, were given separate exhibit numbers.  I'm in Your Honour's

23     hands as to how you would prefer to deal with that.  I just thought to

24     have the transcript clear, there could be a document linked to the number

25     that the president at that time was referring to.

Page 19532

 1             JUDGE KWON:  It is evident from the transcript itself that they

 2     are duplicates of another one.  So I don't think we need to admit it at

 3     all.

 4             And shall I come back to the -- one of the original?  5772.

 5             MS. EDGERTON:  Yes?

 6             JUDGE KWON:  I'm not quite sure how it forms an indispensable and

 7     inseparable part of the transcript.  According to the transcript, the

 8     witness just read out and nothing was asked about this article.  And same

 9     seems to be true at the 65 ter number 11740.  So if you are minded to

10     tender those articles, I would recommend you to explore those articles

11     with the witness yourself.

12             MS. EDGERTON:  Would I be able to do that now, then, Your Honour?

13             JUDGE KWON:  Yes, please.

14             MS. EDGERTON:  Could we have 65 ter number 05772, please?

15             JUDGE KWON:  While the documents are being uploaded, I forgot to

16     ask you, Mr. Robinson, whether there is any objection.

17             MR. ROBINSON:  No, Mr. President, and you're taking care of this

18     issue quite well, better than we could do.

19             MS. EDGERTON:  Thank you.

20        Q.   Mr. Witness, are you able to read Cyrillic?

21        A.   Yes, I can read Cyrillic.

22        Q.   Sorry, Your Honours, I'm a little bit hesitant.  I hear a delay

23     when I'm speaking in the microphone today.  Do you see the article on the

24     left-hand side of the page in front of you?

25        A.   Yes, I can see it.  Representatives of Krajina in Prijedor.

Page 19533

 1        Q.   Do you recognise this article?  Have you seen it before?

 2        A.   Yes.  In the trial of Stakic.  It was shown to make clearer the

 3     situation around that visit to the camp by the delegation, the

 4     Presiding Judge let me read this article from Kozarski Vjesnik and

 5     another one from Glas of Banja Luka.  I read those texts and they showed

 6     who was on that delegation from Banja Luka and from Prijedor so that my

 7     first statement, when I mentioned only Radoslav Brdjanin, was

 8     complemented by the reading of these articles.  And it was not necessary

 9     then for me to repeat those names.

10        Q.   Can I just ask you some brief questions about this article?  You

11     said that this article is from Kozarski Vjesnik.  Could you explain what

12     kind of media Kozarski Vjesnik is?

13        A.   Well, Kozarski Vjesnik was the main propaganda vehicle that

14     Serbian politicians in Prijedor used to put out proclamations and

15     pamphlets.  On the 30th of April, and after the takeover, after the

16     military coup --

17        Q.   Sorry, thank you.  You've answered my question.  I would just

18     like to move on to another question about this article.  Is the name of

19     this journal in the bold print at the top left-hand of this page in front

20     of you?  Do you see the words Kozarski Vjesnik headlined on the top left

21     of the page in front of you?

22        A.   Yes, I see.

23        Q.   Now, just stamped on top of the letters OZ is something that we

24     can't quite read.  Are you able to distinguish what that says?

25        A.   I think it says that this is a wartime edition.  At the time they

Page 19534

 1     referred to the editions of Kozarski Vjesnik as wartime editions.

 2        Q.   Thank you.  Now, this article refers to a visit or visits by

 3     Radoslav Brdjanin, Radoslav Vukic, Stojan Zupljanin, and Predrag Radic to

 4     Prijedor on 17 July 1992.  Now, to your recollection, are these persons

 5     some of the same persons who formed part of the delegation that visited

 6     Omarska camp that you saw?

 7        A.   Yes.  Along the political -- alongside the political delegation

 8     there was a group of journalists from Banja Luka who did their utmost to

 9     convey their story in the media.

10        Q.   Thank you.  If that could be marked as a Prosecution exhibit,

11     please?

12             JUDGE KWON:  Yes, that will be admitted.

13             THE REGISTRAR:  [Microphone not activated] 79, Your Honours.

14             MS. EDGERTON:  Thank you.  Could we now see 11740 in e-court?

15        Q.   Now, Mr. Witness, you see here another issue of Kozarski Vjesnik

16     dated 26 June 1992, and the story on the bottom left-hand corner of the

17     page is the story I'd like to draw your attention to.  It's entitled,

18     "Monster Doctor."  Have you seen this article before?

19        A.   I did see it.

20        Q.   Are you familiar with anyone from the Prijedor area who had the

21     nickname Monster Doctor?

22        A.   Kozarski Vjesnik and Radio Prijedor were completely controlled by

23     the SDS in Prijedor.  Through their broadcasts and issues, they turned on

24     prominent Banja Luka citizens accusing them of different types of crimes.

25     However, all those people were decent citizens of Prijedor.  All those

Page 19535

 1     whose names were called out, so to say, by means of Kozarski Vjesnik and

 2     Radio Prijedor were basically marked to be killed, as they eventually

 3     were in the various camps.  This particular article concerns

 4     Osman Mahmuljin, a Prijedor physician, who specialised in internal

 5     medicine.  There is an interesting thing about Prijedor.  At the helm of

 6     the municipality of Prijedor, there were two physicians, Milomir Stakic

 7     and Mico Kovacevic.

 8        Q.   Sorry, Mr. Sivac, I'd just like to ask you one question about

 9     Mr. Mahmuljin who is referred to in this article.  What happened to

10     Mr. Mahmuljin?  Do you know?

11        A.   We were taken to Omarska together.  In late July he was killed

12     there, during a systematic process of execution of prominent Prijedor

13     citizens.

14        Q.   Thank you.

15             MS. EDGERTON:  Could I have this as the next Prosecution exhibit,

16     please?

17             JUDGE KWON:  Yes.  This will be admitted as Exhibit P3480.  So

18     with the exception of those four exhibits, that was tendered for

19     reference.  All the other exhibits will be admitted and given numbers in

20     due course.

21             MS. EDGERTON:  Thank you.

22             JUDGE KWON:  And Ms. Edgerton, given that this witness's evidence

23     was tendered pursuant to Rule 92 ter, why don't you offer the summary of

24     this witness's evidence for the benefit of the public, if you are ready.

25             MS. EDGERTON:  Indeed I'm ready Your Honour, I apologise, I'm

Page 19536

 1     quite disconcerted by the delay in my microphone today, and I would like

 2     to do that.

 3             Mr. Nusret Sivac is a Bosnian Muslim who until 1989 worked for

 4     the Public Security Services in Prijedor and in 1992 was working as a

 5     television reporter in the same area.  His written evidence provides an

 6     overview of the armed Serb takeover of Prijedor in April 1992, and the

 7     Serb attack on the area and consequent ethnic cleansing which began on 30

 8     May 1992.  He has given evidence about the persecution of non-Serbs and

 9     the destruction of non-Serb religious buildings and property.  He was

10     arrested by Serb police on 10 June 1992, and taken to Keraterm and

11     Omarska but released the same day.

12             He was again arrested on 20 June 1992 and returned to Omarska.

13             He describes the brutal, inhumane conditions for huge numbers of

14     non-Serbs in prison there, including himself, women as well as men.  The

15     prisoners were beaten, tortured and killed, barely fed.  Women were

16     brutally abused.  In July 1992, Mr. Sivac saw a delegation of Bosnian

17     Serb officials who he recognised visit the camp.  That day, he was lined

18     up with the rest of the camp population and made to sing Serbian songs

19     and in front of the visitors.  He was transferred to -- he was

20     transferred to Trnopolje camp in August 1992 where he remained for 14

21     days.  On his release he returned to Prijedor where he remained until

22     being finally able to leave in December 1992 after signing over all his

23     property.

24             And just before -- having concluded the summary, just before

25     I finally take my seat, I note that when I asked Mr. Sivac the question

Page 19537

 1     about the members of the delegation, the second time, I omitted one of

 2     the names of the delegation members.  Dusan Jankovic was omitted.  Thank

 3     you.

 4             JUDGE KWON:  Thank you.

 5             Mr. Sivac, your testimony given at the Stakic trial was admitted

 6     in its entirety, and then you will be further asked by the accused,

 7     Mr. Radovan Karadzic, in his cross-examination.

 8             Yes, Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] Thank you.  Good afternoon your

10     Excellencies.

11                           Cross-examination by Mr. Karadzic:

12        Q.   [Interpretation] Good afternoon, Mr. Sivac.

13        A.   Good afternoon.

14        Q.   Given the fact that your evidence is quite voluminous, I'll

15     strive to put short and simple questions which for the most part could be

16     answered with a "yes" or "no."  By the same token, please pause between

17     questions and answers, as I will too, so that the interpreters could

18     catch up.

19             Did you serve your military term?

20        A.   I did.

21        Q.   Thank you.  Did you complete a course during your term?

22        A.   Yes.  I did.  As a radio mechanic for military radio equipment.

23        Q.   What kind of education did this course give you?

24        A.   As part of that course for radio mechanics, when there were

25     military call-ups, I always served as a military radio mechanic.

Page 19538

 1        Q.   Does that mean a signalsman?

 2        A.   Yes, that is my military specialty too.

 3        Q.   Does this also entail working on teleprinters and other

 4     equipment, including coding.

 5                           [Technical difficulty]

 6             JUDGE KWON:  Shall we try again?

 7             THE ACCUSED: [Interpretation] I don't think either of us was rude

 8     or untoward.

 9             THE WITNESS: [Interpretation] Can I answer now?

10             MR. KARADZIC: [Interpretation]

11        Q.   Go ahead.

12        A.   No, Mr. Karadzic.  I did attend courses in coding and telefax

13     operation but only once I was received -- or employed by the state

14     security in Sarajevo.

15        Q.   Did you work for the public or the state security?

16        A.   I worked in the communications and encoding centre, which was

17     part of the Public Security Service under the new structure.

18        Q.   So you did not work in state security?

19        A.   No, never.  In some of my earlier statements I found it to be a

20     mistake, something that was wrongly recorded.  There seems to be a mix-up

21     between the public and State Security Service.

22        Q.   I am confused by that as well because in one of the statements we

23     can find that you worked for the State Security Service, you also had

24     your code name and took care of Tito's safety when he went to Bosnia.

25        A.   Well, I have to expand on that.  We in the communications centre,

Page 19539

 1     we did have nicknames or code names, if you will.  We all worked as team

 2     when Tito was in Bosnia-Herzegovina, but we were at our work posts.

 3     I forgot what your first question was.

 4        Q.   In the statement from 1994, we see that you worked in the secret

 5     service and that you alone and your boss had access to certain material

 6     and that you were answerable to the federal secretariat and to the

 7     military courts rather than civilian courts and that you also took care

 8     of Tito's safety and the safety of other prominent persons on visit in

 9     Bosnia.  It is page 3 of the 1994 statement.  It also says that as a

10     secret agent, your code name was K-5 Joja; is that correct?

11        A.   Mr. Karadzic, this expanded question of yours is an argument.

12     You took it out of the context of something I had said.

13        Q.   Thank you.  When did you --

14             THE INTERPRETER:  Interpreter's correction:

15        Q.   When you started working as a camera man, did you also work for

16     the police simultaneously?

17        A.   Yes, for a while I worked in parallel for the state security --

18     Public Security Service and radio-television Sarajevo.

19        Q.   What was your proper job and what was your auxiliary job?

20        A.   I was employed in full at an accelerated rate of accrual of the

21     number of years in the public service, Public Security Service.

22        Q.   Did you retire or were you fired?

23        A.   That's wrong information again.  Because of certain arguments,

24     I applied for an early retirement.  By the time, I was already working

25     for the television.  I made use of the right I had to receive an early

Page 19540

 1     retirement while continuing to work for radio-television Sarajevo as a

 2     correspondent for western Krajina.

 3        Q.   In other words, you were not fired but you retired because you

 4     had another job as a source of income on top of your pension; is that

 5     correct?

 6        A.   Yes.  Because of the interethnic conflicts and tensions which

 7     came into being in the service, I was basically forced to apply for early

 8     retirement.

 9        Q.   You say basically.  Were you or were you not?  It is difficult to

10     qualify this basic concept or the concept of basically in legal terms.

11     What did you do exactly?

12        A.   Under the law in the then-Yugoslavia, I could apply for early

13     retirement, and I did so.  I started receiving my pension while at the

14     same time continuing as a war correspondent for the Sarajevo TV.

15        Q.   When you applied for retirement, did you also apply due to

16     medical reasons?  Did you submit any medical papers which assisted your

17     claim or your application?

18        A.   Well, yes.  It included standard problems experienced by most

19     security service employees.  Such problems occur due to shift work and

20     overload.  I suffered from insomnia, burnout, and other such symptoms

21     which take place after one had worked in night shift for years.

22        Q.   The documents were issued by a psychiatrist.  What was his

23     conclusion?

24        A.   I have no idea.  Together with a group of men from Prijedor,

25     I went to Sarajevo and we had interviews there.  Or conversations.  After

Page 19541

 1     a while, documents arrived granting my request for early retirement.

 2        Q.   Thank you.  I suppose you wouldn't object to us producing those

 3     documents here without public broadcast?

 4        A.   I do not object to that.

 5             THE INTERPRETER:  Microphone for Mr. Karadzic, please.

 6             JUDGE KWON:  Mr. Karadzic, could you start again?

 7             THE ACCUSED: [Interpretation] My microphone was on.  I don't know

 8     if you can hear me now.

 9             MR. KARADZIC: [Interpretation]

10        Q.   What you said at page 6561 of the transcript, when you said that

11     Milos Jankovic arrived in the service to ethnically cleanse it, but that

12     wouldn't be quite accurate, would it?  It is page 11 in e-court and 6561

13     in the transcript.

14        A.   Yes.  When Milos Jankovic arrived, he assisted greatly in the

15     ethnic cleansing of the service for which I worked.

16        Q.   Are you trying to say that the local police chief, or a local

17     police chief, at any level, had the authority to change the ethnic

18     composition of the force or would this have been something to be approved

19     at a level of the ministry?

20        A.   When Milos Jankovic arrived in the service, he was actually one

21     of the main reasons for my early retirement.

22        Q.   How did you gain that information?  Was this some sort of

23     information or was it an impression of yours that Milos Jankovic was

24     tasked with ethnically cleansing the service?  Do you base your claim on

25     a document or is this merely an impression?

Page 19542

 1        A.   It is part of my knowledge which I base on facts.  In the

 2     service, we kept a close watch of the ethnic makeup of the force.  There

 3     were nine employees, and we always paid attention to the number of

 4     Muslims and Serbs on the force.

 5        Q.   What are the facts which made you conclude that you were retired

 6     because of your ethnic background?

 7        A.   The best employee in the service was Veso [as interpreted]

 8     Vojnikovic.  He was a workmate who was forced to retire following a banal

 9     incident.  Another person was employed instead of him, who was a Serb.

10     Milos Jankovic brought Ranko Kovacevic to the service without any

11     authority.  According to all the regulations and laws in place for the

12     service, such a person ought not to have been employed there.  He had a

13     criminal -- disciplinary file.  He was a simple policeman, of very modest

14     education.  Instead of being driven out of the security service for

15     engaging in a number of dodgy deals, he was brought to our service to

16     work side by side with us.

17        Q.   Are you saying that Milos Jankovic had the authority to employ or

18     fire people in the service, which is highly centralised and follows

19     strict procedures of admission which are not available to any job

20     candidates?

21        A.   It was pursuant to his proposal that our service was manned.  He

22     was the one who put forth proposals to the chief of the service as to who

23     should be employed in the service.

24        Q.   Did you know that there were checks and that there was a certain

25     period of time which had to elapse before someone is employed and that

Page 19543

 1     such procedures go up to the level of the ministry, along the various

 2     department lines, in order to grant the vetting procedure?

 3        A.   Not quite.  Ranko Kovacevic instead of being fired was employed

 4     in our service to work for -- I'm not sure who.  I guess he was there to

 5     control what the rest of us did and noted down.  To use the simple

 6     terminology, he was supposed to monitor us.  I have said already that an

 7     operator working on codes in any particular shift was the only person

 8     entitled to receive certain dispatches in order to forward them to the

 9     appropriate services to which they were addressed.  However --

10        Q.   Thank you.  Did you make your conclusions based on one person

11     being fired and one person being employed, when you say that Mr. Jankovic

12     came there to cleanse the service?  Or do you have any other proof?

13        A.   Following Esad Vojnikovic, I was the next to leave the service.

14     And again, my post was taken up by a Serb.  At the end, on the eve of the

15     war, there was only one Muslim in the office left.

16        Q.   Let us go back to the issue of whether you were fired or retired,

17     and you said you were not fired.  You said you retired.

18        A.   Well, yes.  But Mr. Karadzic, Milos Jankovic and the chief of the

19     security service were supposed to find a replacement for me, to bring a

20     Muslim to the communications and encoding centre, a person of appropriate

21     background and education.

22        Q.   Are you saying that before 1990, before the multi-party

23     elections, Milos Jankovic could implement nationalist policies in the MUP

24     of Bosnia-Herzegovina, in which the most senior positions were occupied

25     by Muslims and Croats since 1967?  Are you basically saying that during

Page 19544

 1     the communist era, Jankovic could replace people along ethnic lines

 2     rather than some other lines?

 3        A.   Well, it proved to be true.  Milos Jankovic followed the ethnic

 4     line or the ethnic policy.  Again, you're taking things out of the

 5     context.  I don't know to what extent you are familiar with our work.

 6     The security service in Prijedor, until a certain time, was fully Serb.

 7     Following Sadikovic, I was the third or fourth Bosniak, Muslim, to be

 8     employed in the service.

 9        Q.   Thank you.  Are you discussing now the post-war period, and does

10     it have anything to do with the participation of Muslims in the Ustasha

11     army and that this was the cause of distrust?

12        A.   I am well acquainted with the history of Prijedor.  In Prijedor,

13     in the area of Prijedor, there were no people who joined Ustasha forces.

14     Or if there were, that number was negligible.  Everyone was on the side

15     of the liberation movement and supported partisans and wanted to chase

16     the fascists away.

17        Q.   What about Dzafer Kulenovic.  Does he not hail from that area?

18        A.   No.  And I was referring to Prijedor alone.

19        Q.   Did you work for the counter-intelligence service in order to

20     break-up Croatian nationalism in 1973 as it says in your statement?  But

21     I believe that Croatian spring concluded in 1971, am I correct?

22        A.   Well, yes.  In that statement I mentioned when I joined the

23     service, and I said that there were still people around who had

24     participated in the infamous Croatian Spring.  My service, as other

25     security services in the area of Prijedor, wanted to see those people

Page 19545

 1     brought before courts.  You know that any police work is team work.  It

 2     means that both Public and State Security Service, as well as all other

 3     segments, work as a team in order to deal with state enemies.

 4        Q.   So it is not correct that you worked for the counter-intelligence

 5     service or is it?

 6        A.   No.  This is just a paraphrase, and I don't know who authored

 7     that paraphrase.  I never stated that.

 8        Q.   This is your 1994 statement, on page 3 and page 4.  At that time,

 9     in the same capacity, did you also persecute members of Cominform Bureau

10     who appeared in 1948?  Was it not late for you to pursue Cominform

11     members in 1968?

12        A.   Mr. Karadzic, a group of Cominform members appeared in Prijedor.

13     They organised their meetings there.  One of them was Gojko Biljajac, my

14     closest neighbour in the building where I resided.  He had already been

15     sentenced to imprisonment on Goli island as a member of Cominform.

16     Together with him in that group, there was also Dr. Orlic from

17     Bosanska Dubica.  This may be of some interest for this Trial Chamber.

18     She was the wife of the chief of security in Bosanska Dubica, and they

19     were indeed involved in organising and reactivating the group of

20     Cominform in Prijedor and in Bosanska Dubica and that is why they were

21     punished to long prison sentences.

22        Q.   And how did you, as a communication officer, how did you figure

23     in all that?

24        A.   In the centre, I did my every day duties, and I had a group of

25     operatives who had arrived from Sarajevo.  They gave me a task to monitor

Page 19546

 1     the situation in my building, or rather to follow the activities of

 2     Gojko Biljajac who was a suspect.  I was supposed to monitor his

 3     movements and to inform people from Sarajevo about that.

 4        Q.   Those were people from Sarajevo, from the state security, right?

 5        A.   Yes, that's correct.

 6        Q.   Very well.  Did they not tell you that a person from public

 7     security should not work for state security under the law?

 8        A.   I was not officially employed by the state security.  I just did

 9     them a favour.  At that moment they saw me as the most reliable person

10     and least conspicuous person.  If they had attempted to install their own

11     man, Gojko Biljajac, who was a dissident, would have found that

12     suspicious.  The building was very small and it had a small number of

13     apartments.

14        Q.   Thank you.  So that means that you worked -- unofficially you

15     were a spy as it were, you monitored the behaviour of people on behalf of

16     the state security while you were still an employee of the public

17     security; is that correct?

18        A.   Yes.

19        Q.   And you don't know that that's against the law?

20        A.   Well, that was the only case, the case of Gojko Biljajac and the

21     group of Cominform members.

22        Q.   Thank you.  Were you a communist?

23        A.   Yes, I was, but I would like to add something in my answer to the

24     previous question, just briefly.  It is not correct that we who worked in

25     the communication centres were not allowed to work for the state

Page 19547

 1     security.  In the Prijedor SUP there was a detachment of the state

 2     security.  The main office was in Banja Luka.  And in our line of work,

 3     we worked quite extensively for the state security.

 4        Q.   You are saying that it is not against the law for the two

 5     services to mix up?

 6        A.   You're referring to that plenum when Ranko was removed.  Let me

 7     tell you, Mr. Karadzic, in my job, and I worked for a long time in public

 8     security, we worked quite extensively for the state security.

 9        Q.   Thank you.  So you were a communist, right?

10        A.   Yes, I was.

11        Q.   Were you a very convinced loyal, hardened communist?  What kind

12     of a communist were you?

13        A.   Well, no.  I accepted the ideology because that's the way my

14     parents were, and you know, to take up such a responsible position you

15     had to be a member of the League of Communists.

16        Q.   Thank you.  I find some other things confusing at the moment.  Is

17     it correct that you were retired after you had put forth a defiant

18     proposal to the personnel service, that person was a Muslim, and it was

19     absolutely out of the question for that person to be employed, and that

20     move was taken against you?

21        A.   I was involved in an informal conversation with a group of

22     colleagues, police officers, and they asked me what I thought who should

23     be the chief of the Public Security Service.  My answer was, well, this

24     time it should be a Muslim, and they held it against me.  They thought

25     that it was a mistake on my part, based on my ethnic feelings.

Page 19548

 1        Q.   Did you also mention the name of that person that would be

 2     appropriate for that position?

 3        A.   No, I didn't mention any names.

 4        Q.   Very well.  So in 1980 and 1981, you behaved quite responsibly

 5     and you monitored the ethnic composition of employees in Prijedor.  You

 6     counted heads.  Wasn't that a bit premature for a member of the Communist

 7     Party, to count heads along ethnic lines?

 8        A.   Well, I didn't count people because of that.  That was just

 9     something that I perceived.  That was my impression and the impression

10     was that in the security service the other ethnic groups are not well

11     enough represented.  I never said it in public.  I never voiced my

12     opinion publicly.

13        Q.   Thank you.  However, it seems that at the time you were

14     embittered, that you were full of bitterness, you were not satisfied?

15        A.   No, no.  I was never embittered with the system which I served

16     loyally until the 1st of January 1990.

17        Q.   Thank you.  And now I would like to hear from you whether there

18     was either an official or an unofficial commission that could say who was

19     a good Muslim and who wasn't.

20        A.   I don't understand your question, believe me.

21        Q.   Well, I would like to know whether the qualifications of Muslims

22     that we found in your statements and in your books, did you take them

23     over from an official organisation or a commission, or are these your own

24     qualifications of those people?

25        A.   The only thing I had were my own impressions, and I was the only

Page 19549

 1     one who could be the judge of other people.

 2        Q.   And then you said about a Muslim whose wife was Serb, that he was

 3     a reserve Muslim.

 4        A.   Yes, that's correct.  In late 1991, on the eve of the first

 5     democratic elections, a man became the head of security.  His name was

 6     Sead Besic, and I qualified him as a reserve Muslim.  That's how

 7     I described him.

 8        Q.   Thank you.  In your book, you mention quite a large number of

 9     Muslims whom you considered traitors because they remained living and

10     working with the Serbs in Prijedor, whereas you thought that that was not

11     okay, that that should not be done; is that correct?

12        A.   No, Mr. Karadzic.  It's not correct.  I published a list of

13     Muslims who killed other Muslims.

14        Q.   On page 243 of your book, you wrote that:  "Muslims Were

15     Committing Crimes Against Their Own People."  That's the title.  And the

16     subtitle is:  "Traitors Who Killed Their Own People," and you provide a

17     list of at least 15 people in Prijedor, including Sead Besic, who was a

18     police officer, or rather a member of the state security.  Then also

19     Hamdija Handzic, also a Muslim, a major in the Serb artillery who stayed

20     in the Serb Army; Zijad Music; Asmir Music; Zlatan Blazevic, also known

21     as Laja; Atko Blazevic, also known as Leri - the last two were Croats -

22     Emso Sabic, Sabo; Sabahudin Zulic, also known as Butko; Goran Egrlic -

23     all Muslims but the two Croats - another person, a lady called Karalic, a

24     Muslim; and then Ernest Badnjevic; Zlatan Crnalic [phoen];

25     Muhamed Sarajlic; Said Alabegovic [phoen]; and Zlatan Selimbegovic.  You

Page 19550

 1     listed them as people who were traitors because they remained living with

 2     the Serbs as members of the Serb army or the Serb bodies of authorities;

 3     is that correct?

 4        A.   No.  It is not.  Mr. Karadzic, I did not put them on the list of

 5     traitors because they served loyally in the Serb army, but because of the

 6     fact that as members of the Serb army, they went and killed people in

 7     Bihac, Gradacac, along the corridor, and in all the other parts where the

 8     elite Prijedor troops went to wage war.  That means that Muslims killed

 9     other Muslims.  So how should they be qualified but as traitors?  There

10     was just one word for that.

11        Q.   Well, very well.  You deny them the right to foster political

12     differences.  Were Serbs not killing other Serbs in the Second World War?

13     Did partisans and Chetniks kill each other or did they not?

14        A.   Mr. Karadzic, I'm talking about the period that I survived.  Let

15     us leave history to talk about the Second World War.

16        Q.   Thank you.  However, you have just told us that these Muslims

17     killed other Muslim people.  Did they go there to fight against the

18     Muslim army or against the Muslim people?  Do you have any proof that any

19     of these people who were obviously in favour of Yugoslavia and in favour

20     of living together with the Serbs, that they killed people and not the

21     troops?

22        A.   Let me tell you, if we're talking about the traitors of Muslim

23     people who I've listed here, I can write their autobiographies.  Your

24     Honours, my explanations would take too long, and I don't want to waste

25     your time.  In all of my previous statements, I stated what I did and

Page 19551

 1     I adhere by my words.  Among these people that Mr. Karadzic has just

 2     named, there are also some people from the margins of life, criminals,

 3     who did not care about any ideology.  From the Serb army, they received

 4     weapons and they could legally go and kill other people, loot their

 5     homes, beat them, and that was their pay for what they did.

 6        Q.   Thank you.  We did not see that, Mr. Sivac, anywhere, no media

 7     has ever mentioned that, let alone court documents.  But tell me, if you

 8     say that they are traitors, what would they say about you?  That you're a

 9     Muslim extremist, right?

10        A.   I would like you to ask them.  I would like to hear their

11     opinion.  Why don't you ask them?

12        Q.   Zlatan Crnalic, who is a graduate of the air force academy is a

13     criminal in your view?

14        A.   I said some of them.

15        Q.   Thank you.  Tell me, who did the Muslim journalists kill?  One of

16     them is Said Hadziahmetovic, he was a male, a journalist, an

17     editor-in-chief in the Serb radio; Dinka Tatarevic, a journalist;

18     Jadranka Vejo [phoen], she is a Muslim; Samija Dzafic [phoen], a Muslim;

19     and Muharem Hasakurtovic [phoen], also a Muslim.  They're all journalists

20     and you also put them on the blacklist, right?

21        A.   Those people worked in Radio Prijedor and Kozarski Vjesnik, and

22     I provided a general statement, and I said that Radio Prijedor and

23     Kozarski Vjesnik were the worst kind of propaganda machinery acting on

24     behalf of the Serbian Democratic Party, and their false propaganda was

25     something that even Goebbels could envy them.  And in general terms,

Page 19552

 1     through the newspaper Kozarski Vjesnik and on the radio, many respectable

 2     citizens of Prijedor were named and later on killed in camps around

 3     Prijedor.

 4        Q.   Thank you.  However, is it correct, however, that you concluded

 5     that all Serbs, irrespective of their party affiliation, had opted for

 6     the politics of the reorganisation of Bosnia, the reorganisation of

 7     Prijedor, and you yourself stated in the book and in the statements, that

 8     there was no difference between the leftist Serbs, the rightist Serbs,

 9     the communists, the reformists, that they were all members of the Crisis

10     Staff, that they all pursued the same politics; is that correct?

11        A.   Yes.  As far as Prijedor is concerned, it was really not

12     important whether people indeed held the idea of the Serbian Democratic

13     Party.  All the Serbs were on the same side and their only goal was for

14     the Prijedor municipality to be ethnically cleansed from all those who

15     were not Serbs, and they were all very fervently working towards that.

16        Q.   Thank you.  When you say that Radio Prijedor was a tool of

17     propaganda of the SDS, it would be better to say that Radio Prijedor was

18     the propaganda tool of the Serbian people, is that what you meant?

19        A.   Well, both would be correct.  But Kozarski Vjesnik and Radio

20     Prijedor were under the direct control of the Serbian Democratic Party.

21        Q.   However, you see that Muslims were also employed there.  You even

22     say that Jadranka published with some joy that the Serb Democratic Party

23     had taken control over Prijedor on the 30th of April; is that

24     correct?

25        A.   Yes.  She was born in a mixed marriage, and she lived in a mixed

Page 19553

 1     marriage, and that was her private opinion.  And yes, she still works in

 2     Prijedor, she is still a journalist affiliated with Radio Prijedor, and

 3     she is a good journalist, I would say.

 4        Q.   However, she is also one of those reserve Muslims, right?

 5        A.   Well, you said that.  I would tell her that if we were to find

 6     each other face-to-face.

 7             JUDGE KWON:  Mr. Karadzic, if it is convenient, we will take a

 8     break now, for 25 minutes.

 9             THE ACCUSED: [Interpretation] All right.

10             JUDGE KWON:  And resume at 4.00.

11                           --- Recess taken at 3.35 p.m.

12                           --- On resuming at 4.03 p.m.

13             JUDGE KWON:  Yes, Mr. Tieger?

14             MR. TIEGER:  Thank you, Mr. President.  If we could move into

15     private session, please.

16             JUDGE KWON:  Yes.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19554











11  Page 19554 redacted. Private session.















Page 19555

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 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

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21   (redacted)

22   (redacted)

23   (redacted)

24                           [Open session]

25             MR. KARADZIC: [In English] It could have been said in public,

Page 19556

 1     I suppose.

 2             JUDGE KWON:  Yes.  Very much so.

 3             THE REGISTRAR:  [Microphone not activated]

 4             JUDGE KWON:  Thank you.  Yes, we are bringing in the witness.

 5                           [The witness takes the stand]

 6             JUDGE KWON:  Thank you.

 7             Yes, Mr. Karadzic, please continue your cross-examination.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Mr. Sivac, I became slightly clearer about your attitude to

11     Muslims.  I would like to clear up your attitude to the Serbs.  There are

12     things that still confuse me about that.  Did you really write that Serbs

13     are criminals and bloodthirsty?

14        A.   Well, considering all that I've been through and all the events

15     I witnessed, it's possible that in some of my writings I did indeed write

16     that, but, Mr. Karadzic, I go to Prijedor nowadays and I spend a lot of

17     time there and I continue to see my Serb friends.  I have coffee with

18     them and a long, nice talk.  I don't communicate only with those Serbs

19     who have blood on their hands.  In fact, I divide people into human and

20     non-human.  I don't divide them into Muslim, Serbs, and others.

21        Q.   However, on the pages 19 and 20 of your book, before the war in

22     Bosnia, you say on page 19, that Serbs took pleasure in the air strikes

23     against hospitals and kindergartens, and on page 20 you wrote:

24             "How can these children wage war against these bloodthirsty Serbs

25     armed to their teeth?"

Page 19557

 1             You wrote that before the war?

 2        A.   I'd like to see it.  If you have a transcript in B/C/S, I'd like

 3     to see exactly what I wrote and how.

 4        Q.   Your book, pages 19 and 20.  Did you write a book?

 5        A.   But what's the context, what kind of events am I talking about?

 6     Oh, you mean the war in Croatia that I followed with my TV crew?

 7        Q.   Yes.

 8        A.   Those were my impressions from Croatia.

 9        Q.   So in your reporting from Croatia, you, as a reporter, sided

10     fully with the Croatian secession, and you reported in a very biased way

11     against the Serbs, according to Serbian evaluation?

12        A.   That's not the case at all.  You misinterpreted and

13     misrepresented completely, trying to accuse me of something that I'm not

14     guilty of.  It was an agreement between the editorial board of my

15     newspaper and the Television Sarajevo.  I was always accompanied by

16     Boro Grubic, a Serb reporter, whenever I went into the battlefield.  That

17     was an agreement made because Boro Grubic was a fantastic commentator.

18     In the war in Croatia, I only worked as a cameraman.  All the political

19     comment was done by a Serb, Boro Grubic.

20        Q.   In your evidence, and in your book, you never mention, let alone

21     highlight, the large numbers of refugees from Croatia.  In 1991, in

22     Prijedor and Banja Luka, weren't there so many refugees from Croatia,

23     including lots of Serbs?

24        A.   No.  There were not that many in Prijedor.  And I remember in

25     1991, together with my colleague Boro Grubic, I was filming a report

Page 19558

 1     about those people.

 2        Q.   I'm confused because you never mention it in your book or in the

 3     testimony recorded in the transcripts.  But there is another thing that

 4     confuses me.  On page 71 of your book, you say:

 5             "This is typical only of Serbs.  They are always extreme, both

 6     when it's time to be a nationalist and when it's time to be communist,

 7     when it's time to be Godless, or a religious fundamentalist.  They are

 8     very quick to embrace completely opposite ideologies.  The only thing

 9     that matters is that they are constantly opposed to other people and that

10     their turn-coat policy brings them advantage."

11        A.   Well, I was just stating facts.  Until very recently, people who

12     used to be extreme communists, hard-line communists, changed -- turned

13     coat completely with the appearance of nationalist parties, and I knew

14     that that would never bring anything good to anyone.

15        Q.   So it was not a slip of the tongue, it was not said by chance?

16     I was hoping it was.

17             Look at what you wrote about the 2nd of September 1991.  I was

18     really astonished by this.  You say that soldiers and office at some sort

19     of celebration, a welcome ceremony, organised for them by the Serbs in

20     the settlement of --

21             THE INTERPRETER:  Could Mr. Karadzic be asked to read slowly?  We

22     don't have this text and we cannot follow.

23             JUDGE KWON:  The interpreters were not able to catch you up a

24     while ago.  Could you repeat, please?

25             THE ACCUSED: [Interpretation] [No interpretation]

Page 19559

 1             MR. KARADZIC: [Interpretation]

 2        Q.   On page 21 of your book, writing about 2 September 1991, you

 3     describe attending a welcome ceremony that the people organised for a

 4     tank battalion, a so-called popular luncheon, and you write that soldiers

 5     and officers are hungrily eating roast pork, drinking local brandy, and

 6     hopping and dancing and skipping.  Isn't this rather offensive to speak

 7     like that, saying that they are drinking hooch by the gallons, and isn't

 8     the wheel dance they were dancing, the Kozara wheel dance, also your

 9     traditional dance?

10        A.   I was just describing what I was seeing.  And in writing those

11     lines, I was so disenchanted by the conduct of the Yugoslav Army that had

12     come to the area of Prijedor from Croatia and turned all their artillery

13     and other guns against Muslim-populated areas, and that army, in which

14     I served loyally once upon a time, became a mono-ethnic one, and that

15     this national -- or nationalist gathering, they made no bones about it.

16        Q.   But on that 2nd of September, you were not able to see that the

17     JNA had trained their guns against any Muslim settlements, right?

18        A.   Well, already, after the withdrawal of the already-defeated,

19     broken Yugoslav Army from Croatia, or just a little later, a large number

20     of artillery and other units stationed themselves in the area of

21     Prijedor.

22        Q.   Is it the case that on the 30th of May Croatia was still part of

23     Yugoslavia?

24        A.   Well, yes, it was, but I followed the entire war in Croatia, and

25     that formerly Yugoslav Army had become completely mono-ethnic.  In

Page 19560

 1     Croatia, it defended and protected only the Serb insurgents, and it

 2     actively participated in the creation of the so-called Serbian Krajina.

 3        Q.   Do you recall that in July and August 1991, there was a historic

 4     Muslim-Serb agreement on the table, initially proposed by

 5     Muhamed Filipovic and Adil Zulfikarpasic with the support of Alija

 6     Izetbegovic and it was accepted by the Serbian side, it was on the table

 7     for all of two months until the end of August?

 8        A.   Let me tell you one thing.  Those plans about the restructuring

 9     of Bosnia-Herzegovina were numberless, and so were peace conferences, but

10     it was impossible to reconcile two sides that were so completely opposed.

11     The Serbs from Bosnia were ultimative in their demands that Serbs and

12     Serb areas in Bosnia remain part of rump Yugoslavia, whereas all the

13     others, Muslims and Croats, were in favour of Bosnia-Herzegovina becoming

14     an independent and sovereign state, which was ultimately accepted by the

15     Badinter commission, and Bosnia was indeed internationally recognised,

16     and on the 22nd of May 1992, it was admitted as a fully fledged UN

17     member.

18        Q.   That much is true, but tell us, Mr. Sivac, did the Serbs ever

19     revise their position and did they make concessions?  Didn't we accept

20     that Bosnia become an independent state on one condition, accepted by the

21     international community, and that was cantonisation?

22        A.   Those were just interim proposals made by you to gain time so

23     that you can create the right setting for what would happen in April

24     1992, for grabbing and carving out a large chunk of Bosnia-Herzegovina,

25     to annex it to the Greater Serbia.

Page 19561

 1        Q.   What do you base this opinion on?  You should be talking about

 2     facts, not your opinions.  Is it a fact, and in that case, what do you

 3     base it on?

 4        A.   I base it all on the events that would follow, and I will be

 5     speaking only about my municipality of Prijedor, where I lived.

 6        Q.   We will come to that.  We are still in 1991.  Is it true that in

 7     your book on page 18 you wrote that Muhamed Cehajic, president of the

 8     municipality, and Dr. Mirza Mujadzic, president of the SDA, came out in

 9     mid-August and put up barriers in the way of the JNA so they can't move

10     through Prijedor?

11        A.   Yes.  That was reported by both Kozarski Vjesnik and

12     Radio Prijedor.  In fact, there was this tank unit that came to Prijedor

13     and was setting itself up there, without informing the legal

14     representatives of Prijedor municipality; whereas by all the rules, the

15     military command should have informed the representatives of the

16     municipality and the authorities that they would be doing that.

17     Indignant over such a manner of conduct by that military unit,

18     Muhamed Cehajic, who was the legal representative of the municipal

19     authorities, and Mirza Mujadzic tried to put up some roadblocks.

20     However, from the neighbouring houses, Serbs came out already very well

21     armed and Cehajic and Mujadzic withdrew.  But the very next day, the

22     military command from Prijedor sent out a communique saying, in no

23     uncertain terms, that they were stationed in Prijedor at the invitation

24     of the Serbian Democratic Party and the Serbian people.

25        Q.   Thank you, Mr. Sivac.  But could you please produce that

Page 19562

 1     communique testifying to the great love between the JNA and the SDS?  But

 2     is there a single country in the world where half of the municipal

 3     authorities would come out and stand in the way of the only legal armed

 4     force in that country?

 5        A.   That happened at that time because strange things were happening

 6     in Prijedor.  Then generally, in 1991, towards the end of that year, we

 7     received reports that at Urije, which is a Serbian neighbourhood in

 8     Prijedor, legally elected representatives of the authorities of Serb

 9     ethnicity were meeting separately, making some sort of plans for taking

10     over power in Prijedor municipality.

11        Q.   We'll come to that later.  Let me first ask you this:  Do you

12     know that the JNA was a legal and legitimate armed force until the

13     19th of May 1992, and that Izetbegovic, Kljujic and I, on 23 December

14     1991, held meetings and begged them to stay and help prevent interethnic

15     conflict?  And that was reported by the media.

16        A.   I remember that.  But this spontaneous incident created by

17     Professor Cehajic and Mirza Mujadzic was something that they believed

18     they should do, and they did it.

19        Q.   Now, for a president of a party, and a president of the

20     municipality, to act spontaneously and spontaneously confront the army,

21     I find that rather confusing.  But let's leave that aside.  Is it true

22     that the police blocked military representatives from removing, taking

23     over, the military documentation they needed to carry out mobilisation

24     and call up recruits?

25        A.   For the first time, a Muslim came to that position, the head of

Page 19563

 1     the military department, Becir Medunjanin came to that position.  It was

 2     always previously occupied by the Serbs.  And before that, Serbs were not

 3     mobilised.  They volunteered at the military department to go to war in

 4     Croatia.  Once, outside the SUP and outside the security service, the

 5     same premises shared by the military department, the military police came

 6     one day and they wanted to remove the files of military conscripts by

 7     force.  And that's when this minor incident occurred.  I don't know how

 8     it all developed later, but I know that a large number of Serbs did

 9     respond to the mobilisation to go to war in Croatia.

10        Q.   Thank you.  Is it true that in addition to individual draft

11     calls, there is also such a thing as a general call-up, whereby people

12     are asked by, or through the media to report to certain locations?

13        A.   That is correct.

14        Q.   Is it correct that the entire infrastructure and documentation in

15     this regard belonged to the federal Secretariat for National Defence and

16     that the employee in the municipality was actually employed by the

17     Ministry of Defence?

18        A.   I don't know the legal definitions, but I do know that once the

19     national parties came to power, Becir Medunjanin, who was an SDA member,

20     was assigned to the post of chief of the military department in Prijedor.

21     I don't know, though, who he reported to.  I do think, though, that he

22     had to have been in touch with the republican TO staff or with a command

23     or the command of a military district in Sarajevo.

24        Q.   In other words, with the TO staff and the JNA in

25     Bosnia-Herzegovina, headed by a Serb general, Vukosavljevic?

Page 19564

 1        A.   I don't know who the person in charge was at the time.

 2        Q.   Do you know Mr. Becir Medunjanin well?

 3        A.   No, I met him for the first time when the SDA carried the

 4     elections, when he was appointed to his position.

 5        Q.   What are the names of his sons?

 6        A.   One is Hanis [phoen], and the one who was killed, well, I don't

 7     know his name.

 8        Q.   Does he have a son who lives in the US?

 9        A.   I don't know where that son is.  I used to know him when he was

10     very young.

11        Q.   Hanis and Adis; is that correct?

12        A.   You are saying that.  I only know of Hanis, the older one, and

13     I remember having met him somewhere in Bosnia.

14        Q.   Did you know that Adis Medunjanin was arrested in the US as an

15     Islamic terrorist?

16        A.   This is the first I hear of it.

17        Q.   Did you know that Becir Medunjanin instigated Muslims from

18     Prijedor to fight?  He actively assisted in their organisation as part of

19     their preparations for war?

20        A.   So you say.  Do you think, though, that there is a lot there

21     which isn't true.

22        Q.   At page 21 of your book you say that the ruling SDA in Prijedor

23     would not allow the conscription commission to access the files.  Was the

24     SDA the only party in power in Prijedor or was there a coalition in

25     place, including the SDS?

Page 19565

 1        A.   Yes.  In Prijedor municipality, the SDA won the most votes in the

 2     elections, and the next party in line was the SDS.  And I believe they

 3     split the power in Prijedor municipality.

 4        Q.   You say that Prijedor was predominantly populated by Muslims, and

 5     according to the census, there were 49.454 Muslims in 1991; whereas,

 6     there were 47.745 Serbs, correct?

 7        A.   That data comes from some earlier documents.  But the difference

 8     in terms of percentage between Serbs and Muslims was some 2 per cent in

 9     favour of the Muslims.

10        Q.   Thank you.  And what about the 6.000 plus Yugoslavs?  Did you

11     include them in any of the categories?

12        A.   I did not, they simply proclaimed themselves Yugoslav.

13        Q.   Do we agree that in 1991, Yugoslavia and declaring oneself as

14     Yugoslav was not a favourable option and that at least four fifths of the

15     Yugoslavs were Serbs?

16        A.   Says you, Mr. Karadzic.  Among the Yugoslavs in Prijedor

17     municipality, there were many Muslims who declared themselves Yugoslavs.

18        Q.   Do you recall that our electoral system was founded on the

19     majority system -- sorry, proportionate system for the council of

20     citizens and the majority system for the council of municipalities?

21        A.   I cannot comment on that at the level of the republic.

22        Q.   Very well.  But do you recall that there was such a thing as the

23     council of municipalities in the Bosnian assembly?

24        A.   I do.

25        Q.   Do you recall that in Prijedor, as part of the majority system, a

Page 19566

 1     Serb, Svetozar Imanac [phoen] won which clearly indicated that there were

 2     more Serbs in Prijedor than Muslims and Croats put together?

 3        A.   I'm not aware of that.  And I don't even remember the person you

 4     are referring to.

 5        Q.   Thank you.  He was a deputy in the assembly.  Is it correct that

 6     in Prijedor town, there are several thousand Serbs more than Muslims,

 7     including Yugoslavs?

 8        A.   These are your assessments, but I do believe that statistics show

 9     otherwise.

10        Q.   I stand by what I'm saying.  There were 34.000 --

11             THE INTERPRETER:  Could Mr. Karadzic kindly slow down when citing

12     figures.

13             JUDGE KWON:  Mr. Karadzic, please slow down when citing figures

14     and could you repeat.

15             THE ACCUSED: [Interpretation] Apologies.

16             MR. KARADZIC: [Interpretation]

17        Q.   In the town itself, 34.627 Croats, 1.756 Muslims, and 13.372

18     Serbs, thirteen thousand nineteen sixty-nine [as interpreted] Yugoslavs.

19     And others such as Ruthenians, Czechs, Italians, amounted to less than

20     2.000; is that correct?

21        A.   This is the first time I hear of this information, of this data.

22        Q.   Thank you.  Do we agree, then, that Prijedor was a municipality

23     of all?  No one was in any significant majority, although there were the

24     most Serbs?

25        A.   In 1991, it was a common municipality of all ethnicities.

Page 19567

 1        Q.   Regarding the Kozarac crisis, Radio Prijedor broadcast that the

 2     Muslims should withdrew to Prijedor due to wartime activities; whereas,

 3     you say that a large number of civilians arrived in Prijedor and that all

 4     Prijedor citizens assisted those who had fled the fighting.  Is that

 5     correct?

 6        A.   It is not.  On the 24th of May 1992, Radmilo Zeljaja, who was on

 7     rampage at the time and in command of the infamous Serb unit --

 8        Q.   Wait.  We'll get to that.  We don't want the whole history.  Did

 9     the radio broadcast such information and did the Serbs invite the Muslims

10     from Kozarac as well as the Serbs to come to the town itself?  Did you

11     touch upon that in your book?

12        A.   I don't know how those people from Kozarac arrived but they only

13     arrived after Kozarac had been shelled.  They were in front of the sport

14     hall in Prijedor for a while, and then they were put aboard trucks and

15     buses and taken to Trnopolje.

16        Q.   In other words, you're saying that in Prijedor, where most of the

17     inhabitants were Serbs and Yugoslavs, the civilians from Kozarac simply

18     arrived there because there had been fighting there?

19        A.   They arrived in Prijedor seeking refuge with their friends and

20     relatives.  However, only a few Kozarac inhabitants who had been driven

21     out found refuge with their friends and relatives.  Most of them were

22     transported to the camp at Trnopolje.

23        Q.   Thank you.  Let's clear this up.  Who received those people in

24     Prijedor, Serbs or Muslims?

25        A.   The Kozarac inhabitants who had been driven away found

Page 19568

 1     accommodation in the Puharska settlement in Prijedor, which was

 2     predominantly populated by Muslims.

 3        Q.   Those who were driven out of Kozarac, well, this is something

 4     that this Defence will have to keep working on, but I'm asking you this

 5     specifically:  The civilians from Kozarac who either fled or were driven

 6     out, we'll see that, did they find accommodation in the town itself, and

 7     with whom?

 8        A.   Only a small number of them were accommodated in Puharska with

 9     their Muslim friends.

10        Q.   So the Muslims that took them in seemed to have been safe in

11     Prijedor, and these people found refuge with them?

12        A.   Yes, but only at that moment in time.

13        Q.   I'll have to skip topics, but at page 26 of your book, you seem

14     to say that the Serbs destroyed the bridge in Bosanska Dubica, and then

15     in one of the subsequent paragraphs, you say that it was destroyed from

16     the Croatian side.  How could the Serbs have crossed over to the Croatian

17     side in order to destroy the bridge?  And you seem to say the same thing

18     about all the bridges across the Sava, in other words that they were

19     destroyed by the Serbs.

20        A.   Mr. Karadzic, I personally shot from the bridge with my camera,

21     together with my team.

22        Q.   So how do you know who destroyed it?

23        A.   Please do be patient with me.  I reported from the -- from the

24     Una valley.  I observed how the Serbs from the Krajina were ethnically

25     cleansing the valley.

Page 19569

 1        Q.   I'm asking you about the bridges now.  How can you assert in your

 2     book that the Serbs, who lived on one bank of the Sava, destroyed the

 3     bridge which connected them with the Serbs living on the other side of

 4     the Sava?

 5        A.   Because Jasenovac had been occupied by Martic's soldiers from the

 6     Serb Krajina in Croatia.  The moment they got into Jasenovac, they

 7     torched a hotel.

 8        Q.   Is it across the river from Dubica?

 9        A.   Yes, but it was occupied by the Knin Serbs.

10        Q.   So we have the Serbs on both banks of the Sava and yet we have

11     Serbs destroying the bridge; correct?

12        A.   That was the information we received at that location.

13        Q.   Who gave you that information?

14        A.   The people who were in the area.

15        Q.   Is it not correct that your acquaintance, Milenko Tubica [phoen],

16     an official of the Bosanska Dubica municipality, complained that the

17     bridge was the cause of isolation of that municipality, so a Serb from

18     the left bank complained of ties being severed with the Serbs on the

19     other side, and yet you still seem to believe that the Serbs destroyed

20     the bridge.

21        A.   My colleague, Boro Grubic, reported on that.  And I simply

22     conveyed information he received.

23        Q.   Thank you.  On page 32 you say that communists

24     Mico Sarjevic [phoen] and Jaksic from the chamber of commerce arrived.

25     Can we agree that neither of them were SDS members?

Page 19570

 1        A.   I don't know what party they belonged to, but I do know that they

 2     came to the Prijedor theatre to have an open discussion at which they

 3     openly invited the people of Prijedor to join the newly formed autonomous

 4     region of Bosanska Krajina.  Prijedor has traditional ties to Banja Luka,

 5     in terms of friendship, economy, transport and other infrastructure.

 6        Q.   Thank you.  And they supported their call by economic reasons,

 7     resources, and the need to become independent of Sarajevo,

 8     Nedim Kadiric [phoen], a Muslim journalist dispersed the gathering in a

 9     way?

10        A.   Yes.  He put a few direct questions, which they were unable to

11     answer, and they simply backtracked.  They realised they wouldn't do

12     anything in Prijedor.

13        Q.   Is Prijedor some 30 or 32 kilometres from Banja Luka?

14        A.   No.  The distance is 55 kilometres.

15        Q.   By road perhaps, but I meant as the crow flies.  With a lot of

16     ill intent, you seem to discuss the issue of reconstructing churches, but

17     you were reluctant to record any footage about that.

18        A.   No.  It only concerns the Serb village of Nisevic, near Omarska.

19        Q.   Next you say that Serbs had a morbid relationship to anything

20     non-Serb.  It was at page 37.  Such proof of ordered crime is without any

21     shame broadcast by TV stations in Yugoslavia and Belgrade, and in Banja

22     Luka.  Can you explain what kind of morbid attitude did Serbs have

23     towards all things unSerb?

24        A.   Zivko Ecim was the most morbid of all in terms of his reporting

25     from the theatre in Croatia.  They recorded Serb soldiers who shelled

Page 19571

 1     certain buildings in the area according to their -- to humour them.  They

 2     made many tapes, and even sold them in Prijedor.  Isn't it morbid to ask

 3     for a Croatian house to be destroyed so that they could shoot some

 4     footage?

 5        Q.   However, Mr. Sivac, you didn't say two men.  You said the Serbs.

 6     Why didn't you accuse them?  They could then defend themselves.  They

 7     would be able to respond, but you accuse the Serbs?

 8        A.   Because the Serbs in Prijedor bought the tape en masse and

 9     enjoyed watching it.

10        Q.   Is it true that you called me a werewolf from

11     Mount Dermiter [phoen]?

12        A.   Yes, it is possible.  Everything is possible.  I paraphrased

13     that.  I took it from a Sarajevo newspaper, I believe.

14        Q.   I'm not sure that a wolf is a correct translation.  It should

15     werewolf, a psychiatrist, a werewolf from Dermiter, Radovan Karadzic,

16     whatever his name is, he clearly is -- sends threats from a hole in

17     Sarajevo and said that Muslims should disappear.  You are referring to my

18     speech in 1991, right?

19        A.   Yes, I am.

20        Q.   However, your attitude towards me, doesn't it disqualify you as a

21     witness?  What do you say to that?

22        A.   I don't think so.  That was the belief at the time when

23     everything started, and I believe that in Bosnia-Herzegovina, among the

24     other ethnic groups, that was the belief.  That's -- many from the other

25     ethnic groups saw you that way.

Page 19572

 1        Q.   And you don't know that we signed a cease-fire with Croats very

 2     early on, that Muslims told us everything that we needed to know, well,

 3     in time, that we cooperated with Muslims, we had very good relations with

 4     them, we had entire Muslim units in our army, and you talk about that in

 5     your book, you say that a lot of Muslims were traitors of the SDA

 6     politics.

 7        A.   I don't know what your question is.

 8        Q.   Do you know that on the 6th of May 1992, we signed a cease-fire

 9     agreement with Muslims and that saved tens of thousands of lives.  There

10     was some fighting after that, but to a lesser extent, and do you know

11     that we signed another agreement with Avdic?  We didn't fight with him.

12     We even supported him and helped him survive.  Do you know that many

13     Muslims from Sarajevo sent us information on a daily basis?

14        A.   I don't know what the Sarajevo kitchen cooked for you, but I know

15     that all the cease-fire agreements and peace agreements that were signed

16     ad hoc were very short-lived.

17        Q.   And do you know that when General Vukosavljevic was removed from

18     a position as the head of the Territorial Defence on the 8th of April,

19     that on the 12th of April, the new commander, Hasan Efendic, issued an

20     order to attack the Bosnian Serbs and the JNA?  That was on the 12th of

21     April, and on the 13th of April that order was on my desk, and then we

22     got the admission from the Bosnian Army.  I received that on the 13th of

23     April from Muslims who were against the war.  Did you hear of that order

24     or that directive?

25        A.   No, I never heard of that order or that directive.  This is the

Page 19573

 1     first time I hear of it.  I heard of a dispatch that was sent by

 2     Jerko Doko who was the Defence Minister.

 3        Q.   Yes, but that's a different thing.  That was towards the end of

 4     April.

 5        A.   Yes, thereabouts, I would say.  And in Prijedor, that dispatch

 6     inspired the Serbs to take over power in Prijedor.

 7        Q.   Let's move on from the 12th of April to the end of April and

 8     let's talk about the second dispatch.  That dispatch was sent to us by

 9     Delimustafic, the Minister of the Interior and Jerko Doko, the Minister

10     of Defence.  It arrived in Prijedor and then every other municipality,

11     and according to that dispatch, the JNA and the Bosnian Serbs were to be

12     attacked with all might.

13        A.   Mr. Karadzic, all that was denied subsequently.  It was a false

14     dispatch that somebody circulated under false pretext.

15        Q.   Mr. Sivac, there was nothing false about that, and the Trial

16     Chamber will learn that, but is it true that on the 29th or between the

17     29th and the 30th of April, the Serb side took over power in Prijedor

18     because an attack had been prepared against the JNA and the Serbs in

19     Prijedor?  You even just confirmed that for us.

20        A.   No, I did not confirm it.  There was no attack in the making

21     against the Serbs.

22        Q.   Very well.  Do you know that then, and after that time, an offer

23     was tabled for Prijedor to be split into two municipalities and that the

24     Serbian should consist of the Serbian part called Varos and the Serbian

25     villages, and the Muslims should be the older part of town, Puharska and

Page 19574

 1     whatever they are called, Puharska and Muslim villages, hilltops and so

 2     on and so forth, do you know that that motion remained on the table until

 3     30th May?

 4        A.   It was a false offer.  The map was published by Kozarski Vjesnik

 5     and that map caused dissatisfaction among the Serbs as well because that

 6     map that was published featured over 70 per cent of Prijedor municipality

 7     that had to be given to the Serbs and that contained the most important

 8     infrastructure, economic entities, the national park.  So all that should

 9     have been given to the Serbs, and what was left to the Muslims was a

10     small part in the part of the town of Prijedor where they constituted a

11     majority, and almost none of the large economic entities.  Even the Serbs

12     who resided in the central part of the city, in its nucleus, which

13     according to that map should have been allegedly been given to the Muslim

14     municipality, they protested, they called in a radio show, there was an

15     open telephone line for them to call in.  And they directly protested

16     against the person who drafted such a map, who composed it.

17        Q.   Thank you.  There will always be somebody protesting that their

18     village did not become part of the municipality, but don't you write in

19     your book that you were fully aware that companies and businesses would

20     be divided, regardless of whether they are -- where they are located,

21     they would be divided, and you write -- did you imply that the public

22     utilities would remain joint, such as electricity supply and water

23     supply, et cetera?  Would it be the only city in Yugoslavia to have more

24     than one municipality?

25        A.   Well, you are either paraphrasing or pulling it out of context

Page 19575

 1     because I never wrote anything like that.

 2             JUDGE KWON:  Mr. Karadzic, pause.  Please pause.  And start

 3     again, please.

 4             THE ACCUSED: [Interpretation] I apologise.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   So you do write that they would be divided but let us look at

 7     1D4275 in e-court, to see what Prijedor municipality looks like.  And

 8     then I would like to ask the AV director to zoom in on the upper left

 9     part.  We can see where Prijedor is.  Can we zoom in on the north west

10     and place it in the centre?  You write about that on page 57 of your

11     book.  You are fully aware that demands are made to divide companies,

12     schools and organisations that were created from withdrawals from the

13     salaries of all the working people like those working people did not

14     involve -- include Serbs.

15        A.   Well, Muslims and Croats were not in favour of that division.

16             THE INTERPRETER:  Speakers need to pause between question and

17     answer.  They are overlapping all the time.

18             JUDGE KWON:  Could you repeat your question, Mr. Karadzic?

19             MR. KARADZIC: [Interpretation]

20        Q.   You say that Muslims and Croats in Prijedor were not in favour of

21     any divisions but they wanted to divide Yugoslavia and they wanted to

22     take Serbs outside of Yugoslavia and make them a national minority.

23        A.   You said that, not I.

24             JUDGE KWON:  Mr. Karadzic, you also need to put a pause between

25     the answer and your question.  You should be familiar with that.  Please

Page 19576

 1     continue.

 2             THE ACCUSED: [Interpretation] I apologise to your Excellency and

 3     the interpreters as well, but I'm really trying to get through as much as

 4     I can.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Look at this.  You must know by heart every single village here,

 7     blue and green.

 8        A.   Well, approximately.

 9        Q.   Do you know, Mr. Sivac, that in Sarajevo, there are ten

10     municipalities, five of which have both one part inside the city and

11     villages outside the city as is the case in Prijedor?

12        A.   Probably, that may be the case in Sarajevo.  All I know about is

13     Prijedor.  I can only answer questions about Prijedor.

14        Q.   And do you know how many people are there in a municipality?  In

15     Yugoslavia and the Soviet Union, the average population is 40.000, in

16     Greece it's 8.000, and Prijedor has more than 100.000, and you still

17     think it shouldn't be divided into several municipalities?

18        A.   All your games about divisions in Prijedor were aimed at gaining

19     time.  If at the level of the republic, at the global level, you realise,

20     and you make a decision to annex the whole of Prijedor to the

21     Autonomous Region of Bosnian Krajina which had already stated they were

22     willing to live only in the former Yugoslavia, or the rump Yugoslavia,

23     then all these games you played at that time, in April, were only moves

24     to win time.

25        Q.   You are reading your own stuff into our intentions.  Do you know

Page 19577

 1     that in February of that year, on 14th of February, we had definitively

 2     accepted that we would not remain a part of Yugoslavia and we accepted

 3     the European community's condition to remain in Bosnia-Herzegovina?  It

 4     was on the 13th of February.  It was all published in the media.

 5        A.   Maybe you paid lip service to all these agreements, but you did

 6     everything differently.

 7        Q.   You write that on the 22nd February, we returned from Lisbon,

 8     that's page 54, the first discussion on BH held in Lisbon, no result

 9     whatsoever.  The SDA wanted a totally independent BH; whereas, the SDS

10     suggested a confederation with complete equality between ethnicities.  Do

11     you know that Croats were a Catholic community in Bosnia, and they

12     supported the proposal of a confederation with three different entities

13     that was also supported by the European community?

14        A.   I don't know much about these agreements at the level of the

15     republic.  You were involved in higher politics, you negotiated with the

16     international community and with the other politicians in Sarajevo.  I

17     can only speak about the municipality of Prijedor.

18        Q.   But you're also talking about central things and Lisbon and you

19     state, inaccurately, that on that February nothing was achieved.  The

20     first step was on 13th of February, the second on the 22nd, the second

21     step, and finally in March, an agreement was made to divide Bosnia into

22     three constituent parts, like it is today, in fact, but it's only two

23     entities instead of three.  Did you know about these things?

24        A.   No, I just conveyed that information as I found it in a Sarajevo

25     newspaper.

Page 19578

 1        Q.   How can you then say that the demand for the transformation of

 2     Prijedor was some kind of manoeuvre on our part?  If Muslims would have

 3     complete authority in all their areas and Serbs would have complete

 4     authority in their areas, while sharing some joint bodies, as we do now

 5     in Bosnia-Herzegovina?

 6        A.   What is your question?

 7        Q.   How can you claim that it was a Serbian game when you would have

 8     the same thing as Serbs?  You would have government in your own

 9     neighbourhoods and areas and you would be in charge of your own affairs.

10        A.   You were only paying lip service to that sort of suggestion and

11     agreement.  All the events that followed showed your real intentions.

12        Q.   Do you know that Cehajic and other Muslim representatives had

13     accepted that and moved to the left bank of the Sana river and started

14     establishing their own municipality and their own police station?

15        A.   That too is not true.  If that had happened, I would have at

16     least known.

17        Q.   You claim that it didn't happen?

18        A.   I claim it didn't happen.

19        Q.   Tell me:  Did the weapons remain in the hands of Muslims in all

20     these green areas?  Did they have check-points at the access roads to

21     each Muslim settlement, all the way until 23rd May?

22        A.   Mr. Karadzic, when you ask a question, please specify the time

23     and dates relevant to the question.

24        Q.   From 30th of April onwards, when the Serbs took over power in

25     Prijedor to prevent, as you said yourself, whether you believe it or not,

Page 19579

 1     to prevent attacks on the army and the Serbs, from the 30th of April

 2     until the 23rd of May, is it the case that all the Muslims in their own

 3     areas have check-points and have their own weapons without anybody asking

 4     them to surrender those weapons?

 5        A.   That's not true, Mr. Karadzic.  Immediately after the takeover, a

 6     call was publicly made for mobilisation.  Both the police and the army

 7     were reinforced to full complement, and the next move of the new

 8     government in Prijedor was to put all the media under their control.  On

 9     the 12th of May they arrested me and a large number of ham radio

10     operators, private persons who had their own radio stations, properly

11     licensed.  The new authorities began to hermetically close the Prijedor

12     municipality and isolate it.  Call-ups for mobilisation were sent out to

13     all the Serbs, and at the same time, an announcement was made to all

14     non-Serbs that they must hand in their weapons, failing which they would

15     suffer consequences.  All this lasted until the 23rd May, when that

16     incident in Hambarinsko Polje happened.

17        Q.   Thank you.  Is it true that General Talic came, and on the

18     20th May, there were talks with the local people from Kozarac, that they

19     should take over law enforcement in their own settlement but stay out of

20     fighting?

21        A.   Let me tell you, I know that after the takeover in Prijedor

22     municipality, Kozarac, that was 90 per cent populated by Muslims, became

23     a big problem for the new Serb authorities in Prijedor.  All sorts of

24     emissaries went to Kozarac to try to convince the local residents to

25     accept the newly installed authorities who had been installed by force,

Page 19580

 1     but they did not accept that.  They expressed their wish to remain to

 2     live in Bosnia-Herzegovina and nothing else.

 3        Q.   Aren't you contradicting yourself?  You were saying they were

 4     trying to convince them by force.  You go to force people with tanks,

 5     whereas they went to talk.

 6        A.   No.  You didn't understand me.  They went to talk, but the

 7     Kozarac people did not want to accept the forcible takeover that had

 8     happened in Prijedor because they thought, very reasonably, that nothing

 9     installed by force could have anything to do with democracy.

10        Q.   Serbs were in power in Prijedor, but they were not the ones who

11     had been planning attacks on the JNA and the Muslims.  It was the Muslims

12     who had planned attacks on the JNA and the Serbs.

13        A.   Let me tell you this:  The Muslims in Prijedor had no means, no

14     resources, to wage war.  If they had the wherewithal, they got the moral

15     right to do it on the 30th of April when the Serbs took over by force,

16     when they disarmed Muslim and Croat policemen.  They had the right to

17     react, to try to stop it.  However, the Muslims had realised, long since,

18     that they did not have a prayer of defending Prijedor if the Serbs ever

19     decided to take it over by force.  Large contingents, large arsenals of

20     weapons, were based in Prijedor and around it, weapons that had been

21     brought from Croatia, and all the other equipment of the former JNA, and

22     I'm underlining that it's former JNA.

23        Q.   Then whose bright idea was it to move against Serbs who were so

24     well armed?  Who opted for war?  Isn't it true that you went to Kozarac

25     and Medunjanin did too, and didn't you all advocate that Kozarac should

Page 19581

 1     resist?

 2        A.   I don't know where you got that, that I went there.  I just heard

 3     that as a news item.  I didn't go to Kozarac at the time.  My reporting

 4     and the reporting of my colleague, Boro Grubic, had stopped long before

 5     because the IT centre in Banja Luka had been seized by the

 6     Serbian Democratic Party, and our communications with our head office

 7     were broken.  The people in Prijedor were never in favour of any military

 8     or war option.

 9        Q.   Thank you.  But is it true that you wrote in your book, page 109,

10     that Alija Izetbegovic had sent a message not to give up weapons?

11        A.   Alija Izetbegovic kept sending all sorts of messages.  Perhaps he

12     sent that one, too.  If I wrote that, then he must have.

13        Q.   Is it true that in that same book, you qualified the SDA as war

14     mongers, and you say on page 91:

15             "They were pushing people and instigating them into war, but now

16     they are nowhere to be found.  They left their people in the lurch on the

17     eve of a great historical battle.  They completely lost face."

18             So you were aware that they were going for the war option in

19     defiance of all Serb proposals to keep peace in Prijedor, and it was the

20     leadership of the SDA who were doing that, Mirza Mujadzic,

21     Hilmo Popovac [phoen], and you named the other people who had first

22     instigated people to war and then ran away.

23        A.   If you are quoting from my book, then I must have written it, but

24     in a different context.  It was a radical branch of the SDA that was a

25     bit trigger-happy.  With the help of their Serb friends after the

Page 19582

 1     takeover, they escaped somewhere outside of Prijedor and their political

 2     activity ceased.  The town of Prijedor and the Prijedor municipality were

 3     left to their own devices.

 4             On one hand, there was you, very well trained and very well

 5     armed, with your units and their combat experience from Croatia, and on

 6     the other hand there were Muslims and Croats who had almost no weapons at

 7     all, apart from a few pieces that they had bought from Serbs who had

 8     smuggled some weapons coming back from the war in Croatia.

 9        Q.   Do you know, Mr. Sivac, that we had no communication with the

10     head office in Prijedor?  And you can find that both in my diary and in

11     the speech made by Srdjo Srdic in the assembly, they didn't ask us

12     anything because they couldn't ask us anything.  The communications were

13     down?

14        A.   I was talking about TV links and radio links, but the telephone

15     worked all the time.  As for Srdjo Srdic, sometime after 12 May, a

16     colleague of mine came to visit, and he kept me very well informed, and

17     he said that at the famous assembly session in Banja Luka, on the 12th of

18     May, you had a brief encounter with politicians from Prijedor led by

19     Srdjo Srdic and you praised them for having taken over the power in

20     Prijedor without a single shot fired.  But you said, However, we have to

21     think of the future.  I'm not quoting, of course I'm paraphrasing the

22     best I can.  Srdjo Srdic asked, How do you mean that, president?  And you

23     said, If in the future we want to join Prijedor municipality as an

24     integral part of this new Serbian state, the international community

25     would probably demand that the population, since it is mixed, declare

Page 19583

 1     their wishes, whether they want it or not.  And since non-Serbs are the

 2     majority, they would probably not want to live in that new Serbian state.

 3     And then Srdjan Srdic asked you what to do, and you said, You have all

 4     you need.  Just make sure to reduce the non-Serb population to a

 5     reasonable number.

 6        Q.   Just tell me, Mr. Sivac, did you make that up or did somebody

 7     else make it up?  Do you have an ounce of evidence for what you've just

 8     told us?

 9        A.   Mr. Karadzic, I got it from a very good friend of mine, who was

10     there, who was present at that meeting, and I believe him.

11        Q.   Well, now, please tell us his name because the defence has the

12     right to check.  What's his name?

13        A.   I won't say it.  I am sure I have the right to withhold it.

14     Unfortunately, he's no longer alive but his family is still there in

15     Prijedor.

16        Q.   You mean he's a Serb?

17        A.   Of course.

18        Q.   How very convenient.  He's not alive but you are making

19     unbelievable claims.  How did you make up that I'm related to

20     Srdjo Srdic?

21        A.   That's what he was boasting about in Prijedor.  He didn't

22     actually say he was directly related to you.  He said his second wife is

23     somehow related to you.

24        Q.   Okay.  You hear something and then you write it in your book as

25     if it were scripture.  Do you stand behind what you wrote in your book

Page 19584

 1     and in what you said in your evidence?

 2        A.   That's how it was.  You ethnically cleansed Prijedor.  You made

 3     it so that non-Serbs disappeared from Prijedor.

 4        Q.   Leave it to the Trial Chamber to decide.  When we collect all the

 5     evidence, the Chamber will make their own conclusions about what happened

 6     in Prijedor.  How did you make up that I am related to the second wife of

 7     Srdjo Srdic and that I slept with my entourage of 12 policemen in his

 8     apartment rather than the hotel?

 9        A.   I never said you spent the night there with your 12 policemen.

10     Srdjo Srdic bragged, and I was on very good terms with him and with the

11     other man, the journalist, he bragged that you always preferred to spend

12     the night at his place and his wife's place, because you were somehow

13     related.  And he was your main political partner in Prijedor.

14        Q.   Do you know, Mr. Sivac, that all the leaders, especially the

15     leaders of major political parties, had official escorts from our joint

16     MUP, official security details, and they never let me spend nights

17     anywhere else but the place chosen by the security detail?

18        A.   I know, because I worked in the security service at one point,

19     how they treated politicians and how it was all organised.  Now, I don't

20     know anything more about this than what I heard from your party member in

21     Prijedor, Srdjo Srdic.

22        Q.   Who set fire to the hotel in Prijedor, Mr. Sivac?

23        A.   Which hotel, Mr. Karadzic?  There were two.  Do you mean 1992?

24        Q.   Yes.

25        A.   Please, I'm asking you once again, specify the time and date

Page 19585

 1     relevant to the question.

 2        Q.   First of all, tell me, is it true, and is it beyond any doubt,

 3     and you confirmed it in your book, that Muslims attacked Prijedor on the

 4     30th of May from several directions?

 5        A.   Mr. Karadzic, that information was taken over from

 6     Kozarski Vjesnik, that published a story in several instalments

 7     reconstructing what they call the attack on Prijedor, and I call it an

 8     attempt to liberate Prijedor.

 9        Q.   Let's take that it's true.  Did this attempt to liberate Prijedor

10     take place on the night of the 29th of May?

11        A.   An informal group, including Slavko Ecimovic and some men that,

12     after the takeover, had to escape from Prijedor because the Serbs wanted

13     to --

14        Q.   I'm not asking you about the background.  I'm just asking you, is

15     it true that there was an attempt to liberate Prijedor with the use of

16     weapons from several directions on the 30th of May at dawn?  Did you

17     listen to the shooting, and did you observe it from your window?

18        A.   Yes.  But I took that reconstruction of the attack from the

19     very-well-informed Kozarski Vjesnik newspaper, which, in its turn,

20     falsified some of the details.

21        Q.   You say an informal group.  These bullets and the rockets fired

22     from "zolja" hand-held launchers, were they also informal or were they

23     controlled by someone?

24        A.   They were not under anyone's control.  They did not belong to the

25     HDZ or the SDA.  It was a group of desperate people who were just trying

Page 19586

 1     to return to their homes in Prijedor.

 2        Q.   Let's leave that aside.  Let's go back for a moment.  Is it true

 3     that at the check-point in Hambarine, on the 22nd of May, a car was

 4     stopped with four Serbian and two Croatian reservists, six young men in

 5     all, two were killed, two were seriously wounded, and two lightly

 6     wounded, and the police held Aziz Aliskovic suspect in that incident?

 7        A.   Yes.  But you failed to say that at the same check-point one man

 8     was killed and two were seriously wounded.

 9        Q.   There was one wounded Muslim?

10        A.   No, that's not true.  One was killed and two were seriously

11     wounded.  And this Ferid Sikiric, who was treated at the hospital after

12     having given an interview, was liquidated by the Serb police.

13        Q.   Do you have any proof of that?

14        A.   Yes.  There is evidence, and I presented a lot of material and a

15     lots of videotapes to this Tribunal.  There is one videotape where this

16     Ferid Sikiric makes his last statement, and after that he was found in

17     one of the mass graves outside Prijedor.

18        Q.   So now he's found in a mass grave, and a moment ago you say he

19     was liquidated by the police?

20        A.   Yes, they took him away.  They killed him and threw his body into

21     one of the mass graves.

22        Q.   How do you know that?

23        A.   I know because I researched it.  I was interested in that case,

24     and I knew the man very well, this Ferid Sikiric.

25        Q.   Can you make available that research to us, your own private

Page 19587

 1     investigation?  How and when did you investigate this?

 2        A.   It's not I who investigated it.  The Serbian television in

 3     Prijedor reported on it, and their report was prepared by Rade Mucic and

 4     another Muslim colleague.

 5        Q.   You just said you researched it.

 6        A.   After the event, I became interested in the fate of this

 7     Ferid Sikiric.

 8        Q.   After you were released from the camp, right?

 9        A.   Yes.  I worked a great deal trying to collect documentation about

10     events that happened in 1991 and 1992.

11        Q.   In the book, on page 113, you say that telephones --

12             JUDGE KWON:  Mr. Karadzic, if you are moving to another topic,

13     I think it's time to take a break.

14             THE ACCUSED: [Interpretation] Yes, we can take the break, but I'm

15     still in May 1992.

16             JUDGE KWON:  Mr. Tieger, in relation to what we discussed briefly

17     in private session, as per your request, we will not be sitting tomorrow,

18     but on Friday, who will we start with?  Yes, and --

19             THE ACCUSED: [Interpretation] Your Excellency --

20             JUDGE KWON:  Just a second.  And excluding this witness.

21             MR. TIEGER:  Yeah, I understand, Mr. President, although hoping

22     we can complete the witness today.  I would imagine that -- well,

23     I thought about that in a couple of permutations but perhaps it's useful

24     if I speak with the Registrar about the videolink issue before --

25             JUDGE KWON:  I'm suggesting -- I'm raising this, that it would be

Page 19588

 1     better, it would be in the interest of justice to conclude the witness

 2     who will testify via videolink on Friday.

 3             MR. TIEGER:  I suspected that the Registrar would feel the same

 4     way, and if the Court feels that way, I am not aware of any circumstances

 5     that would trump that concern.

 6             JUDGE KWON:  Very well.  I think Defence is also following.

 7             We will take a break and we will resume at 6.00.

 8                           --- Recess taken at 5.32 p.m.

 9                           --- On resuming at 6.01 p.m.

10             JUDGE KWON:  Yes, Mr. Tieger?

11             MR. TIEGER:  Thank you, Mr. President, before we recommence can

12     I raise one matter quickly?  The Court is aware that I don't normally

13     interfere with the cross-examinations, but this is -- a matter was raised

14     that I simply thought needed to be addressed.

15             The Court is aware, of course, that a -- the counsel needs a

16     good-faith basis for making allegations in the course of the proceedings.

17     Mr. Karadzic suggested, at pages 39 and 40, that the son of Becir

18     Medunjanin had been arrested in the United States as a terrorist, saying,

19     "Did you know that?"

20             In this case, Mr. President, the simplest scrutiny of the

21     internet, from where this information obviously came, would have revealed

22     that the person arrested in the United States for the event Mr. Karadzic

23     referred to had a different name, was 20 years younger, nearly 20 years

24     younger than the son of Becir Medunjanin, had gone to high school in the

25     United States, many, many completely different factors that would have

Page 19589

 1     resulted in the elimination of this kind of cross-examination, and the

 2     elimination of a canard against the son of Mr. Medunjanin that is

 3     unnecessary, and it would be sitting out here if I didn't address it.  So

 4     I apologise for doing so, but it was just -- given the nature of that

 5     allegation against somebody who was already a victim, as we heard,

 6     I couldn't let it sit.

 7             JUDGE KWON:  Thank you.  Would you like to respond to this or you

 8     just -- I would like you to take into -- take what Mr. Tieger said into

 9     account in the future cross-examination.  Let us proceed.

10             THE ACCUSED: [Interpretation] I can only say this:  If the sons

11     Adis and Anis [as interpreted], then Anis was indeed arrested under that

12     name, Anis Medunjanin.  He was from Bosnia.  He was arrested in America

13     as a terrorist.  One name is certainly Adis.  I'll ask the witness

14     whether Anis was the other name and that's why I thought that that was

15     important, but we'll clarify that.

16             MR. KARADZIC: [Interpretation]

17        Q.   Did you know Nagib, Suljo [phoen], Tadic, Beco, Kanjula [phoen],

18     Medic, did you discuss with them the issue of Kozarac at all?

19        A.   What persons are you talking about?  I don't know who they are.

20        Q.   Beco is Beco, right?

21        A.   Becir Medunjanin, I never discussed the issue of Kozarac with

22     him.  I never talked to him, let alone discussed the issue of Kozarac.

23        Q.   Can we now see 1D04348 in e-court?  Did you know Cirkin?

24        A.   I met Sead Cirkin after the conflict in 1994 -- 5, in Sanski

25     Most.

Page 19590

 1        Q.   Was there another Sivac who was a prominent activist?

 2        A.   Perhaps you mean Sefik Sivac?

 3        Q.   Well, you see here that on the 2nd of May, a meeting was held to

 4     consider the situation in Kozarac.  That meeting did not necessarily take

 5     place in Kozarac itself, but there is a reference to Sivac and to some

 6     other men.  Did you ever attend a meeting of that kind?

 7        A.   Mr. Karadzic, I've never seen this document before.  I never

 8     attended any meetings, and especially not on the 2nd May, 1992.

 9        Q.   Well, in that case, we will not follow that line of questioning.

10     Thank you.

11             We will verify this in other ways.

12             Further on in your book you say, and you mention the directions

13     from which the attack came against Prijedor, right?  And you also

14     mentioned different groups.

15        A.   Yes.  I mentioned the groups as they were identified by

16     Rade Mutic and Zivko Jakic, both journalists.

17        Q.   Was that confirmed by Mirzet, whose diary you quote from or you

18     paraphrase, but you mostly quote from in your book?

19        A.   Only partially did he confirm what was written in

20     Kozarski Vjesnik.  However, he told me that there were a total of some 60

21     men, those desperate men from Prijedor, in those groups.  They had a few

22     rifles, but most of them carried only pistols, and they tried to enter

23     Prijedor in order to see what could be done there.

24        Q.   But they did enter Prijedor, they came as far as the red

25     high-rise buildings, they almost took the radio building.

Page 19591

 1        A.   Well, it was just a trick to allow them to enter as deep as

 2     possible into Prijedor.  The military was already at a stand-by, the

 3     elite unit under the command of Zoran Karlica.  However, Mr. Karadzic,

 4     that was a false attack, as you call it, and I call it a liberation --

 5     the liberation of Prijedor, but there are a lot of controversies about

 6     that attack or that liberation attempt.  When I collected material with

 7     this regard, I came by a number of documents, a large number of

 8     documents, that proved that that attack had been agreed, had been staged,

 9     in order to gain a pretext for the ethnic cleansing of the very nucleus

10     of the town of Prijedor.

11        Q.   Are you saying that this was agreed by the Serbs and the

12     Green Berets and their leader, Slavko Ecimovic; is that correct?

13        A.   No, it's not correct.  Again you're pulling things out of their

14     context.  Those were no Green Berets at all.  They called themselves lads

15     from Kurevo.  They did not belong to any political party.  They did not

16     belong to any political option, either.

17        Q.   Did you not write in your book that when the Serbs arrived in

18     Kozarac to negotiate, that they were encircled, surrounded by the

19     Green Berets?

20        A.   Mr. Karadzic, that was on the very eve of the ethnic cleansing of

21     Kozarac, and you said it yourself that on the 22nd May,

22     Bosnia-Herzegovina was admitted as a member of the United Nations, and

23     the official symbol of the internationally recognised Bosnia-Herzegovina

24     were lilies, and those people in Kozarac had every right to wear the

25     insignia, the symbols of the state that they belonged to.

Page 19592

 1        Q.   On the Green Berets?

 2        A.   On the Green Berets, they -- and on the Blue Berets, they sported

 3     the symbol of lily which was the official symbol of the officially

 4     recognised state of Bosnia and Herzegovina.

 5        Q.   And when it comes to that internationally recognised symbol, you

 6     mention the Green Berets in your book but not the Blue Berets.  So was

 7     that officially recognised symbol accepted by Croats and Serbs?

 8        A.   I don't know.  I'm just telling you what the people of Kozarac

 9     accepted as their symbol and in Kozarac there were no Serbs or Croats.

10     97 per cent of the population were Muslims.  There was just an

11     insignificant number of Serbs, and you know that in Trnopolje there were

12     some national minorities, the Czechs, Italians, and others.

13        Q.   Is it true that in your book, you convey parts of Mirzet's diary

14     which confirm that those terrorists or fighters, if we can put it that

15     way, those who wanted to liberate Prijedor, that they got mixed up with

16     the civilian population in Prijedor?  You say that in your book on page

17     128, that they got mixed up with the people, some took to the woods, and

18     some got mixed up with the people in town; is that correct?

19        A.   No.  That's not correct.  I would like to see that page.  I never

20     wrote that.  The general resistance put up by the group that attempted to

21     liberate Prijedor was crushed within no more than two hours.  Most of the

22     group were arrested.  Eighteen people from that group were killed.  And

23     only a small number managed to swim across the Sana river and they fled

24     somewhere in the vicinity of Prijedor.

25        Q.   Could you explain to all the participants in these proceedings

Page 19593

 1     how was all that staged?  Why did you not write that in the book?  You

 2     were praising Slavko Ecimovic and the liberators of Prijedor.  Why do you

 3     not write about the attack being staged and actually arranged between the

 4     Serbs and the Muslims?  We have to make breaks between questions and

 5     answers, so I apologise to the interpreters.

 6        A.   Mr. Karadzic, I wanted to praise those lads when I was writing

 7     the book because they had attempted to save the honour, save the face of

 8     Muslims and Croats in Prijedor.  Their only wish was to show to the Serbs

 9     that Prijedor belonged to the others as well.  Slavko Ecimovic, engineer

10     Slavko Ecimovic, was captured alive and killed, but his entire family was

11     also killed in retaliation, his father, his mother.

12        Q.   We will come to that.  You didn't see that.  You can't talk about

13     that.  But tell me this:  You say that you praised them in the book

14     knowing that they participated in a staged attack against Prijedor, that

15     they did a favour to the Serbs by having attacked Prijedor, or are you

16     saying that what you wrote in your book is not true?  What is it?

17        A.   No, Mr. Karadzic.  Again you're pulling things out of the

18     context.  I did not describe that attack myself.  That attack was

19     described by Rade Mutic, Zelko Kesmucic [phoen] in Kozarski Vjesnik.

20     I only conveyed that story.

21        Q.   Well, let's look how you conveyed it.  On page 129, you

22     describe --  so you say you carry Mirzet's words from his diary.  And he

23     says, "There was a plan for us to organise ourselves, and when the

24     conditions were put in place, we would threaten the Serbs that had

25     occupied the city."  And then you say, "The first group for the area of

Page 19594

 1     Ljubija headed by Bakir Mualjagic [phoen]; the second group will attack

 2     Zegari.  Slavkovic Muco [phoen] headed the third group."  And that's on

 3     page 129 of the book, "The third group will attack the territory of

 4     Hasrahanovic [phoen], Hambarine, Biscani --"

 5             THE INTERPRETER:  The Interpreter's note:  We do not have the

 6     text in front of us.

 7             JUDGE KWON:  Just -- just simply impossible to follow on the part

 8     of the Judges as well.

 9             THE ACCUSED: [Interpretation] I apologise.  Well, I am in panic

10     because of the time.  This witness has testified to a great extent and he

11     has provided a lot of generalised statements.  The Defence has to reduce

12     his testimony to the mere and bare facts.  That's why I need more time.

13             MR. KARADZIC: [Interpretation]

14        Q.   On page 129 of your book, you describe at least four groups that

15     attacked Prijedor from at least four different directions.

16             JUDGE KWON:  Do we have that book in our e-court, Mr. Robinson?

17             MR. ROBINSON:  I don't know, Mr. President.

18             JUDGE KWON:  Has it been notified to the parties, to the

19     Prosecution?  In my list of documents to be used with this witness, it is

20     not noted.

21             MS. EDGERTON:  No, it hasn't been.

22             THE ACCUSED: [Interpretation] This is a book, almost 300 pages

23     long.  It hasn't been translated.  I take the opportunity of the

24     witness's presence here for him to be able to either confirm or deny.

25             JUDGE KWON:  One further question for Mr. Robinson is that the

Page 19595

 1     line of questioning in relation to this book is to test the credibility

 2     of the witness, or -- I'm asking this because it is not the book that was

 3     admitted as evidence in this case.  Yes, Mr. Robinson?

 4             MR. ROBINSON:  Yes, I'm going to defer this to Dr. Karadzic

 5     because he has a better idea at what he's aiming at than I do.

 6             JUDGE KWON:  Yes, Mr. Karadzic, you have been spending more than

 7     two hours just on this book which is not evidence in this case.  Yes,

 8     Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] However, the witness's testimony is

10     evidence.  He testified in the Stakic case, and what he said there

11     differs from what he has written in the book, when he could do it at his

12     own pace.  The book is relevant because it proves that there was an

13     attack, that he knew about it, and it is contrary to what he testified so

14     far, and I'm also testing his credibility.  You've seen the attitude of

15     Muslims and Croats who wanted to go on living with the Serbs.  You saw

16     the attitude towards me, he calls me a werewolf.  This is all relevant

17     because he is the author of the book.  We have the author in front of us

18     and he confirms everything knowing that I have the book in front of me.

19     Maybe I can provide him with a copy.  I can print -- give him a print-out

20     of the book, but he should know it by heart.  He should know what he

21     wrote in his book.

22             JUDGE KWON:  I take it Prosecution has been provided with a copy

23     of the book at least.

24             MS. EDGERTON:  The book was originally within our files, so yes.

25             JUDGE KWON:  Thank you.

Page 19596

 1             JUDGE MORRISON:  Dr. Karadzic, I see what you say, but you could

 2     achieve the same object by choosing - I pluck a figure from the air -

 3     half a dozen of the best points as illustrative.  You really don't have

 4     to go through the whole book.

 5             THE ACCUSED: [Interpretation] Thank you, your Excellency.  I

 6     believe this shows my inexperience.  I'm much worried about the things

 7     that I'd fail to touch upon and shed some light.  In my view, I did

 8     enough to show, expose the nature of this evidence, although I'm not

 9     convinced the Chamber shares my view.

10             MR. KARADZIC: [Interpretation]

11        Q.   Do you remember having described these four groups at page 129?

12        A.   Mr. Karadzic, this was carried from the Kozarski Vjesnik.  The

13     two men involved were well acquainted with the investigations following

14     the failed attempt.  They described the events, including the groups.  It

15     was for the first time that I learned of the existence of those four

16     groups at that point in time.

17        Q.   Did you quote Mirzet and not Rade Mutic?

18        A.   Yes.  When I was freed in 1993, I met Mirzet in Zagreb.  I knew

19     him well.  We discussed those events in Prijedor between the 30th of May

20     and the 1st of June.  He shed some light on these events, and he informed

21     me that one of them was instructed by someone in the Prijedor barracks,

22     and he took others along, claiming that they should liberate Prijedor and

23     that they would be awaited by 500 armed citizens who would welcome them.

24     Only a few days later before, the Serb TV had some footage on their news

25     of Muslim citizens from Puharska and Biscani, handed over their weapons

Page 19597

 1     voluntarily in the Prijedor barracks.

 2        Q.   So indeed, at page 129, you quote Mirzet, and you even say Mirzet

 3     went on to say, et cetera.

 4        A.   Well, I don't know my book by heart, but you are paraphrasing

 5     many of the things.  You are not quoting them.

 6        Q.   At page 132, do you also mention some information received from

 7     him, that they used a hand-held rocket launcher to set fire to the

 8     Prijedor hotel?

 9        A.   The group that entered Prijedor had only two operational

10     hand-held rocket launchers.  They had another two which malfunctioned and

11     they had bought them from Serb middle men.  They used one to target a

12     hotel in Prijedor which housed an elite unit from the Knin Krajina which

13     assisted the process of the takeover of Prijedor.

14        Q.   And you say that those people were jumping out the windows when

15     the hotel caught fire?

16        A.   Well, that's what Mirzet said.  But no one was killed.

17        Q.   Could we please have 1D04347 in e-court?  Your Excellencies,

18     perhaps I can explain why I'm following the book.  It goes in parallel

19     with this man's testimony.  It addresses the same topics but in a

20     different way.  That is why I'm interested in the book.

21             Mr. Sivac, do you see that this comes from the Prijedor security

22     service on the 22nd June, 1992?  It is a criminal report submitted to the

23     Prosecutor, the document specifies those involved.  Could we please go to

24     the next page in English?  We can even leaf through the document and

25     there is a total of 28 -- no, in total, there are 172; whereas, you said

Page 19598

 1     there were 20 to 30.  So 172 persons who were identified and reported.

 2        A.   What was your question, Mr. Karadzic?

 3        Q.   Do you stand by what you said, which is that Prijedor was

 4     attacked by a group of 20 to 30 rather than the men contained in this

 5     document?

 6        A.   I said already that together with Slavko Ecimovic there were some

 7     20.  With Kemo Divjak, there were another 20.  They were organised in

 8     groups, and their goal was to assemble and try to reach the territory of

 9     Bosnian Krajina, which was controlled by the Army of Bosnia-Herzegovina.

10     They meant to go as far as Bihac and Bosanska Krupa.  The truth is that

11     there were around 80 of them.  This figure of yours is incorrect.  It is

12     a fabrication.  If you wish, I can discuss the names of the people

13     I recognise on the list.  This indictment was issued on the 22nd June,

14     1992.  By that time, Nedzad Babic had been killed.  Asmir Muhic had been

15     killed by that time.

16        Q.   We can't take your word for it, witness.  If you have no proof.

17             Could we please have page 7 in Serbian and 13 in English?  You

18     say that no Serbs were killed?

19        A.   During that operation in Prijedor there were some killed Serbs.

20     I didn't say anything otherwise.  I accept your argument that some Serbs

21     were killed in the conflict.  What I did say was that during the incident

22     at the hotel, no one was killed, as far as I remember.

23        Q.   Have a look at the statement of reasons.  Following the carrying

24     out of all necessary preparations and assessments of the situation, on

25     30th of May 1992, the -- those mentioned in the document carried out an

Page 19599

 1     armed attack by having reached Prijedor together and then broke into four

 2     groups:  The first group was to target the Municipal Assembly building

 3     and the public security stations; the second was to go to the hotel and

 4     Radio Prijedor; the third was to capture the area around the flyover and

 5     they were supposed to link up with another group at that location.  I

 6     don't think this is the right page in English.  We have it now.  So four

 7     groups are being mentioned.  To conclude the paragraph, it says:

 8             "By which they would prevent the army leaving the garrison to

 9     defend the town."

10             It is also stated that they killed 18 and wounded 15 people; is

11     that correct?

12        A.   No.  Far fewer were killed.  The Serb media said that there were

13     18 people killed and that there may have been around 15 wounded.

14        Q.   Very well.  The media is one thing.  But this is a document, a

15     criminal report to the Prosecutor, do you think the police would dare

16     send incorrect information to the Prosecution?

17        A.   I don't know if they dared or not.  In any case, I disagree with

18     it.  This list includes people who were not part of the group at all or

19     the groups.  I know them personally.

20        Q.   Thank you.  Can you explain, then, how the Serbs staged the whole

21     thing to include the 11 killed Serbs?  How did they manage to organise

22     four Muslim groups and get them to attack Prijedor and have Serbs killed?

23        A.   I believe the Serbs who were killed were collateral damage.

24     I seem to have read a document here in which Simo Drljaca asked that the

25     snipers, the sharp shooters, be withdrawn from key positions in order not

Page 19600

 1     to prevent the entry of those groups to Prijedor.  I'm convinced that the

 2     attack or the attempted liberation was staged.  Many of the people on

 3     this list did not take part in the attack on Prijedor.  These people were

 4     simply added on to the list in order to show that there were many.

 5        Q.   Could we please go to the previous page to see the person number

 6     172?  The page before.  There we can see that the list includes 172

 7     participants.

 8        A.   Mr. Karadzic, I'd love to see the whole list.

 9        Q.   Well, go ahead.  Do you know these people?

10        A.   Well, I only see people from 156 to 172.

11        Q.   We'll have a look at that.  We can only have one page at a time.

12        A.   Let's go to the beginning of the list, please.

13             MS. EDGERTON:  Maybe I can help.  I think we can probably print

14     that document up and then it could be handed to the witness, given that

15     he's asked to have a look at the list of names.

16             JUDGE KWON:  Yes.  It's only 13 pages, the document.

17             THE ACCUSED: [Interpretation] It is even less in the Serbian.

18             JUDGE KWON:  I meant the B/C/S version.

19             MR. KARADZIC:  [Interpretation]

20        Q.   You may be right in one thing, and that is that the numbers in

21     the Serbian are different because people were included there.  As you say

22     in your book, did your nephew choose to keep his arms and join the

23     fighting?

24        A.   No, it was a relative of mine.  His name was Adnan.  He was part

25     of the police reserve force.  And he was close friends with

Page 19601

 1     Slavko Ecimovic.

 2        Q.   They were each other's witnesses at weddings, at their weddings?

 3        A.   Yes, and classmates too.

 4        Q.   Slavko Ecimovic, to remind the Chamber, is the one who led the

 5     operation in Prijedor?

 6        A.   Yes, he was an engineer.

 7        Q.   Is it correct that in the Muslim villages surrounding Prijedor,

 8     there were units in each of the villages and that they had dugouts,

 9     radios.  In any case, is it true that they had dugouts and that they

10     stayed there for a while?

11        A.   That is not correct.  This is again some kind of virtual

12     information you only seem to have.

13        Q.   Did you touch upon that in your book when you said that they had

14     powerful radio equipment?

15        A.   These were Serb rumours in order to accuse Muslims of something

16     that they were not guilty of.

17        Q.   How far was the front line from Prijedor, any front line, say

18     towards the corridor or to Bihac?

19        A.   There was no front line in Prijedor.  There were no clashes.

20     There was no war.  As for any other front lines, well, it all depends on

21     the time period.  Do you mean in 1992?

22        Q.   Yes, the 30th of May.  This is what you wrote about.  Was the

23     front line hundreds of kilometres away at that point in time?

24        A.   Well, yes.

25        Q.   Why did the Serbs have fortifications around their houses in

Page 19602

 1     Prijedor as well as sandbags?  This is something you mentioned as well in

 2     your book.

 3        A.   Because the Serbs in Prijedor were constantly being explained by

 4     Radio Prijedor that next to Prijedor, or in its vicinity, there were

 5     several thousand Mujahedin and a number of foreign mercenaries.  They

 6     were also told that there were some sort of elite units surrounding

 7     Prijedor ready to carry out massacres in and around Prijedor.

 8        Q.   But in depth, Mr. Sivac, hundreds of kilometres in the back of

 9     the Prijedor Brigade, weren't there such groups indeed killing farmers at

10     work, who had dugouts, and who communicated among each other?

11        A.   There were no paramilitary Muslim or Croatian units in the area

12     of Prijedor.

13        Q.   Very well.  We'll discuss it further later down the road.

14             Was the HOS or the HVO present in Prijedor?

15        A.   No.

16        Q.   What if I told you that we have Croatian intercepts, they tapped

17     in on our conversations, and they explain in detail the battle in Kozarac

18     and Prijedor, they discuss 3.000 captured Muslim soldiers?  What would

19     you say to that?

20        A.   Well, that's what you say.  I have never heard of any HOS or HVO

21     members in Prijedor.  Another fabrication, it seems, in order to justify

22     what had been done in the municipality of Prijedor.

23        Q.   May we -- I'd like to tender this document, please, and, witness,

24     please look at the names in the meantime.

25        A.   Well, I know that some of these people were killed during the

Page 19603

 1     attempted liberation of Prijedor.  Some were taken to camps and that

 2     would be it.  On the 30th of May, the group was neutralised in less than

 3     two hours.  Following that, there was a systematic process of destruction

 4     in Prijedor.  The entry of Slavko's group was an excuse to ethnically

 5     cleanse the town of Prijedor.

 6        Q.   You discuss ethnic cleansing, whereas we had Muslims from the

 7     nearby villages streaming into Prijedor.  How do you reconcile these two

 8     things?

 9        A.   You're twisting things again.  When the ethnic cleansing began in

10     Kozarac, only a small number of Kozarac people arrived in Prijedor.  And

11     they were accommodated with their friends in Puharska.  After a short

12     while, an ultimatum was issued by the authorities that even those people

13     had to be evacuated to Trnopolje immediately.  In the area of Prijedor,

14     when the ethnic cleansing began --

15        Q.   Do not go into that.  How do you explain what you're saying?

16     What is ethnic cleansing?

17        A.   Ethnic cleansing is this:  When one group uses pressure, force,

18     police, in order to destroy two other ethnic groups, people of other

19     religious beliefs, of other cultures, who prayed to different gods.

20        Q.   Do you say in your book that people left Prijedor even before the

21     war and after the crisis, that they sought ways to leave, to be put on

22     the list to be sold a plane ticket, that they were very determined to do

23     so although their families were against it and they tried to convince

24     them not to leave; is that correct?

25        A.   A number of inhabitants of Prijedor who could no longer bear the

Page 19604

 1     situation --

 2        Q.   I'm not asking for any explanations.  I'm asking you this:  On

 3     page 221 of your book, did you say that Lejla, Alma and Sena from your

 4     brother's family wanted to leave?  Their friends, relatives, and

 5     neighbours wanted to dissuade them but they were determined?  Did you not

 6     write throughout the entire book that everybody was looking to purchase a

 7     plane ticket to Belgrade and from there onwards to Europe?

 8        A.   You're again distorting the facts, and again you're putting me

 9     several questions in one.  First of all, there were those who wanted to

10     purchase plane tickets to Belgrade to travel further afield into the

11     world.  That was before the ethnic cleansing.

12        Q.   Please do not throw terms at me.  I'm asking you about events and

13     not about ethnic cleansing.  Do not give me any qualifications.  I'm not

14     going to allow you the same thing that was allowed to you in the Stakic

15     case.  You have to be very precise.  Please leave ethnic cleansing aside.

16             JUDGE KWON:  You have to be precise first in putting your

17     question, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] I'm asking for the witness to

19     refrain from qualifications.  It is up to the Trial Chamber to put

20     qualifications to different events.

21             JUDGE KWON:  In order to put such a question, you have to put the

22     book to the witness.

23             MR. KARADZIC: [Interpretation]

24        Q.   Did you write this?  They tried to dissuade them but they were

25     determined and there were many such people who were determined to leave

Page 19605

 1     Prijedor?

 2        A.   Mr. Karadzic, there are two questions in one.  What you asked me

 3     about now happened in September 1992.  That's why I would like you to

 4     give me the date and the place where those things happened.  In September

 5     1992, when the convoys of Bosniaks started leaving Prijedor, Alma and

 6     Sena who were members of my cousin Omer's family, they knew that Omer and

 7     Adnan had been killed in Omarska.  There were two other members of their

 8     family.  And that's when they decided to join a convoy and to head for

 9     central Bosnia and the territory under the control of the BiH Army.

10             And let me now go back to your first question.  Your first

11     question was whether people left Prijedor by plane.  No, they didn't,

12     because Prijedor does not have an airport.  People from Prijedor would go

13     to Banja Luka first and those departures by plane happened before April.

14     They took place in March and April 1992.

15        Q.   When the conflicts broke out, did people still want to leave?

16        A.   When the conflicts broke out, nobody could move out from

17     Prijedor.

18        Q.   Unless there was an agreement to arrange a convoy, right?

19        A.   Only later, towards the end of August.  The first people started

20     to move out by way of convoys organised by the Red Cross from Prijedor.

21        Q.   Thank you.  In your testimony, but not in your book, you claim

22     that the private property was taken over and that the ownership titles

23     were changed.  Give me an example.  Can you illustrate the change of the

24     ownership title of property in an illegal way?  Give me an example of a

25     sale of property because that was also forbidden during the war, right?

Page 19606

 1        A.   Well, that was you paying lip service to things.  However, in

 2     Prijedor, strange things happened.  A large amount of private assets were

 3     misappropriated by the Serbs, because the Court and the services that

 4     were in charge of that did a very lackluster job.  Fortunately enough,

 5     after the Dayton Accords were signed, and after people started returning

 6     to Prijedor, many managed to reinstate their assets that had been

 7     illegally taken away from them.  However, there are still people, even

 8     today, in Prijedor, who have not managed to reinstate their personal

 9     property.

10        Q.   If a refugee is found in a Muslim part of Bosnia, I am sure that

11     they had difficulties.  But give me just one example of somebody's

12     property being illegally misappropriated.  Just one example?

13        A.   One example is the example of my colleague.  I don't know if I'm

14     allowed to mention his name.  He was one of the richest people in

15     Prijedor.

16        Q.   It's up to you whether you're allowed to mention the name or not.

17     What was taken from him, and who did it?

18        A.   He was a very rich citizen of Prijedor and his property was

19     misappropriated by his former colleague.  He was the owner of a company,

20     and he and that other person simply registered the company in his name.

21     After the year 1995, when the original owner returned to Prijedor for the

22     first time, after the war, he had to find witnesses, and he had to resort

23     to certain legal institutions in order to prove that that was his

24     property and not the property of the latter person who wanted to

25     misappropriate his assets.

Page 19607

 1        Q.   Are you saying that somebody misappropriated his assets?

 2        A.   Yes, yes.  And while my colleague was in a camp, and while he was

 3     being transferred from the camp into one of the third countries, a Serb

 4     colleague in the Prijedor court falsified his documents and almost

 5     misappropriated his assets.

 6        Q.   Let's not talk about individuals falsifying documents.  I want to

 7     know what the state was doing at the time.  Was it the state that

 8     systematically misappropriated other people's property?

 9        A.   You asked me for one example and I gave you one example.  Please

10     don't be cross with me.  The state was also systematically engaged in the

11     misappropriation of assets.  For my family, for example, for my family to

12     leave Prijedor, we had to sign 15 different documents, one of them was to

13     the effect that we are relinquishing the right on all of our immovable

14     property, and that's when we were able to get the final certificate to be

15     able to move out from Prijedor.

16        Q.   What about the other 14 documents?

17        A.   Those were documents as a means to take money from the other

18     Croats and Bosniaks who wanted to leave Prijedor.  You had to provide 14

19     documents in order to get -- obtain the final certificate allowing you to

20     leave.  And those documents were to prove that you paid all your dues,

21     all your bills, all your electricity, water, that your car was deposited

22     with the SUP as war booty.  I really can't remember all of those

23     documents.  It had to be furnished, they had to be collected, and taken

24     to the military department where you would then obtain your final

25     certificate to the effect that you had paid all your dues and as a result

Page 19608

 1     of that you are allowed to move out from the Republika Srpska.  My wife

 2     had to obtain all those certificates from the military department for our

 3     children, for my son who was 6 and my daughter who was 11, at the moment

 4     when we decided to move out.

 5        Q.   Thank you.  That means that you had to surmount many obstacles

 6     before you were able to move out?

 7        A.   Well, those obstacles did exist but they were erected

 8     deliberately in order to ferret out whatever little money we had left

 9     because all those documents you had to pay for.  Let me give you a

10     trivial example.  For somebody to cancel their electricity account, they

11     had to pay their bills in advance for a year, a year in advance.  And

12     even people whose houses had been burned down or destroyed had to do the

13     same thing.  Why would anybody want to pay electricity a year in advance

14     for the house that doesn't even exist?

15        Q.   In any case, there were many obstacles and it was very difficult

16     to obtain all those documents?

17        A.   Not because of the political situation.  Because of the money

18     that you had to pay.  They wanted to ferret out every little -- every

19     last cent that we had.

20        Q.   Could you please send the Prosecutor's office all those documents

21     and certificates that you have just described for us?

22        A.   Mr. Karadzic, what I'm saying is this:  In order to obtain your

23     final certificate allowing you to move out, you had to furnish all of

24     those documents.  I still keep that certificate for my family, for my 6

25     year old son and 11 year old daughter, issued by the military department.

Page 19609

 1     What did the military department have to do with my minor children?  But

 2     I still keep those certificates.

 3        Q.   Thank you.  I'm talking about the documents, the 14 documents,

 4     not about the final certificate, but the 14 documents that you had to

 5     collect and can you provide us with those, and can you tell us whether

 6     your property was misappropriated or not?  I'm talking about movable

 7     property?

 8        A.   Mr. Karadzic, all the documents had to be handed over to the

 9     military department.  Maybe you should ask your associates to look for

10     those documents that are probably filed in the archives of the military

11     department.  What we ended up with was just one final certificate

12     allowing us to move out.

13        Q.   How big is the public security station in Prijedor?  What is its

14     foot plan?

15        A.   It has two wings, two floors on one side, three floors on the

16     other side.  There is an annex that was later added on.  What is the time

17     frame?

18        Q.   The time frame is May 1992.

19        A.   I did not hear the question.

20        Q.   In May 1992, how big was the police station?

21        A.   I didn't measure it.  It was a very typical building of the kind

22     that was used by the police stations everywhere in Prijedor, Brcko, and

23     elsewhere as far as I can remember.

24        Q.   And how big was the Detention Unit?  How many people could be

25     detained at any one time?

Page 19610

 1        A.   At any one time the Detention Unit could hold a dozen people,

 2     between 10 and 15.  It was a small room because the Prijedor security

 3     service did not have a prison.  It was just a Detention Unit from which

 4     after the sentencing, before the misdemeanour court, the detainees were

 5     taken to the prison in Banja Luka.  There was a prison in Banja Luka, and

 6     that's where people who were detained in Prijedor were taken to.

 7        Q.   Thank you.  On the 10th of June, you were erroneously taken into

 8     custody because you shared a similar name with somebody else.  They were

 9     looking for Nusret but they brought you in, and then you were returned

10     home as soon as the mistake was spotted?

11        A.   Yes.

12        Q.   And then you were taken into custody again on 20th of June.  You

13     spoke about that and you wrote about that.  Do you remember that people

14     were brought in gradually?  For example, one man is brought in and then

15     somebody else, after a certain time, from the same circle?

16        A.   That's correct.

17        Q.   Do you remember that you were told that you would be in

18     Keraterm -- or rather in Omarska for only a short period of time, that

19     you would be interviewed, and that then that you would then be sent

20     either home or somewhere else or to Manjaca?

21        A.   Nobody ever told me any such thing.

22        Q.   And were you told when you were first brought in that you would

23     not stay long?

24        A.   Well, no.  Who could have told us that?

25        Q.   I'll find it and I will tell you who told you that.  Or who was

Page 19611

 1     in a position to tell you that.  And you were brought to Keraterm only

 2     once, right?

 3        A.   Yes, only once.

 4        Q.   In Omarska, who was it who interviewed prisoners in Omarska?

 5        A.   There were interviewers who were known to me.  They were

 6     inspectors of the security service in Prijedor, and there were also

 7     interviewers who had worked in the state security detachment in Prijedor.

 8     There were also people from the business life who were reservists in the

 9     security service, and there were also two inspectors who arrived directly

10     from the State Security Service in Banja Luka.  They were the ones who

11     interrogated us.

12        Q.   Thank you.

13             JUDGE KWON:  I note the time.  I propose to adjourn for the day.

14             Mr. Sivac, I have to ask you whether, in relation to the

15     scheduling matter, when conducting the proceedings of this size and case,

16     there are many things arising during the course of the hearing.  Due to

17     the situations, we are not able to sit tomorrow, and on Friday, there is

18     a witness we have to hear via videolink which is fixed for that day, so

19     therefore I'm inquiring of you whether it would cause you a lot of

20     problem whether you have to continue the remaining evidence Monday -- on

21     Monday next week?

22             THE WITNESS: [Interpretation] Your question is somewhat

23     surprising, I must say.  I've been here for a long time but I'm in your

24     hands, Your Honours.  I'll do whatever you say.

25             JUDGE KWON:  Well, we appreciate it very much.  But Mr. Tieger,

Page 19612

 1     do you have any observation to make?

 2             MR. TIEGER:  No, Your Honour.  I think we exchanged e-mails with

 3     the court officer and the Defence was involved too, and we offered our

 4     best observations about the circumstances.  Of course, we remain

 5     optimistic, perhaps unduly so, that we can complete the testimony of both

 6     on Friday, but I certainly understand the possibility of the need to

 7     continue on Monday and understand why the Court raised the issue.  Other

 8     than that, I -- it appears to me that the parties are in agreement about

 9     tomorrow and about the videolink priority first thing on Friday.

10             JUDGE KWON:  If the legal officer could approach the Bench.

11                           [Trial chamber and legal officer confer]

12             MR. KARADZIC:  May I tender this, Excellency, the last document

13     that was on?

14             JUDGE KWON:  Ms. Edgerton?  SJB Prijedor document?

15             MR. TIEGER:  For what it's worth, Mr. President, I imagine it's

16     been conveyed to you, I suggested a couple of potential efficiencies that

17     might eliminate a run-over into Monday.  Again that depends on a variety

18     of factors, but to the extent the Court's in a position to implement

19     those, we would encourage that.

20             JUDGE KWON:  I asked the Chamber's legal officer to liaise with

21     the witness via Victims and Witness Section to sort it out in the best

22     interests of the witness, but what is certain is that we start off with

23     the videolink testimony on Friday.

24             And do you have any objection to the admission of that document?

25             MS. EDGERTON:  No.

Page 19613

 1             JUDGE KWON:  Yes.  That will be admitted.

 2             MR. ROBINSON:  Mr. President, before --

 3             JUDGE KWON:  First we will give the number.

 4             THE REGISTRAR:  Your Honours, 65 ter 1D4347 shall be given

 5     Exhibit D1741, thank you.

 6             JUDGE KWON:  Yes, Mr. Robinson?

 7             MR. ROBINSON:  Yes, Mr. President, before we rise I just wanted

 8     to first of all thank the witness for his accommodation of our schedule,

 9     and secondly to apologise to the Prosecution and the Chamber for not

10     having notified his book because that definitely should have been done.

11     Thank you.

12             JUDGE KWON:  Thank you.

13             MR. TIEGER:  Mr. President, I would join in that.  I think all of

14     us share the appreciation for the witness's flexibility and willingness

15     to accommodate.

16             JUDGE KWON:  Mr. Sivac, the Chamber does really appreciate your

17     understanding, kind understanding.

18             The hearing is now adjourned.

19                           --- Whereupon the hearing adjourned at 7.02 p.m.,

20                           to be reconvened on Friday, the 30th day of

21                           September, 2011, at 2.15 p.m.