Tribunal Criminal Tribunal for the Former Yugoslavia

Page 25018

 1                           Wednesday, 22 February 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.03 a.m.

 6             JUDGE KWON:  Good morning, everyone.  Good morning, Mr. Lesic.

 7             THE WITNESS:  Good morning, sir.

 8             JUDGE KWON:  Today we are sitting pursuant to Rule 15 bis,

 9     Judge Morrison away due to his urgent personal matters.

10             Yes, Ms. West.  Please continue.  Good morning to you.

11             MS. WEST:  Good morning, Mr. President.  May I be heard on one

12     quick housekeeping matter from yesterday.

13             JUDGE KWON:  Yes, please.

14             MS. WEST:  You will remember that Mr. Mitchell was discussing

15     with the witness 65 ter 7981.  He inadvertently forgot to tender it to

16     the Court.  You will remember this was the document regarding

17     Mr. Karadzic's orders regarding the journalists and how they were to

18     travel.  I can be -- I can be -- I can speak on its admissibility if

19     there is any objection.

20             JUDGE KWON:  That may be similarly treated as the exhibit at that

21     we admitted as P4407, but can I hear from you, Mr. Robinson.

22             MR. ROBINSON:  Yes, Mr. President.  We have the same objection

23     that the witness didn't confirm anything about the document, but other

24     than that it's the same issue.

25                           [Trial Chamber confers]

Page 25019

 1             JUDGE KWON:  We'll admit it for the same reason.  That will be

 2     admitted as Exhibit P4408.

 3             THE REGISTRAR:  Your Honours, that will be Exhibit P4439.

 4             JUDGE KWON:  Thank you.  Yes, Ms. West.

 5             MS. WEST:  Thank you.

 6                           WITNESS:  MILAN LESIC [Resumed]

 7                           Examination by Ms. West:  [Continued]

 8        Q.   Good morning, Mr. Lesic.

 9        A.   Good morning.

10        Q.   Now, yesterday when we had stopped you had mentioned that you

11     travelled to the region between 1992 and 1995 about ten times.  Do you

12     remember talking about that?

13        A.   Yes.

14        Q.   Okay.  Let's talk a little bit more about that.  Now, in general

15     in regard to those trips, how often did you meet with General Mladic?

16        A.   I would presume each time I went there I met with General Mladic.

17        Q.   And how often would you meet with Mr. Karadzic?

18        A.   I would say half of that time, not every time.

19        Q.   Okay.  Now, at one point in the course of those trips did

20     General Mladic make a request of you regarding a video of

21     General Mladic's daughter?

22        A.   Yes, he did.  His daughter passed away, and he asked me could I

23     next time I came back could I provide him a film.  He would like to see

24     it.  So I said, Yes, I will.  So I made a few -- few my trips copies and

25     put all in one film and delivered to him.

Page 25020

 1        Q.   But specifically did he ask for footage of his daughter?

 2        A.   Yes, he did, but I give him more than just the footage of his

 3     daughter.  I give him three or four times that I been there and all those

 4     footages.

 5        Q.   Okay.  Now, yesterday you indicated that when you were

 6     interviewed in August of 2009, you brought video-tapes with you to the

 7     interview.  You brought four with you.  Do you remember talking about

 8     that?

 9        A.   Yes.

10        Q.   Now, when you went to that interview in August of 2009, were you

11     shown a video-tape that was not one of the four that you brought with

12     you?

13        A.   Yes, I was shown, yes.  The one that they -- when they raided

14     Mrs. Mladic house they showed me that video that I brought them

15     originally.

16        Q.   All right.  So, just to be clear, the video that they showed you

17     that you had not brought, did you recognise that video?

18        A.   Yes, I did.

19        Q.   What did you recognise that video to be?

20        A.   I recognised my video and I put together, made over, and I give

21     to General Mladic.

22        Q.   All right.  So, this was the video you gave to Mladic years ago?

23        A.   Yes.

24        Q.   Now, I'm going to show you some footage, and this is footage from

25     that video which is a small part of that video.  It's 65 ter 45349.  This

Page 25021

 1     is July 11th, 1993.

 2             MS. WEST:  There's -- Your Honours, there's a transcript in

 3     e-court as well.  And we're going to show you a short part from minute

 4     26:30 to minute 27:50, and if I can correct myself, 65 ter 45349A.

 5        Q.   Do you see a video in front of you?

 6        A.   I will see it will come up.  It hasn't come up yet.

 7        Q.   Okay.

 8        A.   Yes, I see it now.

 9        Q.   Okay.  Now, sir, you've seen this video in the last couple days.

10     Do you remember this meeting?

11        A.   Yes, I do.

12        Q.   What was this meeting?

13        A.   This meeting I happened to be there the day before that they came

14     from the Trnovo when they sort of free the Trnovo took over was -- and

15     that was discussion about it.

16        Q.   All right.  And in the screen we see in front of us at 26 minutes

17     33 seconds, can you identify the people there?  The person on the left,

18     who is that?

19        A.   That is Dr. Karadzic.

20        Q.   And then?

21        A.   Myself and General Mladic, and I would believe was Koljevic in

22     the back.  It's hard to see it.

23        Q.   All right.  Now, this is -- we're going to play it this is video.

24     Is -- was the video camera yours?

25        A.   Yes, it was.

Page 25022

 1        Q.   And who was operating it at the time?

 2        A.   My brother-in-law that came with me from Belgrade.

 3        Q.   And on the occasions that you used your video camera, when you

 4     were actually seen in the photo, was it typical that you gave your camera

 5     to someone else to operate?

 6        A.   Yes, that's correct.

 7        Q.   Okay.  So now we'll play.

 8                           [Video-clip played]

 9             MS. WEST:  Mr. President, if the translators could translate

10     this.  I know there is a transcript that exists, but it might be easier

11     if they simultaneously translate.

12             THE INTERPRETER:  Interpreter's note:  The soundtrack is not very

13     good.

14             JUDGE KWON:  Were they given the transcript?

15             MS. WEST:  They were.  Maybe if we could wait a moment.

16             JUDGE KWON:  I see the -- I'm seeing the transcript in the

17     e-court.  Why do you have a redaction there?

18             MS. WEST:  Mr. President, that part's not in this clip.  That's

19     the reason.

20             JUDGE KWON:  So what we are going to hearing is Mr. Karadzic's

21     words?

22             MS. WEST:  First we're going to hear from Mr. Mladic, then we're

23     going to hear from Mr. Karadzic.

24             JUDGE KWON:  Could you give the 65 ter number again.

25             MS. WEST:  Yes, 65 ter 45349A.

Page 25023

 1             JUDGE KWON:  But in the transcript Mladic's words do not appear.

 2             MS. WEST:  Your Honour, I'm sorry for this confusion.  The part

 3     we'll focus on is Mr. Karadzic's words.  Mr. Mladic will speak first and

 4     then he will speak.  So if I can just play it through Mladic, we don't

 5     need an interpretation, and then Mr. Karadzic's speech, if that could be

 6     interpreted that would be helpful.

 7             JUDGE KWON:  Very well.

 8             MS. WEST:  Thank you very much.

 9                           [Video-clip played]

10             MS. WEST:  All right.  We are at 26:58, and this is the beginning

11     of Mr. Karadzic's speech.  Mr. Lesic, if you can follow along, please.

12                           [Video-clip played]

13             THE INTERPRETER:  "[Voiceover] Mr. Karadzic:  Congratulations to

14     General Mladic and all his commanders, generals, colonels for the success

15     and the speed with which they achieved it.  There was a time when we had

16     a very long front line and difficulties with the entire world.  That was

17     about Konjevic Polje, Zepa.  They thought it was an immense city.  It was

18     a village with 3.000 inhabitants.  However, they didn't bat an eyelid for

19     Trnovo and there was not a campaign to save Trnovo and to proclaim it a

20     protected area, and that goes to the credit of this army which is as fast

21     as wind.  I notice in a Japanese TV series ..."

22             MS. WEST:  We're going to stop right there.

23        Q.   Mr. Lesic, you heard that speech; correct?

24        A.   Yes, I did.

25        Q.   Okay.  And I know that you've heard it before as well.  And

Page 25024

 1     Mr. Karadzic's -- can you tell us what event prompted this speech?  What

 2     was the event this dinner was celebrating?

 3        A.   Well job done at Trnovo, and they were so quick and no blinked an

 4     eye.  That was job well done.  President congratulate General Mladic.

 5        Q.   Okay.  And in particular, Mr. Karadzic is talking about the

 6     international community.  He says the entire world knew about -- he

 7     mentions Konjevic Polje and Zepa, and then he goes on to say, "However,

 8     they," the entire world, "didn't bat an eyelid for Trnovo and there was

 9     not a campaign to save Trnovo."

10             Mr. Lesic, was the international coverage, the media coverage, of

11     the events in Trnovo less than the others cities that he had mentioned,

12     Konjevic Polje and Zepa?

13        A.   Yes, definitely it was.  It was said that evening that no one

14     made any comments or anything.  Everything went well, was no any

15     obstructions or any discussions that president heard from anybody.

16        Q.   And he goes on to say that there was not a campaign to save

17     Trnovo and proclaim it a protected area.  When he says that there wasn't

18     a campaign to save it, who did he believe would support the campaign?

19     Who would have been behind that campaign, from your experience and your

20     presence at this meeting?

21             MR. ROBINSON:  Objection, Mr. President.

22             THE WITNESS:  The way I understand it --

23             JUDGE KWON:  Just a second.

24             MR. ROBINSON:  Yes, Mr. President.  I believe this is calling for

25     speculation on the part of the witness.

Page 25025

 1                           [Trial Chamber confers]

 2             JUDGE KWON:  Could you reformulate your question, Ms. West.

 3             MS. WEST:  Yes.

 4        Q.   Sir, when you first came to the area in December of 1992 and you

 5     went to the Assembly session meeting, you specifically gave some money to

 6     media and propaganda, and you talked about this yesterday; right?

 7        A.   Yes, that's correct.

 8        Q.   And so was the issue of international -- the international media

 9     coverage of the area one that was of concern to you?

10        A.   It was concern to all of us.  Like media was always against the

11     Serbs and was never in the middle, and that's what we all in Canada or in

12     Serbian Republic believed.

13        Q.   And had you had discussions about this concern with the

14     leadership in Pale?

15        A.   Yes, I did.  I mentioned to them and what can we do about it.  We

16     had some media from Israel there, but they need sort of funds to be

17     spended travelling and cars and gas and all that to be right time and

18     right places.  So we as a Humanitarian Organisation Republika Srpska from

19     Canada we tried to help as much as we could to sort of change that, but

20     it was not that easy.

21        Q.   And earlier today at page 7, line 9, you said it was said that

22     evening no one made any comments or anything.  Everything went well.

23     There was no obstructions or any discussions that the president heard

24     from anyone.  When you talk about obstructions or discussions the

25     president heard from anyone, with do you mean by that?  Can you tell us a

Page 25026

 1     little bit more?

 2        A.   Well, the UN or Western media didn't make a big outcome that

 3     Trnovo was fallen back to Serbian hands.  That's what -- what we all felt

 4     it, that went nice and easy and quiet.

 5        Q.   And from that dinner that evening, did you understand that

 6     Mr. Karadzic was pleased about that?

 7        A.   Well, we were all pleased.  We were all in that room pleased the

 8     way it went.  That's how I got that impression.  We should be.

 9        Q.   From your discussions with Mr. Karadzic about this issue of the

10     international media, did you understand whether he placed any blame on

11     the media for interfering with the affairs of the war?

12        A.   In my opinion, when I was there visiting and talking to different

13     people like Biljana Plavsic and all of them, we all have some comments

14     about the media position they took, that even though in Canada I recall

15     was long time ago, my boys went to school, 10 and 12 years of age, and

16     the media really played if you're Serb, you sort of -- what the heck you

17     people doing over there, that kind of a thinking was.

18        Q.   Okay.  We're going to turn to 65 ter 32769, and this is --

19             JUDGE KWON:  Yes, Mr. Robinson.

20             MR. ROBINSON:  Yes, Mr. President.  Before we leave this video, I

21     notice that in the Prosecution's summary of this witness's testimony and

22     particularly in the 92 ter summary that I'm looking at, they've indicated

23     that was said -- what was spoken about on this particular clip involved

24     Konjevic Polje and Cerska, but we received interpretation of

25     Konjevic Polje and Zepa.  So I'm wondering which is correct.  What did

Page 25027

 1     Dr. Karadzic refer to?

 2             MS. WEST:  I think if we were to look at the transcript we might

 3     get an answer to that.  I think when we heard the translation perhaps it

 4     was a little bit different.  I did today hear Konjevic Polje and Zepa.  I

 5     understand in the transcript itself it says Cerska as well.  I think

 6     we'll have to go back to the clip.

 7             JUDGE KWON:  Shall we try it now again?

 8             MS. WEST:  Thank you.

 9             JUDGE KWON:  Yes.

10                           [Video-clip played]

11             THE INTERPRETER:  "[Voiceover] Mr. Karadzic:  Congratulations to

12     General Mladic and all his commanders, generals, colonels for the success

13     and the speed with which they achieved it.  There was a time when we had

14     a very long front line and difficulties -- the kinds -- the entire world

15     knew about Cerska, Konjevic Polje, and as for Zepa they thought it was an

16     immense city, but it was a village with 3.000 inhabitants.  However, they

17     didn't bat an eyelid for Trnovo and there was [sic] a campaign to save

18     Trnovo and proclaim it a protected area, and that goes to the credit of

19     this army which is fast as mind.  I noticed in a Japanese ..."

20             MS. WEST:  Mr. President, I tender that video-clip.

21             JUDGE KWON:  We'll admit it.

22             THE REGISTRAR:  As Exhibit P4440, Your Honours.

23             MS. WEST:  We may have 65 ter 32769.

24        Q.   Mr. Lesic, this is an intercept from October 10th, 1994.  And

25     your -- you've looked at this before.  Is this a conversation you

Page 25028

 1     remember?

 2        A.   Yes, I do.

 3        Q.   Okay.  Can you tell us who initiated this phone call?

 4        A.   As I can see it, I believe I called a few times, many times over

 5     there with Ned Krajisnik, and with president of humanitarian

 6     organisation, Ranko Rakanovic, and we had discussion with different

 7     people like General Mladic and his secretary and -- his intelligence,

 8     Petar Salapura.

 9        Q.   And what were the circumstances of the call?  Why did you call?

10        A.   Well, we just want to sort of say hello and see how they doing.

11     All different calls go to different times.  I can't say right now which

12     call.  Was many calls.

13        Q.   Okay.  Fair enough.  We're going to focus particularly on page 3

14     of the English, which is the same as the B/C/S.  It's the top of the

15     page.  And the L is you, the M is Mladic.  I'm going to read this small

16     portion out:

17             "Mr. Lesic:  Well, now it is time to take advantage of this

18     situation, Iraqi and this situation.

19             "Mladic:  I agree.  Is it congested there?

20             "Lesic:  It is congested, all right.  There's 600.000 soldiers.

21             "Mladic:  How much, a million?

22             "Lesic:  I said America send an army of half a million.

23             "Mladic:  What do they want?  They want to conquer the world?

24             "Lesic:  Well, it certainly looks that way.  They want to be the

25     world's police force and Husein is objecting, but for us, this is turning

Page 25029

 1     out good.

 2             "Mladic:  Yes, this is good -- it is good."

 3             Mr. Lesic, you remember this call; correct?

 4        A.   Yes, I do, and I agree with all this that was said.

 5        Q.   Okay.  So now let's just talk a little bit about.  It at the very

 6     beginning you said it's time to take advantage of this situation, Iraq

 7     and this situation.  Please explain what you meant by that.

 8        A.   Well, now, sort of media and all other countries were sort of

 9     occupied with Iraq rather than Serbian Republic and former Yugoslavia

10     what's happening there.  That was my opinion, and I said that will work

11     in our favour, sort of that they left us alone.  Just my opinion and

12     that's how we felt it and that's what I told him over the phone.

13        Q.   And towards the end of the conversation you said it's turning out

14     good and Mladic said yes, it is good.  Just tell me, good for whom?

15        A.   Good -- we've been criticised, like, for example, Gorazde and

16     Zepa, all other little bit -- other little villages that was going on.

17     So we were saying now they maybe left us alone.  They won't bug us or

18     media or anything like that.  They'll be occupied in Iraq, over there.

19        Q.   Mr. Lesic, we're not going to go through the rest of the

20     conversation, but you looked at this transcript the other day.  Is this

21     transcript an accurate representation of the entire conversation at the

22     time?

23        A.   Yes, it is.  It's accurate.

24             MS. WEST:  Mr. President, would I move to -- I would tender

25     this --

Page 25030

 1             JUDGE KWON:  Any objection?

 2             MS. WEST:  -- intercept.

 3             MR. ROBINSON:  No, Mr. President.

 4             JUDGE KWON:  We can admit it.

 5             THE REGISTRAR:  As Exhibit P4441.

 6             THE ACCUSED:  I suppose it's MFI as usual.

 7             JUDGE KWON:  Is it not our practice to admit it in full when one

 8     of the interlocutors testified as to the content?

 9             THE ACCUSED:  I understand, yes.  Thank you.

10             MS. WEST:  I'm now going to show another video.  This is

11     65 ter 40567A.  Mr. Lesic, this is one of your videos.  It's just a small

12     clip of one of them, and it's from August 1994.  And we'll just start

13     playing.

14                           [Video-clip played]

15             MS. WEST:  We stopped at 40 seconds -- 40 seconds.

16        Q.   Were you in this car at the time?

17        A.   Yes, I was.  And I was moving.  I was sort of holding camera.

18        Q.   And who else was in the car?

19        A.   General Mladic and the other soldier.

20        Q.   Okay.  And what were the circumstances of this ride?  Why were

21     you doing this?

22        A.   We just went little bit for ride around Han Pijesak, Crna Rijeka,

23     what they call it, and that's about all.  He just want to show us a bit

24     around.  There was no reason.

25             MS. WEST:  Okay.  We'll continue to play it.

Page 25031

 1                           [Video-clip played]

 2             MS. WEST:  We're at 1:28.

 3        Q.   Is that Mr. Mladic driving the car?

 4        A.   Yes, it is driving the car at that time.

 5                           [Video-clip played]

 6             MS. WEST:  We've now stopped at 2:29.  And as we saw in the

 7     subtitles, it said in the Podrinje, we crash them.  And here, if the

 8     Americans and the English, the Ukrainians, the Canadians in Srebrenica in

 9     the meantime, it's the Dutch would not protect them.  There is no sound,

10     but it then follows with they would have disappeared from this area a

11     long time ago.

12        Q.   Now, this is August of 1994.  By this time how long had you known

13     Mladic?

14        A.   Two years, I met him first time 1992 in December, and this was in

15     August 1994, about a year and a half or so, year and eight months, two

16     years, close to two years.

17        Q.   And what did you understand Mladic's view to be of the

18     international community's involvement in the war?

19        A.   Well, at that day when we were driving around, he was showing me

20     around and how we are well equipped with the trees and with the -- that

21     we could open a sawmills and that country is so rich, had a granite to

22     sell to Switzerland and all that, that is Turks were not there hundred

23     years, and now he's hoping they won't be there.  That was just

24     conversation in that vehicle.

25             MS. WEST:  All right we're going to continue to play for just

Page 25032

 1     another 40 seconds, and I hope that there's sound.

 2                           [Video-clip played]

 3             MS. WEST:

 4        Q.   And, Mr. Lesic, you remember being on this car ride and having

 5     this discussion; correct?

 6        A.   Yes.

 7             MS. WEST:  Your Honour, I tender this clip.

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  Exhibit P4442, Your Honours.

10             MS. WEST:

11        Q.   Sir, I'm going to show you a little bit more video, and this is

12     your footage, but we're actually going to show it from the Srebrenica

13     trial video.  It's on another video that we put together.  That's P4201.

14     And this is footage from July 16th, 17th and 18th.  But before we start,

15     I just want to ask a couple questions.  In July of 1995, did you go to

16     Belgrade?

17        A.   Yes, I did.

18        Q.   And what did you bring with you?

19        A.   We were a group of asking from Canada.  We brought a scanner tube

20     for the hospital in Belgrade.

21        Q.   All right.  You said scanner tube, was this a machine --

22        A.   This was sort of medical instruments.  I tried to get a permit

23     which could be exempt.  It was sort of -- gotta wait eight weeks so we

24     got some -- couple husband and wife and they took there as their luggage

25     and they went to Sofia, and two days later when this all arrived three of

Page 25033

 1     us came over and we sort of presented to Belgrade hospital, VMA.

 2        Q.   All right.  And so the scanner that was brought over it was

 3     actually brought over by a colleague of yours; right?

 4        A.   Yes, friends from Toronto.

 5        Q.   And those friends put it in their luggage?

 6        A.   That's how we travelled.

 7        Q.   All right.  Now, on July 16th, you said you went to the hospital.

 8     Which hospital was this?

 9        A.   In Belgrade called army hospital VMA.  It is famous, the best

10     hospital in former Yugoslavia.

11        Q.   And there did you have discussions and was there a conference

12     with Mr. Mladic?

13        A.   Yes, we did.  Was quite a few of us, and we sort of talked about

14     it, and we were congratulated that instruments arrived and president of

15     Humanitarian Organisation Republika Srpska spoke.  He was there as well

16     as Ned Krajisnik and I and Mr. Zaroban and his wife and Ilija Rakanovic

17     was six of us from Canada.

18        Q.   Did you film parts of this meeting?

19        A.   Yes, I did.  I believe I did film quite a bit.

20        Q.   Okay.  So we're going to show you part of that.

21                           [Video-clip played]

22             MS. WEST:  For the record, this is V009016 of the Srebrenica

23     trial video.  We start at 48 minutes and 55 seconds.

24        Q.   Sir, do you recognise this room?

25        A.   Yes, I do.

Page 25034

 1        Q.   And what was that room?

 2        A.   This was sort of reception room where we could have a 10, 20

 3     people discussion around the troubles and --

 4             MS. WEST:  Okay.  We'll continue.

 5                           [Video-clip played]

 6             JUDGE KWON:  Just a second.  Do you have the transcript page in

 7     hard copy?

 8             MS. WEST:  I do, Your Honour.  In the -- in the book itself it

 9     begins at 07047906.  7906 is where we're beginning with Mr. Mladic's

10     words.

11             JUDGE KWON:  Thank you.

12             MS. WEST:  Thank you.

13                           [Video-clip played]

14             MS. WEST:

15        Q.   We stopped at 49 minutes and 41 seconds.  This looks to be

16     different, not the meeting any more.  What was happening here?

17        A.   Mladic was sort of went to the phone and arranging a two cars for

18     us to drive following morning to Pale to Han Pijesak, Crna Rijeka for six

19     of us.

20        Q.   And you, in fact, videotaped his conversation?

21        A.   I did.  Whatever shows here I videotaped, yes.

22             MS. WEST:  Okay.  Continue.

23                           [Video-clip played]

24             MS. WEST:  We stopped at 50 minutes and 6 seconds.

25        Q.   And here he says you don't have to accepted a car for me.  I'll

Page 25035

 1     get there.  You should send two cars and have them report tomorrow.  They

 2     should leave in the morning, not tonight.  You just mentioned something

 3     about cars.  Who are these cars for?

 4        A.   They were for us, for six Canadians that we arrived with scanner

 5     tube from Sofia.

 6        Q.   Okay.  And where were you going the following day?

 7        A.   We are going on Pale and we are going to Mladic headquarters and

 8     Crna Rijeka there just sort of give him some morale and see them all and

 9     that's about it.

10        Q.   And do you know how Mr. Mladic was travelling?

11        A.   I don't.

12        Q.   We'll continue.

13                           [Video-clip played]

14             MS. WEST:  We're at 50 minutes and 50 seconds.

15        Q.   Mr. Lesic, do you know who Vinko is?

16        A.   No, I don't.  I just hear the name.  He was some kind of a

17     commander somewhere else.

18             MS. WEST:  Okay.

19                           [Video-clip played]

20             MS. WEST:  We're going to stop there, an we're at 51 minute and

21     22 seconds.

22        Q.   Now, the following day, did you leave Belgrade?

23        A.   Yes, we left Belgrade.  We went to Intercontinental.  Met over

24     there intelligence Petar Salapura and another driver from army -- jeep.

25     And six of us left with two cars and a jeep.

Page 25036

 1        Q.   Okay.  You just mentioned the Intercontinental.  That the hotel

 2     where you stayed that night?

 3        A.   That's the hotel we usually stay when we go there.

 4        Q.   When you left the next day you mention the Petar Salapura and

 5     another driver from the army.  Is this the person who accompanied you?

 6        A.   Every time we would come, Mr. Krajisnik and myself or anybody

 7     else, they give us a sort of a security guard to take us around because

 8     we are bringing humanitarian aid so that we know where to go.

 9        Q.   Okay.  On the 17th, did you also take footage?

10        A.   Yes, I did.

11        Q.   All right.  So we're going to continue and we're just going to

12     finish out this footage because I think that will be quicker, and we'll

13     continue on to the next day.

14                           [Video-clip played]

15             MS. WEST:  We're at 52 minutes and 45 seconds.

16        Q.   Do you recognise this room?

17        A.   Yes, I do.

18        Q.   And what is it?

19        A.   This is a room where General Mladic in Crna Rijeka was staying,

20     as far as I know, and we were in that room, always invited having a

21     coffee, whatever.

22        Q.   And the person we see on the screen right now, who is that, the

23     one who is speaking?

24        A.   Yes, this is Ranko Rakanovic, president of

25     Humanitarian Organisation Republika Srpska that we have started organised

Page 25037

 1     and registered in 1992 and we got our registration 1993.

 2        Q.   So he was one of your colleagues; right?

 3        A.   Yes, he was.

 4        Q.   And the person to his right who is in the middle of the screen,

 5     who is that?

 6        A.   That's his brother, Ilija Rakanovic.

 7        Q.   And the person to Ilija's right on left-hand side of the screen,

 8     who is that?

 9        A.   It's moved away from my screen.  I can't recognise.

10        Q.   Okay.  I'll ask you when we see it again.

11                           [Video-clip played]

12             MS. WEST:  Now we're at 52 minutes and 52 seconds.

13        Q.   Who are these two gentlemen on the screen?

14        A.   General Mladic and General Milan Gvero.

15        Q.   Thank you.

16                           [Video-clip played]

17             MS. WEST:  We stopped at 54 minutes and 5 seconds.

18        Q.   And here General Mladic said he hopes the area of Zepa will be

19     taken care of in the same way as the area of Srebrenica.  At this time,

20     at this moment, what did you understand had happened in Srebrenica?

21        A.   From this speech, I presumed that Srebrenica was sort of

22     conquered, take over, two or three days before our arrival.

23        Q.   And prior to the speech, had you heard anything else about

24     Srebrenica?

25        A.   Just on travelling from Belgrade to Han Pijesak, Crna Rijeka.  We

Page 25038

 1     had to turn to Bratunac, go little bit around half an hour away, rough

 2     road was, so that we avoid our intelligence.  Petar Salapura was driving

 3     with us says we better go the other route.  Someone could come out from

 4     the forest.  It's safer for us to go back around by the Bratunac.

 5        Q.   And what was the normal route that you typically took from

 6     Belgrade to Han Pijesak?

 7        A.   Normal route was that sort of you could go the better road and

 8     much straighter, much quicker, but then that incident we took a bit a

 9     round route to be safer.

10        Q.   And, if you remember, you said you can go the better road much

11     straighter, much quicker.  Do you know where that went?

12        A.   Well, not exactly.  I wasn't driving, but we went to the sort

13     of -- not to Bratunac but to the -- to the farther straighter.  I can't

14     recall the --

15        Q.   That's fine.

16        A.   -- cities.

17        Q.   That's fine.  Thank you.  We'll continue playing.

18                           [Video-clip played]

19             MS. WEST:  We're at 55 minutes and 42 seconds.

20        Q.   And General Mladic is saying thank you for helping us solve our

21     problems regarding Srebrenica and congratulate you, both you and us, on

22     the occasion of the liberation of the Serb Srebrenica.  At that meeting

23     what problems did you understand they had in Srebrenica?

24        A.   I really didn't understand any of the Srebrenica.  He was here

25     more saying that he thank us for bringing that scanner tube when he

Page 25039

 1     approached me.  I didn't understand anything about Srebrenica here.

 2        Q.   Okay.  Mr. Lesic, yesterday you spoke about the type of media you

 3     watched when you were in Canada.  In the days leading up to this trip in

 4     July 1995, were you watching Serbian television from the region for your

 5     news?

 6        A.   I was watching on a satellite dish that was showing from Belgrade

 7     or Bijeljina or from somewhere what was going on over there.

 8        Q.   Okay.  We'll continue.

 9                           [Video-clip played]

10             MS. WEST:  We're at 57 minutes and 10 seconds.

11        Q.   And here General Mladic says half the world attacked us through

12     the Croats and the Muslims because almost half of the world has been

13     helping them.  What did you understand half the world to indicate?  What

14     did you mean that half the world was helping them?

15        A.   What he was saying he was sort of happy that we were together and

16     we brought humanitarian help.  We are concerned what's happening in those

17     area, and six of us arrived.  He was saying half of world, half of world,

18     in other words -- well, rest of the Western world was against them.

19     That's what they felt at that time.

20        Q.   All right.  And we're not going to continue to play this video,

21     but it goes on for a bit, and this is on the 17th.  On the night of the

22     17th, where did you sleep?

23        A.   I would say I -- as I can remember, I slept there at the

24     Crna Rijeka in a bunker as usual when I don't travel same day back to

25     Belgrade.

Page 25040

 1        Q.   All right.  So at Crna Rijeka they had at least a facility where

 2     guests could sleep, where you could sleep?

 3        A.   Yes, they did.  They had quite a few beds and underground there.

 4     It was quite nice apartment.

 5        Q.   Okay.  And the following morning on the 18th, did you have

 6     breakfast at Crna Rijeka?

 7        A.   We had something, coffee or something.  I don't recall.  It was

 8     long time ago.

 9        Q.   And then where did you go?

10        A.   We went farther.  As far as I know today, we went to see

11     President Karadzic and his -- and his headquarters.

12        Q.   All right.  And was that in Pale?

13        A.   Yes, it was.  That was only short 15, 20 minutes' drive.

14        Q.   Okay.  I'm going to show you some photos, Mr. Lesic.  And when

15     you gave the interview in August of 2009 to the OTP, you brought not only

16     videos with you but photos; correct?

17        A.   Yes.

18        Q.   And you brought many.  I think you brought over 30 photos with

19     you, and I'm just going to show you some to at least get a sense of how

20     many trips you took.  So we're only going to look at some of them.

21        A.   Yes.

22             MS. WEST:  If we can have 65 ter 21939A.  And the first photo

23     we're going to look at ends in the numbers 7196.

24        Q.   Sir, do you recognise this photo?

25        A.   Yes, I do.

Page 25041

 1        Q.   Was this your first trip?

 2        A.   This one, yes.  It was my first trip where we are five of us.

 3        Q.   All right.  If you can go from left to right, tell us who these

 4     people are?

 5        A.   General Mladic, President Karadzic, myself, and

 6     General Milan Gvero, and Ned Krajisnik.

 7             MS. WEST:  I tender this photo, please.

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  Exhibit P4443, Your Honours.

10             MS. WEST:  We can go same 65 ter number photo ending in 7204.

11        Q.   Do you remember where this photo was taken?

12        A.   At President Karadzic's reception or his office or somewhere

13     there.

14        Q.   Let me ask you this:  In early 1993, did you have an occasion to

15     meet Mr. Karadzic in New York?

16        A.   Yes, I did meet him twice.

17        Q.   Okay.  And why did you do that?

18        A.   Well, we came from Canada, four of us, to give him support.  They

19     had a hell of a time with UN negotiations and all that.  They were there

20     two or three days, and we went there to spend with them two days or so.

21     We drove over, four of us, sort of talk to them, help them.  We felt -- I

22     was self-employed and we felt we had enough time, Ned Krajisnik and

23     myself and others, to go there and give them support.

24        Q.   And can you identify the people in this photo, please?

25        A.   Ned Krajisnik, Dr. Karadzic, and myself.

Page 25042

 1        Q.   All right.

 2             MS. WEST:  I'll tender this one, please.

 3             JUDGE KWON:  Yes.

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE KWON:  This is a part of a compilation of nine photos.  Are

 6     you tendering each photo separately?

 7             MS. WEST:  If it's easier, they can be all one.

 8             JUDGE KWON:  If there's no objection, we'll admit it in one.

 9             Mr. Robinson.

10             MR. ROBINSON:  Well, in principle, we would prefer that only the

11     photos that are discussed with the witness be admitted.  So if she

12     intends on going through each one of them, then you can admit them all as

13     one, but if you are going to select just a few, we would ask that those

14     be admitted.

15             MS. WEST:  And if --

16             JUDGE KWON:  Show us the photos you want to tender and then we

17     will admit them all.

18             MS. WEST:  Thank you.  Thank you.  Then we'll now go to 7212.

19        Q.   This is dated October of 1993.  Do you recognise this place?

20        A.   Yes, I do.

21        Q.   Where is this?

22        A.   This is at Crna Rijeka, Han Pijesak.

23        Q.   All right.  And if we can start from the left-hand side and go

24     down the table, can you tell us who's there?

25        A.   Myself, Milan Gvero, Ned Krajisnik, General Milosevic,

Page 25043

 1     Marko Sandal from Canada, General Mladic, and Mrs. Mladic.

 2        Q.   If we can go to 7216.  This is in 1994.  What room is this?

 3        A.   This is in Pale at -- either at Momcilo Krajisnik office or

 4     President Karadzic office.  I'm not sure.

 5        Q.   Okay.  But the map on the wall --

 6        A.   Yes.  Map on the wall is President Karadzic, I believe.

 7        Q.   All right --

 8        A.   Office.

 9        Q.   And on other occasions that you were in that office, had you seen

10     that map before?

11        A.   Yes.  Yes, I have, yes.

12        Q.   All right.  If we can go around the table and tell us who's

13     there.

14        A.   Mile Jelicic, he came from Belgrade with me, my brother-in-law,

15     and that was a lady - I don't know her name - she's some kind of a worker

16     there, secretary of Mr. Karadzic, myself, Momcilo Krajisnik, and

17     President Karadzic.

18        Q.   If we could have 7220, please.  This is December 1994.  Do you

19     recognise this room?

20        A.   Yes, I do.

21        Q.   What room is it?

22        A.   This is at Pale as well, at the President Karadzic headquarters.

23        Q.   And can you start from the left and go around the room and give

24     us the IDs.

25        A.   Deyan Zaroban from Canada, Toronto, Momcilo Krajisnik,

Page 25044

 1     President Karadzic, myself, and soldier down there I don't remember his

 2     name --

 3        Q.   Okay?

 4        A.   -- or the two people turned back to me I don't remember them.

 5        Q.   Well, fair enough.  If we can go to 7238, please.  And this is

 6     18 July 1995.  Where was this taken?

 7        A.   This was taken in Crna Rijeka outside at the picnic table.

 8        Q.   And go from the left to right.  Can you give us the

 9     identifications?

10        A.   Branko Zaroban from Canada, Toronto, General Mladic and

11     General Momcilo Perisic and Ned Krajisnik.

12        Q.   May we have 7242.  This is also July 18th, 1995.  Where was this

13     taken?

14        A.   This was taken same place, Crna Rijeka, Han Pijesak.

15        Q.   And go from left to right.

16        A.   General Milan Gvero, Ilija Rakanovic from Canada, Ned Krajisnik

17     from Canada, and Ksenija Zaroban.

18        Q.   Can you tell us what that house is in the background.  What is

19     that?

20        A.   On the back of the -- their back -- Ned Krajisnik back this is

21     entrance going upstairs to the office and reception.

22        Q.   May we have 7250, please.  This is from January 1996.  Do you

23     recognise this room?

24        A.   I would -- yes.  This is in Crna Rijeka, Han Pijesak, up on the

25     first floor up going to steps, myself, General Mladic, Petar Salapura

Page 25045

 1     intelligence, and Ned Krajisnik.

 2        Q.   All right a number of times you have seen Han Pijesak and

 3     Crna Rijeka together.  Can you tell us what the difference is between the

 4     two places?

 5        A.   Well, Han Pijesak is called all region.  There is a region,

 6     Han Pijesak, and Crna Rijeka is a little bit farther that is in the

 7     mountains under the mountain build.

 8        Q.   All right.  So when we saw photos where there are woods, is that

 9     Crna Rijeka?

10        A.   Yes, yes.

11        Q.   And is that the place where you stayed overnight?

12        A.   Yes, that's the place.

13        Q.   And the building we saw in the background is that the place where

14     General Mladic would stay overnight?

15        A.   At that time, while I was there, he did, yes, as far as I know.

16             MS. WEST:  Your Honour, I would move to -- I would tender these

17     photos as one.

18             JUDGE KWON:  Yes, that will be all included in Exhibit P4443.

19     Added to --

20                           [Trial Chamber and Registrar confer]

21             JUDGE KWON:  So only those photos shown will be admitted, added

22     to the exhibit.  Yes.

23             MS. WEST:  Okay.  Thank you.  Your Honour, at this point I'd like

24     to move to an area upon -- I would like the witness to speak and it's an

25     area that takes place in 2001 and 2009, and I believe the subject matter

Page 25046

 1     is relevant to the indictment.  I know the Defence is of a contrary

 2     position.  And I know it may be an issue.  I looked at your Ruling

 3     yesterday, and you ordered the Prosecution to focus on parts of the

 4     evidence were relevant to the indictment.  It is my position they are

 5     relevant to the indictment, but if I may be heard I'd like to be.

 6             MR. ROBINSON:  Yes, Mr. President, we would also like to be heard

 7     and outside the presence of the witness.

 8             JUDGE KWON:  Very well.  So, Mr. Lesic, if you could excuse

 9     yourself for a moment.

10             THE WITNESS:  Yes, sir.

11                           [The witness stands down]

12             JUDGE KWON:  Yes, Ms. West.

13             MS. WEST:  Thank you, Mr. President.  In 2001, several years

14     after these events that we've been talking about, the witness met with

15     General Mladic and Mr. Karadzic in Belgrade and in Bosnia.  There is a

16     photo reflecting a dinner that the witness had with General Mladic and

17     then the witness would give evidence that following that he went to the

18     area where General Mladic was hiding, and then the following day he went

19     to an area where Mr. Karadzic was hiding.  As you recall this is a period

20     of time where the two -- their whereabouts were unknown.

21             I believe that in addition to this, the witness will also tell us

22     about early 2009 when he was home in Canada and he was at a church event

23     and Ned Krajisnik, the person who's colleague involved in this

24     organisation, came to him with Mr. Karadzic's niece, and Mr. Karadzic's

25     niece asked whether Mr. Lesic would organise a fundraising banquet at the

Page 25047

 1     church to raise money for Mr. Karadzic.  I believe that these events in

 2     2001 and 2009 are relevant to the indictment because they go to the

 3     nature of the relationship between Mr. Lesic and the leadership of the

 4     Republika Srpska and that's important because if we were -- if we

 5     understand that in 2001 and 2009 General Mladic and Karadzic reach out to

 6     this witness at a very risky time, that they reach out to this witness,

 7     it shows the strength of their relationship thereby giving weight to the

 8     impressions and observations that this witness has testified about that

 9     he made in 1992 and 1995.  And my argument is that if Mr. -- had

10     Mr. Karadzic and Mr. Mladic not reached out to Mr. Lesic in those

11     following years, you might be left with some notion that the relationship

12     they had during 1992, 1995, was not so substantial, but because they

13     reached out at a time that was very risky for them, I would suggest that

14     it's relevant to show you that the relationship they had was a very

15     strong one, and that's why I think that these events are important.

16             JUDGE KWON:  Ms. West, could you give me the examples of

17     impressions and observations that Mr. Lesic has testified about --

18             MS. WEST:  Yes.

19             JUDGE KWON:  -- what he made in 1992 and 1995.

20             MS. WEST:  For example, we spoke -- much of the time we have been

21     speaking about the international community and the media and the

22     propaganda that was going on.  And Mr. Lesic testified that in June of

23     1993 at this Trnovo dinner there was this speech from Mr. Karadzic.

24     Several times Mr. Lesic has talked about what Mr. Karadzic and

25     General Mladic's view was of the international community getting involved

Page 25048

 1     with their war and what their impressions were about the media and the

 2     propaganda and the bias that they believed was going on in international

 3     media.  Now, this was an opinion that was shared by this witness as well,

 4     but several times he has indicated to you that they also had this

 5     impression.

 6             JUDGE KWON:  Very well.  Yes, Mr. Robinson.

 7             THE ACCUSED: [Interpretation] There's just something I'd like to

 8     say and then I'll hand over to Mr. Robinson.  Money wasn't requested for

 9     Radovan Karadzic but for the services that isn't being paid for by the

10     court, various services in Belgrade.  It wasn't for Karadzic and that is

11     not what the witness said.  Mr. Robinson could now take the floor.

12             JUDGE KWON:  Very well.  Yes, Mr. Robinson.

13             MR. ROBINSON:  Yes, Mr. President.  This is a very thin reed upon

14     which the Prosecution wants to bring in inadmissible evidence.  The

15     relationship between Dr. Karadzic and Mr. Lesic is absolutely irrelevant

16     to anything that he's testified about.  We're still wondering really why

17     he's here at Dr. Karadzic's trial.  I can see why he would maybe want to

18     come for -- or wanted -- be wanted for General Mladic's trial but he

19     hasn't offered any evidence about Dr. Karadzic other than what was shown

20     on the video-tape, and we can all see what Dr. Karadzic said.  So any

21     relationship that Mr. Lesic had with Dr. Karadzic is completely

22     irrelevant.  And we're not contending that he's untruthful in bringing

23     his video-tapes and showing us what was said at the time.  So I don't

24     think that you can bootstrap otherwise inadmissible evidence by trying to

25     establish a relationship that is of no moment to the witness's evidence

Page 25049

 1     or to the Trial Chamber's deliberations.

 2             JUDGE KWON:  Would you like to reply, Ms. West?

 3             MS. WEST:  No.

 4                           [Trial Chamber confers]

 5             JUDGE KWON:  Given the time, the Chamber will take a break now

 6     for half an hour.  We'll rise.

 7                           --- Recess taken at 10.11 a.m.

 8                           --- On resuming at 10.44 a.m.

 9             JUDGE KWON:  Ms. West, the Chamber is not satisfied that the

10     portions you referred to are relevant.  The objection is sustained.

11             Shall we bring in the witness.

12             MS. WEST:  Thank you, Mr. President, and I have no further

13     questions.

14             MR. ROBINSON:  Mr. President, I would like to commend Ms. West

15     for the way that she brought that issue up in advance to the Chamber so

16     that we could deal with it before -- outside the presence of the witness.

17             JUDGE KWON:  The Chamber appreciates it as well as.  Thank you.

18             MR. ROBINSON:  Mr. President, while we're waiting, yesterday the

19     Prosecution filed a motion concerning our access to materials in a

20     completed case involving Vasiljevic, and I wanted to let you know that we

21     won't be responding to that motion and we don't oppose the relief that

22     they seek.

23             JUDGE KWON:  Thank you, Mr. Robinson.

24                           [The witness takes the stand]

25             JUDGE KWON:  My apologies for your inconvenience, Mr. Lesic.

Page 25050

 1             THE WITNESS:  It's okay, sir.

 2             JUDGE KWON:  Ms. West, could you repeat your last words.

 3             MS. WEST:  Thank you, Mr. President.

 4             Thank you, Mr. Lesic, I have no further questions.

 5             THE WITNESS:  Thank you.

 6             JUDGE KWON:  Yes, Mr. Karadzic.

 7             THE ACCUSED: [Interpretation] Thank you.  Good morning,

 8     Your Honours.

 9                           Cross-examination by Mr. Karadzic:

10        Q.   [Interpretation] Good morning, Mr. Lesic.  Good morning to

11     everyone in the courtroom.  I'd like to thank you for meeting with us,

12     for meeting with me and the Defence.  I hope this will be of assistance

13     to us.  I hope it will assist me to put brief questions to you and

14     receive brief answers so that we can finish within the time allocated.

15     Thank you again.

16             Mr. Lesic, you left Yugoslavia because you objected to the

17     previous regime that imposed restrictions on you in economical and

18     political terms.  Isn't that the case?

19        A.   Yes.  Yes, that was the case.  Economical, better life somewhere

20     else.

21        Q.   Thank you.  Given that you operate as a Serbian diaspora society

22     in Canada, is it true that in a democratic Serbia you recognised us in

23     1995 as being a new democratic force that would be fighting on behalf of

24     democracy and that would be fighting against a one-party system.  Was

25     that your understanding of the situation, and did you support the

Page 25051

 1     political efforts we were making?

 2        A.   Yes, Dr. Karadzic.  We supported.  As I recall, we give you and

 3     Mr. Krajisnik and Biljana Plavsic membership as well from our

 4     Humanitarian Organisation Republika Srpska, and at that time in Pale I

 5     said, well, it is a good news.  We have charted that Canada recognise

 6     Serbian Republic after all.

 7        Q.   Thank you.  I want to dwell on the previous war period.  We had

 8     the support of the diaspora from the democratic world.  Do you remember

 9     that at that time we strove to preserve Yugoslavia -- or, rather, we

10     strove to have Bosnia remain within Yugoslavia, whatever the extent of

11     that state?

12        A.   Yes.  In diaspora Serbian community in Toronto, Canada, all

13     different cities, we supported all your work and Serbian Republic and to

14     stay in Republika Srpska.  We supported the effort at that time what was

15     happening, what was going on.  We were all enthusiastic and with you

16     that's how we put ourselves.  We had 420 members

17     Humanitarian Organisation Republika Srpska to help your cause and to

18     bring humanitarian help because we supported you at that time.

19        Q.   Thank you.  I would still like to deal with the pre-war period.

20     Prior to the war breaking out, did you notice that we were in tolerant in

21     relation to the Muslims, or would you agree that we wanted the Muslims to

22     remain together with us within Yugoslavia?

23        A.   Yes.  I agree with you, sir, that we want to go together with

24     Muslims and with Yugoslavia.  We did not want a war with them.  That was

25     discussion, and that was our opinion as well before the war breakdown,

Page 25052

 1     but political field didn't let us do that direct -- that way.  We were

 2     all aware that was an ideal thing to do.

 3        Q.   Thank you.  Among the leadership of the Bosnian Serbs, did you

 4     notice anyone having shown their tendencies of any kind in relation to

 5     the Muslims or the Croats, or would you agree that we were an openly

 6     democratic community?

 7        A.   Yes, sir.  During my visit over there and discussing with

 8     intelligence Petar Salapura, he was telling me during a car ride from

 9     Belgrade to Pale that we had some Croats and Muslim forces, individuals,

10     going on our side and being with us during that time.  I was surprised,

11     but that's what they tell me, that we want -- that that's what was going

12     on there.

13        Q.   Thank you.  On page 10, a question was put about Trnovo today,

14     and something with relation in relation to Trnovo was shown.  I praised

15     the army for having acted expeditiously.  Do you remember something in

16     relation to the declaration of the protected zones of Zepa and

17     Srebrenica?  Prior to that declaration there was a large-scale Muslim

18     offensive that was launched against our territory, and at the time no one

19     criticised them for doing this, and what I have in mind above all is the

20     media that you could follow in Canada.

21        A.   Yes.  I recall that very well, that Trnovo was quite difficult,

22     that the Muslims was Muslim area one time, and another time they did kick

23     Serbs out that I recall, and I was talking to some people in the media as

24     well, and then as you were praising General Mladic how well job was done,

25     quick and with no any consideration from the West, nobody blinked an eye,

Page 25053

 1     and so on.  That was not -- that was my understanding at that time, but I

 2     was occupied.  I was new there.  I really didn't know half of it, what

 3     was going on.  I stay here a night, a day here, a day there.  I wasn't

 4     very much involved in all that discussion, just what I know, that's what

 5     I'm saying.

 6        Q.   Thank you.  With regard to Cerska, Konjevic Polje, and so on and

 7     so forth, do you remember that before our counter-offensive, there was a

 8     Muslim offensive from Cerska, Konjevic Polje, and Srebrenica?  And do you

 9     agree that the international media didn't attack them for having launched

10     that offensive.  You could hear about that only from our own local media,

11     not from the international media?

12        A.   Yes, Dr. Karadzic, I would agree with you.  That's what I hear

13     from it that no one criticising when they were attacking and when they

14     were sort of on the battle-field against the Serbs.  I've been watching

15     that Serbian media and listening to that.  I would agree with you all the

16     way.

17        Q.   Thank you.  Do you remember that the international media spread

18     propaganda according to which a terrible crime had been committed in

19     Cerska and this continued until General Morillon entered Cerska and

20     showed that this was not the case, denied that that had happened?

21        A.   Yes, I recall that as well through discussion with the army

22     intelligence that that happened the way you said, sir.

23        Q.   Thank you.  Today we had a look at a video excerpt.  The date was

24     the 16th, and it was at the VMA in Belgrade.  Do you remember what time

25     it was when you went to visit Mladic on that occasion?

Page 25054

 1        A.   The time, sir, I'm not aware of the time.  I remember that we

 2     came from Sofia first day in VMA, and I don't recall the time unless

 3     video or picture shows otherwise, and from the Belgrade when we -- the

 4     scanner arrived, scanner too, following morning we went to Pale.  As

 5     well, I don't remember exact time.  Was in afternoon, as I believe, that

 6     we were there.

 7        Q.   Thank you.  Do you remember whether one day before the 16th you

 8     spoke to General Mladic?  Did you speak to him a day earlier, on the

 9     phone perhaps?  Can you confirm, in fact, where General Mladic was one

10     day earlier?

11        A.   I don't remember where General Mladic was one day earlier.  I

12     remember seeing him as -- in Belgrade in hospital, and following day I

13     saw him on Han Pijesak, Crna Rijeka.  That's all I remember where he was.

14        Q.   Thank you.  Do you remember whether on the 16th or the 17th there

15     was a conversation of any kind with General Mladic and his entourage, a

16     conversation that concerned people who may have been killed?  And when I

17     mention these people who may have been killed, it's in relation to

18     Srebrenica.

19        A.   I don't remember any discussion over the people being sort of

20     killed or anything like that.  No one would tell us anything what was

21     this.  I just know that Srebrenica was sort of taken over two or three

22     days prior my arrival there, that's all.  They did not discuss with us

23     about those things, sir.

24        Q.   Thank you.  Did you notice that they were making some kind of

25     allusions when they talked amongst themselves?  Was there anything in the

Page 25055

 1     air, if you will, regarding any kind of unlawful killing?

 2        A.   As I -- as I was talking to the group of people and all that and

 3     they were -- everybody had their own discussion, no one told me about any

 4     group of killing or separate killing, nothing that I was aware of.  I

 5     recall seeing many, many buses going and people -- children and women

 6     having put on the buses and drove away by seeing from international

 7     media, but I don't remember any other discussion that people was telling

 8     me.

 9        Q.   Thank you.  I'd like to ask you now whether you followed in the

10     media what had been happening before that.  For example, did you hear of

11     the slaughter in Dobrovoljacka Street on the 3rd of May, 1992?  Did you

12     hear about that through our media or international media?

13        A.   Yes.  That meaning in market square in Sarajevo?  Was that the

14     question?

15        Q.   That could be the question too.  In 1994, in February, there was

16     Markale I, the first Markale case.  What did you learn about that, and

17     what was your understanding of it?

18        A.   Well, it was awful thing to learn that this took place, but then

19     later on I hear from Canadian or Western media, French, I would say,

20     Mr. MacKenzie, General MacKenzie was sort of saying that did not happen

21     as they claimed it happened, so General MacKenzie sort of was always down

22     the street and talking the way things went, and he got replaced as a

23     general, and then General Morillon later on took his position, and also

24     he was sort of fair general.  He was co-operating with General Mladic,

25     what I was told, and he was also replaced later on.

Page 25056

 1             I don't believe that Serbs did that market square in Sarajevo.

 2     Maybe I'm wrong, but I don't believe they did through my discussion and

 3     through the after founding, that they done that to themselves so that

 4     they have a Western media much more against Serbs.

 5        Q.   Thank you.  So even in the Western media was this idea being

 6     bandied about, namely that this crime had been staged, rigged, in order

 7     to accused the Serbs?

 8        A.   Yes, sir.  That was possible to be rigged because Serbia had no

 9     media on their side.  Was everything going against them at that time.

10     And I recall going up and about the Sarajevo meeting general in charge

11     that they were sort of shooting in the Sarajevo, and I was asking them,

12     Is that true what's happening?  No, no, no.  It is not true.  It is just

13     the media.  I don't know any more than what I was told over there.

14        Q.   Thank you.  As regards aid, you were indeed very helpful, you and

15     all Canadian Serbs.  Do you agree that the aid that you brought, the

16     monetary part of that aid, was always handed over to officials in the

17     presence of several individuals and that certificates were issued to that

18     effect?

19        A.   Yes.  We were organised.  We had, as I said earlier, so many

20     members in Humanitarian Organisation Republika Srpska, and we carried a

21     letter from committee how to disburse the funds and who to help, and then

22     we had our discretion over there asking Biljana Plavsic and asking other

23     officials where it's most needed, and we try to give to the places that's

24     most needed at their suggestion.  We were strangers.  We were out there.

25     We didn't know where what.  We went to hospitals.  We went here and

Page 25057

 1     there.  We always got a receipt.  We always got sort of kind of a gramata

 2     [phoen] certificate that we have.  Yes, we have give funds where we

 3     supposed to and that was always spended or used properly.

 4        Q.   Thank you.  So you gave it to the final beneficiaries, the end

 5     beneficiaries; right?

 6        A.   Yes.  We give to the Red Cross in one case.  In other cases, we

 7     give to the parliament.  In other cases, we give to the treasurer of army

 8     for soldiers to have their meals or whatever, and one time we have given

 9     cigarettes.  That what they most needed.  And Biljana Plavsic suggested

10     to me they should get some cigarettes, and we brought -- we found it

11     somewhere, and we give them what we could.  And we really put ourselves

12     in -- some kind of a tiring spot and flying with helicopter but just to

13     help needy.  That was our decision to do, and that's what we did at that

14     time.

15        Q.   Thank you.  Is it correct that you did not give any kind of

16     financial aid to individuals from the leadership, the civilian

17     leadership, or the military leadership, that would be used for their own

18     purposes?  Rather, you gave this aid to people who needed it.

19        A.   Yes.  What we did we give first time in 1992 in parliament

20     session.  My video camera taped it so I could show back home in Canada

21     how did we give the help and how did we disburse the funds.  Other times

22     we give for the media 15.000, I give, and we sort of -- we give -- people

23     were waiting in a bake shop.  I wish that what that footage would show

24     where there was people waiting for bread, and we were -- I was giving

25     them 10 and 20 Deutschmarks at that time, and I almost was run over, but

Page 25058

 1     that was our goal, and that was our aim, to give where it was possible,

 2     even give people on the street they are needy, like that incidents in the

 3     bakery.

 4             Other time, we always give in to -- we delivered a hundred tonne

 5     of floor, and 20 tonnes we give to different cities, Banja Luka, Doboj,

 6     Prijedor, and so on, as the footage will show wherever there is the

 7     movies for those things as well.  And we were quite happy when I arrived

 8     back to Canada that we did well job done and -- at that time.

 9        Q.   Thank you.  Since you saw how the soldiers were living and how

10     they were receiving food and how people in Republika Srpska lived, do you

11     agree that this was grave poverty, also that the people in the army were

12     barely surviving with a maximum of one or two meals per day?

13        A.   Yes.  I recall General Mladic would take me, I would say, hundred

14     or 200 metres away from Crna Rijeka, showing me a farm and some little

15     farmhouses where they had the pigs and chickens and growing and being

16     self-sufficient, and sort of telling me how they are doing themselves to

17     create food and to be not waiting till comes from outside or from

18     anywhere else.  When I saw all that, every time we arrived from Belgrade

19     we brought some in the cars as much as we could, sort of bringing some

20     kind of food, smoked meat and all other things just to help everybody in

21     the needs as much as we could.

22             I recall one time I ask -- I saw about 20 or 30 soldier around

23     there watching soccer, and I ask General Mladic could I give them a

24     couple of bucks.  He says, No.  I would not advise you to do that.  I

25     said, Why?  He says, Well, I don't want just my army receive some kind of

Page 25059

 1     a gift and other doesn't.  I replied to General Mladic.  I said, Who is

 2     close to the fire, he gets a heat.  I can't -- after all, you're not boss

 3     of my money.  I brought it here and I will disturb [sic] as I see fit and

 4     I give them a 10 or 20 marks to 20 of them.  I felt good about it.  So

 5     ...

 6        Q.   Thank you.  We're not talking about the Main Staff now.  Now

 7     we're talking about other places in the field, the Krajina, for instance,

 8     various towns.  Did you see what kind of life our people had there and

 9     how impoverished they were?

10        A.   Yes, I saw terrible things towards my area.  Personally I am from

11     the Krajina and Bihac over there, and that was sort of end of the line,

12     and from Banja Luka they didn't get much help over there, so as I was --

13     always when I had a chance to go close to Bihac, we delivered some help

14     to them as well.  It was from my village few, five or six.  They were

15     there, and I saw that they were not -- they were pretty poorly living,

16     soldiers and all that.  They had no right uniform on them.  They were

17     cold and all that.  I made a call to General Mladic, and I said, Look,

18     call Banja Luka and send 20 uniforms over here.  These people are

19     completely -- they're cold.  They don't have much to wear or anything.

20     So he says, What size?  I said, Give me the guy.  So I told him size

21     so-and-so and all different sizes.  And it was a tough for them, yes.

22        Q.   Thank you.  Do you agree that in such conditions it was also

23     rather difficult to feed large numbers of prisoners of war properly?  We

24     could feed them only the way we fed our own army.

25        A.   Yes.  I never saw any prisoners, but I was told and I would

Page 25060

 1     presume, yes, if you don't have food enough for yourself, you cannot give

 2     it away as much either.  So it's just going from day to day for survival.

 3     I am aware of all that.  I recall when I was in Austria 1958, young kid,

 4     and we didn't have a good time either waiting to escape to -- waiting to

 5     be emigrated to different countries, and that's what I put myself in a

 6     position this time.  I wasn't in army, so I said now I have a couple of

 7     dollars in the pocket, and it's [indiscernible], and I want to help my

 8     people as much as I can.  Thank you God Canada did well for me and I did

 9     well for Canada.  So I was in a position with a group of others to give

10     that kind of donation and that kind of humanitarian work.

11             Just to explain, wasn't easy to register humanitarian

12     organisation.  At that time we were turned down first time to change our

13     name, and I was persist.  I says, No.  I would like to be

14     Humanitarian Organisation Republika Srpska, and waited another three to

15     six weeks.  We got approval from the Canadian government to receive the

16     charter, and when someone gives like a $10.000 donation, they paying high

17     taxes, so they can claim it, 30 or 40 per cent, depends on each

18     individual's salaries.

19             So when I got visited by Canadian intelligence every time I come

20     back, they say, Well, you took money over there.  You did this.  You did

21     that.  I said, Yes, I did.  My taxes are paid, and I spended the money,

22     was clear money, the way I saw fit, and we collected so-and-so on.

23     Wasn't any issue.

24        Q.   Thank you.  You mentioned the period you, yourself, spend as a

25     refugee.  Did you see for yourself that in Republika Srpska, everywhere,

Page 25061

 1     the Krajina included, at the time there were a large number of Serbs who

 2     had fled not only from Croatia but also from Central Bosnia?  Did you

 3     come across them?

 4        A.   In Canada, yes, I came across with lots of immigrants, being

 5     52 years in Canada, 1992, 1994, up to 2009.  I personally employed 7.500

 6     people to work in an auto motor industry parts for the cars, to help them

 7     out to get settled.  I employ -- I got them the jobs there, and they're

 8     still working.  Up to now is 8.500 people working in different companies.

 9     They all settled.  They all good tradesmen and machinists and all that.

10     The owner of the company is pretty happy with them.

11        Q.   Thank you.  I wanted to ask you about when you travelled through

12     Republika Srpska.  Did you come across refugees there, people who had

13     fled to Republika Srpska from the Muslim and Croat parts of Bosnia?

14        A.   Yes.  When I went to visit hospitals and bishop from Chicago,

15     Irinej.  They were at Kasindol hospital and there were -- some people

16     fled and I was -- pointed out I wasn't close with them, but they say

17     those people fled and we got to help them and all that, and I've been

18     told yes, you're right.

19        Q.   And in the Krajina, Banja Luka, other municipalities, did you

20     notice a considerable number of refugees there?  Did you help them as

21     well?

22        A.   In Banja Luka, they are just outskirts of Banja Luka, Derventa or

23     somewhere, as I recall.  We saw quite a bit from Sanski Most and from

24     other there were 80 people in one room, and I saw quite a -- quite a

25     refugees there that they had no place to go.  They couldn't go back and

Page 25062

 1     all that.  It was quite disaster.  That's when I -- when we brought them

 2     the help.  It was quite difficult for them.  Yes, I saw all that, and I

 3     believe I even took some movies from it.

 4        Q.   Thank you.  Can we agree that you were quite happy with the

 5     distribution of aid that the Canadian Serbs sent through you and that

 6     there was no abuse of this aid?

 7        A.   Yes.  We were quite -- quite -- quite agree with you, yes.  The

 8     aids was never abused.  We give to the proper places.  We got

 9     documentation for it, and I even took the pictures and the movies when we

10     brought the aids to present it back to Canada committee that definitely

11     we give to the right places so -- as well we want to cover ourselves,

12     myself and Ned, that we didn't take to our family or whatever.  We give

13     to the place that we supposed to.

14        Q.   Thank you.  We saw a transcript today -- or, rather, an

15     intercept -- or, rather, a video-clip.  When General Mladic drove you

16     towards Zepa.  This is what I'd like to ask you now:  Do you know that on

17     that same road, the Muslim side, although it had been agreed that a

18     convoy should be allowed through, they killed a large number of soldiers

19     on the 4th of June, 1992?  Did you hear of that case when we lost these

20     young recruits for no good reason whatsoever?  This was an act of deceit

21     altogether.

22        A.   Yes.  I remember that General Mladic was telling me as well when

23     one Serbian young guy was put on a stick and burned at that area over

24     there, and when he was showing me Muslim house and another Muslim house

25     and so on, I recall.  I was only told what was happening there prior to

Page 25063

 1     General Mladic driving me around.  Yes, that's correct.  All I know what

 2     I been told, yes, sir.

 3        Q.   Thank you.  Did you take this seriously, his joke when he said to

 4     you that he could give you that forest as a present, or was this sort of

 5     playful bragging on his part?

 6        A.   I understood what he was saying.  This was sort of a joke between

 7     him and myself.  He says, You are well-off in Canada.  Come here and you

 8     can get all this after the war and all that.  And I said, Thank you, sir.

 9     No, no, just keep up with work.  And that was sort of really just a

10     kidding discussion, was nothing serious about that.

11        Q.   Thank you.  And also, knowing what had happened in June 1992 with

12     that ambush there, as for what he said to you about the Turks, did you

13     also understand that as a kind of bragging in order to correct the

14     picture a bit with regard to those deaths of ours?  Quite simply, the

15     atmosphere in the car, was it one that was conducive to bragging,

16     exaggeration, and so on?

17        A.   I remember my staying over there that was some kind of an ambush

18     from the Muslim side, that they broke the lines, and they came over to

19     the Serbian Republic side where were the lines, and they removed us from

20     one hotel to the other hotel overnight for our safety.  It was quite

21     dangerous at that time, so -- I was quite myself in shock, Why did I come

22     here?  And I recall that.  That's all I know.  I wasn't told all other

23     things what was going on, just that.

24        Q.   Thank you.  During the previous years and especially in

25     July 1995, when you came to Republika Srpska, did that involve danger of

Page 25064

 1     ambushes, and were measures taken for you to be protected?

 2        A.   Every time I came over myself and with Ned Krajisnik or with

 3     others we were always given sort of security.  We don't know the roads.

 4     We don't know the travel.  And that was from 2000 -- 1992 to 2000 --

 5     1995.  Was always same sort of security from intelligence, Pete Salapura,

 6     but it was much less danger in 1995, as I recall, than 1992 and 1993,

 7     yes.

 8        Q.   Thank you.  Since you've mentioned a small road, may I jog your

 9     memory?  Was it the Zvornik-Crni Vrh-Caparde-Sehovici road and Vlasenica

10     as well?  In this way, one would avoid travelling between Srebrenica and

11     Zvornik.  Was that that road that you took in order to get to

12     Han Pijesak, although it was a road that was much worse?

13        A.   As far as I recall, we took farther road from Srebrenica and I

14     ask why I was told we are going to avoid?  We didn't go -- we went to the

15     Zvornik or closer, Bratunac, to the Bratunac to avoid danger.  That's all

16     I can remember.  It's been a long time.

17        Q.   Thank you.  Tell us, please, you as Serbs from Canada, a country

18     in which there is a culture of democracy, to the best of your knowledge

19     did the Bosnian Serbs do anything for which you would feel ashamed?

20        A.   The media was saying, and from beginning, how Serbs do this, do

21     that, rapes and all other things, killings and everything, and I just

22     couldn't believe it, so I sort of tried to find the true information and

23     truth about it, so I went over ten or some times to see what was going

24     on, and I am satisfied that those things did not happen as they

25     proclaimed, that Serbs were bad as they were painted -- they were painted

Page 25065

 1     and accused of.  It was difficult those years for everybody, including

 2     you, sir, over there with so many meetings and all.  I recall, I can't

 3     even see you.  Out of ten times, I saw you maybe three or five times.

 4     You were always somewhere in a meeting or whatever.  But that was the job

 5     you people had to do, so ...

 6        Q.   Thank you.  You confirmed today that you saw me every other time,

 7     that is to say you saw me considerably less than General Mladic.  Is it

 8     correct that you were turned towards the military and helping the

 9     military?  I'm not saying you personally.  I'm speaking of the

10     organisation as a whole.

11        A.   Well, our organisation, Humanitarian Organisation Republika

12     Srpska, dictate to give the help where it's needed, and as we were going

13     forward and backward and come back with the movies, I saw you, as I will

14     say again, out of ten times maybe four or five times, not all the time,

15     but I saw Krajisnik or others in your headquarters, and mostly every time

16     I saw headquarters of General Mladic, and we give the help -- help and

17     need wherever we could, hospitals and people that they were wounded, and

18     I recall the bishop, we bought some equipment in Kasindol hospital and

19     was a French UNPROFOR there.  Actually, they delivered it.  We paid it

20     for and they delivered it.

21             Yes, we were sort of trying to do the best we can to spread our

22     help all around wherever is required, but was too difficult and is not

23     enough to go around to everybody.

24        Q.   Thank you.  So can we agree that when you were there in July in

25     our area you never heard anything about any killings?  When was it the

Page 25066

 1     first time that you heard there were killing around Srebrenica?  Was that

 2     after you returned to Canada, and when was it exactly, and from what

 3     media did you learn that?

 4        A.   At that time, I was occupied -- my head was occupied and my

 5     travelling and business in Canada as well to get the scanner tube over,

 6     and after scanner tube arrived two days or something that's when I

 7     arrived and I been questioned about the Srebrenica, how come you didn't

 8     know, you didn't know.  I didn't know.  I travelled all night, and I

 9     travelled from Sofia to Belgrade.  I was exhausted and tired.  I didn't

10     heard of any killing or anything until media then carry on and carry on.

11     After few days when I returned to Canada, that was things done in

12     Srebrenica.

13        Q.   Thank you.  When you first heard reports in the media about this,

14     did that bring to mind all the earlier instances of propaganda in the

15     media you, yourself, could see what it was -- for what it was?  So was it

16     the same way of blackening the Serbs, as it were?

17        A.   Yes.  Those things were happening there.  Serbs were painted --

18     painted black even though they weren't guilty.  As I recall discussion,

19     if they kill one soldier, they made a big issue out of it, killing 10 or

20     20, and I question intelligence.  What, did it happen?  No, that's only a

21     media, Pete Salapura says.  Don't believe everything you hear.  So it was

22     tough.  It was tough for everybody there to know the truth.  Somehow we

23     didn't have the finance or anything to have a media, Serbian media or any

24     other media to go there, right, and see what's happening and record it to

25     get some time on CNN or CBC or some other.  It's very difficult to get to

Page 25067

 1     those stations to tell your side of the story.

 2             That's what we went through, and I guess we'll never go through

 3     again, I hope we never do again.

 4        Q.   Thank you.  Do you agree that there was a general prevailing

 5     perception that the Serbs had lost the media war, and was a war also

 6     waged in the media that we never actually took part in, and that is

 7     probably the reason why we had lost it?

 8        A.   Well, the way I understand it, living in a Western country for so

 9     many years, media can make you or break you.  In Canada, if you run for

10     prime minister or party or president, media is a crucial -- crucial

11     things, and TV and publicity and everything.  It was the same in the war.

12             I believe personally that Serbs never had a good media on their

13     side from nowhere at that time.  So, yes, I agree we lost the war in the

14     media and could not be any differently.  I don't see why, but it

15     happened.

16        Q.   Thank you.  This type of biased reporting, did that provoke in

17     Serbs a bitterness, and did the Serbs in Canada find this difficult to

18     cope with the way that the media portrayed the Serbs and whether you had

19     occasion to see for yourself where all those lies were coming from and

20     what the lies were?

21             JUDGE KWON:  Mr. Lesic, I was advised that you are speaking too

22     close to the microphone.  Could you move back just a bit.

23             THE WITNESS:  Sorry, sir.  Unexperienced.

24             JUDGE KWON:  Please proceed, Mr. Lesic.  Could you answer the

25     question.

Page 25068

 1             THE WITNESS:  Yes.  The media in Canada, for a moment I actually

 2     believed that first time I went over what was going on.  Then went over

 3     and I saw for myself, and I even ask and ask over and over, and I was

 4     never given that was -- that media was on the right track.  We were

 5     always, always discriminated.  We had no media on our side.

 6             Just the way we all felt in Canada was rough for us, as I

 7     mentioned earlier, when kids go to school and all that and the war's

 8     every hour or every ten minutes on the TV, so people talk about it and

 9     that's the way it was.

10             MR. KARADZIC: [Interpretation]

11        Q.   Thank you.  Is that how you interpreted the intercept of the

12     conversation between you and General Mladic, that both of you actually

13     hoped that this hunger in the media for sensationalism would be slaked by

14     stories coming from Iraq and that they would sort of leave us aside?

15        A.   During discussion with General Mladic about that incident, yes.

16     I was really hoping that media would leave us alone because they were

17     occupied with Iraq.  Yes.  That was my opinion, and I said that to him is

18     good.

19        Q.   And he agreed with you in that respect?

20        A.   Yes.  Yes.  He agreed with me.  General Mladic agreed with me.

21        Q.   Thank you.  I have to ask you the following:  Is it possible that

22     regarding this meeting with me in 2001, you were confused and that it

23     would have been a different year?  I do understand that it may have been

24     sometime before the year 2000.  So is it possible that an error was made

25     in the year?

Page 25069

 1             JUDGE KWON:  Is this serious?  Is he opening the door to --

 2             MR. ROBINSON:  I hope not.  If you would give me a moment to

 3     speak with him about that, please.

 4             THE ACCUSED: [Interpretation] My apologies.  I was not aware of

 5     the Chamber's decision.

 6             May I take advice from Mr. Robinson?

 7                           [Accused and counsel confer]

 8             THE ACCUSED: [Interpretation] My apologies.  I wasn't aware of

 9     the Ruling and that the extent of things that were excluded was.

10             MR. KARADZIC: [Interpretation]  Mr. Lesic, I thank you for your

11     evidence, and I hope that you didn't find it too difficult.  Thank you.

12     I have no further questions.

13             THE WITNESS:  Thank you.

14             JUDGE KWON:  Yes, Ms. West.

15             MS. WEST:  Just briefly, sir.

16                           Re-examination by Ms. West:

17        Q.   You were just asked a short time ago from Mr. Karadzic whether

18     the Bosnian Serbs did anything for which you would feel ashamed.  Do you

19     remember that question?

20        A.   Yes, I remember.  When I was in Canada, I couldn't believe that

21     they did anything to be ashamed of, so when I went there and I got

22     different story, so I didn't see anything or found anything that Serbians

23     would be ashamed of that.

24        Q.   Okay.  So, Mr. Lesic, do you believe that in 1995 that thousands

25     of Bosnian Muslim men were executed by the Bosnian Serbs in the vicinity

Page 25070

 1     of Srebrenica?

 2        A.   That's what media says, but I did not learn from anybody else.  I

 3     don't know.

 4        Q.   Okay.  And at page 41 of today's transcript, Mr. Karadzic asked

 5     you -- we were talking about feeding a large number of prisoners, and he

 6     asked you whether you agreed that --

 7             JUDGE KWON:  Just a second.  Mr. Lesic, you said that's what

 8     media said, but I did not learn from anybody else.  Did you mean you

 9     didn't know at the time?

10             THE WITNESS:  I didn't know.  I didn't see anything.  I didn't

11     know.

12             JUDGE KWON:  What do you think now, Mr. Lesic?

13             THE WITNESS:  What do I think now?  Yes, there could be on both

14     sides some of it, but not as much as they proclaimed it to be, sir.

15             JUDGE KWON:  Thank you.  Yes, Ms. West, please continue.

16             MS. WEST:

17        Q.   Sir, earlier today you were asked about feeding prisoners of war

18     and specific the question was:

19             "Do you agree that in such conditions it was also rather

20     difficult to feed large numbers of prisoners of war properly?  We could

21     feed them only in the way that we fed our own army."

22             And you were answer was:  Yes, I never saw any prisoners, but I

23     was told and I would presume, yes, if you don't have food enough for

24     yourself then you can't give away much of it either.

25             Now, earlier today you said that you also gave money to the

Page 25071

 1     Red Cross.  Is that true?

 2        A.   Yes, we give Red Cross for the medicine to buy from Galenika in

 3     Belgrade.  In hospitals we give not the big money, $5.000, $6.000 here

 4     and there.  Was not enough to go around.  When we give flour as well

 5     later on.  We helped as much as we could.  But when I said I didn't see

 6     prisoners, I didn't see everywhere prisoners, but in one incident when I

 7     was with bishop I saw some prisoners there, and when I was giving money,

 8     cash money to the people waiting for the bread, I saw there prisoners by

 9     the Banja Luka from Sanski Most, from all over.  Eighty people or hundred

10     people sleep in one big large room.

11        Q.   Okay.

12        A.   One area I didn't see, another area, yes, I did see.

13        Q.   Okay.  But I want to speak more about the issue of food for

14     prisoners.  Are you -- you said you gave money to the Red Cross.  You

15     must be familiar with the Red Cross's job of registering prisoners and

16     feeding them and providing for them.  Are you familiar with that?

17        A.   Not really.  What -- what we did, we go to the little room and

18     they have their thing even for Montenegro delegate.  Six or seven people

19     came from Red Cross from Montenegro to Han Pijesak, and they were

20     Red Cross representative.  They brought help.  And something like that in

21     Banja Luka or in Prijedor or somewhere Red Cross office.  You give them,

22     but we get sort of get the pictures and get the paper certificate, get

23     the receipt for it.

24        Q.   Okay.  Thank you very much, Mr. Lesic.

25             MS. WEST:  Thank you, Mr. President.

Page 25072

 1             JUDGE KWON:  Mr. Lesic, that concludes your evidence.  On behalf

 2     of this Chamber and the Tribunal, I would like to thank you for your

 3     coming to The Hague to give it.

 4             THE WITNESS:  May I ask you, sir, to say couple words in regard

 5     of my witness being here?

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  Mr. Lesic, if you could understand, the Chamber

 8     usually does not hear from the witness out of its formality.

 9             THE WITNESS:  All I want to thank.

10             JUDGE KWON:  Very well.

11             THE WITNESS:  I was very impressed with the witness -- the way

12     witnesses being looked after here and a job well done.  They look after

13     these people and witness and all that, asking them how they feel and the

14     hotel and driving back and forth.  It is well -- well planned, and I want

15     to thank you all the way I was here treated.

16             JUDGE KWON:  Thank you.  Please have a safe journey back home.

17             THE WITNESS:  Thank you, sir.

18                           [The witness withdrew]

19             JUDGE KWON:  Could the Chamber move to private session briefly.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 25073

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             JUDGE KWON:  Yes.  We are in open session.

11             Mr. Tieger.

12             MR. TIEGER:  Mr. President, I'm advised that the next witness is

13     not yet in the building and is, in fact, en route.  I am trying to obtain

14     as clear and specific information about how much time that will take.  I

15     presume it's a matter of minutes, in the order of 15 to 20, but I'd like

16     to get that information as quickly as possible and relay it to the

17     Court.

18             JUDGE KWON:  Given the timing, the Chamber is minded to take a

19     two times half an in our break now.  So starting from now, and we will

20     have just a bit more than one hour session twice.  That may suit the

21     situation.

22             Then we will have a break for half an hour and resume at 20 past

23     12.00.

24                           --- Recess taken at 11.49 a.m.

25                           --- On resuming at 12.27 p.m.

Page 25074

 1                           [The witness entered court]

 2             JUDGE KWON:  Good afternoon, sir.  Will you take the solemn

 3     declaration, please.

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

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

 6                           WITNESS:  LJUBOMIR OBRADOVIC

 7                           [Witness answered through interpreter]

 8             JUDGE KWON:  Thank you, Mr. Obradovic.

 9             Yes, Ms. Edgerton.

10             MS. EDGERTON:  That's fine, Your Honour.  Not a problem at all.

11     Thank you.

12                           Examination by Ms. Edgerton:

13        Q.   General, would you be able to state your full name for us,

14     please.

15        A.   My name is Ljubomir Obradovic.  I was born on January 30th, 1950,

16     in Visegrad, Bosnia-Herzegovina.

17        Q.   Thank you.  Now, General, you've appeared before Judges of this

18     Tribunal before, first as a Defence witness in the trial against

19     General Miletic and others in 2008, and then last year you gave evidence

20     as a Prosecution witness in the Tolimir case; is that correct?

21        A.   Yes.

22        Q.   And before coming here to give evidence today, you had a chance

23     to listen to a recording of your testimony in the Tolimir case in your

24     own language; is that correct?

25        A.   Yes.

Page 25075

 1        Q.   Were you satisfied with the accuracy of the recording?

 2        A.   I think it is identical.

 3        Q.   And if I was to ask you the same questions today that you were

 4     asked during your testimony in the Tolimir case, would your answers be

 5     the same?

 6        A.   Yes.

 7        Q.   Thank you.

 8             MS. EDGERTON:  Now, Your Honours, pursuant to your order

 9     yesterday, we've created a redacted version of General Obradovic's

10     Tolimir transcript, and that's been uploaded as 65 ter 23610.  If that

11     could please be a Prosecution exhibit.

12             JUDGE KWON:  I commend your promptness very much.  Yes.  That

13     will be admitted.

14             THE REGISTRAR:  As Exhibit P4444, Your Honours.

15             MS. EDGERTON:  Thank you.  And as for promptness, I extend that.

16     That's due in large measure to the support that we work with.  Thank you.

17        Q.   Now, General, during your testimony in the Tolimir case, you gave

18     some details about your function.  You said -- actually, I'll start a

19     different way.

20             General, in your Tolimir testimony, you made to clear that you

21     were transferred to the Main Staff of the Bosnian Serb Army on

22     1 September 1994.  Do you remember that?

23        A.   Yes.

24        Q.   And you described your function at page 11929 of the transcript.

25     You said you followed the operative situation and the situation in the

Page 25076

 1     battle-field.  You wrote orders, reports, warnings, plans, and followed

 2     the operative log-books.  Do you remember that as well?

 3        A.   Yes.

 4        Q.   Could you just explain to us briefly how you -- how you were able

 5     to do that job?  What information did you rely on to be able to follow

 6     the operative situation, the situation in the battle-field and write

 7     orders?

 8        A.   All of that was done on the basis of regular daily and interim

 9     reports that we received from subordinate units.

10        Q.   Thank you.

11             MS. EDGERTON:  And before I move on too quickly, Your Honours, I

12     realise I omitted to read the summary of evidence which I would normally

13     have done before this first question.

14             JUDGE KWON:  Yes.

15             MS. EDGERTON:  And I will do that now with your leave.

16             JUDGE KWON:  And I also omitted asking you whether Rule 90(E) is

17     necessary for this witness.  It was given at the Tolimir case, so I need

18     your guidance.

19             MS. EDGERTON:  Indeed.  I think that would be the best way to

20     proceed, Your Honours.

21             JUDGE KWON:  General, probably you are aware of this already, but

22     I would like to draw your attention to a particular Rule here at the

23     Tribunal.  Under this Rule, Rule 90(E), you may object to answering a

24     question from the Prosecution or the accused or from the Judges if you

25     believe that your answer will incriminate you.  When I say "incriminate,"

Page 25077

 1     I mean that something you say may amount to an admission of your guilt

 2     for a criminal offence or could provide evidence that you have committed

 3     an offence.  However, even if you think your answer will incriminate you

 4     and you do not wish to answer the question, the Tribunal has the

 5     discretion to oblige you to answer the question, but in such a case the

 6     Tribunal will make sure that your testimony compelled in such a way shall

 7     not be used as evidence in other another case against you for any offence

 8     other than false testimony.

 9             Do you understand what I have just told you, sir?

10             THE WITNESS:  [Interpretation] Yes, and I was advised of the same

11     in the Tolimir case by the Presiding Judge.

12             JUDGE KWON:  Thank you, General.

13             Yes, Ms. Edgerton.

14             MS. EDGERTON:  Thank you.  And very briefly, the summary of the

15     witness's written evidence as filed is as follows:

16             From September 1994, General Obradovic served as the head of the

17     Operations Department in the administration for operations and training

18     organ of the Main Staff of the --

19             THE WITNESS:  [Interpretation] I'm not receiving any

20     interpretation.  No interpretation.

21             JUDGE KWON:  Did you hear me when I explained the Rules?

22             THE WITNESS:  [Interpretation] I'm not getting any

23     interpretation.

24             JUDGE KWON:  Yes.  I hope you are now hearing me, General.

25             THE WITNESS:  [Interpretation] Yes.

Page 25078

 1             JUDGE KWON:  Yes.  Please continue, Ms. Edgerton.

 2             MS. EDGERTON:  Thank you.

 3             From September 1994, General Obradovic severed as head of the

 4     Operations Department in the administration for operations and training

 5     sector of the Main Staff of the Army of Republika Srpska.  His duties

 6     included following the operative situation, the situation on the

 7     battle-field, and drafting documents which included orders, reports, and

 8     plans.

 9             General Obradovic explains the command structure of the

10     Main Staff of the Army of Republika Srpska.  He identifies in his written

11     evidence core members of the Main Staff of the Bosnian Serb Army and

12     their various areas of responsibility and competence.  He explains the

13     structure of the Main Staff.  He sets out the various duties and

14     responsibilities of different organs, including the

15     67th Communications Regiment, the 10th Sabotage Detachment, the

16     65th Protection Regiment, and the Department of Civil Affairs.

17     General Obradovic explains the timely and accurate reporting system of

18     the Bosnian Serb Army from the lowest level through the Main Staff up to

19     the president, Dr. Karadzic.  He addresses how military directives were

20     prepared with all sectors of the Main Staff taking part in their

21     drafting.

22             General Obradovic will describe the communications methods used

23     by the Army of Republika Srpska.  These allowed for immediate contact

24     between military commanders and their subordinates, including forward

25     command posts, located through Bosnian Serb held territory.

Page 25079

 1             That's the brief summary, Your Honours.

 2             And just your indulgence for a moment to see where I left off.

 3        Q.   Thank you for that answer, General, in relating to the

 4     information you relied on to carry out your function.  I'd like to ask

 5     you for a second about the accommodations of the Main Staff.  Can you

 6     tell us where the Main Staff of the VRS operated from?

 7        A.   The VRS Main Staff, as the high command, was housed in an area

 8     that included an underground facility under the Zep mountain,

 9     Crna Rijeka, and the Han Pijesak town.

10        Q.   Would you be able to describe each of those accommodations in a

11     bit more detail for us in order that the Judges can understand the

12     facilities with a bit more detail, beginning with the last one,

13     Han Pijesak town.

14        A.   Han Pijesak was the place where two sectors were accommodated,

15     the logistics sector and the organisation, mobilisation, and personnel

16     affairs sector, and for a while the moral guidance, religious, and legal

17     affairs sector was housed there as well.

18        Q.   And what kind of facilities were located at Han Pijesak?  Can you

19     describe the actual accommodations?

20        A.   Well, for the most part these sectors were housed in a hotel.  I

21     can't recall what the name of that hotel was.  Some kind of lodge or

22     something like that, but it was a hotel, a catering facility of some

23     sort.

24        Q.   And now moving on to Crna Rijeka.  Could you describe the

25     facilities there?

Page 25080

 1        A.   There were two buildings in Crna Rijeka and subsequently another

 2     one.  They were built -- they were like cabins, log cabins, and they were

 3     there for accommodating the 17th Communications Regiment and also for

 4     parts of the 65th Protection Motorised Regiment.  The staff sector was

 5     housed also in these cabins:  The security and intelligence sector, the

 6     air force and air defence administration, the planning, development, and

 7     finance administration.

 8        Q.   Now, I understood from the interpretation that the buildings the

 9     Main Staff was housed in at Crna Rijeka were log cabins.  Did you mean to

10     describe wooden structures or something else?

11        A.   Well, they were wooden structures, yes, like huts.

12        Q.   Were they prefabricated?

13        A.   Yes.  These structures are used for housing personnel.  They are

14     prefabricated, yes.

15        Q.   And I also understood from the interpretation that you also

16     referred to the 67th Communications Regiment -- - pardon me, the

17     17th Communications Regiment.  Did you mean to refer to the 67th?

18        A.   I did say the 67th Communications Regiment, and parts of it were

19     in Han Pijesak, in Crna Rijeka, and also in the underground facility,

20     because its elements were used to provide certain communications assets

21     and types of communications.

22        Q.   Now, let's talk about that underground facility for a moment.

23     First of all, how far from it was your headquarters at Crna Rijeka?

24        A.   About 2 to 2.5 kilometres, because the entrance to the facility

25     faced Crna Rijeka.  It was on that slope.

Page 25081

 1        Q.   And was the underground facility in constant use throughout your

 2     time in the Main Staff?

 3        A.   As it was an underground facility, it's not very comfortable.

 4     It's not well aired, so it's not a good place to spend time.  We would

 5     stay there only when threatened with NATO bombing.

 6        Q.   The communications facility or a portion of the

 7     67th Communications Regiment was permanently housed there; correct?

 8        A.   Yes.

 9        Q.   How big was the underground facility?

10        A.   It was divided into blocks.  One of the blocks was the technical

11     one, and it had generators for the heating, for ventilation, and for the

12     lighting.  There was also a reservoir with drinking water.  There was one

13     section or part that was used for the communications regiment, and there

14     was a part used for offices and for accommodation for the number of

15     people involved at that level of command.  This facility had been built

16     for the command of the 7th Military District in the former SFRY.

17        Q.   Now, just -- I'd just like to go back to communications for a

18     moment, and I wonder if you can list for us the different means of

19     communication that the Main Staff had available to it throughout your

20     time there.

21        A.   Well, communications can be broken down into command

22     communications, co-operation communications, and intelligence

23     communications.  You can use radio, the wire, relays.  I'm not a

24     communications expert, so I could slip up.

25             As for the equipment, there were automatic telephone exchanges

Page 25082

 1     and various types of relay devices.  Again, it all depended on whom you

 2     had to establish communications with.  The communications equipment used

 3     depends on the unit that needs to use certain kind of equipment.

 4        Q.   Well, let's just talk about telephone exchanges for a second.

 5     How many telephone exchanges did the Main Staff have available to it?

 6        A.   I don't know.

 7        Q.   Did it have a PTT telephone exchange available?

 8        A.   It had an automatic telephone exchange, yes, and there were

 9     so-called civil numbers.  That's what we called them.  That was the case

10     in the corps, and in the Main Staff.

11        Q.   Did it have a military telephone exchange, military switchboard,

12     available to it?

13        A.   I assume that there were a number of such switchboards.  The

14     communications regiment had various types of devices that weren't that

15     large, but as for these fixed exchanges, I think that capacity was far

16     greater, and they had far more extensive series of numbers.

17        Q.   Now, you talked in your Tolimir testimony about extension 155.

18     Do you remember that?

19        A.   Yes, yeah.

20        Q.   Was that part of the military -- a military telephone exchange?

21        A.   Yes.

22        Q.   Now, I'm a bit curious about this three-digit number, actually.

23     This first number, 1, does that -- do people who have an extension with

24     that first number have any specific means of communication available to

25     them?

Page 25083

 1        A.   I wouldn't know.  These are three-figure numbers that each office

 2     had or official in a military switchboard, and this had to do with the

 3     agreement, the mutual agreement reached between the organs of command.

 4        Q.   You talked about relay devices, different types of relay devices.

 5     What did you mean to describe when you referred to them?

 6        A.   Radio relays are used by high-level units.  We communicate over

 7     the phone, but up to a certain relay which then connects to the next

 8     relay where the next unit is located, and then the transmission continues

 9     towards the phones.  These are radio relays, and they can be intercepted.

10     Conversations can be intercepted in spite of the fact that people might

11     be using phone devices, have phones in their hands.

12        Q.   When you talk about these relays being available to high-level

13     units, from what level are you referring to?

14        A.   From the level of the brigade as a tactical unit and upwards.  So

15     the Infantry Brigade, motorised brigades, and other types of brigades

16     that are concerned.  The light brigades did not have such equipment as

17     per their establishment.

18        Q.   Now, in your testimony in the Tolimir case, you talked about an

19     encryption device that you referred to as KZU 63.  Was that a device that

20     was used to protect the relay communications you've just described?

21        A.   Yes.  It could be used to protect radio relays, but it was also

22     used for radio links at a lower level.  It would be installed for two

23     participants, for one participant on one device and for the other on the

24     other device.  So you compress the information and in a very short period

25     of time the information is forwarded.  It is an abbreviation for

Page 25084

 1     crypto-protection device 63.  The number 63 refers to the model.  It is

 2     the year in which the device was produced.

 3        Q.   Was this device part of the normal assets of the corps?

 4        A.   I don't know exactly how many such devices the corps had, but

 5     they did have such devices.

 6        Q.   How would such a device -- or what organ would be responsible for

 7     the supply of such a device?

 8        A.   Planning and organising communications in staff sector is done by

 9     the communications organ.  The implementing communications and having

10     equipment, well, it's the 67th Communications Regiment that should have

11     such equipment at its disposal.

12        Q.   Just by way of an example, in the event of an operation that

13     required the establishment of a forward command post, what would the

14     procurement process be for forward command post to secure one of those

15     devices?

16        A.   If we're dealing with the corps forward command post, then when

17     planning an operation, in addition to all the other tasks that concerned

18     assessing enemy strength, engaging one's own forces and equipment and so

19     on and so forth, in addition to those tasks, the communications organ

20     within the corps would plan for certain communications in accordance with

21     the decision of the corps commander.  And if it was a plan when

22     establishing the forward command post taken -- or drawn up by the

23     Main Staff, when one functioned within the Main Staff you attempt to get

24     the 67th Communications Regiment, so the communication the organ, to plan

25     for the necessary communications system.

Page 25085

 1        Q.   If the forward command post related to an operation that involved

 2     one or more corps and was therefore commanded by a member of the

 3     Main Staff, what would the procurement process then be?  How would they

 4     get one of those devices for the forward command post?

 5        A.   Well, in accordance with the plan for the operation, the last

 6     element of an order or a decision that has to do with the commands and

 7     communications, and in that part of the order the commander will request

 8     the kind of communications that need to be organised, and this will then

 9     be the duty for the communications organ from the staff sector.  They

10     will have to use the 67th Communications Regiment in order to organise

11     such communications at the forward command post in question.

12        Q.   Thank you.  On this subject, actually, I'd like us to look at a

13     document, please, 65 ter 02050, dated 14 July 1995.  It's a document

14     bearing the reference number 04-520-56/95 from General Tolimir to --

15     General Tolimir, who is writing at the time from the 1st Podrinje Light

16     Infantry Brigade, to General Miletic.  And he says:

17             "In order to have a complete review of the Drina Corps command

18     radio network, it's necessary to incorporate the Main Staff of the Army

19     of Republika Srpska in the work plan of the Drina Corps command

20     communication with an RU2/2 radio and a KZU-63 set."

21             Now, relating to what we've been discussing, I have a couple of

22     questions about this document.  First of all, can you tell us what an

23     RU2/2 K set is?

24        A.   It's a radio device.  2/2 K, it's a kind of radio device.  It's

25     the kind of radio device that we had.  A little more modern if compared

Page 25086

 1     to a RUP 12.

 2        Q.   When you say "radio device," do you mean that it's just a radio

 3     or do you mean it attaches to and works in conjunction with a radio?

 4        A.   With your leave, I'll explain the entire document.

 5             JUDGE KWON:  Yes, by all means, General.

 6             THE WITNESS:  [Interpretation] In the heading, you can see that

 7     it's the command of the 1st Podrinje Light Infantry Brigade, and at one

 8     of its command posts there is Major-General Zdravko Tolimir.  It is

 9     obvious that from that location -- it says, "In order to monitor combat

10     activities."  That's with it says in the first sentence:

11             "In order to monitor combat activities around Zepa and gain a

12     complete -- gain complete insight into the Drina Corps radio network with

13     brigade commands, it is necessary for the VRS Main Staff to be included

14     in the Drina Corps command work plan for communications, and it should

15     have one radio RU2/2 with encryption, and it says that all brigade

16     commanders have this equipment."

17             So this radio network is protected by these devices.  So in order

18     to be able to listen to communications between the Drina Corps and his

19     command brigades, because he was in charge of the operation, he needs

20     such a radio device.

21             JUDGE KWON:  Ms. Edgerton, in your question, transcript page 66,

22     line 14 to 16, I said:

23             "If the forward command post relate to an operation that involved

24     one or more corps and was therefore commanded by a member of the

25     Main Staff."

Page 25087

 1             That was your question, and we didn't hear from the witness, and

 2     I wonder why don't you put a question to the witness whether the document

 3     we are seeing now is related to an operation that involved one or more

 4     corps.

 5             MS. EDGERTON:  Thank you, Your Honour.

 6        Q.   General, with respect to the document in front of us which

 7     emanates from General Tolimir, do you know, first of all, whether this

 8     relates to an operation that involves more than one corps?

 9        A.   Your Honour, this document shows that this operation had to do

10     with the Drina Corps.  General Tolimir talks about the operations of the

11     Drina Corps.  He talks about this with the brigade commanders.  If it

12     concerned two corps or more, if this operation concerned two corps or

13     more, then the Main Staff would have the obligation of leading the

14     operation, and then all these types of communications would have been

15     planned and communication with all the participants would have been made

16     possible.

17        Q.   General, you indicated in your Tolimir testimony that you were on

18     leave from January until the 17th of July, 1995.  Now, I wonder after

19     your return to the Main Staff whether you became familiar with the

20     operation that found General Tolimir at the command of the

21     1st Podrinje Light Infantry Brigade.

22        A.   I didn't become familiar -- well, the date here is the

23     14th of July.  I returned on the 17th of July.  I broke my leg on the

24     27th of January, and I recovered and returned on the 17th of July.  But

25     the document shows -- well, I couldn't have even known about this because

Page 25088

 1     the Drina Corps planned this operation, and it's the commander who is in

 2     charge of the operation.

 3        Q.   Just one last question, General:  What was General Tolimir doing

 4     writing the Main Staff from the command of the 1st Podrinje Light

 5     Infantry Brigade on the 14th of July?

 6        A.   Well, I can't tell you what he was doing.  Obviously he was in a

 7     brigade that was subordinated to the Drina Corps.  The Drina Corps

 8     carrying out the operation.  As to whether he received a task from the

 9     commander to gain insight into something or not, I don't know.  I can't

10     answer that question.

11        Q.   In what circumstances would one of the assistant commanders

12     normally be deployed to a brigade headquarters as in this situation?

13        A.   In order to supervise certain combat activities, this can also be

14     done in the field.  As to why Mr. -- why General Tolimir was there, I

15     don't know.  Did he receive an order from the commander or was he simply

16     there and tried to find information and thought that perhaps someone

17     should listen in to the radio network within the Drina Corps in the

18     course of the operation.  I don't know what his position was and on the

19     basis of whose order he was down there.

20        Q.   So one last question before leaving this document.  Based on what

21     I just understand you've said, this equipment would enable whoever has it

22     not only to communicate with units of the Drina Corps command but also to

23     monitor those conversations; is that correct?  Is my understanding

24     correct?

25        A.   Yes.  If they have or if he has the same encryption device.

Page 25089

 1             MS. EDGERTON:  Thank you.  Could I have this as a Prosecution

 2     exhibit, please, Your Honours.

 3             JUDGE KWON:  Yes.

 4             THE REGISTRAR:  Exhibit P4445, Your Honours.

 5             MS. EDGERTON:

 6        Q.   Now, I'd just like to go to one further documents and, to change

 7     topics, back to the Main Staff and the structures per se, and that's

 8     65 ter number 23594, an organigramme of the Main Staff prepared by the

 9     Office of the Prosecutor based on your evidence in the Tolimir case.

10             Now, while we can call this up on the monitors, Your Honours, I

11     think the printing might be kind of small, so we have copies of this in

12     A3 format for Your Honours and for the witness and for the parties.

13             JUDGE KWON:  That's very find of you, Ms. Edgerton.  I take it

14     there is no objection to the addition of this and other documents to the

15     65 ter list, Mr. Robinson.

16             MR. ROBINSON:  That's correct, Mr. President.

17             JUDGE KWON:  It's granted.

18             MS. EDGERTON:  If you could just in the fullness of time pass one

19     copy to the witness as well, I'd like to ask him a question about it.

20             JUDGE KWON:  I was told that he has it.

21             MS. EDGERTON:  He doesn't have a paper copy, Your Honour, and

22     just so he can see more clearly.

23             JUDGE KWON:  It's on its way.

24             MS. EDGERTON:

25        Q.   Now, General, do you remember looking at this organigramme

Page 25090

 1     yesterday in preparation for your testimony today, setting out some of

 2     the formations and structures of the Main Staff?

 3        A.   Yes.

 4        Q.   Now, at the time, you noted that the organigramme was accurate

 5     but for the omission of reference to General Mladic's office; is that

 6     correct?

 7        A.   The office, the cabinet, doesn't relate to the commander.

 8        Q.   Where would that fit into this organigramme?

 9        A.   Well, here to the right.  You can see the where the sector for

10     co-operation with foreign military representatives is, so it would be in

11     that area.

12        Q.   And who staffed that cabinet, to your recollection?

13        A.   Well, I can't remember, but I do remember Rajko Banduka.  He left

14     an impression on me, so I do remember him.

15        Q.   Do you remember what his job was?

16        A.   Well, he was a secretary.  I didn't have a secretary, so I don't

17     know anything about the nature of his work.

18        Q.   Now, having a second look at this document today, did --

19        A.   I apologise.  On the whole, he'd make notes, help the commander.

20     He would plan his agenda, receive calls, and so on and so forth.  He

21     would sit in the office that was next to the commander's office.

22        Q.   And where was that?

23        A.   In the Zep Goljak 1 facility, G1.

24        Q.   Just one question regarding the commander's office.  Did he share

25     that office with anyone?

Page 25091

 1        A.   Well, I don't know.  That office is at the very entrance into

 2     this underground area, as you call it.  So this entrance is marked by --

 3     is masked, rather, by this villa, and in this villa there were a few

 4     rooms and that's where the commander was and his closer co-workers from

 5     the cabinet and from security.

 6        Q.   Did the commander have an office at each of the three Main Staff

 7     facilities you've mentioned?

 8        A.   No.

 9        Q.   Where was -- where were his offices then?  And just to be

10     perfectly clear, when the commander was at the Main Staff, where was

11     that?

12        A.   He was staying at the entrance at this villa before you enter the

13     underground.  When he'd come, he would just go to anybody's office to get

14     some business done, usually at the chief's office or some other close

15     co-worker.  Over their barracks, he did not have an office that was

16     particularly his.

17        Q.   I've just understood you to say, Over the barracks, he didn't

18     have an office that was particularly his.  What do you mean by that?

19     Over what barracks?

20        A.   Well, I mean there was no office where he would be the only

21     person who would be signature there and nobody else.  If you have an

22     office, you are in that office.  However, if your boss were to be

23     appointed commander, then he would come to get something done with you,

24     and he'd come to your office to get that done.

25        Q.   Now, you've just said there was no office where he would be the

Page 25092

 1     only person who'd be sitting there and nobody else, so who did he

 2     normally sit with?

 3        A.   Yes.  Well, for the most part he was up there, up there, this

 4     establishment facility where his room was, his bedroom or the room where

 5     he slept and where he worked, and downstairs he'd usually go to see his

 6     assistants who were there, or he'd come to that small operations room

 7     where we were.  I mean, there was not a particular place that had been

 8     envisaged for him to be there permanently.

 9        Q.   Just one last question.  When you say "he was up there," General,

10     I'm afraid we don't know what place you mean by that.  So what do you

11     mean?

12        A.   You insist, or you think that down there where the barracks are

13     in Crna Rijeka, you're insisting on some room that he was staying at all

14     the time.  He did not have any such room.  When he'd go by car

15     2.5 kilometres, if he needed to exchange something with someone, then

16     he'd do that with the assistants.  If he wanted to visit and check, then

17     he'd see everybody.  If he had some business with the intelligence

18     people, then he'd stop by and see them.  If he had something to talk to

19     the operations people, us, then he'd stop by our office and see us.  So

20     he did not have this particular place where he would come all the time.

21        Q.   Thank you.  Now, just to go back to the organigramme, having a

22     second look at this since you last did, the day before yesterday, do you

23     have any information additional that you wish to add to it, anything you

24     feel needs to be filled in to make it accurate?

25        A.   Well, nothing.  I remembered my testimony in the Tolimir case.

Page 25093

 1     The last name of the colonel who headed the communications unit was

 2     Gredo.

 3             MS. EDGERTON:  Thank you, with that, could we have this as the

 4     next Prosecution exhibit, please.

 5             JUDGE KWON:  Yes.

 6             THE REGISTRAR:  Exhibit P4446, Your Honours.

 7             JUDGE KWON:  Ms. Edgerton, I didn't go through the Tolimir

 8     transcript, but I take it he explained the meaning of the dotted line on

 9     this organigramme.

10             MS. EDGERTON:  He did not, Your Honour, and it's something I'd

11     actually like to come back to in the presentation, which is why I wanted

12     it dealt with up front --

13             JUDGE KWON:  Thank you.

14             MS. EDGERTON:  -- if I may.

15        Q.   Now, General, in your Tolimir testimony you explained the combat

16     reporting system of the Army of Republika Srpska and how it worked from

17     the brigade level right up to the Main Staff.  You referred to the

18     Main Staff's reporting obligation to the supreme commander, Dr. Karadzic.

19     You explained how reports were prepared, who prepared them, and how

20     reports from subordinate units were excerpted and incorporated into the

21     Main Staff's report to Dr. Karadzic, and you were shown some examples of

22     this.  That's in your Tolimir testimony at pages 11966 to 11982.  Do you

23     remember all that?

24        A.   Yes.

25        Q.   Thank you.  I'd like to ask you some additional questions about

Page 25094

 1     reporting and then turn to a series of documents.  My first question is:

 2     Did forward command posts have the same reporting obligation as other VRS

 3     units?  And I mean forward command posts at all levels.

 4        A.   Yes.  Forward command posts wrote daily operations reports and

 5     combat reports just like all other units for the area for which they had

 6     been established, and they sent this in encrypted form to the Main Staff.

 7        Q.   The reports that came to the Main Staff from the corps, were

 8     those also in encrypted form or did that depend on the situation?

 9        A.   Well, most often they were sent in encrypted form.

10        Q.   Would reports from the forward command posts come to the same

11     organ as the reports from the corps, the operations sector, in other

12     words?

13        A.   Yes.

14        Q.   In addition to the receipt of written reports from subordinate

15     units, did the commander General Mladic also --

16             JUDGE KWON:  I'm sorry to interrupt him.  I'm not sure I

17     understood the last question and answer:

18             "Q.  Would reports from the forward command post come to the same

19     organ as the reports from the corps, the operations sector, in other

20     words?

21             "A.  Yes."

22             If it is addressed to their organ, or does it mean that any

23     report from the IKM go to any command?  Could you clarify?

24             MS. EDGERTON:  Of course I could, Your Honour.

25        Q.   Was there a particular sector that received reports -- particular

Page 25095

 1     Main Staff sector that received reports from the corps?

 2        A.   Your Honour, I explained that in the previous trial.  Within the

 3     administration for operations and training, in addition to the operations

 4     department and the training department, it was envisaged by establishment

 5     to have a third body that was called the operations centre.  According to

 6     establishment, it was supposed to have a higher ranking officer as the

 7     head of this centre and to higher ranking officers as shift leaders.

 8     Since we did not have enough personnel, this centre never became

 9     operational.  So all these reports from the corps, from the

10     anti-aircraft, from the schools, and so on, and forward command posts

11     came to the Main Staff, addressed to the Main Staff, to the staff sector,

12     to the administration for operations and training.

13             JUDGE KWON:  So I take it that that organ or that unit receives

14     all the reports addressed to the Main Staff?

15             THE WITNESS:  [Interpretation] Yes.

16             JUDGE KWON:  Thank you.

17             MS. EDGERTON:

18        Q.   Thank you very much.  In addition to these written reports from

19     all these units, did General Mladic also have direct contact with the

20     corps commanders?

21        A.   Yes.  He had direct communication with corp commands.  That was

22     envisaged by the rules and instructions, and he had direct communication

23     with all.

24        Q.   And similarly, did he have direct communication with forward

25     command posts for particular operations?

Page 25096

 1        A.   Well, they were not permanent, but he did have relay

 2     communication with certain protection involving encryption.

 3        Q.   This direct communication with the corps commands, you referred

 4     to it being envisaged by the rules and instructions.

 5        A.   These are stationary communications.

 6        Q.   Did they occur with any regularity?

 7        A.   Well, once they were established, they were there throughout.

 8     Command posts of corps did not physically change their positions.

 9             JUDGE KWON:  Ms. Edgerton, we are on some irregular schedule

10     today.  If it is convenient, we will take a break.

11             MS. EDGERTON:  Oh, any time, Your Honour.  I had no idea when the

12     break might be so I just thought I would continued until warned.

13             JUDGE KWON:  Thank you.  We will take the break for half an hour

14     and resume at 2.00.

15                           --- Recess taken at 1.30 p.m.

16                           --- On resuming at 2.02 p.m.

17             JUDGE KWON:  Yes, Ms. Edgerton.

18             MS. EDGERTON:  Thank you, Your Honours.

19        Q.   General, just to continue where we left off before the break, I

20     understood you to be saying that once the lines were established,

21     General Mladic was in, effectively, permanent communication with the

22     corps commanders; is that correct?

23        A.   Every point in time he had the possibility of having direct

24     communication with his subordinate commanders.

25        Q.   Did he do that by using any special system?

Page 25097

 1        A.   No.  It was a very ordinary Iskra switchboard, and when he'd

 2     press a button without dialling a dial, he could communicate with the

 3     commanders when they were at the headquarters of their respective corps.

 4        Q.   Just for those people who don't quite understand what Iskra

 5     means, maybe you could explain.  I'm sorry about that.

 6        A.   It's the make, the manufacturer from Slovenia that was called

 7     Iskra, from the town of Kranj.

 8        Q.   Thank you.  Now, how often or was there a routine to how often

 9     General Mladic would speak with the corps commanders?  Did he do it every

10     day, every second day?

11        A.   Well, I cannot speak about each and every day specifically.

12     Perhaps every afternoon towards the end of the day.

13        Q.   And similarly, do you have any idea how often he might speak with

14     forward command posts?

15        A.   I cannot answer that, because I was not there sitting with the

16     commander, so I cannot -- I mean, it's someone who was with him all the

17     time that could answer that.

18             JUDGE KWON:  What forward command post did you mean,

19     Ms. Edgerton?

20             MS. EDGERTON:  Sorry, Your Honour.  I was referring to those that

21     the general had mentioned shortly before we broke, and I'll just, with

22     your indulgence for a second, scroll back up to see the reference.

23             I'll clarify.  The reference was at page 77, line 7.

24        Q.   In the event one of the assistant commanders was deployed to a

25     forward command post for a particular operation, do you have any idea how

Page 25098

 1     often General Mladic would be in contact with the assistant commander?

 2        A.   I can speak specifically about the point in time when I was at

 3     the western front, Jasenica and Drvar.  Usually when this assistant

 4     commander would return from the field, reports would be written once they

 5     were received from units, and they would be formulated so as to be sent

 6     to the Main Staff.  The commander would sometimes call the forward

 7     command post via safe communication equipment the commander, in this

 8     specific case, General Milovanovic, and ask about the situation in that

 9     particular area.

10             JUDGE KWON:  I'm sorry to interrupt you so often, but let me be

11     clear.  To understand the meaning of deployment, what I understood from

12     your evidence, General, is that assistant commander can be sent out to

13     field.  For example, to monitor or to control whatever, and then he can

14     use the facilities in the forward command post to communicate with his

15     commander.  Am I correct in so understanding?

16             THE WITNESS:  [Interpretation] Yes.  The forward command posts

17     were established with a view to having direct insight into and influence

18     over combat operations.  At these forward command posts, all types of

19     communications are organised like at basic command posts, except that

20     they're on a smaller scale.

21             I specifically spoke about the time when I was at the western --

22             JUDGE KWON:  Then were you said to be deployed at that specific

23     forward command post?

24             THE WITNESS:  [Interpretation] Yes.

25             JUDGE KWON:  Yes, Ms. West -- I'm sorry, Ms. Edgerton.

Page 25099

 1             MS. EDGERTON:

 2        Q.   This system you've just spoken about for communication with the

 3     corps commanders where General Mladic would press a button, was that a

 4     protected means of communication, free from interception?

 5        A.   We believed that it was a protected means of communication, but

 6     how protected it actually was, I don't know.

 7        Q.   Now, just in terms -- or still on the subject of communication

 8     with assistant commanders, would the Main Staff have briefings?  Would

 9     the Main Staff sectors and administration heads depicted in that

10     organigramme gather for briefings with the commander?

11        A.   At certain points in time when necessary and when the commander

12     would ask for such a meeting, yes.  Within the sector and other sectors

13     within their own sectors, we had meetings every morning discussing our

14     work.

15        Q.   Do you know how often the inner circle of the command, if I can

16     call it that, would meet to discuss issues?

17        A.   I cannot say.  Probably they were held often without my being

18     aware of it.  It's very few people involved.  At some office, at the

19     commander's ...

20        Q.   I think the last part of your answer wasn't heard.  What I see

21     you've said is, "At some office, at the commander's."  Would you like to

22     add to that?

23        A.   Well, either at the commander's or in one of offices of one of

24     the assistant commanders or of the Chief of Staff or the assistant for

25     morale, logistics, et cetera.  These are six or seven people plus the

Page 25100

 1     commander.

 2        Q.   The Main Staff's daily combat reports, those sent to --

 3     particularly those sent to the supreme commander and the corps commands

 4     that you discussed in your Tolimir testimony, how frequently were those

 5     sent?

 6        A.   The daily operative combat reports were sent as follows:  One for

 7     the preceding 24 hours, that is to say it pertained to the 24 hours that

 8     had elapsed.  These are regular reports, whereas extraordinary reports

 9     were sent when necessary, and in that way subordinate units reported to

10     the command, the Main Staff, about the situation in their respective

11     areas of responsibility, that is to say about the enemy, about their own

12     forces, about neighbours, and about decisions taken by commanders, and of

13     course they pointed out what the requirements and needs of their corps

14     were.

15        Q.   So reports were sent to the supreme commander on a daily basis.

16     Do I understand correctly?

17        A.   Yes.

18        Q.   Would the supreme commander also be sent extraordinary reports

19     when necessary?

20        A.   If an extraordinary report would arrive from a corps, we would

21     incorporate it into the next one, or if there was something important --

22     well, I did not have that kind of a situation that in my presence an

23     extraordinary report would be sent especially to the commander and to

24     other corps.  For the most part, they were sent all together.

25        Q.   Were they transmitted by secure means?

Page 25101

 1        A.   They were transmitted through secure means, encrypted.

 2             THE ACCUSED: [Interpretation] I believe we should intervene in

 3     the transcript.  The witness said to the Supreme Command, not to the

 4     supreme commander.

 5             JUDGE KWON:  Very well.  Could you clarify, General Obradovic?

 6             THE WITNESS:  [Interpretation] We sent reports to the

 7     supreme commander.  We addressed them to the supreme commander.  However,

 8     they went also to the Ministry of Defence, to the president of the

 9     Assembly, the prime minister, and the minister of the interior, as well

10     as to the forward command posts and all corps commands for their

11     information so that they would be informed of the situation in the entire

12     theatre of war.

13             Now, here the question was about these extraordinary or interim

14     reports.  I did not take part in any forwarding of such reports, and that

15     couldn't be the case anyway before the Chief of Staff was informed of it,

16     because this interim report was meant to be resolved, so if it was

17     resolved by the chief of staff then there was no reason for it to be sent

18     to the Supreme Command.  That would depend on the contents of the interim

19     combat report.

20             MS. EDGERTON:

21        Q.   In what way?

22        A.   Well, whether the information that was contained in the interim

23     combat report was of interest to the Supreme Command or whether it was

24     just of relevance to the Main Staff.

25        Q.   Just one question relating to your earlier answer:  How do you

Page 25102

 1     know that these reports were sent to the minister of defence, the

 2     president of the Assembly, the prime minister, and the minister of the

 3     interior?

 4        A.   Well, I know because at one point in time all of these instances

 5     were mentioned in the address block, and then it would say to the command

 6     of subordinate units.

 7        Q.   Would the assistant commanders also receive copies of these

 8     reports?

 9        A.   No.  They were not addressed to them unless they were at the

10     forward command post, and then they would receive it as the corps command

11     for the entire -- a bit of information for the entire theatre of war.

12        Q.   Now, in addition to these written reports, do you know whether

13     the commander or other members of the Main Staff had meetings with

14     Dr. Karadzic?

15        A.   Well, I assume that they did, but I can't really say with

16     certainty.  If there was a meeting of the Supreme Command and if

17     representatives of the Main Staff were invited to that meeting, then they

18     would be there; if not, they wouldn't.  But I don't know.  I don't have

19     information to that effect.

20             MS. EDGERTON:  Your indulgence for just a moment, please,

21     Your Honours.

22        Q.   General, hearing your answer to that question, I thought I might

23     turn to a transcript of your evidence given when you appeared as a

24     Defence witness in the Popovic case, and I see at page 28244 you were

25     asked by Mr. Petrusic:

Page 25103

 1             "General, do you have any knowledge whether the representatives

 2     of the command of the Main Staff have meetings with the civilian state

 3     leadership of the Republika Srpska, the government of the

 4     Republika Srpska?"

 5             And your answer was:

 6             "Yes."

 7             Do you remember that question and that answer?

 8        A.   Yes, I do, and I think it had to do with -- it was within the

 9     context of an analysis of combat readiness, and when such analysis were

10     discussed, then there would be political representatives attending.

11        Q.   Thank you.  I'll leave that for the moment but come back to it in

12     due course.

13             THE ACCUSED: [Interpretation] Could we get the reference again

14     for that transcript page from the Popovic case?

15             JUDGE KWON:  It's on the transcript.  It says 28244.

16             THE ACCUSED: [Interpretation] Is it correct?  Could you please

17     help with us a line citation?

18             MS. EDGERTON:  Of course.  Lines 1 to 6.

19             THE ACCUSED:  [No interpretation]

20             MS. EDGERTON:

21        Q.   In addition to these written reports and the meetings you've just

22     referred to, did General Mladic or other members of the Main Staff have

23     direct telephone contact with Dr. Karadzic?

24        A.   They did have a communication line.  Now, whether it was a direct

25     line or whether they had to use the PTT lines, I don't know, but they

Page 25104

 1     were at Pale.

 2        Q.   And just to go back to those written reports for a moment before

 3     moving forward, you indicated that they were sent by secure means.  Would

 4     that imply that all the recipients would have had some way of protecting

 5     that information or decoding that information at the other end?

 6        A.   I don't think so.  I think it was printed out at one spot and

 7     then from there it was disseminated to other addresses, taken there.

 8        Q.   When those reports were sent to Pale, to the supreme commander,

 9     where would they be sent to and what then would happen to them next?

10        A.   I don't understand your question.

11        Q.   Well, you just said that they were printed out at one spot and

12     from there it was disseminated to other addresses.  So my question is:

13     What was the spot at Pale they were printed out at?

14        A.   It was the seat of the government.  They would have had to have

15     some kind of communication unit that would have encryption equipment, and

16     then once it was printed out it would be done at that one spot because

17     not every minister would have one of these encryption machines.

18             This is my assumption.  I don't know exactly how it worked, but I

19     assume they don't have so many -- they didn't have so many encryption

20     devices there.

21        Q.   All right.  Now just a question again about communications.

22     Based on your field experience that you talked about in your Tolimir

23     testimony where you were deployed to the command post at the western

24     front, did Dr. Karadzic have direct contact with the assistant commander

25     on that occasion or during that period because it was a lengthy

Page 25105

 1     deployment?

 2        A.   Your Honour, in the Tolimir case I spoke about the general

 3     practice, which was that at the forward command post, they would have

 4     communications established towards the Main Staff and other points, but I

 5     wasn't present to witness possible communications between

 6     General Milovanovic and the president.

 7        Q.   These reports that were disseminated, I think you would agree,

 8     were of a very detailed nature; correct?

 9        A.   Well, they were lengthy.

10        Q.   Could the president issue orders based on the information in

11     those reports?

12             THE ACCUSED: [Interpretation] My remark was that this was a

13     leading question, and it did not make it into the transcript.  That was

14     my prior remark to the previous question.

15             JUDGE KWON:  You mean lengthy?

16             THE ACCUSED:  Line 13.  No detailed nature.  The previous

17     question in interpretation I received that it was a leading question:

18     You would agree, wouldn't you, that they were of a very detailed nature;

19     correct?  The question should have been:  Were they detailed?

20             JUDGE KWON:  Let's proceed.  The witness answered anyway.

21             Ms. Edgerton, I was looking at the previous set of question and

22     answer.  You mentioned a communication with assistant commander, but the

23     general spoke about General Milovanovic.

24             MS. EDGERTON:  I apologise for not naming him.

25             JUDGE KWON:  Were you satisfied with his answer?

Page 25106

 1             MS. EDGERTON:  Yes.

 2             JUDGE KWON:  Very well.  But I take it General Milovanovic was

 3     not one of the assistant commanders.

 4             MS. EDGERTON:  Perhaps I could ask the question to the witness.

 5             JUDGE KWON:  Yes.  Yes.

 6             MS. EDGERTON:

 7        Q.   General, when I referred to communications with the assistant

 8     commander during your deployment to the western front, did you understand

 9     me to be referring to General Milovanovic?

10        A.   Yes, because I was at a forward command post only where -- in a

11     situation where he was the leading commander there, and per

12     establishment, he's also the deputy commander.

13        Q.   And within the Main Staff, within the corps of the Main Staff,

14     did General Milovanovic have the designation "assistant commander"?

15        A.   Well, generally speaking, the chief sector, the staff chief of

16     sector for logistics, for moral guidance, for personnel, security and

17     intelligence and these two independent administrations, planning,

18     development, and finance, and air force and air defence, they were

19     referred to as assistant commanders.  However, General Milovanovic per

20     establishment was the Chief of the Main Staff, and at the same time he

21     was the deputy commander.

22        Q.   Thank you.  To move back to these reports that we've been

23     discussing, could the president issue orders based on the information

24     contained in these reports?

25        A.   The contents of the report would not be the decisive factor in

Page 25107

 1     whether the president would order it or not.  He had the discretion to

 2     bypass the Main Staff, but how it went, I don't know the details.  But

 3     generally speaking and under the rules of service, the second-in-line

 4     commander could issue an assignment to the second subordinate, and he

 5     could say that he received such and such a task from the second in

 6     command.

 7        Q.   Could you just explain for us, please, second-in-line commander,

 8     what you mean by second-in-line commander and second subordinate?  It

 9     might be easier to do that by reference to their titles.

10        A.   For instance, let's take the 1st Krajina Corps.  The commander of

11     the 1st Krajina command -- Krajina Corps has as the first superior the

12     commander of the Main Staff, and his second in command is the supreme

13     commander.  In other words, the supreme commander can issue an assignment

14     to the 1st Krajina Corps, but the commander of the 1st Krajina Corps

15     would have to inform of that his immediate superior, in other words, the

16     commander of the Main Staff, that he had been issued such and such an

17     assignment or a task from the supreme commander.

18             Now, whether there were such instances of bypassing the immediate

19     superior within the chain of command, I don't know, but I just talked

20     about this as general possibilities within the rules.

21        Q.   Even if the immediate superior had been bypassed in the issuing

22     of an order by the president, would the recipient of that order

23     nevertheless be duty-bound to comply with it?

24        A.   Well, that's just what I've tried to explain.  He is duty-bound

25     to implement that order, but at the same time, he would have to report

Page 25108

 1     immediately to his immediate supreme -- to his immediate commander of

 2     this assignment.

 3        Q.   Thank you.  I'd like to actually look at a document, please,

 4     65 ter 07514.  It's an order dated 24 April 1994, from Dr. Karadzic to

 5     the Main Staff, the commander, and the Chief of Staff personally, and

 6     members of the Main Staff, and corps commanders for information,

 7     responding to their report.

 8             Now, General, I know you've seen this document the day before

 9     yesterday in preparation for your testimony today, but because it's a bit

10     of a lengthy one, I wonder if you could take a few minutes to go through

11     the couple of pages that it is and tell us when you've had a chance to

12     have a look at it.  And could you make the English side a little bit

13     smaller, please, so we can see the full page, if you can.

14             If you can scroll down just a little bit now.

15             Do you remember seeing this in preparation for your testimony

16     here today, General?

17        A.   Yes.

18        Q.   Can we go over now to the next page of this document.

19             Now, General, this document refers to a number -- or this order

20     refers to a number of things, including a withdrawal of forces of the

21     Army of Republika Srpska, the disposition of heavy weapons, the equipping

22     and disposition of mobile weapons, and the consolidation of positions.

23             On receiving such an order, would the Main Staff then normally

24     issue further orders and communications to subordinate units?

25        A.   Could we please go back to page 1.  In this order we see that the

Page 25109

 1     addressees are the Main Staff of the VRS, and then to the commander and

 2     Chief of the Main Staff personally, and then on line 3, it says:

 3             "For information to members of the Main Staff and all corps

 4     commanders."

 5             In other words, this order makes it obligatory to the Main Staff

 6     to inform thereof the most responsible members of the Main Staff and the

 7     corps commanders of this order.  I don't know exactly when this was.  I

 8     see that it is dated the 24th of April, 1994.  I was not in the

 9     Main Staff then, so I don't know whether it was sent in writing or how it

10     was communicated, but the command of the Main Staff was duty-bound to

11     implement it.

12        Q.   Now, if we could just go down to paragraph 3 of this document

13     that refers to convoy movement and the instruction that these convoys

14     will be authorised by --

15        A.   I can't see that part.

16             THE ACCUSED: [Interpretation] In Serbian that should be on

17     page 2.

18             MS. EDGERTON:  Is there anyway of --

19             THE WITNESS:  [Interpretation] Yes.  Now I can see it.

20             MS. EDGERTON:  Is it just me or is there anyway we can have the

21     English as well as the B/C/S version, because -- thank you.

22             JUDGE KWON:  Third page.

23             MS. EDGERTON:

24        Q.   Now, do you see the line at the bottom of the third paragraph

25     that says:

Page 25110

 1             "... these convoys will be authorised by a co-ordinating body,

 2     and the Main Staff of the Army of Republika Srpska will be kept

 3     informed"?

 4        A.   Yes.

 5        Q.   Now, I want you to recall in your Tolimir testimony at

 6     page 12022, you explained that -- you explained the process for requests

 7     for convoy movement by UNPROFOR and international humanitarian

 8     organisations and you said that all convoy requests were received by fax

 9     in the department headed by Djurdjic, and he took them to the commander

10     for approval.  It was up to the commander to approve these requests or

11     not to approve them.

12             So I'm wondering, actually, how this document and mention of the

13     co-ordinating body fits with your explanation about the processing of

14     convoy requests within the Main Staff?

15        A.   The UNHCR convoys and UNPROFOR convoys were the types of convoys

16     that existed.  UNPROFOR was -- was a peacekeeping military formation,

17     whereas the UNHCR was humanitarian aid, and it was approved by the

18     co-ordinating body.

19        Q.   So then what was the relationship between the co-ordinating body

20     and the department for civilian affairs within the Main Staff?

21        A.   This co-ordinating body informed by fax which convoys and along

22     which routes and what their destination was were approved and -- or

23     whether they were not approved.  And as for the UNPROFOR supply convoys,

24     approval for them came from the army.

25             MS. EDGERTON:  Do you know who was in charge of this

Page 25111

 1     co-ordinating body?

 2        A.   Well, I've already said that I believe Professor Koljevic was.

 3     I'm not absolutely certain, but I think it was him.

 4             MS. EDGERTON:  Could this be a Prosecution exhibit, please,

 5     Your Honours.

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  Exhibit P4447.

 8             THE INTERPRETER:  The Registrar is kindly requested to repeat the

 9     number.

10             THE REGISTRAR:  Exhibit P4447.

11             MS. EDGERTON:  Thank you.

12        Q.   Could we go to another document related to convoy movement,

13     65 ter 03512.  It's correspondence from the VRS Main Staff to the

14     Sarajevo-Romanija Corps and Drina Corps command dated 6 March 1995.  This

15     document informs the corps commands of convoys which have been approved

16     and instructs them to inform the check-points in order to prevent

17     unapproved movement.

18             Now that we've got the document on the screen in front of us,

19     General, I'd actually like us to go to the signature block on the very

20     last page, please.

21             Now, General, this document has got General Miletic's signature

22     block, and just above that is a line that reads in your language "zastupa

23     nacelnika staba," which I understand means "standing in for the Chief of

24     Staff"; is that correct?

25        A.   That is what it should mean.  However, during my previous

Page 25112

 1     testimonies, I did say that I have never seen an order on this kind of

 2     standing in.  There was no need for that because the Chief of Staff was

 3     never absent from the territory of Republika Srpska.  Perhaps this was

 4     just incorrectly written.  However, a stand-in commander would have all

 5     the powers that the office that he represents should have.

 6        Q.   How -- could you -- because we looked at a large number of

 7     documents issued or signed by General Miletic in this way the day before

 8     yesterday, I wonder if you could explain in a little bit more detail this

 9     term "standing in," and perhaps in that regard I could just ask you one

10     question.  What kind of circumstances -- in what kind of circumstances

11     would someone be asked to stand in for a commander?

12        A.   The commander has to have someone to stand in for him if he is

13     prevented from carrying out his duties for a certain period of time.  An

14     order has to be written on having a person stand in for the commander in

15     this way, and that is in accordance with the Law on the Army.  A person

16     who also has to stand in commander, in addition to his regular duties,

17     has all the authorities and powers of the position that he is in as a

18     standing commander, measures of reward, repression, everything.

19             Here, specifically, General Milovanovic is present in the area of

20     responsibility of the Army of Republika Srpska.  He probably did give

21     some kind of authority, but he should not have said "zastupa."  It should

22     have said "for the Chief of Staff" or "in accordance with the order of

23     the Chief of Staff."  As far as I know, no such order was ever written,

24     and General Miletic did not have the powers that the Chief of Staff has.

25     He could sometimes tell him to organise something within the work of the

Page 25113

 1     staff sector, but not both of them could have the powers of the Chief of

 2     Staff, and they are -- and they are present there.

 3        Q.   So then in this context, what kind of freedom of action would

 4     General Miletic have?

 5        A.   What the Chief of Staff would give him, tell him, that he should

 6     stand in for him in some domains of his work, but he would certainly not

 7     transfer all authority to him.

 8             If you remember my CV, it says at some point in time, in addition

 9     to being the Chief of Staff of the 327th Brigade, I also stood in for the

10     commander in his position two times during six-month periods, and I

11     enjoyed all benefits then, the benefits and everything that is given to a

12     commander.

13        Q.   So in this context, in General Miletic's context, do I understand

14     you to be saying he's limited by directions he receives from the Chief of

15     Staff?

16        A.   Yes.

17        Q.   Now, in the process of convoy requests, review and approval that

18     you described in your Tolimir testimony, at what point would a direction

19     like this to the corps have issued?  And I wonder if we could go back to

20     the first page in both languages, please.  Top of the page in B/C/S.

21             What -- in other words, what happens to a convoy request before a

22     document like this issues?

23        A.   Your Honours, this department for civilian affairs that is

24     attached to the commander as it says here, they receive fax messages.

25     Now, whether they are weekly -- I mean, are requests submitted weekly or

Page 25114

 1     does it happen every time a convoy is supposed to pass, then

 2     Colonel Milos Djurdjic, the head of this department, would collect all of

 3     these requests and go to see the commander.  The commander would look at

 4     all of them together with him, and then perhaps he could say a few things

 5     to him in relation to that activity, because that is the only thing that

 6     he did, that Djurdjic did.  And the commander on the margin of these

 7     faxes wrote that he approved of this or that he imposed certain

 8     restrictions with regard to the passage of convoys.

 9             When they would go through all these documents, then the other

10     man would go back to the department and write up this kind of document.

11     This was open communication.  That is what it says up here, above

12     Sarajevo-Romanija Corps.  And then when he would write that information

13     that had to do with the mentioned units, then since the Chief of Staff

14     would not be there, then he would go to General Miletic for him to sign

15     it because his right was to communicate with subordinates just in that

16     way.  He could sign this information, only Colonel Djurdjic did not have

17     this kind of authority.

18        Q.   Just two questions, quick questions about the -- a couple of

19     notations on the document.

20             First of all, the number that appears above the date, number

21     06/18-104, does that number designate anything in particular?

22        A.   I think that that's the number of the log-book of Djurdjic's

23     department.

24        Q.   And what about the first number, 06?  Does that mean anything in

25     particular?

Page 25115

 1        A.   That is a designation of the department.  I don't know exactly

 2     now.  I cannot remember right now.

 3        Q.   And if we can just --

 4        A.   So if you look at this total number, 104, you see, 106/18, that

 5     is the department.  And then -104, that is the 104th number in the

 6     log-book.  So it was registered under that number.

 7        Q.   Thank you.  If we can just display the handwritten notes.  At the

 8     top of the page for the General.  Right there.

 9             General, what do those handwritten words Bresa, Domar, and Caura

10     mean?

11        A.   These are code-names of brigades that are the addressees to whom

12     this document is being sent.  These are code-names, secret names.

13        Q.   And finally, can we just go down to item 5 on this list in both

14     languages, please.

15             The last question on this document, General.  Could you have a

16     look at item 5 on this list and tell me whether you see any military

17     reason for the Main Staff to be concerned with the passage of a convoy

18     between Sarajevo and Kiseljak, the one listed here, which was to supply

19     drinks, suites, and potato chips for the canteen.

20        A.   I cannot say.  It has to do with provisions for the canteen, and

21     that is a military catering facility.

22             MS. EDGERTON:  Could I have this document as a Prosecution

23     exhibit, Your Honours?

24             JUDGE KWON:  Yes.

25             THE REGISTRAR:  Exhibit P4448, Your Honours.

Page 25116

 1             MS. EDGERTON:  Your Honours, I would next move into one more

 2     document which would take probably more time than we have.  I'll do

 3     whatever I'm instructed, but I was just having a quick look at the clock.

 4             JUDGE KWON:  We'll adjourn for today.  We resume tomorrow morning

 5     at 9.00, General Obradovic.  Oh, yes, we are sitting, because of some

 6     certain circumstances, we will resume at 1.30.

 7             Probably you are aware of this, but you are not supposed to

 8     discuss with anybody else about your testimony.  Do you understand that,

 9     sir?

10             THE WITNESS:  [Interpretation] Yes, I do.

11             JUDGE KWON:  The hearing is adjourned.

12                           --- Whereupon the hearing adjourned at 2.59 p.m.,

13                           to be reconvened on Thursday, the 23rd day

14                           of February, 2012, at 1.30 p.m.