1 Wednesday, 23 January 2013
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, everybody.
7 Good morning, Mr. Harvey.
8 MR. HARVEY: Good morning, Mr. President. And may I say it's a
9 pleasure to see Judge Lattanzi restored to us. And may I introduce,
10 please, Kalin Stoyanov from Bulgaria, a law student here at The Hague who
11 has been with my team since October of last year. Thank you.
12 JUDGE KWON: Thank you.
13 Yes, Mr. Karadzic. Please continue.
14 THE ACCUSED: Good morning, Excellencies. Welcome, Honourable
15 Judge Lattanzi. [Interpretation] Good morning to all.
16 WITNESS: DRAGOMIR MILOSEVIC [Resumed]
17 [Witness answered through interpreter]
18 Examination by Mr. Karadzic: [Continued]
19 Q. [Interpretation] Good morning, General, sir.
20 A. Good morning.
21 Q. Can you please tell us where you were when the war broke out in
22 Slovenia and Croatia. Where were you and what was your post?
23 A. Well, I've just understood. I wasn't in Slovenia when the war
24 broke out. I was in another area when the war started in Slovenia. I've
25 just now understood what you are asking.
1 When the war broke out in Slovenia and Croatia, I was in the area
2 of Bosnia-Herzegovina, in Han Pijesak. I was brigade commander, of
4 Q. Which brigade was that?
5 A. This was the 216th Mountain Brigade. It belonged to the
6 4th Sarajevo Corps, and it was part of the then new system to the
7 2nd Military -- it was part of the 2nd Military District.
8 Q. Thank you. And you mentioned some difficulties in mobilisation
9 yesterday, so we can skip that, but if you can just briefly tell us how
10 the mobilisation proceeded in 1991, and how did the first mobilisation
11 proceed and then the second one?
12 A. I don't remember talking about problems. I just said that the
13 brigade was mobilised. Therefore, yes, that is correct. As for this
14 second part about problems, that is even more correct, I mean now that I
15 hear it this morning.
16 The brigade that I was in command of comprised 50 per cent of the
17 Muslim population and 50 per cent of the Serb population. So it was a
18 very rational structure, and it corresponded to the place, the area, that
19 was -- that the troops were being drawn from. It was an excellent unit,
20 and it was a good system until the -- the system of mobilisation or
21 gathering the men broke down. The structure worked very well both as far
22 as the civilian structure was concerned and as far as the military
23 conscripts who manned the brigade. It all functioned very well. It was
24 a very broad area around Srebrenica, Zvornik, Kladanj, Olovo, Rogatica,
25 Sokolac, Han Pijesak. That was the territory that was being mobilised
1 and where we drew our forces from.
2 And then on the 30th of June, 1991, an order was issued on the
3 mobilisation of the brigade, and then both -- members of both ethnic
4 groups responded to the call-up, the Serbs and the Muslims. However, in
5 the meantime, the Bosnia and Herzegovina leadership, in this case the
6 Muslim part, issued instructions to their soldiers and to their
7 population, their people, not to respond to the mobilisation, and then we
8 had the situation in which I concluded actually these same soldiers were
9 the ones who most regretted that this had happened. Some did obey that
10 instruction or order. Many of them did not. So then there was a very
11 difficult situation then for the survival of the brigade in that
12 composition and also as far as the possibility of engaging the brigade in
13 any kind of capacity. These conscripts, these soldiers, did not create
14 any problems other than not responding, and those who did respond were
15 loyal. Their conduct was normal. They could see that everything was all
17 Later this escalated, so then a selection was made later so that
18 later all of them left the unit and did not respond to the call-up any
19 more for the brigade and that was it.
20 Q. I would like to ask you to give as brief answers as possible,
21 although it's good to hear it all, but we do have a limited amount of
22 time at our disposal.
23 Who was authorised to order the mobilisation, and who issued the
24 mobilisation order in June 1991?
25 A. I know who issued the order to me, but who issued the order to
1 them is something that I cannot confirm. I was given the order by the
2 corps commander. There was a written order issued, and then the
3 mobilisation got underway, that procedure got underway.
4 Q. And the Presidency of Bosnia-Herzegovina, was it in its full
5 composition or was it the Rump Presidency, but did it have the authority
6 to issue the mobilisation order?
7 A. Well, it was a matter for the Yugoslav People's Army. So it
8 wasn't the Territorial Defence that was being mobilised, but it also
9 belonged to the whole of Yugoslavia, like the army did. So I assume that
10 they did not have the authority to do that, because they interfered. And
11 I know who they mobilised.
12 Q. Thank you. And who was your deputy? Who was the Chief of Staff
13 of the brigade?
14 A. Well, the question is very specific. It is not just who was my
15 Chief of Staff, if you permit me to say. The Chief of Staff specifically
16 was Lieutenant-Colonel Asim Dzambasovic [Realtime transcript read in
17 error "Dzambasevic"]. However, the structure of the command, I would
18 say, was absolutely multi-ethnic, and the chief of security was a
19 Slovenian. The main operative officer was a Muslim. The chief of the
20 technical service was Hungarian. It was a wonderful structure. It was a
21 team that one could work with absolutely.
22 Q. Thank you. And can you please tell us how long these people
23 stayed in the unit? When did Dzambasovic leave and when did the
24 Slovenian and Hungarian leave and so on and so forth?
25 A. Lieutenant-Colonel Dzambasovic belonged to the type of people who
1 were reasonable, educated, trained in the military sense, and he was just
2 a normal man to work with and to co-operate with. I cannot specify
3 exactly when he left. I cannot give you the date, but it was in that
4 initial period. Actually, no, no. It was in 1992, 1992. If I'm not
5 mistaken, it was in late 1991, early 1992. He asked in regular channels
6 to leave to go to the corps command, to go and report to the corps
7 commander and to see with him what would happen afterwards. I provided
8 him with a vehicle. I provided him with staff to transport him. So it
9 was a relationship of a civilised nature between people who respect each
11 Q. Thank you. And where were you and the unit when the conflict
12 broke out in Bosnia-Herzegovina, and what happened with the unit while it
13 was still part of the JNA?
14 A. In view of the fact that this is a bit detailed to say where it
15 was, I mean, it was in a number of places on a wide area, and in the
16 context of the whole situation, at the point in time when the conflict
17 became more serious and before we realised that the conflict would
18 escalate, the brigade was in the Mesici sector. This is close to the
19 Drina River. Raca or Praca and Visegrad, that's where we were, and we
20 waited for a solution.
21 Q. And how did the brigade find itself in Sarajevo, on whose orders,
22 and where was it deployed, and what were its tasks? It's a complex
23 question, but I know that you will give us a detailed answer in any
25 A. As I already said, the brigade was in the Drina River Valley, in
1 the area from Mesici to Visegrad. Along the depth it was in Rogatica
2 sector and so on and so forth.
3 At the point in time when - how shall I put it? - the escalation
4 occurred or events that had to do with pulling out the column of the
5 2nd Military District command from Sarajevo and from the Bistrik area,
6 that's when the situation began to become complicated. I had the
7 impression that the corps commander made an assessment that the brigade
8 should come to Sarajevo probably in order to assist in the withdrawal of
9 the forces of the 2nd Military District.
10 I'm not going to go into that. If somebody's in command, they
11 know what their criteria are, and by getting there there was no way that
12 we could help in any way this command of the 2nd Military District, even
13 if we had helicopters and parachutes.
14 So the brigade reached the Lukavica sector. The situation was
15 underway with this column from Sarajevo. It was in progress. The column
16 was cut in half. They fired at those people, and a part of the column --
17 I heard all of this, and I could see that it was going on. I could hear
18 that it was going on. I couldn't see it. And then those who were
19 wounded or killed there, nobody could help them, and those who in the
20 meantime had managed to get out, they just said what had happened. And
21 my brigade happened to be in the staging area in Lukavica without any
23 Q. Thank you. And where was this brigade deployed later, and what
24 happened to it when the JNA withdrew?
25 A. The brigade was deployed in the Grbavica sector, a part of
1 Lukavica, to Vraca and then up there the area below mount Trebevic or
2 close to Trebevic.
3 Q. And was the Jewish Cemetery also in the area of responsibility of
4 the brigade, Bosut and the Jewish Cemetery?
5 A. Yes, yes. Bosut is a military facility, and it's a
6 communications centre. It's a building with all the equipment and
7 installations inside. There's no staff or personnel to defend it. Of
8 course, the area of Bosut was supposed to be secured. I received an
9 order to deploy a part of the forces to protect Bosut.
10 Q. Thank you. And what happened with the brigade when the JNA
11 pulled out and when the Sarajevo-Romanija Corps was formed?
12 A. I went through the situation, because the cadres, the personnel,
13 the officers who were in the brigade had come from all over Bosnia and
14 Herzegovina and from outside of Bosnia and Herzegovina. They were
15 permitted to pull out and go back to Serbia or Montenegro, to that
16 territory. I personally felt that there would be some difficulties and
17 problems, considerable problems. However, we managed to deal with that
18 by additionally engaging the existing cadre so that the command
19 continuity of the forces could be maintained, and we adapted the
20 structure to the given situation, to the conditions, and to the system of
21 command which was possible to apply at the time.
22 Q. Did the brigade change its name, and did its area of
23 responsibility change?
24 A. Yes. The brigade was renamed after the divisions, and it was
25 called now the 1st Romanija Brigade and was part of the
1 Sarajevo-Romanija Corps. And my apology, I'm not sure I heard your
2 second part of your question.
3 Q. Well, the area of responsibility, did that change?
4 A. No. The area of responsibility remained as it was at the outset
5 when we arrived there.
6 Q. How many battalions did you have?
7 A. Well, as I've said, the -- the team or the group, the entire
8 unit, was a wonderful unit. You could use them in very difficult
10 The brigade was left without some battalions that had remained in
11 the area, for instance, in Vlasenica. The brigade had two battalions,
12 but we started a new recruitment procedure, mobilisation, from Sarajevo
13 and Lukavica so that we replenished -- rather, brought up the personnel
14 and manpower level to three battalions, and it existed in this form for a
15 while. That's how it [indiscernible], but later on it grew and became a
16 little bigger, and it was active in the wider area of Sarajevo.
17 Q. Thank you. Can you tell us when you arrived, what did you find
18 there? With units in terms of the municipality, the area there,
19 territorial units, what did you find? What situation did you find, and
20 what happened with those units?
21 A. Yes. Well, they reported to me, and I had contact with them as
22 well. This was a brigade that was called the Novo Sarajevo Brigade of
23 Territorial Defence, and when the name Territorial Defence was lost, then
24 it was just called the Novo Sarajevo Brigade, and it remained as part of
25 the defence of the Republic of BH as a whole.
1 Now, as far as I can remember, the commander of the brigade was
2 Mr. Garic. He was a reserve officer from the area itself. They had two
3 battalions, that was their structure, and they explained to me where they
4 were. And the third battalion was on the other side in Pofalici. In
5 other words, behind the Marsal Tito Barracks, on the slopes of the area
6 that gravitates towards Sarajevo.
7 I asked him whether they were able to command that battalion,
8 because there was already an obstacle between them. They had no contact
9 except for radio contact, and they said, Yes, we can maintain contact
10 with them.
11 This battalion later had a disaster met -- a disaster of sorts,
12 not the battalion itself but the people. There was a raid and an
13 incursion of certain forces from Sarajevo and these people were
14 massacred. And that brigade, Garic's brigade, could no longer count on
15 any help from that battalion, but, rather, should rely only on the forces
16 that were on the southern side.
17 Q. Thank you. The Territorial Defence structure that you found when
18 you got there, was it in keeping with the Law on All People's Defence and
19 Social Self Protection or was it a paramilitary force of sorts?
20 A. No. As long as it was Territorial Defence, of course, it
21 couldn't be a paramilitary force. It was structured and formed on the
22 basis of the regulation that were in place and they existed as such.
23 Q. Thank you. General, sir, how long did you remain in the post of
24 commander of the 1st Romanija Motorised Brigade, and where did you go
25 from there?
1 A. I was commander of that brigade until the end of 1992, but more
2 accurately, what -- I left the brigade and I happen to recall this by
3 chance, I left on the 4th of February, 1993. I remember that, because
4 that was my birthday. So I left the brigade and handed over the command
5 to the Chief of Staff, Lieutenant-Colonel Savcic, and I went to the
6 Drina Corps where I was the Chief of Operations of the corps.
7 Q. Thank you. Did you return at any point to
8 Sarajevo-Romanija Corps? If so, when and to what position?
9 A. That's nicely put, when did I return, but please bear with me,
10 but it would be probably better to say I -- it would have been better if
11 I had not returned, but perhaps then you won't take me seriously.
12 Well, I returned toward the end of June 1993.
13 Q. And to what position were you assigned?
14 A. I was the Chief of Staff of the Sarajevo-Romanija Corps.
15 Q. How long did you remain in the Sarajevo-Romanija Corps, and what
16 positions did you fill?
17 A. Well, from early July 1993, I was the Chief of Staff in the corps
18 up until August 1994, more specifically until the 10th of August, when I
19 was appointed corps commander, and I remained in that post through the
20 end of 1995 and early 1996.
21 Q. Can I take it that as the second person and then the first man of
22 the Sarajevo-Romanija Corps as of July 1993 up until the end of war, your
23 adversary was the 1st Sarajevo Corps of the BH Army?
24 A. Well, your question is good, but it wasn't that I had an
25 adversary. It was the Sarajevo-Romanija Corps that had on the other side
1 the 1st Corps of the Army of Bosnia and Herzegovina.
2 It's very important for me to point out at this point that these
3 were two armed forces that were well acquainted with one another. I
4 would say they were acquainted in detail. Neither me nor my command or
5 my superiors never -- we never thought or were deluded thinking that the
6 adversary didn't know us, didn't know much about us. Well, in the same
7 manner we knew very well what their strategy would be, what their
8 employment would be, their activities. I would say that we knew it to
9 the last little detail, because this was the same people.
10 Q. Does that imply that you also knew the deposition, the deployment
11 of forces, the weapons that they had, the infrastructure? And I'm asking
12 you about the entire 1st Corps of the Army of Bosnia-Herzegovina.
13 A. Well, you cannot command successfully unless you are very
14 familiar with your enemy, and I can confirm here that the deployments,
15 the engagement, the combat fighting, the objectives and intentions, we
16 were very well aware of all of those so that we knew what objectives they
17 had, what intentions they had, and what their purpose was.
18 Q. Thank you. How did you learn these things, or in what manner or
19 manners did you get by information of this nature?
20 A. Well, yes. There were several ways. There were a number of ways
21 that we learned about them. The troops -- or, rather, the command, first
22 of all, relies on its intelligence. The collection of data and their
23 analysis would be cross-checked and compared, so one of the sources of
24 information was intelligence.
25 The other manner was this: We were brought to the point where we
1 had to organise an observation system that would confirm the movements
2 and measures and actions taken by the enemy at any particular moment. So
3 there was the observation system or surveillance.
4 The next -- the next manner would be this: On a daily basis,
5 citizens left Sarajevo. They found different ways to accomplish this,
6 and they would provide information to us about what they had seen there
7 and what deployments they had observed, what forces were there, and so
8 on, and of course we had to check this. It is no secret that soldiers
9 informed one another mutually. In other words, from either side, because
10 the lines were very close. They were some 50 metres away, one from the
11 other, so that they communicated amongst themselves, not in terms of
12 providing information, but there were contacts.
13 And the next way, and I think that's probably the most reliable
14 way was that we would assess what the situation was and see what the
15 enemy was employing, what forces, whether they were employing strong
16 forces or weaker forces. So through all these manners, we would -- it
17 would come to the point where we knew everything about our adversary.
18 Q. Could you tell us how, in a bit more in detail, how and when you
19 knew the enemy would use stronger or weaker forces? How does ...
20 A. Well, I understand what you're asking me. That's clear to me,
21 but I don't think that was a decisive element. But it was significant,
22 because then we would adapt our own deployments and employment of forces
23 in order to create a situation where we would not be caught by surprise.
24 Q. Thank you. General, sir, on page 11 you said that you were
25 familiar and that you knew the objectives, the intentions that they were
1 trying to accomplish and the purpose of their actions. Could you tell
2 us, first of all, what type of establishment and organisation did the
3 Army of Bosnia and Herzegovina adopt, including that of the 1st Corps in
4 Sarajevo? Did that differ in some way? What was the type of
5 organisation and structure that they had?
6 A. I understood your question. I have to try to be more precise in
7 my answer in terms of their organisation and formation from the time when
8 they started establishing it at the time when I assumed my post. There
9 was a difference between the early period when they were organised and
10 the second period.
11 Specifically, in 1994, they transitioned to a new type of
12 organisation, new to them. This is not new in the history of the
13 military, but there was this: The command -- brigade commands were
14 attached to the corps command, and that's how this structure functioned.
15 But in the second half of 1994, the 1st Corps of the BH Army transitioned
16 to a new system, the so-called division establishment or system, and
17 specifically they established three divisions. Of the three, one was
18 deployed in Sarajevo. That was the 12th Division of the ground forces.
19 The second one was the 14th Division, which was deployed in the
20 Tarcin sector, which means to the west of Ilidza. And the next division
21 is the 16th Division, whose command was in the Varos sector. This is to
22 the north-west of the theatre in -- vis-a-vis Sarajevo. So there were
23 these three divisions.
24 The corps commander maintains the command in addition to these
25 three divisions that were later structured, and I will explain that in a
1 moment, but he also commanded six independent brigades that were not
2 attached to the divisions. He referred to them as light brigades. Light
3 brigades because they were manoeuvring units. They were not active in
4 combat but were to be used for action along a certain axis.
5 So this was the global structure of the corps. So the command of
6 the corps and its organs, the military police battalion, and the forces
7 that were attached to the corps as a rear structure.
8 Would you like me to describe the structure of the 12th Division?
9 Perhaps I can do that. It's important and topical in view of the fact
10 that these two other divisions were outside of Sarajevo, but this one was
11 deployed in Sarajevo itself.
12 Q. Could you use this map to show the Chamber the locations of these
13 division. This is 1D7048 in e-court. Could we please have that map on
14 our screens, and then I'll be asking General Milosevic to use the map to
15 indicate these positions for us.
16 THE ACCUSED: [Interpretation] 1D7048, please.
17 THE WITNESS: [Interpretation] I'm not sure we can actually see
18 anything on this one.
19 MR. KARADZIC: [Interpretation]
20 Q. I have nothing showing in e-court. Could you please, sir, use
21 the map on your left-hand side right behind you. Thank you.
22 JUDGE KWON: Just a second. Can we not upload it?
23 [Trial Chamber and registrar confer]
24 JUDGE KWON: I was told that the Registry got an error message
25 because it might be too big in its size.
1 THE ACCUSED: [Interpretation] All right. In that case, I would
2 like to ask General Milosevic --
3 JUDGE KWON: I think it's uploaded now.
4 THE WITNESS: [Interpretation] It's uploaded, but it's still
5 difficult for me to see.
6 MR. KARADZIC: [Interpretation]
7 Q. General, sir, you can point out the positions for us on the big
8 map on your left-hand side, and then everybody else can follow on their
9 screens if they like.
10 JUDGE KWON: Just a second. Mr. Karadzic, do you want the
11 witness to mark on this map or just to explain the general layout?
12 THE ACCUSED: [Interpretation] If the general sees the map clearly
13 enough, it would be very good if he could mark for us the contacts or the
14 units of the BH Army that he was actually clashing with, the three
15 divisions first and foremost, and then he can tell us about the meaning
16 of these markings, 3K, 2K, 4K.
17 THE WITNESS: [Interpretation] All right. I'm getting started.
18 I'll start with positions inside Sarajevo city. As I said, position here
19 fighting actively and engaged here is the 12th Division. The location of
20 Sarajevo city itself, you can see it on this map.
21 I'm not sure if I should mark it at all. It's plain for all to
22 see, Sarajevo, the city itself. The 12th Division --
23 MR. KARADZIC: [Interpretation]
24 Q. Can you just put 12D right next to it. Thank you.
25 A. [Marks]
1 All right. That's that position. I know it all too well, if I
2 can put it that way.
3 As for their operations, the operations that they conducted in
4 the actual fighting, well, we'll be showing that in due course.
5 Q. Can you please mark out the 14th Division of the 1st Corps for us
7 A. Not likely, unfortunately. I can't mark the whole sector for
8 you, but I can draw an arrow there to indicate the general direction in
9 which they would operate. I can't quite see it on the map. But here,
10 I'll mark this, although it's for the working.
11 Q. Do you see this bit where it says "OG Pazaric"? Can you see
13 A. No, it's not on my map. Oh, right. Okay. It's there. All
14 right. Yes. Operative Group, that's right, near Pazarici, the distance
15 being maybe 5 to 7 kilometres. We have Tarcin. So this is sort of on
16 the Herzegovina side, and that's where the command of the 14th Division
17 was positioned. Its exact combat disposition is something that I can't
18 be very specific about because they held all of this western side of the
19 territory under their control. It's difficult to locate each and every
20 individual unit that belonged to that division, but I can only tell you
21 that they were facing us.
22 Q. How far in the direction of the city centre did they ever get,
23 the 14th Division?
24 A. Yes. That's an excellent question. They covered Igman,
25 Hrasnica, Sokolovic Kolonija, and Butmir, and Kotorac, Donji Kotorac
2 Q. Thank you very much.
3 JUDGE KWON: Before going further, could you tell us as to the
4 provenance of this map?
5 THE ACCUSED: [Interpretation] I think General Milosevic could
6 probably tell us about that. We shouldn't move it about too much before
7 it is signed, but perhaps we could explain.
8 THE WITNESS: [Interpretation] I read on the map itself that it is
9 a working map, but that's all that I have been able to ascertain. I
10 don't know the provenance.
11 MR. KARADZIC: [Interpretation]
12 Q. General, sir, could you perhaps check the physical map over there
13 to your left and then see whether you can tell who it belonged to, who it
14 was produced by?
15 JUDGE KWON: In your back, you can take the actual map. Left, to
16 your left, on back side. There. No. Can you see the actual map which
17 is managing on the -- yeah, there. Please look back. You can move, yes.
18 Yes. Do you know what -- the provenance of this map?
19 Could we show the top of the map. It shows Radna Karta or
20 something. Could we unclip the left.
21 Yes. Whose map is this, Mr. Milosevic?
22 THE WITNESS: [Interpretation] This is a war map of the
23 Sarajevo-Romanija Corps.
24 JUDGE KWON: Thank you.
25 THE INTERPRETER: Interpreter's correction: "This is a working
1 map of the Sarajevo-Romanija Corps."
2 MR. KARADZIC: [Interpretation]
3 Q. General, sir, it says the 1st of July, 1994. Did I see that
5 A. Yes, quite right. That's what it says.
6 Q. Thank you. Could you please draw a line, a simple line,
7 connecting the positions of the 14th Division that were closest to you in
8 the city and Pazaric?
9 A. Can I please erase the previous mark that I left there? It's a
10 very poor mark.
11 Q. Yes.
12 A. Right. Fine. So I was trying to draw that arrow before, but
13 that was about something else.
14 It was in this area that the command of the 14th Division was
15 located. This area right here which I'm about to mark is the area
16 covered by the 14th Division along with its 104th Motorised Brigade. So
17 the X that I drew there, the 104th. If you like, I can mark that for you
18 too. 104th Motorised Brigade.
19 Q. At their forward end, facing you, in other words, could you put
20 an arrow there to mark how far they got in your direction, which is the
21 city itself, and what ground specifically did they cover there?
22 A. I don't seem to be very good at drawing things, do I. The area
23 that I marked is about Hrasnica, as far as I can tell. That is the
24 Hrasnica area. But this arrow does not underline the fact sufficiently,
25 because it's showing in exactly the opposite direction. The closest area
1 covered by this brigade is Hrasnica, Sokolovic Kolonija, Butmir, and then
2 down the depth of Igman.
3 Q. Where was the border between you and them in relation
4 specifically to the location of the airport?
5 A. They had some forces in Butmir and some in Donji Kotorac.
6 Q. Thank you, General. No need to worry about your drawing skills.
7 I'd just like to tell you that.
8 JUDGE KWON: Speaking for myself, I have difficulty following
9 this line of evidence. While this is a map that was produced at the
10 time, i.e., July 1994, why do we not see the markings then on this map of
11 14th Division of 104th Unit, et cetera? Why should we rely on the
12 markings of the general now, and what are these markings then which we
13 see on this map?
14 THE ACCUSED: [Interpretation] I'm about to ask the general that
15 very same thing.
16 MR. KARADZIC: [Interpretation]
17 Q. General, this is a working map of the Sarajevo-Romanija Corps.
18 What about these markings, PRB and so on and so forth? What exactly does
19 that mean? And were the enemy units marked on that map as well?
20 A. This is a rough disposition and positions of the units of the
21 Sarajevo-Romanija Corps and their engagement. Anything that was outside
22 these areas, well, that was the enemy, such enemy forces as actually
24 If we were talking about Ilidza, so we're looking at the
25 Ilidza Infantry Brigade. If we're talking about Hadzici then that would
1 be the Igman Infantry Brigade. If we're look at the area surrounding
2 Rukavica and Trebevic, then that would be the 1st Sarajevo Brigade. If
3 we're talking about area just north of Rajlovac, Vogosca, and all the way
4 up to the eastern side where the Miljacka River meets the city at
5 Sarajevo, that's the 3rd Sarajevo Brigade.
6 Q. Yes, but why don't we have the structure of the 1st Corps based
7 on divisions? On the 4th of July, 1994, were they organised like that
8 already, a division-based structure?
9 A. That's quite right, and that's a good question. They had a
10 brigade-based system back then, not a division-based system. The
11 1st of July, 1994, no such thing around -- was there. It wasn't before
12 the latter half that they started restructuring. And then the names were
13 new, the numbers were new, and the whole organisational structure was
15 Q. Did that change anything about the confrontation lines,
16 specifically the forward ends?
17 A. No. They're restructuring effort did not affect the combat
18 disposition at all. Well, aside from the fact that the units now had
19 different names and numbers.
20 Q. General, sir, I'm looking at Pazaric and Tarcin. Can you mark
21 that as 14D, please, 14D. And then also mark for us the sector covered
22 by the 16th Division.
23 A. [Marks].
24 Q. Thank you. The 16th Division, please.
25 A. You can't actually see part of it on this map, but ... [Marks]
1 Q. Thank you. Can you please explain to the Chamber what this
2 means, 3K and then the number 2 over there?
3 A. Please try to understand me in the right way. It doesn't mean a
4 thing. 3K, that should mean the 3rd Corps. The trouble is it wasn't
5 there at all. So I think it's a mistake that they actually marked this.
6 Right where it says 3K, this was actually covered by the 16th Division
7 and not the 3K that they had in mind. So I stick to my previous remark.
8 I think this is an error in marking.
9 Likewise, here you can see 4K, meaning that on at that side, so
10 from Tarcin onwards in that general direction, which is Mostar, 4K should
11 be the 4th Corps.
12 So you could take that at face value, but what we see around the
13 Sarajevo-Romanija Corps -- I hear some background noise. What you can
14 see about the Sarajevo-Romanija Corps, that is the 1st Corps of the
15 BH Army, including the brigades that I specified earlier on. So I'm not
16 talking about the 3rd Corps and the 4th Corps and others. I'm not saying
17 they were actually involved in the fighting. What I'm saying is there
18 was no direct line of contact between them and us at the outset.
19 Q. All right. Tell us about the meaning of that red line just
20 outside the contact zone between 3K and 16D, the red line reaching the
21 lower end of the map.
22 A. Yes. You can see it going through Sarajevo and also beyond. The
23 third line represents the forward end of the defence of the
24 Sarajevo-Romanija Corps.
25 Q. General, sir, I did not mean the dotted line. I meant the full
1 line there between the number 1 that we see there and --
2 A. Yes. Essentially that is the area of responsibility of the
4 Q. Can you mark that on the map, please.
5 A. Yes. We'll use a small cross to mark that, and then we'll call
6 it "Area of responsibility of the SRK." I have trouble finding my feet
7 in terms of how things are actually marked on this screen.
8 Q. You mentioned the 2nd, 3rd, and the 4th Corps that you were not
9 in contact with. Can you please tell us if there was any fighting with
10 those corps and on which occasions?
11 A. First of all, we had battles with the 2nd Corps throughout the
12 war; in the sense that the 101st Olovo Brigade from the area of Olovo, an
13 inhabited town, that 101st Glorious Brigade, as they called it, was part
14 of the 2nd Corps of the B&H Army, and it was in contact with us in the
15 Nisici sector, the broader area of the Nisici sector, the village of
16 Krivajevici, and so on and so forth. And to be more precise, the
17 Gajne [phoen] village area where the Sarajevo-Romanija Corps was in
18 contact with the Drina Corps, that's where the initial contact and the
19 conflict with this 101st Brigade began, and that stretched further, our
20 disposition, and now I'm talking about the contact with the 16th Division
21 under the Zvijezda mountain. Then it lay below mount Cemerska, the
22 broader are of the inhabited town of Breza, up to Visoko, and then from
23 Visoko up to Fojnica and then all the way to Mount Igman.
24 Q. Thank you. Can I ask you to tell us how long was your forward
25 end on the outside edge with the enemy and how long was it in the inner
1 perimeter around the city centre?
2 A. We were in the city centre. This is what I'm trying to say.
3 Q. Yes. Yes. Thank you. You are correct. But can you please tell
4 us how long the contact -- the line of contact was between you and the
5 12th Division.
6 A. Sometimes these estimates are not precise. However, using the
7 instruments that we had to measure this length, we calculated that it was
8 somewhere in the area of 50 kilometres. The total area of our forward
9 defence and was 240 kilometres from the north, north-east to be more
10 precise, from the north-east through these areas that I mentioned below
11 mount Zvijezda and then Visoko up to mount Treskavica is 250 kilometres;
12 or, if I were to use different parameters, from -- then from the extreme
13 right left wing [as interpreted] of the corps to the extreme left wing, I
14 would need 250 kilometres length along the front.
15 Q. Based on this map, can you also tell us which area on the map
16 could be considered to be an area where there was no front, no firing, to
17 be an area where life was normal?
18 A. No. There is no area there without fierce fighting. Of course,
19 the intensity of the fighting centred on Sarajevo, mutual fighting, but
20 there were situations, very difficult ones at that, when the intensity of
21 fighting would increase precisely from the sectors of the 16th and the
22 14th Division, and of course in strict joint action with the
23 12th Division.
24 Q. Thank you, General, sir. Could I please ask you to put your
25 initials and the date in the lower right-hand corner. And I would like
1 to draw everybody's attention to P842. This is a map, a Prosecution
2 document that perhaps demonstrates the structure of the divisions in the
3 1st Corps.
4 A. You want me to put the date here?
5 Q. Yes, in the lower right-hand corner. Could you please put
6 your -- date and have no concerns about your handwriting. We are all
7 aware that you did lose an eye in the war.
8 A. [Marks]
9 THE ACCUSED: [Interpretation] Your Excellencies, thank you very
10 much. I would like to tender the map.
11 JUDGE KWON: Could you kindly turn back and read the legend for
12 us, which is on the left bottom of the map. You can see it on the actual
13 map. Could you read out for us the three lines.
14 A. In the first line, "Line of contact." Second line says "Line of
15 contact as of the 3rd of August, 1994." And the third line states "Line
16 of contact as of the 24th of May, 1994." Actually, no, I apologise. The
17 24th of August, the 24th of August, 1994.
18 JUDGE KWON: Thank you. We'll admit this marked map as well as
19 the unmarked map.
20 Do you have any objection, Ms. Edgerton?
21 MS. EDGERTON: No, and Dr. Karadzic was quite right. P842, if
22 part of the point of this was to illustrate the division structure, is
23 the map that is the witness's own map that sets that out.
24 JUDGE KWON: Thank you. Shall we give the number.
25 THE REGISTRAR: Yes, Your Honours. The unannotated map which is
1 65 ter 1D7048 will be Exhibit D2788, and the annotated version will be
2 Exhibit D2789.
3 JUDGE KWON: Thank you. Please continue, Mr. Karadzic.
4 THE ACCUSED: [Interpretation] Thank you. We don't need to look
5 at the map any more. Thank you.
6 MR. KARADZIC: [Interpretation]
7 Q. General, sir. Can you help us with this: Can we take a look at
8 the forces that were later part of the 12th Division? These were forces
9 that were in Sarajevo itself. What was the strength of that force?
10 I'm going to try to put my questions in such a way that you can
11 give me short answers.
12 A. Well, would I kindly ask, but I will also try to be rational and
13 try to give short answers, but you don't get good information in short
15 Q. Well, you please just go ahead and say as much as you need to.
16 A. I will. Thank you. Could you please put your question again? I
17 didn't understand the point of it properly. I didn't understand the
18 question. I'm sorry.
19 Q. Oh, never mind. In the town itself, the forces that later made
20 up the 12th Division, could you please tell us what the structure was,
21 what the forces were that made up the division? What were you faced with
22 from the city in terms of forces?
23 A. This is why I asked you to repeat the question, because it's not
24 only the 12th Division that's involved. It would be insufficient just to
25 discuss the structure of the 12th Division.
1 Right from the start, what I want to say is that besides the
2 12th Division, there was also action by other forces that I will mention
4 The 12th Division, under the command of Colonel Prevljak - I've
5 forgotten his first name for the moment - it comprised eight brigades,
6 eight mountain brigades. There were changes there. Some were renamed to
7 motorised brigades later, then mountain brigades, but in essence the
8 point is that there were eight brigades. These were strong units, very
9 uniformly deployed, and I can add that I was quite amazed at their
10 military skill in deploying the defence and also the way those forces
11 were used. Not just the defence.
12 It was under the command of Fikret Prevljak, that's right. That
13 was the 101st Mountain Brigade. That 101st Mountain Brigade was one of
14 the most or one the strongest units in this particular set-up, and it was
15 under the command of Colonel Fikret Hodzic, an officer who belonged to
16 the category of smart people. I know him, and I know all the others as
18 Then the next unit, I don't have to go by the actual sectors, but
19 they all focused on Mojmilo, Grbavica, up to the Vrbanja Bridge.
20 Q. General, can you also give us the sector roughly, the area of
22 A. Yes. That's the area, Mojmilo Hill, which dominates Lukavica.
23 It covers the territory and protects in the form of a geographical
24 topographical feature that is 3.5 kilometres long at an elevation of
25 620-something metres above sea level, and that area was where the
1 101st Mountain Brigade was deployed, and this brigade stretched across
2 Ozrenska Street, in the Zeljeznicar stadium sector. Then it reached the
3 Miljacka River all the way to the Vrbanja Bridge up to Marin Dvor to be
4 precise. It had its area and the depth that it was covering, and it was
5 covering all the neighbourhoods that were behind its back:
6 Otokaz [phoen], Rakeno Selo [phoen] and the annex Cengic Vila 1 and so on
7 and so forth.
8 Then from the Vrbanja Bridge was where the 115th Brigade was
9 deployed. It's a famous brigade known to all because it was under the
10 command of the infamous Caco, whom they then liquidated in an action.
11 That's the 115th Brigade. It's area of responsibility begins from
12 Vrbanja Bridge, and then it stretches above Vraca up to Debelo Brdo hill.
13 From Debelo Brdo it is deployed towards the so-called Colina Kapa. From
14 Colina Kapa, the area then continues to the east to the Miljacka River
15 where the Miljacka River enters Sarajevo, and that's where its forward
16 end begins. And its depth is up to the centre of town itself, including
17 Skenderija, Sirokaca, Bistrik, that whole area of the city with its line
18 of decisive defence and launching attacks at us.
19 From there that brigade demonstrated a lot of extreme conduct. I
20 know the commander. They probably inherited their aggressive stance from
21 a previous period and so on and so forth.
22 Then the 152nd Brigade takes over which covers that area from the
23 Miljacka River towards the Hladivode sector. That's its forward end.
24 And its depth stretches all the way to the city hall, the famous city
25 hall in Sarajevo. Actually it's the Bascarsija area. That's that
1 sector. The commander of that brigade belonged to the category of people
2 who knew how to carry out the command duties, and he demonstrated a
3 normal attitude, one that can be given respect and was chivalrous. Then
4 this is the 105th Brigade that was in charge of the Jajce barracks in
5 that area.
6 Then the 105th Mountain Brigade takes over which was a brigade
7 with seven battalions. It's a very large powerful unit. I cannot recall
8 the name of the commander right now, but I do know it well. He had seven
9 battalions, and out of those seven, four were infantry battalions. There
10 was one Engineers Battalion, an artillery division and then one was a
11 Logistics Unit. The brigade held the area of Sedrenik, everything above
12 the Kosevo Hospital, the Breka area, and it linked up to the
13 152nd Brigade, and its depth lay all the way back to the railway station,
14 and it held the centre of the city. The brigade was stronger than a
15 third of the Sarajevo-Romanija Corps. It was very strong. It was very
16 well equipped, had good combat equipment, powerful equipment and I would
17 say that not everything was quite proper in their relationship and in
18 these conflicts and in the fighting. They didn't fire in a normal manner
19 but in a manner which would turn into an attempt to destroy us. And they
20 tried to do that.
21 So then Hladivode towards Orahov Brijeg hill. That's where their
22 area was. The same brigade went over Prevoj, the Grdonj peak, and it
23 joined up through Pionirska Dolina valley with the 111th. The 111th
24 would sometimes be called a Mountain Brigade and sometimes a
25 Motorised Brigade. The 111th, its forward disposition spread from that
1 geographical feature, Orahov Brijeg, through the faculty for transport
2 which is now in Vogosca, to the elevations, the so-called Krcevine
3 elevations, and it covered the highest elevations in Sarajevo, above the
4 town of Sarajevo; and that is Orlic, 840 metres, then Zuc, then Vis, all
5 of them all the way to the area above Rajlovac. And it dominated
6 Vogosca. It could see it really well. It was an inhabited settlement.
7 It was impossible to move around in Vogosca because of the very strong
8 shelling. Perhaps there was some obstacles or barriers put up. Some
9 railway carriages from the railway carriage factory were put up so that
10 people could move.
11 If you permit me, that area was so exposed to fire that it was
12 impossible, unbearable to live there but people managed somehow.
13 Then that linked up to the 112th Brigade, which from that place,
14 from the 111th Brigade, took over the area all the way to the place where
15 the Miljacka River leaves Sarajevo. Miljacka enters Sarajevo on the
16 eastern side. It leaves it on the western side, and that is where the
17 area covered by the 112th Division ended. That division -- actually, not
18 division, that brigade, had a powerful artillery component. These were
19 key positions, artillery firing positions, which they fired from with the
20 weapons that they had at their disposal. From the 112th, the -- and let
21 me add that the 112th and the 111th also covered in the depth the area
22 all the way to Dzemala Bijedica [phoen] Street.
23 Then follows 102nd Mountain Brigade. That was one of the more
24 agile brigades, because they were constantly engaged in combat and in
25 trying to destroy the area of Nedzarici. That was their idea, or
1 whatever, and over that area to link up with the 104th that I mentioned
3 Now, the 102nd Brigade held or covered the area from the Miljacka
4 bridge over the Stup hill, along the student halls, and there it would
5 cross into Nedzarici. On -- onward from it was the 155th Brigade,
6 Mountain Brigade, under the command of Ismet Hadzic, who was a civilian.
7 The 155th Brigade was in Dobrinja, and in my view it was a unit that was
8 very numerous, the personnel, and they were in a very small area, so they
9 were getting out of control. So I understood that they needed more space
10 to try to break through. So they opened fire on Lukavica and Trapare
11 neighbourhood, as well as some houses on our side.
12 Q. General, sir, I would like to call up 1D7047 in e-court. You
13 will be familiar with this document.
14 THE ACCUSED: [Interpretation] And in line 1 on the 30th page, the
15 general didn't say that they were out of control. He said that they were
16 acting in a very wild manner. They were uncontrolled. They were
18 Now, could I request that the usher provide a printout of the
19 document that we've called in e-court, 1D7047.
20 JUDGE KWON: Is it not uploaded in e-court? I don't see it on
21 the --
22 THE ACCUSED: [Interpretation] It should be.
23 MR. KARADZIC: [Interpretation]
24 Q. General, sir, who drafted this map -- or, rather, this
25 disposition of units?
1 A. Well, I did. Observing the situation, revealing their
2 disposition and deployments and observing their direction of action, I
3 managed to put together a mosaic of their activities, and right now
4 looking at it, I'm not quite happy because you cannot really see clearly
5 the extent to which they engaged in combat and opened fire. You can't
6 really see it from this map, but it gives you an idea.
7 Q. Thank you. Now, you talked about the brigades and their
8 dispositions. Can that be seen on this map? You started with the 101st,
9 moved eastward all the way to 155th to the west.
10 A. Well, that's what I tried to present here.
11 Q. You do have a printout of the map that you can look at.
12 A. Well, yes. You see, the semicircles there, the arcs -- maybe I
13 can show it here. For instance, here. This marks the place where these
14 units had contact, physical contact. Likewise, right here, that's where
15 they linked up. You can see it here.
16 Q. And which units were adjacent above Kobilja Glava?
17 A. Well, that was the point contact between 105th and 112th -- no,
18 111th. No, 112th. My apology. So the 112th and the 105th, which spread
19 from Sedrenik via Grdonj to Orahov Brijeg.
20 Q. Thank you. We will -- we're approaching the time for our break,
21 so would you please date and sign this map.
22 A. Very well. This is okay. I've checked again. It's okay. So I
23 should put the date there?
24 Q. Yes, the date and your signature, please.
25 A. [Marks]
1 JUDGE KWON: I'm afraid today is the 23rd, Mr. Milosevic.
2 THE WITNESS: [Interpretation] Correction. I need to correct
4 JUDGE KWON: While the general is putting the date, probably we
5 need the translation of each legend later on. So we'll mark this map for
6 identification pending translation.
7 THE REGISTRAR: As MFI D2790, Your Honours.
8 JUDGE KWON: I see the time, Mr. Karadzic. Shall we take a break
9 if it is convenient?
10 THE ACCUSED: [Interpretation] Very well.
11 JUDGE KWON: Mr. Bourgon, do you have a point?
12 MR. BOURGON: A very quick point, Mr. President. The witness
13 wanted to address the Trial Chamber in respect of his detention
14 conditions very quickly, Mr. President.
15 [Trial Chamber confers]
16 JUDGE KWON: Yes, Mr. Milosevic, you have the floor.
17 THE WITNESS: [Interpretation] Thank you, Your Honour.
18 JUDGE KWON: Mr. Milosevic, I have to turn to Mr. Robinson and
19 Mr. Bourgon whether we can stay in public session.
20 MR. BOURGON: Actually, he just wants to say that he's satisfied
21 and say thank you to the Trial Chamber, Mr. President.
22 JUDGE KWON: Very well. Please proceed, Mr. Milosevic.
23 THE WITNESS: [Interpretation] Thank you for giving me this
24 opportunity to say this. Perhaps I should have asked for this myself,
25 but very well.
1 I need to thank the Trial Chamber for allowing me to have, while
2 in detention, the conditions that are similar to the ones that I have in
3 the prison in (redacted). In other words, I'm not isolated from the other
4 prisoners. And let me just add one thing. Yesterday when I was asked
5 about the notes that I had jotted down, it was only then that I concluded
6 that I was happy that I had already jotted down some of my notes while I
7 was still in (redacted) in Estonia, because when I arrived here and under the
8 conditions that I originally had, I wouldn't have been able to
9 concentrate, but right now everything is fine, and thank you very much.
10 I'm quite happy.
11 JUDGE KWON: Thank you.
12 Could the court deputy approach the bench.
13 [Trial Chamber and registrar confer]
14 JUDGE KWON: We'll a break for half an hour and resume at 3 past
16 --- Recess taken at 10.33 a.m.
17 --- On resuming at 11.03 a.m.
18 JUDGE KWON: Yes, Mr. Karadzic, please continue.
19 THE ACCUSED: [Interpretation] Thank you, your Excellency.
20 MR. KARADZIC: [Interpretation]
21 Q. General, sir, I would now like to show you a document from the
22 command of the 12th Division of the 1st Corps.
23 THE ACCUSED: [Interpretation] Could we pull up, please, in
24 e-court 1D2839.
25 MR. KARADZIC: [Interpretation]
1 Q. General, sir, first of all, could you tell us what the
2 handwritten note means, and could you tell us who wrote that? Could you
3 read it out to us?
4 A. Yes, I can. This is my own handwritten note when I tried to
5 communicate with my attorney and show him a source document, an original
6 document, which shows the exact deployment and shows accurately the
7 engagement of the 12th Division forces, and the intention was for him to
8 understand the problems and to gain insight into this from this document,
9 to gain insight into the adversary or the other side for the
10 Sarajevo-Romanija Corps. And this request of mine was something he did
11 not like. I can't explain why, but he just couldn't understand it, and
12 he did not want to tender this document, and this document was never used
13 in trial -- in my trial. So this is my answer to your question, to
14 explain what happened with this document and my request to use it. But
15 if you need anything else, please just let me know.
16 Q. Thank you. Now, what -- first of all, tell us what kind of
17 document is this? This is an order. What kind of order?
18 A. This is an order for decisive defence by the commander of the
19 12th Division, dated the 14th of April, 1995. The gist of the document
20 is this: He expresses here the deployment of his forces, and he gives a
21 detailed account of everything that his commanders need to know,
22 including what assets they have at their disposal, what resources, what
23 area of responsibility they're responsible for and the direction or the
24 axis, the axis of their advance and attacks, although here it says this
25 is a command for a decisive defence.
1 Q. Could you please tell us what it says in the third line of this
2 text. What was his estimate of the forces that he had against him, the
3 forces of the Sarajevo-Romanija Corps?
4 A. Well, yes. He states here that that's 9.000 troops, yes. He
5 wasn't far off the mark. I believe that his estimate was correct.
6 Q. What about the other 9.000 troops of the Sarajevo-Romanija Corps?
7 Where were they deployed?
8 A. The remainder or the other part of the corps -- although let's be
9 clear on this, both these men and the other men, they're all part of one
10 and the same corps. They were deployed at the wider area at the
11 Nisici plateau, Nisiskavi Soravan [phoen], and including all the areas
12 that were tied up to Visoko and Olovo and Breza.
13 Now, the other elements of the Sarajevo-Romanija Corps were
14 deployed in the general area in the southern front below Treskavica; in
15 other words, in the Trnovo settlement area.
16 JUDGE KWON: Please bear in mind that it's very difficult to
17 follow this line of questioning without having an English translation.
18 And I find it also difficult to understand why we do not have English
19 translation of this document while it was put to one of the witnesses,
20 i.e., Martin Bell, about two years ago, one and a half years ago. Two
21 years ago, more than two years ago, according to what e-court says to us.
22 THE ACCUSED: [Interpretation] We have requested a translation.
23 JUDGE KWON: When did you put in a request for translation,
24 Mr. Karadzic? I think the e-court says it was put to Martin Bell on
25 15th of December, 2010.
1 THE ACCUSED: [Interpretation] Your Excellency, we always have to
2 prioritise, and it is possible that we've overlooked this document as one
3 of the priority documents, but I do believe that we have made a request
4 for its translation, and of course there is a logjam in the translation
5 service, so we do understand that they don't have time to meet the
7 JUDGE KWON: I leave it at that.
8 Mr. Milosevic, could you kindly read out your handwriting for us
9 to understand it.
10 THE WITNESS: [Interpretation] Yes, thank God. Your Honour, it
11 says here, that's what I wrote in my own hand -- well, first of all what
12 you see there which is kind of pale, that says "Important." That meant
13 that it was an important document, as far as I was concerned.
14 Now, what it reads here in handwriting is:
15 "We should finally resolve with the attorney the issue about the
16 presentation on a map of a developed deployment of the 12th Division in
17 the town of Sarajevo. Decidedly developed deployment of the
18 12th Division in the town of Sarajevo."
19 In other words, I asked him to translate this onto a map so that
20 we can see from the map where that was, but he never did any of those
21 things that I asked him to do.
22 JUDGE KWON: And I also find it difficult if your attorney did
23 not tender this document, how could this document be in the custody of
24 Mr. Karadzic? Do you have any clue?
25 THE WITNESS: [Interpretation] Are you asking me?
1 JUDGE KWON: Yes.
2 THE ACCUSED: [Interpretation] I believe, Your Honour -- your
3 Excellency, that this is somewhere --
4 THE WITNESS: [Interpretation] No, no. All I know is that this
5 was what I asked my attorney to do, my Defence counsel. This document
6 was important, as I've already said, in my view. Now, whether this was
7 transposed, I actually had the same suggestion for the trial of Mr. --
8 the Chief of the General Staff who was also connected to this, yes,
9 Perisic, for the Perisic case. And perhaps in that form it actually
10 appeared somewhere.
11 THE ACCUSED: [Interpretation] We will look at the bottom of the
12 page, because perhaps the document was marked for identification.
13 Further down, please.
14 THE WITNESS: [Interpretation] Yes, that's right. We have a
15 number there.
16 JUDGE KWON: Please continue, Mr. Karadzic.
17 MR. KARADZIC: [Interpretation]
18 Q. General, sir, line 3, what was the estimate of troops facing the
19 12th Division, overall strength?
20 A. Nine thousand men.
21 Q. All right. Page 2, please, paragraph 4. It starts with the
22 words "I hereby decide." What about the structure of their decisions?
23 Are they similar to the your decisions, because I noticed in VRS
24 documents that paragraph 4 is always "I hereby decide."
25 A. Yes. That's quite true, but let me just add one thing. We all
1 come from the same military background. Officers on both sides were
2 trained in much the same way, and the same applied to procedures based on
3 which orders and reports were written up. So the command methods were
4 very much alike on both sides of the front line.
5 Q. Thank you very much. Can you please focus on 5.1. What is the
6 brigade that he is talking about there? We shall not be dwelling on
7 this, but what is that brigade, and how does he identify their position,
8 and is that consistent with your information at the time?
9 A. Yes. The 101st Brigade minus one battalion. This sort of
10 indication minus one, you'll find that elsewhere, too, because they'll
11 always have one battalion from a brigade and then send it out elsewhere,
12 send it to Niksic, for example, that area over there. So we're looking
13 at the 101st Brigade and what I see here is consistent with the
14 disposition that I was aware of at the time.
15 THE ACCUSED: [Interpretation] Could this please be MFI'd. We
16 have a similar document that we do have a translation for that again
17 gives you the deployment of units belonging to the 12th Division two
18 months later. It is an attack plan.
19 THE WITNESS: [Interpretation] May I ask the Chamber something,
21 JUDGE KWON: Yes, Mr. Milosevic.
22 THE WITNESS: [Interpretation] I think it would be a good idea to
23 focus on this part where it talks about the combat disposition. The fact
24 reflected here shows the force and equipment available to the commander
25 of the 12th Division. He states in unambiguous terms that he has some
1 forces in one of the echelons with some reservists and that there were
2 some support forces available too. So support was available. And the
3 other commander knew that he could lend support if he needed. So he had
4 artillery. He had the anti-armour, he had anti-aircraft, he had some
5 obstacles available to him, and he has the appropriate command forces
6 available to him; in one word, he has everything that he needs to
7 effectively run the forces available to him.
8 THE ACCUSED: [Interpretation] Your Excellency, I was moving to --
9 to have this MFI'd, and then perhaps we could sum up in e-court a very
10 similar document that we do have a translation for and all the same
11 elements are actually there.
12 JUDGE KWON: Mr. Karadzic, for the record, I was told that the
13 number we saw at the bottom of page 1 is a Defence identification number,
14 not anything else.
15 Yes. Ms. Edgerton, do you have any objection to marking this
16 document for identification?
17 MS. EDGERTON: For identification, no.
18 JUDGE KWON: Yes, we'll do that.
19 THE REGISTRAR: It will be MFI D2791, Your Honours.
20 THE ACCUSED: [Interpretation] Thank you. Could we please have
22 MR. KARADZIC: [Interpretation]
23 Q. General, sir, this is an attack order. What is the date, please?
24 A. Attack order by the commander of the 12th Division,
25 11th of June, 1995.
1 Q. Was this attack carried out?
2 A. Yes. This is no ordinary attack. This is an offensive. The
3 scope of this offensive is brought, the scope of the operations is
4 brought. This operation was meant to crush the forces of the
5 Sarajevo-Romanija Corps.
6 Q. Thank you. Page 1, line 3. This is two months later. What is
7 the estimate of -- of the men he was facing, the number of men he was
8 facing now?
9 A. Now it's down to 8.000 men.
10 Q. Thank you very much. Next page, please.
11 A. And the estimate was actually correct, because many of my men had
12 been killed in the meantime.
13 Q. What does he say there about the 12th Division and the
14 neighbouring divisions, the 14th and the 16th?
15 A. Even without reading I know the context, and I know what you're
16 asking me. There was a full co-ordination of combat operations between
17 both of these units. It's a very clever way to co-ordinate your
18 operations from Sarajevo on the one hand - when I say clever, I mean
19 clever for their own purposes, of course - and combining that with the
20 forces outside Sarajevo but moving in on Sarajevo. The 12th Division was
21 in Sarajevo, and the 14th and 16th Divisions from the area that I
22 specified. Vares.
23 Q. Could we have the next page in English, please. Please continue,
24 General, sir. Tell us briefly about what -- what this is about. What
25 force, are available to him and what exactly does he intend to do?
1 A. You mean the commander of the 12th Division?
2 Q. Yes. What does the document tell us about his intentions?
3 A. The document tells us that all of his forces were active by this
4 time. A while ago we were talking about him co-ordinating with the 14th
5 and the 16th Divisions. In actual fact, it was the corps commander who
6 was doing the co-ordination for him, but he knows that co-ordination will
7 be there, that there will be concerted action. He knows with sure and
8 certain knowledge that heading his way are these other units, but not
9 just from the 1st Corps in relation to this specific situation, and it's
10 not he who is saying this, it's the corps commander telling him what
11 other forces would be involved. The 3rd Corps under General Mahmuljin's
12 command, the 7th Corps, another powerful unit in his own area. The
13 4th Corps under elements of the 2nd Corps. So all these units together
14 along with the 1st Corps were the strike force threatening the
15 Sarajevo-Romanija Corps. So they're calling this -- they're labelling
16 this as deblocking [Realtime transcript read in error "disabling"]
17 Sarajevo. I don't mind that, because that's what it was from their
18 perspective, I suppose. So that certainly was not a deblocking effort.
19 This was about crushing the Sarajevo-Romanija Corps.
20 THE ACCUSED: [Interpretation] Could we please scroll down to the
21 bottom of the English page where it starts to talk about forces and
22 combat disposition. And that is the next page in the Serbian copy, so
23 you can tell us about what it means, combat disposition. Can we have the
24 next page in both versions of the document, please. Can we zoom in,
25 please. We need page number 3 in the Serbian. Page number 3 in the
2 MR. KARADZIC: [Interpretation]
3 Q. Please tell us briefly about what the decision comprises and then
4 what forces would actually be used.
5 A. The meaning of this decision. First of all, he decides to hold
6 on to what he has already, use some of his forces to secure the defence
7 line, and also to use some other units available to him to carry out
8 certain operations and to achieve certain breakthroughs in certain areas.
9 I don't know this by heart, but I know the general direction in which
10 they were moving. Talking of the 12th Division, it was launching
11 operations, trying to break out of Sarajevo using its own brigades along
12 its own axes of operations.
13 Talking about the combat disposition of these forces here, what
14 you see here constitutes a corroboration. He wanted to do this, and he
15 was indeed able to do this. He was able to launch this operation.
16 When a commander decides to lend support to someone, then the
17 other person has to be aware of the fact that there is support coming his
18 way, support in terms of firing, in terms of firepower, support in terms
19 of reinforcements being sent his way. This person must know that he will
20 not be left to his own devices, but help is coming.
21 So these are not particularly adventurous or risky decisions.
22 These are well-thought-out decisions and they are at this point in time
23 ready to go ahead with this.
24 Q. Thank you very much. Could you please tell us about the combat
25 disposition and the units that were available to him?
1 JUDGE KWON: Before -- before you answer, Mr. Milosevic.
2 Yes, Ms. Edgerton.
3 MS. EDGERTON: I'm sorry for interrupting but just before it
4 appears on our screen at page 41, line 5, we see the word "disabling
5 Sarajevo" used and I distinctly heard the witness say "deblocking
7 JUDGE KWON: Thank you. Before we go on further, Mr. Milosevic,
8 could you read the handwritten part at the bottom of paragraph 5.1, and
9 tell us whether it is written in Cyrillic or in Latin.
10 THE WITNESS: [Interpretation] Uh-huh. If this is what you're
11 asking me about -- it's gone now. Latin script it is. Yes. It's a
12 clarification that I jotted down myself, because this is my handwriting.
13 It's about this abbreviation, DAG-12, the division artillery group. I
14 did this because I knew that my Defence counsel understood nothing about
15 these abbreviations and he couldn't possibly figure out what it meant.
16 So I would expand these for his benefit in a bid to explain to him what
17 he was going through. So this is the division artillery group belonging
18 to the 12th Division in this case.
19 JUDGE KWON: Thank you. We'll come back to this page, but can we
20 see the first page, page 1 of this document in B/C/S.
21 So, Mr. Karadzic, this document is from Mr. Milosevic's case.
22 Exhibit D417 is from his case?
23 And, Mr. Milosevic, I see "Plan B" in Cyrillic in the middle
24 of -- on top of the page in Cyrillic. Do you read -- do you see that,
25 "Plan B"?
1 THE WITNESS: [Interpretation] Yes.
2 JUDGE KWON: Is it your handwriting, Mr. Milosevic?
3 THE WITNESS: [Interpretation] No, it isn't. I don't know whose
4 it is. I don't write in Cyrillic. I think this is probably written by
5 my Defence counsel, "Plan T." So linking up the code-name of the entire
6 operation, Tekbir. The 1st Corps, the BH Army as a whole.
7 JUDGE KWON: Thank you. The last question for you was whether
8 you could tell us about the combat disposition and the units that were
9 available to this commander. That is the question from Mr. Karadzic.
10 THE WITNESS: [Interpretation] Yes, but could we please go back to
11 that portion of the text.
12 MR. KARADZIC: [Interpretation]
13 Q. Page 3 in the Serbian. Combat disposition and then the units.
14 A. Yes. I was about to embark on that. The commander here decides
15 to keep some attacking forces, some of the units involved. And to also
16 use some of the units to defend and to offer support, some of the units
17 to be involved in anti-armoured combat. Artillery support, that is
18 understood. When he says support, it's not about actually fetching them
19 a glass of water. Of course, it's about offering support in terms of the
20 firepower, anti-aircraft, and then also some forces to secure the actual
21 combat operations, and that is an element, the importance of which cannot
22 be overestimated. Very important. Signals and command and also reserve.
23 We see everything that is available to him, and he has all of the
24 required elements assembled him there, leaving him in an almost ideal
25 position to carry out combat operations. He has everything that he needs
1 in order to carry out this task.
2 Q. Thank you, General. What about 5.1, 5.2? What are the forces
3 there that he's using? Where are these forces positioned, and what about
4 the command posts and forward command posts? Where are those?
5 A. When discussing these forces that he engaged, first of all, he
6 engaged all of the forces at their disposal, the brigades that I
7 mentioned previously. These are the brigades from the 12th Division.
8 What you can see here, that the independent brigades are also taking
9 part, which are directly in line of command under the corps. These are
10 light brigades.
11 The list of documents with the commanders receiving the order,
12 other than his commanders from the 101st, 102nd, 115th, and so on and so
13 forth, there is also the signature of the commander of the police forces
14 brigade, Mr. Mirkovic. And this is an additional unit outside of the MUP
15 B and H special brigade. It was called the Bosna Brigade. This brigade
16 is purely a police brigade. They had an excess of police.
17 Q. Could you please show us this entire paragraph 5.1 about the
18 112th Brigade? Can you tell us, General, sir, when you lost your right
20 A. I lost my eye in 1995 at Bosut.
21 THE ACCUSED: [Interpretation] Could you please enlarge this for
22 the General.
23 MR. KARADZIC: [Interpretation]
24 Q. And how did you lose your eye?
25 A. I don't know. It was a direct hit by a tank shell at the
1 observation post of the commander, my observation post. It hit directly
2 the observation post. I wasn't hit myself directly, but I did lose my
3 right eye in this hit. The fire originated from Sarajevo, from the
4 Velesici incline.
5 Q. Could you please read this, and then for the others could you
6 please tell us what is supported and what the command forces are? Could
7 you read 5.1, please.
8 A. 112th Viteska Mountain Brigade in decisive defence defends the
9 area of responsibility of the brigade while a part of the forces from the
10 forward section Vis Lemezi is to carry out an attack along the axis of
11 Vis, Perivoj, trig point K 6.34, Dvor and Mijatovici, Mijatovici Kosa,
12 Zabrdje with the objective as follows: By energetic action of the forces
13 from the front route the enemy along the axis of attack, inflict as many
14 losses as possible in manpower and materiel, capture the facilities at
15 Perivoj, elevation 6.34, Mijatovici Strana, trig point 5.82, the village
16 of Mijatovici, the village of Zabrdje, and break out to the
17 Rajlovac-Semizovac road, and in close joint action with the
18 111th Light Brigade and the 143rd Light Brigade organise a defence,
19 repulse a possible attack, and be prepared to link up with the forces of
20 the 7th Corps. And the 7th corps would then proceed from that direction
21 towards Reljevo from the direction of Visoko.
22 THE INTERPRETER: Interpreter's note: We do not have the
23 translation on our screen.
24 JUDGE KWON: Just a second, your last question and answer were
25 not reflected in the transcript because you overlapped with the
1 interpreter's note.
2 THE ACCUSED: [Interpretation] I apologise to the interpreters.
3 MR. KARADZIC: [Interpretation]
4 Q. General, sir, are you able to tell us as it refers to 5.1, who
5 supports? What does that imply? Where's the command post, and where's
6 the forward command post?
7 A. Yes, yes, all right. I understood it now. I thought you meant
8 the overall support for the entire 12th Division. All right. So as far
9 as this brigade is concerned you noticed that well. This brigade is
10 being supported by the 12th Division Artillery Group. The command post
11 of this brigade is in -- at Astra. Astra is right in the middle of town.
12 And the forward command post is in the sector of Sokolje, and that
13 Sokolje dominates Rajlovac, and throughout the war Rajlovac was under the
14 same pressure as Vogosca.
15 Q. Can we now scroll up where it says this part is -- supports also
16 the 146th Light -- not to scroll down but to scroll up. [In English] All
17 the way down.
18 A. What is discussed here is the support provided to the
19 143rd Light Brigade. They are supported by the artillery group of the
20 division, the command post would be in the sector of the
21 Ramiz Slacin barracks. That used to be my barracks, Victor Bubanj. And
22 its command post, the command post of this brigade pursuant to the
23 decision of the brigade commander, I mean the commander picks his own
24 command post, the command post of the 143rd Light Brigade.
25 Q. [Interpretation] Thank you. And all of this, is that in the town
2 A. Yes, yes. I will wait. Sorry.
3 Q. Can we have the next page, please.
4 JUDGE KWON: Mr. Karadzic, we have English translation for this.
5 There is no point of asking the witness to read out whole paragraphs. Of
6 course, it is for you to use your time --
7 THE ACCUSED: [Interpretation] No, no. Not entire paragraphs,
8 your Excellency. I just wanted him to identify the support and the
9 command post for each brigade and to tell us where.
10 MR. KARADZIC: [Interpretation]
11 Q. Mr. General, can you please tell us where the 111th -- actually,
12 just these three paragraphs. Just these three lines at the end of the
14 A. Ah, yes. I can see the 111th at the top of the page. It's being
15 supported by the artillery group 12, the command is in the sector of the
16 Blagoje Parovic school. The forward command post is in the Orlic sector.
17 It's a trig point.
18 Q. And now I'm going to try in order to get things to move faster,
19 let's look at a hundred -- the 105th. Let's skip the MUP forces
20 paragraph. 105th. Does it not state here it's supported by the
21 division's artillery group? The command post is in the sector of the
22 park, and the forward command post is in the sector of the
23 Kosevo Hospital?
24 A. What it states here is what it is, and the fact that the command
25 post is in the park sector --
1 JUDGE KWON: Ms. Edgerton.
2 MS. EDGERTON: With respect, I don't think that's the best way to
3 move forward in phrasing your question. Dr. Karadzic has led the witness
4 a few times now, and as we get into the documents particularly, perhaps
5 he could be cautioned.
6 JUDGE KWON: But it has been the practice of the Chamber to allow
7 the accused to put leading questions until objected to by the
8 Prosecution, and unless it is a serious problem, we'll let him continue.
9 Please bear in mind, Mr. Karadzic.
10 THE ACCUSED: [Interpretation] Thank you.
11 MR. KARADZIC: [Interpretation]
12 Q. I will just ask the General then where the forward command post
13 was supposed to be for the 105th Brigade, the command post and the
14 forward command post.
15 A. Evidently the forward command post -- the commander, this
16 commander, was obviously told that he could legally place his command
17 post at the Kosevo Hospital.
18 Q. And then the next command, where would the command post be?
19 General, sir, is all of this within the city?
20 A. Yes. Yes. This is a neighbourhood when we're talking about the
21 forward command post, and if we're talking about the 152nd Brigade, this
22 area of Vratnik, this is a neighbourhood above Bascarsija.
23 Q. Thank you. Can we scroll up, please, so we can see the bottom of
24 the page. What about this 115th? What is this 6th April square, and
25 what is Mala Kula?
1 A. Yes, yes, yes. The 6th April square, that's the area where the
2 command of the 2nd Military District was, and it's a -- actually, it's in
3 the very centre of town, Bistrik. The forward command post is in Mala
4 Kula. I really cannot tell you what this place is. There was a number
5 of "kulas," towers, around Sarajevo, so I don't know exactly which one it
7 Q. Thank you. Can we please look at the following page, so that we
8 can see -- we will not be looking at the other ones because there is a
9 translation. And then where it says firing support, what is this firing
10 support and what do they have at their disposal in the town itself?
11 Let's look at the page in B/C/S, and the participants can look for
12 themselves for the English version.
13 Can we look at the bottom of the page, item 6.
14 A. Could we please zoom in a little bit on the text? Ah, all right.
15 Thank you. I don't know if I should read this. The fire support is
16 provided by the division of the artillery group which is part of the
17 3rd Battery of the 2nd MAP. There's an anti-air -- a rocket battery.
18 The commander of the 3rd MAD, all the weaponry from the 3rd MAD are to be
19 deployed at the basic firing positions in the sectors of Hum, Busca,
20 Mojmilo, Zrak, Orlovaca. The main observation posts in the sectors of
21 Hum, Orlic, Svabino Brdo, Mojmilo Brdo, the command post of the 12th DAG
22 is in the sector of Velesici and the forward command post is in the
23 sector of Hum.
24 Q. Thank you, General, sir. I would like to tender this document.
25 I don't need to go any further and read the document because the document
1 speaks for itself.
2 JUDGE KWON: We'll receive it.
3 THE REGISTRAR: As Exhibit D2792, Your Honours.
4 MR. KARADZIC: [Interpretation]
5 Q. General, sir, you saw the command post, the forward command
6 posts, and then you said that all of them were located in the city
7 itself. I wanted to ask you what a command post of a force consists of.
8 What are the elements, where are they deployed, and what kind of an area
9 do they occupy?
10 JUDGE KWON: Yes, Ms. Edgerton.
11 MS. EDGERTON: I don't know that the general has said that he saw
12 the command posts and saw the forward command posts, as Dr. Karadzic has
13 just said.
14 JUDGE KWON: Mr. Karadzic.
15 THE ACCUSED: [Interpretation] I said that the general said, not
16 that he saw. He said that he read from the document that these command
17 posts were at localities that he indicated as being within the city
19 THE WITNESS: [Interpretation] May I answer?
20 MR. KARADZIC: [Interpretation]
21 Q. Yes, General, sir. Can you please tell us, all those command
22 posts and all of that that refer to the 12th Division, all of that, was
23 that in the city of Sarajevo itself?
24 A. Yes, yes. Just allow me to clarify that a little bit, the
25 question of that structure, the command structure. That is a key
1 structure for the -- for any combat unit. No one can act in any way if
2 they don't have a command that would provide guidance. And may I add,
3 with the indulgence of the Trial Chamber, when my lawyer -- actually, he
4 just talked about the number of people. There are 50.000 people in
5 Sarajevo, 50.000 people in Sarajevo, and so on and so forth, and I said
6 that that was not sufficient, because if the people are disorganised and
7 there's no command, then it's just a mob and nothing else. We're talking
8 about organised structures here with a command structure that is
9 developed, and this is what is significant.
10 It is correct that these command posts were located in the city.
11 When it says in the park, in the park that is in the Trapare Street, and
12 that is a street and an area that I am familiar with. I know where it is
13 located. It's in the centre of the city. Specifically, the command of
14 the 12th Division was located in the Skenderija sector and the brigade
15 commands practically in the same way had their own command posts just
16 like the corps command did in the centre of town. All of them were in
17 the centre of town. If we're talking about command posts, these are
18 elements that have their complete infrastructure, I would say, which has
19 to do with the system of communications, the system of security, system
20 of parking, and system of processing and preparation of food in order to
21 feed the cadre, to issue tasks, for holding meetings, to also have the
22 functioning messenger and courier service so that in the existing command
23 posts which function in Sarajevo, there is a very lively activity going
24 on constantly which was observable. When madam said that I did not see
25 that, it's not me, but using our observation system, we could all observe
1 that. You could see all of this, and then when you look at these
2 documents, you can see that all of that was correct.
3 I don't know if I was clear enough, that when you talk about the
4 system of command posts and the distribution of command posts, that it's
5 not just one point where a person is sitting and issuing orders. That is
6 where everything originates from.
7 Q. Thank you. Can we now look at 1D7202, and can I ask you to
8 explain to us what this document is and what these markings are and who
9 drafted the document?
10 A. I can. What I would like to stress here is that I drew this
11 myself in an attempt to just give you an idea what -- how these things
12 work. So this is not any particular command post. This is really just a
13 concept, a depiction of the deployment of forces at a command post.
14 So on the right-hand side where we see the communications system
15 or signals system, there are certain command organs that are connected,
16 interconnected, within this entire system. In other words, via the
17 Chief of Staff, they all are connected to the commander. All organs of a
18 certain command have to be there represented, including the operations
19 organ, and they're in charge of monitoring the entire situation, giving
20 proposals and guidelines. Then there's the security organ, and attached
21 to these two, the operations and the Chief of Staff organs, we have the
22 various arms, infantry, artillery, and other arms that would be part of
23 their complement of a certain -- of any given unit.
24 The system of technical and radar support is also depicted here,
25 and this is in fact the key service. All the other elements are just
1 auxiliary elements such as security units, military police units, and
2 very close to them are the reconnaissance companies, depending on the
3 unit, because not every unit would have a reconnaissance company. Then
4 there is also the area for the military police, and we see the location
5 where food is prepared as well as supplies for the organs that are in
6 that area that operate there. And we also see support services or
7 support resources for fire purposes in the event that this command post
8 would be discovered and that somebody opened fire on them.
9 So this would be a battery, an elaborate battery for the
10 protection of the command post.
11 THE ACCUSED: [Interpretation] Thank you. Could the usher please
12 assist the general with the pen so that he can mark this on his drawing.
13 MR. KARADZIC: [Interpretation]
14 Q. And could you please tell us where it says at the bottom an
15 elaborate or developed command post? What does that mean?
16 A. Well, that's what it means. It means that this is a depiction of
17 an elaborate developed command post with all the services that are within
19 Q. Thank you. Could you please tell us what the designation there
20 which says "Staff Command" or "Headquarters Staff"?
21 A. Well, they are the assisting organs that assist with logistics,
22 that provide logistics for a system like this.
23 For instance, a brigade would have its logistics department; so
24 does a command post. It has to have its own logistics, and it is called
25 staff -- headquarters staff.
1 Q. Thank you. Could you please put a number 2 where it says IC or
2 Ech. What does that mean?
3 A. Well, that is the reconnaissance company. That's all it could
4 mean, nothing more.
5 Q. Thank you. And the other marking there where it says "Potential
6 force -- intervention forces," what does that mean?
7 A. Well, each command post has to have a unit nearby that is to be
8 employed for interventions. Now, how large that unit should be, the
9 intervention unit, that would depend on the circumstances. If the
10 commander feels that he should have an intervention unit, then he would
11 establish it.
12 Q. Thank you. Could you please put the number 3 next to the
13 possible intervention force?
14 A. Here it is.
15 Q. Could you please put a number 4 next to "CVP" or "CVP" and tell
16 us what that is?
17 A. Well, that is the Military Police Company.
18 Q. Thank you. Could you put a number 5 next to the parking area.
19 A. That's probably a universal international signal for parking.
20 Well, here it is.
21 Q. What is "Pija"? There is something there which reads P-i-j-a.
22 What is that?
23 A. Well, that is the reception area.
24 Q. Could you tell us there at the top what that is and mark it?
25 A. Well, I'll put number 7 here, and that's the artillery battery.
1 It's a support unit.
2 Q. Support -- in support of what?
3 A. Well, in the event that the command post is discovered and is
4 targeted, if the sector of the command post is targeted, then there must
5 be a support unit that would be used to neutralise the enemy.
6 Q. Thank you. Now, could you move to the right and tell us what
7 this image, the tripod there, what is that? What does that depict?
8 A. Well, that's the radar, so I'll put an R next to number 8. I
9 apologise. In fact -- my apologies. I really am sorry. It's my fault.
10 This is a radio relay device, in fact, a radio relay device which assists
11 in maintaining communications with the brigades. The commander has
12 communication with brigades and subordinate units.
13 Q. Thank you. What does this CV stand for? CV, communications
15 A. Well, yes, that's what it means, the signals centre or
16 communications centre. Here's number 9.
17 Q. Could you now tell us what this POM stands for, POM and then
18 Moral, M-o-r-a-l. What does that mean?
19 A. Well, that's the assistant for morale. Well, this is the heart
20 of the command. The command -- the commander has everything tied to him.
21 So he has the assistant for morale, an assistant for intelligence, and
22 also an entire structure at his disposal to enable him to monitor the
23 operation that he's in charge of.
24 Q. Thank you. Well, you don't have to go -- we don't have to go any
25 further -- into any further detail here. It will be translated. But can
1 you tell me what this flag represents?
2 A. Well, each command has its own flag. So this would represent
3 schematically the command post of the division.
4 Q. Would you put a number 10 next to it, and could you tell us what
5 the marking for a brigade or a battalion would be?
6 A. Well, I could show you if you give me a piece of paper so I could
7 draw on it -- or maybe I can try doing it here. So this type of flag
8 would indicate a battalion, a command post of a battalion, because you
9 have to make a distinction, because not all commands are of the same
11 Q. Thank you. Please put a number 11 next to it, and please date
12 and sign this drawing.
13 A. Okay. So it's the 23rd.
14 THE ACCUSED: [Interpretation] I would like to tender this
15 document, please.
16 JUDGE KWON: Ms. Edgerton, would you agree that we need a
17 translation of this?
18 MS. EDGERTON: Yes, and I'm actually not sure how my colleagues
19 who are very qualified will be able to deal with the very slim
20 abbreviations and acronyms. It might be more useful if the general
21 explains them.
22 JUDGE KWON: The remainder that he hasn't explained.
23 MS. EDGERTON: Correct.
24 JUDGE KWON: Will you start with the security, Mr. Milosevic, OB.
25 THE WITNESS: [Interpretation] I see. OB stands for security and
1 intelligence, a security and intelligence organ.
2 JUDGE KWON: Number 10.
3 THE WITNESS: [Interpretation] Sorry, let me just explain. This
4 can only be -- this can be either an intelligence organ or an
5 intelligence plus security organ, both. They could both be.
6 THE ACCUSED: [Interpretation] Twelve, your Excellency.
7 THE WITNESS: [Interpretation] We already have an 11.
8 JUDGE KWON: Correct, 12. And 13 for the commander.
9 THE WITNESS: [Interpretation] Thirteen for the commander. Here
10 it is. His vehicle is there, and he's always ready to be on the move.
11 JUDGE KWON: And 14 for Chief of Staff.
12 THE WITNESS: Okay.
13 JUDGE KWON: What does OC mean, Mr. Milosevic?
14 THE WITNESS: [Interpretation] Operations Centre. It's a room
15 where operations officers sit and work.
16 JUDGE KWON: Ms. Edgerton, do you need more explanation?
17 MS. EDGERTON: No.
18 JUDGE KWON: Very well. Do we need to -- I don't think so.
19 We'll admit this marked diagram, but I will mark it for identification
20 pending -- I don't think we need translation at this time.
21 MS. EDGERTON: No. Now I think it's fine, Your Honour.
22 JUDGE KWON: We'll admit it.
23 THE REGISTRAR: As Exhibit D2793, Your Honours.
24 THE ACCUSED: [Interpretation] Thank you.
25 MR. KARADZIC: [Interpretation]
1 Q. General, sir, could you now tell us how many of these elaborate
2 staffs or headquarters of units were there in total in Sarajevo as part
3 of what was later to be called the 12th Division?
4 A. In addition to the 12th Division and its subordinate units, there
5 were other command posts as well there, so that the number of command
6 posts in Sarajevo were not solely restricted to the 12th Division, and
7 I'll explain that in a moment.
8 This division had three command posts of its own, the basic
9 command post; the rear command post, that's a separate post; and the
10 forward command post. So these are the division command posts alone.
11 Now, the 1st Corps had the same structure, the same, the same
12 system. Of course it was a larger command, but there was a larger number
13 of personnel there. There was the basic command post, the forward
14 command post, and the rear command post.
15 Q. Thank you. You said Danijela Ozme, at Danijela Ozme. What does
16 that mean?
17 A. Well, that's the Danijela Ozme Street. That's where the basic
18 command post was. And this is the area that they claim had never been
19 hit by anything, and of course no one would even attempt to target it,
20 because that was the centre of town itself.
21 Q. Please go on.
22 A. Well, in addition to these, I represented in a different form --
23 I've explained that the division numbers eight brigades, these mountain
24 brigades, and each of these brigades has a similar command post as the
25 one depicted, but perhaps with a fewer number of men. They would all
1 have these three different posts.
2 Now, the next thing is this: Within Sarajevo itself, there were
3 two brigades which were located in Sarajevo itself, but they were not
4 attached to this division but, rather, to the 1st Corps.
5 Now, these eight brigades, separate from the ninth that I
6 mentioned that belonged to the 14th Division which was the 104th Brigade
7 in Hrasnica. Brigades have their own battalions, and the total number of
8 battalion command posts, and I stress these are smaller sites with a
9 fewer number of men. There were 55 of them in total in Sarajevo. Now,
10 each of those battalions has a company. Some have three companies, some
11 have four. But if we add all that up, the total number of command posts
12 including the battalion companies and the independent companies that
13 belong to the 12th Division or, for instance, the
14 Military Police Company, the reconnaissance, sabotage company and so on
15 and so forth, they all existed, and their command posts that are placed
16 by the company commander with his own structures, there were 164 of
18 I have written all this down. I'm not sure if I've added up this
19 correctly, if I did the calculation right, but I believe that in total
20 there were 200 or so command posts in total there.
21 THE ACCUSED: [Interpretation] Would the Trial Chamber allow the
22 witness to look at his notes?
23 JUDGE KWON: If necessary. I don't understand any problem.
24 THE WITNESS: Thank you. [Interpretation] The number of command
25 posts was 275. These were command posts for the units that I've already
1 mentioned, the command posts that existed within the brigades and
2 divisions, but I failed to mention that there is another structure there,
3 a police command structure. This was the special MUP Brigade. So in
4 addition to the others, there were eight other command posts that were
5 command posts at Ilidza, at Pale, Vogosca -- not command posts but
6 commands, commands that commanded forces. They were in all these
7 municipalities that were on the outskirts of Sarajevo. These were
8 military commands that existed in Sarajevo and had their own structure,
9 but of course these were smaller. So that's how they increased these
10 numbers. And they were working on preparing the forces that would break
11 out of Sarajevo so that they could continue commanding those units when
12 they entered, for instance, Rajlovac, Pale, Ilidza, and so on and so
14 So from this we can see that they had -- that their intention was
15 offensive and the area that they called, they would use the term
16 "temporarily captured territory," which is a category that existed in the
17 one-time JNA strategy of combat, and it referred to situations where NATO
18 would carry out an aggression against Yugoslavia or the Warsaw Pact so
19 that then each area, had it been captured, would have been referred as to
20 temporarily captured.
21 Now, from this fact -- or on this fact they built this structure,
22 and the families that had lived there for ages, they were treated as
23 civilians being in captured territories, and they wanted to expel them
24 from those areas.
25 So I am just trying to say that there were these command posts.
1 They were visible. They functioned. They commanded and directed their
2 forces, and in the end there was fighting against those forces with us.
3 Q. Thank you very much, General. What about the 275 plus 8 for all
4 these peripheral municipalities. What about all these command posts, the
5 275? Does that imply a single location or could a single command post
6 occupy a number of different locations?
7 A. I think that is perfectly clear. There are some levels that have
8 command posts in three different versions, the basic command post, the
9 rear command post, and the forward command post. But a platoon or a
10 company wouldn't have that. A company would not have a rear command
11 post. A company commander would have his own station, then a station for
12 his combat needs. He would have several assistants. He would have
13 messengers and so on and so forth. They would only be in a single
14 location, the company would, because that is a lower level so to speak.
15 Q. And what about larger units, a command post in a single location
16 or perhaps in several different locations?
17 A. No. There would be three locations, as I said, in order to be
18 able to operate. That is the first thing.
19 Secondly, they wouldn't even need to be in a single location,
20 strictly speaking. There would be some distance between the various
21 sections of the command. Just to name an example, the 104th Brigade, for
22 example, has a part of its command in Butmir, and the 104th Brigade is
23 the brigade that we're talking about. It operates and exists in the
24 Hrasnica area. So a part of it is there.
25 And then if I may just clarify now that I've been given an
1 opportunity. In the Butmir area and the Sokolovic Kruna area, you can
2 also find a part of the corps command. I didn't indicate their existence
3 here as a separate component.
4 Q. Thank you very much. Could you please tell us where the
5 Supreme Command of the BH Army was located?
6 A. Truth to tell, I don't know. It is known that the Presidency
7 occupied the Presidency building. I'm not sure if they saw the same
8 building also as their Supreme Command.
9 Q. What about elements of the Main Staff of the BH Army within the
10 city itself, because that's what we're talking about, the city itself.
11 A. Yes, I understand that. The part of the General Staff command,
12 the part, and that is why they had some men there for their own security,
13 the Guards Brigade, a unit that we have not mentioned so far, although it
14 was there in addition to all the brigades that I have so far enumerated.
15 So a part of the General Staff command was indeed in Sarajevo in a number
16 of different locations, as a matter of fact. And I can't say for sure
17 what those locations were.
18 The remainder, and the principal component of the command was
19 the --
20 THE INTERPRETER: The interpreter did not hear the location.
21 MR. KARADZIC: [Interpretation]
22 Q. What about the 1st Corps command? Was it in the city itself or
24 A. Yes. The 1st Corps command, as I said, was at
25 Danijela Ozme Street near the main hygiene office. There's a big park in
1 the middle of Sarajevo, just across the street from the Presidency
2 building. It's difficult to keep track, because I have forgotten a lot
3 of the streets involved, although I did live there at one time, but I
4 think I'm right about this. It was across the way from the Presidency
6 Q. Thank you very much. General, sir, you mentioned the division
7 artillery group. Were there other artillery groups, and can you explain
8 what weapons were available to the 12th Division within the city itself?
9 THE ACCUSED: [Interpretation] I would like the Chamber to rule
10 whether the general is allowed to use his notes.
11 JUDGE KWON: Yes.
12 THE WITNESS: [Interpretation] It's not very practical for me to
13 use so. It's slightly complicated, because I don't have my notes in
14 electronic format.
15 So there was the structure that was shown as the command
16 structure with all of its elements. And then I also have this
17 information here, reliable information, on combat equipment. If I may, I
18 have a lot of information to share here, and I'd just like to specify the
19 provenance if the Chamber allows, what the supply sources were, where all
20 of this came from.
21 JUDGE KWON: Yes, Ms. Edgerton.
22 MS. EDGERTON: I think we need to explore that, Your Honour,
23 because this is not about the general, with respect, testifying on the
24 basis of his notes.
25 JUDGE KWON: I have no clue what the -- what general was
1 referring to. It's for Mr. Karadzic to take up this, but -- yes,
2 Mr. Milosevic, what document were you referring to?
3 THE WITNESS: [Interpretation] I would like to make one thing
4 clear. I wanted to say what the indicators are telling me that the
5 numbers here are true and that these numbers existed. If I may be
6 allowed to explain that. You will receive an answer, because that will
7 then tally with the previous confirmation.
8 JUDGE KWON: The question you were asked about is the artillery
9 group, and in particular what weapons were available to the 12th Division
10 within the city itself. So you can tell us what weapons were available,
11 not necessarily the numbers.
12 THE WITNESS: [Interpretation] Yes. I understand.
13 MR. KARADZIC: [Interpretation]
14 Q. If I may, General, sir, if I may assist. According to your
15 records, according to your information, how many mortars, 80-millimetres,
16 62-millimetre -- 82-millimetre, 60-millimetre, and 122-millimetre mortars
17 were there in the city itself?
18 A. I can proffer some information that will corroborate this, if I
19 may, just in order to follow a sequence that will confirm the existence
20 of these figures. So if I may, if the Chamber can allow me to explain
21 that I can move on to the figures afterwards because that is quite --
22 well, you know.
23 JUDGE KWON: Let's hear him out, Ms. Edgerton.
24 Yes, please proceed, Mr. Milosevic.
25 THE WITNESS: [Interpretation] There's a story behind all of this.
1 When the crisis first began in the former Yugoslavia and combat equipment
2 was brought in from Croatia, from Slovenia, and from elsewhere, why was
3 it being brought to Sarajevo? I don't know. What I do know is that it
4 was now there. Specifically, it was now at the Marsal Tito Barracks at
5 the Jusuf Dzonlic Barracks, and some of it went to Lukavica; meaning when
6 the situation finally began to unravel, when certain areas were created
7 under the control of this party or that party, then all this equipment at
8 the Marsal Tito Barracks, Jusuf Dzonlic, Jajce, Victor Bubanj, all these
9 military compounds, the weapons were kept there, held back, and ended up
10 in the hands of the 1st BH Army Corps. All the companies that used to
11 operate in existent peacetime, these were large-scale systems and they
12 all had their anti-aircraft weapons or anti-aircraft weapon systems.
13 That was part of the protection set-up. So everything that was there was
14 now within the 1st Corps.
15 In this case we're talking about the 12th Division, in a narrower
16 sense. The more weapons that came in simply boosted these figures.
17 Now there was this entire infrastructure in place in terms of
18 accommodation, in terms of command, in terms of the supplies, logistics,
19 repairs. This was all now in the hands of the 1st Corps.
20 As for any military facilities that ended up in the hands of the
21 Sarajevo-Romanija Corps, there was only one such facility, Lukavica.
22 It's also true that some of the equipment ended up in Lukavica and that
23 was where it stayed. I'm talking about the equipment coming in from
24 Croatia, Slovenia, and other territories across the former Yugoslavia.
25 So when I say that there were six howitzers, 120 millimetre, it's
1 a self-propelled weapon, these are the same howitzers that ended up in
2 the Marsal Tito Barracks. So as soon as the men pulled out, students,
3 pupils, secondary military school, military academy, and so on and so
4 forth --
5 THE INTERPRETER: The interpreter did not hear the last part of
6 the witness's answer.
7 THE WITNESS: [Interpretation] Everything else that I'm talking
8 about here are weapons that ended up in that area and they now had them.
9 The weapons were available to them. Talking about anti-aircraft,
10 PAT 20/1 and 20/3, these came from the previously operating civilian
11 companies that I mentioned and these weapons were part of the erstwhile
12 protection and defence set up.
13 So if we put this all together, 60 millimetre, 82- and
14 120-millimetre mortars, there were between 140 [Realtime transcript read
15 in error "100"] and 150 of those in the city itself. Howitzers,
16 122-millimetre, the self-propelled howitzer, six of those;
17 105-millimetre, three howitzers; T-55 tank, three of those;
18 130-millimetre gun, and to be quite specific, it was not in Sarajevo. It
19 was on Mount Igman, and it was firing Sarajevo from Mount Igman because
20 the range for that particular gun is over 30 kilometres; 76-millimetre
21 gun called ZiS, it's a reference to Stalin. Four of those were
22 available; recoilless cannons, 82-millimetres, we discovered that they
23 had a total of 16 of those, but possibly many more than that that we
24 didn't find. So when you fire this cannon, you can see it from miles
25 away, because normally when it fires there's a plume of smoke rising from
1 the gun.
2 What I didn't say, all of the weapons of the special brigade for
3 Yugoslavia. I'm talking about the MUP. I'm not sure what they called it
4 at the time. There was this special brigade whose task it was to prevent
6 So this equipment was kept at a location known as Krtelj, which
7 is right next to Donji Kotorac. Earlier on we said that the
8 104th Motorised Brigade was stationed there.
9 So this was a selection of equipment, APCs, and what was known as
10 Vidra. All of this was, in a manner of speaking, grabbed by the MUP,
11 Sarajevo's police. Then it stayed there and was used as combat
13 These are sophisticated weapons. These are wood weapons, and
14 commanders were using these to drive across Sarajevo and not expose
15 themselves to danger, although actually it was meant to be used by
16 someone else, but that was a different matter altogether.
17 So everything that I've been telling you about is in relation to
18 1994. I'm talking about this period and information telling us what
19 weapons were available to the corps command, and then additional weapons
20 started coming in for the 1st Corps in its entirety with equipment coming
21 in from wherever, further afield, and their friends were helping. And
22 these are the Crna Strela rockets, and the 9K11 rockets, and then
23 107-millimetre rockets, the so-called VBRs, multi-rocket launchers.
24 JUDGE KWON: General, could we pause there. Could we see the
25 memo or document you are looking at now with the assistance of the usher
1 through the ELMO.
2 I see the time. Shall we take a break now? In the meantime,
3 you'd like at that take a look at the document, Ms. Edgerton, yourself?
4 MS. EDGERTON: If it's what I think it is, the General's just
5 read most of page 6 of his aide-memoire into the record, but I will take
6 a look at it to confirm that.
7 JUDGE KWON: In English, what page it would be?
8 MS. EDGERTON: English page 6.
9 JUDGE KWON: Did the Chamber receive that aide-memoire?
10 THE ACCUSED: [Interpretation] I believe that it did. The Serbian
11 version is in the -- in the handwriting is page 11. It was sent by
12 electronic -- it was sent out on Sunday electronically.
13 JUDGE KWON: What Chamber received is a document titled proofing
15 MR. ROBINSON: Yes, Mr. President. The exact situation is that
16 you didn't receive the English. So only the Prosecution received that.
17 JUDGE KWON: That's why I was asking. We'll take a break for 45
18 minutes and resume at 1.25.
19 --- Luncheon recess taken at 12.39 p.m.
20 --- On resuming at 1.26 p.m.
21 JUDGE KWON: Now I understood the nature of the document you
22 relied on, but where did you get those information, Mr. Milosevic, which
23 is written on this document which we see now in front of us?
24 THE WITNESS: [Interpretation] I -- well, the information is the
25 result the direct discovery of the existence of firing position and the
1 fire from these weapons from the relevant firing positions from the
2 Sarajevo area. This is one source of the information. This is through
3 the observation system and by observing the existing weapons as they were
4 firing and also while the weapons were being transferred from one firing
5 position to another. This is one type of information.
6 Then in the system of their documents, documents created by the
7 commands that we're talking about from the 1st Corps or from the 20th --
8 12th Division according to the type of fire they were planning and the
9 actual firing that they executed, we worked out what their resources were
10 in this sense at their disposal. There is a document. These are their
11 original documents in which General Siber divided 100 mortars,
12 60-millimetre -- 160-millimetre mortars were distributed to the units. I
13 really couldn't see that many, but it turns out that there were one
14 hundred 60-millimetre mortars. I don't know if they fired or not.
15 That's a different matter. That would be that.
16 JUDGE KWON: Very well. I'll leave it at that.
17 Please continue, Mr. Karadzic.
18 Just one matter. For the record, Mr. Milosevic, you referred to
19 Lieutenant-Colonel or Colonel Dzambasevic. I take it his name is
20 Dzambasovic, not s-e-v-i-c with last five letters s-o-v-i-c.
21 THE WITNESS: [Interpretation] Dzambasovic.
22 JUDGE KWON: It appears on transcript page 4, line 16, 22, and
23 24. And he was one of the Prosecution witnesses, Ms. Edgerton?
24 MS. EDGERTON: Correct.
25 JUDGE KWON: Thank you. Please continue.
1 THE ACCUSED: [Interpretation]
2 Q. General, sir, on page 66, line 10, I heard you say that there
3 were between 140 and 150 mortars, but in the transcript it states between
4 100 and 150?
5 A. What is correct is what is written. That's what I should have
6 said, and that's probably what I said, that there were between 140 and
7 150 mortars.
8 Q. Thank you. General, I admire your thoroughness and I'm very
9 grateful for that, but we really must now start dealing with conduct and
10 actions and things like that. So we need to complete this as soon as
12 Are you able to tell us whether all of these resources were
13 stationary or whether some of them were movable and would appear in
14 several places and how was this done?
15 A. My screen is not working. I don't know.
16 Q. Do you have page 11 in front of you now?
17 A. Yes, yes, I do have it. I thought that I had to see your
18 questions on the monitor. All right. Very well. Thank you.
19 It's quite clear that these were not stationary weapons. None of
20 them were stationary and installed only in one place. It's a rule, it's
21 a principle that weapons would change their firing positions because they
22 would be discovered when they are used and so on and so forth. So some
23 of them were stationary, some were not, but generally speaking, their
24 positions would change.
25 Q. Thank you. Were there any mobile resources of large calibre that
1 could be fired?
2 A. Of course, there were. I don't know if I should describe it as a
3 major folly, but there were vehicle-mounted weapons. They would be
4 fired, and then they would be moved away. I don't consider that to be
5 warfare with any kind of logic or anything that would take into account
6 the rules of warfare.
7 Q. Thank you very much. And these mobile assets, they were fired
8 from which areas?
9 A. Those assets often moved from the Zitomlin sector. This is the
10 area of the Blagoje Parovic Street or possibly behind some larger
11 buildings so that they would be less noticeable, but always you would
12 notice if they were fired. In any case, they were mostly around the
13 Blagoje Parovic Street. This is the new Sarajevo, centre of new
15 Q. Thank you. In order to finish with this question of the
16 deployment of forces, could you please tell me whose forces, for example,
17 were in Hrasnica, Sokolovic Kolonija, and Butmir?
18 A. It's very important that I should give a clear answer to this
19 question. This is the 104th Motorised Brigade that we're talking about
20 here, which by its size was third largest brigade in that area. As for
21 its combat assets, it was a brigade that had the greatest amount of these
22 assets. That was the 104th in the area of Hrasnica, Butmir,
23 Sokolovic Kolonija, and the eastern slopes of Igman.
24 Q. Thank you. Perhaps we could call up a map which we marked
25 earlier with a witness, foreign witness, and then we could ask you to
1 tell us whether the map correctly reflects who is where. Can we look at
2 1D32243, please.
3 A. Yes, yes.
4 Q. Could you begin from the south?
5 THE INTERPRETER: The interpreter did not catch the names.
6 MR. KARADZIC: [Interpretation]
7 Q. You told us who was there. Who was in Dobrinja in that central
9 A. The 155th Mountain Brigade was in Dobrinja, and as I said it was
10 under the command of Hadzic, Ismet Hadzic, a civilian.
11 Q. Thank you. And who was at these elevations at Mojmilo Brdo and
12 Hrasno Brdo?
13 A. The 101st Mountain Brigade was there. That entire line was held
14 by them from Hrasno Brdo all the way down to the Miljacka.
15 Q. Thank you. Who was at Debelo Brdo and Colina Kapa?
16 A. The 115th Mountain Brigade.
17 Q. And you're talking about brigades that were part of the
18 1st Corps; is that correct?
19 A. Yes, of course.
20 Q. And who was at Jajce? What does that mean, Jajce, and who was
22 A. Jajce is a barracks. It's a military facility. That's where the
23 152nd Brigade was. It was somewhat smaller in terms of its strength and
24 Hilmo Kovac was in command. He was an officer that I admired highly,
25 even in his conduct towards the enemy he was knightly, chivalrous.
1 Q. Thank you and who was at Grdonj?
2 A. Well, I'm not managing to wait for this -- ah, all right. In
3 Grdonj and in a broader area than that, but specifically at Grdonj the
4 105th Mountain Brigade was situated. It was under the command of
5 Major Izet Bisevic.
6 Q. Can you tell the Trial Chamber about the Grdonj and the
7 disposition of the 105th Brigade, and how did that relate to
8 Spicasta Stijena and the village of Mrkovici? Could you please mark the
9 village of Mrkovici here on the map.
10 MS. EDGERTON: Your Honour.
11 JUDGE KWON: Yes.
12 MS. EDGERTON: Just for the sake of the record, it's a satellite
13 photograph, not a map.
14 THE WITNESS: [Interpretation] Should I mark this?
15 MR. KARADZIC: [Interpretation]
16 Q. Well, you can mark it in black because in the original we are --
17 already have markings in red and blue. Could you please mark Mrkovici
18 and could you please tell us what -- the census of the events around
19 Spicasta Stijena and Mrkovici?
20 A. I'm not going to be able to pinpoint Spicasta Stijena here. All
21 I can do is indicate the direction in which it could be in relation to
22 the Grdonj location. This is here in this area, which has to do with the
23 disposition of the 1st Corps. The forces of the Sarajevo-Romanija Corps
24 were not at Spicasta Stijena. They were in the area of Mala Kula, and
25 that area is behind Spicasta Stijena. And this is what -- is something
1 that is being stated throughout the whole course of things that we were
2 at Spicasta Stijena, but actually it's just a normal area, not a rock or
3 a -- anything like that, and that's where the forces of the
4 Sarajevo-Romanija Corps were.
5 Q. All right. Thank you. Could you mark the village of Mrkovici
6 with a number 2.
7 A. I don't see the word indicating the village of Mrkovici, but I
8 know where it is. So it would be somewhere here. Mrkovici.
9 Q. Thank you. And, General, sir, are you able to tell us briefly
10 why in the reports Spicasta Stijena is mentioned so frequently? Mrkovici
11 as well. What were the military activities there, and what was the
12 purpose of the same?
13 A. The key area that is of particular significance for the
14 Sarajevo-Romanija Corps is the road leading from Pale via Sumbulovac to
15 Vogosca, and then on to the rest of the front covered by the
16 Sarajevo-Romanija Corps, that road passes in the immediate vicinity of
17 the village of Mrkovici. As for the 1st Corps, or, rather, the
18 12th Division, what was key was to attempt to cut off this road and in
19 that way divide in two our front, one in the north-west and the other
20 part would stay in the south, south-east or south-western area. So their
21 activities were aimed via Spicasta Stijena at Mrkovici with the objective
22 of severing the road and gaining a military advantage. Our situation did
23 not permit us to lose this military advantage in terms of how we would
24 live and function and carry out our combat activities.
25 The attacks and the assaults were daily, and I'm not exaggerating
1 when I say this. However, the minor ones are not that important. They
2 attempted to break through with a considerably strong force, and then in
3 the situation when they were prevented from doing that, then they would
4 not report that somebody was firing at Sarajevo. They would say the
5 Chetnik forces turned us back to our positions. So meaning that we fired
6 at their positions and not at the city. This is one thing, an attempt to
7 concentrate forces.
8 So this main thrust was attempted on the 18th of September, 1994,
9 and it was not only directed at Spicasta Stijena and the axis towards
10 Mrkovici but other axes as well. This attack was prevented. It was
11 stopped. I came to that place where there were soldiers attempting to
12 break through, encountered some of our mines, and in one place I could
13 see seven dead people there, men who were killed, and I couldn't help
14 myself. Your Honours, if you believe me, I cried over those dead bodies.
15 It was sending people to their death. That's what it was. Seven people
16 in one place were beheaded. Their limbs were blown off in that mine
17 explosion. And I asked myself, who is it that is sending those people
18 towards us without any proper estimation? These people were not skilled
19 for these tasks.
20 Q. Thank you. General, sir, who defended Mrkovici from the
21 Sarajevo-Romanija Corps, which unit?
22 A. The entire -- the entire area between the Miljacka canyon where
23 Miljacka flows into Sarajevo, as I mentioned earlier, via Hresa, and the
24 positions at Mrkovici, Radava, Poljine, all the way to Rajlovac and the
25 place where the Miljacka flows out of Sarajevo, all these positions were
1 held by the 3rd Sarajevo Brigade. That was the main force and the only
2 force that held the entire north-west and part of the north-eastern part.
3 Q. Thank you. Where were these soldiers from?
4 A. What soldiers?
5 Q. Well, the members of the 3rd Brigade? Where were they from?
6 Where did they hail from?
7 A. Well, not just them when talking about the 3rd Sarajevo Brigade,
8 but this will imply to -- this will be true of all those who were in
9 Sarajevo. They were all from the areas, for instance, from Vogosca,
10 Rajlovac, Poljine, Mrkovici, Hresa, in other words -- from Bulog [phoen].
11 In other words, from those villages and the surrounding areas that were
12 there. They were mobilised from there and became members of the
13 3rd Sarajevo Brigade.
14 Q. Thank you. Could you please indicate on this image, this
15 satellite image, where Sedrenik was vis-a-vis Grdonj and what military
16 installations there were there if there were any, and what was the
17 distance between Spicasta Stijena and your positions and Sedrenik?
18 A. Well, first the area of Grdonj, that's the line that was covered
19 by the 12th Division of the 1st Corps, and they had the 105th Brigade,
20 which I mentioned earlier.
21 Now, behind them or in there in their area was Hresa -- or
22 rather, not Hresa but --
23 Q. Sedrenik?
24 A. Well, that's correct, Sedrenik.
25 Q. Well, where is Sedrenik? Could you mark it with an S on these
1 slopes below Grdonj?
2 A. Well, it should be here approximately. This is the area right
3 below Grdonj toward the town itself.
4 Q. Did you have any snipers deployed at Spicasta Stijena, and would
5 they have been in a position to open fire from Spicasta Stijena?
6 A. Well, no. These are great distances, so it would be absolutely
7 impossible to use any type of infantry weapons. You could only use
8 artillery, of course.
9 Q. Well, the artillery that was in Mrkovici village, what did they
10 open fire at?
11 A. Well, no. The artillery was withdrawn, was extracted from there,
12 and it was placed under the command of UNPROFOR. It was centred in
13 certain areas.
14 Q. Well, my apologies. Mortar tubes.
15 A. Well, they too. And I'm talking about the period when UNPROFOR
16 had made sure that all weapons would be placed under control. So the
17 mortars were under their control as well.
18 Q. Thank you. Would you please now go on. Let's take a look at
19 Kobilja Glava, Hum, Zuc, and Sokolje. Who was in control of those hills
20 or elevations?
21 A. Certainly. Hum was within the system of deployment of the city
22 itself, except it was at a higher elevation. But Kobilja Glava and Zuc,
23 let's talk about that. But there is no Orlic mentioned here or indicated
24 here. And that was the highest elevation there between Kobilja Glava and
25 Zuc, 800-something metres. Orlic, mount -- or a hill -- a peak, a
1 mountain peak. This was the area that was under the control of the
2 112th Division -- or, rather, brigade.
3 Q. Would you please indicate Orlic hill. What about Sokolje.
4 A. Well, we'll come to Sokolje. Orlic would be about here
6 Q. Can we take that to be the letter O?
7 A. Yes.
8 Q. And now could you just tell us who had control of Sokolje?
9 A. The area of Sokolje -- well, let me just make one thing clear.
10 Sokolje was both a hill, and there was also a settlement, a place where
11 people lived called Sokolje. And that was under the control of the
12 111th Mountain Brigade of the 1st Corps -- or, rather, of the
13 12th Division. This position is dominant over Rajlovac, so the entire
14 area of Rajlovac and the Sarajevo field are below these elevations such
15 as Sokolje, Bresce Brdo, and so on and so on and so forth.
16 Q. Thank you. We don't have time now to ask you to mark Balino Brdo
17 and Bresce Brdo, but --
18 A. Well, here. It's right here, right next to Sokolje, Bresce Brdo,
19 and I'll put a B there. But I don't see -- well, it's a bit lower than
20 it should be.
21 Q. Would you please date and sign this image in the bottom right,
22 and could you tell us whether you would make any alterations to this
23 image in terms of what areas were under the control of the BH Army?
24 A. Well, there's no need to make any alterations. I would just like
25 to make it quite clear what the situation was with the Nedzarici area.
1 It was in disastrous position. It was semi-surrounded and under attack,
2 the objective being to destroy it.
3 THE ACCUSED: [Interpretation] I'd like to tender this document,
5 JUDGE KWON: Yes.
6 THE REGISTRAR: Exhibit D2794, Your Honours.
7 THE ACCUSED: [Interpretation] Thank you.
8 MR. KARADZIC: [Interpretation]
9 Q. General, sir, at the beginning of your evidence today, you
10 mentioned the intentions, the objectives of the 1st Corps of the BH Army.
11 Could you --
12 JUDGE KWON: Yes. Just a second. Yes, Ms. Edgerton.
13 MS. EDGERTON: I'm very sorry, Your Honours. Just to note with
14 respect to this document which I see is entitled in e-court "Annotated
15 map based on Harland markings in court," Your Honours may recall -- well,
16 in fact I direct Your Honours to page 2371 where there was a discussion
17 of that map, and Mr. Tieger indicated on my behalf that the map which you
18 now see in front of you is a map that included locations which were not
19 only generally referenced by Mr. Harland but also additional locations
20 requested by the accused. So I just wanted to make that clarification
21 when I saw the title of the document. It's not necessarily reflective of
22 locations marked by Harland at all.
23 JUDGE KWON: I remember I encouraged some discussion and to reach
24 an agreement, and I take it that such agreement has never been reached.
25 MS. EDGERTON: But we did engage in discussion in good faith,
1 both parties.
2 JUDGE KWON: You have no problem admitting it as such?
3 MS. EDGERTON: No, no.
4 JUDGE KWON: With that caveat.
5 MS. EDGERTON: Of course.
6 JUDGE KWON: Thank you.
7 Let's continue, Mr. Karadzic.
8 MR. KARADZIC: [Interpretation]
9 Q. Today on page 11, you mentioned the objectives, the intentions of
10 the 1st Corps as well as the purpose of their activities. Could you tell
11 us briefly what the intention of the 1st Corps of the BH Army was, and in
12 particular, the objective of its -- the intention of its 12th Division,
13 and that in relation to your area.
14 A. Well, there is no brief answer to this question, but I'll try to
15 be as brief as I can. The intention was to break through the front line.
16 Now, to be more specific, all operations that were directed through
17 Nedzarici along that axis towards the west had the objective of linking
18 up with airforces in Butmir and Hrasnica. Now, the forces that were in
19 that area, our forces, my forces, they were exposed to constant and total
20 barrage fire with the strongest assets. That's number one. And as far
21 as we could assess the intentions of the enemy, and it's not difficult,
22 it's easy to assess what an enemy's intentions are in a situation like
23 this. Now, the next thing. The cutting off of the road that I mentioned
24 earlier, the road between Pale and Vogosca, that action, that operation,
25 was carried out on the eastward axis via Spicasta Stijena and Mrkovici,
1 and that's where the road is. It's in the vicinity near Mala Kula where
2 our forces were deployed. So if our forces were to be cut off there,
3 then we would lose contact with several brigades.
4 Next, there was an absolute attempt, and they did everything in
5 their power, to cut off the communication leading toward Trnovo from the
6 area of Mount Igman. In other words, from the positions from which the
7 104th Motorised Brigade engaged us. So if they were to cut off the road
8 at Krupac, which was close to Vojkovici village, if that were to happen,
9 we would lose that part of the front line, and we would have no access to
11 The other operations that I could tell you about also had to do
12 with attempts to cut us off in order to prevent us from moving and using
13 our units along the axis between Semizovac towards Nisici.
14 In the area of Srednje village they were in a dominant position
15 which was 800 metres at an elevation of 800 metres, so this road was
16 threatened, and if the road leading to Nisici were to be cut off, then
17 our entire area of Ilidza would be cut off and completely surrounded,
18 including Rajlovac, Hadzici, Vogosca, and Semizovici, not to mention what
19 the situation like with Ilijas. So these were their general intentions,
20 and they kept trying to resolve this and to get it done and finally they
21 did with a Tekbir operation.
22 Q. Thank you. Now, you mentioned that -- the term temporarily taken
23 or temporarily captured territory. What did that -- what meaning did
24 that have in terms of their intentions? What was its significance?
25 A. Well, they legalised, as it were, or legitimised their own
1 actions. So this was a temporarily taken position. This meant that
2 whenever an area was defended and protected by where the
3 Sarajevo-Romanija Corps had its forces, they considered that those were
4 areas that they could legitimately put back under their own control. So
5 this is the significance of the temporarily captured or -- territory.
6 And I repeat that the original meaning of that was it was used in the
7 event of a foreign aggression where people would have the right to defend
8 themselves and there would be people living there, houses of Trapare and
9 Ivcici and so on.
10 Q. Thank you. Now, what significance would this have on the entire
11 war operations in Bosnia and Herzegovina had the 1st Romanija Corps --
12 the 1st BH Army Corps managed to break out of Sarajevo and move on?
13 A. What that would mean? A disaster, a catastrophe. That was
14 overambitious. It was not realistic. And there was an excess of
15 attempts to make it seem as if nobody would be left with anything else,
16 that everything belonged to them. I don't want to go into what belonged
17 to whom, but I just know what the task of the Sarajevo-Romanija Corps
18 was. That was to defend the area where they were deployed. However,
19 that is abundantly clear. Such a force, should it break through, would
20 advance and overwhelm the entire territory of Bosnia and Herzegovina.
21 And I would like to just point out here that it -- I'm not here in order
22 to worry about the Republika Srpska -- or, rather, the Sarajevo-Romanija
23 Corps' corps did not concern itself with the territory of
24 Republika Srpska. Our job, our task was to defend that area where we
25 were deployed. But were they to break through that would automatically
1 jeopardise the rest of the territory. But I don't want to go further
2 into that and elaborate, because had they managed to cut off the
3 Rogoj Pass and connect, link up with Gorazde, then Herzegovina would have
4 been lost. It would be cut off, and it would remain encircled. They
5 would have encircled it. So that's how it was. In other words, you
6 would have had to be a giant in order to be able to fight back and fight
7 with them.
8 Q. Can you tell us what the consequences would have been for the
9 immediate surroundings and the Serb villages around Sarajevo had the
10 Sarajevo-Romanija Corps given in?
11 A. Your Honours this is too broad a subject. I'm going to try and
12 give you the basics on this and that have been quite a fine achievement
13 given the time available to us. I'm talking about the area where there
14 were people that we were meant to protect. They felt it would be a
15 disaster were the corps to give in and allow an enemy incursion into our
16 territory. People were pleading so much. People were trying to
17 encourage us to persist and to do everything in our power to protect them
18 from this incursion. People were living in fear, because were there to
19 be a breakthrough by the enemy that would have meant their disappearance
20 from the area.
21 Q. And what about the enemy getting into Serb villages such as
22 Cemerno and other villages? Did that fear felt by the population appear
23 to be founded?
24 A. Whenever anything like that happened it caused suffering to the
25 people on the receiving end. And it's more than just Cemerno, the area
1 around the village and the village itself. I'm aware of that village for
2 a different reason, not because I have direct experience. I received
3 word at the time that people were killed there, that houses were burned,
4 but the disaster that struck Velesici -- or, rather, Pofalici was in my
5 opinion an even greater disaster. It was on the 15th of May, 1992. Were
6 those military units or paramilitaries units, I don't know, but they were
7 certainly extremists who got there, who set fire to houses and killed the
8 locals there in that area.
9 Q. Thank you. What was the type of operations that the 1st Corps
10 conducted in order to achieve these objectives? Can you tell us more
11 about that? What type of combat operation? What type of offensive?
12 What did you as a corps have to resist at your time as chief and later on
13 at your time as corps commander?
14 A. As for the sheer variety of the operations unleashed against us,
15 I can only congratulate them here or elsewhere. They devised their
16 combat operations in a very clever way. All of the combat activities and
17 operations that were launched in a tactical, operational and strategic
18 sense we used. They used everything that was available. They tried to
19 break through the lines. They tried to infiltrate and get behind our
20 lines. They tried to use artillery. They used night-time combat as
21 well. Sometimes we would find out in the morning that five of our men
22 had been killed the previous night, men deployed at particular positions.
23 So there was a variety -- variety of different operations and actions
24 that they were using, sabotage operations, planting explosives, and so on
25 and so forth. They were particularly good at sniping.
1 I know the person who was in charge of devising this strategy.
2 He's a highly skilled military officer. So he created this environment,
3 and he ran the whole show. These activities and operations covered a
4 particularly broad area, and this constituted an enormous danger to the
5 safety of our own men.
6 Q. Thank you very much. When you look at media reports or indeed
7 when you look at evidence given before this Tribunal, one often mentions
8 acts of provocation by the Muslims and our reaction to those taunts or
9 acts of provocation. How do you distinguish between the two, the mere
10 act of provocation on the one hand and a real combat operation on the
12 A. The two were difficult to tell, and the intention behind each was
13 difficult to distinguish, but we needed a working assessment in both
14 cases, and we had to sort of decipher this for ourselves every time. It
15 would have been irrational. It would have been needless to respond to
16 provocation. So what we needed was reliable information indicating
17 whether there was any serious intention of a military incursion, an
18 attempt to break through our lines before we started firing back.
19 Normally we did not rise to the bait. Obviously sometimes it was easy to
20 tell, but we needed to exercise some caution in terms of our own
21 assessments when assessing the intentions behind a particular move that
22 they were making.
23 Q. Thank you. When you were brigade commander, did you know where
24 they were, where their units and weapons were?
25 A. I think I stated before this Chamber that we knew the enemy
1 really well. We had them down to a T. But all this goes back to the
2 initial stage in those early days when we all had to assess our own
3 situations at our own basic level. So we knew where they were. We knew
4 what they were doing, and we knew what their intentions were and what the
5 danger involved for everyone was. And we had to go on studying the
6 situation, obviously. The same thing that was done at brigade level was
7 also studied elsewhere using certain methods, and then an assessment was
8 drawn up at corps level in order to arrive at their intentions.
9 Q. Thank you very much. I would like to show you a series of
10 documents that you produced at the time. Therefore 65 ter 12446, please,
11 in e-court.
12 MS. EDGERTON: I think that's also P4498, Your Honours.
13 JUDGE KWON: Thank you.
14 MR. KARADZIC: [Interpretation]
15 Q. General, sir, this has been admitted already, so we'll not be
16 dwelling on this. You're talking about the disposition of enemy units;
18 A. Yes, that's right.
19 Q. Boljakov Potok right next to the supermarket. And then you
20 mention all these locations, the skyscraper near the Kosevo pharmacy,
21 Hrasno Brdo, Mojmilo, the Muslim Sandzak Brigade 900 to 1.000 men. And
22 then you talk about Treska. What is this Treska?
23 A. It's a building. There was a furniture shop there. It was a
24 Skopje based company, a Macedonian company.
25 Q. And you mentioned Zetra. What is Zetra?
1 A. It's a sports hall. It's a sports venue.
2 Q. Thank you. The Kosevo Hospital perimeter, there was a unit there
3 that was stationed there.
4 A. Yes. I'm not sure it's necessary to go through all this
5 information. It was information that we obtained in a variety of ways.
6 So it's just information that was available to us at this initial stage.
7 Q. Can we have the next page in the Serbian please. Elementary
8 school, medical school. You see what it says there. The use of civilian
9 facilities and buildings such as schools and hospitals.
10 To what extent did the 1st Corps resort to measures such as those
11 using such civilian facilities and buildings for military purposes, that
13 A. Anything that was available, the facilities and buildings
14 available within the city of Sarajevo, any possible purpose at all that
15 these were used for. All of that was taken by the 1st Corps. Schools,
16 hospitals, too, but let's not focus on that, because it was only
17 Kosevo Hospital that they were using, not any of the other hospitals
18 across the city. Nurseries, commercial buildings, shops, private homes,
19 pubs. It was all covered.
20 Had I been able to use such facilities in my capacity as
21 commander in -- my position would have been a lot better than it was. So
22 they had everything, all the facilities available to them, civilian,
23 military and so on.
24 Finally, when it came to the implementation of the
25 Dayton Accords, their own authorities found it very difficult to persuade
1 them to actually leave those facilities. The military had settled in and
2 they ruled the roost, as it were. They refused to leave.
3 Q. Thank you very much. General, sir, but did they leave at least a
4 single civilian area that would have been a safe place for civilians to
5 stay inside Sarajevo and that did not comprise a single potential
6 military target?
7 A. There were no such areas in Sarajevo. I'll try and be more
8 specific about this. If we're talking about a distance, say, 100 metres
9 between a weapon and the troops there, then you can't consider that to be
10 a civilian area, a safe civilian area. They did not have a choice but to
11 use the space available in order to deploy their troops.
12 Q. Thank you very much. 1D07036, please. Thank you.
13 JUDGE KWON: Mr. Milosevic, you said that, say, a distance of 100
14 metres between a weapon and the troops there, and you can't consider that
15 could be a civilian area. Does it mean that you can shell any part of
16 the area, that being the case?
17 THE WITNESS: [Interpretation] We were not allowed to shell a
18 civilian area, nor indeed would we have chosen to shell a civilian area.
19 The Sarajevo-Romanija Corps didn't do that. Wherever there were
20 civilians, that meant that was not a target for us. We never fired at
21 those areas.
22 JUDGE KWON: What did you mean that you couldn't consider those
23 area to be a civilian area?
24 THE WITNESS: [Interpretation] I probably misspoke in that sense,
25 because that's not what I meant. What I'm trying to say -- if someone
1 was a hundred metres away, that doesn't mean that this person is in an
2 area that is exclusively civilian.
3 JUDGE KWON: Very well. Please continue, Mr. Karadzic.
4 MR. KARADZIC: [Interpretation]
5 Q. General, sir, this is the command of the 1st Romanija Corps, the
6 1st of October. What are you doing there? You are simply rattling off a
7 list of forces of the Sarajevo-Romanija Corps and then everything else
8 that you see there: Bosna Transport, Prorad [phoen], Hrasno elementary
9 school, faculty of architecture, Kosevo Hospital.
10 A. I have nothing special to add. These locations that we
11 identified were their collection points.
12 THE ACCUSED: [Interpretation] Next page in English please, and
13 also the next page in Serbian. Thank you.
14 MR. KARADZIC: [Interpretation]
15 Q. Can you please read out loud the first paragraph from this page.
16 A. I might find that somewhat difficult:
17 "At the railway station near the Vuk Karadzic elementary school,
18 the medical school, the Kosevo stadium, the Marsal Tito Barracks, and the
19 Victor Bubanj Barracks are deployed enemy artillery groups and individual
20 artillery weapons. The artillery groups are of a mixed composition and
21 strength, and they cover a broad area."
22 Q. Can you tell the Chamber where, for example, this medical school
23 used to be? Do you remember the exact location in relation to Bjelovar?
24 A. Yes, yes, right. Right. These schools, the medical school, the
25 secondary school for dentists and dental technicians, it's all within the
1 Kosevo Hospital compound which was a large compound at Bjelovar.
2 Q. Thank you.
3 THE ACCUSED: [Interpretation] I would like to tender this
5 JUDGE KWON: Yes, we'll receive it.
6 THE REGISTRAR: As Exhibit D2795, Your Honours.
7 MR. KARADZIC: [Interpretation]
8 Q. You said that you did not always respond to any -- every
9 provocation. What was your reason not to respond to each provocation?
10 A. Well, it's not only that it was provocations. A response to
11 their fire would often be no response not even when there was firing but
12 it did not have the nature of a provocation. Those who are to use their
13 weapons, and I'm talking from the position of the
14 Sarajevo-Romanija Corps, had to secure a whole series of indicators in
15 order to decide, to decide to open fire. The system of observation, all
16 kinds of observation, observation of artillery, movements of the
17 infantry, surveillance of the terrain, all of that was covered by our
18 observation posts, and the observers had to provide information about
19 what they were seeing and what was happening there and from which area
20 did they open fire at us.
21 One detail that occurred very often was that they would open fire
22 at us, but they would fall below target because they use an insufficient
23 charge or because the crews were not working properly, so the shells
24 would fall short. They would not reach the intended purpose. So for
25 that reason there was no need for us to intervene or to open fire. So
1 for a senior officer to decide whether he would fire at a target or not,
2 there had to be a certain number of indicators as well as there had to be
3 an estimate as to whether there would be civilian victims or not. If
4 there was any chance that there would be civilian casualties, then one
5 would not open fire. If it was established that the area was clear but
6 there was a danger, in that event we would open fire.
7 Q. General, sir, thank you. This is intriguing to me that they even
8 fell into their territory due to errors. So are you saying that there
9 were instances when they did not deliberately fire at their own
11 A. Yes. Yes. The first point is correct factually. They did that
12 without intending to fire at themselves, because there were some cases
13 when the projectiles fell short. But there were also situations when
14 their explosives blew up at the very location where the fire was coming
15 from. We don't know whether this was for technical reasons or
16 mishandling. That is something else.
17 Secondly, it was very obvious that there were clans, I would call
18 them, in Sarajevo who would vie with one another, and they would shoot at
19 each other in order to silence them and to grab the area from them. They
20 had their own calculations there. But it was always with the expectation
21 that that would be considered as fire coming from us.
22 Observers would report and follow. I did not ever manage to see
23 it, but I was interested in it. They would report that, let's say from
24 the area of Sirokaca, which is an area below Trebevic, they were firing
25 at Kosevsko Brdo hill. Why they were firing there, what they were
1 settling accounts for we don't know, but this would happen.
2 There was some other such instances, very original and very
4 Q. Thank you. And what about Livanjska Street? Where is
5 Livanjska Street in Sarajevo?
6 A. Livanjska Street is on Kosevsko Brdo hill.
7 Q. Thank you. Not counting the major incidents that were heard of
8 internationally, did you register any deliberate firing from high-calibre
9 weapons by Muslim forces in areas of Sarajevo which were under their
11 A. Well, I'm just looking at the English text. If it's not too much
12 trouble, can I please ask you to repeat your question.
13 Q. I'm not asking you about major incidents now such as Markale,
14 Vasa Miskina, and all the other ones cited as major instances. Were
15 there any deliberate instances of firing from large-calibre weaponry on
16 their own territory? Did you observe anything like that?
17 A. There were such instances.
18 Q. Can we look at 1D32016 in e-court now, please. There is also a
20 In paragraph 1 there's talk about enemy activity in the following
21 sectors. Could you please read the one that discusses the firing from --
22 THE INTERPRETER: Interpreter's note: We do not see the text in
24 JUDGE KWON: Just a second. Is there a way that interpreters
25 could see the English translation? Our public monitor shows only the
1 B/C/S for the benefit of the witness.
2 Can you read it, Mr. Milosevic?
3 THE WITNESS: [Interpretation] Yes. This is the third paragraph
4 that you're looking at. The fire from rifle grenades, and infantry
6 MR. KARADZIC: [Interpretation]
7 Q. Rifle grenades an infantry weapons?
8 A. Rifle grenades an infantry weapons from positions above Breka and
9 the monument at their own positions in the Bascarsija with the intention
10 blaming the Serbs for firing. And so now I can see the content
11 indicating that we noted that there was some fire from positions above
12 Breka at Bascarsija and that is all their territory.
13 Q. Thank you.
14 THE ACCUSED: [Interpretation] I would like to tender this
16 MR. KARADZIC: [Interpretation]
17 Q. And is this your document? Can we look at the last page, please,
18 and the signature?
19 A. Yes, yes. This is my signature. First and last name and
21 Q. Thank you.
22 JUDGE KWON: Yes. We will receive it.
23 THE REGISTRAR: As Exhibit D2796, Your Honours.
24 THE ACCUSED: [Interpretation] Can we look at 1D7505 in the
25 e-court, please.
1 MR. KARADZIC: [Interpretation]
2 Q. This first paragraph up to this Serb side, but I will summarise
3 it. Near the school in Dobrinja they're also firing at and they have
4 torched a house near the Jewish Cemetery, but this second thing, from the
5 observation point. Line 3.
6 A. "From the observation point at Vidikovac, the Muslims are opening
7 machine-gun fire against the town and the building of the UN command,
8 with the intention of 'crediting' the Serbian side with this action."
9 Should I continue?
10 Q. No, General. No need to read any further. Was this something
11 that was infrequent or surprising, or did you have instances like this
12 more often? Was this an exception or the rule?
13 A. The first thing that I know, that I'm very familiar with, is that
14 they constantly try to provoke UNPROFOR with the intention of creating
15 the impression with UNPROFOR that this was done by our forces, the forces
16 of the Sarajevo-Romanija Corps. They would fire, and then they would
17 lodge a protest. That was the form that it was done in.
18 THE INTERPRETER: The interpret did not hear the last sentence.
19 MR. KARADZIC: [Interpretation]
20 Q. Thank you.
21 THE ACCUSED: [Interpretation] Can we tender this document,
23 JUDGE KWON: The interpreters didn't hear your last sentence,
24 Mr. Milosevic. As noted, your last answer was that this was the form
25 that it was done in. Did you add anything after that?
1 THE WITNESS: [Interpretation] I said that they would fire at
2 UNPROFOR and then they would request UNPROFOR to intervene against us
3 because they would allegedly inform them that the fire came from us.
4 They would ask UNPROFOR to lodge protests with our side, because it was
5 allegedly our weapons that fired.
6 MR. KARADZIC: [Interpretation]
7 Q. Thank you. And it says here that they also fired at the city.
8 Does that mean that other than firing at the UNPROFOR building, they also
9 fired at the town?
10 A. Yes. Yes.
11 THE ACCUSED: [Interpretation] Could we tender this document,
13 JUDGE KWON: Yes, Ms. Edgerton.
14 MS. EDGERTON: Noting that Dr. Karadzic fed the witness the
15 answer. He should really try and guard, in my submission, against
16 leading the witness in his questions.
17 THE ACCUSED: [Interpretation] I apologise. I just wanted to get
18 whether this was on the town or at the building, because it says here in
19 the town and on the building. I don't know how it was translated. So
20 this is why I wanted to clarify where it was that they fired.
21 JUDGE KWON: Mr. Karadzic, once you establish some foundation of
22 a document, you may put certain passages, but in doing so, you have to be
23 very precise in refraining from -- otherwise refrain from making leading
24 questions or comment.
25 Please continue.
1 THE ACCUSED: [Interpretation] I have finished with this document.
2 I with like to tender it, please.
3 JUDGE KWON: Yes. We will admit it.
4 THE REGISTRAR: As Exhibit D2797, Your Honours.
5 MR. KARADZIC: [Interpretation]
6 Q. Can we look at 1D7500 now, please. You don't need to read, but
7 you can just tell us what it was that happened at 1245 hundred hours.
8 This is the third bullet in -- from the top.
9 A. Yes, yes. I can see it. Yes. What happened was what it states
10 here. Our observers noted that from this area they were shooting at the
11 Ernest Green [phoen] hospital. This used to be a hospital specialising,
12 as far as I remember, in -- it actually partially belonged to the part of
13 Republika Srpska, to the Sarajevo-Romanija Corps, and I would say that it
14 was a good base, a good basis possibly to treat the wounded. However,
15 they carried out fire at that area.
16 Q. And this Miladin Cukovic, this doctor, was killed; is that
18 A. Yes.
19 Q. And are you able to tell us what it is that is stated in
20 paragraph 2, that you did not respond to provocations? Why didn't you
21 respond to provocations, which is contained in this paragraph 2?
22 A. The first and main reason was - and I'm sure now - is that a
23 certain cease-fire period had been established when firing at each other
24 was ruled out. So in the situation when any kind of restriction or ban
25 was in force or when an agreement was in place we would not do that. And
1 in other circumstances when we did not do it, we did not do it in order
2 to avoid hurting the civilian population.
3 Q. Thank you.
4 THE ACCUSED: [Interpretation] Can I tender this, please?
5 MS. EDGERTON: Noting that it's not General Milosevic's document.
6 It was signed by someone on his behalf.
7 JUDGE KWON: Very well. We will admit it.
8 THE REGISTRAR: As Exhibit D2798, Your Honours.
9 THE ACCUSED: [Interpretation] Can we look at one more document
10 today, please? It's 1D7502. It's a document of the
11 Sarajevo-Romanija Corps, and you signed it and the 30th of September,
12 1993. 1D7502.
13 What I am particularly interested in terms of your evaluations or
14 assessments of -- for provocations, I would like you to look at this last
15 paragraph which is the paragraph after the one marked number 8. I think
16 this is on page 2 in the English.
17 A. Yes, yes. I see it.
18 Q. Can you please read it out loud.
19 A. "In view of the political situation, the enemy will try to
20 provoke our forces into action, especially against Sarajevo, and thus
21 provide for the enemy's political structures."
22 I cannot see:
23 "And provide trump cards for the enemy's political structures."
24 This is what this is about. This is something that we had to
25 take into account and respect. Statesmen, politicians, certain
1 structures would come to Sarajevo for the purpose of contacts. They had
2 different important meetings in Sarajevo. So it was important to them
3 for us to go into action then at those times, and then they would
4 undertake some action in order to prompt us to fire and show that we did
5 not respect any behaviour codes in given situations. And I know very
6 well that during any kind of important gathering or even less important
7 gathering, our forces did not do it in order not to provide any kind of
8 pretext to them. In that same period, even General Rose asserted,
9 claimed, that at the time when the Turkish prime minister came, they
10 opened fire in order to show what danger they were in. They opened
11 artillery fire from their positions in their zone. That would be that.
12 THE ACCUSED: [Interpretation] Can we tender this document?
13 JUDGE KWON: Yes.
14 THE REGISTRAR: Exhibit D2799, Your Honours.
15 JUDGE KWON: Mr. Milosevic, we will adjourn for today now, and
16 given the scheduling, you will interposed by another witness tomorrow
18 Is my understanding correct, that you will start with
19 Mr. Indjic's cross-examination?
20 MS. EDGERTON: Correct.
21 JUDGE KWON: And I take it we may start your -- resume your
22 evidence in the afternoon, but I'm not sure about it. I'm just telling
23 you for your information.
24 Do you understand that, sir?
25 THE WITNESS: [Interpretation] Thank you, Your Honour. Yes, I
2 JUDGE KWON: Yes, Mr. Bourgon.
3 MR. BOURGON: Mr. President, I would like to have -- to make a
4 request to the Trial Chamber, and on this table I have access only to one
5 screen where I can see the -- what is on the public monitor. However,
6 because I do not have access to the materials, the confidential material
7 in the case of Dr. Karadzic, I cannot have anything else loaded up on the
8 other two computers, and I'm not able to see the transcript at the same
9 time as a document is put up on the screen. If -- with my undertaking,
10 Mr. President, that I would only look at the computer while in the
11 courtroom and look only at the transcript from the two computers, I would
12 ask the Trial Chamber to grant me permission so I can see the transcript,
13 and it will be my personal undertaking that I will not look at any other
14 material on those two computers. This would make my life much easier if
15 I can see both at the same time. Thank you, Mr. President.
16 JUDGE KWON: The Chamber will consider that in due course. We
17 will give a ruling in due course, but I'm not sure the Chamber should be
19 The hearing is now adjourned.
20 --- Whereupon the hearing adjourned at 2.50 p.m.,
21 to be reconvened on Thursday, the 24th day
22 of January, 2013, at 9.00 a.m.