1 Wednesday, 4 December 2013
2 [Open session]
3 [The accused entered court]
4 [The witness takes the stand]
5 --- Upon commencing at 9.06 a.m.
6 JUDGE KWON: Good morning, everyone. Please continue,
7 Ms. McKenna.
8 MS. McKENNA: Thank you, Your Honour.
9 WITNESS: BORO TADIC [Resumed]
10 [Witness answered through interpreter]
11 Cross-examination by Ms. McKenna: [Continued]
12 Q. Mr. Tadic, in response to question 18 in your statement, you say
13 that equal rights were afforded to everyone regardless of their
14 nationality and, again, in response to question 44, regarding the SDS
15 policy to permanently remove Bosnian Muslims or Croats, you say there
16 were no policies of persecution, forced deportations or ethnic cleansing.
17 Now, yesterday, we talked about co-ordinated attacks on
18 neighbourhoods populated by non-Serbs but this morning I'd like to focus
19 on the issue of forced deportations. Now, while you claim that there was
20 no policy of forced transfer, it's true, isn't it, that in Sanski Most,
21 as in other municipalities in the ARK, the position of the Serb
22 authorities was that Muslims and Croats had to leave these
24 A. The position was to treat everyone equally. However, if somebody
25 takes up arms, organising secretly against the state, then that person
1 loses that status. We have to distinguish between the policy of equal
2 treatment for everyone and the relocation of population who wanted to
3 join their own community, ethnic community; thus Serbs went from the
4 parts where they were a minority in Bosnia-Herzegovina to parts where
5 they were in the majority, and Croats chose to do the same, to feel
7 I know that several thousand Muslims spent months gathering
8 various papers to meet all the requirements to depart. They had to have
9 documents from various institutions of Republika Srpska in order to
10 leave, and they had to have a permit from the area where they wanted to
11 go, and a permit to cross the border. So the Muslims were organising to
12 leave, and many of them are grateful to me to this day because I had
13 helped them get their names on the lists for departure.
14 So it was not expulsion, like I was expelled from Sanski Most.
15 I was expelled from Sanski Most under fire, where they left in a
16 civilised way with the escort provided by our armed forces. Of course,
17 in all these situations, there were isolated cases and incidents, or, as
18 you in the West would put it, collateral damage. But every such instance
19 when a Serb inflicted pain on somebody else, is my pain, because I know
20 that it was not the intention of the leadership of Republika Srpska to
21 inflict pain on anyone and you can see that from the speeches of our
22 presidents on many occasions, because Republika Srpska was established on
23 St. Stephen's day and St. Stephen was a martyr for Christ.
24 Q. I'm going to stop you there. Again, I remind you as I did
25 yesterday to try and answer the questions as concisely and as precisely
1 as possible and your answer to my question is, it was not expulsion.
2 MS. McKENNA: I'd like to call up P3664.
3 Q. Now, Mr. Tadic, this is a 1st Krajina Corps command state of
4 combat morale report, as you'll see, dated 14th of June, 1992, and it's
5 from General Talic to the Serbian Republic of Bosnia-Herzegovina army
6 Main Staff. I'm interested in page 2 of the B/C/S and page 4 -- excuse
7 me, page 4 of the B/C/S and page 2 of the English. Sorry, perhaps it's
8 the following page in the English. Thank you. And I'd like you -- to
9 direct your attention to the last paragraph just before item 3 begins,
10 and it states: The most difficult situation concerns the Muslim and
11 Croat refugees in the area of AOR Krajina, their security and the
12 provision of food. The attempt to expel them to Central Bosnia failed
13 because of transportation difficulties and their resistance to leaving
14 their places of residence.
15 So, firstly, Mr. Tadic, this isn't about armed combatants, as you
16 claimed. This is about Muslim and Croat refugees; and secondly -- well,
17 can you comment on that? Do you agree that this document refers to
18 refugees rather than armed combatants?
19 A. Indeed, you see a sentence here with the word "expulsion" and
20 that's too strong a word for what was happening. I know only about
21 Sanski Most. I cannot comment on other areas. I know there was huge
22 pressure on the local authorities from people who wanted to leave and we
23 couldn't even easily provide security, and provide them with the means to
24 leave because it was difficult to organise it without incidents and
25 deaths. And this reference to food supply, the situation was horrible
1 then. The Serbs were being punished by the international community.
2 Everything was blocked. Krajina was cut off. There was no food. There
3 were huge shortages and we were all in a very difficult situation.
4 Q. Mr. Tadic, it's clear from this document that Muslim and Croat
5 refugees are being expelled and they do not want to leave. Now, you say
6 you only know about the situation in Sanski Most. Let's refer to a
7 document in which you discuss the situation in Sanski Most.
8 MS. McKENNA: Could we please have P3657.
9 Q. And the document that I'm calling up, Mr. Tadic, is one of the
10 Executive Committee sessions which you stated yesterday that you
11 attended, and at this session, there were extensive discussions regarding
12 the forced displacement of Sanski Most's non-Serbs. You see that this is
13 the minutes of and decisions taken during the 9th session of the
14 Executive Committee of the Municipal Assembly of Sanski Most on the
15 27th of July, 1992. Could we please refer to English page 3 and B/C/S
16 page 4.
17 I'd like to focus your attention on item 4 which was the debate
18 on the political and security situation on the territory of Sanski Most
19 where Mirko Vrucinic gave an introductory presentation, and he stated
20 that: About 4.500 Muslims and Croats have left this territory and
21 continues that there are about -- there are still about 18.000 of them in
22 our municipality. So Mr. Vrkes enters the discussion and he states:
23 With respect to the political and security situation on the territory of
24 the Sanski Most municipality, it has been rather unfavourable recently.
25 There will be a joint meeting of the -- this is continued on page 5 of
1 the B/C/S. He says: There will be a joint meeting of military and
2 civilian authorities this week. A stumbling block for the new
3 authorities was what to do with the other ethnic groups, Muslims and
4 Croats. The most humane thing to do is to allow them to move away
5 peacefully. Certain results have been achieved. We are working through
6 UNPROFOR to resettle people who are interested in leaving the territory
7 of our municipality.
8 JUDGE KWON: Next page.
9 MS. McKENNA: I apologise.
10 Q. And he continues: We have to persist in this work because this
11 is what the soldiers and the people of Sanski Most require of us because
12 this has to be a Serbian town.
13 So that was the true aim of the Sanski Most authorities, wasn't
14 it, to ensure that Sanski Most was a Serbian town?
15 A. This interpretation is lopsided. You see, in the contribution of
16 Vlado Vrkes and the previous speakers, an exclusive position that it is
17 also a request of the Muslims and their own wish to leave the territory,
18 so their wish to leave coincided with the situation where providing
19 enough food for the population and the aggravating crisis caused by
20 sanctions imposed by the international community, and people needed a
21 heap of documents from various institutions in order to be able to leave.
22 And Vlado Vrkes - and you can even look at the previous speaker - says
23 that Muslims are asking to leave and we need to make it possible for them
24 in the safest possible way. That is separate from what was happening to
25 the Serbs in the Federation of Bosnia-Herzegovina, who couldn't even hope
1 to leave in such a way, with safe escort provided by the authorities. We
2 acted as a humane state, as humane people, to try to minimise casualties
3 because war had been imposed on us, and once war begins, there are all
4 sorts of evil happening. And if you go back to the previous speaker, he
5 also talks about the fact that Muslims are demanding to leave. There was
6 huge pressure on me personally.
7 Q. Muslims were asking to leave, weren't they, because of the
8 conditions that we discussed yesterday, because of the massive
9 destruction of their towns and because of the crimes being committed
10 against them with impunity; isn't that correct?
11 A. That is an exaggeration. It was the policy of the Muslim
12 leadership, because in Trebinje nobody attacked Muslims, instead they had
13 received orders to leave.
14 Q. Mr. Tadic, we are not discussing Trebinje. And right now we are
15 talking about the policy of your leadership and you noticed that -- or
16 I'll refer you to your comment, which is halfway down the page, where you
17 state how to implement the conclusions made here. And you say: To set
18 up a council for people's defence and oblige someone from the higher
19 commands to come to meetings so that all this can be implemented more
20 efficiently. And before I ask you to comment on that, let's go to the
21 conclusions that were being implemented. If we could go to page 8 of the
22 English and page 11 of the B/C/S.
23 JUDGE KWON: But I think it's fair to note that as the witness
24 indicated, after passage related to 18.000 of them, Muslims, there is a
25 sentence which goes to the effect that Muslims are asking to move away,
1 and it should be made possible for them to do so, which you omitted
2 reading. Having said that, shall we continue.
3 MS. McKENNA: Thank you.
4 Q. If we refer to conclusion number 1 and three paragraphs down, it
5 states: At present, about 18.000 Muslims and Croats remain on the
6 territory of the Sanski Most municipality, and to avoid danger to the
7 Serbian people, it is necessary to organise their voluntary resettlement.
8 So here the Crisis Staff's conclusion is to organise the
9 so-called voluntary resettlement of 18.000 Muslims and Croats, and your
10 concern is how that could be implemented in the most efficient way.
11 A. I'm repeating again: War is an evil that Satan has imposed on
12 the world, and in all that evil, we need to make sure to minimise it. It
13 is evil when somebody has to leave their hearth, their home, but it's
14 important to try to make the evil as small as possible. This is a very
15 complex problem. You can't simplify. In the first point, there is a
16 description of how difficult the situation is, militarily and
17 politically. It's difficult to provide enough food for all the people,
18 and if one part of the population wants to leave and the other, Serbian
19 part, also wants them to leave, so as not to create more problems, to
20 prevent the extremists on both sides to commit evil, and we wanted to
21 enable the most humane possible resettlement, which is a necessary evil
22 in all wars. You can see that all those Muslims returned before, and in
23 Republika Srpska their property was restituted to them. But look at the
24 situation of Serbs who had fled from other parts of Bosnia-Herzegovina.
25 Where did Serbs return? Did Serbs return perhaps to Kosovo? So all
1 these consequences were to the detriment of the Serbs. Serbs are still
2 leaving various areas.
3 Q. Thank you.
4 JUDGE KWON: Why does the presence of Muslims, Croats, 18.000 of
5 them, would cause danger to the Serbian people, Mr. Tadic?
6 THE WITNESS: [Interpretation] They wanted to leave because in
7 their ranks --
8 JUDGE KWON: No, you said that. But this document does not say
9 because they want to leave, let them leave. It says, in order to avoid
10 danger to Serbian people. Why do they cause danger to the Serbian
12 THE WITNESS: [Interpretation] Because there were constant
13 provocations. The weapons they had not yet surrendered, they kept
14 secretly. There was always room for provocation, and our soldiers were
15 not always under the control of their commands, and it was possible to
16 create incidents that we didn't really need. And at the same time, their
17 badgering of institutions in Sanski Most with demands to enable them to
18 leave created huge pressure. We were snowed under their requests to
19 leave, and we needed to enable them to do so with as little damage as
20 possible, with as little -- few casualties and deaths.
21 That was the situation, and through these conclusions, you can
22 see that. We wanted them to leave in order to minimise the problems, and
23 when their property was left behind, we never said that this property
24 would now belong to the Serb refugee who had fled from the Federation of
25 BH. We said it was property that was only in temporary use by someone
1 else and we proved it after the war because that property was restituted.
2 JUDGE KWON: I wonder whether everybody's LiveNote is running.
3 THE ACCUSED: If you reconnect.
4 JUDGE KWON: Yes.
5 THE ACCUSED: I had a problem.
6 JUDGE KWON: Ver well, but it's running on the common computer.
7 So shall we continue.
8 MS. McKENNA: Thank you, Your Honour. I note that I'm out of
9 time. There is one additional topic that I would like to cover briefly.
10 JUDGE KWON: Yes, please carry on, Ms. McKenna.
11 MS. McKENNA: Thank you, Your Honour.
12 Q. Mr. Tadic, in your capacity as head of the Ministry of Defence of
13 the Republika Srpska in Sanski Most, you were responsible for work
14 obligation in the municipality; isn't that correct?
15 A. Yes, yes. We are talking about a mobilisation all the resources
16 including human resources and materiel resources for the functioning of
17 the military, first and foremost, and also to improve the conditions of
18 life under such harsh circumstances in Sanski Most; on the one hand, we
19 had mobilisation for the army, and on the other, we had the work
20 obligations because we had only few factories running but we had to keep
21 them running in order to involve all those people who were not able
22 bodied to allow them to survive. It was my task, the task of the
23 Ministry of Defence of Republika Srpska, and my task as the chief of that
24 department who was in charge of the municipality of Sanski Most.
25 I attended the meetings of the Executive Council as a representative of
1 the Ministry of Defence of Republika Srpska, as the chief of a department
2 in the Ministry of Defence of Republika Srpska, as I told you yesterday.
3 Q. Thank you. Once again, can we focus on the questions and give a
4 concise answer. Your answer is: Yes, you were responsible for work
5 obligation as the head of the Ministry of Defence in Sanski Most. But
6 it's true, isn't it, that non-Serbs who were allowed to remain in
7 Sanski Most were subjected to work obligation?
8 A. Yes.
9 MS. McKENNA: Could we please see 65 ter 25613.
10 Q. So, Mr. Tadic, this is a letter -- if we can in fact go to the
11 signature page. Do you recognise your signature on this letter?
12 A. Yes, yes, yes.
13 Q. And this is your letter from the -- rather, to the
14 Executive Board of the Sanski Most Municipal Assembly regarding the work
15 obligation units. If we could go -- my apologies. If we go to the first
16 page, and you state: Over the past 16 months, the Ministry of Defence
17 department of Sanski Most has deployed work obligations units consisting
18 of non-Serbs as requested by the Army of Republika Srpska and various
19 enterprises, institutions and individuals. You explain that work
20 obligations were originally established -- rather, work obligation units
21 were originally established in May 1993. And you state: Subsequently,
22 units comprising non-Serbs began to be utilised while the units made up
23 of Serbs never were.
24 And if we could briefly go to the annex, please, which is the
25 last page of the document, you'll see this details the breakdown of
1 non-Serbs in work obligation in 1994 and you'll see it's in the region of
2 1.000 non-Serbs in work obligation. It's true, isn't it, that contrary
3 to your testimony about the equal treatment of Serbs and non-Serbs, in
4 the work obligation units that you were responsible for, only non-Serbs
5 were required to do this labour; that's correct, isn't it?
6 A. Again, yet another lopsided opinion and a total misunderstanding
7 of the situation. Let me tell you what this is all about. The
8 Ministry of Defence engaged the most capable men for war operations for
9 the military. Some of the population had to be deployed into work
10 obligations. A report is only about that work obligation that the
11 Muslims and the Croats had in order to give an overview of that, but the
12 Serbs were also engaged in work obligation units. There are also tables
13 that show you where they were engaged. Therefore, Muslims were in no way
14 at all humiliated in that way. On the contrary, we involved them in the
15 creation of new commodities and goods, we helped them to feel useful in
16 the territory of Sanski Most, i.e., in Republika Srpska, and it is all
17 explained so nicely here. The Ministry of Defence had a task to comply
18 with requests of units, the Executive Council, and the factories. So
19 whenever those institutions requested people, I would send them either
20 Serbs or Croats or Muslims. This is the information about the engagement
21 of Muslims and Croats only, which doesn't mean that Serbs did not have
22 work obligation. Obviously we are talking about those who could not be
23 deployed into regular military units.
24 Q. Mr. Tadic --
25 JUDGE KWON: I'm not sure there is a translation issue, otherwise
1 there's an omission. Can we go back to the first page of this document?
2 Ms. McKenna read that sentence, probably you missed it, second paragraph,
3 second sentence, I'll read from the first. Work obligation units were
4 originally established in May 1993. And then second sentence reads like
6 "Subsequently, units comprising non-Serbs began to be utilised
7 while the units made up of Serbs never were."
8 You state here that Serb units were not utilised.
9 THE WITNESS: [Interpretation] Yes. There is a difference here.
10 Before those units were set up for non-Serbs, we had work obligation for
11 all the Serbs who were engaged on the same tasks in companies, in
12 factories. However, we were faced with the military and security
13 problem. There was a sentiment of insecurity, and the conditions were
14 not ripe before them to set up those units. We feared incidents and
15 problems because they had to be safe and secure. There was a war,
16 fighting was going on, people were getting killed.
17 The Ministry of Defence issued an order to set up those units.
18 However, we always had to bear in mind that their use had to be made as
19 safe as possible. This is the only difference. I repeat: Serbs already
20 had work obligation in order to keep companies running, in order to be
21 able to supply our units, in order to keep the war going on. Our
22 priority, like in every war, were war activities and provisions for units
23 engaged in the war, and deployed in the field. This order of the
24 defence ministry means that Croats and Muslims should be made useful.
25 They were not supposed to only sit at home but also to be made -- feel
1 useful and involved in the life of society, although the society was a
2 far cry from a normal peacetime society because there was war going on.
3 But we tried to make sure that their engagement in war units did not
4 compound the security situation even further.
5 JUDGE KWON: Back to you, Ms. McKenna.
6 MS. McKENNA: Thank you, Your Honour.
7 Q. Mr. Tadic, you talk about making Croats and Muslims feel useful
8 and involved and as safe as possible in your work obligation units. An
9 investigation took place into the war crimes committed in Sanski Most
10 municipality in 1996, and the criminal report that was issued against you
11 and other members of the Sanski Most authority detailed that during this
12 work obligation, during the forced labour, that was carried out under
13 your authority, non-Serbs were taken to the front line to dig trenches,
14 carry ammunition and wounded, and many were killed in so doing.
15 Non-Serbs were used as human shields and sent to minefields, and
16 non-Serbs were subjected to physical and psychological torture. Now,
17 that was the reality of the forced labour to which non-Serbs were
18 subjected under your authority; isn't that correct?
19 A. Can I see the table that you showed me just a while ago? I would
20 like to use it to illustrate my answer.
21 JUDGE KWON: Page 4 of this document?
22 THE WITNESS: [Interpretation] You see here, this is a table with
23 the exact breakdown of people from various places. You can see that
24 there are 14 locations mentioned here with Muslims who were living there,
25 and you see an overview of the work obligation places. It says local
1 commune, military battlefield, military logistics, military wood
2 chopping, socially owned enterprise. This is a table showing where
3 Muslims were engaged in various work obligation units. My task, or our
4 task, was to use the available population and to select those who were
5 fit for various jobs and to send them wherever they were needed to
6 perform those tasks from the --
7 MS. McKENNA:
8 Q. Sending them wherever they were needed included sending them to
9 the front line and sending them to clear minefields and sending them to
10 their deaths; isn't that correct?
11 A. I sent many more Serbs to their deaths. This is about 113 people
12 being sent to the front line. We, however, sent thousands upon thousands
13 to the front lines. If I sent thousands of Serbs to the front line, why
14 wouldn't I send a hundred Muslims to carry water, to dig trenches, and so
15 on and so forth? Because we didn't consider Republika Srpska only a
16 Serbian state. It does bear -- it does have the word Serb in its title,
17 but we never thought that non-Serbs would not be living in our state. A
18 state is as fortunate as it can afford rights and happiness to its
19 minorities. Many more Serbs were killed by our enemies, and those were
20 Croats and Muslims who were shooting at us. It is not only about the 113
21 who were sent to the front line to help the Serbian army in their
22 activities. It was my task to mobilise people and to send them to those
23 units or to other units, as you can see from the table. As I've already
24 told you, Serbs were also engaged in work in privately and socially owned
1 Once conditions were in place, when the situation was safe, we
2 could send Muslims to work there. Why would we send somebody to get
3 killed if the situation was not safe? Obviously, those who inflicted
4 harm on somebody else will have to answer God for that, not only courts.
5 I had meetings with all those people. Not a single person was sent to
6 the front line without me telling him with a lot of love that only
7 hardships would await him there, and I did the same with the Serbs. But
8 I thought that people had to help, that they had the obligation to help
9 because a new Republika Srpska was being created. The previous state was
10 broken up by people who hated, and we wanted to create our state from
11 love. How could I be an aggressor on my own land? How could I be an
12 aggressor in my own homeland of Bosnia and Herzegovina.
13 Q. Thank you. You have answered the question.
14 MS. McKENNA: I would like to tender that exhibit, Your Honours.
15 JUDGE KWON: We will receive it.
16 THE REGISTRAR: Exhibit P6541, Your Honours.
17 MS. McKENNA: That completes my cross-examination, Your Honours.
18 Thank you.
19 JUDGE KWON: Yes, Mr. Karadzic.
20 THE ACCUSED: [Interpretation] Thank you. Good morning,
21 Your Excellencies. Good morning to everybody.
22 Re-examination by Mr. Karadzic:
23 Q. [Interpretation] Good morning, Mr. Tadic.
24 A. God speed be with you, Mr. President.
25 Q. Please make a pause between my question and your answer.
1 THE ACCUSED: [Interpretation] And now I'd like to call up P6541.
2 I'm interested in page 1. Previous document. 6541.
3 MR. KARADZIC: [Interpretation]
4 Q. Help us, Mr. Tadic, and tell us whether it is correct that this
5 was issued on the 5th of October, 1994.
6 A. Yes, it is correct.
7 Q. Thank you. And now can we go to page 4 and look at the table
8 again. Thank you. Mr. Tadic, what I can see here are 18 villages. It
9 is true that -- is it true that on the 5th of October, 1994, you had
10 18 Muslim and Croat villages predominantly inhabited by Muslims and
12 A. Yes, Mr. President. This is correct, and this tallies with the
13 statement that I provided.
14 Q. Thank you. Did you not expel them already in 1992?
15 A. No. You can see --
16 MS. McKENNA: Mr. Karadzic's questions are blatantly leading.
17 JUDGE KWON: Very much.
18 THE ACCUSED: [Interpretation] Yes. We can rephrase.
19 MR. KARADZIC: [Interpretation]
20 Q. You were asked about deportations, forcible deportations of the
21 population. In October 1994, were these pure Muslim and Croat villages?
22 Did the people remain living there?
23 A. Yes. They remained living there. It is correct that they were
24 there. Those who did not want to leave were -- or if they requested
25 subsequently to be allowed to leave, I organised meetings with them.
1 They were never forced to be deployed to work obligation units. All
2 those tasks were preceded by conversations where they were told what they
3 were supposed to do and how they were supposed to do. I was sincere with
4 those people and I tried to convince them that something new was being
5 created, that no harm would befall them, and all that they could not
6 accept that, they could not love us, they could still be convinced that
7 I, as authority, would protect them. And they felt that on numerous
8 occasions, I protected them, and not only myself, but also everybody else
9 who constituted authorities in the municipality of Sanski Most.
10 Q. Thank you. Can you please tell the Trial Chamber what kind of
11 obligations exist in wartime?
12 A. In a war, priority was to mobilise people for war units. It was
13 a very tall order.
14 Q. Thank you.
15 A. And second of all, there was work obligation for everybody, for
16 Serbs and Muslims, to provide for the army units.
17 Q. Thank you. Were Muslims duty-bound to join war units, to shoot
18 and to fight?
19 A. No.
20 Q. And what about Serbs? Were they duty-bound to join war units and
21 to be deployed?
22 A. Yes, that was their obligation.
23 Q. Were people paid in war units and in work obligation units?
24 A. Yes.
25 Q. Was a distinction made between the Serbs who were deployed in
1 war -- work obligation units and Muslims?
2 A. No.
3 Q. What was better for the people, to be in a war unit or in a work
4 obligation unit?
5 A. Many people were afraid of being killed or wounded. Many of the
6 combatants asked me to transfer them to a work obligation unit, and when
7 a healthy and able bodied person had to be transferred from a war
8 obligation unit -- to a work obligation unit to a war unit, that was also
9 difficult task. We protected Muslims and Croats from any bigger harm, at
10 the same time allowing them to feel useful as a member of our society, as
11 members of the state of Republika Srpska.
12 Q. Thank you. We no longer need this document. It's
13 self-explanatory. Please bear with me for a moment.
14 On page 4 of the previous document, P3657, mention is made of the
15 pressures, and the document number is 3664, pressures on the government
16 to allow Muslims to leave. Who was it who put the pressure to bear on
17 the government?
18 A. I have to admit one thing to you. I have dozens of
19 thank-you notes from people who thank me for my engagement in helping
20 them to leave Sanski Most. They have been sending me such letters over
21 the past years. Muslims and Croats wanted to leave the territory so
22 badly that we sometimes could not meet their requests. However, we tried
23 to make their departure as humane as possible with as few consequences as
24 possible, because we were aware that we were creating a state that cannot
25 persist on the evil and on crimes because every crime is a crime
1 primarily for the human soul. And we all tried very hard, and that
2 includes our President Karadzic, who is a believer and a good person.
3 And you saw that yesterday that in Banja Luka, the first word he
4 mentioned was democracy, which means that he is a person who, together
5 with the Serbian Democratic Party, wanted to form a state that we would
6 not be ashamed of.
7 Q. We saw the minutes of a meeting, the document number was P3657,
8 when Vrkes spoke. Was that recorded or was that just transcribed by the
9 person who took the minutes?
10 A. I believe it was just transcribed by that person who took the
12 Q. Thank you. On page 101 of yesterday's transcript, it was
13 suggested to you, and it was read to you, that on the 28th people were
14 first to jump and then they were killed. According to what you know, did
15 the 6th Sana Brigade open fire on civilians and was the culture of
16 attacking civilians being fostered by us?
17 JUDGE KWON: Yes, Ms. McKenna.
18 MS. McKENNA: Objection. That is a leading question and already
19 the witness has made it clear that he didn't know anything about the
21 JUDGE KWON: Yes. Will you move on, Mr. Karadzic.
22 THE ACCUSED: [Interpretation] Thank you.
23 MR. KARADZIC: [Interpretation]
24 Q. On page 99, it was suggested to you that there were prisoners and
25 you agreed that there were indeed prisoners. The question contained the
1 word "civilians." Were civilians detained in Sanski Most if they had not
2 been involved in fighting?
3 A. There were two groups of people: Those who were detained after
4 having acted against the army and against civilians, those were truly
5 detained, true prisoners; and the second group involved transfer to a
6 certain facility in order to avoid any major incidents.
7 Q. Thank you. What about Vrhpolje and Tominska Palanka? Are they
8 in Sanski Most?
9 A. No. Those settlements are not in Sanski Most. They are about 15
10 to 20 kilometres away.
11 Q. I apologise. Are they parts of the municipality of Sanski Most?
21 JUDGE KWON: Inappropriate question. Have you done with your
23 THE ACCUSED: [Interpretation] No, I have two or three more
24 questions. Very well, then.
25 MR. KARADZIC: [Interpretation]
1 Q. Did that unit break a law or did it violate the customs of war?
2 MS. McKENNA: Objection. Once again the same objection, it's
3 totally inappropriate question.
4 JUDGE KWON: Did the witness not say that he didn't know about
6 THE ACCUSED: [Interpretation] No, no. When it comes to the
7 transfer of the population from one village to another, he's aware of
8 that and he said so. The Prosecution asked him about deportations. Now
9 I'm asking him whether the removal of the population from one village
10 is -- to another constitutes deportation.
11 JUDGE KWON: Whether a certain act is a violation of custom of
12 war, I don't think it is for this witness to answer the question.
13 THE ACCUSED: [Interpretation] Your Excellencies, with all due
14 respect, this witness was a representative of the Ministry of Defence in
15 his municipality and he knew what was -- he knew the dos and don'ts and
16 he is familiar with the law.
17 JUDGE KWON: But please move on.
18 THE ACCUSED: [Interpretation] Thank you.
19 MR. KARADZIC: [Interpretation]
20 Q. On page 98, you were asked about events in the town itself
21 concerning Mahala on the 27th of May, and you stated that you were not in
22 town but in Palanka. What is the distance between Sanski Most and
23 Lusci Palanka?
24 A. Twenty-five kilometres.
25 Q. Thank you.
1 THE ACCUSED: [Interpretation] Let's show 65 ter document 04898.
2 Could it be shown to the witness, please.
3 MR. KARADZIC: [Interpretation]
4 Q. Could you please assist the witness to use the stylus to show
5 Lusci Palanka and the route that you had to take through Muslim villages
6 that you mentioned yesterday between Sanski Most and that place? A KDZ97
7 witness -- witness was KDZ97, under 92 bis.
8 A. [Marks]
9 Q. Could you please indicate the route you had to take to reach
11 A. [Marks]
12 Q. Thank you. That will be the 25 kilometres; is that right?
13 A. Yes.
14 Q. Could you please encircle the Muslim villages that you had to go
15 through to get there?
16 A. [Marks]
17 Q. Thank you very much, Mr. Tadic. Could you please place the date
18 and your initials on the bottom.
19 A. [Marks]
20 Q. Thank you.
21 THE ACCUSED: [Interpretation] I would like to tender this
22 document into evidence.
23 JUDGE KWON: Yes.
24 THE REGISTRAR: It receives Exhibit D4164, Your Honours.
25 THE ACCUSED: [Interpretation] Thank you.
1 MR. KARADZIC: [Interpretation]
2 Q. On page 97, it was suggested to you that 6th Sana Brigade took
3 part in occupying the municipal building. Who occupied that building?
4 A. It was occupied mainly by Muslims. I'm not sure how many Croats
5 there were. They barricaded themselves in that municipal building,
6 desiring to regain power from that building, power in the municipality of
7 Sanski Most, although the SDS had won the elections in Sanski Most and,
8 of course, they elected the president of the municipality.
9 Q. Thank you. Do you know, or could you explain to the Chamber how
10 was it possible for the war to start in Sarajevo on the 5th of April and
11 in Sanski Most on the 25th of May?
12 A. Thanks to the arrival of the brigade and what I discussed.
13 MS. McKENNA: Objection.
14 JUDGE KWON: Is it related to the cross-examination?
15 MS. McKENNA: That was my objection, Your Honour. It's outside
16 the scope of the cross-examination, the start of the war in Sarajevo on
17 the 5th of April.
18 THE ACCUSED: [Interpretation] Your Excellencies, with all due
19 respect, the Prosecution suggested that the Serbs attacked but war was
20 preserved there for two months. I'm inquiring about a municipality where
21 the Serbs are in power and there is 50/50 per cent of the population and
22 I'm asking why didn't they attack right away and not two months later.
23 It was suggested on page 97 that something happened on the 12th of July.
24 Well, by the 12th of July, the work had flared up.
25 JUDGE KWON: I don't think that arises from the line of
2 THE ACCUSED: [Interpretation] Thank you.
3 MR. KARADZIC: [Interpretation]
4 Q. You were shown the publication, "Informator [phoen]," and you
5 were told that this was a propaganda. What was the target audience of
6 that publication?
7 A. Well, to everybody, Serb population and everybody else, whoever
8 could get hold of a copy could read it.
9 Q. Thank you. Was there any propaganda in that publication? Did
10 the contents contravene the facts?
11 A. Well, it may seem that the texts were harsh but this was nothing
12 compared to what our ancestors had to go through and suffered a couple of
13 decades earlier. I would like to tell the Chamber that the hardship that
14 was imposed on us Serbs by the Germany -- by Germany and the fascists and
15 the Ustashas was such -- such large scale that we had suffered atrocities
16 which were not replicated in 1 per cent in the latest war. Five and a
17 half thousand people were, on St. Elijah Day, killed and murdered. And
18 in Jasenovac, which is a concentration camp that was never investigated
19 properly, was the terminus point for thousands of people from Sana. And
20 there were many more pursuant to German sources, and those wounds were
21 still fresh. And in 1914, that very Serb people had to suffer such
22 hardship. Fifty-six per cent of males in Serbia were killed in
23 World War I. The only country whose army had to flee to another country,
24 to Greece, to survive. Two great evils had been committed against the
25 Serb people in the preceding century, and thank God for that brigade
1 because that enabled us to maintain peace for an additional two months
2 without suffering and without victims and sacrifice.
3 Q. Thank you very much, Mr. Tadic, I have no further questions.
4 JUDGE KWON: Well, that concludes your evidence, Mr. Tadic. On
5 behalf of the Chamber, I'd like to thank you for your coming to The Hague
6 to give it. Now you are free to go.
7 THE WITNESS: [Interpretation] Thank you very much.
8 [The witness withdrew]
9 JUDGE KWON: Yes, Ms. McKenna.
10 MS. McKENNA: Your Honour, it's probably best if we move into
11 closed session, I think.
12 JUDGE KWON: Yes, could we move into private session briefly?
13 [Private session]
17 [Open session]
18 THE REGISTRAR: We are in open session, Your Honours.
19 JUDGE KWON: And I take it the next witness is ready,
20 Mr. Robinson?
21 MR. ROBINSON: Yes, Mr. President, the next witness is
22 Marko Adamovic.
23 MS. EDGERTON: Good morning, Your Honours.
24 JUDGE KWON: Good morning, Ms. Edgerton.
25 MS. EDGERTON: I just wonder, I have a couple of points to raise
1 with respect to the rendering of four adjudicated facts that the witness
2 dealt with, pardon me, in his statement and I wonder if it might be
3 better just to make those points before he comes into the room.
4 JUDGE KWON: Please go on.
5 MS. EDGERTON: So in -- this refers to adjudicated facts
6 discussed in paragraphs 7, 17, 18 and 19. With respect, first of all, to
7 paragraph 7, which deals with adjudicated fact 2433, I want to note that
8 the version of the adjudicated fact discussed in the witness's statement
9 deletes the location of Krasulje which is included in the original
10 adjudicated fact. So it should read: Armed clashes broke out in
11 Krasulje between local Muslims, and so forth.
12 And the adjudicated fact referred to in paragraph 17, I, actually
13 with respect to that fact, don't quite know what's going on, because the
14 reference to 3500 houses which the witness discussed is -- appears in
15 adjudicated fact 2448, not 2450.
16 [The witness entered court]
17 MS. EDGERTON: And adjudicated fact 2450 reads completely
18 different, I think. It says: Following the Crisis Staff's order, a
19 Catholic church, at least four Muslim monuments in Kljuc, including the
20 Atik mosque in the town of Kljuc, were either completely destroyed or
21 heavily damaged by fire and explosives set by Serb forces. So I actually
22 can't quite figure that one out.
23 JUDGE KWON: Very well.
24 MS. EDGERTON: Now, with respect to adjudicated fact 514 in
25 paragraph 18, adjudicated fact 514 also says something completely
1 different. It reads: On 27 March 1992, the Serbian Republic of
2 Bosnia-Herzegovina Assembly established the Serbian MUP, and so forth and
3 so on.
4 And then with respect to 2428, finally, in paragraph 19, the
5 version discussed by the witness does not include the first phrase in the
6 original adjudicated fact, which is "in the days following 5 May 1992"
7 these events happened.
8 THE ACCUSED: [Interpretation] If I may provide an answer, with
9 your leave. Adjudicated facts are so composite and complicated as well
10 as many questions put forward by the Prosecution. We do not deny that
11 the MUP had been established, but it was stated there that non-Serb
12 policemen were fired. Those facts are entwined in such a way.
13 JUDGE KWON: No, that's nothing to do with the objection raised
14 by Ms. Edgerton. I'll deal with it when we discuss the admission of this
15 statement. Very well.
16 Would the witness make the solemn declaration, please.
17 THE WITNESS: [Interpretation] I solemnly declare that I will
18 speak the truth, the whole truth and nothing but the truth.
19 WITNESS: MARKO ADAMOVIC
20 [Witness answered through interpreter]
21 JUDGE KWON: Thank you, Mr. Adamovic. Please be seated and make
22 yourself comfortable.
23 Before you commence your evidence, Mr. Adamovic, I must draw your
24 attention to a certain rule of evidence that we have here at the
25 Tribunal, that is Rule 90(E). Under this rule, you may object to
1 answering any question from Mr. Karadzic, the Prosecutor or even from the
2 Judges if you believe that your answer might incriminate you for -- in a
3 criminal offence. In this context, "incriminate" means saying something
4 that might amount to an admission of guilt for a criminal offence or
5 saying something that might provide evidence that you might have
6 committed a criminal offence. However, should you think that your answer
7 might incriminate you and, as a consequence, you refuse to answer the
8 question, I must let you know that the Tribunal has the power to compel
9 you to answer the question. But in that situation, the Tribunal would
10 ensure that your testimony, compelled under such circumstances, would not
11 be used in any case that might be laid against you for any offence, save
12 and except the offence of giving false testimony.
13 Do you understand that, Mr. Adamovic?
14 THE WITNESS: [Interpretation] I've understood, Your Honours.
15 JUDGE KWON: Thank you. Please proceed, Mr. Karadzic.
16 Examination by Mr. Karadzic:
17 Q. [Interpretation] Good morning, Mr. Adamovic.
18 A. Good morning, Mr. President.
19 Q. I have to ask you as any other witness speaking Serbian to make a
20 pause between questions and answers, and to proceed at a steady pace for
21 everything to enter into the transcript.
22 Did you give a statement to my Defence team, Mr. Adamovic?
23 A. Yes.
24 Q. Thank you.
25 THE ACCUSED: [Interpretation] Let's please show 1D9595 in
2 MR. KARADZIC: [Interpretation]
3 Q. Can you see that statement on the screen in front of you?
4 A. Yes, Mr. President.
5 Q. Thank you. Did you read and sign that statement?
6 A. Yes.
7 THE ACCUSED: [Interpretation] Could we please show the last page
8 to the witness so that he can see and identify his signature.
9 MR. KARADZIC: [Interpretation]
10 Q. Is this your signature?
11 A. That is my signature.
12 Q. Thank you. Does this statement reflect what you said to the
13 Defence team?
14 A. Yes, Mr. President.
15 Q. Thank you. If I were to ask you the same questions today as you
16 were asked by my associates, would your answers in essence be the same?
17 A. Yes, they would be the same.
18 Q. Thank you.
19 THE ACCUSED: [Interpretation] I would like to tender this
20 statement pursuant to the Rule 92 ter.
21 JUDGE KWON: Do you have any observation as to the two paragraphs
22 in which the adjudicated fact numbers were erroneously referred to, i.e.,
23 para 17 and para 18?
24 Yes, Mr. Robinson.
25 MR. ROBINSON: Yes, Mr. President, first of all, I would like to
1 apologise for that. As you know, the Prosecution filed a written
2 pleading indicating that there were errors in the numbers of adjudicated
3 facts and we directed our Case Manager to correct those errors but
4 unfortunately, that job apparently wasn't done 100 per cent successfully.
5 As far as the remedy, I think it's best to just leave -- this is a
6 statement signed by the witness. I think it's best to just leave it in
7 there. These adjudicated facts are referred to for the convenience of
8 the Chamber in deciding whether they have been rebutted and don't
9 constitute the evidence of the witness. The evidence is his answer. So
10 we will inform the Chamber by e-mail of the correct adjudicated fact
11 numbers, but I don't think there is any need to change the statement.
12 JUDGE KWON: I don't follow your statement that they don't
13 constitute the evidence of the witness. What did you mean, Mr. Robinson?
14 MR. ROBINSON: Well, for example, if you look at number 17, which
15 appears to be maybe a compilation of multiple adjudicated facts or a
16 merging of them, the evidence is what the witness states and then he
17 describes what happened during that period. So the fact that it's
18 adjudicated fact number 2450 in the statement and it's really maybe
19 adjudicated facts 2448 through 50, doesn't affect his evidence.
20 Similarly for number 18, the reference to adjudicated fact number 514,
21 the number is somehow different. It doesn't really affect his evidence
22 as to what he explains happened with his contacts with his Muslim
23 friends. So I think we can remedy it without altering the statement.
24 But if you prefer us to alter the statement, we can do that. My only
25 concern was whether that's a good thing to do after -- when the witness
1 has already signed the statement like this.
2 JUDGE KWON: Yes. I would prefer the second option. I would
3 like the Defence to redact those two paragraphs later on and -- and if
4 the Defence wants to lead evidence as to this part, it should be led
6 MR. ROBINSON: That wasn't actually one of the options that I had
7 suggested, Mr. President. I was not talking about redacting the
8 paragraph but changing the number of the adjudicated fact that's referred
9 to. We don't have time to lead this evidence live and that seems to be
10 an unnecessary penalty for a clerical error.
11 JUDGE KWON: No, it's not a penalty, it's up to the Defence. And
12 as to the remaining paragraphs, I think it will do no harm in admitting
13 as it is with your caveat. Yes, the witness statement will be admitted
14 into evidence. Shall we assign a number for that.
15 THE REGISTRAR: It's D4165, Your Honours.
16 JUDGE KWON: And I take it there is no associated exhibits being
17 tendered, Mr. Robinson?
18 MR. ROBINSON: That's correct, Mr. President.
19 JUDGE KWON: Very well.
20 Please continue, Mr. Karadzic.
21 THE ACCUSED: [Interpretation] Thank you.
22 Now I'm going to read in English a brief summary of
23 Mr. Marko Adamovic's statement.
24 [In English] Marko Adamovic worked at the Kljuc Territorial
25 Defence Staff from 1976 until 1989. After that, he moved to the Kljuc
1 municipality assembly to work on duties pertaining to Defence preparation
2 in 1998 -- in 1989, and he stayed there until the start of the war in BH.
3 The court of BH initiated criminal proceedings against him for war crimes
4 in Kljuc, and in the first instance judgement he was acquitted of -- on
5 all counts. Proceedings are currently ongoing before the appeal chamber.
6 After the first incidents caused by the extremists, there was
7 some chaos which lasted until the political authorities of Kljuc, the VRS
8 and the civilian police were established. The roads were cut off,
9 telephones were down and the security of citizens regardless of their
10 affiliation and ethnic background was under threat. Individuals and
11 groups wandered around the territory to acquire personal gain. When the
12 Serbian authorities restored order, they also tried to establish peace
13 and security for all people of Kljuc. Adamovic's unit, that is the
14 Kljuc Battalion, received the task of controlling the territory with the
15 goal of protecting all the people in the area. The unit carried out the
16 task, treating every citizen professionally, humanely and honestly.
17 In Velagici, there was a clash with the people who were found in
18 possession of weapons and military equipment. Some of those persons who
19 had been brought in tried to escape and the guards opened fire on them.
20 The people who fired on the detained Muslims were arrested and
21 proceedings were conducted against them. The grounds were not -- the
22 guards were not members of either VRS or the police from Kljuc.
23 During the clashes in the territory of Kljuc municipality, which
24 lasted about 20 days, there was considerable destruction of material
25 goods. As for the destruction of buildings, whether individual
1 residential units or religious, this was not done by the army or police.
2 During interventions and arrests of Muslim paramilitary units, the
3 civilian population was called on to come out to an open space so that
4 the legal military and police forces could see that they were not armed.
5 The army shelled only the places where the armed extremists were hiding,
6 and not populated areas.
7 The political leadership of Kljuc municipality made an offer for
8 all the people to stay in the area and live with the Serbs in peace.
9 About 3.000 Muslims stayed to live in Kljuc in 1992/1993 and nobody
10 mistreated them. Some Muslims joined the VRS voluntarily, and some
11 joined the civilian police on a voluntary basis too. However, after the
12 first incidents, all those who had someone in third countries tried to
13 leave the municipality. This was true not only for the Muslims and
14 Croats but also for the Serbs. The reasons to leave were primarily
15 security, fear of war and fear of famine because the corridor was closed.
16 Food and medicine supplies were low and there was no electricity or any
17 other basic necessities for life. When a curfew was imposed it applied
18 to all people and not only the Muslims.
19 Everybody was free to choose whether to leave or stay, since the
20 SDS of Kljuc municipality did not plan any ethnic cleansing of the
21 non-Serbian population. The Red Cross helped people who voluntarily
22 wanted to leave Kljuc and there was no need for any permit to be issued
23 by the municipal authorities. The transport was organised privately or
24 by companies and not by the police. Mr. Adamovic learned from his Muslim
25 friends that the Muslim authorities had ordered them not to stay in any
1 institution of Republika Srpska. In Pudin Han village, they formed the
2 Muslim municipality of Kljuc together with the staff of units of the
3 Territorial Defence. Furthermore, in all local communes where the
4 majority of the population was Muslim, they issued a decision to secede
5 from RS. In the whole territory of the municipality, there were joint
6 check-points until May the 20th, 1992. They consisted of Serbs, Muslims
7 and Croats and functioned until the Muslims left them following the
8 instructions from their relevant organs from Sarajevo.
9 And that is a short summary. At that moment, I would not have
10 any questions.
11 JUDGE KWON: Yes, Ms. Edgerton.
12 MS. EDGERTON: Well, Your Honour, since Dr. Karadzic read out in
13 his summary that Adamovic was attached to a unit which was the
14 Kljuc Battalion and that's not contained anywhere in the witness's
15 written evidence, I would think Dr. Karadzic -- it would be incumbent
16 upon Dr. Karadzic to lead that evidence.
17 JUDGE KWON: That's fair enough.
18 Yes, Mr. Karadzic.
19 MR. KARADZIC: [Interpretation]
20 Q. Mr. Adamovic, I'm not sure I understood what the -- wherein the
21 omission lay. Well, could you please tell us what was your connection
22 with the battalion, the Kljuc Battalion, or with the Defence effort as a
24 A. Mr. President, the Kljuc Battalion was not the Kljuc Battalion.
25 It was called so by the people. It was a battalion of the
1 30th Infantry Division which was deployed in the area of Mrkonjic Grad.
2 We were summoned, called up, in the regular way and the battalion was
3 established in the area of Sitnica. As I said, it was a part of the
4 1st Battalion Sipovo Jajce Brigade. It was past the 30th Division.
5 I was assistant commander or deputy commander and assistant for morale
6 and religious and legal issues. The 30th Infantry Division used the
7 battalion as the 1st Light Infantry Brigade, that is.
8 Q. Thank you.
9 THE ACCUSED: [Interpretation] Would that suffice? I thought that
10 this was contained somewhere in the witness statement.
11 JUDGE KWON: Mr. Adamovic, as you have noted, your
12 evidence-in-chief in this case has been admitted in its most part in
13 writing; that is your written statement. And now you'll be
14 cross-examined by the representative of the Office of the Prosecutor. Do
15 you understand that?
16 THE WITNESS: [Interpretation] I understand.
17 JUDGE KWON: But for now, we will have a break for half an hour
18 and resume at five past 11.00.
19 [The witness stands down]
20 --- Recess taken at 10.35 a.m.
21 --- On resuming at 11.07 a.m.
22 JUDGE KWON: Yes, Mr. Tieger.
23 MR. TIEGER: Thank you, Mr. President. May we move very briefly
24 into private session, please?
25 JUDGE KWON: Yes.
1 [Private session]
1 [Open session]
2 THE REGISTRAR: We are in open session, Your Honours.
3 JUDGE KWON: Thank you. Shall we bring in the witness?
4 [The witness takes the stand]
5 JUDGE KWON: Yes, Ms. Edgerton, please proceed.
6 MS. EDGERTON: Thank you.
7 Cross-examination by Ms. Edgerton:
8 Q. Mr. Adamovic, I want to start by just asking you a little bit
9 about the war crimes proceedings in front of the state court in Bosnia
10 that Dr. Karadzic alluded to in his summary, and you refer to in your
11 statement. Now, you said that these proceedings are presently before the
12 appeals chamber. In fact, what happened in your case is after you were
13 acquitted at the first instance, the matter went to appeal and the
14 appeals chamber ordered you be retried; right?
15 A. Yes.
16 Q. And that trial took place in March of this year, and the verdict
17 hasn't been rendered yet, has it?
18 A. That's correct.
19 Q. And the verdicts only -- they only expect the verdict to be
20 rendered some time later this month, in fact, in December 2013; right?
21 A. On the 12th of December.
22 Q. So to be perfectly correct, you're actually still under
23 indictment for charges relating to allegations of war crimes in Kljuc in
24 1992, aren't you?
25 A. I think I am a suspect.
1 Q. Some of the offences that you were charged with include the
2 killing of a number of people in Pudin Han around 28 May 1992; right?
3 A. No.
4 Q. We'll have a look at your indictment later. In fact, among the
5 offences that you're charged with is included the killing of people in
6 Prhovo on or around the 1st of June, 1992, and the killing of men,
7 77 men, at a school in Velagici on or around June the 1st, 1992; right?
8 A. Correct.
9 Q. These killings that I've just referred to, you're not denying
10 they happened, are you? Because you actually confirmed in your statement
11 that innocent civilians were killed in Prhovo and people were shot at
12 Velagici while they were trying to scape. You're not denying them. They
13 happened; right?
14 A. I'm not denying, Your Honours.
15 Q. And your position at your trial with respect to these offences
16 was that when they happened, you weren't there; right?
17 A. That's right.
18 Q. So on the 27th of May, 1992, you said at your trial that you were
19 in Mrkonjic Grad; right?
20 A. Not concerning these events. I was not in Mrkonjic Grad when the
21 killings in Velagici and Prhovo happened. I was in Kljuc at the time,
22 but I was not on the scene.
23 Q. At your trial, and Mr. Adamovic, I've listened to the transcript,
24 I've listened to the trial as it was going on live and I heard you say
25 that on 27 May 1992, you were in Mrkonjic Grad conducting reconnaissance.
1 That's what you told the Court in Bosnia-Herzegovina; right?
2 A. I said that on the 27th of May, but you mentioned the 1st of June
3 when the killings in Velagici and Prhovo happened. At that time, I was
4 in Kljuc. However, on 27 May, I was in Mrkonjic Grad.
5 Q. And on the 10th of July, you were at Mrkonjic Grad as well?
6 A. On the 10th of July, I was in Mrkonjic Grad.
7 Q. And the evidence you gave at your trial was that on the
8 1st of June, you were at a meeting of the Crisis Staff in Kljuc; right?
9 A. Right.
10 Q. Now, your position at your trial was that you weren't a member of
11 the Crisis Staff but you attended their sessions; correct?
12 A. Right.
13 Q. And you went there to brief your immediate superior, your brigade
15 A. Correct. My brigade commander was present at the Crisis Staff
16 and on the orders of my battalion commander I went to inform my commander
17 on the situation in the unit.
18 Q. And you also briefed your division commander, General Galic. You
19 said that at your trial. You went to the Crisis Staff meetings and there
20 you briefed your brigade commander and General Galic; right?
21 A. I briefed my commander, Lieutenant-Colonel Vukasevic, but I also
22 stated that Galic was present at that meeting, once or twice, not every
24 Q. Well, in fact, what you said at your trial was: With respect to
25 the Crisis Staff every time I went there, there was the same group of
1 people, and I note that I never went there without
2 Lieutenant-Colonel Vukasevic or Galic being present. That's what you
4 A. Generally speaking, yes. Perhaps he was absent a couple of times
5 but after all this time I can't remember.
6 Q. And these -- and you briefed them, these briefings, and their
7 presence there was to make sure that everybody was on the same page,
8 right, to make sure all the activity in the area was co-ordinated?
9 A. I don't know the answer to that question. I only know that
10 I reported to my superior on the situation in the unit. Now, how the
11 information I gave would be used by someone else, I didn't know then and
12 I don't know now.
13 Q. All right. And you briefed them often, you briefed them on a
14 daily basis at that Crisis Staff, sometimes even twice a day; right?
15 A. Perhaps it happened once that I briefed them twice in one day,
16 but generally speaking, I informed not the Crisis Staff but my superior
17 commander, and in that period, that was only five times. And twice
18 I reported to my superior at the War Presidency because I was there only
19 from 28 May until the 28th of June.
20 THE ACCUSED: [Interpretation] Transcript.
21 JUDGE KWON: Yes.
22 THE ACCUSED: [Interpretation] I believe the witness said until
23 the "20th June," not "28."
24 THE WITNESS: [Interpretation] 20th of June.
25 JUDGE KWON: Thank you.
1 MS. EDGERTON:
2 Q. So if you don't know what the purpose of your briefing the
3 Crisis Staff, your immediate superior, General Galic, during these
4 Crisis Staff meetings would have been, I take it you're not a political
5 man. You didn't pay any attention to what was going on during those
7 A. I was present at that meeting only the time it took me to do my
8 duty and brief them, and then I left. There were sessions when I stayed
9 on a bit longer, but, for the most part, I didn't stay until the end of
10 the session while they were doing other things, dealing with other
12 Q. And during your trial, you also gave evidence that until 1993,
13 you were never a member of the SDS; right?
14 A. Correct. I was president of the SK, the movement for Yugoslavia,
15 at the level of the municipality south. That has been established
16 through all my witnesses.
17 Q. And you actually only joined the party so that you could keep
18 your job; right? That was your evidence in your trial.
19 A. I said at the trial that I joined the party towards the end of
20 1993, and/or the beginning of 1994. A recommendation came down that
21 assistant commanders for moral guidance, religious and legal affairs
22 should be involved in the party; in other words, it was necessary for
23 them to be members of the SDS. At that time I signed the paper joining
24 the SDS and that, too, was established at the trial.
25 Q. And so you weren't a member of the Crisis Staff, you weren't a
1 member of the SDS and you also weren't a member of the War Presidency for
2 Kljuc municipality, were you?
3 A. No.
4 Q. All right.
5 THE ACCUSED: Just a moment. I would like to clarify, we have
6 problem with the negation in Serbian and in English. Sorry, in
7 translation was that a no would be contrary to the meaning.
8 JUDGE KWON: The witness confirmed that he was not a member of
9 the Crisis Staff. Were you a member of the Crisis Staff, Mr. Adamovic?
10 THE WITNESS: [Interpretation] No.
11 JUDGE KWON: Is it clear to you, Mr. Karadzic?
12 THE ACCUSED: Yes, Excellency, but in Serbian, translation was
14 JUDGE KWON: Very well. Shall we continue.
15 MS. EDGERTON: So --
16 JUDGE KWON: But before we continue --
17 MS. EDGERTON: Of course.
18 JUDGE KWON: -- I'd like to make it clear, what the Chamber
19 ordered to redact from paragraph 17 and 18 from his statement is that
20 the -- the reference to the adjudicated facts, so the part which appears
21 after, "I can state the following" can remain in both paragraphs.
22 MR. ROBINSON: Thank you, I didn't understand it that way. Thank
23 you very much.
24 MS. EDGERTON: Thank you.
25 Q. So having put politics aside, let's talk about your military
1 function. You explained to Dr. Karadzic that the Kljuc Battalion wasn't
2 actually -- it was only called the Kljuc Battalion by the people and you
3 said you were deployed in the area of Mrkonjic Grad. I'd like us to have
4 a look at a document in that regard, please. It's 65 ter number 00895.
5 So Mr. Adamovic, you've seen this document before, I know. It's
6 dated 2nd November, 1993, and it's drafted by Slavko Culic, who succeeded
7 Colonel Vukasevic as your brigade commander, and it's a supplement to the
8 monograph of the first --
9 THE ACCUSED: Sorry, no translation. So far I didn't hear.
10 JUDGE KWON: Very well. If you could repeat, Ms. Edgerton.
11 MS. EDGERTON: Sure.
12 Q. So we are now talking about the Kljuc Battalion because you told
13 Dr. Karadzic the Kljuc Battalion was only called that by the people and
14 you said you were deployed in the area of Mrkonjic Grad.
15 Now, you've seen this document before, Mr. Adamovic, and I'd like
16 us to go over to page 3 in B/C/S and page 2 in English, please. Now,
17 Mr. Adamovic, this document, this military report, specifically refers to
18 the Kljuc Battalion as being formed on 18 April 1992, and lists you as
19 its deputy commander; right?
20 A. Yes. That's right. Except, Your Honours, one needs to read this
21 sentence till the end. The Kljuc Battalion which became part of the
22 1st Light Infantry Brigade, as its 3rd Infantry Battalion, was stationed
23 in the area of the village of Sitnica. It was called sometimes the
24 Kljuc Battalion because all the members were from Kljuc. But, actually,
25 it was part of the 3rd Infantry Battalion. That's what I stated and
1 that's how it was, and I was assistant commander of that battalion.
2 Q. Now, let's go over to page 3 in English and let's have a look at
3 what the battalion was doing, and we can stay on the same page in B/C/S.
4 This document says, Mr. Adamovic, when the armed conflict in Kljuc began,
5 the entire battalion was relocated to the region outside Kljuc from where
6 it was deployed to mop up the town and the surrounding settlements. The
7 decision to assign this task - I'll just wait a second - to the battalion
8 was issued on 27 May 1992. And the document lists the deployment areas
9 of the 1st and 2nd Company. My question to you is: That's your
10 battalion this passage is referring to; right? Yes or no?
11 A. That's correct.
12 Q. The battalion's task was to disarm paramilitary formations and
13 arrest them; right?
14 A. In this document, I just saw that this was written by
15 Lieutenant-Colonel Culic. Culic joined that brigade after several months
16 of various actions in Kljuc. The battalion was not engaged in combat in
17 Kljuc. The battalion was engaged only in controlling the territory from
18 Pudin Han, Velagici, Ramici and Krasulje, controlling the road and all
19 the movements in that area of the population, goods, et cetera. That was
20 the task of the battalion. Why this commanding officer wrote this,
21 I can't understand. The battalion was not employed in any other way,
22 because other units did what it says here the battalion did.
23 Q. Let's just have a look at this for a second. This document says
24 the 1st Company of the battalion unit attacked from the area of the
25 village Rezevici, the village of Hadzici, the village of Pudin Han.
1 That's correct; right?
2 A. No. The company was only transferred there in the sector of
3 Ramici. On the 27th there were no combat actions anyway.
4 Q. How would you know that when you said you weren't there?
5 A. On the 27th, I arrived at Kljuc at night and the battalion could
6 not have been without us, without the command. We came to Kljuc on the
7 night of the 27th, and that's the truth.
8 Q. So when you said in your trial on 27 May 1992, you were in
9 Mrkonjic Grad conducting reconnaissance, was that also the truth?
10 A. Yes. I was involved in reconnaissance that morning and during
11 the day, and we arrived at Kljuc around 2000 hours.
12 Q. Now, if you go down further in the same document in English, last
13 paragraph, and then go over to the next page in B/C/S, this document
14 talks about the battalion's deployments the following day. The following
15 day, it says: The battalion was deployed to carry out the same task in
16 the area of the village of Pudin Han, Vukovo Selo, Humici, Plamenice,
17 Vrhovo and Peci. A mopping-up operation in the villages of Kamicak and
18 Vrhpolje ensued. That's true; right? That's your battalion.
19 A. This is not true. It's not correct. And during my trial, we
20 established and proved that the battalion was not involved in any combat
21 operations. Why this commander who came later wrote this, including
22 about some other battalions such as the Jajce and Sipovac Battalion,
23 I can't understand. But during my trial, we proved undeniably,
24 irrefutably that my battalion was not involved in these events.
25 Q. Well, Mr. Adamovic, we can go to the judgement in your first
1 instance trial and see if what you said holds true because it's available
2 on the internet and we'll do that later on.
3 Let's leave this document aside for a minute, and leaving
4 deployments aside for a minute.
5 JUDGE KWON: Are you tendering this?
6 MS. EDGERTON: Yes, I was going to come back to it, but for the
7 sake of reference why don't we just give it a number now.
8 JUDGE KWON: Yes, we'll receive it.
9 THE REGISTRAR: Exhibit P6543, Your Honours.
10 MS. EDGERTON: Thank you.
11 Q. Now, we've talked about Crisis Staff meetings and meetings that
12 you attended, and I'd like to have a look at minutes of meetings of the
13 Kljuc Crisis Staff, that's P2606. These are meetings from May to
14 July 1992. Now, you've seen this document before as well, Mr. Adamovic.
15 So since you have --
16 A. Yes.
17 Q. Since you have, I'll go straight over to English page 10, B/C/S
18 page 34, and that should show us minutes from the meeting of 3 June 1992.
19 Could we just try the next page in B/C/S -- in B/C/S, please. It seems
20 like every second page has this name and date stamp.
21 Now, these minutes refer to your presence, Mr. Adamovic, at the
22 meeting of June 3rd, and they describe you as the Kljuc defence commander
23 and I want to show you another page. Let's go over to English page 17,
24 B/C/S page 49, minutes of the 16th of July, 1992 -- pardon me,
25 16th of June, 1992. These minutes also describe you as defence
1 commander. And we can actually even pop back over to minutes of the
2 meetings of the 4th of June, if you'd like to see them, English pages 11
3 and 12 and B/C/S page 37. There, again, you're also described as defence
5 Now, you told this Chamber that you were never a commander of the
6 Kljuc Battalion. We've seen, in the last document, P6543, you were
7 actually a deputy commander. You've told this Chamber that you were a
8 deputy commander for morale and religious affairs. That document we just
9 saw, P6543, makes no mention of you having the position of deputy
10 commander for morale and religious affairs. Instead, what we have here
11 now, in June of 1992, is you noted by the Crisis Staff as being a defence
12 commander, and that was defence commander for the city of Kljuc, wasn't
13 it, Mr. Adamovic?
14 A. It says in the minutes what it says but that was not the case,
15 Your Honours. Please allow me to explain. I'll just need two sentences
16 and I won't be long. On the 1st of June, the commander of the
17 30th Division came with an order to establish the command of town
18 defence. He brought that order and in view of the situation on the
19 ground - and let me not go into the details of what the town command was
20 supposed to do - several officers had suggestions and proposals as to who
21 that should be. According to one of the suggestions, I was supposed to
22 be the commander of the town defence, but one session was not enough.
23 The corps commander had to issue an order to appoint the town commander
24 and the town command had to be established. I was told, orally, to
25 prepare myself to become the town commander, but that lived for only
1 three days.
2 A subsequent order came to set up the
3 17th Light Infantry Brigade. Commander Drago Samardzija came and the
4 setting up of the brigade started on the 6th of June. On the 1st of
5 June, we received that first order to set up the town command. Those
6 people who made those records, I don't know what to call them, they
7 tended to call everybody commander. During those first days they called
8 even me commander. However, the command of the town defence was never
9 set up because, instead, the brigade was established, and I became the
10 assistant commander of the brigade for moral guidance and legal and
11 religious affairs. That was established during my trial, and that was
12 how things indeed were.
13 Q. So these minutes aren't accurate, is that what you're saying?
14 A. In my view, the title is not correct. I can't talk about any
15 minutes. I never took any minutes. What that person meant is entirely
16 up to him. What I'm saying is this: The town command was never set up.
17 There is not a single document corroborating the setting up of the town
18 command. The town command didn't exist. Therefore, it did not issue a
19 single order or a single document. I believe that you have that document
20 talking about the setting up of the town command where it says the town
21 commander will be, and then an empty dotted line, and the rest of the
22 document, the dotted line was never filled out because the town commander
23 was never appointed because he was supposed to be appointed by the
24 commander of the 1st Corps. He was the person in charge of setting up
25 all the commanders within the corps. Why he didn't appoint him, because
1 four days later there was a change and the 17th Light Infantry Brigade
2 was established. I became a member of the 17th Light Infantry Brigade on
3 the 4th of June. You can see that in my personnel file. I'm sure that
4 you can gain access to the personnel files of that brigade and you will
5 find me there.
6 Q. Now, Mr. Adamovic, you just said there is not a single document
7 corroborating the setting up of the town command. It's -- in fact,
8 Mr. Adamovic, there is also not a single document corroborating your
9 presence at the meeting of the Crisis Staff on 1st of June, 1992, is
10 there? In fact, to the contrary, these minutes, and if we can go over in
11 English to page 7, these minutes for the meeting on the 1st of June,
12 1992, don't list you among the participants. B/C/S page 27, please.
13 Mr. Adamovic, you weren't there and you're grabbing at this as
14 the only possible opportunity to alibi your presence at Prhovo on the
15 1st of June, 1992.
16 A. Your Honours, I believe that this is only Madam Prosecutor's
17 assumption, a mere assumption. The position of the town defence
18 commander does not presuppose the command of a unit. If I was a town
19 defence commander I would have never been in command of any unit. The
20 town commander is never in charge of any unit, a smaller unit or a bigger
21 unit for that matter. And if I had ever been supposed to be the town
22 commander, I would not have been in Prhovo -- I could not appoint myself.
23 You don't have those minutes but I have them. Are you not willing to
24 show the minutes here? Or I can't say. But I have the minutes of the
25 1st where the town command was discussed and an order did arrive that the
1 town command should be established. I was present. I don't know whether
2 you have those minutes or not, but I have them.
3 Q. Mr. Adamovic, you're looking at them, and my question to you was:
4 Mr. Adamovic, there is not a single document corroborating your presence
5 at the meeting of the Crisis Staff. You have in front of you the minutes
6 of the meeting of the Crisis Staff of the 1st of June, 1992. It's two
7 pages. When the witness has had a look at the first page, we can flip
8 over to the second page. You're not there.
9 A. Your Honours, according to those minutes, I was not present.
10 However, there were sometimes two or even three different sessions.
11 I suppose that I was not there when those minutes were taken. However,
12 in the course of that day, there were two or three sessions in view of
13 the crisis. I attended that evening's session and I had arrived to
14 inform the commander about the situation in the unit and then the
15 proposal arrived to set up the town defence command. That document
16 exists. It was issued on the 31st of May and it was presented at the
17 meeting in Kljuc on the 1st of June. Why the second set of minutes is
18 not there, I really don't understand.
19 Q. You're not answering my question. You haven't got a single piece
20 of paper to corroborate your presence at a Crisis Staff meeting on the
21 1st of June, 1992, have you?
22 A. I stated that I had that paper. It is not here, I don't know
23 why, but I have it.
24 Q. What do you have, Mr. Adamovic? And you knew you were coming
25 today, you knew you were coming for a long time ahead of time.
1 Mr. Adamovic, are you saying that you have evidence that confirms your
2 presence at this meeting on the 1st of June, 1992, and you didn't bring
3 it? Mr. Adamovic, you didn't bring it at your own trial in
4 Bosnia-Herzegovina either, did you, because it doesn't exist?
5 A. I had that document -- I didn't bring it myself because the
6 Prosecutor showed it to the Trial Chamber, and it is in the file of that
7 case, but I did not know that I was coming here to be questioned as a
8 suspect, and you are now questioning me as if I were accused. That's why
9 I don't have it. I am here to testify and in my testimony I'm supposed
10 to follow the statement that I provided, and now you're not sticking to
11 that statement at all.
12 Q. No, I'm not. I want to know what you have. Do you have a set of
13 minutes that records you as being present at a Crisis Staff meeting on
14 the 1st of June, 1992, in Kljuc?
15 A. Yes, I do. A set of minutes that shows that the command of the
16 defence of the town of Kljuc was set up on the 1st of June, and I have
17 those minutes.
18 Q. Can we go over to the next page in B/C/S and in English, please.
19 Mr. Adamovic, it's not here, and you didn't offer those minutes at your
20 trial in Bosnia and Herzegovina. You never said they existed. That's
21 because it never happened; right?
22 MS. EDGERTON: Sorry, you're going to have to skip over to the
23 odd-numbered pages. I really apologise for forgetting about this. And I
24 don't know why in B/C/S these copy certifications are uploaded as
25 separate pages. Thank you. Oh, now, wait a minute. It seems like the
1 B/C/S is -- the B/C/S doesn't correspond with the English translation
2 page. In all fairness, let me have a look at that, please. Do you know
3 what? The B/C/S pages, even though they are uploaded in the way in which
4 they are stamped with an ERN are out of order. And in fairness to the
5 witness, I'm not going to deal with this any more until he can get a
6 chance to look at the correct version and I'm just going to move on, and
7 we'll come back to it.
8 Q. I want to stay, Mr. Adamovic, on the subject of the take-over of
9 Prhovo on the 1st of June, 1992, and the killings during the take-over.
10 Mr. Adamovic, when you said in your statement that the state court in
11 Bosnia acquitted you of any responsibility related to the event, you
12 actually omitted to say that they found that you were there the day
13 before the attack. That's right, isn't it?
14 A. Your Honours, I was there every single day in the sector where
15 things were happening, not only in Prhovo but in all of the surrounding
16 villages, because I lived there.
17 Q. So it's correct, you were in Prhovo the day before the attack?
18 A. Not correct. And I never said that. The day before the attack,
19 I was not in Prhovo. There were witnesses who said that they saw me.
20 Allegedly, I was wearing a uniform, the others said that I had a
21 camouflage uniform, some saw me in civilian T-shirts, but I'm sure I was
22 not in Prhovo. It was established by the Court who was there and who
23 carried out those activities.
24 Q. The day before the attack on Prhovo, at paragraph 304 of their
25 judgement, the state court of Bosnia and Herzegovina accepted witness
1 testimonies and concluded that you were present when soldiers mistreated
2 the residents of Prhovo on the day before the attack.
3 A. I was not there, absolutely not. And it was proven, contrary to
4 the testimonies, that on that day I attended the meeting of the
5 Crisis Staff. On that day, the order arrived to set up the town defence
6 command. During my trial, it was established which units had done it and
7 which units had been deployed in the area. During my trial, I was forced
8 to say the name, but the Prosecutor there did not want to accept my
9 suggestion. She stuck closely to the indictment and she tried her
10 hardest that I was there. I was never in command of a military police
11 unit, and there was a military police unit there. And I told the
12 Trial Chamber, You have a VOBH, she found mine, she could find the VOBH
13 of the military police officers who were there. She could have listened
14 to the testimonies of a couple of people who were -- who would have
15 corroborated the fact that those military policemen were indeed there.
16 She could have done all that instead of trying to pin guilt on an
17 innocent person.
18 Q. You talked about -- well, what you actually said about those
19 testimonies of people who put you in Prhovo, either the day before or the
20 day of the attack, was that they were lying and that you thought that it
21 was all pre-arranged. Those lies, you thought, were all prepared in
22 advance. That's what you said in your trial at the state court; right?
23 A. That's correct, yes.
24 Q. Well, Mr. Adamovic, it's not those witnesses, it's not just those
25 witnesses who testified in your trial at the state court who placed you
1 in Prhovo the day before and the day of the attack. It's a large number
2 of additional witnesses. Let's have a look -- just talking about the
3 30th of May, 1992, let's have a look at 65 ter number 25732.
4 Mr. Adamovic, this is a statement to this Tribunal taken in 1997 from
5 Nafa Krantic, and she talks about Serb soldiers passing through her
6 village, which was Plamenica, on 28 or 29 May, 1992. If we could go over
7 to the next page, please. I'm going to read this to you because I don't
8 think you speak English or read English. But what Ms. Krantic says: On
9 Saturday, either 28 or 29 May, 1992, Serbian soldiers entered our
10 village. They came as infantry and then one APC. They wore regular JNA
11 uniforms. And then she goes on and she talks about what -- their
12 feelings of fear, that the soldiers told them that nothing would happen
13 and to stay in the village. And she says: The commander was the
14 teacher, Marko Adamovic, whom I know. He was teaching me in the
15 elementary school in Humici. That day he wore a JNA uniform and I saw he
16 had some rank on his epaulettes. That day I only recognised
17 Marko Adamovic and the soldiers passed through the village.
18 Mr. Adamovic, this woman, who didn't testify in your trial,
19 recognised you as her teacher and she recognised you in the immediate
20 area of Prhovo on 28 or 29 May, 1992.
21 A. And what am I now supposed to say? I claim that she did not
22 recognise me because she did not see me there. Your Honours, during my
23 trial, there was a witness who was born in 1971, and I taught school
24 until 1972, claimed that I was a teacher, that he knew me, that he knew
25 that I was a teacher, and he had never seen me before, never. Twelve
1 years later, he claimed that he recognised Marko Adamovic's words on the
2 bull-horn. Let's start from the initial assumption. If you know
3 military structure, you will know that Marko Adamovic could not be in
4 charge of Pragas, APCs and anything else. It would be impossible. But
5 nobody prevents her from telling whatever she wants to say and it's not
6 the truth.
7 Q. You were a teacher in Humici before the war, weren't with you,
8 before you joined the Territorial Defence; right?
9 A. That's correct, until 1973, as a matter of fact.
10 Q. Right. In fact, Mr. Adamovic, there is not one, there is not
11 two, there is not three, but there is -- and this is just dealing with
12 the day before the attack, there is multiple witnesses who gave evidence
13 to this Tribunal about events in Prhovo on the 1st of June, 1992, and
14 each one reports seeing you there, and these are not witnesses,
15 Mr. Adamovic, who testified at your trial. Let's look at
16 65 ter number 25733. It's a statement to this Tribunal taken in 1997, so
17 five years only after the incident, from Bajro Hadzic. He didn't testify
18 at your trial, and if you go over to page 3, if you go over to page 3,
19 the second full paragraph, he describes the 1st of June, 1992, the
20 occupation of Prhovo by soldiers. He describes people being called out
21 through a loud speaker. He describes seeing Marko Adamovic, who had the
22 command. I know Marko Adamovic. He was working in the military
23 department in Kljuc. He was a captain in the reserves, and in Humici, he
24 was teaching children. So you've conceded you were a teacher in Humici.
25 You were also -- it's true, isn't it, you were also a captain in the
1 military reserves; right?
2 A. I was a teacher, and I stopped teaching and joined the TO staff,
3 and I was a member of the reserves, and I'm not saying that people don't
4 know me. I'm just saying that I was not in Prhovo on the day when those
5 activities happened. It is well-known which unit was there, which unit
6 was deployed in the area, and Marko Adamovic was not in command of that
7 unit. I have no other answers, Your Honours.
8 Q. We are going to look at one more document, 65 ter number 25738.
9 It's the ICTY statement of a survivor from Prhovo by the name of
10 Azim Medanovic taken in 1997. Now, if we go over to page 4, he says,
11 about halfway down the page:
12 "Of all the Serbs there in Prhovo on the 1st of June, 1992,
13 I recognised only Marko Adamovic. He wasn't masked, it was obvious he
14 was in charge. I remembered him from the time when he was a teacher in
15 Peci. I'm not sure I would recognise him now, but I did at the time."
16 And further on on this same page, Mr. Medanovic describes being
17 separated from the women and children in Prhovo, being marched out of the
18 village in a column. He describes you taking a microphone, ordering
19 women and children to be killed, and the village burned to the ground.
20 In the column, this witness says you ordered it was -- it be split in
21 two. This witness says you beat him. This witness describes how five
22 people who couldn't stand up after being beaten were killed. He
23 describes how a soldier singled out a 16-year-old from the column and
24 shot him after you called out that there were too many of them. And he
25 was saved, this witness, when one of his prospective executioners
1 recognised him.
2 Mr. Adamovic, these people have lost family, friends. They have
3 been beaten. They have been threatened. They have been detained.
4 You're still indicted, though. These witnesses have no interest in
5 telling anything but the truth. It's in your interest, still under
6 indictment, to exculpate yourself from the charges you faced in
7 Bosnia-Herzegovina, isn't it?
8 A. No. Your Honours, fully consciously, I state with all moral and
9 other responsibility, that I did not carry out those actions that the
10 witnesses are mentioning. Nobody is prohibited from saying what they
11 think or any other information -- or to share any other information. It
12 was proven at trial because there was this activity, it was known who was
13 involved, there is a written order - maybe you, lady, don't know that -
14 by the commander of the 1st Corps specifying which unit was supposed to
15 go there. And I'm reiterating this was a platoon of the military police
16 from Banja Luka, from the 1st Krajina Corps. It went there to control
17 the territory. At the exit of Prhovo village, they were caught in an
18 ambush by a paramilitary armed group who opened fire at a column, killed
19 some civilians, and then there was a conflict.
20 Q. If you weren't there, how do you know so much about what was
21 going on?
22 A. I did not finish, Your Honours.
23 Q. No, Mr. Adamovic --
24 A. And that is when the conflict --
25 Q. -- answer my question, please. If you weren't there, how do you
1 know enough to give us this explanation?
2 A. I was about to explain. I know about these things because the
3 officer in question at the meeting concerning the establishment of the
4 town defence command, that officer came in, and I have witnesses from the
5 Crisis Staff members who attended -- the members attended the meeting saw
6 that officer who came in crying. He said that I was there with Pragas
7 and APCs, we were ambushed, one member of the military was killed, and
8 Prosecution witnesses confirmed that, and then after that, that soldier
9 was killed, there was spontaneous fire being opened, quite a lot of
10 people were killed, he was crying, and he asked for some people to be
11 sent there to expect what was -- what had been done to the civilians. In
12 my defence, I don't want to be responsible for somebody others' actions,
13 Your Honours. I stated the name of that officer and stated the -- which
14 unit was involved there. And if this is not true, I offer my head on the
15 block. I wanted to help the prosecution to blame those responsible, but
16 they didn't want to. They wanted to frame me. But truth will out
18 Q. Well, Mr. Adamovic, you said you had witnesses from the
19 Crisis Staff who could talk about this story. I'm going to just read you
20 the evidence of one of the Crisis Staff members, Mr. Rajko Kalabic, and
21 I apologise if I mispronounce it, that he came to testify before a
22 Chamber of this Tribunal in the case against Brdjanin. And he talked
23 about the events in Prhovo on the 1st of June, 1992, at transcript
24 pages 22664 and 22665. He said nothing about someone coming into the
25 meeting afterwards and upset about what had happened in Prhovo. In fact,
1 he said: It was only after the event that the information reached the
2 Crisis Staff, whether it was on the same day or one or two days after the
3 events, I can't say. So the Crisis Staff member who came to testify here
4 in defence of Mr. Brdjanin says something completely different to you.
5 The truth is: You were there, and it's only in your interest to deny it.
6 A. No, Your Honours. Rajko Kalabic testified in my trial as well
7 and corroborated what I'm saying, and some other members of the
8 Crisis Staff as well. Maybe he wasn't asked about that in that other
9 trial. Maybe at that time he did not know what was going on after so
10 many years, but he did testify in my trial, and he corroborated the words
11 that I'm offering to you here and now.
12 Q. Ah, so you're saying that Mr. Kalabic gave different evidence at
13 your trial in Bosnia-Herzegovina than what he gave on the same subject as
14 a defence witness here at this Tribunal? That's what you're saying?
15 A. I'm saying that he did testify that on that day I did attend the
16 meeting of the Crisis Staff and that I wasn't in Prhovo.
17 Q. Let's move on to a different subject. I want to just touch on
18 some of the incidents that you discussed in paragraph 3 of your
19 statement, under the heading, "Paramilitary and para police organisation
20 incidents in Kljuc."
21 Now, all of those incidents -- and you've got a copy of your
22 statement in front of you so you look at paragraph 3. All of those
23 incidents happened on the 27th of May, 1992; right?
24 A. Yes, those that I mentioned. That's correct.
25 Q. And all those incidents that you refer to happened at a time when
1 Serb authorities were in total control of Kljuc municipality, didn't
3 A. No.
4 Q. All right.
5 A. The municipality of Kljuc was controlled by two, not just the
6 Serbian authorities, but also the Muslim authorities. On the 27th, the
7 municipality was split into two territories, that under the Serbian
8 authorities and that under the Muslim authorities, because they
9 seceded --
10 Q. Mr. Adamovic, these incidents happened in areas that were under
11 the control of Serbian authorities at that time; right?
12 A. No.
13 Q. I'm going to show you a document.
14 A. Those incidents took place in the area controlled by the Muslim
15 forces. In Velagici, Ramici and Crljeni.
16 Q. All right, given your answers I want to show you a document.
17 It's P3438.
18 JUDGE KWON: There seems to be a technical difficulty with
19 e-court. Shall we break now?
20 MS. EDGERTON: Fine.
21 JUDGE KWON: Very well. We'll have a somewhat early lunch break.
22 We will resume at 10 past 1.00.
23 --- Recess taken at 12.21 p.m.
24 --- On resuming at 1.14 p.m.
25 JUDGE KWON: Yes, please continue, Ms. Edgerton.
1 MS. EDGERTON: Thank you. We left off trying to have a look at
2 P3438, if my colleague could bring that up on the screen. All right.
3 Q. Mr. Adamovic, what you see in front of you are minutes of the
4 8th meeting of the Kljuc Crisis Staff on 23 April 1992. And at this
5 meeting, in the third paragraph under point 1, on the page in front of
6 us, you see Veljko Kondic, who is president of the SDS municipal board,
8 "Serbs are the majority population in Kljuc. We control all the
9 important positions."
10 Actually, I think in B/C/S it might be on page 2. Yes. I think
11 so. So Kondic says:
12 "Serbs are in the majority in Kljuc. We control all the
13 important positions."
14 And if we go over to page 2 in English, and page 3 in B/C/S,
15 paragraph 2, you see Mirko Rosic say -- he tells people at the meeting,
16 at the Crisis Staff meeting: The SUP is ours. And there is nothing to
17 divide. So, Mr. Adamovic, we left talking about -- we broke off before
18 lunch talking about Serb authorities being in total control of Kljuc
19 municipality, and it doesn't take a politician to figure out that what
20 Kondic is saying is that by the end of April, all power in Kljuc was
21 controlled by the Serbs. That's what Kondic and Rosic are saying, isn't
22 it? All power in Kljuc is controlled by the Serbs.
23 A. I was not involved in those party political meetings. I was not
24 there. And I personally, my opinion is, if you wish to hear it, is that
25 most of the authority in the territory of Kljuc was in the hands of the
1 Serbs. But in mid-May, there was a splitting up of the municipality into
2 two parts, and that territory which was predominantly populated by the
3 Muslims was -- was under the control of the Muslim leadership, MBO and
4 the SDA, and they separated the Pudin Han, Velagici, Krasulje, Filipovici
5 and other villages, that area predominantly populated by the Muslims
6 split off from the municipality. They issued decisions on that split,
7 and, for that reason, I believe that they controlled that particular
8 territory. They formed municipal staff of the TO, units of the TO, and
9 they armed people, controlled the territory, set up check-points,
10 facilities, et cetera, et cetera.
11 Q. And you took them back; right? You took those places.
12 Pudin Han, Velagici, Krasulje and other villages, you took them back;
13 right? That's what happened.
14 A. Kljuc did not retake those villages. I see this differently.
15 I see this from a military point of view. After the ambush at -- of the
16 line of young soldiers departing from Zadar towards Serbia, which was
17 ambushed in Kljuc, there was a double ambush in Velagici and Pudin Han by
18 the Muslims. They attacked six or seven young soldiers. Nineteen were
19 injured. The 1st and the 2nd Krajina Corps units intervened there and
20 those units took that area.
21 Q. You're repeating your statement and that wastes time. You've
22 taken all that time to say to us that the 1st and 2nd Krajina Corps
23 intervened and those units took that area, so what I put to you was
24 right. You took it back; correct?
25 A. I answered you that this wasn't done by the civilian and other
1 organs of the Kljuc municipality. These were military organs. My
2 purpose when answering was to express that.
3 Q. Well, let's have a look at what the civilian authorities of Kljuc
4 municipality did. I'd like to get out D1724, please. It's a public
5 announcement from the Kljuc Crisis Staff, Mr. Adamovic, and it's dated
6 8 May 1992, so it's a little over a week after the document we just
7 looked at. And this document informs the public that since the
8 7th of May, 1992, the police in the whole municipality are going to be
9 wearing blue berets with the Serbian flag and that from this point
10 forward, a Serb flag would fly from the Kljuc municipality building,
11 signifying the fact that Kljuc municipality is now a part of the
12 autonomous region of Bosanska Krajina and the Serbian Republic of
13 Bosnia and Herzegovina. So, Mr. Adamovic, what the -- what the -- what
14 the authorities did is, on the 7th of May, 1992, they put into effect a
15 unilateral political and military take-over of control of the
16 municipality, and all aspects of life in it. That's what this document
17 shows. Isn't that the case?
18 A. Your Honours, I cannot comment on this public announcement.
19 I did not take part in forming that decision. I wasn't there. At that
20 time I was with my unit 20 kilometres away, and I cannot comment or be
21 responsible for the activities or for the consequences stemming from this
22 public announcement or this decision.
23 Q. We'll move on. Now, we looked earlier on today at a document
24 that's now got the number P6543, and it was a supplement to the monograph
25 related to the 1 KK, and you said, with respect to that document, that it
1 was effectively a fabrication by the man who came to be your brigade
3 MS. EDGERTON: We could have it up just so the witness remembers
4 what he gave that comment on. P6543.
5 Q. And what you said, when we talked in terms of this document about
6 military operations by your battalion, was that you couldn't understand
7 why the brigade commander wrote it; right? Do you remember that?
8 A. I remember saying that.
9 Q. All right. Let's have a look at P5406, then, please. This --
10 you would recognise this sort of a document. This is a daily combat
11 report from the command of the 1st Infantry Brigade - and we can go over
12 to the second page and Mr. Adamovic can see who signed it - to the
13 command of the 30th Infantry Division. See, it's got the typewritten
14 signature of Milorad Vukasevic. That's your commander. Now, we can go
15 back to the first page in both languages, bullet point 2, and have a look
16 at bullet point 2, the second-to-last paragraph of bullet point 2.
17 Sorry, I've got my numbering wrong. I apologise. The second-to-last
18 paragraph of bullet point 2 is on the second page in English. Could you
19 go to page 2 in English? My apologies. There we go.
20 That paragraph says, I think you have to do the same in B/C/S,
21 but I'll read it for Mr. Adamovic. It says: Because of the situation in
22 Kljuc, the 3rd Battalion was -- of the 1st Infantry Brigade was made
23 fully combat ready as ordered. If the Muslims don't surrender their
24 weapons by 27 May 1992 at noon, the battalion will carry out a mopping-up
25 operation. And to this battalion, Combat Group 2 has been attached and
1 has been under our command since last night.
2 That's your battalion; right?
3 A. Well, he was the commander, I don't know about this document.
4 I wasn't battalion commander. This, as you know, is addressed to
5 battalion commanders, such documents as this. He could tell you more
6 about that. I couldn't. I wasn't the commander. I didn't even know it
7 existed. Brigade commander issues orders to battalion commanders,
8 assistant commanders for moral guidance do not command battalions. I
9 cannot comment on this document. I did not receive it.
10 Q. Well, you said you didn't know why P6 -- why your commander at
11 the time wrote P6543, why that monograph was written, why it had those
12 deployments set out in it. What this document you're just looking at
13 shows you, Mr. Adamovic, is that the monograph or the supplement to the
14 monograph was written that way because it's true. This document confirms
15 exactly what was written in P6543, in terms of the deployment of your
16 battalion, doesn't it?
17 A. Your Honours, I stated that it was unclear to me why battalion
18 commander, who subsequently came to that post after Vukasevic, wrote
19 this. For this reason, at that time, the battalion could not have been
20 issued with a combat task. We had not been equipped, no ammunition, was
21 not trained for that. The battalion was rather deployed to control the
22 territory between Pudin Han and Krasulje, inclusive of both villages, and
23 this was where the battalion was deployed on the 29th or the 30th and it
24 did -- it would stay put, it would carry out control of territory
25 operations, and sometime around 20th of June, that battalion went to
1 Jajce as part of the Tactical Group 2 and carried out activities in the
2 territory of Mrkonjic Grad municipality. What I do know and what I do
3 state is that my battalion - I had left by that time - never committed
4 any evil acts in the areas where it held control. I can say before this
5 forum that the citizens of Krasulje, Ramici, cried when the battalion set
6 off towards Jajce because they thought who would guarantee them safety
7 after they are gone?
8 Q. This is -- we are getting off topic. Let's stick with this time
9 period. You talked in your answer about the 29th and 30th of May, and
10 said that your battalion was deployed to control the territory between
11 Pudin Han and Krasulje, and I'd like to have a look at 65 ter 25725,
12 please. And we'll look at what your battalion was doing on the
13 30th of May. This is a combat report from the command of the
14 1st Infantry Brigade Sipovo command to the 30th Infantry Division and
15 it's dated on 30 May 1992. So we need to go over to page 2 in both
16 languages, please, and I want to look at the second-to-last subparagraph
17 of bullet point 2. That says, in the Velagici, Kula, Pudin Han area, the
18 3rd Battalion is conducting mopping up of Green Berets who are
19 surrendering in droves. Some of the Green Berets have fled and are in
20 hiding. One of our soldiers was killed.
21 Mr. Adamovic, they weren't controlling the area. They were
22 clearing the area out of non-Serbs, and that's what this document shows.
23 What you're saying isn't true.
24 THE ACCUSED: [Interpretation] Objection.
25 JUDGE KWON: What objection, Mr. Karadzic?
1 THE ACCUSED: [Interpretation] It doesn't say non-Serb population,
2 it says Green Berets.
3 MS. EDGERTON: Fine.
4 Q. Clearing the area of Green Berets. What you said your battalion
5 was doing is completely untrue and that's what this document shows.
6 Isn't that the case?
7 A. This is not the case. I state that the battalion did not carry
8 out any mopping-up operations. I can bring you 300 witnesses to testify
9 to that. The battalion was transferred through that area and was tasked
10 with controlling the road in the area of Pudin Han, et cetera. But the
11 mopping up operations were carried out by other units but not mopping-up
12 operations. They were after a sabotage group that had carried out an
13 attack in the area of Busija and this was done by units of 1st and
14 2nd Krajina Corps, the 3rd Battalion did no such thing.
15 Q. So we've looked at three separate military reports from the
16 3rd Battalion. You're saying all of them are lies. Is that your
18 A. My evidence is that the battalion did not participate in these
19 combat activities. It participated in controlling the territory. That's
20 what I maintain.
21 Q. So your evidence, despite what this document says, your evidence
22 is that the battalion was not involved in mopping up; right? It was not
23 involved in mopping up the Green Berets?
24 A. That's right.
25 Q. Had nothing to do with clearing the area of non-Serbs, despite
1 what these three documents say?
2 A. No.
3 THE ACCUSED: [Interpretation] Objection again. Again non-Serb
5 MS. EDGERTON: With respect, Your Honours, I'm entitled to put
6 our case to the witness.
7 JUDGE KWON: Yes, yes, please carry on.
8 MS. EDGERTON: Thank you.
9 Q. So that would mean that your battalion was lying in their reports
10 to General Galic and General Talic; right?
11 A. I don't maintain that he was lying. You should ask perhaps the
12 author, the commander, why he wrote that. Maybe initially he did get
13 that task but I know that that task was not executed, and the battalion
14 did not mop up the terrain from Green Berets as it says there, in the
15 municipality of Kljuc. It simply wasn't involved in combat activities
16 one single day.
17 Q. But you weren't there, so on what basis can you possibly deny the
18 veracity and the accuracy of these reports? Your evidence is you weren't
20 A. Excuse me, which date is it, in the order?
21 Q. But you -- you've read it. You know that it's the 30th of May.
22 You've said you weren't there. You've said you weren't there at any of
23 these critical moments. You said that you were not in Prhovo on the
24 30th of May. You said you were not in Pudin Han on the 30th of May. So
25 on what basis are you saying that these documents, these military
1 reports, are untrue?
2 A. I didn't say that I wasn't there. I was part of the battalion on
3 the 30th of May. I didn't say I wasn't there. I was a member of the
4 battalion. But the battalion was active on the axis Pudin Han-Sanski
5 Most, et cetera. And the battalion was not involved in the
6 Pumici [phoen]-Plamenica-Prhovo axis or in the mopping up of the terrain,
7 and from that trial in Sarajevo, my trial, it was possible to make that
8 finding, I believe the Trial Chamber made that finding, and made the
9 judgement as it stands.
10 MS. EDGERTON: Could I tender this as a Prosecution exhibit,
11 please, Your Honour?
12 JUDGE KWON: Yes. We will receive it.
13 THE REGISTRAR: It's P6544, Your Honours.
14 MS. EDGERTON: Thank you.
15 Q. To move on to another area, Mr. Adamovic, you talked in
16 paragraph 11 of your statement about the killings at Velagici and you
17 said that 12 members of the unit responsible were arrested and
18 proceedings conducted against them. So when you say the unit
19 responsible, members of the unit responsible, you're referring to the VRS
20 soldiers who were responsible for the killing of these prisoners at
21 Velagici; right?
22 A. No. That's not right. In my statement, I said that units from
23 the territory of Kljuc, or the units of the VRS, were not responsible.
24 It was JNA units which were in that area and were moving from Croatia
25 that stayed in Laniste and were responsible. Twelve of their members
1 perpetrated what they perpetrated. The authorities of Kljuc immediately
2 arrested these men. The responsible judicial authority, and I don't know
3 who else, conducted an on-site investigation, the perpetrators were
4 arrested, judged and sent to serve their sentence in Banja Luka. And
5 that's why I said that the authorities had done their job, as best they
6 could. They made the arrests, but it was not VRS members or members of
7 the units from Kljuc.
8 Q. Well, clearly, Mr. Adamovic, when you said in your statement that
9 you didn't know any of the details, that was absolutely correct because
10 what happened was that those VRS soldiers responsible were arrested a
11 couple of days after the killing. They were released from custody. An
12 investigation -- they were still out of custody in March of 1993 when the
13 first request for investigation into the incident was launched. By
14 August -- pardon me, by July -- July 29th, 1993, more than a year after
15 that killing took place, only two of the 12 VRS soldiers responsible were
16 in custody and their detention was terminated after one month. And,
17 Mr. Adamovic, on 29 July, 1993, the military prosecutor's office of the
18 1st Krajina Corps command proposed to halt any proceedings against these
19 12 people and the Court followed that recommendation. The proceedings
20 never happened, they were judicially halted, there was no intention to
21 bring them to justice, and you've just told us a lie, Mr. Adamovic.
22 MS. EDGERTON: And, Your Honours, I refer to P3614, 6143 and 3616
23 with respect to the evidence I've just cited.
24 THE WITNESS: [Interpretation] Your Honours, if I may respond.
25 First of all, I don't agree with what Madam Prosecutor just said. In my
1 statement I only stated things that I know. I don't know about
2 everything that happened. And I shouldn't be told that I'm lying.
3 I only stated what I know, and I stated that in that sector, there was a
4 unit in transit that was responsible for these acts. I don't know about
5 everything that happened, but I know the authorities reacted and made
6 arrests and sent these people to the competent institution. An on-site
7 investigation was conducted, and I believe the authorities of Kljuc did
8 their job properly. As to what later happened with those soldiers,
9 whether they went to the 1st or the 2nd Corps or before a military court,
10 I don't know. I have no clue about these things. And I believe that I'm
11 not lying. I am telling only what I know and that's all I said in my
12 statement, nothing else.
13 MS. EDGERTON:
14 Q. To move on to another topic, you said in your statement that --
15 and it was in, I think, paragraph 6 -- that 3.000 Muslims stayed to live
16 with the Serbs in Kljuc in 1992 and 1993. But, in fact, more than
17 15.000 Muslims left, didn't they?
18 A. I think so, but the point of my statement was to say that three
19 and a half thousand Muslims who wanted to stay stayed, that there was no
20 expulsion, because I was asked what I knew about the expulsion of the
21 Muslim people. I know that our authorities did not persecute Muslims,
22 did not expel them. Those who were arrested, disarmed and who were
23 responsible for some offences, they were expelled; whereas, normal,
24 peaceful Muslim people who wanted to live there were able to go on living
25 there. And I also want to say that politics got involved. People were
1 being talked into leaving. I have lots of friends in many circles. I
2 have very good friends among the people who left. There was a lot of
3 political pressure. There was also much fear, chaos, panic. And lots of
4 people fled Kljuc, not only Muslims but also Serbs who feared joining the
5 army, who feared crisis, war, God knows what else. That's all I wanted
6 to say in my statement. That's the only point I wanted to make.
7 MS. EDGERTON: I think I have no further questions, Your Honours.
8 JUDGE KWON: Thank you, Ms. Edgerton.
9 Do you have any re-examination, Mr. Karadzic?
10 THE ACCUSED: Very few, Excellency.
11 Re-examination by Mr. Karadzic:
12 Q. [Interpretation] May I ask you, Mr. Adamovic, to explain to us
13 this last thing you said? Which people did you mean when you said that
14 politics got involved? Who from the politics?
15 A. I mean Muslims. The SDA and HVO exerted pressure on people to
16 move to other territories where Muslims were in the majority, and that
17 was the area of Bihac, Zenica, Tuzla, Travnik.
18 Q. Thank you. Now, could we please look at P02606, minutes of
19 Crisis Staff meetings. You said you were mentioned as the town
20 commander. Who else was mentioned as town commander?
21 A. Initially, it was Bosko Lukic, major; Major Dusan Petrovic;
22 Major Branko Ribic; and Marko Adamovic.
23 Q. What kind of educational attainment did the recording secretaries
24 on the Crisis Staff have?
25 MS. EDGERTON: Your Honour --
1 THE WITNESS: [No interpretation]
2 JUDGE KWON: Just a second.
3 Yes, Ms. Edgerton.
4 MS. EDGERTON: That has nothing to do with the cross-examination
6 JUDGE KWON: Correct.
7 THE ACCUSED: [Interpretation] Your Excellencies, we have to
8 establish whether they put the correct names on various speakers. Could
9 we see page 21 in B/C/S? I'll have to see the English page. No, sorry,
10 page -- one page before, 29 May.
11 MR. ROBINSON: While we are getting that, Mr. President, I don't
12 understand myself how when the Prosecution is relying on the accuracy of
13 the minutes of the Crisis Staff, how that question could not arise from
14 the cross-examination when the accuracy of those minutes can be
16 JUDGE KWON: Educational attainment? I don't see where it's
17 going, even if we have any evidence about it.
18 MR. ROBINSON: I think where it's going is calling into question
19 whether or not these minutes are accurate, but that seems to me to be
20 within the scope of the cross-examination which was what the objection
22 JUDGE KWON: I tend to -- very well, let's hear the evidence.
23 The witness answered the question but we didn't hear the translation.
24 Could you repeat your answer, Mr. Adamovic?
25 THE WITNESS: [Interpretation] Now it's not quite clear to me
1 which question should I answer? Could the question be repeated?
2 MR. KARADZIC: [Interpretation]
3 Q. I said who kept these minutes at the sessions of the
4 Crisis Staff? What kind of education did these people have? Were the
5 meetings recorded or were the notes taken by hand?
6 A. No. It was not recorded. There was no electricity, not even for
7 lighting to see properly what you're writing, let alone for recording.
8 It was some young clerks who took these notes. I don't know whether the
9 officials of the Crisis Staff took any notes themselves, because
10 I attended these Crisis Staff meetings only for five, ten minutes.
11 I would come, inform my commander about the situation in my unit, he
12 would then release me, and what they did after I left, I have no idea.
13 Q. Could you look at this session of 29 May, item 2? Could you read
14 item 2 out loud? Item 2.
15 A. That a defence command be set up and Major Bosko Lukic be
16 appointed as its commander. Until then he was Chief of Staff.
17 Q. Can you read the first sentence.
18 A. "The Crisis Staff is continually in session. It is monitoring
19 all developments in the territory of the municipality because combat
20 operations are underway and information from the ground is coming in."
21 Q. What does it mean, "is continually in session"?
22 A. That means that the Crisis Staff is constantly at the office with
23 all of its members, and, occasionally, when they find a spare moment,
24 they have lunch and some rest, but most of the time they are in their
25 offices and busy working.
1 Q. Do all the people who come to a particular meeting come on time
2 and stay until the end of the meeting, or are people coming and going all
3 the time?
4 A. I believe most of them stayed throughout the session, but
5 sometimes people had to leave early because among them there would be
6 doctors and businessmen and people in different types of industry whose
7 other engagements required their attention elsewhere.
8 Q. Now we need the next page, and leave the same page in English.
9 Could you look at item 4?
10 A. The chief of the public security station reported to the staff
11 negative events on the ground which reflect adversely on the entire
12 situation and are linked primarily to theft, breaking and entering,
13 et cetera.
14 Q. And could you look at the entry for 30th May? I believe it's
15 page 21. Yes. It's page 21 in B/C/S. Could you tell us, what is it at
16 the bottom, considering that there is information?
17 A. That their armed forces are in Plamenica village and have no
18 intention of surrendering --
19 Q. May I help? Force them by using force, the Crisis Staff needs to
20 make sure, to the extent possible, to avoid all arson, looting,
21 et cetera.
22 How does this fit in? Is it consistent with what you know about
23 the Crisis Staff?
24 A. I believe the Crisis Staff only tried to preserve security and to
25 create favourable conditions for a normal life for all the people who
1 lived there.
2 JUDGE KWON: I didn't see you, Ms. Edgerton.
3 MS. EDGERTON: Keeping in mind that the witness has already given
4 evidence that he was not a member of the Crisis Staff, and at temporary
5 transcript page 40, that he was only present at -- he was present at
6 meetings only the time it took him to do his duty and brief them, and
7 then he left.
8 JUDGE KWON: I don't see the point. What is your point,
9 Ms. Edgerton? So there is no point of asking this question to the
11 MS. EDGERTON: Exactly.
12 JUDGE KWON: Whether it was consistent with what he had known
13 about the Crisis Staff? I will allow the accused to continue his
15 MR. KARADZIC: [Interpretation]
16 Q. Do you consider that you have answered this question?
17 A. I have nothing to add.
18 Q. Do you know of any actions of the Crisis Staff contrary to
19 this -- what we see here?
20 A. Not while I was in Kljuc.
21 Q. Could we now look at page 31 in B/C/S. Can we now -- except for
22 the brigade commander, who is hiding behind these titles, commander of
23 the municipal staff, commander of the Kljuc defence command, et cetera?
24 Can we know what this recording secretary meant with any certainty?
25 A. We cannot know that. That's what I said before. When this
1 meeting was held, five names were on the list for this post, and party
2 people did not want me to be the town defence commander because I was not
3 a member of the SDS, I was a member of the SK movement for Yugoslavia.
4 However, the officer cadre got their way and they wanted me to be
5 accepted, and they said an order would come down to establish the town
6 defence and to appoint the commander. However, before that order came,
7 which was never written, by the way, it would be in the documents
8 otherwise - the order appointing the defence commander was never written,
9 instead, a unit, the 17th Light Infantry Brigade was established, and
10 beginning with 4th of June, I became assistant commander for moral
11 guidance, religious and legal affairs, and I stayed in that job until the
12 end of the war and continued serving until 2003.
13 Q. What does it say about Bosko Lukic?
14 A. Bosko Lukic informed the Crisis Staff of the possibility of
15 procuring certain technical equipment for the needs of a future light
16 brigade which would probably be formed in Kljuc.
17 Q. Is this what you have been talking about all this time?
18 A. Yes.
19 Q. Thank you. Earlier today, it was suggested to you that the
20 Serbian Municipality of Kljuc took over the Muslim municipality of Kljuc
21 and reinstated their territories and you said that it was carried out by
22 a military body. Were there any military reasons for the military to do
24 A. Yes. There were military reasons.
25 Q. Can you tell us more about that. What military reasons and
1 justifications were there?
2 A. The military justification was the fact that the
3 Territorial Defence of Velagici had carried out an attack on the military
4 convoy. They did what they did and the army reacted the way they did. I
5 don't think that there is any military in the world that will allow
6 others to kill the troops. And the military was the only body that
7 carried out the attack, and arrested armed men who belonged to the unit
8 and who carried automatic and semi-automatic rifles, mostly small arms in
9 any case.
10 Q. And now the last page. This was recorded on the
11 18th of June, 1992. It was another Crisis Staff meeting. It will
12 probably be on page 38. Let's call up that page and see.
13 JUDGE KWON: Page 20 of English?
14 THE ACCUSED: [Interpretation] It is possible. The date is
15 18 June.
16 MR. KARADZIC: [Interpretation]
17 Q. I don't have it in Serbian. I'm going to read the text to you.
18 It says here:
19 "Marko Adamovic read the order of the brigade commander which the
20 Crisis Staff accepted."
21 What was your capacity when you were there and read out the
23 A. I was the assistant commander for moral guidance and religious
24 and legal affairs. I was also assistant commander for information. My
25 brigade commander sent me there to read that order, whatever that was.
1 Q. And that was actually the only item on the agenda of that
2 session. There was nothing else; right?
3 A. I really can't remember, Mr. President.
4 Q. Thank you very much, Mr. Adamovic.
5 THE ACCUSED: [Interpretation] I have no further questions,
6 Your Excellencies.
7 THE WITNESS: [Interpretation] Thank you.
8 JUDGE KWON: Yes. It was e-court page 63 in B/C/S. Very well.
9 That concludes your evidence, Mr. Adamovic. On behalf of the Chamber,
10 I would like to thank you for your coming to The Hague to give it. Now
11 you are free to go.
12 MS. EDGERTON: And just with respect to P2606 --
13 JUDGE KWON: The witness can be excused.
14 MS. EDGERTON: Of course. What we'll do is -- pardon me.
15 JUDGE KWON: You may be excused have a nice, safe journey back
17 [The witness withdrew]
18 JUDGE KWON: Yes, Ms. Edgerton.
19 MS. EDGERTON: I'm very sorry. My apologies. I didn't mean to
20 interrupt. With respect to P2606, what we'll do is try and take the
21 pages out of the order in which they are presently uploaded and reload
22 them in a coherent order and advise my colleague, Madam Registrar, and
23 the Defence when that is done, in case we need to use it at any further
25 JUDGE KWON: At least we have the date correct so far.
1 Yes. Is the next witness ready, Mr. Robinson?
2 MR. ROBINSON: Yes, Mr. President. It's Mikan Davidovic.
3 [The witness entered court]
4 JUDGE KWON: Would the witness make the solemn declaration.
5 THE WITNESS: [Interpretation] I solemnly declare that I will
6 speak the truth, the whole truth and nothing but the truth.
7 WITNESS: MIKAN DAVIDOVIC
8 [Witness answered through interpreter]
9 JUDGE KWON: Thank you, Mr. Davidovic. Please be seated and make
10 yourself comfortable.
11 Yes. Before you commence your evidence, Mr. Davidovic, I must
12 draw your attention to a certain rule that we have here at the
13 International Tribunal, that is Rule 90(E). Under this rule, you may
14 object to answering any question from Mr. Karadzic, the Prosecutor or
15 even from the Judges if you believe that your answer might incriminate
16 you in a criminal offence. In this context, "incriminate" means saying
17 something that might amount to an admission of guilt for a criminal
18 offence or saying something that might provide evidence that you might
19 have committed a criminal offence. However, should you think that your
20 answer might incriminate you and, as a consequence, you refuse to answer
21 the question, I must let you know that the Tribunal has the power to
22 compel you to answer the question. But in that situation, the Tribunal
23 would ensure that your testimony, compelled in such -- under such
24 circumstances, would not be used in any case that might be laid against
25 you for any offence, save and except the offence of giving false
2 Do you understand that, Mr. Davidovic?
3 THE WITNESS: [Interpretation] I do, Your Honour.
4 JUDGE KWON: Thank you.
5 Yes, please proceed, Mr. Karadzic.
6 THE ACCUSED: [Interpretation] Thank you.
7 Examination by Mr. Karadzic:
8 Q. [Interpretation] Good afternoon, Mr. Davidovic.
9 A. Good afternoon, Mr. President.
10 Q. I kindly ask you to make a pause after my question so that your
11 words may be properly recorded. Did you provide a statement to my
12 Defence team?
13 A. Yes, I did.
14 Q. Thank you.
15 THE ACCUSED: [Interpretation] Could the witness please be shown
16 1D9593 in e-court.
17 MR. KARADZIC: [Interpretation]
18 Q. Do you see the statement before you?
19 A. Yes.
20 Q. Did you read the statement and did you sign it?
21 A. Yes, I did.
22 THE ACCUSED: [Interpretation] Could the witness please be shown
23 the last page so that he can identify his signature.
24 THE WITNESS: [Interpretation] Yes, this is my signature.
25 MR. KARADZIC: [Interpretation]
1 Q. Thank you. Does the statement accurately reflect what you said
2 to my Defence team?
3 A. Yes, it does.
4 Q. If I were to put the same questions to you today here in the
5 courtroom, would your answers be the same?
6 A. Yes, they would.
7 Q. Thank you.
8 THE ACCUSED: [Interpretation] I'm tendering this statement
9 pursuant to Rule 92 ter.
10 JUDGE KWON: I take it also the Defence is tendering one
11 associated exhibit?
12 MR. ROBINSON: That's correct, Mr. President.
13 JUDGE KWON: Good afternoon, Mr. Zec, do you have any objection?
14 MR. ZEC: Good afternoon, Your Honour, there is no objection.
15 JUDGE KWON: We will admit them both.
16 THE REGISTRAR: The statement receives Exhibit D4166 and the
17 associated exhibit, D4167, Your Honours.
18 JUDGE KWON: Please continue, Mr. Karadzic.
19 THE ACCUSED: [Interpretation] Thank you. And now I'm going to
20 read a short summary of Mr. Davidovic's statement in English.
21 [In English] Mikan Davidovic was born in Sanski Most municipality
22 where he lived and worked throughout the course of the conflict in
23 Bosnia and Herzegovina. At present, he works at the Ministry of
24 Administration and Local Self-Government in the government of
25 Republika Srpska in Banja Luka. Mikan Davidovic decided to join the SDS
1 towards the end of 1991. The SDS was established as the party of the
2 Serbian people in response to the establishment of the SDA and HDZ. The
3 SDS was a democratic party with a decentralised structure.
4 Mikan Davidovic was a member of the commission which organised the
5 plebiscite in Sanski Most municipality. The plebiscite ensured after --
6 ensued after the Serbian members of the parliament of Bosnia-Herzegovina
7 were outvoted on the issue of the independence of BH whereby the Serbs
8 thought that they should stay in Yugoslavia. Eventually, Muslims and
9 Croats declared independence without Serbs.
10 The SDS never adopted any policy of persecution, forcible
11 deportation and ethnic cleansing. The population was relocated but that
12 was due to fear of the conflicts that had broken out and the
13 deterioration of the overall security situation in economic and social
14 conditions. The SDS state bodies of Republika Srpska and Dr. Karadzic
15 did not spread, instigate or enable a propaganda campaign among
16 Bosnian Serbs with the intention of causing fear from and hatred against
17 the Bosnian Muslims and Croats.
18 In mid-June, 1992, Mr. Davidovic was appointed as the head of the
19 department for professional and common affairs of Sanski Most
20 municipality. During this period of time, he was not engaged in any of
21 the SDS organs. In 1993, Mr. Davidovic was hired as the head of the
22 centre for social welfare of Sanski Most municipality. The main
23 activities of the institution concerned the most vulnerable population
24 categories and, as part of these duties, the centre attempted to set up a
25 register of citizens in need so that humanitarian aid would be
1 distributed accordingly and in the fairest possible way. Among the
2 needy, there were members of all ethnicities and attempts were made to
3 ensure that all citizens irrespective of their ethnicity or religion had
4 at least a bare minimum of life's necessities. Once the conditions of
5 wide-ranging tensions and fear were created, non-Serbian population
6 started moving out of -- out from Sanski Most. Mr. Davidovic was a
7 member of the municipal commission for an unhindered departure which was
8 set up to control the departure process, provide assistance and make sure
9 that non-Serbs moved out from Sanski Most without any hindrance.
10 The assistance requested by the citizens who wished to leave the
11 municipality consisted of arranging contacts with competent institutions
12 which made appropriate transportation arrangements, collecting the data
13 from representatives of local communes and citizens from other
14 ethnicities about the number of persons who expressed a wish to leave,
15 announcing their departure to competent organs. Nobody had ever forced
16 non-Serbs to move out. At first, people mostly moved within Bosnia and
17 Herzegovina and then the number of requests to move abroad increased.
18 That is why, at the end of 1993, a new commission was established and
19 Mr. Davidovic became one of its members. The commission acted upon
20 requests of those citizens who needed assistance with getting hold of
21 their visas and helped them with group applications for approvals of
22 their unhindered departure. The process was initiated and implemented by
23 the representatives of non-Serbs. They performed all mediation tasks in
24 relation to the take-over of the visas and established the place and time
25 of entry into Croatia.
1 And that is a short summary. At that moment, I do not have
2 questions for Mr. Davidovic.
3 JUDGE KWON: For the record, I would like to note that while
4 paragraph 22 of this witness refers to adjudicated facts -- fact 2524,
5 this adjudicated fact 2524 actually was not admitted in this case.
6 Well, Mr. Davidovic, as you have noted, your evidence-in-chief in
7 this case has been admitted in writing, that is through your written
8 statement, and now you will be cross-examined by the representative of
9 the Office of the Prosecutor. Do you understand that?
10 THE WITNESS: [No interpretation]
11 JUDGE KWON: Yes, Mr. Zec.
12 MR. ZEC: Thank you, Mr. President.
13 Cross-examination by Mr. Zec:
14 Q. And good afternoon, Mr. Davidovic.
15 A. Good afternoon.
16 Q. You told us in your statement about your role in the SDS and the
17 municipal authorities in Sanski Most. Apart from this, Mr. Davidovic,
18 you were also secretary of the Sanski Most municipal board and you
19 attended sessions of the Serb Municipal Assembly and Executive Board;
21 A. Sometimes, not all the time. I was not always present. Yes,
22 I discharged the duties as the secretary, but I did not attend all the
24 Q. After the conflict broke out, you were assigned to the SJB police
25 force; right?
1 A. No. I was never in the police, no.
2 MR. ZEC: Can we have 65 ter 25635.
3 Q. And this, you will see, Mr. Davidovic, is an overview of
4 assignments in the SJB Sanski Most for June 1992. And if we can have
5 second page --
6 A. Yes, but this is not me. This is another Mikan Davidovic, also
7 from my village. I know the man, but that's not me, no.
8 Q. So if you look item number 34, it says Davidovic, Mikan, and this
9 is not your signature?
10 A. No, no. I know the guy. I'm sure that he's from my village. He
11 is two years older than me, and he was indeed a member of the SJB or the
12 MUP but not me.
13 Q. Fair enough.
14 MR. ZEC: Can we have 65 ter 17305.
15 Q. And this is a proposal for appointment sent to Mr. Karadzic in
16 November 1996 -- 1994, excuse me. And on this page, can you see your
18 A. Yes. This is me. This is a proposal for my appointment.
19 Q. And here we see that you were proposed to the position of the
20 chief of the SJB Sanski Most, at second page in both languages.
21 A. Yes, yes, yes, that was indeed a proposal, yes.
22 Q. Can we turn one more page in both languages? We need second page
23 of the actual document which would be e-court 3. And here it says that
24 you were proposed to this position by the SDS municipal board and the
25 municipal Executive Board. This proposal was sent by Nedeljko Rasula and
1 Mr. Rasula had been president of the Crisis Staff in 1992, and he
2 remained to be a leading figure in Sanski Most in 1994; right?
3 A. Yes, but he was also the president of the Municipal Assembly.
4 When he sent this, he was the legally elected president of the
5 municipality of Sanski Most. He was actually duty-bound. It was part of
6 his duties to send this out to the competent institutions.
7 MR. ZEC: I will tender this document, Mr. President.
8 JUDGE KWON: Yes, we will receive it.
9 THE REGISTRAR: It receives Exhibit P6545, Your Honours.
10 MR. ZEC:
11 Q. Let's focus now to the work of the commission for relocation of
12 population. You say in paragraph 20 that the first head of this
13 commission was Bosko Banjac, but you did not provide any date.
14 Bosko Banjac was assigned to this position in June 1992; right?
15 A. I can't remember the dates. It was a long time ago. I believe
16 that it was in late 1992. The date may be correct, but I really can't
17 remember it. I know for a fact that that was during the period when
18 I arrived in Sanski Most and started working there. That was sometime in
19 the second half of 1992.
20 MR. ZEC: Can we have a look at P02732.
21 Q. And these are conclusions of the Crisis Staff from June 1992. At
22 page 2, under item number 4, it says that Bosko Banjac is ordered to form
23 a commission for population migration, consisting of five members. So
24 you were a member of this commission headed by Banjac as of this date or
25 shortly after; right?
1 A. No, not from this date but from a date much later. I can't
2 remember the date. But the Executive Council set up the commission and
3 I became its member, and that's a fact.
4 Q. So you don't remember the date?
5 A. No, I can't remember the date. It was a long time ago. It was
6 20 years ago.
7 MR. ZEC: Can we look at 65 ter 25636?
8 Q. And while this is coming up, are you saying that you were not in
9 Sanski Most at this time or that you did not work in the municipality?
10 A. No, no, no. I was in the territory of Sanski Most but not in its
11 urban part but in a village called Bosanski Milanovac which was some 15
12 to 20 kilometres away from the centre of the municipality. So I did not
13 work in the municipality at the time. First, I was an intern and then
14 I wasn't working anywhere. I was not employed either in Sanski Most
15 proper or in the broader region of Sanski Most.
16 Q. And here you're looking at conclusions of the Crisis Staff from
17 16 June 1992. So can you read for us item number 6? What is the title?
18 A. A commission is set up for the population. It is composed of --
19 what does it say here? Dusko Radic, Mirko Stanic, Sofija Praca-Veljovic,
20 Mikan Davidovic, Borislav Stojicic. I never received this. Something
21 has been crossed in this document. This commission never took off the
22 ground. It never started operating. I don't know what these people did
24 JUDGE KWON: Do we not have English translation?
25 MR. ROBINSON: It looks like it's in e-court but not released, I
1 think. I can see the entry for translation but when I open it, it
2 doesn't show any document.
3 MR. ZEC:
4 Q. So, Mr. Davidovic, I'm not sure -- you saying you were not
5 working for municipality and then here Crisis Staff is basically ordering
6 you to be a member of this commission for population. So you were in the
7 Crisis Staff?
8 A. I don't know about the others. For instance,
9 Sofija Praca-Veljovic, she was a professor working at the secondary
10 school; Stanic Mirko, I don't know.
11 Q. I'm not asking about others. I'm asking about you. You were in
12 Crisis Staff. You were ordered --
13 A. The Crisis Staff could order but I did not perform any functions.
14 They did not inform me. I wasn't in the area. I wasn't available. Of
15 course, the Crisis Staff could have placed me on any lists in any
16 commission, and could have given me my purview and I would have worked.
17 Q. Mr. Davidovic, it's not clear how Crisis Staff can order someone
18 to do something that is not around. You were there. They appointed you
19 to the commission.
20 A. I can say with certainty that this commission did not carry out
21 any activities and never took off the ground.
22 Q. The witness in another case, in Brdjanin case, Besim Islamcevic,
23 testified that in the period June or July 1992, you and Vlado Vrkes came
24 to Podbrezje to explain people what categories of people can apply for
25 papers necessary to leave Sanski Most. And he said again he met you in
1 September 1992. These are transcript pages in Brdjanin case 7431, 7432,
2 7474. So witnesses saw you coming, talking to people about these issues,
3 issues of immigration; right?
4 A. That's correct. At that time, I would come to the municipality,
5 I met with SDS and the assembly of the municipality, and Vlado asked me
6 to go to Podbrezje. I believe Islamcevic used to work in the football
7 club. He was a coach there and I know him from that time.
8 Q. And he said you were in charge of immigration, it's not that you
9 just happened to be there and going there with Vrkes but you were doing
10 this sort of work.
11 A. That was later. Yes, I did later on. After the
12 Executive Council appointed that commission, this is what I did, and this
13 is what I stated in my statement. This was towards the end of 1993.
14 Q. And to be clear, Besim Islamcevic was talking about late June and
15 after that, so it's not like sometimes later on, it's June 1992, you were
16 dealing with resettlement of population called immigration.
17 A. I think that this was the period July, maybe even August.
18 Q. Let's move on. You say that Muslims and Croats left Sanski Most
19 on their own desire. In fact, there were efforts throughout the Krajina
20 region to force Muslims and Croats to leave; right?
21 A. I cannot confirm your statement because I was not familiar with
22 that. I do not have such information that you may have in your
24 MR. ZEC: Mr. President, just before I move on, I would like to
25 tender this document and we will provide -- and we will provide
1 translation shortly.
2 JUDGE KWON: Yes, we will admit it.
3 THE REGISTRAR: It receives Exhibit P6546, Your Honours.
4 MR. ZEC:
5 Q. Mr. Davidovic, this Chamber has received evidence that the
6 1st Krajina Corps explicitly acknowledged that an attempt to expel
7 Muslims and Croats failed because of the transportation difficulties and
8 their resistance to leave their homes, P03664. So this was something
9 that was taking place in Sanski Most among other municipalities; right?
10 A. I don't have that kind of information.
11 Q. These efforts in Sanski Most and elsewhere took the form of
12 targeting Muslims and Croats, attacking and destroying their towns,
13 places of residence and detaining many of them; right?
14 A. That fell within the purview of other organs. I was not
15 competent for that and neither did I verify such information.
16 MR. ZEC: Can we have a look at P03662.
17 Q. This is a combat report of the 1st Krajina Corps from May -- May
18 1992. We need page 2. At page 2, item number 3, it says that in areas
19 of Prijedor, Kljuc and Sanski Most, mopping up continues. The resistance
20 of Croat and Muslim formations is weak --
21 A. There is no Serbian version.
22 Q. So e-court page 3 in B/C/S, so it's page 2 of the actual
23 document. So if you look at -- I was talking about item number 3. The
24 resistance of Croat and Muslim formations is weak and their mass
25 surrender is underway. A little bit below in item number 5(b), it says
1 that after actions in Kozarac, Kljuc and Sanski Most, some conscripts of
2 Muslim nationality have asked to be released from the units, and the
3 reasons they say was the massive destruction of their towns. So these
4 were the reasons, Mr. Davidovic, massive destruction,
5 people [overlapping speakers]...
6 A. That's possible but this is not known to me. It's possible but
7 those facts were not known to me. What I did hear I heard it from people
8 going there, that the problems were fear, so fear of combat activities,
9 fear in terms of assistance, welfare assistance, et cetera.
10 Q. You're repeating your statement. There is no need to do that.
11 Your statement is already in evidence.
12 A. Okay.
13 Q. Just focus on the question and answer as short as you can.
14 In the same paragraph here, it says that the situation was made
15 worse by public statements made by the ARK SDS leaders who advocate
16 moving and expelling all Muslims and Croats from these areas. So this --
17 these statements, Mr. Davidovic, caused the fear among non-Serb
18 population and they wanted to leave; right?
19 A. That wasn't known to me.
20 Q. At the same time, there were public announcements made over the
21 radio to non-Serbs to surrender, otherwise they will be attacked and
22 their homes and families devastated and destroyed; right?
23 A. At that time, I did not listen to radio. There were statements,
24 there were information about the security situation, and the competent
25 organs would issue them. But I do tell you really that I don't know much
1 about that. I could not tell you with any degree of certainty what was
2 broadcast on the radio at that time.
3 Q. I'm going to play to you what was broadcast on the radio in
4 Sanski Most over and over time.
5 MR. ZEC: And can we have P00725. In the portion that I'm going
6 to play is at -- on the transcript it's at page 7 of the English and
7 page 11 and 12 of the B/C/S and it's a Sanski Most radio broadcast of
8 27 May 1992, and I'm going to play that -- a portion of it in court now
9 and this portion is time code 15 minutes, 13 seconds, to 16 minutes
10 21 seconds of the tape.
11 [Audio-clip played]
12 JUDGE KWON: Just a second, shall we stop. Two questions:
13 Whether it's audible to the witness; second question, would you like
14 to -- would you like the interpreters to interpret? We haven't heard any
15 translation. First, Mr. Davidovic, can you hear that?
16 THE WITNESS: [Interpretation] Very poor sound, but there is
17 some -- some portions are intelligible.
18 MR. ZEC: Mr. President, we have provided transcripts to the
20 JUDGE KWON: Given the time, shall we continue tomorrow?
21 MR. ZEC: That's fine.
22 JUDGE KWON: Before we adjourn today I would like to issue one
23 ruling. It's about the accused's request filed today in which he
24 requested counsel for Vladimir Domazet be present during the proofing and
25 testimony of Vidoje Blagojevic, the Chamber notes that the Prosecution
1 indicated via e-mail that it did not wish to respond to the request. The
2 Chamber takes no issue with Domazet's presence in the courtroom during
3 Blagojevic's testimony. The request is therefore granted. The Chamber
4 takes no position with regard to Domazet's presence during proofing.
5 Mr. Davidovic, we will adjourn for today and continue tomorrow
6 morning at 9.00. I'd like to advise you not discuss with anybody else
7 about your testimony. The hearing is adjourned.
8 --- Whereupon the hearing adjourned at 2.44 p.m.,
9 to be reconvened on Thursday, the 5th day of
10 December, 2013, at 9.00 a.m.