1 Wednesday, 29 October 2008
2 [Open session]
3 [The accused entered court]
4 [The witness entered court]
5 --- Upon commencing at 2.21 p.m.
6 JUDGE AGIUS: Good afternoon, Madam Registrar. Could you kindly
7 call the case, please.
8 THE REGISTRAR: Good morning, Your Honours. This is the case
9 number IT-05-88-T, The Prosecutor versus Vujadin Popovic, et al.
10 JUDGE AGIUS: I thank you so much, ma'am, and good afternoon,
11 everybody. All the accused are here. Prosecution is in full force
12 today: Mr. McCloskey, Mr. Thayer, Mr. Mitchell.
13 Amongst the Defence teams, I notice the absence of Ms. Nikolic
14 and Mr. Haynes.
15 Good afternoon to you, Mr. Simic.
16 THE WITNESS: [Interpretation] Good afternoon.
17 JUDGE AGIUS: Welcome back. I hope you've had time to relax. We
18 are going to continue and hopefully finish with your testimony.
19 Mr. Lazarevic.
20 MR. LAZAREVIC: Good afternoon, Your Honours. Good afternoon,
22 WITNESS: SLAVISA SIMIC [Resumed]
23 [Witness answered through interpretation]
24 Examination by Mr. Lazarevic: [Continued]
25 Q. [Interpretation] Good day, Mr. Simic.
1 A. Good day.
2 Q. We'll now continue with your examination. And if you remember,
3 yesterday we were talking about the 14th of July, 1995. That's the last
4 subject we were talking about, and to refresh our memories --
5 MR. LAZAREVIC: [Interpretation] -- could we see 4D620 in the
6 e-court system, again. Page 28, please. And naturally, we can see the
7 entry here for the 14th of July. Could we perhaps zoom in a little bit,
8 and could we scroll down a bit. That's fine.
9 Q. Can you now see the entry for the 14th of July? It says on the
10 13th, you went there -- from the 18th to 24, and that continues on the
11 14th from 00 to 06; is that correct?
12 A. Yes. That's the information that -- could I have the date?
13 MR. LAZAREVIC: [Interpretation] Could we scroll down a bit -- the
14 other page. I apologise.
15 Q. So I think we can now see from 00 to 06. It's quite clear here
16 now. Can you tell me, on the 14th of July, in the morning -- well, how
17 long did you stay in the police station?
18 A. Well, look. Upon finishing my shift in the early morning hours
19 on the 14th, I returned home to have a rest.
20 Q. Very well. So you had a rest at home. Do you remember an event
21 that you witnessed on the 14th of July?
22 A. On that day, having had a rest at home I was present at the
23 funeral of our colleague who had died. His name was Zeljko Ninkovic.
24 According to our customs, a funeral is held at about 13 or 1400 hours, so
25 I was at the funeral.
1 Q. Very well. Apart from yourself, can you tell me whether there
2 were any other members of the Bratunac police station who attended Zeljko
3 Ninkovic's funeral?
4 A. Yes. As far as I can remember, a certain number of members of
5 the Bratunac police station from the 1st company were present because
6 they fired in honour of the deceased colleague; they fired shots.
7 Q. Very well. Apart from them, were there any other members of the
8 Bratunac police station who were perhaps there?
9 A. Certainly. To the extent that they had the time to attend, there
10 were such other members.
11 Q. Tell me, after the funeral, where did you go?
12 A. Well, look. After the funeral of the deceased, as a rule in our
13 country you go to the family's home to express your condolences for the
14 deceased. So after that funeral, I spent some time in his home, and then
15 I returned to my home, put my uniform on, and returned to work, and I
16 spent that day at work too.
17 Q. Very well. I would like to ask you something about certain
18 events. You have already told us about your movements on the 14th. Can
19 you tell me whether on that day you had the opportunity to perhaps see
20 some senior MUP officials in Bratunac?
21 A. I personally didn't see any such officials, but I heard that on
22 that day there was a high-ranking MUP official who was present, Tomo
23 Kovac. I didn't see him myself, I heard about his presence from my
24 colleagues. And later on when I arrived at work, they told me that he
25 had visited the Bratunac police station and that he was on the his way to
1 Srebrenica. But I personally did not see him.
2 Q. Very well. Tell me, now, did you at any point in time hear
3 anything about an incident that took place in the agricultural
4 cooperative in Kravica?
5 A. I heard about an incident in that agricultural cooperative or
6 association in Kravica, so-called Oka. According to the information I
7 received, according to what I was told, some Muslims had been detained in
8 that building. They had surrendered at the time, and there were quite a
9 lot of them. At one point in time, some of them attempted to escape from
10 the building, and they managed to take the rifle from a policeman. I
11 heard that that policeman died, but I don't know which police station he
12 was from. That's all that I heard about the event that you are
13 interested in.
14 Q. Can you tell me who you heard this from? If you can remember,
15 naturally. Was this something that was discussed in Bratunac?
16 A. Well, yes. There were rumours, stories that circulated among the
17 population, among the citizens at the time; and on the 14th, I heard
18 about this when I attended the funeral. They discussed the death of our
19 colleague and this event in Oka
21 Q. And tell me, is this all the information you have about the
23 A. Yes. I have no other information about the event.
24 Q. Tell me, on that day - we've been speaking about the 14th - on
25 that day, did you have the opportunity of seeing Mr. Borovcanin?
1 A. Not on the 14th. Not on the 14th. That's certain.
2 Q. And on the following days, on the 14th -- on the 15th, 16th, and
3 17th, did you see him on those days, perhaps?
4 A. No. No, I didn't.
5 Q. And tell me, during that period, during those days, as far as
6 your work in the police station is concerned, is there anything in
7 particular that you can remember in the police station?
8 A. Well, look. Every day we had our duties. As far as I was
9 concerned, I went to work. I performed my duties. I was still working
10 for my service. After the fall of Srebrenica, quite a few troops had
11 retreated from the lines, returned home. There was no more tension at
12 the lines, so days passed by, you know, fairly regular men [as
13 interpreted]. I don't know what else I could add.
14 Q. Very well. Can you now tell me, can you remember when you
15 established contact with members of Mr. Borovcanin's Defence team?
16 A. I think that was this year around July and September, I believe.
17 There were two occasions on which there was contact up until the time I
18 came to The Hague
19 Q. Very well. I would just like a minor correction to be introduced
20 for the sake of the transcript. It's on page 5, line 12. In English, it
21 says "fairly regular men," whereas it should say "fairly regular days."
22 JUDGE AGIUS: Thank you, Mr. Lazarevic.
23 MR. LAZAREVIC: [Interpretation]
24 Q. So you had those two brief meetings in July and September and
25 then again when you had the opportunity to see Mr. Borovcanin's Defence.
1 I'd just like this to be clear for the transcript.
2 A. As I have said, upon arriving in The Hague. I think that was on
3 Saturday afternoon and on Sunday, too. So that would be the time.
4 MR. LAZAREVIC: [Interpretation] Very well. Thank you, Mr. Simic.
5 I have no more questions for you.
6 THE WITNESS: [Interpretation] Thank you.
7 JUDGE AGIUS: Mr. Zivanovic.
8 MR. ZIVANOVIC: No question for the witness.
9 JUDGE AGIUS: Thank you. Mr. Ostojic.
10 MR. OSTOJIC: No questions, Mr. President.
11 JUDGE AGIUS: Thank you. Mr. Bourgon.
12 MR. BOURGON: No questions, Mr. President.
13 JUDGE AGIUS: Thank you, Mr. Bourgon. Madam Fauveau.
14 MS. FAUVEAU: [Interpretation] No further question, Your Honour.
15 JUDGE AGIUS: Thank you. Mr. Josse.
16 MR. JOSSE: Same, Your Honour.
17 JUDGE AGIUS: Thank you. Mr. Sarapa.
18 MR. SARAPA: [Interpretation] No questions.
19 JUDGE AGIUS: Thank you. Mr. McCloskey, how long do you expect
20 your cross-examination to last?
21 MR. McCLOSKEY: It's difficult to say. I hope no longer than an
23 JUDGE AGIUS: Okay. Go ahead.
24 MR. McCLOSKEY: Good afternoon, everyone.
25 Cross-examination by Mr. McCloskey:
1 Q. Good afternoon, Witness.
2 A. Good day.
3 Q. In one of the last questions, it was suggested in the question
4 that you first contacted the Defence counsel. Is that correct?
5 JUDGE AGIUS: Mr. Lazarevic.
6 MR. LAZAREVIC: I never suggested that. I mean, this is really
7 not that --
8 JUDGE AGIUS: Mr. McCloskey.
9 MR. McCLOSKEY: You can read the transcript, and that's why I
10 asked it the way I did.
11 MR. LAZAREVIC: Then I should, please.
12 MR. McCLOSKEY: He's been very good at correcting the transcript,
13 so I'm kind of shocked he missed it this time.
14 JUDGE AGIUS: Wait one moment because I heard a mobile phone
15 ringing. Whoever it is, please switch it off. Yes, Mr. -- "Can you now
16 tell me, can you remember when you established contacts with members of
17 the Borovcanin Defence team?" That's how it was put, anyway.
18 Let's not make a storm in a tea cup on it or an issue on it.
19 Mr. Simic, go ahead. Try to explain to us what happened. Were
20 you contacted by the Defence team for Mr. Borovcanin and you then met --
21 did you ask for a meeting with the Defence team? How was it?
22 THE WITNESS: [Interpretation] Mr. Borovcanin's Defence contacted
23 me. I didn't have the need to contact the Defence. They contacted me.
24 JUDGE AGIUS: All right. It's clear now. So let's move ahead.
25 MR. McCLOSKEY:
1 Q. And did they tell you how they got on to you, how they were able
2 to identify you as a person to contact?
3 A. Well, I don't know how they work, how they reached me, but I know
4 that these people contacted me. They probably had some reasons for which
5 they contacted me.
6 Q. That's my question. Do you know the reasons?
7 A. Well, I assume that the reasons can be found in the testimony I
8 have given so far.
9 Q. Sir, do you know why they contacted you? It's not in the
10 testimony, how they knew to contact you.
11 A. The question is not clear to me. I think I have answered that
13 MR. McCLOSKEY: This may be, Mr. President, longer than I
15 JUDGE AGIUS: When we asked, it was not meant to restrict you,
16 Mr. McCloskey. We'll decide what to do as you go along.
17 MR. McCLOSKEY:
18 Q. Sir, you have told us that you were the duty officer that day.
19 Can you tell us how it was that the Borovcanin team was able to find out
20 that you were a possible witness?
21 A. I don't know how they obtained the documents that have been
22 presented here, but these documents confirm the time-period during which
23 I acted as a duty police officer. I assume that that's why they called
24 me to testify here.
25 Q. Had you received any communication from Mr. Borovcanin, any
1 friends or family before they contacted you? It's perfectly normal that
2 someone -- that a colleague of his may have called up and said, Would be
3 willing to be a witness for your former boss? Did that happen, anything
4 like that, before the Defence contacted you?
5 A. No. Nothing of the kind happened. I didn't have any contact
6 with the friends or family of Mr. Borovcanin. I was only contacted by
7 Mr. Lazarevic.
8 Q. Did you follow Mr. Borovcanin's testimony in the state court in
9 the case against people for the Kravica murders?
10 JUDGE AGIUS: Did you say Borovcanin's testimony?
11 MR. McCLOSKEY: Yes.
12 JUDGE AGIUS: All right. Okay.
13 MR. McCLOSKEY:
14 Q. The very recent testimony.
15 A. No. I didn't have the opportunity to follow the proceedings.
16 Q. Well, did you know that there was a big trial going on in
19 A. The trial was held in Sarajevo
20 the media, but I personally did not follow the trial by watching
21 television or reading the papers, listening to the radio.
22 Q. Well, you must have spoken about it with your friends, fellow --
23 you had fellow MUP officers on trial in that case.
24 A. As I have said, I personally didn't follow the trial on
25 television. I could read about it in magazines, or I could read about
1 certain details that concerned the trial in magazines, but I never had
2 occasion to comment on the entire trial with anyone because during that
3 period of time when the trial was held in Sarajevo, I was too busy at
4 work. Given the fact that I no longer live in the area of Bratunac - I
5 have to travel to work - and given the fact that I have family
6 obligations, I don't have enough time to follow the media coverage of the
7 trial, and that concerns the trial in The Hague and the trial in
9 Q. You've been a police officer for many years now. Have you ever
10 testified in any court aside from this one?
11 A. No. I've never testified.
12 Q. Okay. And before coming to testify and after you were contacted
13 by the Borovcanin Defence, did you make any effort to find any documents
14 or records that might help you make you remember or help you remember the
15 events of July 1995?
16 A. I did not find any documents, nor do I possess any documents with
17 regard to this. I've told you what I remember, and these were the events
18 that I witnessed; I was present.
19 Q. And did you look for any documents that might help you?
20 A. No. I did not think that they would be necessary at all.
21 Q. Well, certainly there was a duty officer notebook that you would
22 have and other duty officers would have taken notes at during the day
23 while you were on duty, wasn't there?
24 A. I apologise, sir. Which duty officer are you referring to in
25 your question?
1 Q. You.
2 A. I'm asking this because there is also a duty operations officer
3 at the centre level, and the duty police officer operates in the police
4 station in Bratunac. Duty service does involve recording certain events
5 but mostly reports filed by citizens about certain events. But I did not
6 think that it would be necessary for me to have any of these documents
7 available to me for this trial.
8 Q. So tell us about the duty officer notes that are kept at the
9 Bratunac SJB in July of 1995, complaints from -- you've said complaints
10 from civilians? I would think important calls from commanders, other
11 things that you needed to remember. All of us take notes when we pick up
12 the phone. This went into a book, I take it?
13 A. Yes. Complaints, either personal complaints or complaints over
14 the phone about certain problems or incidents; for example, if somebody
15 broke into somebody else's house or somebody got drunk and opened fire
16 from a firearm, somebody had a row with their wife. These were the kind
17 of incidents that we recorded because they mandated the police to act
18 upon them.
19 Q. So if people got -- if you got a report of shots at the Oka
20 warehouse, the police would be mandated to act on that?
21 A. Well, I never received such report. There is no way for me to
22 know what was happening in Kravica. It was only the following day at the
23 funeral that I learned about the event, and it was after my duty -- when
24 I got off work the following day, I learned about the events that had
25 taken place at Kravica.
1 Q. Well, you must have then, as soon as you learned about it, called
2 the duty officer and reported it to him, then, something of that
3 significance. We have a Serb getting killed, for instance.
4 A. No, I didn't call him when I learned that because I fully believe
5 that he had already been informed.
6 Q. And so this duty book would have had that information in it, had
7 the system been worked properly, receiving the complaint, noting it down,
8 and acting upon it?
9 A. I did not see any such thing as having been entered in the
11 Q. So you had a chance to review the logbook when you came back on
12 duty for the days that you weren't there or the days that other people
13 would have written stuff down?
14 A. This was the logbook that we used every day, but this was not
15 recorded. I did not read it. I don't know whether the person working
16 before me had had any information to that effect or not.
17 Q. What did you call this logbook?
18 A. A diary, the logbook of daily events of the duty police service.
19 Q. And can you tell us what it was made out of? Was it a
20 leather-bound book? How many pages? How many days would it normally
22 A. Well, it was a book of a record of a larger size, a hard cover.
23 I don't know what colour, and I can't even remember that the pages were
24 numbered. It was a somewhat thick notebook. There were various things
25 to be entered: What happened, who filed the complaint or report, show a
1 description of the event or the incident, and which policeman was tasked
2 to act upon the complaint, and that was all.
3 Q. Did you tell the Defence about this logbook when you spoke with
5 A. No.
6 Q. Did they ask you about any potential logbook or other diaries or
7 records that -- of that time period?
8 A. They didn't have to ask me because the records are kept at the
9 police stations, and the superior officers of the police stations are
10 responsible for them.
11 Q. So they never even asked you about any records or logbooks or
12 anything like that, any reports you might have made or somebody else
13 might have made on any of these events?
14 A. They didn't ask me about the logbook of events kept by the duty
15 police officer.
16 Q. Any other records? Did they ask you about any -- if there was
17 any records?
18 A. Well, the only ones are the lists of shifts that we have seen in
19 the courtroom. That's the only type of document that I know of that they
20 have asked me about.
21 Q. All right. Where should that logbook be, the diary be today for
22 July of 1995?
23 A. I really don't know where it should be. I know that SFOR members
24 subsequently seised certain documents. They searched the Bratunac police
25 station, and I really don't know where the 1995 logbook might have ended
1 up at.
2 Q. Okay, let's go to another area. You said you, I believe,
3 reported for duty March 1993, and you met your commander, Mr. Borovcanin,
4 that day in March sometime, March -- I don't remember the exact day you
5 told us, 4th, maybe.
6 A. Sir, I did not report for duty on the 4th of March, but on the
7 3rd of March, 1993, I met Mr. Borovcanin for the first time. He received
8 me and interviewed me with regard to my application and my joining the
9 active force of the police at the police station.
10 Q. Okay. Now, back in 1993, were Bratunac police officers made
11 available to be part of combat units in those days like we knew they were
12 in 1995? In 1995 we know they were called PJP units. Was there a
13 similar thing in 1993?
14 A. No.
15 Q. Did the police defend Bratunac in some way in 1993 along with the
17 A. At the time I was still a reservist, a reserve police officer,
18 and active members did have their tasks and duties, but I personally
19 never participated in combat. Most of the staff patrolled the city.
20 They maintained public law and order, and they were involved in regular
21 policing duties.
22 Q. You said you were a member of the Bratunac Brigade's Red Beret
24 A. Yes.
25 Q. You know Rade Petrovic?
1 A. Yes.
2 Q. You've known him all your life?
3 A. I've known him since July 1992. I did not know him before that.
4 Q. And what was his relation, if any, with the Red Beret unit of the
5 Bratunac Brigade?
6 A. What do you mean when you say "relation"? Can you rephrase,
7 please? Can you put your question in some other way?
8 Q. Was he ever a member? Was he a commander?
9 A. While our commander was still alive, he was a member, a foot
10 soldier, just like me.
11 Q. In the Red Berets?
12 A. Yes.
13 Q. And later he became the commander of that unit, correct?
14 A. I don't know what his duty was later, but I've already told you
15 that I left that unit and I joined the reserve force of the police
17 Q. Sir, are you telling us today that despite your service
18 throughout the war in Bratunac, you do not know Rade Petrovic's position
19 in the Red Berets?
20 A. What I'm saying is this: While the commander of the Red Berets
21 was still alive, Rade Petrovic was a foot soldier just like me, and I
22 really don't know what his subsequent duties in the unit were. I've not
23 seen Rade Petrovic for four or five years.
24 Q. Do you know a person named Miroslav Stanojevic?
25 A. I believe I do.
1 Q. Do you or don't you?
2 A. I know that his nickname is Krle. I know that he was killed in a
3 car accident or a traffic accident, but I can't remember what year. It
4 happened somewhere in or around Bratunac, if we are talking about the
5 same person. If we are, then I know him better as -- by his nickname,
7 Q. Well, you knew that he was a member of the Red Berets, too,
8 didn't you?
9 A. Well, I was a member of that unit. He wasn't. He was not a
11 Q. Well, that wasn't my question, sir. My question was, did you
12 know that he was a member of the Red Berets, let's say, to make it more
13 specific, in 1995?
14 A. I can't say anything. I don't know. While I was in the unit, I
15 really don't know that he was a member also. I don't think so.
16 Q. Surely, sir, you know that he was wounded at the Kravica
17 warehouse at 13 July, the incident you have testified about. Surely
18 that's a part of the story that you know, correct?
19 A. I didn't even know that he was wounded. I never heard about
21 Q. So were you on duty the night of 13 July until the early morning
22 hours of 14 July? Is that what we just saw up on the screen?
23 A. 13, 14, the night between the two.
24 Q. Yes. Was that you on duty, I think, from around midnight to 6.00
25 a.m.? I just want to make sure I got that right. There's no trick here.
1 A. In the early morning hours, from midnight to 6.00 in the morning
2 on the 14th, yes. You're asking me that?
3 Q. Okay. So you were a duty officer at the Bratunac police station
4 in the centre of Bratunac, then, correct?
5 A. Yes.
6 Q. Tell us what you learned was going on in the town of Bratunac
7 that night during that 6-hour time-frame that you were there.
8 A. I learned about the death of our colleague, another policeman,
9 who had been killed in the early morning hours, sometime in the morning.
10 I don't know what else to tell you.
11 Q. That's it? That's all you know?
12 A. At that moment, yes.
13 Q. You didn't have any information about any Muslims around town?
14 A. I had information that they were on buses around the school and
15 on the road leading up to the playground, but that's what I heard. I
16 only heard that.
17 Q. So would you call it rumours or reports to the duty officer?
18 A. Public stories. There were no official reports about that.
19 Q. So as you sit here today, you don't even know if that's true?
20 A. I heard about that based on stories, and I also heard that the
21 Muslims in question were guarded by MPs, by members of the military
22 police. I did not hear anything else, and I did not receive any concrete
23 reports about the same event.
24 Q. What else did you hear? We're getting a little bit more here.
25 A. That's all I heard. I don't believe there was something else.
1 The -- the colleague's death was enough to -- to shake me.
2 Q. You didn't hear about the 50 Muslims that were murdered that
3 night, huh? Maybe a hundred, maybe 200, maybe more.
4 A. I've already told you. I only heard that on the 14th at my
5 colleague's funeral. In the evening, when I was on duty as the duty
6 police officer, I did not have the information about the Muslims having
7 been killed.
8 Q. Surely you must have been aware of the sanitation going around
9 and scraping up all the dead bodies off the different floors of the Vuk
10 Karadzic school and around the school? This Court's heard testimony on
11 it. It's been established in numerous trials. Never heard anything
12 about all those dead Muslims picked up on the streets of Bratunac and the
13 school of Vuk Karadzic?
14 A. Sir, there were no killed Muslims on the streets of Bratunac or
15 had I heard. Whether there were any killings or not, I don't know.
16 Q. I think we can leave that subject, but just to clarify the
17 record, a close review of the duty officer sheet shows that you were on
18 duty from 12 hours, from 6.00 p.m.
20 Now, let me try to ask you some questions of something maybe you
21 know about because you've testified about it. You've testified you knew
22 where -- about the -- where the 2nd company PJP went on the 12th of July,
23 right? You remember that testimony?
24 JUDGE AGIUS: Yes, Mr. Lazarevic.
25 MR. LAZAREVIC: Yes, just to assist my colleague. What I heard
1 that was translated to the witness was "June."
2 JUDGE AGIUS: All right. Thank you. But it's July.
3 THE WITNESS: [Interpretation] On the 12th of July, the 2nd
4 company set off to Srebrenica in order to establish a police station
5 there. So they left Bratunac and went to Srebrenica.
6 MR. McCLOSKEY:
7 Q. How do you know that they went to establish a police station
9 A. Well, on the 12th I was at work. So this information, according
10 to which they had set off there, was conveyed to me.
11 Q. By who?
12 A. I arrived in the department. I received information according to
13 which they had set off in order to establish a police station in
15 Q. By who?
16 A. It was probably from the other duty officer. The command of the
17 police station in Bratunac set off together with the 2nd company.
18 THE INTERPRETER: The witness is kindly asked to speak a little
19 more loudly.
20 MR. McCLOSKEY:
21 Q. Sir, they would like it if you could speak a little more louder.
22 The interpreters have having a heard time hearing you.
23 So it was the normal practice for duty officers to share
24 information about -- important information, for example, what units are
25 going where?
1 A. Well, in any event he informed me of the fact.
2 Q. Sir, you need to try to answer my questions. Did you understand
3 the question?
4 A. Sir, when I arrived to do my shift at 1800 hours, I received
5 information from the previous duty officer that the 2nd company had set
6 off to Srebrenica, so from the officer who did the shift before mine.
7 Q. Okay. But I'll try with the same question. Was that the normal
8 procedure whereby duty officers would share important information with
9 each other, such as where various units or officers were stationed or
10 other important details?
11 A. Well, in any event this information was exchanged, information
12 about what happened in the course of his duty. He conveyed this
13 information to me.
14 Q. Will you answer my questions about the normal practices and
15 process? It's a perfectly okay question. Was that the normal practice
16 and process for duty officers to exchange information?
17 JUDGE AGIUS: Mr. Lazarevic.
18 MR. LAZAREVIC: Maybe -- I believe that the answer of the witness
19 was misinterpreted.
20 It's here on page 20, lines 10 to 12. He -- what --
21 MR. McCLOSKEY: Can we get on with this?
22 JUDGE AGIUS: If he's alleging that it was misinterpreted to the
23 witness, we need to hear about it. Please continue, Mr. Lazarevic.
24 MR. LAZAREVIC: What is witness said is what he conveyed -- what
25 he conveyed to me -- what he conveyed to me what my duties would be.
1 That's what the witness said.
2 MR. McCLOSKEY: Yeah, we heard that.
3 MR. LAZAREVIC: But here it says: "He conveyed this information
4 to me." That's a bit different, I think.
5 MR. McCLOSKEY: Yeah.
6 JUDGE AGIUS: All right. Anyway, let's take it up from there and
7 continue, Mr. McCloskey, please. Thank you, Mr. Lazarevic.
8 MR. McCLOSKEY:
9 Q. Sir, I'm just asking you whether or not it was the normal process
10 for duty officers to exchange information, important information so the
11 new shift was aware of important information. Is that normal practice?
12 A. Well, naturally I would ask my colleague, the one on duty about
13 what had happened during his shift, if that's an answer.
14 Q. Well, I think it would be kind of natural to be curious, but what
15 I'm asking you about is was it a police procedure for the duty officers
16 to exchange information with each other to find out important details of
17 what had happened on the previous shift? Was this a practice or a policy
18 of some sort?
19 A. Well, as I have said, he informed me of the fact. That's usual
20 when you take over a shift. What he conveyed to me had to do with the
21 records, with whether the vehicles were there or not, details of that
23 Q. So it was a practice or a policy of the Bratunac police
24 department for the duty officers to exchange important information with
25 each other at the changeover?
1 A. Yes.
2 Q. And Mr. Vasic was present at the Bratunac police station during
3 the 11th, the 12th, the 13th when you were a duty officer, right?
4 A. He was present at that time during those days because at the time
5 the Crisis Staff had its headquarters in our police station.
6 Q. Right. And when you learned information such as the information
7 you just told us, that the 2nd company was sent to Srebrenica, did you
8 provide that information to Mr. Vasic or anybody else in the police
9 station for their reports or for police purposes?
10 A. I assume that they themselves were aware of the fact. I was only
11 an ordinary policemen at the time and nothing else. I didn't have the
12 duty to convey information of any kind to them because they were my
13 superiors. The chief of the centre and the others in the Crisis Staff, I
14 assume that they were aware of the fact that the 2nd company had set off
16 Q. So as the duty officer that day, no one would have ever asked you
17 about what was going on, what information you had received, what might be
18 in the duty book, what someone else might have reported to you? You're
19 just left alone? Nobody's talking to you or asking you information
20 within your command structure?
21 A. Do you have the members in the Crisis Staff in mind who were at
22 the police station?
23 Q. Anybody. Vasic or whoever was with him, Josipovic, whoever might
24 have been a sergeant if you had such a thing at the time, Mr. Borovcanin
25 if he happened to ask you a question? Wouldn't you be giving information
1 to all these people so they could help get their reports right? Wouldn't
2 the duty officer be part of that information process that was so critical
3 that would eventually have gone up to Zvornik and then from Zvornik gone
4 up higher and eventually to Pale? You're a pretty key man on the ground
5 as the duty officer, weren't you?
6 MR. LAZAREVIC: It's a very compound question. Maybe my
7 colleague could split it up.
8 JUDGE AGIUS: I don't think it will help you much if he splits it
9 up, Mr. Lazarevic. Let's proceed.
10 MR. McCLOSKEY:
11 Q. Can you just answer that, maybe yes or no. Were you a key man?
12 Let's just leave it at that. Wasn't the duty officer, an individual SJB
13 like Bratunac at the time, a key person in the communication network?
14 A. No. I was just a duty officer. I had my superiors.
15 Q. So you don't really know if the 2nd company went -- even went to
16 Srebrenica for real, do you?
17 A. I am telling you about information I had, information according
18 to which the 2nd company set off on the 12th of July. They went to
19 Srebrenica in order to establish a police station there. My commander,
20 from Bratunac, left with members of the 2nd company.
21 Q. Well, was it ever confirmed to you that they actually went there
22 and they just didn't stop in Potocari or do something else?
23 A. If something concrete had happened, they wouldn't have informed
24 me of the fact. They had their own superiors who ranked above them, were
25 superior to me.
1 Q. Did all the platoons of the 2nd company go to Srebrenica on the
3 A. I don't know about other platoons, but I know that members of the
4 2nd company who were from the Bratunac police station set off there.
5 Q. Well, you know Nenad Deronjic was a member of the 2nd company,
7 A. A policeman, yes.
8 Q. So do you know where Nenad Deronjic went on the 12th?
9 A. I assume that he set off with his colleagues.
10 Q. Well, let's look at 65 ter 3040, and since you seem to have some
11 specific information on him -- or excuse me, on this unit, maybe this
12 will help you. This is a report. Let me give you a hard copy so you can
13 see the whole thing at once. I'm sorry. The last part in this hard copy
14 is not easy to read. But this is a 12 July report to the Republika
15 Srpska Ministry of the Interior police headquarters in Bijeljina and the
16 officer of the minister in Pale. And it's in the name of the chief of
17 the CJB, which should be Mr. Vasic.
18 And mostly I just want to ask you about paragraph 5.
19 MR. McCLOSKEY: So if we could go to paragraph 5. If we could
20 get that up on the English, paragraph 5. It should be the first page --
21 yeah, if you could scroll up, and it's page 2 of the B/C/S. And it
22 actually goes over into page 6 as well. So -- I don't know if we can do
23 that, but -- I'll read paragraph 5 slowly just so there's no worry.
24 Q. "Acting upon the President Karadzic's order, which was conveyed
25 to us today over the phone, the 2nd Company of the Zvornik PJP shall be
1 dispatched to Srebrenica with a task to secure all facilities of vital
2 importance in the town at all cost and protect them from looting and
4 "It will carry out the task without cooperation of the military
5 police, which is busy with other tasks. A platoon of this company will
6 lie in ambush at Ravni Buljim, since the Muslims groups were spotted
7 fleeing along this axis."
8 So you were aware that a platoon of this 2nd company was sent
9 into the woods at Ravni Buljim, which is, as we know, just past Susnjari
10 and Jaglici up towards Konjevic Polje?
11 A. Well, first of all, I should say that this is the first time I've
12 seen this document, and let me just clarify something, Mr. Prosecutor.
13 PJP was organised in what was then the centre in Zvornik. As far as the
14 2nd company in particular is concerned, all the police stations that were
15 part of the Zvornik centre allocated a certain number of their members to
16 that platoon.
17 So if the entire -- as for the entire company going to this area,
18 I'm not aware of that. Only members, as I have said, of the police
19 station from Bratunac went there to establish the Srebrenica police
20 station on the 12th of July. I know about our men who were from the
21 police station and who went there, but I am not aware of anyone else.
22 Q. Sir, I ask you that because a Muslim man that survived an
23 execution at the banks of the Jadar river, who was taken there by an
24 execution squad the morning of 13 July, he has testified that Nenad
25 Deronjic was part of the execution squad, and that if Nenad Deronjic was
1 a member of the 2nd company, and that 2nd platoon of the 2nd company was
2 sent to the area of Ravni Buljim on the 12th, then if they had stayed
3 there they would have woke up in the morning near the area of Konjevic
4 Polje right where this Muslim said he was picked up and dealt with by
5 Nenad Deronjic.
6 So have you heard, sir, that your colleague, Nenad Deronjic, was
7 part of an execution squad that in the morning of the 13th of July took
8 about 15 or 16 Muslim men in a bus from Konjevic Polje, drove a little
9 ways up the road, went down to the bank of the Jadar river where they
10 were all shot? Have you heard that story? Have you heard that account?
11 A. I am not aware of that.
12 Q. If I could have one moment.
13 [Prosecution Counsel Confer]
14 MR. McCLOSKEY: Okay. Just the last couple of questions. I hope
15 I can finish before the break.
16 Q. Did you assist the international community with the exhumations
17 of Muslim dead in the last few years around Bratunac?
18 A. As far as exhumations are concerned, well, yes, I was present as
19 part of a team from the federation. It was the commission for locating
20 missing persons from Tuzla
21 they carried out in the past year of a Bratunac police station member.
22 At the time, I also worked as a forensic officer in the police station.
23 Q. And those mass graves, those contain Muslims, I take it, from
24 Srebrenica from July 1995?
25 A. I don't know whether all the bodies were from the area of
1 Srebrenica. We carried out the exhumation of the bodies that had been
2 buried in the ground there.
3 Q. Did you know about the huge mass grave at Glogova where people,
4 hundreds and hundreds of Muslim men were put after they were murdered at
5 the Kravica warehouse or the Oka
6 A. I had heard about the Glogova grave, but I wasn't present when
7 they carried out the exhumation there.
8 Q. When did you first hear of the Glogova grave?
9 A. I can't remember when exactly, but I didn't have any information
10 until the exhumation was carried out by this team from Tuzla.
11 Q. So you didn't know about the Glogova grave in 1995, 1996, 1997,
13 A. No, I personally didn't know about it.
14 Q. When did you first hear that your colleague Ninkovic was killed?
15 A. Zeljko Ninkovic was killed in the morning, on the 13th in the
16 morning, in the early morning hours. He was killed at the Sandici pass
17 as far as I can remember.
18 Q. And when you did you first hear about that?
19 A. I heard that he had been killed when I was performing my duties
20 in the department.
21 Q. What time?
22 A. Well, I don't know what time it was. On the 13th, I left in the
23 morning. I returned home, and I received information according to which
24 he had been killed. In the evening [as interpreted] hours, I was resting
25 at home preparing to go to the funeral.
1 MR. LAZAREVIC: It's a mistake in the transcript. I have to
2 correct it. The witness said "in the morning hours, I was resting at
3 home preparing to go to the funeral." This is what he said, I mean. We
4 heard it.
5 JUDGE AGIUS: Do you confirm that, Mr. Simic?
6 THE WITNESS: [Interpretation] In the morning hours on the 13th,
7 Zeljko Ninkovic was killed. As to the exact time, I really don't know.
8 JUDGE AGIUS: But what time were you resting at home preparing to
9 go to the funeral, and on which day?
10 THE WITNESS: [Interpretation] I left my night shift in the
11 morning on the 14th, and I went to have a rest because the funeral was on
12 the 14th.
13 THE INTERPRETER: The interpreters apologise for any mistake and
14 would kindly ask the witness to speak a little more loudly.
15 JUDGE AGIUS: Thank you. Mr. Simic -- are you finished,
16 Mr. McCloskey?
17 MR. McCLOSKEY: Yes. Thank you, Mr. President.
18 JUDGE AGIUS: All right. Is there re-examination?
19 MR. LAZAREVIC: There will be, Your Honour.
20 JUDGE AGIUS: All right. We'll have a break now of 25 minutes,
21 and then we'll have the redirect.
22 --- Recess taken at 3.45 p.m.
23 --- Upon resuming at 4.22 p.m.
24 JUDGE AGIUS: Yes. Sorry for the delay, but something urgent
25 came up which had to be attended to.
1 Mr. Lazarevic. Your redirect, please.
2 MR. LAZAREVIC: Thank you, Your Honour. I will try to reduce it
3 as much as possible.
4 Re-examination by Mr. Lazarevic:
5 Q. [Interpretation] Mr. Simic, I'll have a number of questions for
6 you about some of the things that you said in answering my learned
7 friend's questions. If you remember, Mr. McCloskey asked you about a
8 certain Miroslav Stanojevic and whether that person belonged to the Red
9 Berets, and he also asked you about Rade Petrovic.
10 Let us look at two documents that have something to do with the
11 questions put to you by Mr. McCloskey.
12 MR. LAZAREVIC: [Interpretation] The first one is 4D488.
13 Q. Do you see the document in front of you? It actually has two
14 pages. Let's first look at the first page. In the left corner, you see
15 that it reads "command of the 1st Bratunac Light Infantry Brigade," and
16 the date is 8th August, 1995
17 Further on in the document, you can read category of persons,
18 registered number, but I would like us to look at the line where it says
19 name, father's name, last name. It says Miroslav, Andjelko Stojanovic
20 here. The address is indicated as being Pobrdje, and also you will see
21 where it says the first time mobilised to unit, next to it the 1st
22 Bratunac Light Infantry Brigade. Can you now move to the following page
23 of the same document, please.
24 This is actually a -- a report of death, wounding, capture or
25 disappearance. We can see that the word "wounding" is underlined. Am I
2 A. Yes, you are.
3 Q. The date that you can see in the frame is 13/07/95 and the rest
4 of the figures. Would that stand for the 13th of July, 1995?
5 A. Yes.
6 Q. The indication of the place is Kravica, is it not?
7 A. Yes.
8 Q. And where it says description of wound event, it says "gunshot
9 wound to the right elbow, wounded while taking captured Muslims into
10 custody. The aforementioned person was wounded."
11 A. Yes, you're right.
12 MR. LAZAREVIC: [Interpretation] Let's look at the following
13 document which is 4D558.
14 Q. The document is headed by the will following words: "Command of
15 the 1st Bratunac Light Infantry Brigade." The date is 14th of May, 1994.
16 The title of the document is "List of the rapid reaction company
17 delivered to," and here you can see that it says Sreten Petrovic, company
18 commander, and below that the 1st rifle platoon, Neskovic, Neljko, Bosko,
19 platoon commander. Am I reading everything correctly?
20 A. Yes, you are.
21 MR. LAZAREVIC: [Interpretation] And now let's look at 35 on the
22 list. These are all members of the 1st rifle platoon.
23 Q. Under 35, you will see the name Stanojevic, Andeljko, Miroslav,
24 fighter, combatant. Would that be the same person judging by the first
25 name, the last name, and the father's name, as the person that was named
1 in the previous document?
2 A. Yes, this seems to transpire from this document.
3 Q. This is a document from 1994, and the previous one was from 1995.
4 Does it arise from this that Stanojevic was a member of the Berets in
5 1994 as well as in 1995?
6 A. Yes, he was.
7 Q. Thank you. I will no longer need this document. My learned
8 friend Mr. McCloskey also asked you about certain exhumations that you
9 attended, and you said that this had been part of the cooperation with
10 the commission for the search for missing persons from Tuzla
12 A. Yes.
13 Q. And when these exhumations were carried out, did anybody from
14 that tell you, you personally, what the ethnicity of the bodies was or --
15 did they tell you anything about bodies, which side they belonged to or
16 any such thing?
17 A. Nobody from the commission ever told me that those bodies
18 belonged to the people that had been killed in Srebrenica or hailed from
19 Srebrenica. They assumed that they hailed from Srebrenica, and they also
20 assumed that they were Muslims. In any case, it was not their duty to
21 tell me anything about what they knew about the bodies.
22 Q. In answering my learned friend McCloskey's questions, you said
23 that the duty officers were supposed to take complaints, that people
24 could call in, phone in, or come to the police station in person. Do you
25 remember whether at that time, and we are talking about the time before
1 the fall of Srebrenica, a few days before that and a few days after that,
2 were the telephone lines in Bratunac operating? Were they up?
3 A. As far as I can remember, there was a time when they were down.
4 Even my private telephone line was switched home -- switched off at home.
5 Q. And what about the public security station in Bratunac? Was
6 there a telephone that was still operational or that could be used that
7 was not switched off?
8 A. As far as the police station is concerned, we had just one
9 telephone number, but that telephone number was upstairs on the first
10 floor, and it was the chief who used that telephone line. That was the
11 only operational number that the police station had.
12 Q. Well, thank you very much. And while you were on duty in
13 Bratunac, were you allowed to leave your post as the duty officer? Were
14 you allowed to leave the building of the police station?
15 A. No. That particular post is tied to the room of the duty officer
16 within the building of the police station.
17 Q. Well, yes. I understand. I'm clear.
18 A. I couldn't leave the building.
19 Q. Yes, that's obvious. And Mr. McCloskey also asked you a certain
20 number of questions, and if I understood him well, and I believe I did,
21 the questions were about the logbook -- logbook that served to record all
22 the changes during a shift. It's the logbook of events in the police
23 station, and he asked you a certain number of questions with regard to
24 this logbook. Do you remember the questions that he asked you about
1 A. Yes, he did ask me questions about that.
2 Q. He obviously asked you whether the Defence team had shown you the
3 document or if they had told you anything about that document, and you
4 said that the Defence team never showed you or told you anything about
5 the document. My question to you is this: Do you know anything about
6 the attempts on the part of the Borovcanin Defence team to get hold of
7 this document, either in the police station in Bratunac or elsewhere? Do
8 you know that the team tried that? Do you know anything about that?
9 A. I personally don't have any information to that effect. I can
10 only suppose that they have made attempts to get hold of that document.
11 Q. Obviously, what you don't know you can't tell us.
12 A. I can just assume or suppose.
13 Q. You've also been asked certain questions about the establishment
14 of the police station in Srebrenica. My first question with this regard
15 is the following: During the examination-in-chief and during the
16 cross-examination by my learned friend, you were shown a number of
17 documents to -- about that. There was first an order by the president to
18 the minister and then from the minister to the chief of the security
19 centre, and further down, orders issued by the chief of public security
21 A. I remember the documents.
22 Q. And finally, who was it who finally selected those persons that
23 would be appointed to work at the new public security station in
25 A. Somebody from the superior bodies, from the Main Staff of the
1 police station in Bratunac or the Main Staff that was at the time at the
2 police station in Bratunac.
3 Q. Very well. So did that superior, whoever it was, have any
4 obligation? Was he duty-bound to inform you about that?
5 A. Of course not. I was a mere policeman, a police officer.
6 Q. Just one thing. You use the term "Main Staff." Are you
7 referring to the Main Staff of the police forces? Is that what you're
8 referring to?
9 A. Yes. They called it, also, the Crisis Staff. That was the staff
10 that was headquartered in Zvornik and then was moved to the police
11 station in Bratunac.
12 Q. And although there are no suggestions on the part of the
13 Prosecutor - at least I was not aware of any - did Mr. Borovcanin have
14 anything to do with the 2nd company of the PJP that you would be familiar
16 A. No, I don't know any such thing.
17 Q. And you were also asked about your colleague, Mr. Nenad Deronjic,
18 and the Prosecutor presented a -- certain suggestions with this regard.
19 I would like to show you another document.
20 MR. LAZAREVIC: [Interpretation] May the Court please produce
22 Q. You have not seen this document before. I didn't know whether to
23 use it before Mr. McCloskey's cross-examination. Unfortunately, the
24 document has not been translated, but maybe you will be able to help us
25 to understand. This is the title page. Could you please read the title?
1 A. It says "Duty shift of the SJB Srebrenica from 12 July 1995
2 I can't see the little --
3 MR. LAZAREVIC: [Interpretation] Can we below up a little?
4 A. Yes, the bottom part.
5 Q. As far as I can read, it says D. Nenad [Realtime transcript read
6 in error, "DNA
7 A. Yes, it does say Nenad.
8 Q. Very well. And now, let's look at the fourth page of this
10 MR. LAZAREVIC: Just to clarify the transcript, on page 35, line
11 5, it does -- I didn't say "DNA
12 JUDGE AGIUS: All right. Slightly different. Let's proceed.
13 MR. LAZAREVIC: [Interpretation]
14 Q. We have identified the document first, and here we can see the
15 date: 12th of July, 1995. Am I correct?
16 A. Yes.
17 Q. And could we please now -- and we can see that this is actually
18 the first entry, but let's first look at the first couple of pages so as
19 to be totally convinced that the page that we have in front of us now
20 actually depicts the first entry for the day.
21 Under 1, it says "Slavoljub Mladjenovic." Is that the commander
22 of the Bratunac station or your commander who, according to your
23 knowledge, went to Srebrenica on the 12th?
24 A. Yes, that was my superior commander at the time. My superior --
25 immediate superior.
1 MR. LAZAREVIC: [Interpretation] Can we scroll down a little,
2 staying on the same page. Let's go all the way to the bottom of the
3 page, please. Very well.
4 Q. And here we can see where it says Sector 1, there are four names
5 there, and among them under number 2, Deronjic, M. Am I correct?
6 A. Yes, you are.
7 Q. And it says here Sector 1, 19 to 24. Is that correct?
8 A. Yes, it is.
9 MR. LAZAREVIC: [Interpretation] Very well. And now we have a
10 little problem with this document. The document is what it is, and
11 that's how it has been found in the general collection of the
12 Prosecutor's office, i.e., the Tribunal. And since one of the pages was
13 upside down, could we please put the page that I'm holding my hand on the
14 ELMO. That page is missing in e-court, but my learned friends have been
15 informed about the document that I'm just going to put on the ELMO. It's
16 a document that we have found on their collection.
17 This should be page 6 in the e-court system. That's what I was
18 told, but it's missing.
19 Q. Can we have a look at the date up at the top? Can you see it?
20 A. The 13th of July, 1995.
21 Q. Very well.
22 A. It's not very clear.
23 Q. That's right. It might be easier for you to have a look at the
24 document on the ELMO. It's right next to you.
25 A. Yes, it's clearer.
1 Q. You can see that it says duty department, duty service. Can you
2 see the name Deronjic, N?
3 A. Yes. Under number 2, a shift from 19 to 07, if I've read it
5 MR. LAZAREVIC: [Interpretation] Let's now have a look at page 6
6 in the e-court system. You'll see page 6 on the screen now. This is the
7 page that follows the one that we have just had a look at on the ELMO.
8 Let's see whether it's page 6 in the e-court system -- I apologise.
9 Let's have a look at the following page. Yes.
10 Q. In the top part, it says Domavia Drina security. Can you see the
11 name Deronjic, N. It says 07 to 19. I agree that it's a bit smudged,
12 but I think we can see it?
13 A. Yes, that's what it says.
14 Q. And now let's have a look at the next page for the sake of the
16 JUDGE KWON: Was Deronjic on page 6?
17 MR. LAZAREVIC: He's not on page 6. It was my mistake, Your
18 Honour. It was actually page 7.
19 MR. McCLOSKEY: I'm sorry. I can't see what we're talking about
20 here, so if we could make that clear.
21 JUDGE AGIUS: Yes, Mr. Lazarevic. Back to you now. I can see
22 Nenad or N. Deronjic. But what page it is? I take your word for it that
23 it is page 7.
24 MR. LAZAREVIC: Yes. Can we return at previous page?
25 JUDGE AGIUS: Uh-huh.
1 MR. LAZAREVIC: [Interpretation] In the top part, it says
2 "security Domavia Drina", and number 1 -- under number 1, it says
3 Deronjic N, 07 until 19. It's the 13th of July.
4 JUDGE AGIUS: Mr. McCloskey.
5 MR. McCLOSKEY: Can I state for the record that it's a very clear
6 alteration on this document given that I won't be cross-examining on it.
7 JUDGE AGIUS: Thank you.
8 MR. McCLOSKEY: On -- next to Nenad Deronjic's name.
9 JUDGE AGIUS: Yes. Thank you.
10 MR. LAZAREVIC: In response to my colleague, I already said that
11 there are some alteration obviously here, but I didn't try to hide
12 anything from him. This is what I said to the witness already.
13 JUDGE AGIUS: All right. Okay. Go ahead.
14 MR. LAZAREVIC: That's the way we found this document on the DS.
15 Q. [Interpretation] So it seems that these are entries for the 13th
16 of July. When we had a look at the following page, it was obvious that
17 that was for the 14th of July. So the documents that you have seen, did
18 they say anything about the presence of Deronjic in the police station
19 and in the area of the town of Srebrenica
20 MR. McCLOSKEY: Objection. The document speaks for itself. This
21 witness clearly has nothing to add or subtract to this, and I will have
22 no objection to it coming into evidence.
23 JUDGE AGIUS: Will you then proceed with your next question,
24 Mr. Lazarevic, because, indeed, it does say exactly what you were --
25 MR. LAZAREVIC: No, Your Honours. I don't think I will have any
1 further question for the witness.
2 JUDGE AGIUS: All right. Thank you. So Judge Kwon.
3 JUDGE KWON: Just one minor point. Do you by any chance know
4 whether that Nenad Deronjic was related to the late Miroslav Deronjic?
5 THE WITNESS: [Interpretation] I don't know if they were related.
6 I personally know Nenad Deronjic, but as to whether he was related to
7 this person, I really don't know.
8 JUDGE KWON: Very well. Thank you.
9 JUDGE AGIUS: Thank you, Judge Kwon. Judge Prost? Judge Stole?
10 All right. Mr. Simic, we are finished with your testimony. You
11 are free to go. You will receive assistance from our staff. On behalf
12 of the Trial Chamber, I thank you for having come over and also wish you
13 a safe journey back home.
14 THE WITNESS: [Interpretation] Thank you. Thank you to all of
16 JUDGE AGIUS: Thank you.
17 [The witness withdrew]
18 JUDGE AGIUS: Mr. Lazarevic, documents.
19 MR. LAZAREVIC: Yes, Your Honour. We have two documents. One is
20 4D244. The other one is 4D333. I am not quite sure whether this one is
21 already admitted. I just -- through our expert witness, Mladen Bajagic,
22 and there are three other documents which I used in redirect of this
23 witness. It's 4D488 [Realtime transcript read in error, "4D388"], 4D558,
24 and 4D560.
25 JUDGE AGIUS: Any objections, Mr. McCloskey?
1 MR. McCLOSKEY: Mr. President, regarding the last document, the
2 Srebrenica book that had the various police officers, the one with the
3 alteration, that document was retrieved by the OTP, but there are some
4 circumstances that I think the Court should be aware of in the retrieving
5 of that document, what the police department knew before we retrieved it,
6 that may help put the context of possible alterations on it. And so
7 I'm -- I will talk to my friends, and perhaps we can reach a short
8 stipulation on that, and then it will come in, you know, in a more
9 complete way so you understand this document.
10 JUDGE AGIUS: All right.
11 MR. McCLOSKEY: And in addition, I believe the -- and I don't
12 object to the document that indicates the -- I think the wounding of
13 Mr. Stanojevic, which is 4D488. However, I would like to note that the
14 health centre log that I believe is already in evidence, which we --
15 01892, which we do have the original of, indicates the time of wounding
16 to be different than that of the one on the document. And it's right
17 before the wounding of Rade Cuturic, and it appears to be 1730 hours,
18 just so that you can have that in mind for that other document that is
19 coming in through the witness.
20 JUDGE AGIUS: All right. And also for the record, we need to get
21 the numbers correct because, for example, you referred to 4D488, but on
22 line 19 of the previous page, Mr. Lazarevic, was referring to 4D388 and
23 4D558, and so we need, also, to have clear which is the last document
24 that you are moving towards a stipulation. We need to have on the record
25 a clear indication of that document. The last one should be 4D560, but
1 I --
2 MR. McCLOSKEY: That's my understanding, Mr. President.
3 JUDGE AGIUS: Okay. But at least we have it on the record
4 that --
5 MR. LAZAREVIC: I can confirm that it's 560. 5D560. 4D. It
6 says here 5D. It's 4D560.
7 JUDGE AGIUS: And is the other one -- is the other one 4D388 or
9 MR. LAZAREVIC: The other one 488, 4D488.
10 JUDGE AGIUS: 4D488. So the transcript on line 19, in line 19 of
11 the previous page, page 39, is wrong. Okay.
12 JUDGE KWON: But only those pages shown to the witness will be
13 tendered, not entire 76 pages.
14 MR. LAZAREVIC: Well, Your Honour, I don't believe that
15 everything is relevant but only the pages that were shown to the witness,
16 but I already draw the attention of the Trial Chamber that this little
17 problem that we have in the e-court system that we simply couldn't open,
18 so we'll try to organise it in a way to put this missing page in and have
19 the entire document in order.
20 JUDGE AGIUS: Yes, Mr. McCloskey. Thank you, Mr. Lazarevic.
21 MR. McCLOSKEY: It may be helpful just to have the 11th through
22 the 16th just so it's -- context, but yeah, we certainly don't need the
23 whole thing.
24 JUDGE AGIUS: Okay. I think you can reach an agreement on that.
25 Do you have any documents to tender, Mr. McCloskey?
1 MR. McCLOSKEY: No, Mr. President.
2 JUDGE AGIUS: All right. Thank you. That concludes the Simic
4 Now, the next witness, we still have to decide the issue on
5 protective measures.
6 [Trial Chamber confers]
7 JUDGE AGIUS: So, as I said, we have the next witness that we
8 need to decide the protective measures issue. However, before that we
9 have an important communication, which is in itself a directive that we
10 are giving, and this relates to the Prosecution motion regarding the
11 Hotel Fontana documents, a motion that arose in the wake of the use by
12 you, Mr. Zivanovic, in the course of these proceedings of some documents
13 allegedly from -- retrieved from the Fontana Hotel.
14 Now, in relation to the pending motion from the Prosecution,
15 which I just have referred to, we would like you, Mr. Zivanovic, to make
16 arrangements for the recalling of witness Pero Mijatovic. The Trial
17 Chamber wishes to clarify the testimony of this gentleman as to the
18 documents he obtained from the Hotel Fontana; and thus, when he comes
19 over, this witness should come prepared to testify very specifically on
20 that. We also require him to bring with him a detailed list of these
22 You will need, of course, to discuss the scheduling of the
23 witness with the Borovcanin and Miletic Defence teams, as we would like
24 to have this witness here to answer questions as soon as possible. So,
25 Mr. Lazarevic, if you are still involved, and Ms. Fauveau, kindly
1 cooperate as much as you can with Mr. Zivanovic. All right?
2 MR. ZIVANOVIC: Yes. I will, Your Honour.
3 JUDGE AGIUS: Okay. Thank you.
4 Now, the next witness. The next witness, you will recall that
5 there is a motion by the Borovcanin Defence team for protective measures
6 of pseudonym, facial, and voice distortion. We have discussed at length
7 about this motion, and we have decided in the first place by majority to
8 interview him shortly, briefly in private session.
9 Before we do so, have you by any chance discussed the issue again
10 with him, Mr. Lazarevic? Is he still of the opinion that he wishes to
11 have protective measures?
12 MR. LAZAREVIC: Yes, Your Honour. I had the opportunity to
13 discuss this issue with the witness, and he still requires -- he's still
14 asking for protective measures as required in our motion.
15 JUDGE AGIUS: And you still oppose, Mr. Thayer?
16 MR. THAYER: Mr. President, based on the filing, we do. As we
17 stated in the motion, subject to the Court's interview with the witness,
18 we may withdraw our opposition.
19 JUDGE AGIUS: Okay. Thank you. So the members of the public in
20 the gallery will have to be patient with us. We are going to draw the
21 curtains down while this gentleman enters the courtroom, and we will be
22 interviewing him for a few minutes to decide whether to give him
23 anonymity or not. Then we will proceed the sitting in a normal fashion.
24 Yes, please.
25 Let's go into closed session now, for a while, and bring in the
2 [Closed session]
11 Pages 27556-27563 redacted. Closed session.
18 [Open session]
19 --- Recess taken at 5.26 p.m.
20 --- On resuming at 5.56 p.m.
21 JUDGE AGIUS: One moment. Witness, now we are going to proceed
22 with your testimony. You have already been sworn in. The procedure is
23 as follows.
24 Mr. Lazarevic will ask you some questions, and he will then be
25 followed by others on cross-examination, and when we conclude, you can
1 did home. I don't think that is going to happen today. We will proceed
2 tomorrow, continue tomorrow, and I am sure we will finish with you
4 Mr. Lazarevic.
5 MR. LAZAREVIC: Thank you, Your Honour.
6 Examination by Mr. Lazarevic:
7 Q. [Interpretation] Good afternoon, sir. As I have already said it,
8 I am going to avoid using your names, especially when we are in open
9 session as we are now. However, according to the procedure I am going to
10 introduce myself first, although we have already seen each other. My
11 name is Aleksandar Lazarevic, and together with my colleagues I represent
12 Mr. Ljubomir Borovcanin before this Tribunal.
13 And before we proceed, I would like to draw your attention to the
14 fact that the two of us speak the same language; therefore, I would
15 kindly ask you to wait for me to finish my question before you start
16 answering. If you follow the record on the screen in front, you will see
17 at what speed the words are being recorded, and you will be able to see
18 more or less when you can safely start to avoid overlapping.
19 And as the Presiding Judge has explained, you have been granted a
20 protective measure, which is facial distortion. Irrespective of that, I
21 am going to be very attentive. I am not going to address you by your
22 name, and if any of the information may divulge your identity, I will go
23 into private session. Did you understand my words so far?
24 A. Yes, I did.
25 MR. LAZAREVIC: Your Honours. Can we move into private session?
1 I would prefer to have this line of questions in private session.
2 JUDGE AGIUS: Yes, by all means, Mr. Lazarevic. Let's go into
3 private session, please.
4 [Private session]
11 Pages 27567-27569 redacted. Private session.
9 [Open session]
10 JUDGE AGIUS: We are in open session.
11 MR. LAZAREVIC: [Interpretation]
12 Q. Could you now tell me, sir, whether at one point in time your
13 wife and daughter left Bosnia and Herzegovina?
14 A. The second thing I did was to send them off in the direction of
16 brother who lived in Krusevac with his family, and I hoped that he would
17 put them up.
18 Q. Very well. And tell me, did you at some point in time return to
19 Bosnia and Herzegovina?
20 A. I didn't even leave Bosnia and Herzegovina. I only escorted my
21 wife and daughter, and then as it was clear to me that I had to become
22 engaged, I sought out part of the special unit that I had previously
23 worked in, and I joined the educational centre of the MUP in the Sarajevo
24 settlement of Vraca.
25 Q. Very well. Now, tell me, after that were you assigned a position
1 of some kind in that unit?
2 A. Yes, I was. I was still in my tracksuit and in training shoes,
3 but I was assigned as a -- an operative duty commander in the unit.
4 Q. Did that unit remain in Vraca in the subsequent period after you
5 had returned?
6 A. As far as I can remember, towards the end of May we were moved --
7 or rather, we moved the command of the special unit to Brdo, to a hill
8 above Vraca. It was at the top. It was Moravska Street, perhaps, and
9 our lines were -- or positions stretched along the hill that is called
10 the Hrasno Hill.
11 Q. Tell me, afterwards did the unit move somewhere else?
12 A. About the 6th or 7th of June, because the people were exhausted,
13 we withdrew the unit to rest in the premises of the Sarajevo factory
14 Envergoinvest, which is located in the Lukavica settlement.
15 Q. Very well. And then did you get some other position with your
17 A. The men briefly stayed in the presence of the Envergoinvest
18 factory, and then some were selected to rest in the Jahorina Moharina
19 [phoen], in the Kosuta Hotel.
20 Q. Very well. If you can remember, do you remember whether the unit
21 then moved to some other place? Did it have its headquarters somewhere
23 A. We left Jahorina to perform tasks in the Sarajevo settlement of
24 Vraca. And then I, in fact, towards the end of July - I can't remember
25 the exact date - was granted a brief leave to visit my family. They were
1 staying with my brother in Krusevac, my son and daughter and my entire
2 family, in fact, was there. I stayed there for four or five days. When
3 I returned, when I moved from Serbia
4 Zvornik, to be more precise, I met members of my special unit at
5 checkpoints in the direction of Sekovici. I was surprised. I asked what
6 they were doing there. They told me they had been there for three or
7 four days already. Later, I found out they had been assigned a task, the
8 task of neutralizing some paramilitary formation in Zvornik known as Zuta
9 Osa or the Yellow Wasp. I know that the mission was accomplished
11 Q. Very well. Tell me, did the headquarters of the unit remain
12 there for a while, or was the location changed, and if so, when?
13 A. Having accomplished the mission and having neutralized the
14 paramilitary formations, the unit was provided with accomodation in the
16 to Zvornik. But part of the unit, a small part of the unit remained on
18 Q. Very well. Now, tell me, how much time did the unit stay in
19 Zvornik? How long did it stay there, and did it then move to some other
21 A. We stayed in the Drina
22 1994, up until February or March. That's when changes were introduced in
23 the brigade command; the structure of the command was changed. The head
24 of the brigade was changed.
25 Q. Where did the brigade -- where did the unit move from Zvornik,
1 and then I'll continue with other questions.
2 A. In the early spring, in February or March, 1994, the unit was
3 moved the Janja settlement, to the premises where we already had a police
4 detachment of ours.
5 Q. Very well. And now tell me, as far as you can remember, when was
6 the special police brigade established? That's what it was called, later
7 became the special police brigade. When did this happen? Can you
9 A. Well, I was involved in those tasks, and I think that when the
10 special police brigade was formed -- well, I think they had already
11 started forming it in the autumn of 1992. I think it was in October.
12 Q. Tell me, now, during this period of time that we have been
13 discussing, what sort of duties did you have to perform in the unit?
14 A. Well, initially I had the following tasks in Zvornik. I had to
15 deal with personnel issues, all personnel issues that related to the
16 unit. I took care of seriously -- of the seriously wounded, of the
17 families of those who had been seriously wounded or killed. I also dealt
18 with administrative issues.
19 Q. Tell me, in 1995, where were the brigade headquarters located?
20 A. The same place where we were moved to in 1994, in Janja.
21 Q. And can you now tell me, to the best of your recollection, what
22 was the structure of the command of the special police brigade in 1995?
23 What was the command structure like?
24 A. At the head of the brigade, there was the commander, Goran Saric;
25 the deputy commander, Ljubomir Borovcanin; the assistant commander for
1 logistics, Milutin Ratkovic; the assistant for training, Dusko Jevic; the
2 assistant for personnel affairs, Obrad Savic; the assistant for logistics
3 support, Vitomir Kapuran and so on.
4 At that time, I had a decision according to which I was an
5 official for information.
6 Q. Very well. I would now like to put a few questions to you that
7 have to do with the special police brigade, and it relates to 1995, the
8 year 1995. Do you remember whether at the time in 1995 there were any
9 ranks in the police, and were there any ranks in the special police
10 brigade as well?
11 A. I think that in the second half of 1995, something was done to
12 assign ranks, and ranks actually came to life or started being used on
13 the 21st of November, let's say, 21st of November, 1995.
14 Q. Very well. And now I would like to move on to a different
15 subject. It concerns the training centre in Jahorina and the police
16 forces staffs. Tell me, do you remember when the police forces staff was
17 established on Jahorina?
18 A. I think that was February or March 1995.
19 Q. To the best of your recollection, tell me, what was the reason
20 for establishing this staff on Jahorina?
21 A. Well, the reason for establishing the staff was to obtain
22 operative information for the police services; and on the other hand,
23 from the direction of Sarajevo
25 Q. I would now like to have a look at a number of documents that
1 have to do with the police forces staff on Jahorina.
2 MR. LAZAREVIC: [Interpretation] The first one I would like to
3 have a look at is 4D622.
4 Q. You'll see it on the screen. Unfortunately, we don't have a
5 translation, so I'll go through it with you.
6 MR. LAZAREVIC: [Interpretation] Could we just show the entire
7 document on the screen --
8 Q. -- so that you can follow.
9 MR. LAZAREVIC: [Interpretation] Maybe we can enlarge it a bit.
10 Q. This is the first page. It's a dispatch from the command of the
11 special police brigade, Goran Saric. It's dated the 15th of March, 1995
12 In this document, he informs a number of levels in the MUP, in a number
13 of departments about the activities taken to establish a staff for the
14 police forces.
15 And now let's have a look at the first paragraph in the document.
16 Can you see it?
17 A. "On the basis of a written order from the deputy minister of
18 internal affairs and the leader of the RJB on establishing police forces
19 staff for the needs of control and command in the upcoming combat
20 operations on the Sarajevo
21 "In addition to the activities mentioned in the dispatch, we have
22 undertaken the following" --
23 Q. Very well, I don't want to go through the entire document, to
24 read through the entire document. I would just like to gain a picture of
25 what is at stake in the document, and therefore, I'd like to have a look
1 at the next page.
2 A. All this corresponds to what I actually witnessed on Jahorina.
3 Q. And on this page, we see what they say about efficient operations
4 of the staff, how it should achieve efficiency. It mentions the measures
5 that should be taken to make sure that the staff functions properly.
6 Tell me, this document shows that we're dealing with a written
7 order from the deputy of the -- deputy minister of the MUP, a written
8 order on establishing the staff.
9 A. Yes. This is already the implementation of this oral order.
10 It's an oral order.
11 MR. LAZAREVIC: [Interpretation] Let's have a look at 4D391.
12 Q. Very well. We can go through the document a little more rapidly
13 because we have a translation into English. It's an order from the
14 Ministry of the Interior Zivko Rakic. It is dated the 16th of March,
15 1995. It is an order on forming a command and control staff of the
16 police forces in the Sarajevo
17 of the document, the 16th of March, 1995, and we can see who the
18 addressees are.
19 We have the public security department, the state security
20 department, the police forces staff, and so on and so forth. Have a look
21 at the order. Who, according to this order, should become part of the
23 A. Yes. There is a number of segments of the police, of special
24 police units, logistics material and financial assistance. All I can do
25 is confirm that this was implemented. I witnessed that.
1 Q. Very well. And according to this order, who was designated as
2 the commander of the staff?
3 A. Well, here it says Saric, Goran.
4 Q. Let's look at item 5 of the order where it says that "Continuous
5 functioning of the staff should be issued as of the 20th of March."
6 A. Yes, the 20th of March, 1995.
7 Q. I would kindly ask you to bear in mind the break between the
8 question and the answer. Please wait a little before you start giving
9 your answer, and I'll try to bear in mind the same. Thank you.
10 MR. LAZAREVIC: [Interpretation] Very well. Let's now move to the
11 following document, which is 4D -- I apologise. [In English] [previous
12 translation continues]... to page 65, line 15. It should read: "The 20th
13 of March." This is what the witness said.
14 Q. [Interpretation] It seemed that this hasn't been recorded. In
15 any case, the document that I wanted to show you next is 4D623.
16 Very well. If we look at the document now, we will see that this
17 is information by Dusko Jevic, the command of the special police brigade,
18 and the date is 28th of March, 1995. And we see that he informs the
19 command of the special police brigade about the concrete steps that were
20 taken with a view to establishing the staff.
21 I would like to show you, first of all, the written version of
22 this version -- the handwritten version for identification.
23 MR. LAZAREVIC: [Interpretation] The document is the same. Can we
24 please look at page -- at the following page. Let's just look at the
25 number, please.
1 Q. If we look at this document, in handwriting the number is 1/95,
2 is it not?
3 A. Yes, that's the beginning.
4 Q. Very well. According to your best knowledge, what was the reason
5 for the establishment of the education and training centre of the
6 Ministry of the Interior Republika Srpska?
7 A. From the very beginning of the war, we trained police officers
8 for simple tasks in the police; and three years into the war, because of
9 the casualties, people being wounded, there was a constant shortage of
10 men, so the units were replenished with military conscripts who had not
11 undergone police training. That is why periodically police training
12 courses were organised for police apprentices to provide them with the
13 necessary skills and knowledge.
14 Q. In the centre for training of the Republika Srpska MUP, did you
15 have a position, a function? Did you have to do anything with the staff?
16 A. At the time, I was in charge of the logistics support. The
17 offices had to be equipped. Office supplies had to be provided with
18 basic -- basic equipment had to be procured, and that's what was
19 happening at the time.
20 Q. One more thing I would like to ask you. According to your best
21 recollection, did Mr. Borovcanin have a position? Did he have a function
22 to perform at the training centre?
23 A. No, not at the training centre.
24 MR. LAZAREVIC: [Interpretation] Let's look at the following
25 document. This is 4D400.
1 Q. Very well. Since we have it in front of us, on the right-hand
2 side is the document in Serbian. Again, this is a report of the police
3 forces commander Jahorina Trnovo, Dusko Jevic. The date of 1st of April,
5 A. Yes.
6 Q. Let's look at the number this document bears in the right-hand
7 side corner. The number is 3/92, is it not?
8 A. Yes.
9 Q. And the commander of the Jahorina Trnovo police forces informs
10 the Ministry of the Interior that the trainees started arriving at the
11 Jahorina Hotel. We can see this in the first paragraph of this document.
12 A. Yes.
13 Q. Further on, we can see that the commander of the police staff
14 forces is requesting that officers who have been selected for command and
15 control should be sent -- sent urgently to prevent any possible problems.
16 A. Yes.
17 Q. Now that we have seen the document and we have seen the list of
18 addressees - which is the public security department, the police
19 administration, the special police brigade - what training course is
20 referred to in this document?
21 A. Again, this training course was organised for members of our
22 detachments who had not been trained despite the fact that they were
23 still involved in combat. However, they had not undergone previous
24 police training.
25 Q. Was that a course for policemen?
1 A. Yes.
2 Q. And it arises from this document that there is a possible problem
3 with officers who were supposed to be in charge of the training course.
4 Could you please tell me, which officers were supposed to manage the
5 course? Who were the lecturers? Where were they supposed to arrive
7 A. Those were teachers, i.e., professors from the school of the
8 interior who were trained to educate future policemen.
9 Q. Were there also lecturers from the special brigade?
10 A. Only for special physical training they could be instructors, for
11 special training, the use of chemicals and similar things. And the
12 theory of policing was something that was lectured by full-time
13 professors. They were the only ones with the degree that enabled them to
14 do that.
15 Q. I apologise. I'm just waiting for the -- for your answer to be
16 recorded properly. Tell me, please, according to the best of your
17 recollection, did the course take off the ground in that period?
18 A. I've already told you that they -- those courses were organised
19 periodically, even before. So I am fully convinced that the training
20 courses continued.
21 Q. Did you personally participate in the training?
22 A. No, I didn't.
23 MR. LAZAREVIC: [Interpretation] Very well. I would like us to
24 look at the following document, which is 4D251. I would kindly ask the
25 Court to produce the document in e-court.
1 Q. Again, this is a dispatch by the Jahorina commander. The number
2 is 5/95, and the date is 6 April 1995
3 of addresses in the MUP of Republika Srpska. Could we please look at the
4 second page to inspect the signature on the document?
5 A. The same person.
6 MR. LAZAREVIC: [Interpretation] Let's look at the second page,
7 please. Can the next page be produced in e-court, please?
8 Q. Very well. Again, the dispatch was sent from the police forces
9 command Jahorina Trnovo, and it was co-signed by Dusko Jevic and Cedo
11 A. I know the people, and I can confirm the credibility of the
12 signatures. I worked with both of them for a number of years.
13 MR. LAZAREVIC: [Interpretation] Can we now go to the first page
14 in order to remove an ambiguity.
15 Q. In the first paragraph, it says: "In the evening of 5 February
16 1995, a group of trainees arrived from the CJB Zvornik (8 trainees) so
17 that the total number of trainees now is 142."
18 In view of the date when this dispatch was sent and the date that
19 is mentioned herein as the date of the arrival of the trainees from
20 Zvornik, is this really the 5th of February, 1995, or is this a typo?
21 A. This is a typo, obviously. It should be the 6th of April, and
22 the information applies to that course. It's obvious that it was very
23 difficult to set up a course of that nature and to implement it.
24 Q. And now, if we look at what we have already read in the first
25 paragraph of this document, does the number of 142 trainees tell you
1 something about the implementation of this training course?
2 A. It is obvious that those were members of the special police
3 brigade and public security centres. A reference is made here to eight
4 trainees from Zvornik, but I'm sure that there were others from other
5 public security centres.
6 Q. Now, if we look at the bottom part of the document where it says
7 "It has been agreed with the deputy commander of the special police
8 brigade," and here a reference made to a certain number of names: Nedo
9 Sevo on behalf of the school of internal affairs, and Aco Milic, a
10 psychologist from the school. What does this tell us about the
12 A. It says that the lecturers were full-time professors from the
13 school of the -- of internal affairs and that special police training was
14 carried out by the instructors from our brigade.
15 MR. LAZAREVIC: [Interpretation] Very well. Let's move on to the
16 next document, which is 4D252.
17 Q. Again, this is a dispatch by the commander of the staff of the
18 police forces Jahorina Trnovo, Dusko Jevic. The number is 11/95, and the
19 date is 8 April 1995
20 Mirosavic to work with the trainees. Do you know where Tomo Mirosavic
21 came from?
22 A. I believe that he was the Chief of Staff of a department at the
23 school of internal affairs; in any case, he was a full-time professor.
24 It's obvious that a lecture was missing for one of the modules of the
25 course, and it the commander believes that Tomo Mirosavic would be the
1 best-suited person to fill the position. I wouldn't be able to tell you
2 what his specialty was.
3 Q. Very well. And now, can you remember modules of the course?
4 What kind of training was provided to the trainees during the course?
5 A. It was a very special -- a very simple training course for
6 beginners. The trainees were informed about the law on internal affairs.
7 They were familiarized with policing procedures, patrolling, and they
8 were provided some special physical training. They were familiarized
9 with weapons, chemical agents and similar things.
10 Q. And now, could you please tell me if you remember, how long did
11 the course last?
12 A. Well, as a rule the courses would normally last three weeks,
13 about 20 days.
14 Q. And do you know on the base of what a programme was this course
15 the policemen conducted?
16 A. Well, usually there was a -- an officer who would prepare for the
17 main courses. He'd assess the conditions and take into consideration the
18 time-period concerned. But it varied. It was on the basis of experience
19 and varied from course to course.
20 Q. Very well. Let's now have a look at the following document.
21 Unfortunately, we don't have a translation --
22 MR. LAZAREVIC: [Interpretation] 4D624 is the document.
23 Q. I'll just put a few questions to you about this document, since
24 it's one you have already seen. Could we just have a look at it?
25 Can you tell us what the title of the document is?
1 A. "Republika Srpska, the ministry of internal affairs, special
2 police brigade, police force staff, Jahorina Trnovo." That's the
3 title -- or rather, the title is "The programme for professional training
4 for the police course." I'm familiar with this handwriting.
5 Q. It's not very clear here. Perhaps we could scroll down a bit to
6 see the date.
7 A. That's the very same course. The date is the 10th of April,
9 Q. And tell me, you said that you recognized the handwriting. Whose
10 handwriting is this?
11 A. It's Dusko Jevic's handwriting, the deputy commander of the
12 special police brigade.
13 Q. You've already seen this document. Can you just tell us
14 something about the contents of the document, especially with regard to
15 the programme for professional training?
16 A. Well, the programme consists of various subjects that have to be
17 dealt with during the course and on a day-by-day basis. You start off on
18 Monday. Then you have Tuesday, Wednesday. The subjects change. Some of
19 the subjects can be modified, can be changed. If there is inclement
20 weather, one subject can be taught instead of another. But on the whole,
21 it's physical preparation, training, shooting, and learning about
22 chemical agents, et cetera. I've already mentioned this.
23 Q. Very well. I would now like to put a few more questions to you
24 before we adjourn for the day.
25 Do you remember, perhaps, that at one point in time some of the
1 beginners at the police course were moved to Konjevic Polje?
2 A. Yes, I am familiar with that. I don't understand why this was
3 done. Perhaps it was to bring some unit up to strength in order to
4 secure a road - at the time, Konjevic Polje was a checkpoint -- or there
5 was a checkpoint in Konjevic Polje; there wasn't combat of any kind - or
6 perhaps to gain experience in the course -- of the course itself.
7 MR. LAZAREVIC: [Interpretation] And let's just have a look at
8 the following document, 4D625.
9 Q. It's a dispatch dated the 11th of April, 1995. And if we have a
10 look at the signature at the bottom, it says the commander of the 8th
11 special police detachment, Branislav Okuka. And if we have a look at the
12 first paragraph of the document, it says, "Having visited the course
13 attendees who are presently in Konjevic Polje, it has been established
14 that the following attendees joined the course later..." and then you
15 have the names of the individuals concerned.
16 Can you tell me whether this document, and in relation to what we
17 have just discussed, in relation to sending some of the beginners to
18 Konjevic Polje, has it got anything to do with that?
19 A. Yes, I assume that this commander was working on behalf one of
20 the -- was working as one of the officers on the course, perhaps a
21 company commander.
22 Q. Very well.
23 MR. LAZAREVIC: [Previous translation continues]... maybe we can
24 adjourn just right now.
25 JUDGE AGIUS: Thank you, Mr. Lazarevic.
1 Witness, we are going to stop here today. We will continue
2 tomorrow in the afternoon at 2.15. Between now and tomorrow, it's
3 important that you do not communicate or you let anyone communicate with
4 you on the subject matter of your testimony. It's an obligation that you
5 have. Have you understood me? All right.
6 THE WITNESS: [Interpretation] I have.
7 JUDGE AGIUS: Thank you.
8 --- Whereupon the hearing adjourned at 6.57 p.m.
9 to be reconvened on Thursday, the 30th day of
10 October, 2008, at 2.15 p.m.