Tribunal Criminal Tribunal for the Former Yugoslavia

Page 29584

1 Wednesday, 26 November 2003

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.04 a.m.

6 JUDGE MAY: Yes, Mr. Milosevic.


8 [Witness answered through interpreter]

9 Cross-examined by Mr. Milosevic: [Continued]

10 Q. [Interpretation] So, Mr. Velic, according to the information I

11 have, you had the main say in your municipality regarding all decisions

12 that were taken at the time. Is it true that Semsudin Velic, your own

13 brother, was appointed head of the Secretariat of the Interior precisely

14 at your proposal?

15 A. No, that is not correct because at the time when he was appointed

16 to that position I was not president of the SDA of Bosanska Krupa at all.

17 Q. You were not president, okay, but was he appointed?

18 A. Yes, he was appointed immediately after the multi-party elections,

19 and I was elected president of the SDA only a year later.

20 Q. But is it true that the secretary of the Executive Board was Edhem

21 Dizdarevic, your relative?

22 A. Edhem Dizdarevic was secretary of the Executive Board but I'm not

23 aware that he's my relative.

24 Q. But is it true that Suad Alibegic, president of the Executive

25 Board, was appointed at your proposal?

Page 29585

1 A. Late Suad Alibegovic -- Alibegic, who died in a car accident, was

2 appointed at the proposal of the independent municipality of Buzim.

3 Q. You were not involved?

4 A. Of course I was not involved because I did not know Mr. Alibegic

5 at all at the time.

6 Q. But is it true that your uncle Omer Velic held one of the

7 managerial positions in Krupatrans company?

8 A. I have only one uncle, Kasim Velic. He was never employed with

9 that company in Bosanska Krupa. He worked abroad in Austria.

10 Q. And who is this Omer Velic?

11 A. I know the gentleman but we are not related.

12 Q. All right.

13 A. I know Mr. Omer Velic, but we are not related, as I said.

14 Q. So you were not involved in any of these appointments, were you?

15 A. As far as the appointment of my brother Semsudin Velic, chief of

16 the police station is concerned, I was not involved directly because I was

17 only a member of the Executive Board of the SDA of Bosanska Krupa at that

18 moment. And as far as the appointment of Omer Alibegic is concerned, I

19 was not involved because he was nominated by an independent organisation

20 of the municipality of Buzim.

21 Q. So what was your influence on it?

22 A. My influence was limited to presenting my positions and arguments.

23 Q. So in paragraph 4 you said that problems in the interrelations

24 between the SDS and the SDA in the area of Krupa resulted from the --

25 their attitude towards the role of the JNA in the conflict in Croatia.

Page 29586

1 A. I don't have that statement with me. It hadn't been given to me.

2 But problems did arise around that, because the SDA and the SDA [as

3 interpreted] had different positions -- had different views on the role of

4 the JNA in Croatia.

5 Q. You say in paragraph 4 that you didn't agree with the JNA being

6 used to resolve problems in Croatia. Is that true?

7 A. If you ask me directly about --

8 Q. I'm not asking you about your opinion, I'm asking you about your

9 statement.

10 A. I cannot find this passage at the moment, so I cannot comment upon

11 it, but in any case, I did not agree nor would I agree today with the use

12 of the JNA in any internal conflict in the former Yugoslavia.

13 Q. You are talking about the resolution of political problems in the

14 former Republic of Croatia.

15 A. I think that is a wrong interpretation of my statement.

16 Q. A wrong interpretation of your statement?

17 A. That's what I think.

18 Q. So you could not give me the example of a single political problem

19 in Croatia where the JNA would be involved?

20 A. You would have to be more specific. I don't know what you mean.

21 Q. You say that this is a wrong interpretation of your statement

22 because the resolution of political problems in Croatia was not something

23 the JNA was involved in or interfered with?

24 A. I did say it was a wrong interpretation of my statement because

25 political divergences in the multi-party political life of Croatia were

Page 29587

1 what they were. It was only later that the JNA -- in fact, even later the

2 JNA did not interfere with that.

3 Q. What would you consider as taking sides on the part of the JNA?

4 A. The commanding staff of the JNA were never given the opportunity

5 to present their views publicly.

6 Q. All right. In 1991, the year you are referring to, Bosnia and

7 Herzegovina was an integral part of Yugoslavia, wasn't it?

8 A. That is not in dispute.

9 Q. I suppose you agree, both as a lawyer, former judge, public

10 prosecutor, a person who is familiar with the law, that with the decision

11 on mobilisation that was adopted then by the federal authorities, the

12 decision was binding on everybody regardless of their ethnicity.

13 A. I am not aware that the decision on mobilisation that was then

14 adopted was adopted by federal authorities.

15 Q. All right. You say on page 4 in paragraph 2 that the SDS wanted

16 to have direct control over personal documents of military conscripts in

17 Bosanska Krupa. Is that correct?

18 A. What I meant, actually, was that the SDS wanted to dispose of the

19 military documentation of military conscripts of Serb ethnicity.

20 Q. So they wanted to have the documentation of military conscripts of

21 Serb ethnicity.

22 A. Yes. In inter-party negotiations, representatives of the SDS were

23 explicit. They wanted the documentation of military conscripts of Serb

24 ethnicity to be separated from the rest so that they could dispose of it

25 and mobilise these conscripts.

Page 29588

1 Q. All right. I suppose that you imply the files, the military files

2 of these conscripts, not their personal documents.

3 A. Of course.

4 Q. I suppose that the following imprecision is also accidental: The

5 documents did not belong to the conscripts. They belonged to the military

6 authorities that were part of the -- that had the Territorial Defence as

7 its integral part.

8 A. Yes.

9 Q. And this documentation was held by the Secretariat for National

10 Defence?

11 A. On their premises.

12 Q. Is it true, as you say, that the head of the Secretariat for

13 National Defence was a Serb, a man named Boro?

14 A. Yes.

15 Q. You say you don't know his exact name but he was a member of the

16 SDS.

17 A. Yes. He was nominated to that position by the SDS.

18 Q. How is it possible, then, that this man Boro, who was head of that

19 secretariat, was unable to get hold of that documentation?

20 A. He was of course authorised, as all the other senior staff of the

21 secretariat, to handle their documentation and use it for purposes

22 envisaged by the law.

23 Q. So he had access to that documentation and was able to use it.

24 A. Of course. He had every legal authority to review and use that

25 documentation in keeping with the decisions of the competent authorities.

Page 29589












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Page 29590

1 Q. But in paragraph 12 you say that the SDS was denied this so-called

2 control by the secretariat.

3 A. The SDS could not have control of that documentation. Only

4 authorised officers were able to handle the documentation, and that's how

5 you should understand my statement.

6 Q. All right. Does it mean, then, that the SDS -- sorry, the SDA had

7 actual control of the documentation?

8 A. No, it doesn't mean that. It means that the staff of the

9 secretariat disposed of the documentation in the legally envisaged way.

10 THE INTERPRETER: The interpreter missed the question. This is

11 going too fast. Would you please repeat the last question.

12 JUDGE MAY: Wait a moment. Now -- just a moment. Both of you

13 must bear in mind that this has to be interpreted. So, Mr. Milosevic, you

14 know quite well, you've been here long enough to know that, so would you

15 bear the interpreters in mind.

16 We will go on from now. I don't think we'll be able to recover

17 what the last question was.

18 MR. MILOSEVIC: [Interpretation]

19 Q. All right, Mr. Velic. In paragraph 3 on page 4, you say that

20 after this decision was taken by the SDA, the JNA intervened, but: "The

21 police and the civilians managed to prevent this, and the JNA did not

22 attempt to do so." Is this a precise quotation of what you said?

23 A. You read my statement correctly, but what does it mean? Perhaps I

24 did not use the most precise terms.

25 One day a small military unit came to Bosanska Krupa, to the

Page 29591

1 office of the president of the municipality, Mehmed Mahic, and asked to

2 take away the documentation from the Secretariat for National Defence. As

3 far as I know, this was met with the dissatisfaction of a certain number

4 of citizens who gathered on the premises of the Secretariat of National

5 Defence. In talks with the president of the secretariat, Mehmed Mahic,

6 the military abandoned the idea of taking this documentation.

7 Q. So the JNA did not even try to intervene?

8 A. I think the term "intervention" is too strong. Armed soldiers,

9 about 15 or 20 of them, did come, but they did not try to use force to

10 take this documentation.

11 Q. All right. Is it correct, though, that then in early autumn 1991,

12 the documentation was the focus of negotiations between representatives of

13 military authorities and local officials, representatives of the SDA

14 rather than between the SDS and the SDA?

15 A. I don't know the details of these negotiations. I did not even

16 attend the talks between representatives of the municipality and the

17 military. And I don't know if there were any other talks.

18 Q. All right. But the talks were between military representatives

19 and representatives of the SDA?

20 A. Not representatives of the SDA but official representatives of the

21 municipality of Bosanska Krupa.

22 Q. But they were SDA members, weren't they?

23 A. In this specific example, Mr. Mehmed Mahic was a member of the

24 SDA. He was president of the secretariat. If you give me another name,

25 I'll be able to tell you.

Page 29592

1 Q. Is it true that your wife was taking out this documentation on the

2 quiet, on the sly, through the window while negotiations were going on,

3 together with Semso Sepic [phoen]?

4 A. I don't know about that, sir. She was a member of the staff of

5 the secretariat, that much is true.

6 Q. All right, Mr. Velic. You advocated the abolishing of the

7 secretariat and its attachment to the secretariat of the economy.

8 A. You cannot say that I personally advocated it. What is true is at

9 the time a reorganisation of municipal administration bodies was under

10 way. At that time, as far as I remember, there was a proposal to organise

11 the Secretariat for National Defence as part of the Secretariat of the

12 Economy.

13 Q. And what justification was given for that, pray?

14 A. I don't know, I couldn't tell you now but there are documents

15 about that and they can be made available to the Court.

16 Q. But can you tell me, based on pure logic, what could be the

17 justification for attaching the Secretariat of Defence to the Secretariat

18 for Economy?

19 A. I cannot give you an explanation. I told you that I worked as

20 president of the SDA from September 1991 as a volunteer, on voluntary

21 basis.

22 Q. All right. We'll move on to another topic. In paragraph 5, page

23 -- in paragraph 3, page 5, you say that in local commune of Otoka of the

24 municipality of Bosanska Krupa there occurred an arrest of some people you

25 refer to as Martic's policemen.

Page 29593

1 A. Yes.

2 Q. However, I assume that your brother knows a lot more about this

3 incident, that is Semsudin Velic, the then chief of police.

4 A. I guess that's so.

5 Q. All right. That same evening, as you mention, Martic himself was

6 arrested who was together with Smiljanic, an officer of the JNA from the

7 Banja Luka Corps; is that right?

8 A. Yes, that's right. Perhaps arrest, it would be the wrong word,

9 though.

10 Q. All right, so what's the word you would use?

11 A. Well, the previous events that took place with Martic's policemen,

12 as I said, caused unrest among citizens in Bosanska Krupa because they

13 were released from the Bosanska Krupa police station when yet another

14 20-odd policemen of Martic's came in. It was Sunday, the police station

15 was not properly secured, and that's how this happened. I thought then

16 and I think today that this was an armed provocation and an attempt to

17 destabilise the situation in Bosanska Krajina, specifically in Bosanska

18 Krupa.

19 In view of the anxiety among the citizens themselves, in Otoka

20 that evening about 500 to 1.000 citizens assembled around the bridge. It

21 was in the early evening. There was a police checkpoint there for

22 controlling traffic, and as the citizens assembled there, quite

23 accidentally a vehicle came up and Mr. Martic and Mr. Smiljanic were in

24 that vehicle.

25 Since the citizens noticed SAO Krajina insignia on the uniforms of

Page 29594

1 the persons in the vehicle, then this caused even greater unrest. The

2 policemen who were present were compelled to transport this vehicle to the

3 police station Otoka. It was only when he was identified at the police

4 station that Martic was recognised and Smiljanic introduced himself as he

5 offered his ID, his military ID.

6 Q. You say on page 5 of your statement -- because you say it just

7 now, that arrest is not an adequate word -- you say: "That same evening

8 Milan Martic, Serb commander from Croatia, was arrested near a small town

9 called Otoka." I asked you about that and then you also referred to

10 Colonel Smiljanic or, rather, Lieutenant Colonel Smiljanic.

11 JUDGE MAY: The witness has answered that question so there is no

12 need to go over it again. He has explained the circumstances and what he

13 means.

14 THE ACCUSED: [Interpretation] All right.

15 MR. MILOSEVIC: [Interpretation]

16 Q. Tell me now, please, who issued the order to arrest Martic?

17 A. As far as I know, no one. As a matter of fact, I've just said

18 that "arrest" was not an adequate term at all, and it does not correspond

19 to the situation in which this happened.

20 That night I came to Otoka and I saw for myself that Martic was

21 already there at the police station in Otoka and that he was actually

22 protected by the police.

23 Q. All right. In view of the fact that your brother, as you said

24 yourself, was the chief of police at the time, is it correct that under

25 his command Muslim civilians were then given weapons by the police station

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Page 29596

1 in Bosanska Krupa?

2 A. As far as I know, that's not correct, Mr. Milosevic, but arms were

3 distributed to the reserve police force, or rather, part of the reserve

4 police force.

5 Q. So arms were distributed to part of the reserve police force as

6 you put it. And then further on you say that the -- the order for

7 Martic's arrest was annulled from Belgrade; is that right?

8 A. Well, when Martic was released, he was given an escort of the

9 republican MUP of Bosnia-Herzegovina, he and Mr. Smiljanic were, and they

10 were transported to Bosanski Novi. In Bosanski Novi, Mr. Mahic Mehmed was

11 present, president of the municipality of Bosanska Krupa, who attended the

12 meeting between Martic and Mladic, General Mladic, who at that time did

13 not probably hold the rank of general. He deserved it later.

14 It was a cordial meeting. It ended with a hug. And this is what

15 Mahic told me about it: They were saying that the APB for Mr. Martic had

16 been annulled.

17 Q. But I'm quoting your statement. "An arrest warrant was issued for

18 Martic, the Bosnian MUP intervened, and then he was sent back to Bosanski

19 Novi. Mladic was waiting for him and the order was annulled from

20 Belgrade."

21 Do you allow for the following possibility, that it was not from

22 Belgrade that the arrest warrant was annulled. It wasn't even issued by

23 Belgrade but it was done by then minister of the interior of

24 Bosnia-Herzegovina, Alija Delimustafic?

25 A. Do you mean the APB or do you mean the arrest warrant? Well, as

Page 29597

1 far as I know, what was made public then was there was a federal APB

2 issued by the federal authorities but at the initiative of Croatia.

3 However, it was annulled after what happened in Otoka and if we are to

4 abide by the principles of legality, Mr. Delimustafic could not have

5 annulled something that was issued by the federal authorities.

6 Q. So you don't know who annulled it.

7 A. I don't.

8 Q. Is it correct that while Martic was at the SUP premises in Krupa a

9 large number of armed Muslims had assembled in front of the SUP building?

10 A. Mr. Martic was never at the police station in Krupa, he was at the

11 place station in Otoka.

12 Q. Otoka is in Krupa I believe.

13 THE INTERPRETER: Could the speakers please speak one at a time,

14 the interpreters ask.

15 JUDGE MAY: You're being asked again, you're being cautioned by

16 the interpreters. Just leave a moment after the other has spoken, before

17 you respond. Yes.

18 THE WITNESS: [Interpretation] Otoka was a local commune within the

19 municipality of Bosanska Krupa, and that is where the police department

20 was, one of the police departments, and that is where Martic was during

21 the night between the 8th and 9th of September, 1991. As I had already

22 said, a number of citizens of Otoka had assembled in the centre of that

23 area, but no, there was no harm done.

24 MR. MILOSEVIC: [Interpretation]

25 Q. However, they had assembled and they wanted Martic to be handed

Page 29598

1 over to them so that they could judge him.

2 A. Mr. Milosevic, they had gathered there. Some of them were under

3 the influence of alcohol, but the police held everything under control and

4 there were no concrete requests put forth by the citizens, as far as I

5 know.

6 Q. All right. On page 5, in paragraphs 9 and 11 you say that you

7 from the Party of Democratic Action made every effort to increase the

8 number of reservists of the police force and that that was the only way in

9 which you could legally obtain weapons. Is that right?

10 A. That is quite right.

11 Q. This initiative was started in the autumn of 1991. Is that right,

12 Mr. Velic?

13 A. I think that that initiative was launched much earlier, perhaps

14 even about a year earlier, perhaps the spring of 1991, and it was launched

15 from official quarters, the municipal authorities of Bosanska Krupa. It

16 was also addressed to the appropriate authorities, that is to say the

17 then-Presidency of Bosnia-Herzegovina.

18 Q. Tell me, why did you need weapons at the time, that is to say in

19 the spring of 1991? There were no conflicts then. How did you know there

20 would be some kind of conflict? Why did you need weapons then?

21 A. Well, Mr. Milosevic, what was asked for was a legal increase in

22 the police force, because our area, Bosanska Krajina, had been

23 destabilised a lot earlier before the war conflict actually started in

24 Bosnia-Herzegovina. Due to the conflicts in Croatia, all of this was

25 reflected in our area, Bosanska Krajina, and almost for one year people

Page 29599

1 could not travel through the part of Croatia called the Serb Krajina.

2 Some people were even killed when they tried to travel through that area.

3 Q. When you say that you linked this to what happened in Krajina, let

4 me mention something that did not happen in Krajina, that happened in your

5 region, as a matter of fact. You certainly remember when the following

6 happened: In 1991, in Bosanska Krupa, when a monument disappeared, the

7 monument dedicated to the author Branko Copic, and it was supposed to be

8 placed close to the public security station building and it simply

9 disappeared.

10 A. The monument did not disappear, Mr. Izetbegovic [sic]. It cannot

11 be treated that way. This is something that happened actually at the

12 beginning of 1991.

13 The dispute over the monument started because the permit to place

14 the monument there had been issued against the law, illegally. All of

15 this was done by the then-president of the SDS, Miroslav Vjestica, as

16 secretary of the Secretariat for Social Services.

17 Q. All right. Already twice you've addressed me as Mr. Itzetbegovic.

18 It's probably your subconsciousness speaking. You probably have some

19 reason for that.

20 A. Well, probably I do.

21 Q. All right. You're trying to say that this was organised by the

22 secretary of the Secretariat for Social Services. Is it true that the

23 monument was stolen from the very centre of town during the night?

24 A. Of course that's not right.

25 Q. Well, what happened to the monument?

Page 29600

1 A. As I've already said, the monument never existed. When the

2 preparations started to build the base for the monument, a procedure was

3 started to annul the permit that had been issued illegally. So then the

4 authorities in charge said that the entire activity should be halted.

5 Just before the first church service was supposed to be held in

6 the Orthodox church in Bosanska Krupa - and I can't remember exactly on

7 which date this was - persons unknown left a bust of Branko Copic right

8 next to the place where the works had started. As far as I can remember,

9 this bust was removed by the authorities in charge in a legal way.

10 Q. Is it true that this led to inter-ethnic tensions because of which

11 a meeting was held among the leadership of Bosnia-Herzegovina attended by

12 Alija Izetbegovic, Momcilo Krajisnik, Ejub Ganic, Avdo Hebic [phoen],

13 Halil Delimustafic, Mehmed Mahic, and Suad Alibegic, officials from your

14 municipality; is that right?

15 A. Yes. There were certain tensions. I think that that is why the

16 whole thing was prepared as such, to bring yet another thing into the

17 situation that prevailed at the time that would lead to further

18 destabilisation.

19 Actually, the representatives of the SDS and the local

20 representatives of the Orthodox church in Bosanska Krupa visited the

21 Presidency of Bosnia-Herzegovina, and they launched the initiative to have

22 such a meeting held. The meeting was not actually held in the Presidency

23 of Bosnia-Herzegovina because the representatives of the SDS did not wish

24 to participate in the meeting until the then-president of the SDS of

25 Bosnia-Herzegovina, Mr. Karadzic, withdrew the statements that he made on

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Page 29602

1 TV Bosnia-Herzegovina in this respect, and what he said was wrong. As far

2 as I know, only a press conference was held.

3 Q. As far as I know, Mladen Drljaca, a Serb, attended this meeting

4 and for a while he was secretary of the municipality of Bosanska Krupa; is

5 that right?

6 A. I repeat yet again there was no official meeting held, only a

7 press conference was held. As for Mladen Drljaca, Mr. Mladen Drljaca, I

8 know him personally, I do not remember that he was present there. I don't

9 remember him coming to Sarajevo, because I was one of the representatives

10 of the SDA from Bosanska Krupa.

11 Q. So you attended the meeting?

12 A. I attended the press conference, Mr. Milosevic.

13 Q. All right. Do you know, then, since this was not held as an

14 official meeting, that Ejub Ganic at this meeting, not knowing that Mladen

15 Drljaca was a Serb, said to Mehmed Mahic that, "All these Serbs should be

16 cleansed." Did Mahic inform you about that?

17 A. Mr. Milosevic, Mahic Mehmed was not present at this press

18 conference, and he was not on the delegation of the SDA of Bosanska Krupa

19 that was supposed to participate at the planned meeting. As a matter of

20 fact, we concluded in Bosanska Krupa that it would not be right for the

21 official representatives of the authorities from Bosanska Krupa to attend

22 the meeting because that could be interpreted as pressure against these

23 representatives of the authorities in resolving this particular case. So

24 practically only Mr. Kabijevic [phoen] and I were sent to attend this

25 meeting.

Page 29603

1 Q. I'm asking you whether you know that Ejub Ganic then said that all

2 these Serbs should be cleansed.

3 A. If there was no meeting, that means that I cannot be aware of what

4 you say just now.

5 Q. So if you don't know, then just say that you don't know and let's

6 move on.

7 On the same day after the meeting was held, the monument was found

8 at the chapel of the municipal cemetery in Bosanska Krupa.

9 A. After a meeting that was held in Bosanska Krupa itself, this was a

10 day before the church service at the Orthodox church, the bust of Branko

11 Copic was handed over to the gentleman who had actually financed the

12 building of the monument. He actually ordered this bust. He commissioned

13 it. And I assume that this was at the chapel of the cemetery in Bosanska

14 Krupa.

15 And also, there was a written argument -- agreement that he should

16 keep the bust in his garage.

17 Q. In paragraph 2, page 6, you refer to what happened in the village

18 of Arapusa. You call it an incident.

19 A. Yes, I remember that.

20 Q. You say that on that occasion that there was a bit of shooting and

21 that a young Serb was wounded.

22 A. Yes. I heard about this indirectly. Mr. Mehmed Mahic, president

23 of the municipal Assembly, was involved in the entire course of these

24 talks, and I can only convey the information I learned from him.

25 Q. But you certainly know that three young Serbs were wounded,

Page 29604

1 gravely at that, from firearms.

2 A. I'm not aware of that, Mr. Milosevic. As I said, I can only have

3 information that I received from others in this regard.

4 Q. When you say some shooting, but -- that means an exchange of

5 gunfire, but these young men were ambushed. There was no exchange of

6 gunfire. Don't you know that?

7 A. According to the information I received, there was some shooting.

8 It was a skirmish because this happened during the night. Arapusa was a

9 village that was populated by Bosniaks only. These young men, who were

10 driving in a car through the village, came a cross a checkpoint of the

11 reserve police force. As far as I was informed, there was a skirmish,

12 there was an exchange of gunfire.

13 Q. In this same paragraph on page 6, you say that this was staged by

14 the SDS in order to cause an incident.

15 A. That is what I believed then, and I still believe that.

16 Q. So you believe that the SDS sent young Serbs to a Muslim village

17 and also that the SDS sent members of the Muslim police force to go to

18 that village and to shoot at these young Serbs and to seriously wound or

19 kill these young Serbs, because those men who were in the ambush could not

20 have known whether they killed them or not, so that they could afterwards

21 attack Bosanska Krupa. So is that what you're trying to say?

22 A. That's not what I said and that's not what I'm trying to say.

23 Q. You say the SDS staged this. So they sent these young men there

24 and they probably sent the Muslim police to shoot at them.

25 A. These are speculations, Mr. Milosevic.

Page 29605

1 Q. How can it be speculation if it says in paragraph 2, page 6, that

2 it was staged by the SDS, this shooting at the young Serb men?

3 A. I think I've already answered this question. If you need

4 additional explanation, I would kindly ask you to say so.

5 Q. All right. Your brother knew then and knows now who exactly shot

6 at these young men, but nothing was ever done. The police was under his

7 command. Nothing was done to arrest the perpetrators and to calm down the

8 inter-ethnic tension that resulted.

9 A. As far as I know, Mr. Milosevic, this incident took place two days

10 before the attack on Bosanska Krupa. Whether measures had been taken

11 against these reserve policemen, I don't know, because already on the 21st

12 of April -- and I must say that in the meantime, between the 19th and the

13 21st of April, SDS representatives did not show up for planned meetings

14 and negotiations in Bosanska Krupa, and I had no information from them.

15 Q. All right. But you say in another paragraph on page 6 that the

16 SDS reacted to this incident by sending their paramilitaries to this

17 village to surround the village. Was it an organised action of the

18 paramilitaries of the SDS or was it just a spontaneous reaction of the

19 local residents?

20 A. As I said, a representative of the municipality of Bosanska Krupa

21 went immediately to that village on a visit - I'm speaking about Mehmed

22 Mahic, president of the Municipal Assembly of Bosanska Krupa - and from

23 talking to him, I learned that he toured the village in the presence of

24 Gojko Klickovic, president of the Crisis Staff that had been formed by the

25 SDS. When they were touring the village, they were able to clearly see,

Page 29606

1 in fact, Mr. Mahic clearly saw armed paramilitaries, and he had the

2 impression that they were commanded by Mr. Klickovic. He even told me

3 that when touring this area, one of the members of the paramilitary units,

4 whether deliberately or not, fired a volley of automatic fire.

5 Q. But during this siege, as you call it, nobody was wounded or

6 killed. The only demand was made to surrender to the police, and I

7 repeat, the police, not local residents, the perpetrators of the crime

8 against young Serb men.

9 A. The people who were responsible for this incident - and I'm not

10 going to call it a crime - were available to the police from the very

11 beginning, but I cannot agree with you when you say that in this operation

12 of the paramilitaries, the Serb paramilitaries, nobody was killed.

13 Arapusa remained under seige for the next two days and even after

14 the attack on Bosanska Krupa. All civilians were subsequently driven away

15 from their homes, and some people, at least two of whom I can name, went

16 missing. They were taken to concentration camps and were never seen

17 again. These two people are Ibrahim Ibrahimovic, and Sulejman

18 Ibrahimovic.

19 Q. I don't know about these camps.

20 JUDGE MAY: You have two minutes left now, Mr. Milosevic.

21 THE ACCUSED: [Interpretation] I will do my best.

22 MR. MILOSEVIC: [Interpretation]

23 Q. I would appreciate short answers, Mr. Velic. I have just a few

24 more questions. It will take two or three minutes.

25 On the 21st of April, 1992, a meeting was held in Bosanska Krupa

Page 29607












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Page 29608

1 to discuss this incident, and it was attended by General Spiro Ninkovic

2 from the 10th Banja Luka Corps.

3 A. Well, not exactly. It was his liaison officer who arrived. I

4 don't know his name. He was a captain by rank. And Mr. Spiro Ninkovic

5 turned up just in time for the beginning of the meeting. He did not want

6 to attend the meeting, he only wanted to talk to the president of the

7 Assembly, Mr. Mehmed Mahic.

8 Q. All right. Is it true that he came to Bosanska Krupa to talk to

9 the local authorities who were then located in Jasenica village in order

10 to convey the position, the message of Blagoje Adzic, chief of the General

11 Staff, that every effort must be made to defuse the tensions that occurred

12 after the incident of the killing of Serb men?

13 A. I cannot say that, but I can say that Mr. Ninkovic left the

14 building accompanied by Mr. Mahic, and he went on to visit the village of

15 Vranjska and Jasenica. However, a couple of minutes after Mr. Mahic

16 returned to the building, the shelling of Bosanska Krupa began precisely

17 from that direction.

18 Q. Is it true that two kilometres away from the entrance to Bosanska

19 Krupa the vehicle containing Ninkovic and his entourage came under fire

20 from automatic weapons?

21 A. I don't know that that is true. Muslim positions did not exist

22 then. There was only a police checkpoint at the exit from the town. He

23 passed through that checkpoint accompanied by Mr. Mahic.

24 Q. Precisely during -- due to the fact that fire was opened against

25 him, he wanted to be escorted.

Page 29609

1 A. I'm not aware of that.

2 Q. It was then, as you say, that the attack on Krupa occurred, and

3 shooting continued throughout that night.

4 A. Well, the shooting lasted for about an hour, and then there was a

5 lull. There were no more activities, no more operations during the night,

6 and the shelling resumed at 6:00 a.m. the next morning.

7 Q. Who was it who opened fire at Bosanska Krupa then?

8 A. I cannot name any names and I cannot tell you anything specific; I

9 can only tell you what I think.

10 Q. All right. So you didn't see anything. But is it clear to you

11 that it wasn't the JNA that was firing?

12 A. My opinion is that it was the armed formations of the SDS firing

13 from guns of the JNA.

14 JUDGE MAY: This must be your last question.

15 MR. MILOSEVIC: [Interpretation]

16 Q. So it was not the JNA that attacked the town. On the contrary.

17 At the meeting of the 25th of April attended by Fikret Abdic, Miroslav

18 Vjestica, and others, General Spiro Ninkovic suggested that neutral areas,

19 neutral zones, be established to prevent this from re-occurring.

20 A. I attended another meeting in Bosanski Petrovac which was another

21 attempt to discuss the case of Bosanska Krupa. This meeting in Bosanski

22 Petrovac was indeed attended by General Spiro Ninkovic as well as Fikret

23 Abdic. The talks that took place at that meeting were too vague,

24 unspecific. General Spiro Ninkovic did speak about some kind of role for

25 the army, but he made no specific proposals. We thought that the case

Page 29610

1 could be resolved within the institutions of the system without any

2 participation or involvement of the JNA.

3 JUDGE MAY: That's your last question.

4 Yes, Mr. Tapuskovic.

5 MR. TAPUSKOVIC: [Interpretation] Your Honours, I believe that

6 there is one thing that remains unclarified with regard to the statement

7 of this witness.

8 Questioned by Mr. Tapuskovic:

9 Q. [Interpretation] If you would be so kind, Witness, look at the

10 last paragraph on page 8 where you spoke first about the meeting between

11 the SDS and the SDA, which turned out to be the last meeting. You did not

12 mention any negotiations with the JNA, and then you say: "The front lines

13 around Bosanska Krupa narrowed. The town was divided into two parts. The

14 Una River became a front line. In that period, there were no serious

15 attempts on the part of Serbian forces to capture the left bank. They

16 seemed to be content with the territory they held at the moment."

17 And then you mention further on that you discussed possible ways

18 of defending yourself.

19 My question is: This defence line, this front line, existed

20 between your forces and the forces of the SDS, that is your paramilitaries

21 and their paramilitaries; is that correct?

22 A. Excuse me. My microphone wasn't working. "Front line" is not a

23 term I would use, and it certainly does not correspond to the situation on

24 the ground in Bosanska Krupa at the time.

25 You say that the participation of the JNA in that meeting is not

Page 29611

1 mentioned, but what is mentioned is the presence of General Ninkovic and

2 his specific proposals.

3 As for front lines, they did not exist in the true military sense

4 of the word. There were only police forces in Bosanska Krupa who were

5 disorganised over a period of three or four days that followed, and there

6 was a certain number of volunteers, if I can call them that, who

7 self-organised in order to defend the town. I can accept that the

8 remaining part of your quotation is true.

9 Q. But you do speak about front lines and the division of the town in

10 two parts. Then you say in the next paragraph they managed -- in fact:

11 "We managed to hold these lines until November 1992. Serbs moved to the

12 left bank and captured some parts of the town."

13 Could you explain this?

14 A. I can. After a few days in which chaos reigned in that part of

15 the town on the left bank of the Una River, the population of Bosanska

16 Krupa withdrew to the left bank of the Una River, and that situation

17 continued for the few months that followed. And then the events that I

18 mentioned already occurred. I wasn't in town any more, but the

19 information that I quoted here is information I received from others who

20 did live there.

21 Q. Because at that time, you were in the War Presidency of

22 Bosnia-Herzegovina, which was located in Zagreb at the time. Is that

23 true?

24 A. This is a completely wrong interpretation of what I said. I was

25 in Zagreb according to the decision of the War Presidency of Bosanska

Page 29612

1 Krupa. I was sent to Zagreb on a certain mission.

2 Q. So it's not true if it says here: "I left Bosanska Krupa in

3 November 1992. I was sent to Zagreb to work in the War Presidency."

4 A. That's not true. The War Presidency was located in Bosanska

5 Krupa. It should say, "... according to the decision of the War

6 Presidency." I don't know how this error found its way into my statement.

7 MR. AGHA: Yes, Your Honours. With permission, I'd just like to

8 ask a few questions in re-examination

9 Re-examined by Mr. Agha:

10 Q. Mr. Velic, in your evidence you mention that you were shown a

11 study on the administration division of Bosanska Krupa as being the first

12 steps in creating a Balkan state. Do you remember that study? Now, how

13 many other municipalities were shown similar studies like that?

14 A. Yes, I did mention that study which in everyday talk we referred

15 to as the feasibility study on the division of the Bosanska Krupa

16 municipality. The official title was probably different.

17 It was not a step towards forming a phantom state. It said in the

18 first paragraph of the study it was -- it said it was the first step to

19 the establishment of the first unified Serbian state in the Balkans. I

20 later learned that a similar study was done for the municipality of Bihac,

21 and in subsequent informal contacts, I found out that in municipalities

22 with mixed population - mixed consisting of Serbs, Croats, Bosniaks, and

23 others - the SDS suggested and offered similar studies.

24 Q. Now, I think this is quite an important point which the Trial

25 Chamber would like to know about, and being a lawyer and one of the

Page 29613












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Page 29614

1 leading SDA people, perhaps you can help. You refer in your evidence that

2 there was a decision of the Bosnia-Herzegovina Presidency that no one

3 should join the JNA. At that time, which ethnic groups made up the

4 Bosnia-Herzegovina Presidency?

5 A. Yes. That happened during the events in Croatia in 1991. At that

6 time, there were seven members of the Presidency of Bosnia-Herzegovina,

7 including representatives of the three constituent peoples, because there

8 were three constituent peoples at that time, Serbs, Muslims, and Croats,

9 plus one representative of the group called Yugoslavs; that is, there were

10 seven members in total.

11 Q. Now, that decision, who was it legally binding on in the Republic

12 of Bosnia-Herzegovina?

13 A. That decision of the Presidency of Bosnia and Herzegovina was, of

14 course, binding on all authorities in Bosnia and Herzegovina that were

15 subordinated to the Presidency including, of course, Secretariats for

16 National Defence in various municipalities.

17 Q. So that would include the Muslim, Serbian, and Croatian

18 population; everybody?

19 A. Certainly, because the authorities, the bodies of administration,

20 the bodies of government in Bosnia and Herzegovina, were unified and

21 single, and they were elected after multi-party elections in 1991.

22 Q. Now, I have one final question for you, is that you mention that

23 the mosque and the Catholic church on the bank of the Una, which the

24 Serbian forces were occupying at Bosanska Krupa, were destroyed. What was

25 the fate of the Orthodox church?

Page 29615

1 A. Well, the buildings that you mentioned are at most 100 metres away

2 from each other in Bosanska Krupa. The mosque was set on fire as soon as

3 Serb forces entered Bosanska Krupa. The Catholic church was destroyed

4 under circumstances that I'm not familiar with because I only saw that

5 when I returned to Bosanska Krupa after the war, and the Serbian Orthodox

6 Church remained intact, in the condition in which it is still today.

7 MR. AGHA: That completes my re-examination.

8 JUDGE MAY: Thank you. Mr. Velic, that concludes your evidence.

9 Thank you for coming to the International Tribunal to give it. You are

10 now free to go. If you would just wait one moment.

11 [The witness withdrew]

12 JUDGE MAY: Yes.

13 THE ACCUSED: [Interpretation] I want to avail myself of this idle

14 time to ask you a question. I received this schedule. It says 9th

15 December to be decided. Are we sitting on the 9th or not? I am not clear

16 on that, because I need to know for purposes of my own planning.

17 JUDGE MAY: That is undecided. It depends on the health of Judge

18 Robinson. You should keep it clear for sitting. If he is fit enough, we

19 will sit. Otherwise, we won't. But I'm afraid we can't make a firm

20 decision on that because, as I say, it depends on his health.

21 MR. NICE: Your Honours, the next witness -- I'm not sure whether

22 we're in private or open session.

23 JUDGE MAY: We're in open session.

24 MR. NICE: We can be in open session, there is no problem. The

25 next witness --

Page 29616


2 MR. NICE: The next witness is Mr. Deronjic. We haven't made a

3 formal written application to have his statement admitted under 89(F).

4 The Chamber will possibly recall that we first, I think, provided draft

5 copies of his statement before the order to make written applications was

6 made, and we didn't get a final signed version until yesterday.

7 The position on disclosure of his material is as follows: Leave

8 was granted to call him on the 16th of October, and in anticipation of

9 that, transcripts of his interviews have been disclosed on the 10th of

10 October. The first draft of his statement in English was provided on the

11 13th of November, and much of that cross-referred to his interviews.

12 Another draft in English and B/C/S was provided on the 24th of November.

13 The witness signed the statement with minor amendments yesterday, and that

14 was provided in English and B/C/S yesterday, the Chamber having had the

15 earlier draft version and having had, I hope now by the form of a

16 memorandum, a notice of the very limited changes to some six paragraphs.

17 JUDGE MAY: Yes. We will admit the statement.

18 MR. NICE: Your Honour, I'm very grateful. The statement deals

19 with a large number of matters. The witness has given evidence twice

20 recently publicly, once as recently as last week. In the interests of

21 saving time, and unless the Court orders otherwise, I would not propose

22 necessarily to take him through any of his evidence in chief, although I

23 might ask him simply one or two general questions and get him to produce

24 one exhibit additional to those that have already been produced by other

25 witnesses. I don't know if that approach is acceptable to the Court.

Page 29617


2 MR. NICE: May the witness come in.

3 [The witness entered court]

4 JUDGE MAY: Yes. Let the witness take the declaration.

5 THE WITNESS: [Interpretation] I solemnly declare that I will speak

6 the truth, the whole truth, and nothing but the truth.

7 JUDGE MAY: If you'd like to take a seat.


9 [Witness answered through interpreter]

10 Examined by Mr. Nice:

11 Q. Can you give us your full name, please.

12 A. My name is Miroslav Deronjic.

13 Q. Mr. Deronjic, it's a matter of public record that you have entered

14 pleas of guilty at this Tribunal in respect of an indictment and are

15 awaiting sentence in respect of matters to which you've pleaded guilty;

16 correct?

17 A. Yes, that is correct.

18 Q. You've already given evidence before component parts of this

19 Tribunal on two previous occasions and have cooperated with the Tribunal

20 in the preparation of an extensive witness statement, now in some 232

21 paragraphs.

22 A. Yes, that is correct.

23 Q. You reviewed that statement in your own language in the course of

24 the last couple of days and signed a version of it and signed every page

25 of that version yesterday?

Page 29618

1 A. Yes, that is also correct.

2 Q. And is that statement and its contents true and accurate to the

3 best of your knowledge and belief?

4 A. This statement is completely accurate, and I agreed to sign it as

5 a completely accurate statement.

6 JUDGE MAY: Yes. It should be given the next exhibit number.

7 THE REGISTRAR: Exhibit 600, Your Honours.


9 Q. In the course of your statement, you identify really four

10 exhibits, three of them exhibits that have been produced before.

11 MR. NICE: And, Your Honours, for purposes of ease of reference,

12 can I deal with those.

13 Q. At paragraph 45, Mr. Deronjic, you dealt with the question of

14 Variant A and B municipalities, as described, and with instructions that

15 had been disseminated.

16 MR. NICE: And, Your Honour, that's Exhibit 434, tab 3. I don't

17 desire to go through it, I'm just doing this for identification purposes.

18 Q. At paragraph 68 of your statement, you dealt with the question of

19 the strategic goals of the Serbian people in Bosnia-Herzegovina, and the

20 document that sets out those strategic goals is Exhibit 451, tab 12.

21 At paragraph 224, just to deal with exhibits already produced, you

22 dealt with the document signed eventually by Mr. Franken after he'd

23 amended it. And we've heard from Mr. Franken recently, and that document

24 is Exhibit 591, tab 9.

25 Have you reviewed those three exhibits and do you confirm that

Page 29619












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Page 29620

1 those are the documents to which you were referring?

2 A. Yes. I looked at all three documents, and these are the documents

3 that you referred to just now.

4 MR. NICE: Your Honour, I'm not - it's my mistake. I'm not --

5 Q. I should tell you, Mr. Deronjic, that the Trial Chamber has agreed

6 to accept your statement in full as your evidence-in-chief so that I'm

7 going to be asking a very limited number of questions and we'll be moving

8 rapidly to cross-examination. But before I do that, there is the one

9 additional exhibit that I want to produce through you, and you're entitled

10 to look at your witness statement at any point, subject to the decision of

11 the Trial Chamber, if you wish to. And at paragraph 206, dealing with

12 both the evacuations and executions that occurred on the 13th of July,

13 1995, you speak of a phone call that you made to Karadzic. And if you

14 please look at the exhibit that is presently before you, which is a

15 transcript of an intercept of a telephone conversation between you and

16 Karadzic, have you reviewed the transcript of that intercept?

17 A. Yes, I have reviewed that transcript.

18 Q. Are you in a position to help us whether that appears to be an

19 accurate transcript of a conversation you had with Karadzic?

20 A. Yes. This is an accurate transcript of the conversation that I

21 had with Mr. Karadzic on the 13th of July.

22 MR. NICE: If the usher would be good enough just to place the

23 first page of the English version of this on the overhead projector.

24 Q. Mr. Deronjic, we find in this transcript of the intercept

25 reference to -- at the bottom of the page if we see it, part of the

Page 29621

1 conversation goes -- "Can you hear me, President?" Somebody saying, "The

2 president can't hear, Deronjic, this is the intermediary." And you

3 saying: "I have 2000 here now by ..." and then your voice was drowned

4 out, and then X says: "Deronjic, the president says: 'All the goods must

5 be placed in the warehouse before 12 tomorrow.'" "Right." X says:

6 "Deronjic, not in the warehouses but somewhere else." You say,

7 "Understood." And if we can then go to the next page. It says: "I'm

8 waiting for a call to President Karadzic. Is he there?" "Yes." "Hello.

9 Just a minute, the duty officer will answer you now, Mr. President."

10 "Hello, I have Deronjic on the line," and then you speak to him.

11 "Hello. I can hear you." "Deronjic, the president is asking how many

12 thousands." You say: "Two for the time being but there will be more

13 during the night."

14 Now, what was being referred to as goods and by the number of

15 2.000, if you can help us, please.

16 A. The goods that are mentioned, or the 2.000 mentioned in terms of

17 figures, pertained to the imprisoned Muslims who were brought to Bratunac

18 during the night of the 13th, and they were put up at various localities

19 including the elementary school, the hangar, the stadium, and so on.

20 MR. NICE: May this transcript of an intercept be admitted, either

21 fully admitted or admitted for identification purposes, but the

22 acknowledgement by the witness of its accuracy may take it into the

23 position of being an exhibit that can be fully produced.

24 [Trial Chamber confers]

25 JUDGE MAY: At this stage we're going to mark it for

Page 29622

1 identification because we're going to have evidence about these intercepts

2 in due course.

3 MR. NICE: Certainly.

4 JUDGE MAY: Yes, give it the next number.

5 THE REGISTRAR: 601, Your Honour, marked for identification.

6 THE ACCUSED: [Interpretation] Mr. May.


8 THE ACCUSED: [Interpretation] Perhaps I'm mistaken, but I have not

9 received either on tape or on CD this intercepted conversation, so I would

10 kindly ask to have this provided for me if it exists.

11 JUDGE MAY: Mr. Nice.

12 MR. NICE: I'll deal with that over the break and check whether

13 it's one of those that has been provided; and if not, I'll find out why

14 not.

15 Q. Mr. Deronjic, your statement, which is now an exhibit in the case,

16 covers a range of matters from the arming of the Serbs to your particular

17 position as commissioner at Srebrenica and so on. Can you help us,

18 please, by giving, just in a few sentences because you're an educated man,

19 a teacher, of all these events, can you, just in a few sentences, survey

20 the relevant history and explain how it was that people such as you came

21 to be involved in these events. And without leading you but simply

22 reminding you how you've described it in the past, I think you've used the

23 word "spiral" or spiral of events. If you could do it in a few minutes,

24 perhaps up to five, I think that would be very helpful for us.

25 A. Yes, Your Honour. I will try to answer this question. You have

Page 29623

1 noticed that my statement contains events ranging over a period of almost

2 five years, that is to say from 1990 until 1995. In that statement, I

3 tried to focus on the events that I participated in directly, namely the

4 events in Bratunac with reference to what was happening in the

5 neighbouring municipalities to the extent to which I followed these events

6 and was aware of them.

7 Also, I gave a broader survey of political activities, from the

8 lowest level, where I acted for the most part, all the way up to the top

9 level where I took part in 1993 as a member of the Main Board of the SDS.

10 Of course that is a question that preoccupied me, like many other people:

11 What really happened in that area, including the entire area of

12 Bosnia-Herzegovina?

13 As I made this statement, I actually wanted to testify about the

14 following: First and foremost, the events that took place are well known,

15 and the political concepts of the Serbs, Muslims, and Croats are well

16 known in the early 1990s in the absolute crisis that the former Yugoslavia

17 was engulfed in.

18 What led me and many people to take part in these events were the

19 plans that were fully public in their first stage. Now I'm talking about

20 the plans of Serbs in Bosnia-Herzegovina. They pertained to the need that

21 all Serbs should remain together in one state. At first this was an

22 endeavour to preserve a single Yugoslavia, and after that, these plans

23 were somewhat changed as events developed. This is something that is well

24 known in this Tribunal as well.

25 What did I try to show now throughout my statement: First and

Page 29624

1 foremost, that these public plans that I was involved in too from 1991

2 onwards, actually related to the establishment of an entity of the Bosnian

3 Serbs in the area of Bosnia-Herzegovina. They are known as the plan to

4 create Republika Srpska. This was a public plan. There were many

5 manifestations related to this plan. This was recorded in the media, in

6 speeches made by top people, including some of the activities I had at

7 local level primarily in the area where I lived and worked.

8 These plans involved certain stages in their implementation. At

9 first it was communities of municipalities that were established and later

10 on they grew into those well-known Serb autonomous regions. There were

11 five of them in Bosnia-Herzegovina. They were formed in the period of

12 1991, and in the autumn they were verified at an Assembly, at a Serb

13 Assembly, as regions that were roughly supposed to grow into this Serb

14 entity in Bosnia-Herzegovina.

15 Towards the end of 1991, I took part in these events to an extent

16 to which this surprised most people who were -- there were some measures

17 involved that surprised most people who were involved in political

18 activities in those days. These were the first secret measures that were

19 taken and that were supposed to contribute to the attainment of this

20 objective, namely the establishment of a Serb entity in

21 Bosnia-Herzegovina. This Tribunal knows about them as Variants A and B.

22 This is what all the party authorities of the SDS in the former

23 Bosnia-Herzegovina received this at the time, with the obligation of

24 carrying this out in the field.

25 These political orders were strictly confidential, highly

Page 29625












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13 English transcripts.













Page 29626

1 confidential, and it was the first time ever during my involvement in

2 politics that I then received this kind of paper that was strictly

3 confidential and marked as such. Namely, it was the executive and

4 legislative branches that were supposed to be divided in municipalities.

5 This primarily had to do with minority municipalities. When I say

6 "minority municipalities," that is where Serbs were minority, and there

7 were such municipalities. Bratunac, Zvornik, Srebrenica, Visegrad, not to

8 mention any others. This was within the Serb autonomous regions that I

9 spoke of earlier on.

10 After that, and I have to say this for the sake of the truth,

11 people in various areas interpreted this in different ways and implemented

12 it in different ways. There was even resistance to it, and people tried

13 to adjust to the local situation. And I described the way in which I

14 carried out these instructions. This was a rather special way. I carried

15 out this in Bratunac in the joint Assembly in agreement with

16 representatives of the Muslims in the joint Assembly of the municipality

17 of Bratunac. I just insisted on the singling out of one particular group,

18 and that was the police in Bratunac.

19 So I know that there were special situations in Zvornik too. I

20 knew the leadership very well there too and also in some other

21 municipalities.

22 In this situation, the beginning of April 1992, certain military

23 formations known as the volunteers of Arkan's guard arrived in these areas

24 as well as Seselj's volunteers, and so on and so forth, not to mention all

25 of them. They arrived in the Drina region and some other areas of

Page 29627

1 Bosnia-Herzegovina, and they caused conflicts.

2 For many people, this came as a surprise. I'm not going to talk

3 about myself now but I know some of the things that happened in Zvornik,

4 some of the things that happened in Bijeljina. I know that some Serb

5 leaders were arrested, beaten, kept in prison, tortured, et cetera. So

6 this was a radical stage in the inter-ethnic relations in that area,

7 including the municipality of Bratunac.

8 When these people arrived, they were supposed to constitute a

9 secret part of these plans. So a certain number of people, I cannot say

10 how many, within the SDS leadership itself was not aware of such plans.

11 What happened later, in my opinion, is only a matter of cause and

12 consequence in the area, cause and effect.

13 Quite briefly, when these volunteers in these units from Serbia

14 came to the area, they started killing people, looting. They brought

15 panic to these municipalities, and the inter-ethnic relations that were

16 already threatened led to growing fear and predominantly Muslims started

17 fleeing from the area.

18 Now I'm going to focus on Bratunac because I am most familiar with

19 the situation there. It was to be expected that the Muslims would not

20 simply sit and watch all these things that were happening. Soon after

21 these people came to this region, Naser in Srebrenica, in the village of

22 Potocari, on the 20th of April ambushed these units and killed these men.

23 I don't know exactly how this incident occurred but I know that basically

24 most of the men were killed in this ambush, or practically all of them

25 were killed in this ambush, as far as I know.

Page 29628

1 After that, Goran Zekic was killed, who was one of the leading

2 Serbs in the area, in Srebrenica, on the 8th of May. And then on the 9th

3 of the May we already took some steps, and I explain these in detail in my

4 guilty plea or, rather, in the sentencing brief. All of this led to this

5 cause and effect that I already said, and that is how things evolved.

6 Already in 1992, after everything we did in Bratunac, then the

7 Muslims from Srebrenica took action. They attacked the area of Bratunac.

8 There was a lot of fighting there. Great territories were taken, there

9 were many casualties, military and civilian. In 1993 a counter-offensive

10 of the Serbs started in the area of Srebrenica, and then the well-known

11 Morillon affair, and Srebrenica was proclaimed a safe haven of the UN,

12 safe area, on the 13th of April, 1994.

13 In 1994, both sides made efforts to take the entire area. Muslim

14 area -- Muslim forces from Srebrenica made incursions in the Serbia area.

15 Also I managed to see here some orders of lower level and higher level

16 commands, orders issued to Serb forces around Srebrenica. All of this

17 testified to the fact that these people in the safe area were -- their

18 life was supposed to be made impossible by all means.

19 The logical effect -- I say unfortunately this is the logical

20 effect, and I'm not saying it's a normal thing, that was the offensive of

21 the Serb forces in 1995, the attack on Srebrenica and the denouement that

22 occurred. That is a fact that is well known. Several thousand imprisoned

23 Muslims in the area were killed.

24 I wish to show that what happened in Bratunac in the Drina region

25 and in the municipalities that I knew developed according to a domino

Page 29629

1 effect principle. People came from Serbia to that area that had already

2 been hampered by these different political concepts, and inter-ethnic

3 relations were already quite bad, and all of this led to what happened

4 afterwards. And in my opinion, Srebrenica 1995 is a logical finale, the

5 only thing that could be the result of these events.

6 I'm sorry if I took up a lot of time, but this is a very complex

7 issue, and I wanted to cover all these developments in my statement.

8 Q. Dealing simply with that last --

9 THE INTERPRETER: Microphone for Mr. Nice, please.

10 MR. NICE:

11 Q. Dealing simply with your last observation about Srebrenica 1995

12 being a logical finale, the only thing that could result, is that

13 something that you've simply judged looking back or was it something that

14 was in your mind as an observer at the time?

15 A. Your Honour, of course I was a participant in most of these

16 events, and I explained this in my statement in a very precise manner. Of

17 course I thought about everything that was going on during the war as

18 well. But I drew a great many conclusions after all these events when I

19 had the opportunity of having contacts with the Office of the Prosecutor

20 that went on from 1997 onwards. I saw a series of documents which

21 explained the situation that I was in from various other aspects. Most of

22 these documents, orders, et cetera, were things I was not aware of at the

23 time when I was engaged in my work that had to do with the war conflict

24 itself.

25 Q. I'm not sure that that answers the question, but you say --

Page 29630

1 whether you thought about these things at the time and thought that

2 something like this was going to happen or not, but if you don't want to

3 answer further, I won't press you.

4 A. I have said that I realised many things during the war itself but

5 that I finally came to my own conclusions after the war operations in the

6 area ended.

7 Q. Thank you very much.

8 MR. NICE: Your Honour, I see the time. I'm slightly undecided in

9 my own mind whether the Court, having allowed the whole statement to go

10 in, it would be appropriate for me to go through any of the paragraphs.

11 At most I have about four that I might ask the witness to deal with, but

12 can I deal with that after the break, if it's appropriate. Otherwise, we

13 will just let the statement stand and move straight to cross-examination.

14 JUDGE MAY: Yes. We'll adjourn now for the break.

15 Mr. Deronjic, during your evidence, don't speak to anybody about

16 it, please, until it's over, and that does include any members of the

17 Prosecution.

18 We will adjourn now for 20 minutes

19 --- Recess taken at 10.30 a.m.

20 --- On resuming at 10.53 a.m.

21 JUDGE MAY: Yes, Mr. Nice.

22 MR. NICE: With Your Honours' leave, I'll identify about six

23 points of evidence in the witness's statement to give additional context

24 for those viewing who haven't read the statement.

25 Q. Mr. Deronjic, if you would be good enough just to look at the

Page 29631












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Page 29632

1 appropriate paragraph numbers as I come to them, starting at paragraph 8

2 where you're dealing with the arming of the Serbs. You speak of what

3 Karadzic told you about a conversation he had with the accused Milosevic

4 about the arming of the Serbs; correct?

5 A. Yes, Your Honour, that is correct.

6 Q. And as you put it, what had Karadzic achieved in the discussions

7 with Milosevic about the arming of the Serbs? What had he achieved?

8 A. At that meeting in the village of Milici attended by Dukic,

9 Mr. Zekic, and myself, Mr. Rajko Dukic uttered the following sentence: He

10 said that Mr. Karadzic personally convinced Mr. Milosevic that Serbs in

11 Bosnia and Herzegovina should be armed. I later had the occasion, and I

12 don't remember the exact date or the form of the meeting with Karadzic, to

13 hear that said from his own mouth, namely that he had persuaded

14 Mr. Milosevic that Serbs in Bosnia and Herzegovina should be armed.

15 There was some degree of disagreement about the involvement of the

16 army in the possible resolution of the crisis, and I think that is why

17 Mr. Karadzic wanted Serbs in Bosnia and Herzegovina to be armed. That is

18 what I meant when I said what I said in this paragraph.

19 Q. Thank you very much. Paragraph 63. You made an observation about

20 the pattern of events and the takeover of municipalities where volunteers

21 came first, killings, liquidations, and intimidation followed, and the JNA

22 arrived thereafter but in a short period of time; and your inference from

23 the pattern of events occurring in more than one place was what?

24 A. Yes. I called it a scheme of developments in Eastern Bosnia, and

25 I am referring to Eastern Bosnia because that's the area I'm most familiar

Page 29633

1 with.

2 There was a certain precise chronology, sequence of developments,

3 of course with certain nuances depending on the peculiarities of a

4 particular community's. I meant, first of all, that these volunteers such

5 as the Arkan's -- the Arkan guards and others would come to the territory

6 before the outbreak of a conflict where inter-ethnic relations had already

7 been disrupted, and we know that by referring to materials known as

8 Variant A and B.

9 The arrival of volunteers would create a certain climate in these

10 areas primarily due to the killings of innocent people, widespread

11 looting, robbing of private property, mainly from people of Muslim faith,

12 resulting in the intimidation of the Muslim community and their fleeing

13 from the area. Those were the complex events that took place in those

14 regions.

15 With the arrival of the army - and we are talking about the JNA

16 since this took place before the 15th of May - created an impression, a

17 false impression maybe, that the JNA would make efforts to prevent these

18 developments. But then from a series of facts, we could see that the

19 Yugoslav People's Army sided with the Serbs, and its activities in those

20 areas contributed to the deepening of inter-ethnic tensions, the fleeing

21 of Muslims from these areas, and as far as I know, in Bratunac

22 municipality and in neighbouring municipalities the JNA took part even in

23 the offensive actions undertaken by Serbs in that territory.

24 Q. The next paragraph is 136, but it's within a passage that begins,

25 to give you the context, Mr. Deronjic, it begins at paragraph 131 with the

Page 29634

1 Red Berets in Bratunac, and you speak of a meeting possibly in June,

2 possibly July. And then at paragraph 134 you explain that Mr. Simatovic,

3 known as Frenki, was there. And at paragraph 136, and it is only this

4 that I want your evidence on live, because you understand your entire

5 statement is in: Did Frenki Simatovic tell you at what level the task he

6 had to accomplish had been agreed?

7 A. Yes, Your Honour. Frenki, at that time meeting whose exact date I

8 don't know, said that it had been agreed at the highest level, meaning

9 probably the highest political level of the state of Serbia and of

10 Republika Srpska.

11 Q. Thank you very much. We'll move on, please, to paragraph 163, by

12 which stage in your statement we are into 1995, and indeed the spring of

13 1995. You deal with Karadzic touring the regions and scheduling meetings,

14 at one of which he spoke to you and said of Srebrenica what was to come.

15 Can you tell us, just in a sentence or so, what it was that Karadzic told

16 you about what was to come for Srebrenica as of that date, spring of 1995.

17 A. Yes. This is the first I ever learnt of that, namely that in

18 Bratunac, a neighbouring municipality to Srebrenica, certain military

19 activities would take place. He didn't say exactly which activities, but

20 he said certain military activities would be undertaken there, and I

21 should, if I deem it necessary, undertake the necessary preparations in my

22 area. Those were his words.

23 Q. And what if anything did he say specifically about what was going

24 to happen in Srebrenica itself?

25 A. At that moment, he did not say anything. He said some military

Page 29635

1 activities would be carried out around Srebrenica, that I should not talk

2 about it to anyone, that he was not going to divulge any details, but if I

3 thought it necessary, I should carry out some preparations such as making

4 sure that we had enough oil supplies and supplies of other commodities,

5 the usual routine activities related to the army, without explaining

6 precisely what was about to happen in Srebrenica in the military sense.

7 Q. About two or three more references at most. The next one, please,

8 at paragraph 175 when you are dealing with a meeting of the 9th of July in

9 Pale. You saw Karadzic --

10 A. Yes.

11 Q. -- but you also saw another man, and at paragraph 175, you deal

12 with how he was introduced to you and who he was.

13 A. The person in question was Mr. Jovica Stanisic. I said that I had

14 been introduced to him in such a way that I understood that they had been

15 discussing Srebrenica at their preceding meeting, and I attended the

16 following meeting on the 8th or the 9th when I received confirmation, new

17 confirmation that the topic of their talks was Srebrenica. And he

18 introduced me as one of their people from the area, from the ground,

19 meaning Srebrenica. And the way he phrased it confirms that they had been

20 discussing Srebrenica at the meeting that they had just had.

21 Q. At about 200 -- paragraph 208, Mr. Deronjic, you deal with the

22 arrival in Srebrenica of a man called Beara who you understood to be the

23 man spoken of by Karadzic, and his instructions in relation to the

24 prisoners were to the effect that what should happen to them?

25 A. Excuse me, could you give me the number of the paragraph again.

Page 29636

1 Q. 209, Mr. Deronjic.

2 A. Yes. In that paragraph I spoke about the arrival of Mr. Beara in

3 Bratunac, I would say, because I'm not sure whether he had been to

4 Srebrenica. I spoke about the fact that he came to my office late at

5 night between the 13th and the 14th of July.

6 It is a well-known fact, and I mentioned it in my statement, that

7 on the 13th, at night, I talked to Mr. Karadzic, and the transcript of

8 that conversation is precisely the document which we read from a moment

9 ago.

10 Mr. Beara showed up at my office on the 13th in the evening, and

11 in this paragraph I described in detail the atmosphere in my office and

12 the orders he related to me regarding the Muslim prisoners who at the time

13 were located in the municipality of Bratunac.

14 Do you need any further details on this?

15 Q. No. It's in the statement, and people can read what his

16 instructions were.

17 And then finally in paragraph 227, you deal with the document with

18 which the Chamber is very familiar because it's been recently produced.

19 That's the document dealing with the apparently, or so said to be,

20 legitimate and proper evacuation of people from Srebrenica. It's the

21 document Mr. Franken signed, having amended it.

22 You deal with that document in paragraph 226 and 227, and you say

23 that the document did not correspond with reality. And if you'll go right

24 to the end of paragraph 227, we can read all the reasons why it didn't

25 correspond to reality if necessary, but you say finally the main reason or

Page 29637












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Page 29638

1 the basic reason for that document not corresponding with reality was

2 what, please, Mr. Deronjic?

3 A. I said that the main reason was that there was no real intention

4 to allow that population, and I mean now the civilians who found

5 themselves in the base in Potocari after we captured Srebrenica, to remain

6 there. All the preceding events and this event itself confirm my theory

7 which I may have explained earlier, namely that the Muslim population

8 should be cleared from that area, eliminated from that area. That was the

9 real intention. And the instructions I had received did not coincide with

10 the reality. And I am referring now to the options that I was instructed

11 to convey to the Muslims on behalf of President Karadzic.

12 Q. Mr. Deronjic, thank you very much. You'll be asked further

13 questions.

14 MR. NICE: Your Honour, the audio -- I beg your pardon, the

15 intercept that the accused asked about, this is one of those for which we

16 do not have an audio version. We have the hard copy, and it will be

17 production of the hard copy that will be dealt with in later evidence.

18 JUDGE MAY: Mr. Milosevic, it's now for you to cross-examine the

19 witness. We've considered the time which you should have available, and

20 we think you should have two and a half hours to cross-examine this

21 witness.

22 THE ACCUSED: [Interpretation] Mr. May, I don't understand how you

23 can allocate to me only two and a half hours for a witness who is for all

24 practical purposes not a live testimony witness, who comes in with a

25 statement containing 232 paragraphs, or in other words 232 different

Page 29639

1 assertions --


3 THE ACCUSED: [Interpretation] -- which means that I am supposed to

4 cover 100 paragraphs per hour, including all this documentation. It is

5 completely impossible.

6 JUDGE MAY: Yes. Get on with the cross-examination. Don't waste

7 any more time.

8 THE ACCUSED: [Interpretation] I'm not going to waste any time, but

9 can I establish first what kind of transcript is it which is not

10 accompanied by an audio recording? What is it a transcript of then? I'm

11 talking about this conversation between Deronjic and Karadzic.

12 JUDGE MAY: At the moment, the exhibit has purely been marked for

13 identification. We will decide in due course whether to admit it.

14 Yes. Let's move on.

15 THE ACCUSED: [Interpretation] Very well, then.

16 Cross-examined by Mr. Milosevic:

17 Q. [Interpretation] Mr. Deronjic, first of all I would ask you a few

18 introductory questions, background questions that have to do with your

19 assertion you made a moment ago in response to a question by Mr. Nice,

20 namely that you drew your conclusions about the events in question in 1997

21 at the time of your contacts with the Prosecution.

22 A. Mr. Milosevic, that is not what I said. I said that for the most

23 part, I drew my conclusions during the war, and some conclusions I drew

24 after the war was over.

25 Q. Well, you did mention the side opposite and your contacts with

Page 29640

1 them starting with 1997, and you said that in 1997, you arrived at some

2 sort of version of your own about the events in Bosnia and Herzegovina.

3 A. That is correct.

4 Q. In that connection, I would like you to clarify a few things for

5 me. I have in front of me the agreement that you concluded with the

6 Prosecution, your plea agreement. I suppose that you are familiar with

7 it. You concluded a plea agreement with the side opposite; correct?

8 A. Correct.

9 Q. I have no time to go through this entire document, but I will

10 refer to some things contained in it.

11 THE ACCUSED: [Interpretation] I hope, gentlemen, that you have

12 this agreement in front of you.

13 JUDGE MAY: We do not. We do not, but we will have it available.

14 THE INTERPRETER: May the interpreters say they don't have this

15 agreement either.

16 JUDGE KWON: Microphone.

17 MR. NICE: If we can make one copy available to the Bench straight

18 away, I have one other copy of my own, if we can get the others copied,

19 then the shortfall will be remedied as soon as possible.

20 JUDGE MAY: Yes, Mr. Milosevic.

21 MR. MILOSEVIC: [Interpretation]

22 Q. In that plea agreement you concluded with the Office of the

23 Prosecutor, from what I can see with regard to the key part of your

24 testimony, they are not charging you with anything related to Srebrenica;

25 is that correct?

Page 29641

1 A. Yes, that's correct.

2 Q. "Interpretation of the agreement on the part of the Prosecutor."

3 That's what it says. "Based on complete and significant cooperation of

4 Mr. Deronjic with the Prosecution, the Prosecution will recommend to the

5 Chamber to determine a sentence of ten years." Is that correct?

6 A. Yes.

7 Q. B reads: "The Prosecution will undertake the necessary and

8 reasonable measures to ensure complete safety to Miroslav Deronjic and his

9 family." Correct?

10 A. Yes.

11 Q. It reads on: "Based on this plea agreement, Miroslav Deronjic

12 assumes complete responsibility for his criminal acts in the village of

13 Glogova." That is, it reduces your responsibility to events in Glogova;

14 correct?

15 A. Yes.

16 Q. Further on, point D, it says: "Regarding the criminal

17 responsibility of Miroslav Deronjic for all other criminal acts he could

18 be charged with regarding events in Glogova on the 9th of May, 1992, as

19 described in the charges in the second amended indictment, the Prosecution

20 will inform the competent national courts that these acts have been dealt

21 with." In other words, they should not prosecute you; correct?

22 A. Correct.

23 Q. It goes on to say regarding events in Glogova on the 9th of May,

24 1992, as described and so on and so forth in the second amendment

25 indictment: "The Prosecutor will --" I am warned by the interpreters that

Page 29642

1 they do not have the document so I will read more slowly.

2 "The Prosecutor will inform national courts that this particular

3 act falls under the jurisdiction of the International Criminal Tribunal."

4 Correct, Mr. Deronjic?

5 A. Correct.

6 Q. Tell me, since we are dealing here with the second amended

7 indictment, in what way is it different from the first amended indictment,

8 Mr. Deronjic, or simply first indictment?

9 A. How is it different? Well, I cannot tell you precisely what the

10 differences are because I don't have the text in front of me, but it is

11 different, certainly, from the first one.

12 Q. The difference is, I suppose, that it reduces your responsibility

13 to Glogova, and you are promised a sentence of ten years. Isn't that

14 right?

15 A. Mr. Milosevic, the first indictment against me related only to

16 Glogova, exclusively to Glogova.

17 Q. Very well, Mr. Deronjic. We have a sub-heading "Cooperation by

18 Mr. Deronjic. He commits himself to meet with the representatives of the

19 Prosecution as often as necessary and provide them with the necessary

20 information related to the well-known events in the former Yugoslavia."

21 It goes on to say that: "Miroslav Deronjic agrees to testify

22 truthfully at any trial, at any hearing, in any other proceeding before

23 the International Tribunal where, in the opinion of the Prosecutor, his

24 testimony could be relevant be it a current case in front of the Tribunal

25 or any future case."

Page 29643












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Page 29644

1 Is that correct?

2 A. Yes.

3 Q. Therefore, your testimony is based on this plea agreement you made

4 with the Prosecution. Is that correct, Mr. Deronjic?

5 A. It is correct, Mr. Milosevic. However, I will tell you a couple

6 of things that you don't know.

7 During my first contacts with the Office of the Prosecutor - and

8 this can be confirmed by my Defence counsel - I said that even if I never

9 make a plea agreement, I will testify in front of this Tribunal. I don't

10 have the text in front of me, but you can check that with my lawyers.

11 Q. I have no intention of doing anything of the kind. In this second

12 amended indictment which refers only to Glogova --

13 A. Excuse me, Mr. Milosevic. Even the first indictment, and I've

14 said this already, relates only to the events in Glogova, and I would like

15 to say this again on record.

16 Q. Very well, Mr. Deronjic. My point is not the coverage of the

17 indictment, my point is your plea agreement with the Office of the

18 Prosecutor whereby they take it upon themselves to recommend to the Trial

19 Chamber to sentence you to ten years; and that is the basis on which you

20 concluded this agreement, isn't it, Mr. Deronjic?

21 A. Inter alia, this recommended sentence is an element of the plea

22 agreement.

23 Q. As well as other elements such as protection measures, relief from

24 Prosecution in national courts, et cetera, et cetera.

25 A. Mr. Milosevic, you know that this honourable Tribunal gives

Page 29645

1 priority to the Prosecution of persons guilty of war crimes in the former

2 Yugoslavia. I don't see anything wrong with the same formulation being

3 used in my case.

4 Q. I don't know what the priorities are of this so-called Tribunal,

5 but let us move on to your actual testimony which is based on this plea

6 agreement with the Office of the Prosecutor. Let us move on in accordance

7 with the main events involved. I don't know exactly how much time I will

8 get eventually, but first I'm going to deal with Srebrenica in 1995.

9 In paragraph 161 of your statement, you say that you often talked

10 to Karadzic on the subject of Srebrenica. And as you say about the

11 presence of international forces, relations with these forces personnel

12 matters, personnel issues with the army, military issues, and so on and so

13 forth. Is that right, Mr. Deronjic?

14 A. Yes, that's right.

15 Q. Because of all these frequent conversations and exchanges of

16 opinions, you must have been very well aware of Karadzic's views of

17 Srebrenica even before 1995 and what happened then.

18 A. To the extent to which Mr. Karadzic had the intention of telling

19 me openly about his intentions, so I know what I know.

20 Q. I assume that since you talked frequently and you were the person

21 who was in charge of Srebrenica that you had to be aware of all these

22 positions; is that right?

23 A. It is absolutely not right. If there are secret plans and if the

24 president does not deem it necessary to tell me about this, then he's not

25 going to tell me. At any rate, I can confirm that I was aware of some

Page 29646

1 plans related to Srebrenica.

2 Q. All right. Therefore, it seems that you were not aware of his

3 positions in Srebrenica, because otherwise you would have spoken about

4 them in your statement.

5 A. Yes, I had heard of some plans. I don't know how objective and

6 truthful they are, and that's what I said to the Office of the Prosecutor

7 in my extensive statement. I said that there were some stories to the

8 effect that it would be possible that Srebrenica would be exchanged for

9 some territory within the federation. I did hear of such plans in these

10 conversations, but I don't know how objective this was and how possible

11 this was at that point in time.

12 Q. All right. Some concrete talks that you had about Srebrenica with

13 Karadzic that you mention. I assume that you did not mention all of them

14 in this statement. You provide the information that in your opinion has

15 to do with your own behaviour there and the events that have to do with

16 you yourself.

17 This conversation took place when Karadzic once came to Zvornik,

18 and you say it's spring. It's the spring of 1995 or perhaps the month of

19 May; is that right? Then you say that he took you to the side and that

20 Karadzic told you then that in Srebrenica some military operation would be

21 taking place but he did not give you any details.

22 A. That's right. He said that to me, among other things.

23 Q. In view of the fact that he told you about that already then, he

24 told you that you shouldn't talk to anyone about this.

25 A. That's right.

Page 29647

1 Q. I assume that he had great confidence in you. Is that right?

2 A. I assumed that he had confidence in me too.

3 Q. Then he asked you that upon your return to Bratunac you should

4 take the measures that you deem necessary in relation to this military

5 operation, that he only hinted at, if I understood this correctly.

6 A. Yes, that's right.

7 Q. Tell me, what were the preparatory measures that you took in

8 relation to this military operation that he had hinted at to you upon your

9 return to Bratunac?

10 A. I explained this in one particular paragraph. These were routine

11 actions that were customary in preparation of military operations. I

12 checked whether we had among our reserves sufficient quantities of oil,

13 then also whether there was enough medicine at the health centre and also

14 whether we had sufficient food supplies at the time, and I asked the

15 municipal leadership to prepare this if they realised that there wasn't

16 enough of any of these materials. I said that there would be something

17 going on in connection with Srebrenica and that we should be ready, too,

18 as we did several times before that when operations took place in the

19 area.

20 Q. As you say yourself that you did not know anything about these

21 operations in greater detail, how could you on the basis of such scant

22 information know what were the quantities involved in relation to all

23 these supplies? What did you actually have to prepare and how much?

24 A. We never knew what the necessary quantities were. We made an

25 effort to have optimum quantities in relation to the possibilities that

Page 29648

1 the municipality had. For example, if in that area there is going to be a

2 military operation, then it is necessary for us to have a large

3 transportation company there. It is necessary to suggest to people that

4 they should have as many oil reserves as possible and also that the

5 municipality should make an effort to set up oil reserves. Of course we

6 never had any idea how much would be necessary. Oil supplies come through

7 military channels as well, but very often during this war the municipality

8 assisted the military, and I can give you countless number of examples to

9 this effect, and I can say that the municipality bought some food

10 supplies, oil reserves, et cetera, everything that was of priority

11 importance.

12 Q. All right. Mr. Deronjic, did you report to Karadzic in the

13 meantime at all about preparations carried out to that effect?

14 A. No. Even in the previous period in relation to these activities

15 that are normal for the civilian authorities in this area, there was no

16 practice of informing the leadership of Republika Srpska about this.

17 Q. All right. So Karadzic could not have known what he could count

18 on in Bratunac if this operation that he hinted at was to take place.

19 A. He could absolutely count on the preparations that were supposed

20 to be carried out by the military, and from that point of view he probably

21 had that information made accessible to him.

22 Q. But since you say that you did not report about your preparations,

23 then this could not have made it possible for him to count on you in

24 relation to the tasks that you carried out.

25 A. Well, no, not really but then he could have known that I acted

Page 29649












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Page 29650

1 within the scope of the material possibilities of the municipality and

2 that I did whatever I could.

3 Q. All right. In paragraph 164, you say that these preparations that

4 you took care of were not something that caused spectacular interest among

5 the population because you were not involved in the military aspect of the

6 preparation for Srebrenica.

7 A. The first part is contained in that paragraph first and foremost.

8 I said that these were routine actions, and I said that when the units

9 arrived in the second half of June in that area, and then the command of

10 these units and the reconnaissance that took place, et cetera, all of this

11 did not cause any spectacular interest among the ordinary people because

12 such operations had taken place in the previous period as well.

13 Q. All right. Does that mean that although you said that you talked

14 to Karadzic about this operation from the very beginning but that you did

15 not really talk to anyone else about Srebrenica?

16 A. That's right.

17 Q. When did the military operation regarding Srebrenica start in

18 actual fact?

19 A. I'm not sure when the action actually started. The first days of

20 the month of July, I believe. But some activities started already in the

21 second half of June. I cannot say exactly and I was not involved in them

22 but there were some activities of the military that were noticeable in the

23 second half of June. Specifically, I think that the Srebrenica action

24 started in the first days of July.

25 Q. It is my understanding on the basis of what you say in paragraph

Page 29651

1 167 that as a matter of fact during the first days when the operation

2 started, you did not even go towards Srebrenica, as you said yourself, in

3 order to see for yourself what was going on.

4 A. Yes. This does say the month of July. Perhaps during the first

5 two or three days in the month of July. That's the period I meant when I

6 said that I did not go in the direction of Srebrenica.

7 Q. All right. But in paragraph 168 you say that on the 1st of July,

8 or perhaps a day or two before that --

9 A. Yes.

10 Q. You say on the 1st of July or perhaps a day or two before that, so

11 then perhaps on the 29th or 30th of June, you went to the forward command

12 post at Pribicevac and that is the first time you briefly saw General

13 Krstic; is that right?

14 A. Yes, that's right. That's what I said because I cannot remember

15 exactly the date when I was present myself at Pribicevac. That is why I

16 said the 1st of July, a day or two before that, or perhaps a day or two

17 after that. I cannot say exactly.

18 Q. Tell me, how is that possible when in the previous paragraph, 167,

19 you say that during the first days you did not go anywhere from Bratunac

20 and that you were only guessing that this was fighting for the road

21 between Skelani and Milici.

22 A. What do you mean that it's not possible? I said that the

23 preparations of the military in that area started in the second half of

24 the month of June, certain activities of the army. So I did not take part

25 in this, and I was not present myself during these activities. When I

Page 29652

1 went to Pribicevac, and that has to do with those days approximately, I

2 cannot exactly remember, then I saw for myself what the activities were

3 like in the actual area.

4 Q. Very well. Since you say that on that occasion you had a brief

5 meeting with General Krstic, tell me, what did you talk about?

6 A. Nothing special. I said that this meeting was a very brief one, I

7 said that I met Mr. Krstic at Pribicevac during those days in the month of

8 July. I spoke to him briefly, I introduced myself to him, I said who I

9 was and what I did, and nothing special. I didn't discuss anything

10 special with him because he was busy issuing certain orders in that area.

11 Q. I see. So you just said hello to him and you didn't really talk.

12 A. Well, of course I cannot remember very precisely. These are

13 events that took place a long time ago. I explained that there was this

14 table in front of this forward command post, perhaps we sat down and had a

15 cup of coffee. I personally did not know Mr. Krstic, and he had not known

16 me either. This was a courtesy talk. I did not want to be a hindrance in

17 any way and I cannot say how long this lasted.

18 Q. In paragraph 170 you say that one day you went to the actual

19 combat site on the south side of Pribicevac where you say the actual

20 military operation was taking place.

21 A. Yes, that's right.

22 Q. On which day did you go?

23 A. I cannot say exactly which days these were. It was these days in

24 July, and I cannot say exactly whether it was the 10th. Perhaps it was

25 the 10th, the 7th, the 6th of July. I cannot say exactly because at this

Page 29653

1 point in time it's not quite clear to me when the military part of the

2 operation started, but that is where I saw the commander of the Zvornik

3 Brigade. I said hello to him, and I saw directly how these operations

4 around Srebrenica were evolving.

5 Q. All right, you say that you saw the commander of the Drina Wolves

6 at the time, whose nickname was Legenda, the Legend.

7 A. I remember that I saw Vinko Pandurevic, and I saw this man whose

8 nickname was Legenda. I didn't know his real name.

9 Q. All right. Did you talk to him then?

10 A. I can explain this quite accurately. This is a trench where they

11 were, a communicating trench -- communication trench towards -- facing a

12 locality on the other side. During the actual operation while these

13 elevations were being taken, they are called the three tits, that's what

14 they're called in that area. I did not stay for very long there. I just

15 said hello to Mr. Pandurevic and I realised that he was in a great hurry

16 and that this operation was already under way and whether it continued

17 later, I really don't know about these details, because I did not stay

18 long there and I went back.

19 Q. All right, Mr. Deronjic. As for General Krstic or this Legenda or

20 Pandurevic, so these men who are officers, commanders within the command

21 that was involved in the operation, you did not ask any one of them about

22 the objectives of the operation. You simply inferred your own

23 conclusions; you did not get any information from them.

24 A. No, I didn't.

25 Q. However, not knowing about the goals of that military operation,

Page 29654

1 you decided then to seek your own information from Radovan Karadzic

2 directly and to suggest to him to involve a special police unit of the MUP

3 of Republika Srpska commanded by Ljubisa Borovcanin and to have them

4 involved in all this. That's what you say in paragraph 171; is that

5 right?

6 A. Yes, that's right.

7 Q. Tell me, why did you get this idea, this military idea, if I can

8 put it this way? You say that you were layman and that you didn't know

9 anything about this, and so how did you get this idea that Borovcanin's

10 special unit should be involved in all this?

11 A. Mr. Milosevic, in my statement I explained in greater detail that

12 as I spent time during the first half of July at this particular place

13 that is called Pribicevac, I visited the units of the Bratunac Brigade

14 that were for the most part deployed in that area. And I spent one night

15 or even more in the area talking to people about various things, of

16 course, but we were mostly interested in the plan regarding Srebrenica,

17 and people were asking me about the plans, the military plans that had to

18 do with Srebrenica that they were taking direct part in. So this was one

19 of the motives involved. And I told the men that I would see how I could

20 get more information about this because I did not they anything about it.

21 That is one of the motives that led me to go and see Mr. Karadzic.

22 Another motive was that I should make the proposal that I already

23 referred to, that Mr. Borovcanin should come with his unit. I noticed

24 during this war, which was not a war between classical armies, it was the

25 armed people that were waging war for the most part. I saw that some

Page 29655












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Page 29656

1 casualties were completely unnecessary and were due to the fact that these

2 people were not well trained to conduct military operations.

3 I must tell you that when I was touring the units this area, many

4 of my colleagues, teachers, were at these positions, as well as managers

5 from companies, people who were even elderly, who were unable, or at least

6 that was my assessment, to make any major breakthroughs or take some

7 fortified positions of the enemy, and so on and so forth. I understood at

8 one point in time that the actions around Srebrenica were not only routine

9 matters but that there was a serious objective involved to enter

10 Srebrenica itself, and I understood that while I was in the field, and I

11 thought that that would be disastrous for a great many people that I saw

12 myself. Bratunac is a small town, we are all acquaintances and friends,

13 and I thought that it would be a good thing that if the plans were the way

14 they were, that a trained professional unit should come to the area.

15 I knew Mr. Ljubisa Borovcanin, I knew some people from his unit,

16 and I thought that they were absolutely capable to carry out such a task.

17 Of course it was for me to make a suggestion but it was up to the

18 president to decide whether he would act in accordance with my suggestion

19 or not.

20 Q. All right. From what you say and from what you wrote in paragraph

21 171, it follows that you had actually noticed that apart from these Wolves

22 from the Drina, it was ordinary men who were involved in combat, not

23 trained soldiers, and that's why you suggested to Karadzic that the

24 special unit of the MUP of Republika Srpska should be involved.

25 A. Correct.

Page 29657

1 Q. And you now explained that in order to accomplish these missions

2 which you knew nothing about, a unit like that was needed.

3 A. Mr. Milosevic, I didn't say that I didn't know anything about it

4 at that moment. I didn't know anything about the goals of the military

5 operation in Srebrenica and around Srebrenica in the preceding period. At

6 that time, I saw very intensive activity going on on the ground, and I saw

7 that the move to take Srebrenica was impending. If I hadn't seen on the

8 ground what I had seen, I wouldn't have gone to see President Karadzic.

9 But since I witnessed the previous routine operations that took place, I

10 could compare them to the current ones and see that it was not the same

11 thing.

12 Q. I understood you as saying that you did not know the combat

13 objectives of the units which were involved in those attacks and those

14 operations around Srebrenica.

15 A. Mr. Milosevic, none of the people on the ground who were involved

16 and who commanded these operations told me those goals word-for-word, but

17 I was able, based on logic and experience, to make my own conclusions

18 about the events I was witnessing.

19 Q. Very well. I received from my associates a couple of documents

20 that I will try to clarify with your assistance.

21 Are you aware that the corps commander, General Zivanovic, on the

22 2nd of July, 1995, issued an order to carry out active combat operations?

23 That referred to the operation known as Krivaja 1995.

24 A. No, Mr. Milosevic, I'm not aware of it.

25 Q. I will read out to you. It's dated 2nd of July, 1995, military

Page 29658

1 secret, strictly confidential, copy number illegible, Krivaja 1995, order

2 for active combat operations. There is reference to maps.

3 On page 2, item 2, it says: "Command of the DK," meaning Drina

4 Corps, "based on the instruction OP 71 of the Main Staff of Republika

5 Srpska and based on the situation in the area of responsibility, has the

6 order to carry out active combat operations, to separate the enclaves of

7 Zepa and Srebrenica as soon as possible and reduce them to their urban

8 areas."

9 That's as far as I can see the objective. "Completely separate

10 and reduce the enclaves of Zepa and Srebrenica, improve the tactical

11 position in-depth." That is the order of the commander. It is a pretty

12 lengthy one. Order issued by Major General Zivanovic.

13 You know this general, don't you?

14 A. I do.

15 Q. In this order, it is very clearly formulated what the objective

16 is. The date is the 2nd of July. And then further on, I will quote from

17 page 5 of this document. It reads: "Security organs and the military

18 police will designate areas of assembly and the security of prisoners of

19 war and war booty. In treatment of prisoners of war and the civilian

20 population, adhere to the Geneva Conventions in full."

21 That is what is written in the order of General Zivanovic

22 regarding operations around Srebrenica.

23 Are you saying, Mr. Deronjic, that you knew nothing about this,

24 you as the person holding the highest responsibility for this area?

25 A. Yes, that is what I'm saying.

Page 29659

1 Q. Very well. But can we conclude from this order that already on

2 the 2nd of July it was quite clear what the objectives of the operation

3 were and how one should treat prisoners of war and the civilian

4 population? It is written in this order and everyone who received this

5 order behind the lines must have been aware of it.

6 A. Well, I can't say anything about this. I don't know who received

7 the order. I didn't, and I don't see how I could be aware of it. But I

8 do not dispute that the persons who did receive the order were well

9 acquainted with its contents.

10 THE ACCUSED: [Interpretation] Mr. May, I would like to tender this

11 order.

12 JUDGE MAY: Let the witness see it. Show it to the witness,

13 please.

14 THE ACCUSED: [Interpretation] Yes, the witness may see it. This

15 is a photocopy, and I don't have the original, but he will be able to see

16 that it is an authentic order.

17 JUDGE MAY: Mr. Deronjic, I know you haven't seen this order, but

18 perhaps you'd like just to have a look at it, and if you have any comment

19 on it, to make it now. If not, we will simply take it, and we'll have a

20 look up here.

21 THE WITNESS: [Interpretation] Your Honours, Your Excellency, it

22 would take too much time for me to read all of this. I can only note that

23 I'm seeing this for the first time. I had no prior occasion to see this

24 document. If you want my comments --

25 JUDGE MAY: Very well. What we'll do for the moment is perhaps we

Page 29660

1 could have a look, and then I propose that we mark it for identification.

2 Yes. We'll mark this for identification with the next D number,

3 please.

4 THE REGISTRAR: Your Honours, Defence Exhibit 219, marked for

5 identification.

6 MR. MILOSEVIC: [Interpretation]

7 Q. Please tell me, Mr. Deronjic, did General Krstic, when you met him

8 briefly at Pribicevac, him or some other qualified officer, did they tell

9 you that the operation was not being implemented successfully?

10 A. No. I don't remember anything of the kind. At one point, I came

11 to my own conclusion that it is not going on very successfully because I

12 was present during an attempt of the Muslim forces within that protected

13 area to push our forces back as far away from the focus of events as

14 possible. But I didn't discuss it with General Krstic or any other

15 officer.

16 Q. Tell me now, how did you then, as a layman, manage to notice that

17 the operation is not going on very successfully and that it was necessary

18 to engage this special unit, Special Police Unit of the MUP of Republika

19 Srpska?

20 A. Mr. Milosevic, you don't seem to be listening to me. My

21 motivation for the decision I made is varied. I am not a soldier, but I

22 was able to see with my own eyes what was going on on the ground. A

23 person who is able -- capable of logical thinking can make their own

24 conclusions about whether a military operation is going on successfully or

25 not. I was able to see that there were a lot of casualties, great losses

Page 29661












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Page 29662

1 were incurred, et cetera.

2 Q. All right. Regardless of the fact that you haven't read that

3 order, even I only glanced through it because my associates provided me

4 with it only yesterday, I understood that the combat objectives of the

5 Bratunac Brigade and the Milici Brigade where some display of force, in

6 fact, that would tie up enemy forces and keep them engaged so that they

7 would not be able to fight elsewhere. It was some sort of demonstrative

8 action aimed at tying up enemy forces. That's what I understood from the

9 documents available to me. That was the objective of the Bratunac and the

10 Milici Brigades. Of course I don't have enough information to be certain

11 about this.

12 A. Well, I told you what I saw on the ground. The Bratunac Brigade

13 for the most part was deployed in the area from Pribicevac to Bratunac.

14 What its immediate objectives in the operation were, I really don't know,

15 because it was only in the afternoon of the 11th that I met with the

16 commander of the Bratunac Brigade, Mr. Blagojevic, and by then the order

17 to go into Srebrenica had already been issued. The troops were already

18 ordered to go in.

19 I have no reason to doubt what you're saying, but I was simply not

20 informed at the time.

21 Q. All right. In paragraph 172, you say that you went to Pale to see

22 Karadzic alone by night. What date was it?

23 A. Well, I had to say that I could not say for certain. I told you

24 it was a long time ago. I think it could have been either the 7th or the

25 8th or maybe the 9th. Most probably the 8th or the 9th. Those were the

Page 29663

1 likely possible dates when I went to Pale.

2 Q. I had in mind that you went there on the 9th of July. Let me just

3 look at this paragraph 172. It says: "I went to Pale alone on the 9th of

4 July. Ljubisa Borovcanin came to Bratunac with his unit the next day."

5 And then it goes on to say: "... so this is how I can determine the exact

6 date of the visit."

7 You seem to be pretty specific.

8 A. Yes, but in my earlier statement I specified that it could have

9 been the 8th or the 9th.

10 You know, Mr. Milosevic, that I gave this statement without being

11 able to refresh my memory, especially with regard to dates, because I was

12 already in detention. So I expressed my reservation about the timing of

13 certain events. And I didn't even think that I needed to be completely

14 accurate. Unfortunately, I cannot tell you the exact date.

15 Q. Very well. Let it be the 9th, as it says in your statement. Let

16 us not go into that.

17 These objectives of the operation -- and I suppose you know that I

18 have been in detention for three years now, and it is very difficult for

19 me to gain access to all sorts of documentation, but from what I do get to

20 see, I can reconstruct certain events.

21 So if you went on the 9th to ask what the objective was and the

22 objectives are determined in the order dated the 2nd of July as separating

23 Zepa, Srebrenica, taking hold of roads, et cetera - we can check all that

24 - therefore, everybody involved in that operation in view of the order

25 that had been issued must have been clear about the objectives. You, the

Page 29664

1 top political chief in the area, are the only one who doesn't know the

2 objectives so you have to go and see Karadzic on the 9th.

3 A. Well, I don't know and I couldn't have known how long it was

4 between the order and my visit.

5 Q. I'm only pointing out the date of the order. And you went to see

6 Karadzic seven days later. We're talking about an order that was widely

7 known, that specified the objective of the operation. The fact that you

8 went to see Karadzic seven days later is a bit unclear to me.

9 JUDGE MAY: What is the point in arguing about this,

10 Mr. Milosevic?

11 THE ACCUSED: [Interpretation] Well, Mr. May, the point is that it

12 is my firm conviction that the statement of this witness in its main

13 points is based on this plea agreement with the Prosecution, and these are

14 contradictory matters, because if on the 2nd of July this order was issued

15 in which the objectives are described --

16 JUDGE MAY: He's told you more than once, I don't know how many

17 times he has to repeat it, he knows nothing about this order, nor do we.

18 It's something that you've put up. Whether it was issued or not you can

19 give evidence about, or whether anybody believed it you can give evidence

20 about, whether it meant anything. But he doesn't know anything about it.

21 That's his evidence. It's pointless to go on arguing and going over it.

22 THE ACCUSED: [Interpretation] Mr. May, I care about having these

23 things clarified. As you know full well, Serbia has nothing to do with

24 this, but I do want to have this clarified.

25 MR. MILOSEVIC: [Interpretation]

Page 29665

1 Q. Tell me now, since you went on the 9th or some day around the 9th

2 of July to Pale, did you announce your arrival there? How could you know

3 whether Karadzic was there, whether he was not there, especially in the

4 evening, whether you could find him, whether he could receive you and so

5 on? Did you telephone before that to make sure that he was there and that

6 he could receive you? How did this meeting take place?

7 A. Mr. Milosevic, I explained this. I explained it in my statement.

8 Truth to tell, it's not contained in this particular version, but then as

9 far as I know, you yourself visited Pale a few times. You know how big a

10 place it is, and you know that Mr. Karadzic spent most of his time there.

11 During the operations that had to do with Srebrenica, it was logical to

12 assume that he would be at the Presidency or at one of the neighbouring

13 buildings. My possibilities to get in touch with him were quite

14 realistic. It was quite realistic for me to expect that I could find him

15 in Pale and speak to him.

16 Q. I did visit in Pale once, and this was when the Assembly of

17 Republika Srpska was meeting in relation to the Vance-Owen Plan. Yes, I

18 do know that it is a small town and that before the war it was basically a

19 tourist area.

20 So you went, just like that, expecting to find him, and indeed you

21 found him.

22 A. Yes, you can put it that way. I did not want to make any

23 assumptions here. I cannot remember whether I made a telephone call

24 before that. That's why I didn't say anything. I could have stopped by

25 the office and checked whether the president was in Pale, and that was

Page 29666

1 sufficient. Then I could simply go to Pale and speak to him.

2 Q. All right. If you then went to see him, did that have to be

3 registered in some protocol book? Did this information have to be

4 registered somewhere, when you visited him?

5 A. I don't know.

6 Q. Are there any traces of that?

7 A. I really don't know about this, Mr. Milosevic. How could I know

8 whether there was any trace of that?

9 Q. Did you tell anybody in Bratunac where you were going?

10 A. No. Bratunac at that time was quite empty. Everybody was

11 mobilised except for the staff in my office, and I'm primarily referring

12 to my secretary. I said this to the Office of the Prosecutor. At that

13 time, I was seeing Mr. Sinisa Glogovac at Pribicevac. He could have

14 known. I'm not sure whether I told him, but I could have told him that I

15 was going to Pale.

16 Q. Wait a second. I don't understand that. Now you're saying that

17 you may have told Glogovac and before that you said that you had not told

18 anyone.

19 A. Well, if you read this, I saw him at Pribicevac, and he was there.

20 Q. Where is he now?

21 A. He works at the state security of Republika Srpska, or rather, he

22 was working there until the moment of my arrest.

23 Q. All right. So you went to Pale all by yourself; is that right?

24 A. Yes, that's right.

25 Q. You did not tell anyone about this except that you may have told

Page 29667












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Page 29668

1 Sinisa Glogovac; is that right?

2 A. Yes.

3 Q. So these claims of yours could perhaps only be supported by

4 Glogovac; is that right?

5 A. That's not true. It can be corroborated by Karadzic, Krajisnik,

6 and Mr. Jovica Stanisic.

7 Q. All right. And how far away is Bratunac from Pale? How much time

8 was necessary in order to get there by car?

9 A. Bratunac is about 130 kilometres away.

10 Q. When did you arrive in Pale?

11 A. In my statement I said that I cannot remember the exact hour, but

12 it could have been in the afternoon. Perhaps my memory can be playing

13 tricks on me. This is in the mountains, and as you know, it gets dark

14 there a bit earlier than in Bratunac, which is in a valley. But I think

15 it was in the afternoon.

16 Q. All right. You say that at the entrance into the Presidency

17 building you saw Karadzic, Krajisnik, and Stanisic as they were walking

18 about.

19 A. As they were walking out of the Presidency building. I didn't see

20 them as they actually walked out, I just saw encountered them there. I

21 could explain the Presidency building in detail and the place where I saw

22 them. This was on the left hand of the Presidency building. They were

23 getting out of the Presidency building, and they were getting closer to

24 the exit from the yard of the Presidency building, and that's where I

25 encountered them.

Page 29669

1 I'm not saying that they were taking a walk in that sense, I mean

2 that they were strolling in the street or something like that. They were

3 simply walking at a slow pace, and they were talking amongst themselves.

4 Q. All right. In paragraph 173, you say that knowing the position

5 Jovica Stanisic held, you assumed that they were talking about Srebrenica.

6 Is that what you stated?

7 A. Yes, that's what I stated.

8 Q. You say that on that occasion, Radovan Karadzic introduced you to

9 Jovica Stanisic, and he said, "This is one of our guys from the area." Is

10 that right?

11 A. Yes, that's right.

12 Q. Is that why you concluded that they were talking about Srebrenica?

13 A. Well, that among other things, but also his very presence there at

14 Pale at the moment when this military operation is taking place, a

15 military operation that is of significance. And I assume that his

16 presence at Pale at that moment had to do with the operations around

17 Srebrenica. I'm not asserting that. I did not have any facts at my

18 disposal to be able to say this for sure.

19 Q. All right. This expression that someone is from down there, from

20 the field, in the communications that I know of, this usually has to do

21 with local leaders from the field, from the area.

22 A. Excuse me. I have to add something, Mr. Milosevic. When it's --

23 when somebody says, "This is a guy of ours from there, from the field,

24 from the area."

25 Q. Yes.

Page 29670

1 A. But if this has to do with an event that is about to take place or

2 that is taking place when it just says "down there" without saying

3 Bratunac, Trebinje, Zvornik, Bijeljina, et cetera, then it means that this

4 from "down there" is something that people know of on the basis of

5 something.

6 Q. Was that the only thing that was going on at the time, or was this

7 a general way of putting things when people were being introduced, saying

8 that somebody was a local leader?

9 A. On the basis of what Mr. Karadzic said, the way he had phrased it,

10 and on the basis of the fact that right afterwards we talked about the

11 events in Srebrenica, I drew the only logical conclusion, that the

12 conversation that they were having had to do with Srebrenica too. And I'm

13 not even claiming that, I said that I assume.

14 Q. I don't know why and on the basis of what you could make such an

15 assumption except for what you say just now and which is very flimsy

16 grounds for this kind of assumption. Please tell me, Mr. Deronjic, why do

17 you think they were discussing Srebrenica?

18 A. Well, Mr. Milosevic, I believe that the Trial Chamber has

19 understood what I've been saying. I used -- I said that the president

20 used a general term, "from down there." It meant that it would be known

21 where I was coming from exactly, and that is something that addresses your

22 question.

23 Q. All right. And then he took you to the side; is that right? And

24 while Krajisnik and Stanisic waited a few steps away from you; is that

25 right?

Page 29671

1 A. Yes. Well, not waiting, they were talking.

2 Q. All right. They were standing there talking between themselves,

3 and he took you to the side a few steps from them.

4 A. Yes.

5 Q. And then you talked about this engagement of Borovcanin; is that

6 right? That was a proposal made and he said that that proposal would be

7 carried through; is that right?

8 A. Yes.

9 Q. Or rather, he said that it was a good proposal but that it was

10 impossible to be carried through because he was engaged in the Sarajevo

11 theatre of war near Kalinovik; is that right?

12 A. No, that's not what he said. He agreed to my proposal, he agreed

13 with my proposal, and it was my impression that he would it carried

14 through, which ultimately did take place, but he said that he certainly

15 had to discuss this with the minister of the interior, because that unit

16 was indeed engaged in the area around Sarajevo.

17 Q. You say Karadzic apologised to Krajisnik and Stanisic - that is

18 176 - "and took me to the side, to the left, some five or six steps from

19 them. I then asked him what the exact goal was for the operation in

20 Srebrenica." That is when you asked him what was the exact goal for the

21 operation in Srebrenica. You did not know anything in relation to these

22 orders and things like that. And then Karadzic said to you that there are

23 two plans concerning the Srebrenica option or options that had been agreed

24 to. Plan option A is liberation of the road on the south side and a

25 reduction of the protected zone, safe haven of Srebrenica to the size that

Page 29672

1 had been agreed to or described in UN documents.

2 Plan/option B -- I mean I'm reading paragraph 177. Plan/option B

3 was entering Srebrenica and taking it militarily. He made it known that

4 option B or plan B was a tentative one, a conditional, and that it would

5 only come into effect if it was militarily doable, practical. Is that

6 right?

7 A. Exactly.

8 Q. And let me just go through this now because your statement is very

9 long, many pages.

10 Now, you say: "The second issue was actually my proposal, that if

11 they do not want to enter Srebrenica, then it would be indispensable to

12 bring a serious military unit to that area. I told Karadzic quite openly

13 that I trusted Ljubisa Borovcanin's military skills and his personal

14 qualities. Karadzic agreed in principle but quickly explained that the

15 unit was engaged in the Sarajevo area in Kalinovik. I was persistent and

16 had the impression that my request would be granted."

17 So that's what happened then when you talked about it. And you

18 say that practically Borovcanin came the day after you had been in Pale.

19 That's what you said in the paragraph that I quoted to you a few minutes

20 ago; is that right?

21 A. Yes, Mr. Milosevic. That is what I said, but I keep telling you

22 time and again that I'm not sure about all these dates. I told you that

23 just a day or two after that Ljubisa Borovcanin came to Bratunac. It is

24 very hard for me to remember each and every date exactly now.

25 Q. I'm asking you this without any intention of leading you to any

Page 29673












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Page 29674

1 kind of contradiction. I'm simply going through your statement. You said

2 that on the following day, he came to Bratunac with his unit. Is that the

3 way it was?

4 A. Well, what I learned subsequently, the information I obtained

5 subsequently over here, Ljubisa came to Bratunac on the 10th or 11th. So

6 up to a degree what I said is contradictory, but I told the Office of the

7 Prosecutor quite clearly that I'm not certain of each and every date

8 regarding these events, because I did not take part in some of them

9 directly. I did not meet Ljubisa there in Bratunac when we came there, so

10 I just gave my opinion as to when he could have come.

11 Q. All right, Mr. Deronjic. Now, in paragraph 180, you say:

12 "Karadzic asked me, 'What do you, Miroslav, intend to do with that

13 population down there?' I perhaps did not quote him exactly, but I

14 remember clearly him using the word 'you,' meaning in plural. As far as I

15 know, he used the second person plural when addressing practically

16 everyone as a matter of courtesy.

17 A. I know that.

18 Q. So he addressed you in such terms as well; is that right?. Did he

19 speak to you addressing you in the second person singular, saying "ti"?

20 A. No, no.

21 Q. That's why I'm asking you this. So he addressed you in the second

22 person plural as well, as a matter of courtesy.

23 A. Yes.

24 Q. So you cannot be quite certain that when he said "vi" in the sense

25 of the second person plural, it wasn't really in the plural but he was

Page 29675

1 addressing you personally as an act of courtesy as an official he was

2 speaking to.

3 A. Mr. President -- Mr. Milosevic, I'm sorry. I'm sorry. Perhaps I

4 misspoke. I said "Mr. President" and you're not the president now and I

5 had no intention of saying that actually. But you forget the fact, and

6 perhaps you don't even know it, I am a language teacher. I can feel this

7 finesse, nuance in expression.

8 Q. All right. Let's not waste any time over that. In

9 communications --

10 JUDGE MAY: Let us adjourn now because we're past the time. We'll

11 adjourn for 20 minutes.

12 --- Recess taken at 12.18 p.m.

13 --- On resuming at 12.40 p.m.

14 JUDGE MAY: We'll go on, Mr. Milosevic, until 2.00 to try and make

15 up some of the time that's been lost.

16 MR. MILOSEVIC: [Interpretation]

17 Q. Mr. Deronjic, in paragraph 181, you claim that Karadzic at one

18 point told you, "Miroslav, all of them need to be killed." And then you

19 say that you are 100 per cent sure that he used those precise words. Is

20 that right, Mr. Deronjic?

21 A. No, Mr. Milosevic. It's true that he uttered that sentence, but I

22 added, and I would kindly ask you to read the entire context, that he said

23 a couple of more things. And I said in reference to the last thing he

24 said, namely the principles of Western Slavonia, that I'm 100 per cent

25 sure that he used those words.

Page 29676

1 Q. All right. But you're not 100 per cent sure that he said all of

2 them need to be killed.

3 A. I'm sure that he said it. I'm not sure of the precise words, but

4 the gist of what he said was that all of those people needed to be killed.

5 Q. All this is going on on the 9th.

6 A. Yes, provided that I was there on the 9th; and I expressed my

7 reservations about the date.

8 Q. But that coincided with the arrival of Borovcanin, which was on

9 the 10th or 11th. So you were there on the 9th.

10 A. It could have been the 7th or the 8th.

11 Q. Which means that Srebrenica hadn't been taken yet.

12 A. No, it hadn't.

13 Q. So what is that supposed to mean, that they all need to be killed

14 if Srebrenica hadn't been taken yet?

15 A. Well, Karadzic previously told me that our forces would go into

16 Srebrenica.

17 Q. We'll come back later to that when we have more elements and

18 clarify it, I hope. But now I want to ask you this: At that time, and

19 generally speaking, Mr. Deronjic, did you have any role in the command

20 chain, in the chain of command of the Ministry of the Interior of

21 Republika Srpska?

22 A. I had no role whatsoever.

23 Q. Was there any way you could have affected the decisions of

24 commanders in the police or the army?

25 A. No.

Page 29677

1 Q. You couldn't. How, then, do you explain the fact that Radovan

2 Karadzic told you that all of them needed to be killed if you were not

3 able to do that, according to your own words?

4 A. That's correct.

5 Q. So he couldn't have issued that order to you.

6 A. It was not an order that he issued to me. At the time when we

7 were speaking, it was clear to me and clear to him that it was not an

8 order. It was a possible outcome of the events in Srebrenica.

9 Let me just add that we discussed Srebrenica more than once and

10 that at our various meetings, we discussed the possible amount of

11 population in Srebrenica. And the question that imposed itself was what

12 would happen when our troops entered Srebrenica to the population.

13 Q. Do you know that Radovan Karadzic only on the 9th of July, in the

14 evening, when you claim you were with him, learnt from talking on the

15 phone to General Tolimir that there was a chance of capturing Srebrenica?

16 A. I don't know about that.

17 Q. If you don't know that, do you know that it was from that

18 information that the order of Karadzic followed to Generals Gvero and

19 Krstic?

20 A. I heard about that from one testimony in the Krstic case.

21 Q. That is an order issued on the 9th of July, 1995, signed by

22 General Tolimir, where it says, among other things: "In keeping with the

23 orders of the president of the republic, the order is issued to all units

24 involved in military combat activities around Srebrenica to ensure maximum

25 protection and safety to UNPROFOR troops and the civilian population.

Page 29678

1 Forward this order to all units to refrain from destroying any civilian

2 facilities unless forced to defend themselves. Refrain from destroying

3 property and treat prisoners of war and the civilian population in keeping

4 with the Geneva Conventions of the 12th of August, 1949."

5 I am quoting from an order which I have in front of me.

6 A. Yes, I saw that order in the Krstic case.

7 Q. You didn't see that order before, and you didn't know about it at

8 the time of the events in Srebrenica?

9 A. No. I never even saw it.

10 Q. And it is clear that what is conveyed here is the order from

11 President Karadzic himself on how to treat civilians and prisoners of war,

12 and it says that this order needs to be forwarded to all commanders in all

13 units involved.

14 A. Yes, that's what it says.

15 Q. This is dated 9th of July, 1995. Is it then clear, Mr. Deronjic,

16 that on the 9th of July, on that day you had no direct or telephone

17 contact with President Karadzic?

18 A. No, you cannot draw the conclusion that I was not at Pale then.

19 Q. If that conclusion cannot be drawn, then can we conclude that it

20 is indisputable in view of this order that Karadzic could not have issued

21 the order to kill people either to you or to anyone else? That's

22 precisely what the document says.

23 A. I told you, Mr. Milosevic, what we discussed. I never said that

24 it was in the form of order either to me or addressed to anyone else. It

25 was a conversation that followed after I learned that troops would enter

Page 29679












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 29680

1 Srebrenica. The president wanted to explain to me in a few words what

2 could be the epilogue and the denouement of these developments. He

3 referred to the principles of Western Slavonia. You do not believe, I

4 hope, that I imagined in some magic way this particular phrasing.

5 Q. I don't imagine anything. I'm presenting to you a document which

6 speaks clearly that Karadzic could not have told you or anyone else that

7 people needed to be killed. His orders are quite to the contrary: Take

8 care of the prisoners of war, civilians, et cetera.

9 JUDGE MAY: No. You have not paid attention to the witness's

10 answer, and you must do that if you are to cross-examine him properly.

11 You keep insisting that Karadzic was issuing an order, he tells you

12 plainly, the witness, that it was no order, it was simply a comment which

13 Karadzic made. There's no good repeating that it was an order when the

14 witness says firmly it wasn't. Let's move on to something else.

15 THE ACCUSED: [Interpretation] Mr. May, the point here is not

16 whether it was the order. The point is that what I just quoted was an

17 order, and the order clearly shows that Karadzic is saying that prisoners

18 of war, civilians, and the UNPROFOR troops should be treated in keeping

19 with the Geneva Conventions. That is why I am disputing that Karadzic

20 could have said to anyone, to this witness or anyone else, that people

21 needed to be killed.

22 JUDGE MAY: He said to you quite plainly that that is what

23 Karadzic said to him. Whatever other documents he may have issued,

24 whether they were truthful ones or not, doesn't matter. It's the

25 witness's evidence which we are dealing with at the moment. You can

Page 29681

1 produce other evidence in due course if you want, but you have heard what

2 this witness says; Karadzic told him.

3 MR. NICE: Your Honour, to assist, the document that the accused

4 is referring to is, I think, already in as D171.

5 JUDGE MAY: Yes. Marked for identification, I understand, at the

6 moment.

7 MR. NICE: And the document that's just been handed to you I think

8 is the document that the accused had marked for identification earlier.

9 It comes from our collection. You now have an English version of it.

10 JUDGE MAY: We have now got 171 too. Yes, we've got this order.

11 THE ACCUSED: [Interpretation] All right, then. It's not necessary

12 for me to tender it again, is it?

13 JUDGE MAY: There's no need to tender it again.

14 MR. MILOSEVIC: [Interpretation]

15 Q. All right, Mr. Deronjic. When you referred to this principle of

16 Western Slavonia, which is something that Karadzic referred to himself in

17 this conversation with you, there were only the two of you present then;

18 right?

19 A. Yes, at the moment when he referred to Western Slavonia and he

20 said all these things, we were standing about five or six steps away from

21 Momcilo Krajisnik and Jovica Stanisic.

22 Q. All right. You explained that they were talking between the two

23 of them and he took you aside to talk to you separately; correct?

24 A. Yes.

25 Q. And when up mentioned this principle of Western Slavonia, do you

Page 29682

1 know that during the events that took place in the Operation Flash, there

2 occurred a mass expulsion of Serbs from that territory? That was the

3 context. It could not have meant kill them all.

4 How did you deduce that it meant kill them all?

5 A. Mr. Milosevic, never did I say that I inferred that they all

6 needed to be killed. I quoted, memory permitting, what I remember from

7 that conversation, and my comment which I stated in my statement was that

8 I replied there was no way I could forecast what would happen on the

9 ground. That is one.

10 Second, the events in Western Slavonia that occurred on the 1st of

11 May, if I'm not mistaken, were commented upon by the leadership, the Serb

12 leadership of Republika Srpska, and the media. It was accepted wisdom at

13 the time that the Croatian army attacked not only the fleeing troops but

14 the civilians who were fleeing together with the troops. I think it was

15 widely reported.

16 Q. The events from Western Slavonia are well known, but it could not

17 have meant for a second that all of them needed to be killed.

18 A. There is a continuation to this sentence.

19 Q. On the 11th of July, and you say this in paragraph 184, Vidoje

20 Blagojevic, commander of the Bratunac Brigade, told you that there was an

21 order to go into Srebrenica. This is what you said, is it not?

22 A. Yes, that is correct.

23 Q. But you found out on your way to Srebrenica that Karadzic was

24 looking for you.

25 A. Yes.

Page 29683

1 Q. That's why you didn't go into Srebrenica. You returned to

2 Bratunac instead.

3 A. Yes.

4 Q. Couldn't you have talked to Karadzic from Srebrenica? Did you

5 have to return to Bratunac?

6 A. No, I couldn't because the troops had not yet entered Srebrenica.

7 They were just moving towards it.

8 Q. All right. So when you established contact with him - I'm drawing

9 your attention to paragraph 185 - the first thing he asked was the

10 following: "Deronjic, is my information correct that we had entered

11 Srebrenica?"

12 A. Yes. And that's what I said.

13 Q. Very well. Tell me, then, how do you explain the discrepancy in

14 what you are saying? Radovan Karadzic, president of the Republika Srpska

15 and its Supreme Commander, the Supreme Commander of its army, who only a

16 day before, in your own words, spoke to you about plans A and B and told

17 you to kill everyone, did not know how the Srebrenica operation was

18 proceeding and that he did not know whether his own troops had entered the

19 town and had instead to ask you. How come he was calling precisely you,

20 of all people, to ask this?

21 A. Mr. Milosevic, first of all, I want to say that these quotation

22 marks you see sometimes in my statement are not necessarily correctly

23 placed, because when my testimony was summarised, certain things may have

24 been marked as a quotation incorrectly.

25 Second, as I said, he was just asking me to confirm the

Page 29684

1 information he had already received. What is illogical about that?

2 Q. He asked, "Is my information correct?"

3 A. Yes, and it means he already was in possession of that

4 information.

5 Q. And he was asking you whether it was correct.

6 A. Yes, precisely.

7 Q. In that telephone conversation, among other things, Karadzic

8 explained to you what your duties would be as the newly-appointed

9 commissioner for Srebrenica.

10 A. Yes.

11 Q. Tell me briefly, what did he say about that?

12 A. The gist of his instructions to me had to do with the fate of the

13 civilians who were gathering in Potocari as we were speaking. He told me

14 to propose to them three alternatives and to establish contact with

15 Mladic, if possible. If you want me, I can describe to you the three

16 alternatives that I was supposed to convey to Muslim representatives

17 regarding their own treatment.

18 Q. All right. But the first alternative, the first option was to

19 tell them that they could stay in Srebrenica. Everybody who wanted to

20 stay in Srebrenica could do so.

21 A. Correct.

22 Q. And you say in your statement that it was complete madness. This

23 idea was complete madness.

24 A. Yes. If you want me to put it this way, it was mission

25 impossible.

Page 29685

1 Q. Can you explain to me the following: When he told you to tell the

2 Muslims that everybody who wanted to stay in Srebrenica could, why was

3 that madness?

4 A. I have already given you five or six reasons for that, and I can

5 repeat them if necessary. I don't think it is necessary. I think all

6 those reasons were widely known to Mr. Karadzic, to myself, and everybody

7 involved. You cannot seriously contend that that population, those

8 people, could have stayed in Srebrenica unhindered.

9 Q. What I know is that all the decisions and conclusions of the

10 leadership was that the population should be allowed to stay where they

11 were, not only in Srebrenica but in all other areas.

12 A. I don't know about any conclusions of the kind. Developments in

13 the field spoke to the contrary.

14 Q. Let me ask you this: I have this document that I had been served

15 with related to another witness. It says that the leadership of the SDS

16 issued instructions on the organisation and activity of the Serb

17 population in a state of emergency, and in item 8, because these are the

18 instructions you followed, reads: "In undertaking all these measures,

19 make sure that ethnic civil and other rights of all ethnicities are

20 observed and that they are organised under the conclusions of the Serb

21 authorities in the given municipality."

22 So that was a general conclusion, that ethnic and other rights of

23 all peoples should be respected and that they should be represented in

24 government bodies to be established later.

25 A. Yes. That's what it says.

Page 29686

1 Q. Since Mr. Nice insisted that there were Variants A and B according

2 to which members of other ethnicities from those areas should be removed,

3 and I did not find it anywhere in the programme of the SDS; on the

4 contrary, I see they speak of respecting the rights of all peoples.

5 A. It's true that it doesn't say so in the instructions, and I never

6 claimed that the document titled Variant A and B was the only reason that

7 caused a great number of people from that area to flee. It was just an

8 element, as I said, in the entire plan which caused the expulsion and

9 fleeing of those people. The events from the end of the war - let me add

10 this - have very little in common with the situation from the beginning of

11 the war. There were -- in the situation in Srebrenica as it was in 1995,

12 with Serbs ruling, it was absolutely impossible for the Muslims to stay

13 there.

14 Q. That may be your judgement, shared by other people perhaps, but

15 what I quoted was a generally accepted political stance expressed here.

16 But let us come back to the fact that you were the newly-appointed

17 civilian commissioner for Srebrenica. You discussed those two variants.

18 Is it true that he told you that you needed to contact General Mladic,

19 speaking of those three options, because General Mladic was in charge, and

20 you needed to agree on a meeting with the UNPROFOR and with the Muslims to

21 discuss these three options? I'm speaking about paragraph 187.

22 A. Mr. Milosevic, I will have to answer something else, to address

23 something else that you alluded to when you just spoke now. I'm going to

24 remind you that in 1992, an enormous number of Muslims from the eastern

25 part of Bosnia-Herzegovina, I'm talking about Muslims, left the area,

Page 29687

1 including leave the municipality of Bratunac and Zvornik.

2 If those were not the intention of the leaders of Republika

3 Srpska, do we know that somebody was arrested, tried because of this, or

4 convicted?

5 Q. Mr. Deronjic, I could address that question to you because you

6 were an official of Republika Srpska, not me. You were an official of the

7 SDS, not I.

8 A. Well, that's why I'm telling you, Mr. Milosevic, because I know

9 this, and I assume that I know it better than you do. Nobody was

10 punished.

11 Q. I assume -- well, it's not that I assume, I know for sure that you

12 know this better than I do.

13 All right now.

14 A. Shall we go back to this question, if you wish, the one related to

15 Mladic, the one that you put to me just now? I said that he had said to

16 me that Mr. Karadzic had told me to contact Mr. Mladic about this.

17 Q. Yes, and then you presented these options there.

18 A. At the meeting on the 12th of July at the Fontana Hotel, I

19 presented these options.

20 Q. So the first option was that the Muslims should stay in

21 Srebrenica, those who wished to do so; and the second option was that they

22 should go where the army of Bosnia-Herzegovina was in control, in the

23 direction of Kladanj; and the third was to go wherever they wished to go,

24 some third countries. So theoretically these were the only three options;

25 for them to stay, to go to territories that were under their control, or

Page 29688

1 to go to other places as refugees, wherever they wanted to go.

2 A. That is correct.

3 Q. And then you say that Karadzic on that occasion warned that it's

4 possible that some war criminals might try to hide among the civilians and

5 that he insisted that such people, if found, should be kept behind or

6 held, because you had the right to do that in accordance with the

7 conventions that had to do with the customs of war. Is that correct?

8 A. Yes.

9 Q. So he only wanted war criminals to be detained if such people were

10 to be found, and also the conventions that relate to customs of war should

11 be abided by.

12 A. Yes.

13 Q. So Radovan Karadzic, this same person who is telling you that

14 everybody should be killed, all the Muslims in Srebrenica, later on

15 insists that you meet in your capacity as new civilian commissioner with

16 the Muslims, with Mladic and UNPROFOR, that you present these three

17 options. That you present these three options and also you try to

18 identify war criminals in the ranks of the Muslims.

19 Mr. Deronjic, isn't that quite contradictory in relation to what

20 you asserted before, that he had said to you that all the Muslims should

21 be killed?

22 A. Yes, Mr. Milosevic. To a degree, these orders that I had received

23 directly over the telephone are contradictory to what the president told

24 me on the 9th of July, but let me explain. Let's dispel any possible

25 doubt. Do you think that in public directly he would tell me of any other

Page 29689

1 intentions that possibly - and I'm not claiming anything - he or somebody

2 else might have had and that these intentions could be carried through in

3 Potocari with the presence of the international forces, notably UNPROFOR?

4 And some journalists had already arrived as well. I'm not speculating on

5 this but I don't want to owe you any answers.

6 Q. Well, precisely. I don't think that anyone should speculate

7 because the entire idea is sheer madness, to have all these people killed.

8 Isn't that clear to everyone who has any degree of common sense? That's

9 why I find this incredible, that you say to me, "Karadzic told me, kill

10 everyone."

11 A. Mr. Milosevic, you keep repeating time and again only part of my

12 statement. When you put it that way, "kill everyone," it can imply

13 exactly what I've been saying, but he added yet another sentence,

14 "everything you can." So when he says "everything you can," then he's

15 not referring to absolutely everything, everybody.

16 Q. Well, whatever you managed to, in that sense. But it is sheer

17 madness for anyone to present that kind of idea.

18 JUDGE MAY: You know, we have been over this for half an hour.

19 You've been wasting time going over the same point. The witness has given

20 his evidence. This is what he claims Karadzic said. That's his evidence,

21 that that is what Karadzic said. There's no point going over it and

22 saying you found it contrary to common sense and whatever else. The point

23 is the witness's evidence is to that effect. Your going on asking him the

24 same question doesn't help.

25 Now, if you want more time and you're asking for it, you must use

Page 29690

1 your time usefully and not repeating.

2 THE ACCUSED: [Interpretation] All right. I'm not putting same

3 question to him all the time, Mr. May, though.

4 MR. MILOSEVIC: [Interpretation]

5 Q. Tell me, Mr. Deronjic, is it also correct that on that occasion he

6 say to you on that it was necessary for you yourself to enter Srebrenica

7 and to establish the police there to secure facilities and to establish

8 control over town?

9 A. Once the conditions are right for me to enter Srebrenica, that was

10 one of the primary tasks that I was given that evening.

11 Q. And you got -- and you asked him to give you all these orders in

12 writing; is that right?

13 A. First of all, I asked to get an order on my appointment because it

14 would have been wrong for me to do anything or say anything without that

15 kind of order.

16 Q. All right. But in relation to this establishment of the police,

17 securing facilities, establishing control over town generally speaking,

18 protection and so on, this was your task as civilian commissioner; isn't

19 that right?

20 A. Yes.

21 Q. You asked for him to give it to you in writing; is that right?

22 A. Yes.

23 Q. So then if you asked for all of this, how come you didn't ask for

24 the order to have someone killed when that is a cardinal thing? Is that

25 possible?

Page 29691

1 A. I'm sorry, Milosevic, we're going back to the same thing yet

2 again. I never said that everybody should be killed. You keep neglecting

3 all the time that I explained what "everybody" meant. The principle of

4 Western Slavonia, the army fleeing in different directions, possibly

5 civilians too, and that these columns should then be targeted. That is

6 how I understood it.

7 Q. All right. Is it correct that that evening on the 11th you found

8 out from people in the area, as you claimed, that a large number of

9 military-age Muslims withdrew in the direction of Konjevic Polje?

10 A. That's right.

11 Q. Do you know the numbers involved and how many of them were there?

12 A. I presented my opinion on this. I gave President Karadzic my

13 opinion too, that it was 15 to 20.000 men.

14 Q. Were they armed?

15 A. I don't know how many of them were armed. Many of these people

16 managed to get through to Tuzla having used weapons. I cannot give this

17 evidence. It's not possible for me to know this. But I assume that an

18 enormous number of them were armed.

19 Q. All right. So then, being armed and through fighting, they worked

20 their way all the way through to Tuzla.

21 A. As far as I know, a part of them were armed, but I don't know how

22 many actually.

23 Q. All right. Next morning early, on the 12th, you were told that

24 Mladic was looking for you and that he was waiting to see you at a meeting

25 at the Fontana Hotel; is that right?

Page 29692

1 A. Yes, that's right.

2 Q. Is it true that the meeting was attended by Muslim representatives

3 and you recognised two of them?

4 A. Correct.

5 Q. Is it correct that at this meeting they kept insisting that they

6 wanted to leave Srebrenica safely?

7 A. That's quite right.

8 Q. And nevertheless you presented the three options to them, the ones

9 that Karadzic told you about the previous day.

10 A. Yes, that's right.

11 Q. And also to detain persons for which civilian and military

12 authorities ascertained that they had something to do with the commission

13 of crimes; is that right?

14 A. That is correct too.

15 Q. All right. I thought that you could not remember and I wanted to

16 remind you. That is paragraph 193.

17 A. No, sorry. We had to pause between question and answer and you

18 weren't finishing so I was waiting for you to finish your question.

19 Q. Very well. But in spite of that, the Muslim representatives

20 insisted that the Muslims leave Srebrenica; is that right?

21 A. Yes, that's right.

22 Q. Isn't it beyond any doubt, Mr. Deronjic, in view of this

23 insistence on the offered options, that the Srebrenica Muslims and all the

24 others who were in the safe haven left Srebrenica at their own insistence?

25 A. That is a fact that is beyond any doubt.

Page 29693

1 Q. So they were not expelled. They left Srebrenica at their own

2 insistence.

3 A. Due to all these activities. I think that there was no other

4 solution anyway.

5 Q. And is it correct, Mr. Deronjic, that Karadzic telephoned you the

6 following day as well, on the 13th of July, to find out how the transport

7 of civilians was progressing and to express his interest in the fighting

8 that took place the previous day, on the 12th, in the area of Konjevic

9 Polje. This is paragraph 199 through 201.

10 A. Correct.

11 Q. Is it true that you said to him then that over a half of the

12 civilians had been transported by the time he made his telephone call and

13 that in the area of Konjevic Polje 12 to 15.000 people were pushing

14 through in the direction of Tuzla with heavy fighting and that you could

15 even hear fire exchanges and even artillery fire?

16 A. I don't know if each and every word is correct, but that is the

17 essence of my statement.

18 Q. But then you did not tell Karadzic on that occasion that in the

19 area of Konjevic Polje that they were already capturing or arresting

20 Muslims.

21 A. No. I did not tell him that because this is a telephone call from

22 my office.

23 Q. Why did you keep silent about that when speaking to him? Don't

24 you think that if you told him about it then that he could have stopped

25 such activities such as killings by way of his authority?

Page 29694

1 A. Mr. Milosevic, during a previous meeting I had, and that was on

2 the 11th, I was warned that if I had some information that I should go

3 through military channels. Also, anything that could be dangerous -- I

4 mean, that meant anything that could have been dangerous because of

5 eavesdropping. And also I was invited precisely because of this meeting

6 to come to Pale. So I had the possibility on the 14th in the morning to

7 inform the president about what had happened.

8 Q. All right. That means that until then he could not have been

9 informed.

10 A. That's not what I said. On the contrary. There are three

11 possibilities to inform the president from that area. One is the military

12 line, the Ministry of the Interior, the head of the public security

13 station, Mr. Vasic, and the state security with the office in Bratunac.

14 Q. All right. In paragraph 201, since you talk about liquidations,

15 in some way you are trying to say, and I want to be quite precise, when I

16 say "liquidations," I mean killings. I mean somebody was killed. It

17 doesn't have to mean that a person was executed, it means that these

18 persons were killed, lost their lives. What does this mean, not shot but

19 liquidated, executed? Isn't that one and the same thing?

20 A. How could it be one and the same thing, Mr. Milosevic? Somebody

21 could be taken prisoner and then shot, and then also a person could get

22 killed in fighting during a breakthrough.

23 Q. All right. What is your knowledge? How many of them were killed

24 during this fighting, during the breakthrough that we referred to a few

25 minutes ago when you said 12 to 15.000 persons were pushing their -- were

Page 29695

1 trying to get to Tuzla with heavy fighting?

2 A. I'm try to explain, Mr. Milosevic. We did not have any

3 information at the time. I had semi-information, information from people

4 in the field involving primarily the police high officials who were

5 involved in these communications. They told me that there were killings

6 and that there were liquidations. That meant that fighting had already

7 been going on, and of course there were casualties in fighting, in combat.

8 But also, people were being taken prisoner and liquidated, as they told

9 me.

10 The information I got about these events subsequently, that is to

11 say not on that day but later, much later, I found out that there were

12 very many people in that region who were killed in combat. I even had the

13 opportunity of informing the international public about this. When

14 Mrs. Elizabeth Wren visited Bratunac, I told them that in that area there

15 were a great many people who had been killed. They visited the area. I

16 don't know what the figures involved were, but very many people were

17 killed in combat.

18 Q. Just explain one thing to me, please -- rather, what was your

19 information on that day? Liquidations of prisoners on that day or were

20 most of the casualties due to the combat that was taking place?

21 A. I had both pieces of information on that day, namely that there

22 were casualties as a result of combat but also that there were persons who

23 were taken prisoner and killed. Revenge was also mentioned, that people

24 were doing this at their own initiative. That was the information I

25 received.

Page 29696

1 Q. All right. Do you have, or rather, did you have on that day any

2 information as to the scope of the killings? I'm not talking about combat

3 casualties. You said that many people were killed in combat. Were these

4 individual cases of revenge and similar matters, as you said just now, or

5 did you have information that many people were killed that way?

6 A. On the 13th, in the afternoon -- that is to say in the evening,

7 rather, but not at the moment when I spoke to Karadzic on the telephone

8 when he called me. So on the 13th, in the afternoon and in the evening, I

9 had received information that at the Kravica cooperative, several persons

10 had been killed. I don't know who conveyed this information to me, but it

11 was explained to me by Mr. Borovcanin in the evening, namely what had

12 happened exactly. That involves a great many victims. That is my answer

13 to your question. Everything else that I heard, that I mentioned can

14 refer to individual cases but I do not have much information.

15 Q. So on that day when you talked to Karadzic, you had not received

16 information about this yet, what you said just now at the cooperative, at

17 the farm, that there had been many persons who were killed.

18 A. Yes.

19 Q. And then after that did you inform Karadzic about this or anybody

20 else from the leadership, either civilian or military leadership, about

21 what had happened, what you found out later?

22 A. Yes.

23 Q. When did you inform him?

24 A. On the 14th. Because on the 13th I was invited to come to Pale.

25 So on the morning of the 14th, sometime during the morning, I was in Pale

Page 29697

1 and I said this to the president.

2 Q. All right. Before we get to the 14th when you were in Pale, the

3 person who informed you about this, what had happened, did this person

4 tell you who had committed the killings?

5 A. No, Mr. Milosevic, this was not something he said to me. This

6 person told me the circumstances under which these persons were killed at

7 the cooperative.

8 Q. I don't understand what "circumstances" means. He did not tell

9 you who killed these people?

10 A. Of course not. I don't think he knew at that moment. This was

11 right after that. How could he have known? How could he investigate so

12 quickly and tell me about this? He told me that these were the units that

13 happened to be there, including his own unit of the special police. But I

14 do not preclude the possibility of somebody else having taken place in

15 that, even until the present day.

16 Q. In 205 you say that Borovcanin said to you that Mladic had issued

17 orders for the army to move to Zepa.

18 A. You mean 205, paragraph 205?

19 Q. Yes, yes. That's correct.

20 A. Yes.

21 Q. And you said that this information was something you found

22 upsetting because, as you say, the majority of the Muslim forces were not

23 defeated and were very close to Bratunac, to the Bratunac area.

24 A. Correct.

25 Q. So in spite of the fact that the majority of the Muslim forces had

Page 29698

1 not been defeated yet, Mladic, with the bulk of his forces, moves towards

2 Zepa; is that right?

3 A. He issues orders for the army to go to Zepa, and I do not know how

4 many forces actually went to Zepa and how this evolved in formal terms.

5 Q. Tell me, then, Mr. Deronjic, does it mean that already on the 13th

6 and the 14th Mladic was not in Srebrenica any more?

7 A. How could I draw that conclusion? I don't understand.

8 Q. You were informed that Mladic had moved on towards Zepa.

9 A. No. Borovcanin said that an order had been issued for troops to

10 move on. First of all, the troops did not necessarily move on that very

11 day; and second, Borovcanin did not necessarily have to go with then.

12 Q. In paragraph 206, you say that due to the great number of captured

13 Muslims who were in danger of being killed, you called Karadzic to ask him

14 what to do.

15 A. Yes.

16 Q. Didn't you by that time have very clear instructions from both

17 Karadzic and Tolimir that all civilians, all Muslims should be given

18 security and treated in keeping with Geneva Conventions?

19 A. How could I have had this information? I told you I did not know

20 about that order that you mentioned.

21 Second, even if I had known about it, at that moment the prisoners

22 were not guarded properly, were not kept in appropriate premises and

23 killings were already taking place in the Vuk Karadzic school building.

24 Q. You say that Karadzic told you on that occasion, "Well, Miroslav,

25 can you hear me? I'm going to send such-and-such a man who will be

Page 29699

1 carrying instructions."

2 A. Yes. He said something like that.

3 Q. Is that the kind of conversation you have with mediators, with

4 go-betweens involved?

5 A. Yes.

6 Q. This conversation was first transcribed in hand and then typed

7 out. I don't know what "B" means and "D." "D" must be for Deronjic, I

8 suppose.

9 A. Probably.

10 Q. And "B" is the go-between. Is that correct?

11 A. Yes, yes. I'm not disputing any of these things.

12 Q. Tell me, then, where does this transcript come from? What is true

13 about this? What actually happened?

14 A. I told you. It was my conversation with President Karadzic, and

15 I'm not going to go into whether it was recorded or intercepted. That's

16 what we talked about on the phone. And I told you that I described this

17 conversation even before I found out that this transcript existed, and I

18 can confirm every sentence here.

19 Q. All right. But until I saw this transcript, which was very

20 recently, it seems that you were not talking to Karadzic. You were

21 talking to a mediator.

22 A. I talked and explained to the Office of the Prosecutor. At one

23 point I heard the voice of President Karadzic, but I'm not going to claim

24 that any of these sentences were uttered by him. Many of them were

25 conveyed by a go-between.

Page 29700

1 Q. At one point you say: "Can we hear each other, President?" And

2 the go-between says: "The president cannot hear you. This is the

3 intermediary." And then you go on to say: "I have about 2.000 here now

4 by --" and in brackets it says the teleprinter drowns him out. I suppose

5 that it was some sort of background hum. And then the president says:

6 "All the goods must be placed in warehouses before 12.00 tomorrow," and

7 you reply: "Right." And then this "X" says: "Deronjic, not in the

8 warehouses but somewhere else."

9 Could you please explain which part of this is something that he

10 said, and what did you mean in the last line by "understood"?

11 A. First of all, Mr. Milosevic, this is not a complete recording of

12 my conversation with President Karadzic. That conversation included other

13 things as well.

14 You have three dots here after the word "by". It means that there

15 were interruptions in that conversation, or at least in the record. I

16 pointed this out to the Office of the Prosecutor, and they confirmed it.

17 Second, a part of the conversation was indeed drowned out by a

18 teleprinter. Third, I asked for instructions as to how to treat the

19 captured Muslims. Instructions not for myself. My primary intention was

20 to inform the president very briefly, because I could not give him all the

21 details over the phone, I just told him the number of prisoners in

22 Bratunac and asked how to treat them. And to that Karadzic or the

23 mediator, whoever, said that they should be placed in warehouses but not

24 in Bratunac but elsewhere, from which I understood that they should not be

25 held in Bratunac. That was something I thought even before the

Page 29701

1 conversation, and I just understood him as confirming my own idea.

2 Q. I am asking you about this part. You say at this point that they

3 should not stay in Bratunac but they should be evacuated instead.

4 A. Yes.

5 Q. There is no mention of liquidation at all.

6 A. No, not in this conversation.

7 Q. Reference is made to evacuation from Bratunac. Is it possible

8 then, since you stated earlier, I don't know in which paragraph but when

9 you described your duties as civilian commissioner to provide material

10 supplies or war booty, could "goods" here be a reference to war booty?

11 A. Absolutely not, Mr. Milosevic. I relayed to the president

12 information that I couldn't go in detail on the phone, and I told him

13 about how many people were captured.

14 Q. And was that number 2.000?

15 A. Yes, approximately. He asked me, and I gave him my rough

16 estimate.

17 Q. And who is this mediator to whom you spoke? Do you have any

18 information at all about that?

19 A. I have no precise information, and my memory of these events has

20 faded considerably. But that was a military communication line from the

21 Bratunac Brigade with the president. I don't know how it works,

22 technically speaking. All I know is that somebody would say, "Hello. You

23 are now talking to the president. You can start talking," et cetera.

24 Q. So indeed if this is a reference to people, the order is to

25 evacuate them from Bratunac, not to liquidate them.

Page 29702

1 A. Yes. He says that they should be evacuated.

2 Q. In the same paragraph, you say you wanted to inform him that

3 people had been killed in the Vuk Karadzic school.

4 A. My intention when I went to speak to Karadzic was to warn him that

5 there were incidents and killings.

6 Q. It was your intention but you didn't actually inform him.

7 A. I don't know exactly. I believe I didn't.

8 Q. Why didn't you?

9 A. Because it is not the best idea to say such things on the phone.

10 Q. You implied, you thought, that he needed to be informed, as you

11 just said, because something needed to be done to prevent this.

12 A. That's correct, Mr. Milosevic. I cannot remember the exact words

13 in that conversation, but I did use hints and allusions to relay the most

14 important information, and I think he understood me well.

15 Q. So he was talking to you, and you informed him as the main person,

16 the civilian commissioner for Srebrenica, that killings were occurring,

17 and you didn't know at the time on what kind of scale it was going on.

18 But I suppose that at the moment you did intend to put a stop to it, to

19 prevent it.

20 A. Absolutely correct. And that was one of my intentions when I went

21 to have this conversation. I will not mention all the other measures I

22 took. If the Court asks me, I will describe them.

23 You mention that I was appointed civilian commissioner for the

24 area of Srebrenica with a very strictly defined purview. If you think

25 that these killings were also part of my responsibility, I reacted to them

Page 29703

1 as a human being. It had nothing to do with my duties, with my official

2 responsibilities.

3 I want to remind you that the complete staff of the army of

4 Republika Srpska was present there. Everyone from the Main Staff to

5 brigade staffs, all the relevant steps in the hierarchy were represented,

6 including the police force, and with all that in mind, do you really think

7 it was my job to secure those prisoners?

8 Q. No. What I'm saying is that if you are Man Number One in

9 political and administrative terms, it is your job to protect these

10 people, or at least to protect them from these killings. And what have

11 you done about it? You didn't even inform Karadzic.

12 A. Interpreters are warning me to make pauses.

13 It is absolutely true that I did take certain actions. In my

14 statement, I enumerated them. I invited police officers to come to my

15 office. I asked them to provide better protection to those prisoners.

16 During the night, certain people, retired people and even underage

17 people, were mobilised and engaged as security. Bratunac was absolutely

18 empty at that time. All available forces were engaged along the axes of

19 combat that were exactly 22 kilometres away from Bratunac.

20 I did inform the president, using indirect speech, telling him

21 that bad things were happening, and he understood me very well.

22 I apologise to the interpreters.

23 I told him that this transcript is not a reflection of the

24 entirety of my conversation. You can ask for an expertise and you will

25 see that there were other things said during that conversation.

Page 29704

1 Wait. Don't interrupt me. I haven't finished answering.

2 Q. I just want to tell you that I cannot consult documents that have

3 never been given to me. I don't want to put you on an unequal footing in

4 this discussion. This is an exhibit of the side opposite, and if there

5 are any inconsistencies, I want you to point them out.

6 A. I will. That's precisely why I'm saying this. Let me give you a

7 comparison.

8 In 1992, when volunteers came, 32 of them, armed to their teeth,

9 started killings in Bratunac. At that time, I am a civilian, a political

10 figure. How do you think that I could have adequately protected those

11 people in Bratunac on the 13th of July, 1995, if I was unable to act in

12 1992?

13 Q. But you said yourself that you didn't even inform Karadzic.

14 A. I informed Mr. Karadzic of that on the 14th in the morning,

15 because after the conversation we had in the afternoon on the 13th, I knew

16 that I would meet him at Pale the next day.

17 Q. All right. Before we move on to the 14th, you say that on the

18 13th in the evening, a colonel or a lieutenant colonel burst into your

19 office. Some sort of intelligence officer or security officer of the army

20 of Republika Srpska; right?

21 A. Absolutely correct.

22 Q. This Colonel Beara -- and you supposed, you assumed that he was an

23 emissary from Karadzic conveying his orders.

24 A. Yes, that's exactly what I said.

25 Q. How did you assume that? On what basis? Did he say in so many

Page 29705

1 words that he was coming on behalf of the president of the republic or was

2 it as you say, that he barged in, he was in his cups. Did he say that he

3 was coming with a message from the president of the republic, Radovan

4 Karadzic?

5 A. I will answer your questions one by one. Your first question was

6 how could I have known that he was coming from Karadzic. I just explained

7 to you that I had talked to Karadzic three or four hours prior to that,

8 and he told me, without naming names, that a man would come - I explained

9 this in precise terms to the Office of the Prosecutor - a man come

10 carrying instructions.

11 The arrival of Beara even took me by surprise. I didn't know. I

12 didn't expect that he would come to my office. I was concerned about the

13 situation in Bratunac, and I was looking for a way out, for a solution.

14 It is true that Beara did not say in so many words that he was coming with

15 instructions from President Karadzic. It is my inference that he was

16 coming with instructions, and it is based on the fact that he later took

17 charge of these people and the security provided to them, and on the fact

18 that nobody else appeared in Bratunac after that with any sort of

19 instructions.

20 Q. Okay. Tell me, what exactly did Beara tell you on that occasion?

21 A. If you are referring to explicit orders, he told me,

22 "Mr. Deronjic, I have orders from the top that these people should be

23 killed."

24 Q. He told you he had orders that these people should be killed?

25 A. Yes.

Page 29706

1 Q. And you inferred it was coming from Karadzic, although he didn't

2 tell you so.

3 A. At that moment, I was not thinking about that. He just said from

4 the top, from above.

5 Q. From above. And you asked Ljubo Simic -- who is Ljubo Simic, tell

6 me.

7 A. The president of the Bratunac municipality.

8 Q. So you asked this Ljubo Simic to leave you alone in the office

9 because you wanted to be one-on-one with Beara.

10 A. Yes.

11 Q. And when you remained one-on-one, wasn't it natural to ask him,

12 "Did Karadzic send you? Who gave you these orders?" Once you had

13 removed this person who was your Man Number Two, a municipal official,

14 wasn't it logical to ask the question, "Who sent you, and what exactly did

15 they say?"

16 A. I talked to Beara for a couple of minutes, maybe 10. He spent

17 some time, quite some time in my office, because he was inebriated, as I

18 explained to the Office of the Prosecutor, and this is just an expert --

19 excerpt from my description. And I quoted only the most relevant facts

20 that he stated.

21 I returned to my office after seeing Mr. Simic off, and then

22 speaking in a rather sharp tone, I told Beara, "What you are conveying to

23 me as orders does not coincide with the instructions I received from

24 President Karadzic." And then we had a confrontation.

25 Q. So according to you, Beara told you that people needed to be

Page 29707

1 killed, people should be killed, and you replied that that was not in

2 accordance with Karadzic's instructions. And an hour or two ago you

3 explained that it was Karadzic who told you that people should be killed,

4 everyone should be killed. Is it now clear that Karadzic did not tell you

5 that everyone needed to be killed, and it is questionable even what Beara

6 told you if he was so drunk as you say?

7 JUDGE MAY: We're not going over that point yet again. We've been

8 over it I think 20 times. No need to answer that question.

9 MR. MILOSEVIC: [Interpretation]

10 Q. All right. Tell me, what Beara allegedly said, did he say it in

11 front of Simic or did he say it after you had removed Simic from the

12 office?

13 A. The direct order, the way he conveyed it to me is what he said

14 after Mr. Simic left.

15 Q. So Simic cannot corroborate what you said?

16 A. Not this order. Not for sure.

17 Q. According to what your statement says, after you sent Simic away,

18 you told Beara that you had talked to Karadzic and that the prisoners

19 should be taken out of Bratunac, evacuated from Bratunac, that is, towards

20 Bijeljina, Batkovic. Well, Batkovic was a kind of collection centre,

21 wasn't it?

22 A. I don't know exactly what it was, but I had information that it

23 was a prison, a military prison in the area around Bijeljina.

24 Q. All right. So you conveyed to him that in agreement with

25 Karadzic, these prisoners should be taken to the military prison?

Page 29708

1 A. Exactly.

2 Q. And that was in accordance with the instructions you had received

3 from Karadzic when he had said to you that the prisoners should be taken

4 to the military prison in order to establish whether there were any war

5 criminals among them; is that right?

6 A. I'll tell you quite precisely that was my interpretation of the

7 president's instructions and I acted in accordance with my own

8 interpretation.

9 Q. So your interpretation of his instructions was that the prisoners

10 or, rather, prisoners of war should be taken to the military prison.

11 A. Correct.

12 Q. Not killed; right?

13 A. That's right.

14 Q. All right. On the basis of what you said, that Karadzic said that

15 a man would come who would tell you what to do, not to hand over the

16 prisoners to him or anything else; is that right? He said a man would

17 come who would tell you what to do.

18 A. No. He did not say that a man would come who would tell me that,

19 and I do not have any kind of direct role. It's not that I am supposed to

20 hand over the prisoners to anyone. My concern had to do with the fact the

21 president said, "All right. I'll send a man who has instructions." So

22 what did I have to do with that? I mean, how could I hand over anyone to

23 the military? How could I hand over the military prisoners to the

24 military itself?

25 A. Well, that's what I was wondering too.

Page 29709

1 A. No. That's not what I was supposed to do.

2 Q. But in accordance with Karadzic's instructions, you insist that

3 they be evacuated to the military prison, these prisoners.

4 A. Yes. I insisted they be taken there because that was my

5 understanding.

6 Q. All right. So that was your understanding of what Karadzic said,

7 that he asked for the prisoners to be sent to the military prison.

8 A. Correct.

9 Q. And after this meeting with Beara -- and he had not been announced

10 to you because you say that he just barged into your office.

11 A. That's right.

12 Q. And this meeting ended in the early morning hours on the 14th of

13 July; is that right?

14 A. That's right.

15 Q. You informed Karadzic and you asked him whether that was the man

16 who was allegedly supposed to convey instructions, is that right, since

17 you did not ask this man?

18 A. Mr. Milosevic, I did not because this was late in the night or,

19 rather, already the morning of the 14th of July, and that morning I went

20 to Pale.

21 Q. Wait a minute. Before you went to Pale, you say in paragraph 211

22 that you met up with Beara again that morning, that is to say the 14th of

23 July, halfway in relation to a place that you marked here as the brick

24 factory and Bratunac; is that right?

25 A. Yes, that's right.

Page 29710

1 Q. When was that?

2 A. In the morning of the 14th.

3 Q. But when? You say that you ended that meeting in the morning. So

4 again you say "in the morning." What does this term "in the morning"

5 actually mean? When did you meet Beara on this road leading to the brick

6 factory?

7 A. Lest there be any conclusion so that you would not confuse anyone

8 else or that you would not be confused, this meeting took place in my

9 office with Beara during the night until the early morning hours, and it

10 can be concluded, since I say "in the night," that it had not dawned yet.

11 After that meeting, I went home. I decided to get some rest, to get a bit

12 of sleep for a while, and then to go to Pale on the following day and to

13 see Mr. Karadzic as agreed with him.

14 And I don't know exactly when I was awakened; 5.00, 6.00, 7:00 in

15 the morning, it has been a very long time since then, after all, but I

16 remember very well my encounter and also what the reason was why somebody

17 had awakened me, and that was more important for me to remember that

18 rather than what time it was exactly. Namely, I left because somebody

19 told me that Beara was trying to take people to the brick factory in order

20 to possibly do something to them. Nobody said to me that he'd kill them

21 there or something like that, but that was the assumption on the basis of

22 his behaviour, and that is the kind of assumption that I made.

23 Q. Excuse me, Mr. Deronjic. Then I did not link all of this up

24 properly. You say now that you heard that Beara would take the people to

25 the brick factory.

Page 29711

1 A. Yes.

2 Q. So people were not already at the brick factory. The danger was

3 that Beara would take them to the brick factory.

4 A. Exactly.

5 Q. And when you caught up with Beara, as you say yourself in your

6 statement, you caught up with him at some kind of bridge that is halfway

7 between Bratunac and the brick factory. He was alone. He was not

8 bringing anyone along with him.

9 A. He was on his own. He was in a car and I think that he had his

10 escorts there.

11 Q. I was not referring to his driver escorts or someone, but he was

12 not bringing the prisoners along, none of them.

13 A. That's right.

14 Q. So you did not see him with any prisoners. He was not taking

15 anyone to the brick factory.

16 A. No, he wasn't.

17 Q. So what was the result of your conversation with him then?

18 A. I asked him why he went to the brick factory, and I asked him what

19 he intended to do there. He's not the manager of the brick factory in

20 Bratunac. He went to the brick factory with a clear intention of doing

21 something, to see what he could do to the prisoners. He said -- well,

22 I'll try to remember his exact words as best I can. "Well, I went there

23 to see whether perhaps some of the prisoners could be put up there." He

24 did not say that he wanted to kill anyone there because he saw how worried

25 I was about all of this. And I said to him, "Mr. Beara we talked about

Page 29712

1 this last night. All of this is out of the question. The brick factory

2 or anything else in Bratunac. Please go ahead and act on your orders

3 but --"

4 Q. Mr. Deronjic, on the basis of what you've been saying just now it

5 is my understand that you did not want the prisoners to be kept in

6 Bratunac. You wanted, regardless of whether they would be detained in the

7 brick factory or some other facilities, you wanted them to be evacuated

8 from Bratunac and to the military prison; is that right?

9 A. Yes, that's right.

10 Q. That is what you insisted upon, that Beara should do that, and

11 that is what he accepted; is that right?

12 A. Yes. Ultimately that's what he did. And he did take these people

13 in the area of -- in the direction of Zvornik the next day or, rather,

14 that day.

15 Q. So on the 14th, he took them from Bratunac.

16 A. The 14th. But I should just like to remind you of a fact. I

17 think it's important, and that's why I refer to it. On the evening of the

18 13th, I received information that some buses, before Beara came to my

19 office, had already set out - I don't know on whose orders, that is

20 something I don't know at all - in the direction of Zvornik.

21 Q. All right. So this Beara who came to see you in the early morning

22 of the 19th -- of the 14th, that was after midnight, actually. He had

23 nothing to do with the people who were taken to Zvornik because he came to

24 see you later.

25 A. Mr. Milosevic, why do you preclude that possibility? And I'm sure

Page 29713

1 that you are smart enough. He could have been in my office before too.

2 Q. I'm just asking about what you could know.

3 A. I don't know whether he was there before but there is such a

4 possibility, isn't there?

5 Q. All right. According to the information that I have,

6 Mr. Deronjic, you came to Pale on the 14th of July with a delegation from

7 Srebrenica, is that right, for a meeting with Karadzic?

8 A. I will explain this to you, Mr. Milosevic. I explained this quite

9 precisely in my longer text, and I expressed my doubts as to whether we

10 held that meeting that day with the representatives from Srebrenica. Was

11 it that day or perhaps the next day? I could not remember exactly. I

12 thank you if you have this document. That means that it confirms that on

13 that day we had that meeting too with the representatives from Srebrenica,

14 who were opposed to my appointment as civilian commissioner, and they said

15 that at a previous meeting. And I know on the 13th they went to see

16 Karadzic, and they demanded that one of them be involved or appointed to

17 the position that I had been appointed to.

18 What am I trying to say now? I did not leave with the

19 representatives of Srebrenica. I left the way I described this. I don't

20 want to repeat it yet again.

21 So there were two possibilities: The president and I perhaps met

22 before that meeting if that meeting was on that day, with the

23 representatives from Srebrenica; or there is this other possibility that

24 perhaps on one of the following days this meeting was held with the

25 representatives of Srebrenica. But at this meeting where I informed the

Page 29714

1 president about these events, the people from Srebrenica were not present,

2 although it is possible that on that day after that talk we also spoke to

3 the representatives from Srebrenica.

4 And I remember this meeting. I remember the details of the

5 meeting with the representatives from Srebrenica, but I just wasn't sure

6 whether this was after this meeting of mine with Karadzic or perhaps on

7 one of the following days, because there was a great deal going on, and

8 it's hard for me to remember each and everything exactly.

9 Q. I have an excerpt here from the diary of the 14th of July. It

10 says the 14th of July, but all of it is handwritten. Nevertheless, it can

11 be read. I assume it's some plan, some schedule of meetings for that day,

12 and it is my assumption that it was Karadzic's secretary who wrote this.

13 I don't know. 1800 Churkin, and then 19 to 2240. And then it says Miraz

14 or Mira Petrovic, 1315 to 1345, so that is half an hour. And then

15 Karadzic and Ostojic, and then that was respond for the following day, and

16 then 11:00 Deronjic Miroslav and the delegation from Srebrenica.

17 MR. NICE: Your Honour, this is not a document known to us, and

18 obviously if the witness is to be asked about it, he should be shown

19 copies of it, and it's a document obviously --

20 JUDGE MAY: Let's wait and see. We'll come to the point in a

21 moment.

22 Yes, go on, Mr. Milosevic, if you would get to the point, please.

23 THE ACCUSED: [Interpretation] Well, this is what the point is:

24 This is a diary. This is an ordinary notebook of Karadzic's secretary,

25 and my associates obtained this during the past few days. It says 1100

Page 29715

1 Deronjic Miroslav and delegation, "DLG" it says, of Srebrenica 11:00. But

2 then in brackets it says 1425 until 1825.

3 So on that day were you there with the delegation of Srebrenica

4 for all of four hours with Karadzic? I'll give you this. You can have a

5 look at this.

6 JUDGE MAY: Yes. Let the witness see it. Before answering, he

7 should be able to see what it says.

8 MR. MILOSEVIC: [Interpretation]

9 Q. It is in the second part, where it says the 14th of July. I have

10 read all of this out to you in order. Perhaps it would be of assistance

11 in terms of reconstructing what had actually happened.

12 A. Mr. Milosevic, what I see here is that it was envisaged, I imagine

13 in this diary that you referred to, that Mr. Karadzic would meet with me

14 at 11:00 in the morning of the 14th, and that the meeting with the

15 representatives of Srebrenica would take place at 1425 until 1825.

16 Q. No. The only thing that it says there was that it was planned for

17 the 11th but that it was held from 1425 until 1825, as it says in other

18 cases when it was planned and when it actually took place. And for a

19 variety of reasons, I cannot fathom this, but it's not for me to fathom it

20 anyway.

21 Did you spend four hours at Karadzic's with a delegation from

22 Srebrenica?

23 A. Wait a minute, look at this up here, Djoko Pudarevic [phoen] from

24 1520 to 1525. I'm not talking about the previous day. The date is behind

25 it. It doesn't have to mean that it was actually held then, the meeting,

Page 29716

1 but it was scheduled for then. But I am going to answer your question.

2 I arrived in Pale, and I said it already and I cannot remember

3 exactly at what time, and before that, President Karadzic and I were on

4 our own. We held a meeting devoted to the subject of the events that had

5 to do with the evacuation of civilians from Potocari. I think this is

6 quite logical because it was the first time that we had the opportunity of

7 meeting up again after the 12th, after the 13th, after the evacuation of

8 Muslims from Potocari. And all the information that had to do with the

9 meeting in Fontana, and so on and so forth, I had quite a few things to

10 tell the president about. And during this part of the conversation, I

11 conveyed to President Karadzic the details that I had at that moment

12 related to the incidents in Konjevic Polje, about the large-scale massacre

13 in Kravica at the cooperative in Kravica.

14 I remember -- I recall that he asked me what happened to the

15 bodies. That is something that remains in my memory.

16 Then we also talked about Mr. Beara showing up in my office and I

17 quoted the sentence that he conveyed to me verbatim, trying to find out

18 what you are asking me about now all this time, whether this was his order

19 or whether these were his instructions.

20 JUDGE MAY: We've gone past the time for an adjournment. Can we

21 see that document, please, Mr. Deronjic.

22 Do you want to exhibit this photocopy, Mr. Milosevic?

23 THE ACCUSED: [Interpretation] I think it would be useful, Mr. May.

24 JUDGE MAY: We will simply mark it for identification, no more,

25 because it's only a photocopy and the original is not present, but we

Page 29717

1 could keep it marked for identification.

2 Do you also want to exhibit the plea agreement you referred to

3 earlier?

4 THE ACCUSED: [Interpretation] Certainly, Mr. May.

5 JUDGE MAY: Yes. Well, we'll exhibit both those items.

6 THE REGISTRAR: Your Honour, the plea agreement will be Defence

7 Exhibit 220, and this recent document will be Defence Exhibit 221 marked

8 for identification.

9 JUDGE MAY: Yes. Mr. Milosevic, we've considered the position

10 about your cross-examination. You can have half an hour tomorrow morning

11 further to continue your cross-examination of this witness.

12 Mr. Deronjic --

13 THE ACCUSED: [Interpretation] Mr. May, Mr. May.

14 JUDGE MAY: Just a moment, I'm speaking to the witness.

15 Mr. Deronjic, would you back, please, tomorrow morning at 9.00 to

16 continue your evidence.

17 THE ACCUSED: [Interpretation] Mr. May, I absolutely cannot finish

18 the cross-examination of this witness within half an hour. It is

19 impossible.

20 JUDGE MAY: You were warned about the time. You have chosen to

21 devote the entire time which you had today, which you were told about at

22 the beginning, on one topic. You must understand that these time limits

23 mean that you must organise your time to take account of them.

24 We will adjourn now. Nine o'clock tomorrow morning.

25 --- Whereupon the hearing adjourned at 2.07 p.m.,

Page 29718

1 to be reconvened on Thursday, the 27th day of

2 November, 2003, at 9.00 a.m.