Tribunal Criminal Tribunal for the Former Yugoslavia

Page 5756

 1                           Friday, 29 January 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.07 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 6     everyone in and around the courtroom.  This is case IT-08-91-T, the

 7     Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Good morning to all.  Before I call for the

 9     appearances, I wish to indicate for the record that, again, due to the

10     continued indisposition of Judge Harhoff, we are sitting under the

11     provisions of Rule 15 bis.

12             MS. KORNER:  Good morning, Your Honours.  Appearing for the

13     Prosecution, Joanna Korner, Belinda Pidwell, and Crispian Smith.

14             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

15     Slobodan Cvijetic, and Eugene O'Sullivan appearing for the

16     Stanisic Defence this morning.  Thank you.

17             MR. PANTELIC:  Good morning, Your Honours.  For Zupljanin

18     Defence, Igor Pantelic and Dragan Krgovic.

19             JUDGE HALL:  Thank you.

20             MS. KORNER:  Your Honours, before the witness comes back in, can

21     I formally apply for more time as I indicated yesterday.  Having reviewed

22     what is left yesterday evening and having being told that I have already

23     taken two hours and 50 minutes, which I had not appreciated.  I suppose

24     one could it's amazing how time flies when one is enjoying oneself.

25     However, can I ask formally if I may have between an extra hour and

Page 5757

 1     90 minutes, taking it up to a total of five and a half.  I hope to

 2     complete within 2 hours and 10 minutes, but there is still a lot of

 3     documents to be evidenced.  And his own account of what happened to him

 4     after the beginning of April.

 5                           [Trial Chamber confers]

 6                           [Trial Chamber and legal officer confer]

 7             JUDGE HALL:  Ms. Korner, before we formally rule on that

 8     application that you are now making, we are trying to work backwards, as

 9     it were, from the -- what is fixed for Tuesday.

10             MS. KORNER:  Yes.

11             JUDGE HALL:  And bearing in mind the time that is -- would be

12     required for cross-examination and re-examination, I suppose, where do

13     you think that this would place us?

14             MS. KORNER:  I'm trying -- the Defence estimates for

15     cross-examination were ... four plus one.  So that is four hours for

16     Stanisic, one for Zupljanin.  That's five hours.

17             Hour and a half -- sorry, an extra hour and a half for me would

18     take us up to just before the second break, I think.  Give or take.

19             So that should still leave time for Monday for the Defence to be

20     completed.  And obviously if I'm denied my re-examination, I have to

21     accept that's -- that's something that I will have to deal with.  But I

22     appreciate we've got videolink lined up for Tuesday through Thursday.

23             JUDGE HALL:  It has been confirmed to us that there is a

24     courtroom available on -- on Monday morning, because the -- we were

25     scheduled on Monday afternoon.  And is the -- is it premature to think

Page 5758

 1     now, in terms of resumption on Monday morning with an extension into the

 2     afternoon with a view to finishing this witness.

 3             MS. KORNER:  I think, Your Honour, that would be very helpful if

 4     I may so.  We all hope that it's completed, if we can sit Monday morning,

 5     by Monday morning.  And I know that the witness in particular would --

 6     would wish to be completed.  Indeed, I understand from VWS he had not

 7     appreciated the possibility that he might be here on Monday.  And I think

 8     maybe we need to do deal with that.

 9             But I think certainly we would -- obviously we would have to be

10     completed on Monday, and I think that would help, if it's available.

11             JUDGE HALL:  So we grant your application for the extra time,

12     Ms. Korner.

13             MS. KORNER:  Thank you very much, Your Honour.

14                           [Trial Chamber and registrar confer]

15             JUDGE HALL:  Thank you.  The Registry will make arrangements for

16     the court to sit the usual morning session on Monday and then one extra

17     session in the afternoon.

18             MS. KORNER:  Thank you very much, Your Honours.

19             JUDGE HALL:  And if that disposes of preliminary considerations,

20     would the usher kindly escort the witness back to the stand.

21             JUDGE DELVOIE:  Ms. Korner, Ms. Korner, is the witness aware of

22     the fact that he is expected to be here on Monday as well?

23             MS. KORNER:  The answer is, I'm not sure.  I think he has

24     realized it because he raised with VWS there was a problem.

25             JUDGE DELVOIE:  One told us that he already had a problem being

Page 5759

 1     here today.

 2             MS. KORNER:  Yes, I know.  And now I understand from VWS he has

 3     raised the problem of Monday.

 4             Just before the witness comes in, the letter that he received

 5     from the home office which was -- reference was simply said he had to

 6     report here for Thursday or Wednesday.  And it didn't make it clear,

 7     although there is a further letter which you may have seen saying he is

 8     at the disposal of the Court, obviously.

 9                           [The witness takes the stand]

10             JUDGE HALL:  Dr. Zepinic, good morning to you.

11             THE WITNESS:  Good morning, Your Honour.

12             JUDGE HALL:  Before Ms. Korner resumes her examination-in-chief,

13     we should alert you that having been informed that there may have been

14     some miscommunication in the information provided to you, as regards the

15     length of time that you were expected to be before the Tribunal.

16             We should now put you in the picture so that any consequential

17     personal and domestic arrangements as you may have to make, you may do

18     so.  It is now anticipated -- it is clear that your testimony would not

19     have been concluded by the time the Court rises today at 1.45, and that

20     you will be required to return on Monday, and it is expected that your

21     testimony would be completed on Monday, and you be released by

22     mid-afternoon on Monday.

23             Yes, Ms. Korner.

24                           WITNESS:  VITOMIR ZEPINIC [Resumed]

25                           [Witness answered through interpreter]

Page 5760

 1                           Examination by Ms. Korner: [Continued]

 2        Q.   Dr. Zepinic, I want to -- I want to start today by continuing the

 3     chronological progression, if we can, through 1991.

 4             JUDGE HALL:  Excuse me.  Can I reply to His Honour.

 5             MS. KORNER:  Oh, certainly.

 6             THE WITNESS:  Your Honour, I understand your explanation, and I

 7     accept and there is no any question about my co-operation and assistance

 8     to this Tribunal.  I should remind you and inform you that I received a

 9     letter from home office, and that I'm required to testify for 28th of

10     January.  In my phone conversation with officials from Tribunal, I

11     accepted possibility to stay on Friday as well.

12             However, I have -- my already booked duties regarding my

13     employment, and regarding duties that I should attend in middle of

14     February in Sydney.  I understand, I would say, comfortable decision by

15     Tribunal to finish testimony as soon as possible on one, I would say,

16     part, instead of coming again.  And I accept that.

17             I just received a fax letter from home office of UK saying that

18     my further staying here is a matter of the Tribunal.  I would appreciate

19     if Tribunal can issue, like, letter or statement to my employer and

20     subject in Sydney saying that I should stay until, of course, decision by

21     Tribunal that I am not necessary to be here anymore.  And that my planned

22     duties could be in some state delayed because of my duties to Tribunal.

23             JUDGE HALL:  Thank you, sir, and we would be happy to arrange the

24     issue of such a letter.

25             THE WITNESS:  Thank you very much, Your Honour.

Page 5761

 1             MS. KORNER:

 2        Q.   I'd like you to have a look, please, at a document that you saw,

 3     I think you have seen before.  It's 1809.

 4             If we go, for a moment -- well, the second page, it's -- in

 5     English not in B/C/S.  I think it's all on one page.  This is a document

 6     that is going out under the name of Mr. Delimustafic.

 7             And then if we go back to the first page.  Can we just pull up

 8     the first page in B/C/S for a moment, because we can see the signature at

 9     the bottom, or the name.  Yeah.

10             It's addressed - and if we go to the top of the B/C/S, please -

11     to the chief of the CSBs, the SJBs, and to the secretary of the interior.

12     And it's stressing, as the first paragraph says, that the reserve police

13     force must not be used ... engaged in ways and situations that are not

14     stipulated by the law.

15             And then it goes on to point out what the law is, in

16     paragraphs 1, 2, and 3.

17             Now, first of all, I think you were familiar with this document,

18     is that right, at the time it was issued?

19        A.   This question answer on English or my first language?

20        Q.   [Overlapping speakers] ...

21        A.   Yes, sorry.  Yes, this document is known to me.

22        Q.   If you could, sorry, sir, if you could stick to Serbian for the

23     purposes of Mr. Cvijetic.

24        A.   [Interpretation] Yes, I know this document.

25        Q.   What was the reason that Mr. Delimustafic sent this document?

Page 5762

 1     What was happening?

 2        A.   Delimustafic didn't send this letter or communication to all

 3     chiefs of CSBs and the SUP in his own name but on behalf of the

 4     collegium.  We received instructions or, rather, information that reserve

 5     police officers were used in contravention of the instructions and rules

 6     of the SUP.  At the moment, I cannot be more precise and say how many

 7     police stations were involved.

 8             There was a misuse to the effect of the restructuring of

 9     personnel, especially the executive positions.  Then the manning of the

10     reserve police, without prior approval, so we thought that we should

11     inform all the chiefs to take all measures necessary and, in line with

12     the law, to prevent this use or, rather, misuse of the reserve police

13     force.

14             The reserve police force must be used only in accordance with the

15     Law on the Internal Affairs, as set out in the Official Gazette of Bosnia

16     and Herzegovina, issue 17/19.

17        Q.   Thank you, sir.  I think we'll hear from other evidence what was

18     actually happening.

19             MS. KORNER:  Your Honours, may that be admitted and marked,

20     please.

21             JUDGE HALL:  Yes, so marked and admitted.

22             THE REGISTRAR:  Exhibit P896, Your Honours.

23             MS. KORNER:

24        Q.   I want to go back, please, to some intercepts, again, that you

25     listened to.  The first one is a conversation again between you and

Page 5763

 1     Mr. Karadzic on the 24th of July.

 2             And could we have up, please, 1038.

 3        A.   [In English] Madam Korner, if you don't mind --

 4             [Interpretation] I would just like to follow up on your question

 5     about item 1 of this communication.

 6             We didn't only have operational information about the misuse I

 7     spoke about, but some chiefs of SJBs informed us that some commanders of

 8     police stations without the approval of the SUP or the Security Service

 9     launched some actions of the reserve police that were not in accordance

10     with the law?

11             THE INTERPRETER:  Could we have the tab number, please.

12             MS. KORNER:  The tab number of intercept is 17, but I think

13     Dr. Zepinic is still dealing with the last document.

14        Q.   Do you know what -- can you give us an example, just very

15     briefly, of what these actions were, that were against -- not in

16     accordance with the law?

17        A.   Any manning of the reserve police, any personnel change in the

18     reserve police, should have been done in accordance with the law.  In

19     some police stations we found out that the manning of the reserve force

20     was going on contrary to the Law on the Internal Affairs.  That there was

21     -- the restructuring of personnel and manning of the reserve force,

22     including executives, in contravention of the agreed criteria that set

23     out basic characteristics of the personalities of those who could be

24     reserve police officers.  First and foremost that they don't have a

25     criminal record and that they have never been in conflict with the law.

Page 5764

 1             Secondly, what was also very important was the fact that the

 2     reserve police, in some police stations or, rather, in all police

 3     stations, had to, if possible, reflect the ethnic composition of the

 4     population of the respective municipality.  We had some operational

 5     knowledge or information that there had been some tipping of this -- that

 6     the national balance or ethnic balance had been tipped in some cases, and

 7     some reserve police officers were used for regular activities in some

 8     police stations, even though the police stations had the right to call up

 9     reserve police only for training but not for active duties without the

10     approval of the Ministry of the Interior.

11        Q.   Yes.  Thank you, sir.  That's very helpful.

12        A.   [In English] Pleasure.

13        Q.   If we can now go back for you, sir, to the intercepts you

14     listened to.  It's you and Mr. Karadzic on the 24th of July.  And again

15     at the beginning of -- I mean, I think have you listened to this.  Could

16     you confirm it is your voice and that of Mr. Karadzic?

17        A.   [Interpretation] Yes.

18        Q.   There is some discussion again about arming his escort.  And then

19     can we go to the second page, please, in B/C/S and -- sorry, English, and

20     the -- it's still on the first page, no, sorry, and the second page in

21     B/C/S as well.

22             You say to him, we look at the bottom, yes, pull up -- thank you.

23     That you had meetings this morning, and you were visited by or talked to

24     Mico -- Mica.  Again, can you tell us who you're talking about there?

25        A.   I suppose that Mica was Mico Stanisic.  At this moment, I can't

Page 5765

 1     remember any other Mica that I may have spoken to.

 2        Q.   And Karadzic says to you:

 3             "Aha, let me tell you, please, this thing about the

 4     reorganisation going on, we have to see to see exactly what is the

 5     meaning of this reorganisation, and also don't let them remove a single

 6     man of yours if you don't want to ..."

 7             Can you recall now what reorganisation he was talking about and

 8     telling you not to remove a single man?

 9        A.   Yes, in keeping with the dispatch that was sent to all security

10     centres and the city SUP, after that, we embarked on a certain personnel

11     shakeup and replenishment of the reserve forces of the police, including

12     recruiting younger and more capable staff.  The reorganisation of the

13     reserve staff was probably due to take place a few laters [as

14     interpreted] into our coming to power.  Mr. Karadzic's intervention was

15     to say that at all cost we had to respond to some partisan requests as

16     any other party leader, and I respected that.  However, there was no

17     direct pressure on us to respond to what party leaders wanted us to do or

18     wanted to implement, not only among the active force but also the reserve

19     force of the Ministry of the Interior.  And that was to have party

20     candidates who were loyal to certain political parties instead of being

21     professionals who would carry out their tasks professionally under the

22     Law on Internal Affairs.  This is customary pressure being exerted on the

23     part of Dr. Karadzic.  He wanted to achieve as much as possible, what the

24     party wanted him to achieve.  And that was to have party people in many

25     positions, as many as possible, rather than professionals.  In the

Page 5766

 1     Ministry of Interior our position was that our members could be party

 2     members.  They could be members of ethnically-based parties; however,

 3     their affiliation to an ethnically-based party could not have had any

 4     influence on our request for the tasks to be carried out professionally

 5     and in keeping with the law.  If the --

 6             I apologise.

 7        Q.   I think you have explained, and I just want to ask you about one

 8     other aspect of this conversation.

 9             Could you go to the fourth page in English -- could we go to the

10     fourth page in English and the third page in B/C/S.

11             And we can see there at the -- towards the bottom of the page in

12     English Karadzic saying to you: "Don't let go of a single one," talking

13     to Simovic.  And you then say to him: "Who shall I get instead of

14     Kezunovic?"

15        A.   Yes.  Your pronunciation is quite good.

16        Q.   Thank you.  It's unusual.

17             So you were seeking his advice, were you, as to who should become

18     appointed within the police?

19        A.   No.  I believe that this is a misinterpretation of my question,

20     the one that I put to Dr. Karadzic.

21             This was an instances involving a person who was an engineer

22     communications expert in the Ministry of the Interior, and he was there

23     even before we came into power.  He was a very conscious and responsible

24     professional, and I was very surprised that Dr. Simovic as the

25     vice-president of the government had some combination involving

Page 5767

 1     Mr. Kezunovic which excluded me or anybody else.  I suppose that we

 2     should have had previous negotiations about that, and I realized from my

 3     conversation with Mr. Karadzic that Mr. Kezunovic was supposed to be

 4     transferred to the Ministry of Defence.  And in my conversation I told

 5     Mr. Karadzic that I didn't agree with that.  And that's why I asked him

 6     who I should find to replace him, because that person was a very well

 7     qualified and experienced engineer.  He had spent a lot of time in that

 8     position, and leaving a gap in his place meant that there would be -- a

 9     gap, it would be impossible to carry out the tasks that Mr. Kezunovic was

10     involved in.

11             I did not agree with that, and my question is actually seeking

12     advice from Dr. Karadzic -- actually, it is not seeking advice from

13     Dr. Karadzic.  My question is more a protest against Mr. Karadzic's and

14     Mr. Simovic's initiative to transfer Mr. Kezunovic from his position in

15     the Ministry of Interior to the Ministry of Defence.

16        Q.   I think the point of all of this is that, although Mr. Karadzic

17     had no power to transfer or do anything, he was pretty insistent, from

18     what you -- being said about what should happen, in respect of Serbs?

19        A.   I wouldn't say just in respect of Serbs.  Political leaders put

20     pressure on all types of appointments.  In this particular case, yes,

21     Dr. Karadzic was insisting on a person who was a Serb by ethnicity.

22     However, as far as I remember, Dragan Kezunovic stated that he was in

23     Yugoslav.  His father had a been a hero from Romanija, Mr. Stanisic knew

24     him very well, a very well-respected family.  So in this case, we're

25     talking just about one candidate, but that was common practice to

Page 5768

 1     intervene at all costs in terms of personnel shakeups or personnel

 2     appointments.

 3             This is one obvious way, as it were, of an unfair relationship

 4     between Dr. Karadzic and Mr. Simovic.  Something that bypassed us from

 5     the ministry where Mr. Kezunovic was employed.

 6        Q.   All right.  As we will see, because I want to continue with this

 7     conversation, Mr. Karadzic was becoming quite emphatic.

 8             Can we move please to the next page in English, I think it's

 9     still the same page in B/C/S.

10             Karadzic says to you:

11             "Please arrange for the collegium to meet every morning, see what

12     happened the previous day and what's plan for that day.  See that no one

13     is appointed without the full approval of all Serbs."

14             And you then intervene and say:

15             "I don't know.  I have to consult with Simovic."

16             And Karadzic says:

17             "Because this will result, we've prepared an alternatively which

18     will be atrocious.  We prepared it, and we'll fuck their mothers.  But to

19     stop that from happening, let them sit every day and for this to --"  I

20     mean.

21             Now, when he said, We've prepared an alternative which will be

22     atrocious, you didn't ask him what he was talking about.  So what did you

23     understand that he was talking about?

24        A.   I will reply, and I'm sure it will be difficult to translate this

25     conversation and similar conversations with Dr. Karadzic and the other

Page 5769

 1     leaders, was just shooting the breeze, nothing else.

 2             It was nothing but shooting the breeze.  I don't know whether the

 3     interpreter has been able to interpret this properly.  If not then I will

 4     do the interpretation and use the proper reading.

 5             So what was -- what was said in those conversations had nothing

 6     whatsoever to do with the reality of the matter, and I find -- found it

 7     surprising that political leaders were still not able to understand that

 8     they did not have any right to influence the appointment of the personnel

 9     the way that they thought they could.  When it comes to some

10     alternatives, cursing, swear words, and these language inappropriate --

11     in a civilised word, I can say nothing else but this was just shooting

12     the breeze.  That should not have been understood seriously.  It did not

13     mandate any further discussion.  Nothing serious would have arisen from

14     that anyway.

15        Q.   Yes.  But the question, sorry, Dr. Zepinic was this.  He says we

16     have prepared an alternative which will be atrocious.  We have prepared

17     it, and we'll fuck their mothers.

18             Now you didn't ask him what he was talking about, so whether you

19     took it seriously or not, what did you understand his threat to mean?

20        A.   If you had an occasion, and I'm sure you did, to look at all the

21     other conversations, the customary tone or language that Dr. Karadzic

22     used, and I'm not going be repeating the terms that he was using in the

23     conversations, and to be honest, I don't know who he meant.  He is using

24     a swear word and somebody's mother, I don't know whose.  Mine?  Yours?

25     Muslim's mother?  Croatian's mother?  Mr. Stanisic's mother?  It is just

Page 5770

 1     talking stupidities that I did not even give a second thought to.  I did

 2     not want to go into further discussions as to who he was threatening, how

 3     he was threatening to do whatever he wanted -- was going to do.  We

 4     didn't -- not have any clear evidence as whom he was threatening, and

 5     then we would have reported him for that.  But we didn't have that.

 6             This was just his customary way of saying next to nothing in a

 7     very stupid way, and it really did not call for any other discussions or

 8     anything.

 9        Q.   Well, let's look, shall we, and maybe we can get some

10     enlightenment what he was saying to you later on.

11             Page 9 in the English, please.  And --

12        A.   [In English] I'm not smoking.  I am coughing.  I understand you,

13     Madam, but I don't know what is going on with me.

14        Q.   Okay.  I'm afraid it is catching.

15             Can we have look at page 9 in the English and -- the page numbers

16     don't seem to be marked in the B/C/S, 1, 2, 3, 4, 5, 6, in the B/C/S.

17     Yeah.

18             Now in the middle of the page in B/C/S near the top in this.

19     Mr. Karadzic says to you, continuing with the theme:

20             "Please let the collegium meet every morning and clear all that

21     out.  I was with Izetbegovic last night and with Zulfikarpasic, and I

22     told him right into his face, We'll establish a parallel government,

23     parallel police, or withdraw our people, and they'd have to be paid by

24     the government.  Withdraw all our people under arms.  We'll then

25     establish an entire parallel state if you keep on screwing us.

Page 5771

 1             "And he just looked and blinked because we'll do that.  Not even

 2     God could stop us in that, because they started to fuck with us and to

 3     fuck us up, and there is no doubt we will do all of that in a week.  So

 4     let there be war, let there be war, but we'll finish the job for once."

 5             And your response to that was:

 6             "At least we'll know where we are."

 7             Now, when you heard this, this was a plain, plain threat, wasn't

 8     it, about setting up a parallel government in July of 1991?

 9             MR. KRGOVIC:  Objection, leading.

10             MS. KORNER:  I agree it is leading.  But, all right, if you can

11     find any other way of describing it, Mr. Krgovic, I will happily take

12     your suggestion.

13        Q.   When you heard this, did you -- why didn't you say something

14     about it?

15        A.   [Interpretation] Could you please remind me of the date of this

16     conversation.

17        Q.   Yeah.  It's July -- 24th of July, 1991.

18        A.   Very well.

19             24th July 1991, nothing happened for the following next -- for

20     the following seven days despite what Dr. Karadzic said.  And my comment

21     was, Okay, we -- we will know where we stand, hoping and looking forward

22     to Mr. Karadzic and other leaders doing what they promised to do.  We

23     should have only been so lucky if they had -- the coalition would have

24     broken down.  There would be no more ethnically-based parties.  There

25     should have been new elections and ethnically-based parties would not

Page 5772

 1     have won.

 2             If I could influence Dr. Izetbegovic, Karadzic, and Kljuc, and

 3     make them do what he promised he would, I would be very happy because

 4     there would probably be no war in my country.  I had an meeting in

 5     Zulfikarpasic and Alija Izetbegovic, and in all the conversations, it is

 6     mentioned that they had met.  Whether they did or not, it's up to them.

 7     In any case I cannot accept the fact that what Dr. Karadzic said to

 8     Zulfikarpasic or Izetbegovic that Mr. Izetbegovic as the president of the

 9     Presidency or the president of the SDA, did not react to any of that,

10     because it -- if it was an open threat that means that there was no

11     coalition, that there was no partnership in power.  My comment was, at

12     least we will know where we stand, and what this meant was that I really

13     wanted to know what political and ethnically-based parties in Bosnia and

14     Herzegovina were up to.

15        Q.   All right.  But the real question is, your response is at least

16     we will know where we are.  Was there any reason why you didn't say to

17     him words to the effect of, Don't be stupid.  That is not going to get us

18     anywhere; that is going to lead us to war?

19        A.   I used to say that in official meetings, in government sessions,

20     Presidency session, and assembly sessions.  Not once.  I'm sure I will

21     not exaggerate if I say that that I was really adamant in telling them

22     that ethnically-based parties are not good for Bosnia-Herzegovina but

23     that, rather, their political agendas can only lead to a crisis in

24     Bosnia-Herzegovina.  In an interview where I was attacked, I said that a

25     war would bring at least 100.000 dead and 2 million people who have move

Page 5773

 1     from their homes.  I was even too optimistic when I mentioned the figure

 2     of 100.000 according to the current data that 250.000 people eventually

 3     died.

 4             Did say that at official meetings of a various institutions and

 5     at my meetings with the leaders.  I did say that.

 6        Q.   I absolutely accept that, Dr. Zepinic.  I'm just asking why,

 7     given that you said this on television and at meetings, why you didn't

 8     say that in this private conversation with Dr. Karadzic.  That's all.

 9        A.   In private conversations that we had, given the tone and the

10     structure of this particular conversation that he had had with

11     Mr. Zulfikarpasic, Izetbegovic, and the threats, in a private

12     conversation I could do you know what.  Let me not tell you what it would

13     have been.  Because this is just not my style, and that's why I did not

14     use the lingo that involved swear words that Mr. Karadzic so freely used

15     in -- in his conversations.

16        Q.   All right.  And then, finally, on this conversation, could we go

17     to page 10 in English, and to - sorry, I have to count out the pages -

18     7 in B/C/S.

19             At the bottom -- I'm sorry.  You say to Dr. Karadzic that, Mico

20     will see you in the morning at 8.30.

21             And he says, Stanisic.

22             And you say, Yes, and we'll discuss that, and I'll let you know

23     what we did.

24             Now, did you have meetings with Mico Stanisic to discuss the

25     appointment or replacement of personnel?

Page 5774

 1        A.   Mr. Stanisic had been appointed as secretary of the Sarajevo SUP

 2     and general region which included territory of Romanija, and when it came

 3     to personnel issues, I talked to all the chiefs, including Mr. Stanisic.

 4     It was only natural that the selection of personnel was to the

 5     satisfaction of the chief of the security services centre, rather than

 6     those candidates being imposed by the ministry.  We wanted to find the

 7     best possible joint solution for a person that would be working as a team

 8     member together with Mr. Stanisic.

 9             Therefore, I suppose that we did have a meeting to discuss

10     personnel issues.  My initiative was to sit down with everybody over a

11     cup of coffee irrespective of the pressures of political parties.  It was

12     only natural and customary when it came to appointments of lower-ranking

13     personnel or command personnel in the police stations or security centres

14     to have a word with the respective chiefs, including the Sarajevo SUP.

15        Q.   Well, this conversation was about, in fact, I don't want to go

16     back to it, the Deputy Chief for Defence Preparations and the State

17     Security Service, wasn't it?  And Devedlaka's appointments.

18        A.   It is not stated precisely whether that was the matter at hand.

19             However, within the Sarajevo SUP, there was also the Department

20     of State Security and Mr. Stanisic, as the chief of the security services

21     centre in Sarajevo was responsible for the functioning of the State

22     Security Service for the Sarajevo region.  And that applied to any other

23     chief who had a state security department within the -- their respective

24     security services centres.

25        Q.   All right.  From your observation of Mico Stanisic and

Page 5775

 1     Dr. Karadzic, what did you gain the impression, was their relationship?

 2     In other words, was it a close relationship, a distant one?

 3        A.   Their closeness or lack of closeness, their friendship, was their

 4     private matter.  I was not interested in that.

 5             What I was interested in was to what extent Mr. Stanisic was

 6     capable of performing his tasks without caving in to pressures, including

 7     pressures from Dr. Karadzic.  And irrespective of the possible

 8     relationship that existed between the two of them.

 9             My observation, with regard to their relationship is absolutely

10     irrelevant.  I was never interested in that.  I did not pay any attention

11     to that, therefore.

12        Q.   Well, I -- Dr. Zepinic, this was a question you were asked in the

13     statement you made.  Do you remember that?  Whether you think it's

14     irrelevant, that's what you were asked.

15             Do you remember making a statement about this?

16        A.   I suppose so.  I provided a lot of statements.

17             I can only say that, yes, they had a quite a close relationship.

18     I don't know whether it was friendship and what was the base of their

19     relationship.  That was not up to me to -- to say or pay attention to.

20        Q.   All right, but I'm just asking for your observation, that's all.

21     And your observation is -- is that they had quite a close relationship,

22     but you can't say if it was friendship.

23             Is that what you're saying?

24        A.   Look, when it comes to interpretation, we have to bear in mind,

25     and I am kindly asking the interpreter to allow me to explain that.

Page 5776

 1             In Bosnia and Herzegovina a relationship among people fell into

 2     four categories.  He's my colleague, my work colleague, my friend, or an

 3     acquaintance.  In English all that would be friend.

 4             So the use of any term that falls into the category of friend is

 5     probably going to be interpreted in English as friend, although I am

 6     using three or four different words in my language.

 7             When it comes to English the relationship between myself and

 8     Mr. Stanisic or me and Mr. Karadzic is also going to be interpreted as

 9     friendship.  Unfortunately, we have to make a certain distinction here.

10        Q.   All right.  Did you see -- when you attended meetings of the SDS,

11     was Mico Stanisic also at those meetings?

12        A.   Yes, he attended some.  I remember that.  And he didn't attend

13     others.

14             The first time I was invited to a meeting of the SDS concerning

15     some security issues involving my ministry, I was surprised to see

16     Mr. Stanisic there.  And I asked him in what capacity was he present,

17     since the security issues were not on the agenda.  At least not the

18     security of the Sarajevo region.  If that had been a meeting of the city

19     committee of the SDS, Mico Stanisic would have been duty-bound to attend

20     such a meeting and discuss security issues.  However, this was a meeting

21     at the national level, and when I asked him, he replied that he was a

22     party member and that was his own thing, whether he was or not.  So I did

23     see him at the party meetings.  I can't tell you that it was every time.

24     I can't tell you how many times I saw him.  I did not keep track of that.

25     It would have been beyond me to do that.

Page 5777

 1        Q.   Thank you very much.

 2             MS. KORNER:  Your Honours, may that intercept be admitted and

 3     marked.

 4             JUDGE HALL:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit D897, Your Honours.

 6             MS. KORNER:  Can we next have the intercept - which is at tab 18

 7     of for the interpreters - 1799.  It is the same day as the last

 8     conversation.

 9        Q.   It's not one to which you were a party, Dr. Zepinic, but you

10     listened to it, and there's a reference to you.

11             Right, this is a conversation between Radovan Karadzic and

12     Devedlaka.  Firstly, did you know Devedlaka?

13        A.   Yes, I did.

14        Q.   All right.  And can you tell us very briefly what his position

15     was at this period in July 1991.

16        A.   I really don't remember.  If he had been in an important position

17     or played an important role, I would probably remember.

18        Q.   All right.  Which branch of the MUP was he in?  Can you tell us

19     that.

20        A.   As far as I remember, he worked at the centre of the State

21     Security Service of the city SUP.  Later, he -- he was a candidate for

22     post in the defence preparations unit or some other unit under

23     Mr. Kresic.  But I don't really remember his role in mid-1991, nor what

24     he did, probably because he wasn't in a high position.  I remember him

25     well from the time after the war began, when he harassed me and arrested

Page 5778

 1     me, but that was later.  But while I was in power, I really don't know

 2     what he did.

 3        Q.   All right.  I'm going to digress for a small moment from this,

 4     but when you listened to this conversation, were you able to recognise

 5     his voice and that of Radovan Karadzic?

 6        A.   Yes.

 7        Q.   I just want to digress for one moment because I think it's the

 8     second time we've dealt with -- or we've mentioned the defence

 9     preparation.

10             Could you just explain very briefly to the Court what defence

11     preparation was, or what -- what the defence preparation unit was.

12        A.   I kindly ask you to be more precise in your question.

13             You mean different preparation within my ministry, the CSB, or

14     generally the preparation of defence in the republic?  I'm sorry, I don't

15     want to appear as splitting hairs, but I don't want to provide a wrong

16     answer.

17        Q.   No, I'm very grateful.  You're quite right, Dr. Zepinic, we

18     should be precise about this.

19             Can we start with what the defence preparation unit within the

20     ministry was.  Again, if we could keep this brief because of the time,

21     that would help.

22        A.   I'll try to be as brief as possible in my inclination [as

23     interpreted].

24             As any other ministry, the MUP, too, had a section of defence

25     preparation which drafted plans for the protection of vital facilities in

Page 5779

 1     case of crisis or imminent threat of war.  These plans also included the

 2     engagement of personnel, the SJBs, and the reserve forces of the police

 3     in accordance with the need.  Likewise, the engagement of the police

 4     special forces.

 5             Defence preparation also included the drafting of plans with

 6     detailed instructions about what any subject in the -- from the SUP to

 7     the last police station in the field was supposed -- and obliged to do in

 8     case of crisis or imminent threat of war.

 9             Defence -- the Department of Defence preparation was duty-bound

10     to make a -- to space, to specify, which equipment was required.  When I

11     say "equipment," I mean weapons, protective equipment, gas masks,

12     uniforms, et cetera, anything that can enable the ministry, in case of

13     crisis or imminent threat of war, to function, to be ready and have

14     appropriate plans and equipment to live up to its duties, the duties of

15     the MUP, under the law.

16        Q.   Right.  That's -- now, first -- sorry, first thing arising from

17     that is, you said it had plans -- it drew up plans for the engagement of

18     the police special forces.  Was it in any way connected with the

19     Special Police?

20        A.   Who do you mean?

21        Q.   The defence preparation unit.  In other words, did it come under

22     the command --

23        A.   No, no, no.

24        Q.   All right.  Under which --

25        A.   No, the special unit was under the exclusive command, as I

Page 5780

 1     explained yesterday, of Delimustafic and me.  And within the special unit

 2     there was a person who drew up plans and specified the equipment required

 3     for the special unit and forwarded that to the sector of defence

 4     preparation of the MUP to organise supply.

 5             So the defence preparation was the executive part of the overall

 6     planning and preparation activities but not in the position to issue any

 7     orders or indeed a request to any unit to go into action to intervene.

 8        Q.   And within the ministry, before we come to the CSBs, the defence

 9     preparation unit -- or department, was that a separate department, or did

10     each department within the ministry have somebody tasked with that

11     function?

12        A.   No.  Defence preparations within the MUP were not a separate

13     department or unit, and the same applies to the CSB.

14             In the centre of State Security Service, there was also a defence

15     preparation unit that took care of equipping or specifying equipment for

16     the requirements of the State Security Service, including surveillance,

17     wire-tapping and whatever state security is supposed to do.  I don't need

18     to elaborate.  But, essentially the defence preparation unit in no

19     service, be it the CSB or the state security, was a -- was an autonomous

20     service and couldn't function as such.

21        Q.   Thank you.  So within the CSBs, was it, as you described, that

22     each of the departments we've seen would have somebody tasked with

23     defence preparation?

24        A.   Yes.  Within the CSB there would be a unit or a single officer,

25     depending on the size of the respective CSB.  The largest CSBs were those

Page 5781

 1     in Banja Luka and Sarajevo, so I suppose that there were more than one

 2     staff in that unit.  And in others there was only one who was in charge

 3     of issuing equipment and taking care of the quantities of weapons and

 4     other equipment available to enable the CSB to function properly.

 5        Q.   Thank you very much.  I'm sorry, we digressed.

 6             So can we go back to this intercept.  And if we go to the second

 7     page in the English, and it's still on the first page in the B/C/S.

 8             To put this in context, Karadzic is asking Devedlaka, and this is

 9     the same day you had spoken to Karadzic, about his nomination of somebody

10     from Romanija.  And Devedlaka denies it.

11             And then Karadzic says to him, Please call Zepinic now, because

12     he told me that you had proposed this man.  No one has the right to put

13     forward personal proposals.  You have staff meetings, everyone's voice

14     should be heard?

15             Devedlaka replies, I went to his office this morning and told him

16     I did not support this man Suka because he is incompetent.

17             And then Karadzic says, Why has Vito nominated him?

18             And Devedlaka says, I don't know.

19             Had there been a conversation between you and Devedlaka to the --

20     to the effect of what he told Karadzic?

21        A.   Frankly, I cannot remember a conversation about the appointment

22     of Mr. Suka.  I really don't remember.

23             The comment of Dr. Karadzic is a bit strange, when he says, Well,

24     why does Vito propose him?  Whether I proposed him or Mr. Stanisic and

25     whether that had to do with the CSB of Sarajevo, I really cannot say.

Page 5782

 1     Whether I spoke to Devedlaka, probably in passing.  But whether there was

 2     a decision on my part about the appointment of Suka, I really don't know.

 3     I don't even remember who that guy Suka was.

 4             MS. KORNER:  Your Honours, may that just be marked for

 5     identification then, please.

 6             JUDGE HALL:  So marked.

 7             THE REGISTRAR:  Exhibit P898, marked for identification.

 8             MS. KORNER:  Can we go to, please, to document 1044, and it's

 9     tab 22 for the interpreters.  It is an intercept again.

10                           [Prosecution counsel confer]

11             MS. KORNER:

12        Q.   Again, this appears to be, in fact, as we will see, a three-way

13     conversation on the 2nd of September of 1991.  Mr. Karadzic, yourself,

14     and we'll see later somebody called Rajko is also present.

15             Now have you listened to this conversation.  Were you able to

16     identify your voice and that of Mr. Karadzic?

17        A.   Yes.

18        Q.   And the man Rajko who apparently -- can you hear him when you

19     listen to the conversation, or not?

20        A.   Believe me, I cannot confirm that, because I really don't

21     remember.  I have listened to so many conversations.  I can't remember

22     each and every one.  So I can't give an answer to your question.

23        Q.   Well, let's just start at the beginning, very quickly on this

24     one.

25             At the bottom of page 1 in the English.  And somewhere in the

Page 5783

 1     middle, not quite at the bottom.

 2             Karadzic says to you:

 3             "Vito, have I been trying to reach you, but could I not get

 4     through.  People from Vogosca are with me.  There will be barricades and

 5     all sort of things there."

 6             This is September 1991.  Can you recall why there were going to

 7     be barricades in Vogosca?

 8        A.   From the point of view of the MUP, or, rather, at the MUP we had

 9     no such information.  As far as I know, and Mr. Stanisic will know

10     better, because that was within the CSB Sarajevo, there weren't any

11     barricades eventually.  But that was the usual style of exerting pressure

12     on the part of Mr. Karadzic or Mr. Izetbegovic and so on.  If you do not

13     give in to our demands, then we will raise 10.000 people.  We will take

14     weapons, and this and that.  But I never took that seriously.  This is

15     probably about some personnel issues at the CSB or the police station of

16     Vogosca.  I cannot give you a specific answer now, but if I can take a

17     look at the -- at how the conversation continues, then I may be.  But

18     this thing about the barricades was a bluff, which was -- which we were

19     faced with daily.  These were threats that were not addressed only to my

20     ministry.  There were also threats to me personally or to my family.  But

21     that was, as it were, the normal style of the people I was confronted

22     with.

23        Q.   All right.  We can see the next -- in fact, the next part in

24     English, and I think it is already on the B/C/S, explains that this is --

25     the barricades are going to be raised because of an appointment.  Because

Page 5784

 1     you asked why.

 2             Now, I want to move, please, to the fourth page in English, and

 3     it's the third page, I think, in B/C/S.

 4             You ask at the top of -- I'm not -- yes, we have the right one.

 5             "Dr. Karadzic, do we have a chief of the town SUP?"

 6             And Mr. Karadzic says:

 7             "The chief of the SUP says that the MUP is going to make

 8     appointments later on.  We can ... give me an answer straight away

 9     because I want to clarify this.  Is he or not?  Can he write a letter of

10     appointment and appoint a man?"

11             You say:  "Who?"

12             And he says:  "Chief of the town SUP."

13             Question:  "Why didn't he make a proposal?"

14             Karadzic:  "Wait a second.  Why didn't he make it ... you are,

15     please, have you been warned in the MUP that this man cannot be

16     appointed."

17             And you say:  "By whom?"  And you say:  "By the municipality?"

18             Karadzic says:  "By the municipality, by the Executive

19     Committee."

20             Now, was the Executive Committee issue warnings to the MUP about

21     appointments?

22        A.   Looking at this conversation, it is it obvious that Dr. Karadzic

23     didn't have the faintest idea about the functioning or about how people

24     were appointed.  First and foremost, it was normal to consult the

25     secretary of the SUP of the town in question.  If we consider the date of

Page 5785

 1     this conversation, then we know that it is Mr. Stanisic.

 2             Dr. Karadzic is confusing apples and pears here.  The town -- the

 3     City Committee and the Executive Committee of the municipality are two

 4     separate bodies.  The Executive Committee of the town had no interest in

 5     the appointment of a commander of a police station in Vogosca.  So these

 6     comments of his are nonsensical.  That is why I had trouble understanding

 7     him, because obviously he was not informed.

 8        Q.   All right.  Well, I want to just continue very quickly to finish

 9     this conversation before the break.

10             The -- as I say, the -- Rajko, who is in the room, has a

11     conversation there with Karadzic.

12             Can we go to the next page in English, 5.

13             And whoever it is says:

14             "I went to see Zepinic.  I called him personally in Dudjaskovic

15     [sic]."

16             And he says:  "Then I went to see Zepinic two months ago --"

17             Go over the page in the English to the next page.  And it's -- in

18     the B/C/S, it's the fourth page, fourth page in B/C/S.

19             This Rajko is saying:  "I called Mandic," and then he says, "what

20     did Mandic say?"

21             "It will not happen.  He called Draskovic ... he called Stanisic,

22     but Stanisic was the only one who said he is helpless and he cannot

23     control anything."

24             And you were asked:  "Did you hear this?"

25             And you say:  Yes, I heard everything."

Page 5786

 1             Now, does that remind you of who the Rajko was?  Very quickly, if

 2     it doesn't, don't worry.

 3        A.   I suppose that this is Rajko Dukic because he was the chairman of

 4     the executive board of the Serbian Democratic Party, and it was his duty

 5     in the party to take care of personnel issues at the level of BiH.  I

 6     think it was Mariofil Ljubic for the Croats, and Muhammed Cengic for the

 7     SDA, who were in the same positions, if I remember well.

 8        Q.   All right.

 9        A.   The conversation that took place here -- [In English] Can I

10     continue.

11        Q.   Yes, I'm just going to ask -- Yes, can I just before you

12     continue --

13        A.   [Overlapping speakers]

14        Q.   The -- Dr. Karadzic -- you say you heard everything.

15             Karadzic says, Stanisic says he cannot control anything because

16     is he not writing letters of appointment; they're coming from the MUP.

17             You say, Dr. Karadzic, if he is helpless, he should resign.

18             And Karadzic says, Come on, we must check who else is helpless

19     and who else has to resigned, because Stanisic is not the only one.  I

20     have to deal with the crap that is going to cause a civil war.

21             Now, tell us, please, yes, about this conversation.  Stanisic

22     saying that he could not control anything and Karadzic agreeing, was that

23     an accurate portrayal of Mico Stanisic's position?

24        A.   What kind of conversation went on between Dr. Karadzic and

25     Mr. Stanisic, I don't know.  And about Mr. Karadzic's remark that

Page 5787

 1     Stanisic is helpless, this isn't the first time I say that.  If any chief

 2     of a CSB feels helpless and unable to do anything, then it would be fair

 3     to resign.  And that applied to me too.  It is true that Mr. Stanisic

 4     could not decide on the appointment of anyone, not even a police

 5     constable in any police station of the Sarajevo CSB without a decision

 6     from the ministry.

 7             Mr. Stanisic, like any other chief of a CSB, was consulted about

 8     executive positions because a team to had to be established that could

 9     function.  But, the minister or his deputy or any assistant in the MUP

10     could not check or verify what -- the chief of the CSB about the

11     appointment of a police officer.  That was within -- within somebody

12     else's remit and Mr. Stanisic, like any other chief, I repeat, was not in

13     the position to decide about anybody's appointment.  That was the job of

14     the personnel service of the MUP.  And if Dr. Karadzic, if he were to

15     give in to Dr. Karadzic's insisting, as we can see here, then that would

16     have been a breach of regulation, and he could be held responsible for

17     acting illegally.

18        Q.   All right.  And one last question --

19             MS. KORNER:  Your Honours, think I think the time for the break,

20     but I have just got one last question on this.  Yeah.

21             Can we go, in English, please, to page 1821, and in the B/C/S, I

22     am afraid I don't know.  I don't think it matters.  I just want to --

23     sorry.

24                           [Prosecution counsel confer]

25             MS. KORNER:

Page 5788

 1        Q.   It's just this.  Karadzic in the middle of the page allegations

 2     that Selimovic has been preparing a civil war, and you're not preventing

 3     that.  And you say you don't anticipate that.

 4             And he says, I'm going to ask Mr. Izetbegovic tomorrow to

 5     dissolve the MUP.

 6             And you say, I have nothing against that.

 7             Did you take that seriously?

 8        A.   No, I didn't.  But I was all for Mr. Izetbegovic and Dr. Karadzic

 9     to take a final decision about division, that the people of

10     Bosnia-Herzegovina be saved from the misfortune that the ethnic parties

11     brought upon them.  And this about the dissolution of the MUP is nonsense

12     because neither Karadzic nor Izetbegovic were the owners of the MUP.  It

13     wasn't their private backyard where they could do what they wanted to.

14     There was a law in force, but, obviously, neither Dr. Karadzic nor

15     Mr. Izetbegovic adhered to its provisions.  To their minds, they were the

16     law, and they could do what they want because they were in power.

17        Q.   Yes, thank you.

18             MS. KORNER:  Your Honours, may that be admitted and marked,

19     please.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  Exhibit P899, Your Honours.

22             JUDGE HALL:  And we take the break at this point.

23             We resume in 20 minutes.

24                           [The witness stands down]

25                           --- Recess taken at 10.29 a.m.

Page 5789

 1                           --- On resuming at 10.58 a.m.

 2                           [Trial Chamber and legal officer confer]

 3                           [The witness takes the stand]

 4             MS. KORNER:

 5        Q.   Dr. Zepinic, I'm afraid that my time is rapidly getting shorter.

 6     So if we could go fairly swiftly through a few more intercepts.

 7             MS. KORNER:  Could we have up, please -- sorry.  Now I've got my

 8     own notes saying "swiftly."

 9             I'm sorry, could we have up document 1803, please.

10        Q.   Now, this -- last conversation we looked at with you and

11     Dr. Karadzic was the 2nd of September.  This is an article in

12     "Oslobodjenje" on the 7th of September of 1991.  And it's entitled: The

13     MUP response to Dr. Radovan Karadzic's statement.

14             Now, it appears that there was a press conference of the SDS, and

15     he was complaining publicly, effectively, what we've seen him complain

16     about in these various telephone conversations, and the MUP, apparently,

17     gave a response.

18             Now, did you see this article at the time?

19        A.   I can't remember.  There was a lot of news reports and other

20     material that we had at the time.  My head of office and -- certain

21     services made a short list for me.  However, in this document, we pointed

22     out, again, as I had already said on many occasions at some meetings and

23     press conferences that I personally held, that ethnically-based parties

24     were not pursuing policies that led to the stabilisation and progress in

25     Bosnia-Herzegovina.  But, rather, they led to the state of disintegration

Page 5790

 1     and the break-up of Bosnia-Herzegovina which inevitably further on led to

 2     an armed conflict or war.  This is just one of the statements that

 3     Mr. Karadzic gave to the press, in which he displayed his displeasure

 4     with the work of the Ministry of Interior.  The hard-liners of the

 5     Ministry of Interior were proposed to be held in the ministry as an organ

 6     that carried out its duties in keeping with the law.

 7             This is nothing new.  This is something that we faced daily in

 8     the Ministry of Interior.  There are all sorts of attacks and pressures

 9     put by political leaders or institutions, if can I call a party an

10     institution.  So this would have been our customary reaction to the

11     normal pressures that were put on us.

12        Q.   And the statement put out by the MUP that:  They were untrue,

13     malicious, and calculated to divide the ethnic groups in our Republic,

14     was that something that you believed?

15        A.   I never believed, I never accepted, I still do not accept that

16     the resolution to the post-communist Yugoslavia and Bosnia-Herzegovina

17     was war, and that the only solution for us was to fight and do whatever

18     we had done to us, and to set the country back by at least 50 years,

19     thwarting progress for the next 50 years.

20             War, as a solution, was not a solution, in my mind, because every

21     war has to end up in negotiations.  My motto, and I'm sure you will find

22     it in documents, that it is better to negotiate for five years than to

23     wage war for five years.

24             What you see in Dr. Karadzic's interview in which he calls us a

25     new armed force in Bosnia-Herzegovina.  I'm very sorry that we were not

Page 5791

 1     better equipped and sooner in order to prevent war.  We should have even

 2     raised in -- up in arms against anybody who wanted to pursue the war.  We

 3     were not duty-bound do tell Dr. Karadzic where our arms were kept.

 4        Q.   No.  Can I -- can I -- because as I say, I'm sorry about this.  I

 5     know you have a lot to tell us, but all I'm concerned about in this

 6     particular article was these statements put out by the MUP in response to

 7     Dr. Karadzic.  Were you in agreement with those statements?

 8        A.   You mean in the media?

 9        Q.   Yes.

10        A.   The one that I'm looking at now?

11        Q.   Exactly.

12        A.   Of course.  Of course.

13        Q.   Thank you.

14        A.   [In English] It's no question.

15        Q.   Thank you.

16             MS. KORNER:  Your Honours, may this be admitted and marked,

17     please.

18             JUDGE HALL:  Yes, admitted and marked.

19             THE REGISTRAR:  Exhibit P900.

20             MS. KORNER:  All right.  Thank you.

21        Q.   Now I would like to back please very, very swiftly to intercepts.

22     First of all -- sorry, I just need to confirm this.

23                           [Prosecution counsel confer]

24             MS. KORNER:  Could I have up 65 ter 10248.  And it's divider 24.

25        Q.   Again, it's a conversation between you and Dr. Karadzic.  This

Page 5792

 1     time, on the 9th of September.  If you go to the first page, bottom of

 2     the page, please.

 3             You're saying -- you're telling Dr. Karadzic about gatherings.

 4     And Karadzic is, Again, we're talking about blocking Sarajevo.

 5             And then second page in English and in B/C/S, please.

 6             Again, Dr. Karadzic repeating the threat of barricades.  And then

 7     him saying in the middle of the English page:

 8             "They'll not escape the MUP, our MUP in Krajina, and not only in

 9     Krajina but all over Bosnia and Herzegovina ... we shall establish our

10     authority," et cetera.

11             So again, Dr. Zepinic, is it right -- and I appreciate what you

12     say about how you took his threats.  He is making more threats of

13     barricades and establishing their own authority.  Is that right?  If can

14     you just answer yes or no, so we can move on.

15        A.   Yes.

16        Q.   Thank you.

17             MS. KORNER:  Your Honour, please, admitted and marked.

18             JUDGE HALL:  Sorry, admitted and marked.

19             MS. KORNER:  Thank you.

20             THE REGISTRAR:  Exhibit P901.

21             MS. KORNER:  Moving then --

22             JUDGE HALL:  Ms. Korner, I was distracted momentarily by doing

23     the arithmetical calculation of how much time you have left.  And it's an

24     hour and 27 minutes.

25             MS. KORNER:  Thank you.  I'm very grateful, Your Honours.  Even

Page 5793

 1     so, there's still a lot to get through.

 2             Could we have up, please, on the screen, the next intercept which

 3     is 1046.  Tab 25, please, for the interpreters.

 4        Q.   Again, I think you -- you listened to this and identified your

 5     voice that of Dr. Karadzic.

 6             If we look at the bottom of the English, yes, Dr. Karadzic is off

 7     again, about this time the replacement of a gentleman named Nedjo Vlaski.

 8     Very quickly, can you just tell the Court who Mr. Vlaski was.

 9        A.   I remember Vlaski more as being the idiot when I was arrested and

10     how he behaved towards me and my family.  He a minor role to play in the

11     State Security Service before the war.

12        Q.   And then we see, if we go into the English, in page 2, and I

13     think the B/C/S in page 2 as well.

14             You offer to resign at that stage.  And can you just - and I

15     apologise for asking you - could you briefly say why, at this stage, you

16     were offering to resign.

17        A.   I believe that was my second or third attempt at offering my

18     resignation to the government and the Presidency.  I had realized that my

19     concept and my political views and thinking, as well as the way I managed

20     the Ministry of Interior, were all in conflict with the policies and

21     intentions of the ethnically-based parties which were then in power.

22             Therefore, I was part of the executive power.  I was a member of

23     that executive power, and in any case, I am really surprised that I had

24     not been removed even before, because there was no segment in which I

25     subscribed to the policies of the coalition powers the way they wanted me

Page 5794

 1     to do.  My resignation was open at any time, but it was never accepted.

 2     On two occasions Mr. Krajisnik told me that that resignation could not be

 3     made public before the Assembly of Bosnia and Herzegovina.  I don't know

 4     why that was impossible, but it is true that I offered my resignation,

 5     not once, but on several occasions.

 6        Q.   Thank you.

 7             MS. KORNER:  Your Honours, may that be admitted and marked,

 8     please.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  Exhibit P902.

11             MS. KORNER:  Could you now -- could we have up on the screen,

12     please, 3074.  Divider 26 for the interpreters.

13        Q.   Not a conversation in which you were involved, but you are

14     referred to, and I just want it ask you about it.

15             Again, this is 17th of September.  This is a conversation between

16     Karadzic and Miodrag Simovic who you have referred to on a number of

17     occasions.

18             When you listened to the conversation, were you able to identify

19     the voices?

20        A.   Yes, I identified Dr. Karadzic and Dr. Simovic.

21        Q.   You see, Dr. Karadzic is saying here that Simovic should tell you

22     - this is in the middle of the page - that, All the ministers and the

23     officials in the MUP will be withdrawn, discontinuing the partnership

24     because you are allowing maltreatment and removal from office.  Vlaski

25     removed.  Going to break up with Izetbegovic.  Establish our own SUP.

Page 5795

 1             And then Karadzic says that he should resign immediately -- you,

 2     sorry, you should resign immediately if you're able to protect

 3     [indiscernible].  And it says you should submit it.

 4             Now, did Mr. Simovic speak to you about Karadzic saying you

 5     should resign?

 6        A.   I don't remember that Simovic spoke to me about that.  But let me

 7     just side track a little.

 8             Dr. Simovic was the vice-president of government in charge of

 9     internal affairs and political affairs.  I don't remember that we

10     discussed that.  As far as my resignation is concerned, I have tabled it

11     already in the previous intercept.  That resignation was on at all times,

12     and it was available to anyone who wanted it.  When it says we will meet

13     again, Izetbegovic and I, I would say that this is it just a customary

14     threat about Dr. Karadzic and Mr. Izetbegovic being able to find a way to

15     break up the MUP.  But that's their business, and I -- never occurred to

16     me to pay attention to that.  We should only have been so lucky for them

17     to have made and implemented such a decision.

18        Q.   Yes, thank you.

19             MS. KORNER:  Your Honours, may that just be marked for

20     identification, please.

21             JUDGE HALL:  So marked.

22             THE REGISTRAR:  Exhibit P903, marked for identification.

23             MS. KORNER:  And finally for this period of time, can we look at

24     1048.  Divider 27 for the interpreters.  This is a conversation between

25     you and Mr. Karadzic, 18th of September, so the day after that.

Page 5796

 1             MR. ZECEVIC:  Sorry, can we have the 65 ter number, I'm sorry.

 2     It wasn't recorded.

 3             MS. KORNER:  1048.  Divider 27.

 4             Can we go -- again, I think you listened to this, identified your

 5     respective voices.

 6             MS. KORNER:  Could we go in the English, please, to page 3.  And

 7     in the B/C/S, it's page 2.  And can we move up the English slightly, and

 8     the B/C/S too.  It's the last -- yeah, thank you.

 9        Q.   Karadzic, again talking personnel issues, it would appear.  And

10     he says to you:

11             "Everything regarding personnel, all these matters should be

12     fixed and finished.  This is something I want rectified.  Our people have

13     been constantly alert and make sure they don't let them fuck up things in

14     any way.  It is down to you as a master of the house to play a crucial

15     role.  You're a Serbian minister, and everything that the Serbian people

16     have entrusted to the authorities, they have accordingly entrusted to you

17     and the people who have assembled there."

18             Did you regard yourself as a Serbian minister, in the sense of

19     being answerable to the SDS?

20        A.   No.  I was accountable and answerable to the Assembly of

21     Bosnia-Herzegovina, the government of Bosnia-Herzegovina and Presidency

22     of Bosnia-Herzegovina.  Political leaders or parties in power as

23     political parties received information from us, and we participated in

24     their meetings when matters within our purview were discussed, within the

25     purview of our ministry.  Not a single party leader under the law, the

Page 5797

 1     practice was a different matter, but under the law, no single party

 2     leader had the right to intervene in the matters of the Ministry of the

 3     Interior, be it in the matter of its functioning, be it in the personnel

 4     matters.  That is why the political parties had agreed to have three

 5     committees that were supposed to meet and possibly propose or table their

 6     proposals for the personnel and other relevant facts that were necessary,

 7     not only for the functioning of my ministry but also of other ministries.

 8     Individual invitations by political leaders were primarily, in my mind, a

 9     certain level of pressure that was put on us who were working there.

10     However, we were answerable only to the government, the Presidency, and

11     the Assembly of Bosnia-Herzegovina, and not to political -- to the

12     political parties.

13             And let me just say that the assembly appointed people as members

14     of government, not as party members.

15        Q.   All right.  Thank you.

16             MS. KORNER:  May that be admitted and marked, please.

17             JUDGE HALL:  Admitted and marked.

18             THE REGISTRAR:  Exhibit P904.

19             MS. KORNER:  All right.

20        Q.   Could you now have a look, please, at a document which is

21     exhibit 1805 -- 65 ter number 1805.

22             This is a letter of complaint from the SDA, dated the 8th of

23     October, addressed to Mr. Izetbegovic, Mr. Delimustafic, and then the

24     third person is you.  And it's largely a complaint about the behaviour of

25     Mr. Mandic.

Page 5798

 1             Did you receive this document?

 2        A.   I can't remember whether I saw this document or not.  I can say

 3     that, together with Mr. Cengic and Mr. Brko, who was the secretary of the

 4     SDA, we held several meetings about personnel issues and the selection of

 5     personnel to be put forward by the SDA.

 6             I must say that they were satisfied with my positions, just as

 7     Mr. Karadzic and others were.

 8        Q.   Well, I'm just concerned about one aspect of this.  One of the

 9     complaints -- let me go back to -- it's at the --

10             MS. KORNER:  Yes, it's the paragraph which is near the bottom.

11     So if we can move the document up in English.  I don't think it's on --

12        Q.   They complain that Mandic has managed to give employment to a

13     significant number of his relatives, friends, and family members,

14     including his brother and kum, which I think - I don't understand what

15     that means - Mico Stanisic.

16             Firstly -- was -- did you know whether or not Mico Stanisic was

17     the -- the kum to Momcilo Mandic?

18        A.   I really wouldn't know.  In any case, Mr. Stanisic was not

19     appointed the secretary of the Sarajevo SUP because he was

20     Momcilo Mandic's kum.  As for the younger Mandic, Momcilo Mandic's

21     brother, he was at the school of the interior, at the time when I was the

22     chief administrative officer of that school.

23             As for the people who Mr. Cengic mentions here, I knew some of

24     them and with great satisfaction, I can say that I kept Vahid Pasic,

25     Idriz Pesic, and Pajnovic, because they were professionals.  I am

Page 5799

 1     surprised that Mr. Cengic given, on behalf of the SDA, asks why a place

 2     couldn't be found for Sredoje Novic or - just a moment, the brain's gone

 3     - and Momo Andzic, I believe.  They were both Serbs.

 4        Q.   All right.

 5             MS. KORNER:  Your Honours --

 6             THE WITNESS: [In English] Excuse me.  I'm just looking

 7     translation here.  Firstly, Mico Stanisic was the kum to Milan Martic.

 8             MS. KORNER:  I'm sorry.  It says Milan Martic, does it?

 9             THE WITNESS:  Yes.

10             MS. KORNER:  I don't think that can be right.  Line -- sorry, I

11     can't see it on the B/C/S.

12             THE WITNESS:  Eighteen.

13             MS. KORNER:  Oh, I see --

14             THE WITNESS: [Interpretation] Line 18.

15             MS. KORNER:  It should be Mandic, not Martic.

16             THE WITNESS: [Interpretation] I apologise for this intervention.

17             MS. KORNER:  Thank you.

18             Your Honours, may I ask that this document then be admitted and

19     marked.

20             JUDGE HALL:  Admitted and marked.

21             MS. KORNER:  Thank you.

22             THE REGISTRAR:  Exhibit P905.

23             MS. KORNER:  Next, could you have a look, please, at a document

24     that's already been exhibited, very quickly, P180.

25             THE REGISTRAR:  I apologise has the counsel just been tendering

Page 5800

 1     1805?

 2             MS. KORNER:  Yes.

 3             JUDGE HALL:  It has already been exhibited as Exhibit P904.

 4             MS. KORNER:  Oh.  Thank you.  Didn't realize that.  In which case

 5     could I -- P180, thank you.

 6        Q.   This is the gazette.  And we're moving now really to the end of

 7     the year and after there has been the split in the assembly.  This is the

 8     Ministerial Council of the Assembly of the Serbian people in Bosnia and

 9     Herzegovina.

10             You are shown as the second person on that council, with

11     Mico Stanisic.  We have go down a bit on the page, in English, as number

12     18.

13             Now, why did you agree to go on to the ministerial council that

14     had been set up by the Assembly of the Serbian People?

15        A.   This was not on the initiative by the SDS.  It was an agreement

16     between the three parties to establish councils or committees of those in

17     power on behalf of the parties.  I told you that I had information that

18     the minister of the SDS and the SDA were meeting.  This was an initiative

19     on the part of the political parties to establish committees or councils

20     composed of people who acted on behalf of their parties in the positions

21     to which they were appointed by their parties.

22        Q.   All right.  Shall we step back for a moment, please.  Stop there,

23     Dr. Zepinic.

24             In October of 1991, the Serbs left the assembly.  There had been

25     the passing of the resolution, and I don't want to enter into the

Page 5801

 1     legality of that, but the Serbs were establishing -- had established

 2     their own assembly.

 3             Now, whether or not, as you say, the only other assembly, the

 4     Bosnia-Herzegovina Assembly had established a ministerial council, what

 5     I'm asking is why you agreed to join a specifically Serb ministerial

 6     council.

 7        A.   Because I was in a position that belonged to the SDS.

 8        Q.   Okay.  And do you know why Mico Stanisic was also put onto the

 9     council?

10        A.   I couldn't tell.  Probably because -- but I'm not sure whether he

11     was still secretary of the SUP of Sarajevo at the time, or whether he had

12     been appointed counsellor in the minister's office.  Some of the names

13     mentioned here are the names of people I've never met, so ...

14        Q.   All right.  And just to complete this, you did actually attend -

15     and I don't think that we need to put up the documents because they're

16     already exhibited - meetings of this ministerial council, didn't you?

17        A.   I believe I attended one meeting of this council.

18        Q.   I think -- I think we'll find it's two.  But if we look,

19     please -- I don't --

20        A.   Maybe two, possibly.

21        Q.   And what did you understand was the purpose of this Ministerial

22     Council of the Serb Assembly?

23        A.   To be honest, I had expected that the appointment of a council

24     composed of persons who were in certain positions to which they were

25     appointed by their parties, would prove a way of finding agreement among

Page 5802

 1     political parties.  But my expectations were proven wrong.  I believe

 2     that you're in possession of documents that show that I didn't

 3     participate in the activities of this council, once I understood that it

 4     was set up to no avail.  These ministerial councils were eventually

 5     dissolved.  Whether new ones were established later, I don't know.  But

 6     I'm referring now to the ministerial council whose composition is shown

 7     here, and my name figures among the members.

 8        Q.   And you have -- I'm sorry.

 9             MR. ZECEVIC:  I'm sorry, Your Honours, 45, 3, I believe the

10     witness said that these ministerial councils were eventually dissolved on

11     all three sides.  Maybe you can verify that with the witness, Ms. Korner.

12             Thank you.

13             MS. KORNER:

14        Q.   Is that what you said?

15        A.   Yes.  I think that yesterday documents were shown to me, which

16     say that the Serbian Democratic Party dissolved this ministerial council.

17        Q.   Let's be clear about this, please, Dr. Zepinic.  The documents

18     you saw yesterday related to SDS meetings and whatever SDA party

19     meetings.  This is alleged to be a ministerial council.

20             What ministerial council existed in the Assembly of Bosnia and

21     Herzegovina, which was still meeting during this period?

22        A.   The ministerial council was not in existence, as such, when that

23     would have been appointed by the cabinet or the Assembly of

24     Bosnia-Herzegovina.  These are ministerial councils appointed by

25     political parties, and they are composed of candidates that held

Page 5803

 1     positions in the assembly and the cabinet.  And the positions were those

 2     that belonged to the political parties.

 3        Q.   All right.  Had, in Bosnia and Herzegovina, at that stage, the

 4     Croats taken themselves out of the Assembly of Bosnia and Herzegovina and

 5     set up a separate assembly with a ministerial council?

 6        A.   I believe that there is an misunderstanding, at least judging by

 7     your question.

 8             The Serbian Democratic Party, the SDA, and the HDZ had their

 9     respective assemblies, and they had their bodies, political bodies.  And

10     the same parties established their ministerial councils, according to the

11     agreement struck by political leaders, the same way the SDS did as we see

12     in this document.  The Croatian Democratic Union, that is the Croats, as

13     far as I know, did not walk out of the Assembly of Bosnia-Herzegovina

14     and --

15             [Previous translation continues] [In English] ... Your Honour, if

16     you don't mind, take a little bit time to explain a little bit more about

17     consequences of [indiscernible].

18        Q.   No, I don't -- for the moment don't trouble about that.  I think

19     we need to establish what we're all talking about here.

20             The Serbs had walked out of the assembly in October 1991.  That

21     is correct, isn't it?

22        A.   [Interpretation] Yes.

23        Q.   In -- they had set up their own separate assembly of the SDS,

24     which was separate from the Assembly of Bosnia and Herzegovina.  That's

25     right, isn't it?

Page 5804

 1        A.   Well, that Assembly of the Serbian Democratic Party, the HDZ and

 2     the SDA had existed even before the new government was established.  They

 3     had their assemblies all the time, and based on that, they nominated

 4     their cadres.

 5             A new Assembly of the Serbian people or the SDS was not

 6     established after the Serbs had walked out of the assembly, but the

 7     existing assembly had only continued to function.

 8        Q.   All right.  So you -- all right.  You are equating, are you,

 9     this -- the Assembly of the Serbian People in Bosnia and Herzegovina with

10     party congresses - let's get the terms quite clear, please - or party

11     structures, you are saying this is the same thing.  That was your view.

12     Is that right?

13        A.   No new candidate was elected, as far as I know, to the Assembly

14     of the SDS once the Serbs had left the coalition partnership in the

15     Assembly of Bosnia-Herzegovina.

16        Q.   All right.  Let's move on then, because, as I say, time is

17     running out.

18             Can we turn now, please, to -- yes, I just want to ask you to

19     look very briefly at the head of this document.  It has already been

20     exhibited as P -- no, for some reason, it appears to be a Defence

21     exhibit, which is 1D135, I don't know why, but let's hope it's the right

22     one.

23             On the 11th of February 1992, a large gathering of senior police

24     officers was held in Banja Luka.  Were you ever told about this gathering

25     at the time, or invited to attend?

Page 5805

 1        A.   No, I wasn't invited, nor did I know about that gathering.  But

 2     it wasn't their duty to inform me either because I had officially

 3     resigned and the Speaker of the Assembly of Bosnia-Herzegovina

 4     Mr. Krajisnik, accepted my resignation.  It was dated the 4th February,

 5     1992.

 6        Q.   I don't think --

 7        A.   So that was seven days before this gathering.  If they had

 8     invited me, I most certainly would not have gone, but I was not invited,

 9     nor did they consult me about anything.

10        Q.   I think you have made a slight mistake about your resignation

11     because we're going to come to that.

12             You resigned in April, not February.  Or rather --

13        A.   I'm sorry.  Yes, you're right.  Correct.  But I was not aware of

14     that gathering, nor was I invited.

15        Q.   So neither Mico Stanisic nor Momcilo Mandic told you that this

16     meeting was going to be held or had been held?

17        A.   No.

18        Q.   Thank you.

19             All right.  Next, can we look at, please -- you asked about

20     Mico Stanisic's appointment.  The document is 2596.

21             He was apparently appointed to the -- as an advisor to the State

22     Security Service on the 14th of February, 1992, which is after the

23     appointment of the Council of Ministers.  So in your view, as he hadn't

24     been appointed to the position which he held then, was there any reason

25     for him to have been on the Council of Ministers, as a result of him

Page 5806

 1     being secretary to the SUP in Sarajevo?

 2        A.   When he was secretary to the SUP in Sarajevo, there may have been

 3     a reason for him to be a member of the council, or whatever they called

 4     it, because his position was that of a member of the minister's office.

 5             And about his appointment as advisor, I don't know about that.  I

 6     believe Delimustafic signed this.  It seems so.  So I cannot comment.

 7     But there was some disagreement about the carrying out of duties of the

 8     secretary to the SUP at Sarajevo, and that probably brought about the

 9     replacement of Mico Stanisic and his being appointed advisor at the

10     minister's office.

11             But, as far as I know, his -- his own office was not at the

12     ministry, but he still had his desk, his workplace, at the city SUP, if I

13     remember well.

14        Q.   All right.  Are you saying that Mr. Delimustafic didn't discuss

15     with you at all the appointment of Stanisic to this position?

16        A.   I'm not saying that.  I'm saying that there was some disagreement

17     between the ministry, or, more specifically, me and Mr. Stanisic, because

18     the concept of leadership of the secretary to the SUP of Sarajevo did not

19     match my concept or the concept of the ministry.  So that's why any

20     agreement with Mr. Stanisic, decided to appoint him advisor, and I

21     believe that Kemo Sabovic was reinstated in his position because he had

22     been in that position before Mr. Stanisic was appointed.

23        Q.   All right.  Thank you very much.

24             MS. KORNER:  Your Honours, may that be admitted and marked,

25     please.

Page 5807

 1             JUDGE HALL:  Admitted and marked.

 2             THE REGISTRAR:  Your Honours, this is Exhibit P906; and page 43,

 3     line 1 through 4 should be Exhibit P905.

 4             MS. KORNER:  Right.

 5        Q.   I now want to move, please, to the events of the barricades at

 6     the beginning of March about which you told us a little yesterday.

 7             Can you just tell us --

 8             THE WITNESS: [Interpretation] I just have a correction.  It was

 9     in early March, not May.

10             MR. ZECEVIC:  I note that the transcript is not precise what the

11     witness has said.  I heard the witness say that this -- this change was

12     because of the differences in concept, In agreement with Mr. Stanisic, it

13     was decided to appoint him advisor, and I believe that Kemo Sabovic was

14     reinstated after that.

15             MS. KORNER:  Isn't that what it says?

16             MR. ZECEVIC:  It says so that's why any agreement then, I don't

17     know, assign with Mr. Stanisic decided to appoint him advisor, so ... I'm

18     not -- I just wanted to be -- to have it precise, if it is possible,

19     please.  So maybe the witness can repeat his answer slowly so it can be

20     recorded properly.

21             MS. KORNER:

22        Q.   Very, very briefly, sir, because we have still got a lot to

23     cover, what did you say about Mr. Stanisic's appointment?  Was that with

24     his agreement or with Delimustafic's agreement?

25        A.   I will repeat once more and try to be brief and precise.

Page 5808

 1             There was open disagreement with regard to the concept and the

 2     way of working at the SUP of Sarajevo, and my position in the ministry.

 3     So, and that was spelled out, openly.

 4             Mr. Stanisic accepted that the differences between his concept

 5     and mine were unsurmountable.  Because the CSB of Sarajevo was one of the

 6     most important CSBs in the former Bosnia-Herzegovina.

 7             So we agreed with Mr. Stanisic that he be appointed advisor in

 8     the minister's office, but his workplace remained in the building of the

 9     city secretariat, and he never moved physically to the building of the

10     ministry.

11             MR. ZECEVIC:  Thank you.

12             MS. KORNER:

13        Q.   Now, sir, you told us something about the barricades yesterday.

14     Let's see if we can deal with this quite shortly and look at some of the

15     documents that relate to it.

16             How did you find out, please, very briefly, sir, that these

17     barricades had been arrested [sic] on the 1st of March?

18        A.   Rajko Dukic called me on the phone and informed me that there had

19     been a murder by the church in Sarajevo and, for that reason, barricades

20     had been set up in Sarajevo, and that the SDS was behind that, as a

21     response to that act, which had been committed at a wedding.

22             As far as I remember, that was around 7.00 p.m.

23        Q.   Pause there for a moment because page 51, line 9, it says

24     barricades had been "arrested."  Erected is what I said.

25             All right.  So you were told by Rajko Dukic that the barricades

Page 5809

 1     gone up in response to this killing, the SDS was behind it.  What did you

 2     do then?

 3        A.   I went to the building.  Meanwhile, I already had problems at

 4     some barricades.  I was stopped because representatives of the SDS were

 5     saying that I wasn't the person to continue making decisions, because the

 6     Assembly of the SDS had, allegedly, appointed Mr. Stanisic the Serb

 7     minister.  And I apologise, if I'm using the wrong term now.

 8             But I was able to reach the building eventually.  I walked around

 9     some barricades, and then I tried to contact the members of the

10     Presidency and the political leaders.  Mr. Dukic said to me that

11     Dr. Karadzic, Dr. Koljevic and Mr. Krajisnik were in Belgrade at an

12     important meeting.  Later, I found out that they were gambling with Arkan

13     at the Yugoslavia Hotel.  I tried to contact the other members of the

14     Presidency and was able to speak to Mr. Izetbegovic, who showed no

15     interest whatsoever to find a solution to the issue of the barricades.

16     He said that it was for the MUP to take care of that.

17             Meanwhile, I had called my co-workers to come to headquarters

18     urgently and see what we could do to avoid conflict because the SDA had

19     already started erecting barricades too.  And my assistants responded to

20     my call.  They came to headquarters.  We were in my office all the time,

21     setting up contact with the local police stations to be fully informed

22     what this was all about and why barricades had been set up.  Also,

23     because the active police force should try to prevent an escalation of

24     violence at certain spots, and we also wanted to prevent clashes between

25     opposing barricades.  I mean, Serb and Muslim barricades.  And I cannot

Page 5810

 1     say whether it was on that day or on the following day that I decided to

 2     call up a part of the reserve police in Sarajevo.  And around 1.00 or

 3     2.00 a.m., I was able to speak to Ms. Plavsic.

 4             She responded, and she was surprised, she didn't know about the

 5     barricades.  She said to me that she would come to my office so that we

 6     may see what we could do.  And I informed her that I already spoken to

 7     Mr. Izetbegovic and -- who answered that he wanted to -- to get a good

 8     night's sleep rather than take care of problems that the MUP should take

 9     care of.

10        Q.   All right.

11        A.   And I wanted as many people from the MUP to come, so that we

12     could take care of the situation.

13        Q.   Pause, please.  Because we looked earlier yesterday about the

14     conversation about Mr. Plavsic which -- Mr. Dukic.

15             Before we look at a couple of other conversations, I want do show

16     you, please, a short clip from the Death of Yugoslavia about the

17     barricades.  I have no idea what the number is.

18                           [Prosecution counsel confer]

19             MS. KORNER:  2931.  2764.

20                           [Prosecution counsel confer]

21                           [Video-clip played]

22             THE NARRATOR:  "For centuries Muslims, Serbs, and Croats have

23     lived here together.  Now they had to choose a future.  Half the Yugoslav

24     republics had gone for independence, and it was time for the Bosnians to

25     decide.

Page 5811

 1             THE INTERPRETER: "[Voiceover] we created a situation in which" --

 2             MS. KORNER: [Previous translation continues] ...

 3             THE INTERPRETER: "[Voiceover] but the Muslims and Croats wanted

 4     it out.  I was clear that Bosnia was doomed."

 5             THE NARRATOR:  "Muslims and Croats were the majority, so the

 6     president won his vote.  He was expecting trouble, but he didn't know it

 7     would start from his own side.  It happened as the guests arrived at a

 8     Serb wedding.  The Muslim killed the father of the groom.  That night,

 9     Serbs hit back.  Their gunmen erected armed barricades all over the

10     Bosnian capital."

11             THE INTERPRETER: "[Voiceover] The Serbs of Sarajevo demand,

12     number one" --

13             MS. KORNER:  Could we just pause for a moment there.

14        Q.   Who was that speaker?

15        A.   It was Rajko Dukic.  Mr. Dukic.

16        Q.   Thank you.

17             MS. KORNER:  Yes, carry on.

18                           [Video-clip played]

19             THE INTERPRETER: "[Voiceover] That the Bosnian government stopped

20     seeking international recognition of the sovereignty of

21     Bosnia-Herzegovina."

22             THE NARRATOR:  "Neither the Bosnian police nor the Green Berets

23     and Muslim paramilitaries under Izetbegovic were strong enough to take

24     own the Serbs."

25             THE INTERPRETER: "[Voiceover] Then we decided" --

Page 5812

 1             MS. KORNER:  All right.  Thank you very much.  That's all we

 2     need.

 3        Q.   Sir, did you see the scene that we saw of the police officer --

 4     sorry, of a person at the barricades pointing a gun, was that a seen that

 5     you saw when you were doing your tour of the barricades?

 6        A.   Yes, it was a normal, scene.  I visited all barricades, and at

 7     some I was arrested, simply because I had decided not to use the police,

 8     either active or reserve units, to scatter the barricades, but I wanted

 9     to resolve the issue with political means.

10             So I went from one barricade to another all night through, and on

11     the following day, because I wanted to calm down the situation and

12     prevent open conflict.  As you saw from these videos they were armed

13     persons at these barricades so that Sarajevo was completely blocked, and

14     they controlled the passing of the civilian population.  And then the --

15     that's -- that's why I wanted the Presidency to make a decision about the

16     solution to the barricades issue.

17        Q.   Yes.

18             MS. KORNER:  Your Honours, I wonder if that clip could be

19     admitted and marked.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  Exhibit P907.

22             MS. KORNER:  Just so we can deal with film clips at the same

23     time, I want to you have a look at a short clip from the film -- the

24     documentary Serbian Epics, which is 65 ter 2931.

25                           [Video-clip played]

Page 5813

 1             MS. KORNER:  Pause for a moment.

 2        Q.   Do you recognise him?

 3        A.   Yes.  This is Mr. Mico Stanisic.

 4             I apologise, Your Honour, my emotion -- my reaction is a bit

 5     emotional.  I believe that you will appreciate how I feel watching the

 6     footage which confirmed that my country is dying, and I apologise for my

 7     emotional reaction.

 8             Could I please be given a break.

 9             JUDGE HALL:  We are a few minutes short of the ordinary break, so

10     we would rise at this time and resume in 20 minutes.

11             MS. KORNER:  Thank you.

12                           [The witness stands down]

13                           --- Recess taken at 12.05 p.m.

14                           --- On resuming at 12.30 p.m.

15                           [The witness takes the stand]

16             JUDGE HALL:  Dr. Zepinic, I trust you have sufficiently recovered

17     in order to continue your testimony.

18             MS. KORNER:

19        Q.   I'm just going to ask to you look at a bit more of there film.

20        A.   It will take a lot more to recover from everything, but there you

21     go.

22        Q.   Yes.

23                           [Video-clip played]

24             MS. KORNER:  Sorry, can we just pause for a moment.

25        Q.   Until the time of your resignation at the beginning of April, did

Page 5814

 1     you ever see Stanisic wearing uniform like that?

 2        A.   No.  Nor did I have an occasion to meet with Stanisic after I

 3     resigned.

 4        Q.   Right.

 5             MS. KORNER:  Can we just play the rest then, please.  I just want

 6     to ...

 7                           [Video-clip played]

 8             THE INTERPRETER: "[Voiceover] I'm Mico Stanisic, interior

 9     minister of the Serbian Republic of Bosnia-Herzegovina.  Here you see my

10     closest collaborators, participants in the first battle for our Serbian

11     people, and they're also participants in the first victory" --

12             MS. KORNER:  I don't think we need translation, it's subtitled,

13     Your Honour.  Thank you.

14                           [Video-clip played]

15             MS. KORNER:  Just pause, please, for a moment.

16        Q.   Karisik, had he been appointed as head of the Special Police by

17     the time you had resigned?

18        A.   Milenko Karisik was Dragan Bikic's deputy in the special unit

19     while I was there.  And later on, as I can see, he was appointed the

20     commander of the special unit when Mr. Stanisic took over the role as the

21     minister in Republika Srpska.

22        Q.   The next person that he is about to identify, we can see the name

23     on the screen, did you know him?

24        A.   Zlatko Brdar, yes, I knew him, he was also a special unit member.

25     I wasn't aware of the fact that he had a command role.

Page 5815

 1             MS. KORNER:  Just play to the end of this, and then we'll stop.

 2                           [Video-clip played]

 3             MS. KORNER:  Pause, please.

 4        Q.   Who is that?

 5        A.   Mane -- I'm not sure that I know the person.  But looking at him,

 6     I would say that is also a former member of the Special Police unit.

 7        Q.   All right.

 8                           [Video-clip played]

 9             MS. KORNER:  Pause, please.

10        A.   [In English] I don't know.

11        Q.   You don't know.

12                           [Video-clip played]

13             MS. KORNER:  Pause, please.

14        Q.   Do you know that gentleman?

15        A.   [Interpretation] No.

16        Q.   All right.  Thank you.  That's all I wanted to play.

17             MS. KORNER:  Your Honours, although I played it in opening, it

18     actually hasn't been admitted yet.  Could that be admitted and marked.

19             JUDGE HALL:  Admitted and marked.

20             MR. ZECEVIC:  Could we have just the date of this video, please.

21             MS. KORNER:  June 1992, and I'm sorry, I can't remember the exact

22     date.  But it is June 1992.

23             MR. ZECEVIC:  Thank you very much.

24             THE REGISTRAR:  Exhibit P908, Your Honours.

25             MS. KORNER:

Page 5816

 1        Q.   All right.  We know, Dr. Zepinic, and I have got a number of

 2     other things to cover with you that the barricades incident was in fact

 3     settled by a form of negotiation.

 4             But I want to ask you to you look at some intercepts, please,

 5     very quickly.

 6             MR. ZECEVIC:  I'm sorry, Ms. Korner, again, I believe you offered

 7     this as -- as document to be marked for identification.

 8             MS. KORNER:  No.  I asked for it to be exhibited.

 9             MR. ZECEVIC:  I'm so sorry.  I missed that.

10             MS. KORNER:  Thank you.

11             Could we have up, please, very, very quickly a couple of the

12     conversations that took place during the barricades.  The first is in

13     tab 31, for the interpreters.  It is 1052.

14        Q.   And because of the time I'm not going to do too much of the

15     contents.  But you listened to this, and we can see that Mrs. Plavsic is

16     saying, in the middle of the first page, that the minister is here, the

17     deputy minister, Mr. Jusuf, is here, as far as the MUP.  Were you there

18     -- is this when she was there with you or you were there with them, or is

19     this somebody else?

20        A.   I was there.  The meeting was held in the morning on the 2nd of

21     March, 1992, around 8.00 in the morning in the Presidency building.

22     Delimustafic and I were there, I don't know who this Jusuf is.  Whether

23     it was Jusuf Pusina or whether it was Jusuf who was Mr. Abdic's head of

24     office.  I can't identify the person.  But, yes, the two of us were

25     there, and discussed the barricades.

Page 5817

 1        Q.   And when you listened to the tape, were you able to the voices of

 2     Plavsic, Dukic, Ostojic, and Mr. Cengic?

 3        A.   Yes.

 4             MS. KORNER:  Your Honours, then he was present for this one, so

 5     may that be admitted and marked, please.

 6             JUDGE HALL:  Yes, admitted and marked.

 7             THE REGISTRAR:  Exhibit P909, Your Honours.

 8             MS. KORNER:

 9        Q.   I want to you look, however, please, at a conversation with --

10     sorry.

11                           [Prosecution counsel confer]

12             MS. KORNER:

13        Q.   Yes, it is tab 36, please, 1427.  And it's the 2nd of March,

14     during the incident again.

15             Now, when you listened to this, were you able to identify the

16     voices of Mr. Stanisic and Mr. Dukic?

17        A.   Yes, I identified their voices.

18        Q.   Right.  In the middle of the first page, Mr. Stanisic says when

19     he's asked, Where you are calling from?

20             I am up there, at Vrace's community hall.

21             Were you aware that that's where he was at the time?

22        A.   No.

23        Q.   All right.  And then if we go, please, to the third page in

24     English, and the second page in the B/C/S.  Stanisic is saying to

25     Mr. Dukic, Since was visited there, I visited all the check-points.  He

Page 5818

 1     says, Sarajevo is ours, 100 percent.  And he repeats that.

 2             Did you ever see him?  You were visiting the various barricades

 3     or whatever, did you ever see him during any of this?

 4        A.   No, I didn't have an occasion to see Mr. Stanisic at any of the

 5     barricades, and I find this statement of his surprising, given the fact

 6     that the SDA also erected barricades.  So it is really surprising for me

 7     to hear that he could tour and inspect all the barricades because he

 8     would have had to pass through the SDA barricade in order to reach the

 9     SDS barricades.

10             But during that night or the following morning, I did not see him

11     on any of the barricades, be it those erected by the SDA or those erected

12     by the SDS.

13        Q.   Thank you very much.

14             MS. KORNER:  Your Honours, then this is one should be simply

15     marked for identification.

16             JUDGE HALL:  So marked.

17             THE REGISTRAR:  Exhibit P910, marked for identification,

18     Your Honours.

19             MS. KORNER:  All right.

20        Q.   Thank you very much.  That's all I want to ask you about the

21     conversations on the barricades.

22             Can we just look briefly, please, at a report that was prepared

23     after the incident, and that is 376, please.  Yes.

24             MS. KORNER:  376?  I hope we're connected to e-court.

25                           [Prosecution counsel confer]

Page 5819

 1             MS. KORNER: [Microphone not activated] See if we can put up the

 2     Sanction.

 3             THE INTERPRETER:  Microphone, please.

 4             MS. KORNER:  Sorry.

 5             Your Honour, we seem to have e-court problems again, so we will

 6     see if we can put this document up in Sanction.  Yeah.  And if we could

 7     have the English.

 8        Q.   It's a long report, Dr. Zepinic, so I just want you to -- was a

 9     report done by the -- by someone - it is dated, but it doesn't look like

10     it is signed at the end - on the barricades incidents, and were you made

11     aware of this report?

12        A.   I'm not familiar with the report.  I have not seen it before I

13     started today in the courtroom.  When I read it, I believe that the

14     report is not complete.  This is probably just one part or some of the

15     information obtained by the State Security Service, but there was other

16     information held by crime services and public security services about the

17     participation of persons on the barricades and the incident that took

18     place there.  And, obviously, all the consequences which took place two

19     days thereafter, when the perpetrator was brought in but then released

20     without any charges being brought against him.

21        Q.   Yes.  All right.  I -- because it is a long report, I haven't got

22     time to go through it.  When you read it, the contents of the report, did

23     that seem to be accurate to you?

24        A.   Partially accurate but not fully accurate.  I would say that it

25     is not fully accurate.  It doesn't provide the full information about the

Page 5820

 1     complete security situation with regard to the incidents that took place

 2     in Sarajevo between the 1st and the 4th of March.

 3             I would not accept this report as an official report on behalf of

 4     the Ministry of the Interior with regard to the incidents on the

 5     barricades because it does not contain all the elements that the ministry

 6     was privy to as obtained based on the intelligence, the circumstances of

 7     the murder, the participation of various persons in manning the

 8     barricades, and so on and so forth.

 9        Q.   All right.

10             MS. KORNER:  Your Honours, I'm going to ask that it be admitted

11     as an exhibit --

12             Your Honour, it is going -- just can I finish.  It is going take

13     me too long to take him through all the bits to say which is accurate and

14     which is inaccurate.  That's the problem.

15             JUDGE HALL:  Before I hear from Mr. Zecevic, Ms. Korner I'm at

16     lot as to the basis of this.  You're seeking the exhibit through this

17     witness.  A, he hasn't seen it before; B, from what he has seen he has

18     grave reservations, to put it mildly, about the accuracy of what it

19     contains; C, it's incomplete.  So the -- I can understand your having it

20     marked for identification, but I really don't see it admitted through

21     this witness.

22             MS. KORNER:  Very well, then, Your Honour.  I will have it marked

23     for identification.  That is fine for my purposes.

24             MR. ZECEVIC:  I'm thankful to Your Honour.  There is nothing more

25     I can add to you analysis.

Page 5821

 1             JUDGE HALL:  So it's marked for identification.

 2             THE REGISTRAR:  Exhibit P911, marked for identification,

 3     Your Honours.

 4             MS. KORNER:

 5        Q.   Yes, very quickly, can we have up -- in fact what is a -- already

 6     a Defence exhibit, I'm told, 1D120?

 7             JUDGE HALL:  Sorry.  Before we go on, I see the transcript

 8     reads --

 9             THE INTERPRETER:  Microphone for the Presiding Judge, please.

10             JUDGE HALL:  Sorry, the transcript at line -- page 63, line 23,

11     my comments on Ms. Korner's application from what he has seen, he has

12     grave reservation to "future mindly" about the accuracy about what it

13     contains.  What I did say is, "to put it mildly."

14             MS. KORNER:  One always hopes these things will be corrected when

15     it's listened to in the background, but I agree it is probably better to

16     be safe than sorry.

17             Can we have 1D120 up, please.  Yeah.

18        Q.   This is the -- the council for the protection of the

19     constitutional order.  And if we go to the second page in each, we can

20     see your name as an attendee.  Is that right, you did attend this

21     meeting?

22        A.   Yes.  I attended those sessions almost regularly and

23     Professor Plavsic was the chairperson of that council.

24        Q.   All right.  Thank you.  That's all I want to ask you about that.

25             Now in fact you told us earlier you thought Mr. Stanisic had been

Page 5822

 1     -- or you had been told at the barricades that he been appointed minister

 2     of the interior at the beginning of the March.  In fact, he was - we know

 3     because we have documents - he was appointed on the 23rd of -- 24th of

 4     March, I'm sorry.

 5             Between this period in March and your resignation on the 4th of

 6     April, can I deal with this quite shortly, did you in fact receive

 7     information that Arkan and his forces were in Bijeljina?

 8        A.   Yes.  I was put in charge by the Presidency, together with

 9     Mr. Fikret Abdic, who was a member of the Presidency; Mr. Simovic; and

10     Mr. Jerko.  Delimustafic and I, actually, were put in charge of going to

11     Bijeljina and dealing with the situation.

12        Q.   Right.  I want to take that shortly, as I say, because I want to

13     come on to the circumstances of your resignation and arrest.

14             Was the upshot there that you were told when were stopped by a

15     check-point - and I am leading on this, and I hope there is no dispute -

16     and you were then told that Mico Stanisic had been appointed as minister

17     of the interior, Serbian minister of the interior?

18        A.   Yes.  After the interview on TV and problems with avoiding the

19     assassination, we managed to get to the airport.  A helicopter took us to

20     Tuzla from the barracks there, we were transferred to the centre of

21     security, and then a volunteer took us to Bijeljina, and our column was

22     stopped on the road by a group led by an SDS MP, Kerovic.  I can't

23     remember his name.  He asked me to step out of the vehicle because they

24     wanted to kill me, because I no longer represented anybody and had no

25     authority in the Ministry of the Interior from the positions of the SDA

Page 5823

 1     -- SDS, which, according to him, had, in the meantime, appointed

 2     Mico Stanisic for the Serbian minister in Republika Srpska.

 3        Q.   Right.  Had you been informed -- a simple yes or no, had you been

 4     informed in advance that Mr. Stanisic was going to be appointed?

 5        A.   I can't remember, to be honest with you.  I don't know.

 6        Q.   All right.  Then can you look, please, very quickly at a document

 7     dated the 1st of April, which is -- actually, it seems to have been

 8     exhibited already apparently.  I can't read what that is.  1D78?  Let's

 9     hope it's the right one.

10             I didn't -- no.  No, it is not.  Could I have up, please, 65 ter

11     2768.

12             JUDGE DELVOIE:  That's 1D78, indeed.

13             MS. KORNER:  Yes, I'm sorry, it is an error, and it should be 2

14     -- 65 ter 2768.

15                           [Prosecution counsel confer]

16             MS. KORNER:  Sorry.  No, that's wrong.  All right.  Oh, no it is.

17     It is the right document, I beg your pardon.

18             Can we just look at the second paragraph -- not -- on the

19     English.  Don't worry about the B/C/S.  I think it is the first

20     paragraph in the B/C/S.

21             It says the following members of the current advisory board of

22     the MUP discussed this matter about the organisation for internal

23     affairs, et cetera, on the 1st of April, and it shows you.

24             Is that right, did you discuss this matter?  Did you have a

25     discussion on the 1st of April.

Page 5824

 1        A.   I can't remember the date.  However, I know that I invited to my

 2     office my assistants, including Mr. Stanisic, I wanted to discuss the

 3     complete situation.  But I'm not sure that that was on the 1st of April,

 4     I'm sorry.

 5        Q.   This is apparently -- it's an official document, it looks like.

 6     And it talks about this meeting on the 1st of April, and then we better

 7     look at the second page, please, in English, and still on that page in

 8     B/C/S.

 9             Having realistically reviewed the evidence situation, et cetera

10     et cetera, the advisory board decided the existing MUP should be

11     transformed peacefully and without excesses.

12             Do you remember attending a meeting where this was discussed.

13     And please just yes or no.

14        A.   Could you please show the signature on this document to me.

15        Q.   It's -- it says Kolegij MUP.

16        A.   I cannot refrain from commenting this document, which is the

17     worst garbage.  Because this signature, the collegium of the MUP, means

18     nothing at all.  A dispatch can be sent on behalf of the MUP by the

19     minister, his deputy, or his assistants for some -- for some division.

20     But I don't know who may have represented the collegium of the MUP and

21     had the authority to send out such a dispatch, especially since it was

22     addressed to some federal institutions.

23             But to come back to the meeting you mentioned, it is true that I

24     invited my co-workers to my office.  It was not a collegium meeting but

25     an initiative of mine to say good bye to each other.  And I said then --

Page 5825

 1             Can I continue?

 2             MS. KORNER:

 3        Q.   You can.

 4             Can I just say, I'm just being reminded how little time there is,

 5     so if you can keep it short.

 6             All right.  Before this meeting had you become aware of Mandic's

 7     telegram about the MUP -- the split in the MUP and Mr. Delimustafic's

 8     response?

 9        A.   I cannot remember the exact date when I got acquainted with the

10     dispatch that Mr. Mandic sent on behalf of the CSB, and without any

11     authority to do so, but I know that there was an initiative for the two

12     of us to co-sign a dispatch and send it out to all organs and the

13     services of the MUP in Bosnia-Herzegovina, in which we would invite all

14     staff to continue carrying out their duties in accordance with the law

15     and regulations.

16             I believe that it was sometime in April, but at that time I spent

17     more time in a -- or on a helicopter, than in my -- in a bed.  I went to

18     Bijeljina, visited special units, went to Bratunac.  I was in the field

19     much more than in Sarajevo.

20        Q.   I'm just going to show you, please, the response which you

21     collaborated with on with Mr. Delimustafic.

22             MS. KORNER:  1D136, is that right?  It has been -- it has

23     definitely been exhibited, in which case I'm not going to bother.

24        Q.   But can I show you, please, the Mandic dispatch.

25             Sorry forget that, I don't have time.

Page 5826

 1             All right.  1st of April, this -- on the 4th of April, did you

 2     have a meeting with the special forces -- sorry, on the 3rd of April,

 3     with the commander, Mr. Vikic?

 4        A.   Yes.  Not only with Vikic but also other commanders who came to

 5     see me on the evening when I returned from Mostar.

 6        Q.   Did Mr. Karisik attend that meeting?

 7        A.   Mr. Karisik was not present.

 8        Q.   And, please, in two sentences, what was the purpose of this

 9     meeting?  What did you want to do?

10        A.   The purpose of the meeting was for the minister and me to appear

11     together before all the units of the Special Police and the commanding

12     staff and point out that it was necessary that the service function as a

13     single service and that they support -- they enjoyed our support in doing

14     so, because the circumstances had grown out of control.  But when it

15     comes to the unity of the -- these units, we emphasised that and that

16     they should act in accordance with the law and legal provisions.

17        Q.   In your view, Dr. Zepinic, what was going to be the effect of

18     splitting the MUP in the fashion that it happened?

19        A.   I start with the special unit.

20             With regard to the circumstances and the crises that were popping

21     up in Bosnia-Herzegovina, the special unit received orders to be in full

22     combat readiness.  And you can imagine 3 to 400 young men fully armed and

23     in full combat gear trained to carry out the most complex police

24     interventions what it would have meant if any kind of incident had

25     occurred within the unit.  Probably we would have witnessed such a

Page 5827

 1     massacre within the unit, and the consequences would have been

 2     disastrous.  And this opinion applies to the entire MUP.  A division of

 3     the MUP and its staff that were appointed on ethnic grounds.  And the

 4     ensuing establishment of MUPs, ethnically-based MUPs in one country, in

 5     which a ministry -- ministry staff should be mono-ethnic, a consequence

 6     of all that would have been a -- an armed conflict, and we all know what

 7     eventually came out of it.

 8        Q.   Yes, thank you.  Can we look first, please, at your resignation

 9     letter, and then if could you tell the Court how you came to resign.

10             MS. KORNER:  Could we have up, please, 1786.

11        A.   Yes, this is my resignation, addressed to Mr. Krajisnik as the

12     Speaker of the Assembly of Bosnia-Herzegovina and the president of the

13     Assembly of the SDS.

14             It was drafted during the meeting.  I received a phone call while

15     we had a meeting with the special unit from Mr. Krajisnik in person,

16     ordering me to -- to stop the meeting and come immediately to the

17     assembly, and I replied that - I called the meeting; it was my initiative

18     - and that we'll have the meeting and after which I will come to his

19     office, and he accepted that.

20             I did so.  And, upon coming there, in the waiting-room in front

21     of his office there was some armed and masked individuals whom I didn't

22     know in full combat gear so that my escort and my driver were a bit

23     frightened by that.  And the entire leadership of the SDS was in

24     Krajisnik's office.  Karadzic was there.  Mr. Koljevic, Mrs. Plavsic,

25     Mr. Djeric, Mr. Stanisic, and others.  And I also noticed, among others,

Page 5828

 1     that there was Momcilo Mandic present.  I also saw Karisik there, and I

 2     immediately asked him why he hadn't attended the meeting that I had

 3     called the previous night for all commanders, and why he didn't come to

 4     the meeting at the special unit, because he was still the

 5     Deputy Commander of that unit.

 6             Mr. Stanisic reacted to that very angrily by saying that I was

 7     undermining the concept, the -- on which the parties had agreed about the

 8     splitting of the MUP and the splitting of the special unit.  My reaction

 9     was that if such a meeting had taken place, it would have been natural

10     for me to be informed about it.  The atmosphere was very tense.

11     Mr. Stanisic, even produced a pistol to shoot at me, and then I said,

12     Well, let's at least go down to the basement and not do in the office of

13     the Speaker of the Assembly.

14             Mr. Krajisnik was the only person there trying to calm down the

15     situation.  Dr. Karadzic, and especially the late Dr. Koljevic were

16     extremely aggressive with regard to my opposition of the concept of

17     ethnically-based parties.  He stated -- or, rather, repeated the type of

18     statements that he had uttered often, and I, again, offered my

19     resignation to Mr. Krajisnik as the Speaker of the assembly to

20     Mr. Pelivan who was the prime minister and Mr. Izetbegovic who was the

21     president of the Presidency, and that they should have accepted rather

22     than refused my resignation.

23             Mr. Karadzic commented that it was easier to replace Tito than me

24     and such nonsense.  The atmosphere was very tense.  And there were many

25     weapons there.  My driver and me only had light arms, our personal

Page 5829

 1     weapons, which was usual, side-arms, and Mr. Karadzic or Mr. Stanisic,

 2     I'm not sure, said that the Serb members of the special unit were

 3     unwilling to leave or take any instructions from anybody expect me.  I

 4     reacted by saying that I would resign if -- if I personally was a

 5     hindrance to the implementation of the policy of ethnically-based

 6     parties, which Mr. Krajisnik accepted.

 7             In the meantime, Mr. Simovic had left and brought this document

 8     which I signed, and I didn't even look what it said.  I wasn't

 9     interested.  It was very clear that it would be inevitable -- or, rather,

10     that our division or rift would be inevitable.

11             There was a -- an argument about my opposition to the splitting

12     of Bosnia-Herzegovina and the MUP and about my opinion that in case this

13     should happen, the consequences would be disastrous for

14     Bosnia-Herzegovina.

15             Mr. Krajisnik was calming the situation.  This went on for an

16     hour or two, and -- until they said to me that in the hallway there were

17     two or three -- I know Mr. Repja and Mr. Maric who were commanders in the

18     special unit of the police, and there is one more person whose name I

19     can't recall now, they were armed in full combat gear with hand grenades,

20     automatic rifles, pistols, knives, so there was a great likelihood that

21     conflict could break out among them three.  And in the office of

22     Mr. Krajisnik there were some armed persons wearing paramilitary

23     uniforms.  I asked Mr. Repja and Mr. Maric to sit down.  There was no

24     need to intervene, which Mr. Repja had wanted to do.  Probably from

25     preventing us from killing each other.  And then we went to the office

Page 5830

 1     across the floor from the -- from the one in which we were, and then I

 2     believe Mr. Stanisic, Dr. Karadzic, Dr. Koljevic, Mr. Krajisnik, were

 3     with me, and I can't remember who else still was.  I believe it was

 4     Momcilo Mandic and Karisik.

 5             At that moment, Repja issued an order - I would call it that.  He

 6     took his automatic weapon into his hands, and he ordered everybody else

 7     to leave because he wanted to speak to his supervisor.  And he said that

 8     he wouldn't listen to any -- anybody else's orders but to mine.  I stayed

 9     there with only the three of them in that room.  I explained that I had

10     resigned, that the situation was what it was, and that I actually had no

11     more authority or accountability now.  So I couldn't demand them do

12     anything, but I requested them to show understanding.

13             I had known many of them from earlier times, especially Repja, he

14     was a member of the same karate club as me.  And Maric was one of my

15     students, so they were totally loyal.  Some of them asked me later why I

16     hadn't told them to arrest or kill some of the people in Mr. Krajisnik's

17     office, but I never had that idea.  It was far for me to do that.  After

18     that, Repja went to the office next door and ordered Mr. Krajisnik,

19     Mr. Karadzic, and the others to return to the room in which I was.  Then

20     he produced his official ID.  He tore it up and said, This is the only

21     man I will obey.  And he left the room.

22             The atmosphere -- well, you can imagine what it was like.  I

23     requested to be -- requested them to let me go, to return to my family

24     because I had no more official position.  I was merely a citizen like

25     everybody else.  But then Mr. Krajisnik and the others again entreated me

Page 5831

 1     to give it a second thought and join them in -- in keeping up political

 2     functioning, but I replied, I took no interest in that.

 3             I left the building.  I sat in my car.  I am not sure what

 4     happened to my escort because there was just a driver waiting for me.

 5     The escort probably left with Repja.  My driver burst out in tears, and

 6     he said to -- that he had been ordered by Mr. Momcilo Mandic to kill me.

 7     Otherwise, they would kill my family.  My driver who had driven me for a

 8     long time told me, Minister, I cannot kill you.

 9        Q.   [Previous translation continues] ... thank you --

10        A.   I told him, Zoran, think of your family.

11             Anyway, we reached my apartment.  When I entered my apartment,

12     the special forces who were my body-guards, I informed them that they

13     were no longer obliged to mind me and that they could leave, but they

14     refused my request and said that they would stand by me and mind me as

15     long as they could.

16        Q.   Dr. Zepinic, just one thing I want to ask you about.  You say

17     Stanisic pulled out a gun and waved it at you, and you said, ready to go

18     down to the basement.

19             When he pulled out the gun, did he say anything as to why he was

20     waving the gun at you?

21        A.   I cannot faithfully reflect his words.  But he said that there

22     was no other way to have it out with me other than kill me, because I

23     opposed the concept embraced by the ethnic parties.  Other methods proved

24     unsuccessful, and the assassinations that were organised were also

25     unsuccessful.  And I would now once again like to thank all those who

Page 5832

 1     saved me.

 2             And Stanisic said, Well, we can't come to terms with this guy in

 3     other way, so let's kill him to prevent him from causing us any further

 4     headache.  But he may have -- he may be able to come up with another

 5     reason later.

 6        Q.   All right.  Now, you went home.  And when you -- after you -- you

 7     went home, did you -- were you in your apartment the following day.  And

 8     did you hear gun-shot from the direction of Vrace?

 9        A.   Yes.  Upon returning home, I didn't go to the MUP on the

10     following day.  And I stayed in my apartment, which is actually a little

11     studio in Lenin Street, number 52, on the tenth floor.  My family was

12     also there, all of them.  And around about 3.00 -- and let me mention

13     that the lads who were my security detail from the special unit.  I heard

14     over the radio that the attack on Vrace had started around about 3.00 on

15     the following day.

16        Q.   Over the police communication system, who did you hear in

17     connection with this attack?

18        A.   Listening to police radio communication, I recognised the voices

19     of Mr. Mandic; Mr. Stanisic; Mr. Mladjen Mandic, Momo Mandic's brother;

20     and the voice of Jusuf Pusina.  I believe that's all.

21        Q.   And what they doing, Mr. Mandic and Mr. Stanisic, in particular?

22     What were they saying?

23        A.   I can't remember now what the conversation was exactly like.  But

24     I remember well that Mladjen Mandic, Momo's brother, said come on, Momo,

25     let's get this over with, because there were students who were lying on

Page 5833

 1     the ground on a football pitch between the two sides, not to detail I

 2     remember, but I cannot paraphrase the conversation between Mr. Mandic and

 3     Mr. Stanisic or Mr. Pusina.

 4        Q.   All right.  Now, between then and 18th of July, did you remain in

 5     Sarajevo?

 6        A.   Yes.

 7        Q.   And on the --

 8        A.   With my entire family.

 9        Q.   Yes.  Did you decide that the only thing to do would be to leave

10     Bosnia, and, as a result, in August, did you go to the Canadian embassy?

11        A.   While I was in Sarajevo, I was under terrible pressure, and

12     thanks, first of all, to some colleagues and friends and thanks to those

13     who took my kids under their protection, we remained alive.  There were

14     several instances where I was interviewed, interrogated, questioned to

15     the effect that why I was still in Sarajevo and so on.  In a previous

16     interview, I said that if I was to be forced to leave Sarajevo, then I

17     would leave Bosnia and Yugoslavia as well because Sarajevo is in the

18     centre of my heart.  This is the best town in the world.

19             So --

20        Q.   I'm sorry.  I do apologise -- know this is -- [Overlapping

21     speakers] ...

22        A.   [Overlapping speakers] [in English] ... Okay, we're going back to

23     your question, sorry.

24        Q.   [Overlapping speakers]

25        A.   We have very short period of time.

Page 5834

 1        Q.   What happened to you when you were outside the Canadian embassy?

 2        A.   In front of the Canadian embassy, there were two cars in front of

 3     it.  Mr. Stanisic emerged from one of the cars.  He was the only person I

 4     recognised.  With some four or five fully armed individuals in combat

 5     fatigues.  And they forced me to enter one of the cars and to be driven

 6     with them.  I said to Mr. Stanisic that I had an appointment with the --

 7     Mr. Pavle Bulatovic - who was murdered, unfortunately.  He was a great

 8     friend of mine, and we shared some ideas of unity - because I had met

 9     Mr. Bulatovic on the previous day.  But Mr. Stanisic said, Just you come

10     along with us.  We have to apprehend you, and we will sort things out

11     with Mr. Bulatovic.  They tried to handcuff me.  I asked Mr. Stanisic not

12     to do so.  He accepted my request, so I was not handcuffed eventually.

13     They transferred me to another vehicle.  There were two escorts,

14     Mr. Stanisic and an escort in -- and a driver in one vehicle.  In the

15     other vehicle I was placed between two armed individuals who were holding

16     their side-arms at the ready, and there was another person in the

17     passenger seat in combat fatigues, and the driver was also armed and also

18     wearing combat fatigues.

19             I was taken to Vila Bosanska, where I encountered Dr. Koljevic

20     who was emerging from Vila Bosanska.  He uttered very nasty comments to

21     the effect, Oh, we finally caught you.  He demanded of Mr. Stanisic for

22     me to be urgently transferred to Pale to prison and he insisted with

23     Mr. Stanisic that I be handcuffed.  Mr. Stanisic refused that.  I would

24     like to thank Mr. Stanisic for that.

25             Later on, they bundled me into that car as well and then the two

Page 5835

 1     cars set out towards Pale.

 2        Q.   Stop for the moment.  Sorry to interrupt, but where is the

 3     Vila Bosanska?

 4        A.   [In English] Sorry, I should explain that.

 5             [Interpretation] Vila Bosanska is an edifice building -- well, in

 6     former Yugoslavia there were buildings which were residencies of

 7     Republican delegations whenever federal organs had sessions.  There was

 8     Slovenian villa, Bosnian villa, et cetera.  And this was used by the

 9     Bosnian delegation.  And when it's war broke out, the SDS took over that

10     building.

11        Q.   [Overlapping speakers]

12        A.   And that is the building in Belgrade.

13        Q.   Thank you.  So that the car that arrested you in Sarajevo took

14     you to Belgrade did it?  Mr. Stanisic.

15        A.   No, no, no, sorry.  A mistake.

16             [In English] I was arrested in Belgrade in front of Canadian

17     embassy.

18        Q.   Belgrade, right.  And the car that took you first to the

19     Vila Bosanska and then where to?

20        A.   [Interpretation] There were two vehicles.  In the front vehicle,

21     Mr. Stanisic, his escorts in that vehicle.  I was in the second vehicle.

22     After a brief stay at -- or in front of Vila Bosanska, we did not enter

23     the building.  We were in the parking lot.  But after Dr. Koljevic

24     emerged from that building, it was decided that they should transfer me

25     to Pale.  I cannot recall whether Dr. Koljevic mentioned Dr. Karadzic,

Page 5836

 1     but it was known to me that Dr. Karadzic supposedly wanted to see me

 2     there, so they bundled me into the same car and the same two armed

 3     individuals with an escort in the passengers seat and the driver, who was

 4     also armed, and we set out towards Pale from that point -- from that

 5     location.

 6        Q.   I want to, I'm afraid, cut this slightly short.  But in order to

 7     go to Pale you had to pass through, obviously, the Serbian border and

 8     check-points.  Did any -- was any attempt made to stop the vehicles?

 9        A.   No.  At no check-points, be it in Serbia or in

10     Bosnia-Herzegovina.  From Belgrade to the Bosnian-Serbian border, we

11     passed a number of check-points.  Obviously the number plates, or the car

12     of Mr. Stanisic were known to the personnel manning those check-points.

13     There were they were not checked.  We had no -- our IDs checked.  When we

14     crossed the border and entered Bosnia-Herzegovina, we were not stopped at

15     any check-points until we reached Pale, which means we were not stopped

16     at any check-points, and we were not controlled or searched at any of

17     them.

18        Q.   And to deal with your imprisonment were you, first of all, kept

19     in a villa in -- in Pale, in -- on Mount Jahorina?

20        A.   After reaching Pale, first, we briefly stayed at a facility

21     intended for the Ministry of Interior of Republika Srpska, where

22     Mr. Stanisic had offices.  I was offered a sandwich there.  After a brief

23     stay there, I was transferred to the Vucko facility, a facility that had

24     been built for the Sarajevo Olympics.  I was the only detainee in that

25     building.  There were 20 armed individuals for no apparent reason, or no

Page 5837

 1     reason apparent to me, who were allegedly guarding me.  I had terrible

 2     health problems at the time.  There were no other detainees in that

 3     building.  I was on my own.  Unfortunately, they did not have water

 4     supply nor electricity, but you know the conditions were as they were,

 5     and that facility is on Mount Jahorina, that is true.

 6             JUDGE HALL:  Ms. Korner, you have exceeded your extended time by

 7     more than 30 minutes.

 8             MS. KORNER:  I am aware of that, Your Honour, but it is really

 9     important.  I'm sorry.

10             JUDGE HALL:  How much longer do you --

11             MS. KORNER:  I just want to deal with two other matters, his

12     transfer from various prisons.

13             JUDGE HALL:  And how long do you expect that would take?

14             MS. KORNER:  Depends on the witness, rather, but I hope that we

15     can keep it quite short.

16             JUDGE HALL:  Because the adjournment time is 15 minutes away, and

17     there are two brief matters which the Court would like to address in the

18     last five minutes.

19             MS. KORNER:  Right.  Perhaps if I can lead on this, it may be

20     quicker.

21             JUDGE HALL:  Yes.

22             MS. KORNER:

23        Q.   Mr. Zepinic, I'm sorry you have had to be cut short on what was

24     obviously an appalling time for you.

25             But, first of all, can you look at a document, very quickly,

Page 5838

 1     which is an order putting you in custody.  I'm sorry I've lost the --

 2     1969, please.

 3             MS. KORNER:  Oh, yes, and could I tender the previous document

 4     whatever the number was, as an exhibit.  His resignation.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  Exhibit P912.

 7             MS. KORNER:

 8        Q.   This is apparently a decision of the 2nd of September, 1992, and

 9     can we see the bottom, please, in both documents.

10             It's got a signature.  Are you able to recognise the signature?

11        A.   I don't know whose signature this is.  I think that Mico Stanisic

12     is supposed to be cited here.  But who signed this and whether this is

13     his signature, I cannot say.

14             The decision on detention was handed over to me.  I said them,

15     How could you expect of me to appeal to a superior Court within in

16     24 hours in Sarajevo while I was being detained here in Pale.

17        Q.   Right.  And what I know --

18             JUDGE HALL:  Sorry, before we go on, I just note that the

19     transcript at line 1 on page 79 records me as saying, "Yes, chick,

20     chick."  I have no idea what that is supposed to mean.

21             Please proceed, Ms. Korner.

22             MS. KORNER:  Yes, thank you.

23        Q.   The reason given from your arrest is that you recruited citizens

24     of Serbian nationality to serve in military formations of the enemy.  Is

25     there any truth in that?

Page 5839

 1        A.   First of all, I don't know who the enemy was in this sentence.

 2        Q.   I think -- I think the idea is that you recruited people to fight

 3     in the Croat or the Muslim formations.  Is there any truth in that?

 4        A.   This accusation is the stupidest thing that could be attributed

 5     to me that I was mobilising people for any formation units of any ethnic

 6     background, and least of all for the purposes of the enemy.  I never saw

 7     members of any other ethnic group as enemies.  I've never categorised

 8     people on the basis of their ethnicity, religion, or the number of -- or

 9     the colour of their skin, neither will I do so any -- any time.  I, first

10     of all, refuse for this term "enemy" to be used in such communication.

11        Q.   Were you then transferred --

12             MS. KORNER:  Sorry.  May that be admitted and marked, please.

13             JUDGE HALL:  Admitted and marked.

14             THE REGISTRAR:  Exhibit P913.

15             MS. KORNER:

16        Q.   Were you transferred from this vila then to Lukavica prison -- to

17     Kula prison in Lukavica?

18        A.   Yes, after a couple of days of investigation and mistreatment in

19     the Vucko facility, I was transferred to prison of Lukavica -- Lukavica

20     civilian prison.  I spent some time there.  And after that I was

21     transferred to the army barracks at Lukavica.

22        Q.   And were you in fact in custody between September 1992 to late

23     November 1992?

24             MR. ZECEVIC:  I'm sorry, Your Honours, 80, line 23, I don't think

25     the witness says "army barracks."  I believe he said something different.

Page 5840

 1     So if my colleague can check that.

 2             MS. KORNER:  Yes, he did say that.

 3        Q.   Is that right, Dr. Zepinic?  First of all, you were in the

 4     civilian prison --

 5        A.   It was prison at Lukavica, and after that I was -- civilian,

 6     after that I was transferred to the military prison within the army

 7     barracks at Lukavica.

 8        Q.   Yes, thank you.  And eventually, effectively, did you escape?  I

 9     think you were allowed out and then made your escape.

10        A.   My escape from detention was, so to speak, aided on the part of

11     some individuals who were in the area.  Yes, I did escape with the help

12     of friends.  I did not organise the breakout.

13        Q.   Right.  And --

14             JUDGE DELVOIE:  Ms. Korner, due to the intervention of

15     Mr. Zecevic, the witness failed to answer the question about how long he

16     was detained from September to November.

17             Could he answer to that.

18             MS. KORNER:  Yes, I'm sorry.

19        Q.   Is that right - thank you, Your Honour.

20             Dr. Zepinic, I put the dates to you.  Is that about right,

21     Dr. Zepinic?

22        A.   Yes, I believe it was the end of November, beginning of December,

23     when I managed to escape from Lukavica.

24        Q.   Right.  The Court has been told of an occasion during the

25     assembly when Milan Trbovic suggested to the assembly that you had

Page 5841

 1     become, an assembly in November, the 23rd and 24th, that you became an

 2     officer of the military security.

 3             Did you ever become an officer in military security?

 4        A.   No.  I have never become an officer in military security, neither

 5     did I have any posts in the military.  I have heard such statements that

 6     I was a general, a colonel, you name it.  This was mere claptrap, on the

 7     part of Mr. Trbovic.  I don't know where he got that idea from.

 8        Q.   And finally, on the topic of your imprisonment and all together

 9     you made statements to the Serbian police during the course of your

10     incarceration.  How were you treated, if can you do that very briefly,

11     during this incarceration?

12        A.   If you allow me, I would like to say, and I would like to mention

13     the name of Tomo Puhalac whom I known and who was a member of the State

14     Security Service while I was in power who was quite fair and conducts

15     himself as per regulations.  As far as the conducts of other members,

16     well, their conduct should be the matter for their conscience, and I

17     don't want to go into that.

18        Q.   All right.  What I'm asking is whether when you made those

19     statements, you did so voluntarily and without any threats or

20     inducements.

21        A.   Probably none of us who were incarcerated was free of pressure or

22     threats.  I believe that Mr. Karadzic, while was in the military prison

23     in Lukavica, came and asked me where my family was.  During the

24     investigation my interrogators insisted on learning where the rest of my

25     family was.  On this occasion, can I thank my mentor, friend, and

Page 5842

 1     Professor Sternic of the -- professor of a medical faculty in Sarajevo

 2     who -- in Belgrade who protected my family and hid them away from those

 3     who wanted to detect their whereabouts.

 4             I must emphasise that other people had it worse during

 5     incarceration than I had.  But the only person who was professional in

 6     his conducts with Mr. Tomo Puhalac, and he was the only one.

 7        Q.   Thank you very much, Dr. Zepinic.  That's all I ask.

 8             JUDGE HALL:  Dr. Zepinic, the next thing to happen would be your

 9     cross-examination by counsel in turn for each of the accused.  That will

10     not happen today.  As I indicated, you -- your testimony will continue on

11     Monday, and I will -- something I failed to do yesterday which I will do

12     now, and that is to caution you that having been sworn as a witness you

13     cannot have any contact with the lawyers from either side.  And in such

14     conversations as you may have with persons outside of the courtroom, you

15     cannot discuss your testimony.

16             So the Court will not rise immediately, because it has certain

17     procedural matters with which to deal.  But you are now excused as a

18     witness, to return to this courtroom -- sorry, where are we on Monday?

19                           [Trial Chamber and legal officer confer]

20             JUDGE HALL:  To return -- you will be escorted to Courtroom I for

21     9.00 on Monday morning.

22             So we trust that you have a safe weekend.  And you are now

23     excused.  The usher will escort you from the courtroom.

24             THE WITNESS:  Thank you, Your Honour.

25                           [The witness stands down]

Page 5843

 1             JUDGE HALL:  The Chamber will now give an oral ruling in respect

 2     of a matter which the written reasons and the full decision will follow

 3     shortly.

 4             The Trial Chamber will now rule on the Prosecution's motion to

 5     amend the mode of testimony of Witness ST-140, ST-150 and ST-176, and to

 6     re-instate Witness ST-74 filed on the 10th of December, 2009, in so far

 7     as it concerns Witness ST-150.  Since the witness is scheduled to testify

 8     on Tuesday the 2nd of February, in its motion the Prosecution request

 9     that witness ST-150 be permitted to testify pursuant to the provision of

10     Rule 92 ter instead of viva voce.  The Chamber is not satisfied that this

11     request is in the interests of justice and, therefore, denies the motion

12     in this respect requiring that witness, ST-150 testify viva voce.

13             The Prosecution may use up to three hours to conduct its

14     examination-in-chief.

15             As I said the full written reasons will follow in respect of the

16     motion of which the Chamber remains seized.

17             The other matter is that yesterday the Chamber raised with

18     counsel for the Prosecution the prospect of suspending or reserving a

19     period in order to deal with the outstanding matter of adjudicated facts.

20     The Chamber, considering the -- what Ms. Korner had to say yesterday

21     about her schedule of witnesses for the week of the 8th of February,

22     nevertheless, has determined that it is during the week of the 8th of

23     February that it will suspend the hearings in Court so that they it can

24     dispose of this matter.

25             So counsel would therefore make the -- consequential arrangements

Page 5844

 1     accordingly.

 2             MS. KORNER:  Your Honour, I understand that.  It may cause

 3     difficulties, but for the moment I will say nothing else.

 4             Is it Your Honours intention also to deal finally with the other

 5     motions as well in this week?  Can I just ask that?  Because we have been

 6     told repeatedly that it will be dealt with.  And we are in the process of

 7     filing further motions.

 8             JUDGE HALL:  Well, the Chamber, of course, is not unmindful of

 9     the outstanding motions.  So the answer -- the only answer that I could

10     sensibly make to your question is that it is intended that priority is

11     given to disposing of these adjudicated facts because -- the motion in

12     respect of adjudicated facts, because clearly a number of other matters

13     are contingent upon the decision in that respect, and the other motions

14     will, of course, be dealt with accordingly.

15             So we take the adjournment, to resume, as I said in this --

16     sorry, in Courtroom I, at 9.00, on Monday morning.  And I wish everyone a

17     safe weekend.  Thank you.

18                            --- Whereupon the hearing adjourned at 1.46 p.m.,

19                           to be reconvened on Monday, the 1st day of

20                           February, 2010, at 9.00 a.m.