Tribunal Criminal Tribunal for the Former Yugoslavia

Page 7397

 1                           Wednesday, 10 March 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.08 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:  Thank you, Madam Registrar.

 9             Good morning to everyone.  May we have today's appearances,

10     please.

11             MR. OLMSTED:  Good morning, Your Honours.  It's Matthew Olmsted

12     and Crispian Smith for the Prosecution.

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

14     Slobodan Cvijetic, and Eugene O'Sullivan appearing for Stanisic Defence

15     this morning.  Thank you.

16             MR. PANTELIC:  Good morning, Your Honours.  For Zupljanin Defence

17     this morning, appearing Igor Pantelic and Miroslav Cuskic.  Thank you.

18             JUDGE HALL:  Thank you.

19             Mr. Olmsted, I gather that there are some matters that we need

20     to -- to which we need to turn our minds before the witness -- first

21     witness comes in?

22             MR. OLMSTED:  Yes, Your Honour, sorry.

23             The first is an oral application to add some documents to the 65

24     ter exhibit list.  As Your Honours are probably now informed, we received

25     some documents just yesterday that is -- that are relevant to the next

Page 7398

 1     witness.

 2             We interviewed the next witness approximately a year ago, and he

 3     turned over a number of documents in his personal collection at that time

 4     that were relevant to this case, and we produced those to the Defence and

 5     we will be showing a number of those to the witness today.

 6             It was a two-day interview and after the first day we said, Go

 7     home, if you find any other documents please turn those over to us as

 8     well.  The second interview went and he did not produce any additional

 9     documents.  However, yesterday afternoon during proofing he turned over

10     seven pages of documents that we've deemed as relevant to our case and

11     that we would like on our 65 ter exhibit list.

12             I believe this is a scenario that we've discussed before where a

13     witness produces documents during a proofing session.  This is probably a

14     quintessential situation where the party calling that witness has good

15     cause to seek to amend their 65 ter exhibit list so long as they can show

16     that the documents are relevant and that there is undo prejudice to the

17     other side.

18             I don't know if Your Honours have had a chance to look at the

19     documents, but our position is they are relevant because -- well, they

20     are relevant to our JCE charges as they show co-ordination and

21     co-operation between various components witness the municipality, the

22     Territorial Defence, the police, the Crisis Staffs, the militaries.

23             This is, of course, the best witness to testify about them

24     because he produced them, he can authentic them, also given his position

25     back in 1992 he is a good witness to talk about them.

Page 7399

 1             With regard to prejudice, we don't believe that the Defence will

 2     be prejudice by adding these documents to the 65 ter exhibit at this

 3     time.  The documents more or less corroborates the -- or the evidence

 4     that this witness provided during his interview.  We don't think they go

 5     beyond the scope of his interview, and therefore they really don't

 6     constitute any surprise for the Defence.

 7             I've spoken to the Defence and they -- so if I understand it,

 8     their position is they, of course, object in principle to addition of

 9     documents at this stage but since the remedy typically in these in

10     instances is additional time, as I understand it, they would be okay if

11     they could begin their cross-examination, at least as to these documents,

12     on Friday.

13             We do not have another witness this week other than this witness

14     and this is due to the fact that the last two witnesses went a lot faster

15     than predicted, and the next witness after this one is under subpoena so

16     we can't bring him forward, and we've definitely scrambled to try to find

17     another witness to come this week but we have just been unable to do it

18     on such a short time-frame.  And so I think we do have the time, if

19     necessary, to give the Defence additional opportunity to review the

20     documents and to cross-examine this witness on them.

21             JUDGE HALL:  Have the documents been translated?

22             MR. OLMSTED:  Yes, they have all been translated.  Last afternoon

23     we produced translation -- a partial translation, and then I sent an

24     e-mail out I think around 6.30, 7.00 p.m. for the remaining documents, so

25     they've all been translated and I believe the Case Manager will have them

Page 7400

 1     loaded in e-court within the next few minutes.

 2             JUDGE HALL:  Before I hear from Defence counsel, when do you

 3     anticipate -- you -- you mentioned that they've raised the possibility of

 4     deferring their cross-examination until Friday.  When did you anticipate

 5     completing your examination-in-chief?

 6             MR. OLMSTED:  Well, Your Honours, we've asked for four hours with

 7     this witness.  There is a number of documents, and we're going to

 8     definitely seek to complete it within that time.  There are a lot of

 9     documents.

10             JUDGE HALL:  Yes, could we hear from the Defence on this

11     application?

12             MR. ZECEVIC:  Your Honours, we don't have a LiveNote.  None of

13     the computer is on our side.  I don't know what is the situation ...

14                           [Trial Chamber and Registrar confer]

15             JUDGE HALL:  It is in the process of being corrected, I am given

16     to understand, Mr. Zecevic.

17             MR. ZECEVIC:  Okay.

18             Your Honours, we do object, of course, on such a short notice

19     that ten documents be introduced.  But we understand the situation as

20     Mr. Olmsted explained to us.

21             Now, we believe the guide-lines say that it has be a written

22     motion.  That is number one.  The second thing is Mr. Olmsted is now

23     offering some translations.  Is it -- is it an official translation or is

24     it a draft translation by the OTP?  Because I believe we -- we discussed

25     this sometime ago, that only the CLSS translation should be accepted

Page 7401

 1     as -- as a translation that can be admitted into the -- into the case as

 2     an exhibit.

 3             That's the second thing.

 4             And the third thing, yes, we -- we discussed this with the

 5     witness -- Mr. Olmsted, and if we would be given some additional time for

 6     preparation for our cross we would be able to -- to start our cross on --

 7     on Friday.  I mean, based on these -- these documents.  That was the gist

 8     of -- of our conversation that we had with Mr. Olmsted.

 9             JUDGE HALL:  Before I call on Mr. Pantelic, please tell me if I

10     summarise your position correctly.

11             Your objection is as a matter of principle; but, substantively,

12     having regard to the practical circumstances in which these documents

13     came to the knowledge of the Prosecution, you raise no substantive

14     objection, save that you be given adequate time to able to deal with,

15     which, as present estimates indicate, you should be in a position to do

16     by Friday.

17             MR. ZECEVIC:  That is correct, Your Honour.

18             JUDGE HALL:  Thank you, Mr. Zecevic.

19             Yes, Mr. Pantelic.

20             MR. PANTELIC:  Your Honour, this witness is not related to our

21     client, so we actually -- as a matter of principle just support Stanisic

22     Defence.

23             JUDGE HALL:  Thank you.

24                           [Trial Chamber confers]

25             JUDGE HALL:  Thank you.

Page 7402

 1             Having regard to the position taken by the Defence and bearing in

 2     mind that the guide-lines are guide-lines and not a straight jacket.  In

 3     other words, they are intended to facilitate and not frustrate the

 4     progress of a trial, in the circumstances, having regard, especially to

 5     the recency of the knowledge of the Prosecution in this regard, we accede

 6     to the application that they be added to the 65 ter -- -- the Prosecution

 7     may add these documents to the 65 ter list.

 8             And the -- Mr. Zecevic, is it necessary for us to rule now on

 9     your application for an adjournment or can that be deferred until you

10     begin your cross-examination?

11             MR. ZECEVIC:  Well, I'm -- I'm -- whatever pleases the Court.  We

12     are fine, even it is deferred before we start our cross-examination.

13             But, Your Honours, there is one thing, we need the LiveNote once

14     the witness comes in, because that is what we are -- we are marking it

15     for, for the purposes of cross-examination.  And we still don't have it.

16             Thank you.

17                           [Trial Chamber and Registrar confer]

18             JUDGE HALL:  Did I understand there was another preliminary

19     matter that ...

20             MR. OLMSTED:  Yes, Your Honour.  And we'd have to go into private

21     session to discuss that.  It's with regard to protective measures.

22             JUDGE HALL:  [Microphone not activated] Sorry.  We are

23     considering a brief adjournment so that the technical correction could be

24     made to bring up the LiveNote.  Could we deal with this new matter or

25     should this also wait until we have LiveNote?  I think we can proceed,

Page 7403

 1     but ...

 2             MR. OLMSTED:  I think we can, because what the Defence is saying

 3     is they need the LiveNote during his substantive testimony.  This is

 4     dealing with a preliminary matter I doubt they're going to cross-examine

 5     him on.

 6             JUDGE HALL:  We have been alerted, though, I suspect that before

 7     we rule on this matter, we may have to hear from the witness.  Because

 8     it's a new application.

 9             MR. OLMSTED:  Yes, Your Honour, and we informed the witness of

10     that fact.  And he's coming ready to present his situation.

11                           [Trial Chamber confers]

12             JUDGE HALL:  Yes, Mr. Olmsted.

13             MR. OLMSTED:  I'm sorry that was the second matter that I wanted

14     to raise prior to this witness's testimony was that there was a

15     protective measures matter for this witness, that we should go to private

16     session to discuss it further.

17             JUDGE HALL:  [Microphone not activated]

18                           [Private session]

19   (redacted)

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Page 7404

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25                           [Closed session]

Page 7405











11 Pages 7405-7410 redacted. Closed session.















Page 7411

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 9                           [Open session]

10             THE REGISTRAR:  We're in open session, Your Honours.

11             MR. OLMSTED:

12        Q.   Sir, is it correct that you were interviewed by the ICTY Office

13     of the Prosecutor in March of last year?

14        A.   It's correct that we had an interview in March last year.

15        Q.   And prior to that interview, were you advised of your rights to

16     have counsel present?

17        A.   Yes.  The complete procedure has been made clear to me before the

18     interview.

19      Q.   And if I understand correctly, you agreed to be interviewed without

20     counsel back -- last year.

21        A.   Yes, precisely.

22        Q.   And at the conclusion of that interview, were you satisfied with

23     how the interview was conducted?

24        A.   Yes.  I was satisfied.  Everything was fair.

25        Q.   I would like to ask you some questions about your professional

Page 7412

 1     background with the police.

 2             Did you begin working for the MUP or, at the time it was known as

 3     the SUP, in Bosnia in November of 1986?

 4        A.   That's correct.  In November 1986, I started working in what was

 5     then the Secretariat of Internal Affairs of Bosnia-Herzegovina.

 6        Q.   And what was the first position you held with the SUP?

 7        A.   My first job was fire inspector, republican fire inspector.

 8             JUDGE HARHOFF:  Mr. Olmsted, before we venture too far into the

 9     curriculum vitae of this witness, I wonder if you want to go into private

10     session for this?

11             MR. OLMSTED:  Perhaps we should, Your Honours.  That's a very

12     good suggestion.

13             JUDGE HALL:  [Microphone not activated]

14                           [Private session]

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Page 7413











11 Page 7413 redacted. Private session.















Page 7414

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24                           [Open session]

25             THE REGISTRAR:  We're in open session, Your Honours.

Page 7415

 1             MR. OLMSTED:  Should I continue for the next few minutes, or

 2     should we take our break now?

 3             JUDGE HALL:  Could you make practical use of the next three

 4     minutes [Microphone not activated] or -- yes, are you about to begin a

 5     line of questioning?

 6             THE INTERPRETER:  Microphone, please.

 7             JUDGE HALL:  I was asking whether you could make practical use of

 8     the next three minutes, or are you about to embark on a line of questions

 9     which you prefer not to interrupt.

10             MR. OLMSTED:  Let me give it a shot, Your Honours.

11        Q.   Prior to the conflict in Vlasenica, was Vlasenica municipality a

12     multi-ethnic municipality?

13        A.   Yes.

14        Q.   Could you tell us approximately what percentage of the population

15     in the municipality was Bosniak?

16        A.   I don't know, but it was perhaps in a 50/50 ratio.  In the urban

17     centre of Vlasenica, it could have been up to 58 per cent.

18        Q.   And when you say "58 per cent," 58 per cent Bosniak?

19        A.   Yes.

20        Q.   And the other 50 per cent, would that be Croat or Serb?

21        A.   Mainly Serb.  Because, traditionally, in that area, there were

22     few Croats.  Not even 1 per cent.

23        Q.   Now, prior to the multi-party elections in 1990, were these

24     percentages that you just described for us reflected in the police force

25     at the SJB Vlasenica?

Page 7416

 1        A.   Yes.  Like in all other agencies, that ratio was respected,

 2     following the principle of equal ethnic representation, proportional

 3     ethnic representation.

 4        Q.   Could you tell us what happened after the multi-party elections

 5     with regard to the ethnic mix of the police force in Vlasenica?

 6        A.   After the multi-party elections, that principle of ethnic

 7     representation remained the same and the ratio remained the same until

 8     the 21st of April, which was the beginning, and we'll talk about that

 9     later.

10             But something else changed.  The leading positions in various

11     services from the station commander to the chief of the CID were no

12     longer appointed by the professional hierarchy but by political parties.

13     So a Serb was appointed chief; a Bosniak was appointed commander; chief

14     of the CID also Bosniak.  But that was according to the compromise and

15     agreement among the political parties, and even the minister probably

16     couldn't influence that.

17        Q.   Can I just clarify one thing you said.  I think you referred to

18     the appointment of the CID.  Would that be the SJB chief?

19        A.   The centre of public security, CJB that is correct's the acronym.

20        Q.   And just to clarify, these political appointments to these

21     positions within the police force, that they included the SJB chief as

22     well as the commanders at the SJBs?

23        A.   Yes.  It was a proposal from the political leadership, so through

24     the minister and the chief of the centre, these proposals were sent and

25     their approval was probably sought.  I don't know.

Page 7417

 1             MR. OLMSTED:  Your Honours, that's a good time for us to stop.

 2             JUDGE HALL:  So we will resume in 20 minutes.

 3                           [The witness stands down]

 4                           --- Recess taken at 10.27 a.m.

 5                           --- On resuming at 10.51 a.m.

 6                           [The witness takes the stand]

 7             MR. OLMSTED:  May I resume?

 8             JUDGE HALL:  Yes, Mr. Olmsted.

 9             MR. OLMSTED:

10        Q.   Sir, after the multi-party elections in 1990, who became the

11     chief of SJB Vlasenica?

12        A.   After the multi-party elections, the public security station in

13     Vlasenica was headed by Radomir Bjelanovic.

14        Q.   What was his ethnicity?

15        A.   Serb.

16        Q.   Who did he replace?

17        A.   It was Midhad Huremovic.

18        Q.   And what was the ethnicity of Midhad Huremovic?

19        A.   He was a Muslim, a Bosniak.

20        Q.   And who proposed Bjelanovic for the position of chief?

21        A.   I've already said that, in the negotiations among the parties, he

22     was put forth by the SDS, and this proposal was then forwarded to the

23     ministry.

24        Q.   What was Bjelanovic's experience in law enforcement, prior to his

25     appointment?

Page 7418

 1        A.   As far as I know, he did not work in the Ministry of the Interior

 2     anywhere.  He worked in the bauxite company.  He was the director of the

 3     work community, or something like that.  He was a mining engineer.  He

 4     worked in various positions in the mine.

 5        Q.   Prior to 1992, how would you describe the relations between the

 6     Muslims, the Serbs, and the Croats in Vlasenica?

 7        A.   Well, let us go back to the period from 1985 to the multi-party

 8     elections.

 9             We can say that their relations were good.  It functioned well in

10     Vlasenica, because, at that time, it was one of the better developed,

11     better organised municipalities.

12             After the multi-party elections, the situation got polarised,

13     just as it did everywhere else, and the relations deteriorated day by

14     day.

15        Q.   Were you aware of the creation of the Serb Autonomous Regions in

16     BiH in 1991?

17        A.   Well, officially, not.  But through various rumours and through

18     the media which did not cover that extensively, but I was able to garner

19     some knowledge but no specifics, really.

20        Q.   Do you know who created these SAOs?

21        A.   Well, the idea was launched by the SDS leadership.

22        Q.   And if you know, what was the purpose of these Serb Autonomous

23     Regions?

24        A.   Well, the purpose was to establish some kind of autonomy over a

25     certain area as its very name indicated.  And if we were to analyse this

Page 7419

 1     topic, although I haven't really prepared for that, those in Serb

 2     Autonomous Regions encompassed areas with a Serb majority.  But there

 3     were other ethnic communities present.  But the areas were those where

 4     Serbs were in the majority.

 5        Q.   Do you recall if Vlasenica was a part of a Serb Autonomous

 6     Region, back in 1991?

 7        A.   Well, an autonomous region, Birac, of Birac, was established at

 8     that time.  But I did not notice any impact of its creation.  But it did

 9     exist.

10        Q.   Do you recall who among the political leadership from Vlasenica

11     was associated with this Serb Autonomous Region of Birac?

12        A.   Well, let me tell you, given that I had worked in the Ministry of

13     the Interior for a long time, I can tell you that by 1989 it was already

14     prohibited that -- for us to be politically active.  We were supposed to

15     be professional, a professional service.  But as a citizen, as a private

16     citizen, I learned that Milenko Stanic, who was the president of the

17     municipality at the time, was involved in those activities.

18             So for as long as this SAO Birac continued to function, he was

19     the president of the government of that Autonomous Region of Birac.

20        Q.   After this SAO Birac was formed, what did the SDS form in

21     Vlasenica?

22        A.   After the SAO Birac was formed, I don't know the date when it

23     happened.  But no impact was felt of its creation.  Some strategic

24     decisions were made at the level of the party, but, on the ground, in the

25     institutions, everything continued to function just as it had before,

Page 7420

 1     with the application of the representation system that I've already

 2     explained.

 3             MR. OLMSTED:  Let's take a look at 65 ter 3103.

 4        Q.   Now, this document is entitled: "Decision to found Assembly of

 5     the Serbian people in the Municipality of Vlasenica."  And it's dated 24

 6     October 1991.

 7             Sir, do you recall that this was one of the documents that you

 8     provided to us, to the Prosecutor, during your interview last year?

 9        A.   Yes.

10             MR. OLMSTED:  If we can turn to page 2 of both of the B/C/S and

11     the English.  And if we look under Roman numeral VIII, it states that:

12             "The Serbian Vlasenica municipality shall remain part of the

13     autonomous region of Birac and shall also be the capital of the region."

14             Sir, do you know why Vlasenica was chosen as the capital of the

15     autonomous region?

16        A.   I couldn't really tell you why, but -- because of it -- its

17     geography, well, that's -- its location, and as I already mentioned,

18     Milenko Stanic, the president of the municipality who became the

19     president of the government of the SAO Birac, well, the seat was there,

20     so that was probably one of the reasons.

21             MR. OLMSTED:  May I tender this into evidence?

22             JUDGE HALL:  Admitted and marked.

23             THE REGISTRAR:  Exhibit P1055, Your Honours.

24             MR. OLMSTED:

25        Q.   At some point, did the SDS create a Serb Crisis Staff in

Page 7421

 1     Vlasenica?

 2        A.   Yes.  If you allow me, I was not active in the party.  These

 3     documents are the documents that I found and studied, and I consider them

 4     to be relevant.

 5        Q.   And since you brought them up, where did you find these

 6     documents?

 7        A.   I found some of those documents in the files kept by my

 8     predecessor, Radomir Bjelanovic.  I simply found them there.

 9        Q.   Did you --

10        A.   And obtained them in this manner.

11        Q.   Did you find them at the SJB Vlasenica?

12        A.   Yes.

13             MR. OLMSTED:  Let's take a look at 65 ter 2897.

14        Q.   Now this document is entitled: "Decision on the Establishment of

15     a Crisis Staff of the Serbian Municipality of Vlasenica and its

16     Responsibilities."

17             Is this another document that you provided us, that you found at

18     SJB Vlasenica?

19        A.   Yes, precisely.

20        Q.   In the first paragraph of this decision, it says:

21             "The decision was made following instructions from the Main Board

22     of BiH SDS regarding operations under conditions of imminent threat of

23     war."

24             Sir, do you know what those SDS Main Board instructions were?

25        A.   No, I don't.  I have never seen them, but I learnt about them

Page 7422

 1     from these documents, because they are mentioned here.

 2        Q.   Under Roman numeral II, it lists ten members of the Crisis Staff.

 3     Can you tell us what are the ethnicities of these persons?

 4        A.   Serb.

 5        Q.   We've already discussed Milenko Stanic.  Who was Bozo Milic?

 6        A.   Bozo Milic was a member of the party; and later on, he was

 7     appointed the president of the Executive Board of the Vlasenica

 8     municipality.

 9        Q.   Under number 9, it lists commander of the TO, which I understand

10     is the Territorial Defence, as a member of this Crisis Staff --

11        A.   Yes.

12        Q.   Who was that at the time?

13        A.   Under the old rules that governed the Territorial Defence, it was

14     Bosko Nastic.  And after the Crisis Staff was established, that post was

15     taken by Bozidar Stanimirovic.

16        Q.   And Stanimirovic was a Serb?

17        A.   Yes.

18        Q.   Under number 10, it lists the chief of the public security

19     station as a member of the Crisis Staff.  At the time of this decision,

20     who would have that been?

21        A.   Radomir Bjelanovic.

22        Q.   Can you tell us what authority did the SDS Crisis Staff have over

23     SJB Vlasenica?

24        A.   The Crisis Staff, as is indicated here, assumed the functions of

25     the Municipal Assembly and the explanation given was that given the

Page 7423

 1     circumstances the Municipal Assembly could no longer function, and this

 2     is why the Crisis Staff was established.

 3             In that period, the Crisis Staff at least tried to influence the

 4     operation of the Ministry of the Interior, or, rather, of the public

 5     security station.  In many situations, we who knew what the ministry

 6     actually is and what the chain of command should look like, and the

 7     minister himself insisted on that.  We tried to oppose in each and every

 8     one of those situations.  We always wanted to keep the MUP as a

 9     professional institution, as a professional service, but in some cases,

10     the influence was so strong that we couldn't resist the pressure that was

11     exerted on us.

12        Q.   Was there ever an occasion in 1992 when the SJB chief in

13     Vlasenica, and that includes yourself once you assumed that role, was

14     subordinated to the Crisis Staff?

15        A.   Not formally.  But they tried in every way they could to

16     influence the decision-making and the functioning, the organisation, the

17     personnel matters and so on.

18        Q.   When the Crisis Staff would attempt to influence your work as SJB

19     [realtime transcript read in error "Secretary-General"] chief or your

20     predecessor as SJB chief, would you report this problem up the chain of

21     command?

22        A.   I did that once I formally became the chief, so from August on.

23     I would always provide reports to my immediate superior, either in

24     writing or orally; that was the centre chief Zoran Cvijetic.  And I'm

25     sure that he, in turn, reported all that to the minister.

Page 7424

 1             There were situations where we would receive feedback as to

 2     how -- what position to take on certain matters and so on.

 3        Q.   And just -- I have been alerted to a correction on the record on

 4     line 25 of page 26, it says:

 5             "Was there ever an occasion in 1992 when the Secretary-General

 6     chief in Vlasenica, and that includes you."

 7             It's actually the SJB chief.

 8             Were you aware whether Bjelanovic attended the Crisis Staff

 9     meetings?

10        A.   Well, I can't confirm that with certainty, but I assume that that

11     was the case.

12        Q.   Who else from SJB Vlasenica would attend these Crisis Staff

13     meetings?

14        A.   For the most part, it was the chief.

15        Q.   And what about yourself?  Once you assumed the role of SJB chief,

16     did you attend at any of these meetings?

17        A.   Well, at that time, the Crisis Staff no longer existed.  It was

18     the War Commission, or the War Presidency that existed at the time.  The

19     situation was different.

20             I think that by mid-June the Crisis Staff was disbanded, possibly

21     by an order from higher up, and the War Commissions were established.

22             So, at the time when I could act on behalf of the station, it no

23     longer existed.

24             JUDGE HARHOFF:  Mr. Olmsted, we have been through this issue

25     before.  But I would like to hear the witness's opinion about why the

Page 7425

 1     Crisis Staffs were demolished or abolished and replaced by the War

 2     Commissions.

 3             THE WITNESS: [Interpretation] Well, I probably can't give you a

 4     relevant answer, but I can give you my opinion.

 5             Since things were developing very quickly, the war broke out and

 6     so on, the leadership at the level of the Republic of Bosnia-Herzegovina

 7     or, rather, the Serbian Republic of Bosnia and Herzegovina as it was at

 8     the time, decided as a strategic decision to disband the Crisis Staffs in

 9     order to create a chain of command that would enable it control the whole

10     area and to eliminate the arbitrary decisions or willfulness on the part

11     of the Crisis Staffs in various municipalities, because they strove to

12     become as independent as they could of the legal structure that was in

13     the offing, that was being built in Republika Srpska.  That's how I see

14     it.

15             And, well, I did have a document somewhere but sometime in

16     June the President of the republic decided that municipal commissions be

17     established in order to create this system of subordination.  So that's

18     my assumption.

19             JUDGE HARHOFF:  You -- you are probably correct in your

20     assumption.  But could you explain to us just how the strings of command

21     and control were strengthened in the War Commissions, compared to the

22     previous situations when the Crisis Staffs were having power?

23             Just how did the War Commissions become stronger and more

24     disciplined under the MUP's control?

25             THE WITNESS: [Interpretation] Well, just one detail in all that.

Page 7426

 1     The Presidency of the Serbian Republic appointed people to each

 2     municipality, or region.  People whose task it was was to establish the

 3     commissions set to replace the Crisis Staffs, and they reported directly

 4     to the Presidency of the republic.  To be more specific, in the region

 5     where we were, in Birac, there was this man Djokanovic.  He was the

 6     commissioner.  There was another man in charge of another region and so

 7     on, but I know about Djokanovic.  I don't know his first name.

 8             So he headed the commission.  And the other members were from the

 9     local structures, from the municipality.  And that's how they functioned.

10             JUDGE HARHOFF:  Thank you, sir.

11             Back to you.

12             MR. OLMSTED:  May we tender this document in front of us into

13     evidence.

14             JUDGE HALL:  Admitted and marked.

15             THE REGISTRAR:  This will be Exhibit P1056, Your Honours.

16             MR. OLMSTED:

17        Q.   Sir, did there come a time when you stopped travelling to Tuzla

18     for your work?

19        A.   Yes.

20        Q.   And -- when -- when was that?

21        A.   Given the developments in Bosnia and Herzegovina, sometime in

22     April or March, some groups, paragroups, were established, check-points

23     were set up.  And then, on the 21st of April, in Vlasenica, when the

24     conflict broke out, I stopped travelling to Tuzla, because I had to go

25     there on Monday and on Friday, and, if needed, even more often.  I had to

Page 7427

 1     go to the headquarters of our service where we would agree what to do, in

 2     terms of fire protection.

 3             But for as long as telephone lines were up, I was able to keep in

 4     contact with Nedim Kurbasic, my boss at the time.  I would call him from

 5     time to time and he told me it's dangerous to travel.  If there's no need

 6     for you to travel, don't go, we'll keep in touch by phone.  It functioned

 7     like that until early May when the telephone lines were disrupted.  After

 8     that, could I no longer communicate with him.  But given the

 9     circumstances and the nature of our job, which was fire protection and

10     explosive protection, there was no need for us to do that job anymore, so

11     I no longer travelled after the end of April.

12        Q.   At some point did the Serb Crisis Staff take over power in

13     Vlasenica?

14        A.   Yes.

15        Q.   Before we begin discussing the takeover itself, I would like to

16     discuss the three weeks in April leading up to the takeover.

17             First, during this pre-takeover period, were there any changes in

18     the composition of the police force at Vlasenica SJB?

19        A.   You mean before the 21st of April?

20        Q.   That's correct.

21        A.   Well, if we look at the ethnic composition, no.  There were no

22     changes.  The only difference was the admission of an increased number of

23     reserve police officers, who were admitted in accordance with the

24     representation system that was in place.  Serbs, Bosniaks, there were

25     very few Croats there.  So maybe one or two Croats.

Page 7428

 1             But, I, as a person who had an office there merely and actually

 2     did something else, I could discern that the relationship had changed and

 3     that groups were being established.  There was a group of people who was

 4     close to the commander, Fadil Hadzic, and there was another group that

 5     was closer to the station chief, Bjelanovic, who was a Serb.  So you

 6     could see how situation was becoming polarised.

 7        Q.   Could you describe for us what the security situation was like in

 8     Vlasenica during this pre-conflict time-period, the three weeks leading

 9     up to the 21 April takeover.

10        A.   The takeover was long expected.  Nobody knew when it would take

11     place, but people were talking about it, because it was obvious that

12     something was in the offing there.

13             But in terms of security, the situation was not bad.  There were

14     no security risks, but you could feel it in the air that something was

15     brewing.  We, as the Ministry of Interior - we, the police, if I could

16     call us that - we who tried to do our job as professionals in the name of

17     the people, it was actually the most difficult for us to find out what

18     would happen, because nobody trusted us because the SDA people and the

19     SDS people did not trust us.

20             So we did get some information, but we tried to create an

21     atmosphere, a climate, we set up joint patrols, I took part there them.

22     We would patrol the town at night in order to reassure the people as much

23     as we could.  We would patrol by car through all the neighbourhoods and

24     streets, but there was nobody around.  People hunkered down in their

25     homes.  They were just sitting there and waiting for something to happen.

Page 7429

 1        Q.   Thank you, and I'll just remind you to try to keep your answers

 2     short, and I can always ask you some follow-up questions.

 3        A.   Yes, very well.

 4        Q.   So prior to the conflict, prior to 21 April, if I understand you

 5     correctly there was no armed resistance by either the Muslims or the

 6     Serbs in Vlasenica?

 7        A.   Yes.  No, there wasn't.

 8        Q.   What, if anything, did you hear during this time-period -- or,

 9     actually, any time prior to the conflicts, about the arming of Serbs,

10     local Serbs?

11        A.   Yes.  This arming did occur, both among Serbs and Bosniaks.  But

12     they were rather discreet about it, and it was difficult for us to get

13     any information.  And even our joint patrols failed to catch them at it.

14     But we knew it was going on.

15        Q.   Based on the information that you did have, who was actually

16     arming the Serb population?

17        A.   The weapons were mainly from the former JNA.  That was the source

18     of arming.

19        Q.   During your interview, you mentioned the SDS was participating in

20     the arming.  Was that the case or -- or not?

21        A.   Precisely.  The SDS, in concord with the JNA, supplied quantities

22     of weapons.

23        Q.   During this pre-21 April time-period, were you aware that the RS

24     MUP had been established?

25        A.   Yes.  But I and the public security station did not operate

Page 7430

 1     according to this new scheme, but we knew that the new MUP of the Serbian

 2     Republic of Bosnia and Herzegovina had been established.

 3             MR. OLMSTED:  Let's take a look at 65 ter 2898.

 4        Q.   Now, this is a Crisis Staff decision, entitled: "Decision on an

 5     Imminent Threat of war," from 19 April 1992.

 6             Is this another document that you provided during your last

 7     interview?

 8        A.   Yes, yes.

 9        Q.   According to this decision, an imminent threat of war was

10     declared and if -- the first reason was:  "... as a result of disrupted

11     interethnic relations."

12             Can you tell us what that was referring to?

13        A.   Here you can see the primary motivation for this decision.  Seven

14     or ten days before the 21st of April, all the leading representatives of

15     the Bosniak people headed by the then-President of the SDA, left

16     Vlasenica.  That was on the one hand.

17             On the other hand, they availed themselves of this opportunity to

18     proclaim this imminent threat of war because the Assembly was no longer

19     able to operate without a significant number of MPs, and that's why this

20     decision was taken.

21        Q.   It provides as another reason that there were outside threats.

22             What outside threat was the municipality facing on 19 April?

23        A.   Well, I don't know specifically what you mean, but in our broader

24     region, Vlasenica is bordered by Kladanj, Zvenice [phoen], Zepa,

25     Srebrenica, and information came through that units were being organised

Page 7431

 1     there as well.  I don't know what else it could be.

 2        Q.   It also gives as a reason for this decision, mass migration of

 3     the population from the municipality.

 4             Members of which ethnic group were leaving en masse from the

 5     municipality?

 6        A.   In that period, let's say from the 4th of April until the 21st

 7     April when this happened, both Bosniaks and Serbs left the municipality

 8     en masse.  Bosniaks were going towards Tuzla, Sarajevo, Kladanj; whereas,

 9     Serbs mainly took their families away left them somewhere there Serbia.

10     That -- that's the kind of migration that was going on.

11        Q.   And why were they leaving the municipality?

12        A.   It must have been the uncertainty and the potential danger to

13     families.  Because based on the existing experience and estimates from

14     Slovenia and Croatia, it was felt that something could happen to us as

15     well, and families were placed somewhere where it was safer, in Serbia

16     for Serbs, or in Tuzla and Sarajevo for Bosniaks.  That made people feel

17     safe.

18             MR. OLMSTED:  May we tender this into evidence.

19             JUDGE HALL:  Admitted and marked.

20             JUDGE HARHOFF:  Mr. Olmsted, before we leave this document, I'd

21     just like to elicit from the witness some information on the background

22     for this, because the document leaves the impression that the declaration

23     of an imminent threat of war was left to some very local institutions.

24             And so my question is:  Was there a similar declaration of an

25     imminent threat of war coming from above, from the government, that would

Page 7432

 1     enable each of the local authorities to declare, on their own, whether or

 2     not they thought that there was now an imminent threat of war in their

 3     little region.

 4             THE WITNESS: [Interpretation] I suppose, because I was not one of

 5     the main players.  But I suppose it was done in coordination with the

 6     highest leadership of the SDS, for instance, or at their suggestion, or

 7     based on their evaluations.  That's how these decisions must have been

 8     made.

 9             JUDGE HARHOFF:  Thank you.

10             MR. OLMSTED:

11        Q.   Just to follow up on that question.  At the ...

12                           [Trial Chamber and Registrar confer]

13             MR. OLMSTED:

14        Q.   At the top of the document it says that this discussion was

15     made --

16             JUDGE HARHOFF:  Mr. Olmsted --

17             MR. OLMSTED:  I'm sorry.

18             JUDGE HARHOFF:  I just need to give the floor to the registrar to

19     assign a number.

20             THE REGISTRAR:  So 65 ter 2898 becomes Exhibit P1057, Your

21     Honours.

22             MR. OLMSTED:

23        Q.   And just -- if we can keep this document up on the screen, it

24     says in the first paragraph of the document that this decision was made

25     pursuant to a decision of the National Security Council of the Assembly

Page 7433

 1     of the Serbian Republic of Bosnia and Herzegovina.

 2             Did you know what this National Security Council was?

 3        A.   I knew that these organs existed but I was not particularly

 4     knowledgeable about their competencies and activities.  Because we're

 5     still talking about a period up to the 21st of April, wherein my

 6     immediate environment at the station nothing much changed within the

 7     organisation and the municipality still functioned the same way.  The

 8     president of the Executive Board, the Bosniak, was still there.  So all

 9     these structures operated as before, although something was simmering

10     already.

11             MR. ZECEVIC:  I'm sorry, Your Honours, for interruption.  But I

12     believe we have a problem with the translation of this document.

13             The translation which is provided is not accurate, because the

14     original says:  Based on the decision of the Assembly, then, comma, the

15     national -- the National Security Council, then, again, comma, the Crisis

16     Staff takes -- of Vlasenica takes this decision.

17             Which, according to me, means that there is, first, the decision

18     of the Assembly, and then, after that, the decision of the Nationality

19     Security Council.

20             And, therefore, the -- the translation is not -- is not correct.

21     Because it doesn't -- it says National Security Council of the Assembly,

22     such a body didn't exist in Republika Srpska at the time.

23             JUDGE HARHOFF:  So, Mr. Zecevic, what am I to make of this?  Was

24     the decision --

25             MR. ZECEVIC:  Well, it's very --

Page 7434

 1             JUDGE HARHOFF:  -- taken in Vlasenica taken in accordance with a

 2     decision taken from a higher level?

 3             MR. ZECEVIC:  Your Honours, I'm not -- I'm not -- I don't want

 4     to -- to mix into the testimony of the witness.  Witness will tell us if

 5     he knows or doesn't know.  I'm just referring to the translation of the

 6     document.

 7             It appears to me from this document that is there a decision of

 8     the Assembly of Republika Srpska.  Then, after that, the executive body

 9     of the Assembly which is the National Security Council, and -- and the

10     Crisis Staff.  Because that is what they referred to in the -- in the

11     preamble of this document.

12             If it's right or wrong, I cannot confirm at this point.

13             Thank you very much.

14             JUDGE HARHOFF:  Thank you, Mr. Zecevic.  I just wasn't sure about

15     which assembly you were referring to.  But now I understand.  Thank you

16     very much.

17             JUDGE HALL:  So should the witness be referred to the original in

18     B/C/S and asked to read into the record what it says and see what the

19     interpreters make of it?

20             MR. OLMSTED:  That sounds reasonable.

21        Q.   Sir, could you read the first paragraph of this document that's

22     in front of you, for the record.

23        A.   "Pursuant to a decision of the Assembly of the Serbian Republic

24     of Bosnia-Herzegovina, the Nationality Security Council, the Crisis Staff

25     of the Vlasenica municipality, at its session held on 19 April 1992,

Page 7435

 1     adopts the following decision."

 2             MR. ZECEVIC:  I'm really sorry.  It -- it doesn't -- the witness

 3     didn't say "its National Security Council."  Oh, I'm sorry.  I'm sorry.

 4     It has been changed.

 5             MR. OLMSTED:  May I proceed?  We've addressed this issue.

 6             JUDGE HALL:  [Microphone not activated].

 7             MR. OLMSTED:  Very good.

 8             MR. PANTELIC:  I do apologise.  I stand corrected, but what we

 9     have here, it's page 38, line 4 -- actually, 5, it says the "nationality

10     Security Council d of the municipality Crisis Staff."  I'm lost.  I'm

11     lost.

12             So my suggestion would be to ask from our learned friends from

13     the interpretation unit to clarify preamble of B/C/S and English version.

14     I don't want to suggest, but, I mean, I -- I -- I'm fully supporting

15     Mr. Zecevic submission.

16             It's very simple.  In English version it should be:

17             "Pursuant to a decision of the Assembly of Serbian republic

18     Bosnia and Herzegovina, national security" --

19             JUDGE HALL:  Mr. Pantelic, rather than your volunteering to

20     assist in the translation and interpretation of this, the -- the prudent

21     course would be to invoke the established procedure for correcting this.

22             MR. PANTELIC:  Yes, thank you, Your Honour.  Thank you.

23             JUDGE HALL:  Thank you.

24             Yes, Mr. Olmsted.

25             MR. OLMSTED:  Thank you, Your Honour.

Page 7436

 1        Q.   Let's take a look at another document, 65 ter 2900.

 2             Now what we have before us is another Crisis Staff decision

 3     entitled: "Decision to Take Over Power in the Area of the Municipality of

 4     Vlasenica," and also from 19 April 1992.

 5             Sir, was this another document you provided during your last

 6     interview?

 7        A.   Yes.

 8        Q.   Under Roman numeral II of this decision, it provides that the

 9     reason for establishing a Serbian Assembly was that the Joint Assembly

10     could not have functioned because the assemblymen and officials of Muslim

11     ethnicity are leaving.

12             I think you touched on this previously.  But what was the Joint

13     Assembly?

14        A.   From this document, we see the reason why they decided to take

15     this decision.

16        Q.   Yes.  My question to you is:  This Joint Assembly, could you

17     explain to us what that was?

18        A.   The Joint Assembly was an assembly where, according to the

19     electoral results from 1991, MPs were represented, both Serbs and

20     Bosniaks.

21             MR. OLMSTED:  May we tender that into evidence.

22             JUDGE HALL:  Yes, admitted and marked.

23             MR. OLMSTED:  May we look at -- I'm sorry.

24             THE REGISTRAR:  This would be Exhibit P1058, Your Honours.

25             MR. OLMSTED:  Thank you.  May we look at 65 ter 2902.

Page 7437

 1        Q.   This document is another Crisis Staff decision entitled:

 2     "Decision to Disarm Citizens Possessing Fire-arms Illegally," also dated

 3     19 April 1992.

 4             Sir, to whom was this decision directed?

 5        A.   This decision was directed at the competent authorities, the

 6     Ministry of Interior, the TO Staff; and it also refers to JNA units.

 7        Q.   And it's calling for citizens to turn in their fire-arms by a set

 8     date.  Would that be citizens of one particular ethnicity?

 9        A.   The decision says it applies to all the citizens who own weapons

10     illegally.  And when this decision was enforced, that's how it started.

11     Everyone started surrendering weapons.

12        Q.   So the Serbs also possessed illegal weapons.

13        A.   At the outset, yes, they did.  They did own weapons.  And, at the

14     beginning, both Serbs and Bosniaks started turning in weapons.

15        Q.   And I think you may have answered my next question.  What was the

16     Muslim population's reaction to this decision?  Did they comply with

17     it?

18        A.   Some understood it literally, that they should return even

19     weapons for which they had a licence, and they started bringing in

20     hunting rifles and pistols they had licences for.  But those who had

21     automatic weapons, Kalashnikovs and such, did not turn in weapons, and

22     they did not want to be exposed, because they obtained them illegally in

23     the first place and kept them in hiding.

24        Q.   How was this decision communicated to the population of

25     Vlasenica?

Page 7438

 1        A.   Well, you see, since I was also called to come to the police

 2     station that morning at 9.00 to turn in my weapon, since we, the members

 3     of the MUP, were issued with automatic rifles in September 1991 and we

 4     also had our service pistols, I was called on the 21st to come to the

 5     station and bring my weapons.  There was some men there masked and told

 6     me that we should turn our weapons.  And I said, Here is my weapon but

 7     please give me a receipt because this is a service gun.  I'm a member of

 8     the MUP, and this is government issue.  And they said --

 9             THE INTERPRETER:  Could the witness repeat what they said.

10             MR. OLMSTED:  Well, we'll come back to that, sir.

11        Q.   My question is with regard to this document which is directed, it

12     appears, to the citizens of Vlasenica, and how that decision was

13     communicated to the general population and not the police.

14             MR. ZECEVIC:  I'm sorry, I believe the -- the witness's answer

15     wasn't recorded.

16             MR. OLMSTED:  All right.

17        Q.   Before you answer that question, if you go back to your prior

18     response, I think the last bit, you say, "I'm a member of the MUP and

19     this is government issue.  And they said ..."  and from there on, the

20     interpreter was unable to catch what you said.

21        A.   So I was a member of the MUP and sometime around 9.00 in the

22     morning I was called from the police station to bring my weapon, or

23     weapons.  Since I had a service pistol as a member of the ministry, and

24     back in September 1991, we members of the MUP, or at least some of us,

25     were also issued an automatic weapon, a Kalashnikov, I obeyed and brought

Page 7439

 1     my weapons to the police station.  I was met by some masked young men who

 2     had their faces masked and wore camouflage uniforms.  And I said, I

 3     brought my weapons, give me a receipt, because this is service weaponry

 4     of the ministry that I was issued with.  But the answer was, Leave this

 5     here and disappear upstairs, and I really did go to an office upstairs

 6     and spent some time there.

 7        Q.   Thank you.  Let's return to my question which is how the decision

 8     in front of you, which is aimed at the citizenry of Vlasenica, how was

 9     this decision conveyed to the population?  By what mens?

10        A.   Already, early in the morning I was still at home.  You could

11     hear something being announced in the streets of the town through a

12     public address system mounted on an APC and on a Volkswagen Golf.  The

13     announcement was that weapons should be turned in.

14             They were obviously reading from a script that citizens should

15     return, or turn in weapons to the closest military JNA unit or to the

16     police station, et cetera.

17        Q.   And the Golf Volkswagen, to what organ did that vehicle belong

18     to?

19        A.   Well, it was the only Golf Mark II.  It was a blue and white car

20     that belonged to the public security station in Vlasenica.

21             MR. OLMSTED:  Let's tender this document into evidence.

22             JUDGE HALL:  Admitted and marked.

23             THE REGISTRAR:  This will be Exhibit P1059, Your Honours.

24             MR. OLMSTED:  And if we could have on the screen, 65 ter 2899.

25        Q.   This is another Crisis Staff decision, entitled: "Decision to

Page 7440

 1     Disarm the Active and Reserve Forces of the Vlasenica Public Security

 2     Station," from 19 April 1992.

 3             Sir, was this decision, which I think you were referring to a

 4     moment ago, was this decision lawful?  Could the Serb Crisis Staff order

 5     the police to disarm themselves?

 6        A.   I don't think so.  There was the former MUP of the BiH which

 7     ceased to exist -- to function, and then the Serbian MUP was formed.  And

 8     I think that, in accordance with the hierarchy in the MUP, no minister,

 9     no assistant would ever sign this decision.  They would seek some

10     correction.  They would seek an explanation as to who needs to be

11     disarmed in actual fact, and they would not sign it the way it stands

12     here.

13        Q.   A while ago you mentioned that the Crisis Staff would

14     occasionally attempt to influence the police in Vlasenica.  Would this be

15     an example of that type of attempt at influencing the police?

16        A.   A classic example where my predecessor, Mr. Bjelanovic, must have

17     been taken aback.  And I assume that he reported to the minister and

18     sought instructions as to what to do.

19        Q.   Now it says under number Roman numeral II that:

20             "... the police in their present formation were not providing

21     security for the citizens."

22             Was that in fact the case?

23        A.   Well, I did not have that impression because the station

24     functioned properly, with the anomalies that I mentioned, but it

25     functioned, and the routine police business was done, as it was supposed

Page 7441

 1     to be done, traffic, crime investigation, law enforcement, and so on.

 2        Q.   Now, you've testified that up until the 21st of April, the police

 3     force in Vlasenica was multi-ethnic.  Did the Muslim police officers at

 4     the SJB comply with this decision?

 5        A.   Yes.

 6        Q.   Under section reman numeral III, it states that the SJB chief:

 7             "Radomir Bjelanovic is hereby authorised to engage the required

 8     number of active and reserve forces to secure public law and order and

 9     safe-guard the citizens."

10             We've already established that Bjelanovic was a member of the

11     Crisis Staff.  What was the reasoning behind this exception for him?

12        A.   You mean Mr. Bjelanovic?

13        Q.   That's correct.

14        A.   Well, I assumed that he agreed to implement this addition;

15     although, you can see that this decision was taken on the basis of the

16     decision of the Municipal Assembly in Vlasenica, that this was not done

17     in consultation with the higher-up levels at the republic.  In other

18     words, it was done at the municipality level, and he probably agreed to

19     implement this decision, in order to change the structure and the

20     composition of the police force, in the police station.

21        Q.   Do you recall how many active and reserve police officers

22     Bjelanovic engaged pursuant to this decision?

23        A.   I don't know the exact figure, but the following happened.

24             After this decision, all the police officers of Serb ethnic

25     background were re-employed.  They continued working, while the Muslim

Page 7442

 1     policemen were laid off or were told to take annual leave.  They no

 2     longer did their jobs, and they were no longer police officers or shift

 3     leaders and whatever.

 4             MR. OLMSTED:  May we tender this document into evidence.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  Thank you.  This would be Exhibit P1060, Your

 7     Honours.

 8             JUDGE HARHOFF:  Mr. Witness, your last comment begs the question

 9     as to whether the weapons that had just been collected from the police

10     force were then given back to the Serb policemen, who were then

11     re-employed.

12             Do you know if they were -- if the re-employed Serbian policemen

13     were then given back their weapons that they had just handed in?

14             THE WITNESS: [Interpretation] They were issued weapons again.

15     Their own, the ones that they had returned, or some other weapons, but

16     it -- I don't know that, but they were issued weapons again.

17             JUDGE HARHOFF:  So am I right to understand that this whole

18     operation was designed to -- to rid the SJB in Vlasenica of the Muslim

19     and Croat policemen and retain only the Serbian policemen?

20             Was that the purpose of this decision?

21             THE WITNESS: [Interpretation] Well, if you analyse the situation,

22     yes, it does follow from this decision that the idea was to change the

23     ethnic composition, to disband everyone, and then to take back only those

24     that you wanted to have back on board.

25             JUDGE HARHOFF:  Thank you, sir.

Page 7443

 1             MR. OLMSTED:  Let's move to the day of the takeover.  So we're --

 2     now we're on the 21st of April, 1992.

 3        Q.   Could you tell us which Serb forces participated in the takeover

 4     the Vlasenica town on that day.

 5        A.   Based on what I know, the members of the JNA took part in those

 6     activities.  They had some APCs and combat vehicles and a certain number

 7     of troops.  Members of the Territorial Defence also took part.  It was

 8     the newly established TO.  And the main agent in this job was a

 9     paramilitary unit, we might call it that.  Later on, I learned that it

10     was called the Serbian Guard from Sekovici.

11             Now whether it was part of a JNA unit that was stationed in

12     Sekovici or not, whether it was some other form of organisation, I don't

13     know.  But, at any rate, those were the forces that were involved in that

14     operation.

15             JUDGE HALL:  Mr. Olmsted, it's 12.00.  It's time for the break.

16             We resume in 20 minutes.

17                           [The witness stands down]

18                           --- Recess taken at 12.06 p.m.

19                           --- On resuming at 12.29 p.m.

20                           [The witness takes the stand]

21             MR. OLMSTED:

22        Q.   Sir, before the break, we were talking about the various Serb

23     forces that participated in the takeover on 21 April, and you mentioned

24     that the JNA was participating in the takeover.  Could you tell us what

25     corps of the JNA was present?

Page 7444

 1        A.   They called it the Novi Sad Corps.  It was a unit provisionally

 2     stationed with their command in Sekovici at Ulovnica [phoen] hotel, and

 3     they got there after withdrawing from Croatia or wherever.

 4        Q.   The Serb guard that you mentioned, could you tell us what kind of

 5     uniforms they were wearing and whether they had any arm-bands or any

 6     other markings to distinguish themselves?

 7        A.   Since it was just the beginning, almost all army troops were

 8     still wearing the traditional olive-green-grey uniforms, the so-called

 9     SMB colour, and these wore camouflage SMB.

10        Q.   Did the Serb guard have any arm-bands?

11        A.   I can't really remember, but I think that they did have the

12     Serbian Guard insignia on their sleeves.  Now, they may have worn a red

13     ribbons on their upper arms, and in that action they also had face paint.

14        Q.   Were these Serb Guards the ones that were at SJB building when

15     you arrived on 21st of April?

16        A.   Yes.

17        Q.   Now, on the day of the takeover, or, in fact, the days that

18     immediately followed the takeover, was there any Muslim resistance in

19     Vlasenica town?

20        A.   No.  No armed resistance was recorded.  There were no incidents

21     of any kind.

22        Q.   Could you tell us how long the JNA Novi Sad Corps remained in

23     Vlasenica?

24        A.   Elements of those forces remained there after the 21st, and the

25     entire formation that was stationed there with its headquarters in

Page 7445

 1     Sekovici remained there until the 19th of May.  And then, on the orders

 2     of the then ministry or the Federal Republic of Yugoslavia, it was tasked

 3     with leaving the territory of Bosnia and Herzegovina but upon its

 4     departure, some of the troops and some of the equipment, military

 5     equipment, remained there.  Whether on a voluntary basis or ... I don't

 6     know.

 7        Q.   Could you describe for us the equipment that they left behind in

 8     Vlasenica?

 9        A.   Well, for the most part, those were infantry weapons, automatic

10     rifles, in military parlance.  Rifles, light machine-guns, mortars, a

11     small quantity.  There were probably some grenades and a number of small

12     armoured vehicles; armoured personnel carriers, as they were called.  And

13     maybe a tank or two, but I can't really say that with any certainty.

14        Q.   Sir, when were you officially mobilised in the RS MUP?

15        A.   I was not mobilised in the RS MUP -- or, rather, I was assigned

16     in the Republika Srpska MUP as early as on -- or around the 23rd or the

17     24th of April.  I don't know the exact date.

18        Q.   And I believe you've testified that, after the takeover, the

19     Muslims who worked at SJB Vlasenica were discharged from the police.

20     Approximately how many days after the takeover were all the Muslim, Croat

21     police officers gone from the SJB?

22        A.   On the 22nd, or the 23rd, on or around those dates, they were

23     issued decisions that they were on annual leave or administrative leave.

24     They did not return to service because they had been issued those

25     decisions.

Page 7446

 1             After the 21st, they no longer served as policemen in the

 2     station.  They were no longer present there at all.

 3        Q.   Sometime around mid-May 1992, did SJB Vlasenica receive an

 4     instruction from the RS MUP regarding personnel matters?

 5        A.   Since I was taken over, in a manner of speaking, from the former

 6     MUP, and in accordance with the mobilisation plan, I was assigned to the

 7     Vlasenica station, I had an opportunity later on to find a document,

 8     instructions from the Ministry of Interior, describing the manner in

 9     which the station is to operate and organise its work in a state of an

10     imminent threat of war.

11        Q.   Who signed that order?

12        A.   This document that I found was signed by Mico Stanisic, the

13     minister.

14             MR. OLMSTED:  If we could take a look at Exhibit 1D46.

15        Q.   What we have before us is an order dated 15 May 1992.

16             Could you tell us whether is this the order that you were just

17     referring to?

18        A.   Yes.

19        Q.   Can you tell us what actions did the SJB Vlasenica take, pursuant

20     to this order?

21        A.   Well, in light of the fact that Mr. Bjelanovic was chief at the

22     time, transformation and reorganisation was carried out in accordance

23     with the instructions.  The existing number of policemen who remained

24     there, who were on active duty, and a certain number of reserve police

25     officers, because some of the active and reserve policemen of Bosniak

Page 7447

 1     ethnic background had left, resulting in a decrease in the number of the

 2     police, and some of the policemen went to the Milici police station which

 3     had been newly established.  So there was a small number of active and

 4     reserve police officers, and for that reason, a request was made to fill

 5     the ranks with the reserve police officers, and a request was put to the

 6     ministry to make sure that it is done in order for the police to be able

 7     to perform its tasks as required in the newly developed circumstances.

 8     And this is why some action was taken in accordance with the order of the

 9     minister.

10        Q.   You just said that a request was made to fill the ranks with the

11     reserve police officers to the ministry.  Did the ministry respond to

12     that request?

13        A.   The Ministry of Defence, that's what I meant.  The Ministry of

14     Defence did respond.

15        Q.   I see.  I think I understand you.  You're saying that the

16     Secretariat of National Defence filled the ranks with the reserve police

17     force?

18        A.   Yes, yes.

19             MR. OLMSTED:  I believe this has already been admitted into

20     evidence.

21             So let's move on to the next document, which has been marked for

22     identification.  It's P1046.  I ask this not be broadcast because it does

23     contain the name of the witness.

24             And if we could go to page -- the second page in both the English

25     and B/C/S.

Page 7448

 1        Q.   Now, this document is entitled: "List of Active Police Workers

 2     who Have Worked at this SM," which I believe is police station, "in

 3     May 1992 and Who Have Been Paid LD," which is salary, "in Advance of This

 4     Month."

 5             Sir, do you recognise the name under entry number 1 as yourself?

 6        A.   Yes.

 7        Q.   Whose signature is at the end of this entry?

 8             MR. OLMSTED:  If we could scroll over.

 9        Q.   Do you recognise that signature?

10        A.   Well, if you mean the signature up there, under number 1, yes, I

11     do.

12        Q.   Is that your signature?

13        A.   Yes.

14             MR. OLMSTED:  And if we could scroll down to the bottom of the

15     page.  Just over to the right a little bit.  Yeah.

16        Q.   We see a signature in the right-hand corner.  Is that your

17     signature?

18        A.   Yes.

19        Q.   Now the rest of the names on this page are a little bit

20     illegible.

21             MR. OLMSTED:  So why don't we move to the next page, page 3.  I

22     think it's a clearer copy.

23        Q.   We see here 27 names of active police workers on this list.  What

24     are their ethnicities?

25        A.   Serbs.

Page 7449

 1        Q.   And according to this list, who was police commander?

 2        A.   Commander, komandir?

 3        Q.   Yes, who was police commander at SJB Vlasenica in May 1992.

 4        A.   You mean the commander?  The Serbian word would be komandir.

 5        Q.   I believe that's correct, yes.

 6        A.   Radenko Stanic.

 7        Q.   What was Radenko Stanic's relation to the president of the Crisis

 8     Staff, Milenko Stanic?

 9        A.   Brother.

10        Q.   And who was chief of the crime service at the SJB?

11        A.   Milenko Sargic.  But I can't really say who was issued the

12     appropriate decision, at what time.  And I believe that those -- since

13     those workers had already been employed in the Vlasenica public security

14     station at the time, and then they continued working in accordance with

15     the previously issued decisions as the minister issued the decision

16     adopting the rules on the internal organisation and final decisions in

17     accordance with the Law on the Ministry of the Interior of Republika

18     Srpska or the Republic of BiH only at a later stage.

19             But the acting chief of crime service was Milenko Sargic, and

20     Radenko Stanic was the commander of the police station.  However, I'm not

21     sure when they actually received the decisions to that effect.  Probably

22     it was at a later stage.

23        Q.   And thank you for that clarification.

24             Who did Stanic and Sargic report to within the SJB Vlasenica?

25        A.   Well, in this period, while Radomir Bjelanovic was the chief, at

Page 7450

 1     one point he was appointed the coordinator for the Birac region.  That

 2     would be the -- he was assistant to the centre chief, Cvijetic, and he

 3     would go there from time to time, and he would also visit the Milici

 4     station.  If there were any problems, they were reported to

 5     Mr. Bjelanovic, and then, later on, he probably reported to the centre

 6     chief, Cvijetic, and then up the chain of command, and great deal of

 7     emphasis was placed on that, Cvijetic would report to the minister, if he

 8     saw fit.

 9        Q.   We don't see Radomir Bjelanovic listed here on this list.  In

10     fact we have you listed as chief of the police on this list.

11             Where was Bjelanovic?  Where did he go?

12        A.   At the time he spent most of his time in the Milici police

13     station because it was in the process of being set up.

14        Q.   So did he become chief of police at SJB Milici?

15        A.   Yes, I think that, at the period when I was issued my decision or

16     maybe earlier, it was all regulated.  When the framework rules were

17     adopted, the minister issued the appropriate decision.  In my case it was

18     on the 8th of August, and I'm sure that the same thing happened for

19     Mr. Bjelanovic, because, at that point in time, the police stations

20     started functioning independently, separately, each had its own separate

21     internal structure and organisation.

22        Q.   You just mentioned that you were officially appointed chief of

23     SJB Vlasenica on 8 August 1992.  On this document, for May 1992, you --

24     you were --

25        A.   Yes.

Page 7451

 1        Q.   It designates you as chief of the station.  You were given a

 2     salary of chief and you signed it chief.

 3             Who gave you the right or the authorisation to perform that role

 4     prior to August 1992?

 5        A.   Until the new rules were adopted, the coordination and the

 6     functioning of the police went in accordance with the procedure that was

 7     in place.  Mr. Bjelanovic authorised me, since he had already been

 8     appointed coordinator, to adopt certain acts that were not of vital

 9     importance and to do some tasks of that nature.  And later on, in

10     conversation with Mr. Cvijetic, the chief, the centre chief, who came to

11     the station, he said that he would put my name forward with the minister,

12     that he would recommend that a decision be issued to me appointing me the

13     chief of the public security station in Vlasenica.

14             So at that time it was my task to act as a coordinator, or

15     whatever, but so -- in agreement with Mr. Bjelanovic and the centre

16     chief, I was to do that job until such time when I was issued the final

17     decision.  An example that could not affect strategy or the overall

18     success of the defence effort in that area was, for instance, this

19     signing a document such as this one, or the payroll.

20        Q.   So if I understand your testimony correctly, Bjelanovic

21     authorised you to submit payrolls and perform other functions that would

22     normally be responsibilities of the chief of police?

23        A.   Yes.  But I could not make decisions without consulting him and

24     further up the chain of command.  I could only do some co-ordinating in

25     order for the police station to be set up properly and to start

Page 7452

 1     functioning properly as a professional police force.

 2        Q.   So if you had a take a decision that went beyond that, you would

 3     have to get the authorisation of Bjelanovic.  Would you also have to have

 4     the authorisation of the CSB chief, Zoran Cvijetic?

 5        A.   Well, in the MUP, there is the subordination system, and logic

 6     dictates that the chain of command had to be obeyed.  Bjelanovic was my

 7     immediate superior because he was the chief of the police station, but he

 8     was also the co-ordinator for the Birac region, and then I would explain

 9     my reason -- reasons to him, and then he would address the centre chief,

10     and then further on, the minister, lest I should, God forbid, address the

11     centre chief or even the minister myself, because that would mean

12     skipping some of the levels in the chain of command.

13        Q.   Just one more question about this list.

14             Under number 20 is there is a Sinisa Miljanic.  Could you tell me

15     was that individual an active police officer before the takeover?

16        A.   I can't remember.  But I know that later on he attended some kind

17     of training, which means that he was a reserve police officer.

18             He was a younger man.  And all those lads, once the rules were

19     adopted, and once MUP became better organised, they were all sent for

20     police training.  And I, in fact, believe that he is to this day a police

21     officer.

22             MR. OLMSTED:  May we tender this document under seal.

23             JUDGE HALL:  Yes, admitted and marked, under seal.

24             JUDGE DELVOIE:  Mr. Olmsted, you called this document to the

25     screen with, if I'm not wrong, an exhibit number, a P number, no?

Page 7453

 1             MR. OLMSTED:  Yes, but --

 2             JUDGE DELVOIE:  What was the P number, please?

 3             MR. OLMSTED:  Yes, sorry about that.  It is P1046.  It was only

 4     marked for identification.  It was 65 ter 2814.  The reason it probably

 5     on your list didn't show up is because it was marked earlier this week

 6     for identification.

 7             JUDGE DELVOIE:  Okay.  So ...

 8             MR. OLMSTED:  Now in addition to the active police workers at SJB

 9     Vlasenica --

10             THE REGISTRAR:  I apologise, the document --

11             MR. OLMSTED:  Oh, sorry.

12             THE REGISTRAR:  -- Exhibit P1046 will be now admitted under seal,

13     Your Honours.

14             MR. OLMSTED:

15        Q.   Now, in addition to the active police workers at SJB Vlasenica,

16     what other police units existed within the framework of SJB Vlasenica?

17        A.   Well, there's the active force and the reserve force.  And later

18     on, there was will also the intervention platoon, which was called the

19     special police unit, or the special purpose unit.  And we will see later

20     on how this unit came into being.

21        Q.   Turning first to the reserve police force.  Could you tell us

22     approximately how large the reserve police force was from May through,

23     let's say, September 1992.

24        A.   The number varied occasionally, as the circumstances in the

25     region changed.  At the moment, for instance, when the Army of Republika

Page 7454

 1     Srpska was established a smaller number was required, but there was 70 to

 2     80 reserve policemen at that time, on the average.

 3        Q.   And what was the ethnicity of this reserve police force?

 4        A.   Well, it's clear by now after that overhaul on the 21st of April,

 5     they were Serbs.

 6        Q.   And could you briefly describe generally what were the

 7     responsibilities of the reserve police after -- well, let's say, after

 8     the takeover on 21 April 1992.

 9        A.   The tasks of the reserve policemen, since they had some prior

10     police training from the past because they had gone through training,

11     were similar to the tasks of the active force.  In addition, in the new

12     circumstances of war and immediate threat of war, everyone had the

13     additional task of being engaged in defence and combat.  For the public

14     security station to be able to function, professional policemen, minus

15     Bosniaks now, and minus a number of Serbs who left the station in

16     Vlasenica for the station in Milici, with a very small number remaining,

17     part of the reserve policemen joined active duty policemen in discharging

18     the usual law enforcement duties, including traffic control, and in

19     addition to that, they were also engaged in combat, as required.

20        Q.   Would the reserve police also participate in manning check-points

21     around Vlasenica?

22        A.   Yes.  There were check-points at the entry to the town and exit

23     from the town, and reserve policemen were engaged, together with active

24     police, on these check-points as well.  But as I've already said, since

25     the number of the active duty force was reduced, then the leader of this

Page 7455

 1     mixed team was always an active duty policeman.

 2        Q.   Let's now turn to the special purpose unit that you mentioned?

 3             Could you tell us approximately what the size of that unit was?

 4        A.   That unit numbered 20 to 25 men.

 5             MR. OLMSTED:  Can we take a look at P1044.  This is marked for

 6     identification earlier this week.  It was originally 65 ter 2378.  And

 7     may we not broadcast this document as well.

 8        Q.   Now, this document consists of two lists.  If we can look at the

 9     first one, it's entitled:  "List of Members of the Reserve Police Forces

10     at Vlasenica SJB."

11             MR. OLMSTED:  And perhaps we can go to page 3.  I'm sorry, page 3

12     in the B/C/S, the English, let's stay on page 1.  There we go.  If we

13     scroll down to the bottom of the B/C/S there's a signature.

14        Q.   Could you tell us if that's your signature?

15        A.   Yes.

16        Q.   Now, if you can go to the very top of the document.

17             This document is not dated but we can see that there's a fax line

18     on it, and it looks like it's July 19, 1992?

19             Do you see that?

20        A.   Yes.

21        Q.   Now I know some time has passed, but would you be able to confirm

22     that generally this is the roster of reserve police around July of 1992?

23        A.   Yes.  These are mainly the policemen who were mobilised and

24     engaged through the Secretariat for National Defence and who were

25     assigned to the station.  They would be assigned as

Page 7456

 1     regular [as interpreted] policemen.

 2             MR. OLMSTED:  If we could turn to page 4 of the B/C/S and page 2

 3     of the English.

 4             MR. ZECEVIC:  I'm sorry, page 58, 20, I believe the witness says,

 5     "They would be assigned as reserve policemen," not "regular policemen."

 6             MR. OLMSTED:

 7        Q.   Now the second list is entitled:  "List of members of the" --

 8             MR. ZECEVIC:  I meant this should be clarified with the witness,

 9     I guess.  I'm not testifying here.

10             MR. OLMSTED:  All right.  I misunderstood.  I thought you thought

11     it was merely a transcription error.

12        Q.   Sir, in your last answer you said that these reserve policemen

13     were mobilised through the Secretariat of National Defence and were

14     assigned to the station.  And then you said: "They would be assigned

15     as" - and the transcript reads - "regular policemen."

16             Is that correct?

17        A.   No, no, I said "reserve policemen."

18        Q.   Thank you.  Now this page of the document, the title is list of

19     members of the special platoon at Vlasenica SJB.

20             Is this the special-purpose unit that you were referring to

21     earlier?

22        A.   Yes.

23        Q.   And if we could go to the next page of the B/C/S.

24             Could you tell us whether that is your signature at the bottom of

25     this list?

Page 7457

 1        A.   Yes.

 2             MR. OLMSTED:  If we can go back to the previous page.

 3        Q.   And if we can look at this list, could you tell us, point out for

 4     us who the commander of this special-purpose unit was?

 5        A.   Miroslav Kraljevic.

 6        Q.   And do you recall who his -- his Deputy Commanders were from this

 7     list?

 8        A.   I couldn't say with certainty, because I wasn't involved in that

 9     part of -- that -- I wasn't involved in that part of the organisation,

10     but I believe Elvis Djuric stood in for him frequently.

11        Q.   And what about number 8, Zoran Stupar, did he have any leadership

12     role in this unit?

13        A.   Not that I know.  He was usually in logistics.

14        Q.   You just stated that you didn't interact directly with this unit.

15     Who in active police force at SJB Vlasenica would Kraljevic report to?

16        A.   Well, according to the law and the rule book on internal affairs,

17     the uniformed police is under the command of the police station

18     commander.  And according to this hierarchy, he was to report to the

19     commander and receive assignments from the commander.

20        Q.   And the commander at this time, well, at least acting commander

21     was Radenko Stanic?

22        A.   Yes.

23        Q.   While this special-purpose unit was active within the SJB, where

24     would they congregate to receive their daily assignments, either from

25     Kraljevic or from Radenko Stanic?

Page 7458

 1        A.   For the most part, they were in the combat zone.  And if they

 2     were not there, then assignments would be made shift by shift.  Ten of

 3     them or so would be at the ready, at the station.  Another group would be

 4     on leave, resting.  That was the system.

 5             So those people who were resting also were duty-bound to report

 6     urgently to the station if they were called to go into combat.  And they

 7     were almost never engaged in police duties because they had no police

 8     training or skills whatsoever.  And it's perhaps important to note here

 9     that this unit used to be an integral part of the so-called special unit

10     attached to the newly established Territorial Defence of Vlasenica.

11             Traditional example -- a classic example of imposition by the

12     Crisis Staff and the leadership is precisely the transfer of this unit to

13     the structure of the ministry.  Actually, not transfer, but assigning

14     them to the public security station.  And this matter, to the extent that

15     I still had a say at that time, I never definitively approved, and

16     neither did Mr. Bjelanovic.  And I believe the minister later reacted in

17     the matter concerning not only this unit but all such units that were

18     attached by various political players in -- in various municipalities.

19        Q.   Thank you, and I understand you're anxious to explain the

20     situation.  But, please, again, address the question that I ask.

21             And just returning to my question, I just want to clarify, when

22     this -- members of this unit would report for assignment to the station,

23     you mean the SJB building?

24        A.   Yes.

25        Q.   Did you make CSB Chief Cvijetic aware that this unit, this

Page 7459

 1     special-purpose unit, existed within SJB Vlasenica?

 2        A.   Yes, I met Chief Cvijetic.  He was unhappy too, because we were

 3     working pursuant to the law.  If we needed a reserve policeman, the

 4     procedure was well known.  We would file a request to the Secretariat for

 5     Defence and they would send us men who had at least been military

 6     policemen in the former JNA, so they had some prior knowledge and skills.

 7             This unit used to be an integral part of the Territorial Defence,

 8     and it was resubordinated somewhere in May, around the 10th of May.

 9        Q.   And just to clarify:  Resubordinated into the SJB Vlasenica?

10        A.   Yes.

11        Q.   Now, you mentioned -- well, I am getting from the tenor of your

12     answer that you were not happy about this special unit.  Why were you

13     unhappy about them?  Were they -- how were they behaving in Vlasenica?

14        A.   First of all, in principle and by law it was not resubordinated

15     as the previous reserve policemen had been resubordinated.  When the

16     complement needed to be refilled, when our policemen left for Milici,

17     when we needed replenishment we went through the Secretariat for National

18     Defence, we filed the proper request, we asked for a certain number of

19     people who had prior skills and knowledge and we were given that.

20             However, some time in May or, to be specific, when this Miroslav

21     Kraljevic came to Vlasenica holding himself out to be a lieutenant and

22     when he established this unit as part of the Territorial Defence, the

23     Crisis Staff made the decision that this unit should be seconded or

24     resubordinated or whatever I shall call it to the public security

25     station, circumventing all these procedures that we had insisted on

Page 7460

 1     because the ministry required us to.  However, we had to go along with

 2     it.  We had no choice.  But we made do somehow, and we directed them

 3     exclusively to combat duty, because they had no law enforcement skills.

 4        Q.   But my question -- again, thank you for the explanation, but

 5     please focus on the question.

 6             My question was:  How were they behaving around the town,

 7     Vlasenica town, during this time-period?

 8        A.   Well, let me tell you, we had a certain system of work and

 9     shifts.  You were at the ready, or you were on duty, or you were resting.

10     And they were causing problems around town, disturbing public order and

11     violating the law, and we had no real ability to punish them or hold them

12     accountable in any way.  So we sanctioned this conduct as much as we were

13     able.

14        Q.   Under number 23 of this document, is Dragan Nikolic.  Is he the

15     same person who was convicted by this Tribunal?

16        A.   Yes.

17             MR. OLMSTED:  May this document be tendered under seal.

18             JUDGE HALL:  Yes, admitted and marked, under seal.

19             THE REGISTRAR:  P1044, MFI'd, becomes exhibit under seal, Your

20     Honours.

21             MR. OLMSTED:  If we could take a look at P5 -- strike that.

22     P857.

23             And, again, please do not broadcast this document.

24        Q.   Now, sir, I have very specific questions to ask you about this

25     document.

Page 7461

 1             First of all, does it contain your signature on the document?

 2        A.   Yes.

 3        Q.   In here you report that the special police platoon was formed in

 4     Vlasenica SJB in order to realise the goals and on the basis of agreement

 5     and suggestions of the Birac SAO government.

 6             Can you explain what you meant by that?

 7        A.   That's precisely what I wanted, trying to draw the minister's

 8     attention to the way this unit was seconded, and we were under pressure

 9     from the SAO Birac government.  Milenko Stanic was the head of that

10     government.  And I wanted to draw the minister's attention that the unit

11     was resubordinated in the way that I had already described.

12             JUDGE DELVOIE:  Do we have the right document on the screen?

13             MR. OLMSTED:  No, we don't.  Thank you, Your Honour.  I

14     apologise.

15             Perhaps we have the wrong P number, but it's 65 ter 2677.

16             Okay.  Now I believe it is correct.

17        Q.   What were the goals and suggestions of SAO Birac?

18        A.   Well, look, when you talk about objectives, it's security

19     objectives that are meant.  That is unequivocal.  And when it says on

20     basis of agreement and suggestions of the Birac Serbian Autonomous

21     District, those were actually pressures to second this unit to the public

22     security station and here is why.

23             The Army of the Republika Srpska had been established by that

24     time, and they tried to foster professionalism just as we did in the

25     ministry so that political leaderships were gradually losing their

Page 7462

 1     leverage of influence, and they were trying to hold on to some lever of

 2     influence through units like this, and that's why the minister reacted to

 3     this problem and asked us to disband such units because they had never

 4     been established with his approval, that is, the approval of the ministry

 5     of the interior, in the first place, and even for us on the ground they

 6     were just a burden because they frequently went out to receive

 7     assignments from politicians rather than their immediate superiors.

 8        Q.   Sir, is it your position, then, that the special unit was not

 9     formed pursuant to the 15 May order of Mico Stanisic?  Is that your

10     position now?

11        A.   No, not the order of the 15th of May.  The 15 May order is clear.

12     That the existing complement of the police should adjust to the

13     circumstances of the immediate threat of war, that one part of the police

14     force should continue with their law enforcement duties and protect the

15     citizens; whereas, another part of the police should be joined by reserve

16     police to pursue other security and defence duties, including combat.

17             I never had occasion, actually, to talk to the minister, but this

18     unit was like units in -- in some other municipalities.  He waited and

19     then issued an order that such units that had been established outside

20     the MUP procedure should be disbanded and that the structure of the

21     ministry should be restored in keeping with the Law on Internal Affairs.

22        Q.   And, in fact, pursuant to the minister's instructions you

23     disbanded this special unit?

24        A.   Pursuant to the minister's instruction, we disbanded, or, rather,

25     reorganised this unit.  All the men who had an inclination and met the

Page 7463

 1     requirements and wanted to be policemen, were directed by us to an

 2     abbreviated police training course.  Some others we turned over to the

 3     Army of Republika Srpska, and yet another part of these policemen were

 4     taken over by the staff of Republika Srpska in Crna Rijeka as security

 5     units or something, so that this unit no longer existed as such.

 6             Only a couple of young men who really wanted to, who completed

 7     the course and who wanted to become policemen, did so; whereas, the

 8     others were handed over to the Army of Republika Srpska or the

 9     Main Staff.

10        Q.   In this letter, you write that the unit was transformed in such

11     way that part of became a reserve contingent.  When you wrote "reserve

12     contingent," were you referring to the reserve police or something else?

13        A.   In the first stage, those who wanted to remain and who met the

14     criteria, they continued on as reserve policemen, and immediately after

15     that, as soon as the course was set up, they were sent there for

16     training.

17             MR. OLMSTED:  If we could look at 65 ter 2809.

18             MR. ZECEVIC:  I'm sorry, Your Honours, will this -- will this

19     document be tendered or ... or you don't want to rely on it.

20             MR. OLMSTED:  I believe it's already been admitted into evidence.

21     Perhaps we could have move it to tender it under seal given that the fact

22     that now this witness has identified himself in it.

23             MR. ZECEVIC:  Well, it is my recollection that it was called by

24     the 65 ter number, not the exhibit number.  That is why I ...

25             MR. OLMSTED:  We have it listed as P857.

Page 7464

 1                           [Trial Chamber and Registrar confer]

 2             JUDGE HALL:  So the -- it's already exhibited.  It just now be

 3     placed under seal.

 4             MR. ZECEVIC:  I'm sorry.  I'm sorry, Your Honours.  I find out

 5     that -- it was my mistake.

 6             I'm sorry, Mr. Olmsted.

 7             MR. OLMSTED:  If we could take look at 65 ter 2809.

 8        Q.   While we're waiting to call this document up, when we -- when you

 9     were interviewed last year, you did say that the special unit was created

10     pursuant to this 15 May 1992 order by Mico Stanisic.  Why now are you

11     saying that it wasn't?

12        A.   I didn't say that it wasn't.  Pursuant to the order of the 15th

13     of May, it was necessary to use the existing force as a basis and to

14     replenish it with the reserve force to set up a company, whatever the

15     minister called it, in order to be able to respond to all the challenges,

16     security challenges in the circumstances of war.  But I also explained

17     that this unit was attached through the Crisis Staff by the Territorial

18     Defence because it was an integral part of the Territorial Defence of

19     Vlasenica, which was established on the 19th of April 1992.

20             MR. OLMSTED:  Can we look at 65 ter 382.

21        Q.   Sir, could you confirm, is this the order to disband the special

22     units that you were responding to in the previous document?

23        A.   Yes.

24             MR. OLMSTED:  May this document be tendered into --

25             May this document be tendered into evidence.

Page 7465

 1             JUDGE HALL:  Admitted and marked.

 2             THE REGISTRAR:  This will be Exhibit P1061, Your Honours.

 3             MR. OLMSTED:  I want to show you another payroll.  It's P1045,

 4     marked for identification this week.  Its 65 ter number is 2815.

 5             And, again, please do not broadcast this document.

 6             JUDGE HARHOFF:  Mr. Olmsted, the last document was signed by who?

 7     The order to disband the special police units.  I don't think we saw the

 8     signature.

 9             MR. OLMSTED:  Yes, I could tell you, for the record, that it's by

10     Zoran Cvijetic.  Let me ask the witness.

11        Q.   Do you recall who signed that order to disband -- the order that

12     you received to disband the special unit?

13        A.   Since I've already explained this manner of subordination, the

14     minister did co-ordination, and he sent a memo of this kind to the chief

15     of the security centre, and then relayed to him to the public security

16     stations in its original form.  I didn't really look, but I think that it

17     was signed by Zoran Cvijetic.

18        Q.   Now, if we can turn -- we can stay on page 1 for the English but

19     if we can turn to page 2.

20             And this is a list dated September 1992 of the payroll SJB

21     Vlasenica reserve police.

22             MR. OLMSTED:  Actually, if you can turn to page 3.

23        Q.   Can you tell us, is that your signature?

24        A.   Yes.

25        Q.   Now, if we can turn to the previous page.

Page 7466

 1             If we look under number 76 there's Miroslav Kraljevic.

 2             MR. OLMSTED:  And I'm sorry, now let's go back to page 3.

 3        Q.   And we see under number 77, Elvis Djuric, and under 97,

 4     Dragan Nikolic.  Were these -- well, is this some examples of some of the

 5     special units members who became members of the reserve police that we

 6     just talked about?

 7        A.   Here we have the names, for instance Kraljevic, Miroslav, was

 8     wounded at the time.  He was hospitalised.  He was wounded some time in

 9     August.  Which means that at the time when this order was implemented he

10     was there, and probably this is why his name was kept on the list, in

11     order for him to receive his salary.  Salaries were not paid regularly.

12     People were paid in arrears and so on.

13             As for Elvis, Djuric, he was a lad who expressed his wish to

14     remain in the reserve force or, rather, to attend the police training

15     course, and that's why he was kept.

16             As for Dragan Nikolic, well, I can't really say whether it was

17     the man or not.  I don't think so because he was in the army and he had

18     been in the army at the time before the unit was disbanded.

19        Q.   If we could go back to page 2 of the B/C/S.

20             If we look at under number 72 there's a Predrag Basta.  Can you

21     tell us are you aware whether this reserve -- can you tell us whether you

22     are aware if this reserve police officer has been convicted of committing

23     war crimes against Muslims in 1992?

24        A.   As far as I know, the trial ended before a BH court.  It was

25     quite recent, in fact.

Page 7467

 1             MR. OLMSTED:  May we tender this document under seal.

 2             JUDGE HALL:  Yes.  Admitted and marked, under seal.

 3             THE REGISTRAR:  Exhibit P1045 admitted under seal, Your Honours.

 4             MR. OLMSTED:

 5        Q.   And just one more payroll I want to show you.

 6             MR. OLMSTED:  It's 65 ter 2813.  And if we could just flip

 7     through the pages one after another.  I want to see if the witness could

 8     authentic these documents, his signature on them.

 9             Could you flip to the next page.

10        Q.   Is that your signature?

11        A.   Yes.

12             MR. OLMSTED:  Can you flip to page 5.

13        Q.   Is that your signature?

14        A.   Yes.

15             MR. OLMSTED:  Could you flip to page 7.

16        Q.   Is that your signature?

17        A.   Yes.

18             MR. OLMSTED:  And, finally, page 11.

19        Q.   Is that your signature?

20        A.   Yes.

21             MR. OLMSTED:  Your Honours I'd like to admit this into evidence

22     as well, under seal.

23             JUDGE HALL:  Admitted and marked under seal.

24             THE REGISTRAR:  As Exhibit P1062, Your Honours.  It will be under

25     seal.

Page 7468

 1             MR. OLMSTED:

 2        Q.   In --

 3                           [Technical difficulty]

 4             THE REGISTRAR:  I apologise, this will be Exhibit P1062 under

 5     seal.

 6                      [Trial Chamber and Registrar confer]

 7             JUDGE HALL:  We are thinking that in as much as we have five

 8     minutes ... she wanted the break.

 9             MR. OLMSTED:

10        Q.   During the May through December 1992 time-period, what kinds of

11     uniforms were the reserve police and the special unit wearing?

12             MR. ZECEVIC:  I'm sorry, I'm just not clear about what is

13     happening with the part of the transcript that is missing, because I

14     believe the document was admitted and we --

15             THE REGISTRAR:  That is correct.  I think it was not recorded.

16     65 ter 2813 is admitted as Exhibit P1062 under seal.

17             MR. ZECEVIC:  Thank you.

18             MR. OLMSTED:  Thank you counsel.

19        Q.   Back in this May through December 1992 time-period, could you

20     describe for us the uniforms that the reserve and special unit were

21     wearing?

22        A.   Between May and December, depending on the capabilities, well,

23     the uniforms changed.  The intent was to have -- for all the police to

24     have the same uniform, camouflage pattern, blue uniform.  But in May,

25     June, July, even in August, some of the police officers wore the old

Page 7469

 1     style blue MUP uniforms, while the special unit, the one that had been

 2     attached, its members came in wearing some kind of camouflage uniforms

 3     which were green.  It was a makeshift uniform.

 4             But based on our requests to the ministry, we did receive a

 5     certain number of uniforms, and the active and reserve force, by

 6     December, they were all issued with blue camouflage uniforms, and that

 7     was the uniform prescribed by law; whereas, the members of the special

 8     unit which were involved in combat, the intervention unit, in addition to

 9     the blue camouflage uniform, they also had the green camouflage uniform

10     when they went into combat, which means that all the uniforms were

11     harmonised by December.  But in this period that you are talking about,

12     various uniforms were in existence, the old style police uniforms, and

13     the camouflage uniforms were gradually phased in.

14             MR. OLMSTED:  I think we can stop there then.

15             JUDGE HALL:  Mr. Witness, we're about to take the adjournment

16     for today.  We will resume at 9.00 tomorrow morning.  But I am to alert

17     you that having been sworn as a witness you cannot have any communication

18     at all with the lawyers from other side, and in such conversations as you

19     may have with anybody outside of the courtroom, you cannot discuss your

20     testimony.

21             Do you understand what I have said?

22             Yes, thank you.

23             THE WITNESS: [Interpretation] Yes, I understand.

24             JUDGE HALL:  So we take the adjournment until tomorrow morning.

25                            --- Whereupon the hearing adjourned at 1.47 p.m.,

Page 7470

 1                           to be reconvened on Thursday, the 11th day of

 2                           March, 2010, at 9.00 a.m.