Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10873

 1                           Thursday, 27 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.06 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.

 6             Good morning to everyone in and around the courtroom.

 7             This is case IT-08-91-T, the Prosecutor versus Mico Stanisic and

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

10             Good morning to everyone.  And everyone's favourite courtroom.

11     May we have the appearances, please.

12             MR. OLMSTED:  Good morning, Your Honours.  Matthew Olmsted,

13     Joanna Korner, and Jasmina Bosnjakovic for the Prosecution.

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

15     Eugene O'Sullivan, and Ms. Tatjana Savic appearing for Stanisic Defence.

16     Thank you.

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

18     Zupljanin Defence, Igor Pantelic and Dragan Krgovic.  Thank you.

19             JUDGE HALL:  Thank you.

20             Before we resume, yesterday the dictates of the clock meant that

21     we had to adjourn before we could resolve a matter that was before us.  I

22     just wish to update the parties that we are still considering the

23     question and will give our final decision in -- in due -- we trust in the

24     course of this day, but in -- certainly we expect by tomorrow.

25                           [The witness takes the stand]

Page 10874

 1             JUDGE HALL:  Good morning to you, Mr. Radulovic.  Can you

 2     hear me?

 3             THE WITNESS: [Interpretation] Good morning.  Yes, I can hear you.

 4             JUDGE HALL:  Yes.  Again, I remind that you are are still under

 5     your oath, as I invite Mr. Olmsted to resume his -- to continue his

 6     examination-in-chief.

 7                           WITNESS:  PREDRAG RADULOVIC [Resumed]

 8                           [Witness answered through interpreter]

 9                           Examination by Mr. Olmsted: [Continued]

10        Q.   Good morning, Mr. Radulovic.

11        A.   Good morning.

12        Q.   Where we left off yesterday was that you had returned to

13     Banja Luka after you had visiting the Omarska and Keraterm camps.  When

14     you returned to Banja Luka, did you meet with anyone from the CSB?

15        A.   Yes, I did.  On that very same day in the -- evening hours I met

16     Mr. Stojan Zupljanin.  There was Djuro Bulic also attending, who was

17     getting ready to go some kind of gym or something like that.  I remember

18     he was wearing track suit pants.  He had sneakers on and, strangely,

19     woolen socks.  I don't know whether that -- whether that you find that

20     unusual, but he actually did have woolen socks.  And considering the

21     circumstances I was witnessed to, I was a little bit under the weather.

22     But I insisted - I remember that - for the Prijedor incident to be put

23     under some sort of operational control in order to stop it.

24             Djuro Bulic --

25        Q.   Let me stop you there, Mr. Radulovic.  Let me -- today let me

Page 10875

 1     really ask the questions and you give answers because I do have very much

 2     limited time left.

 3             Did you tell Mr. Zupljanin and Mr. Bulic everything that you had

 4     observed at the Omarska and Keraterm camps that day?

 5        A.   I told them the most important details about the harassment,

 6     mistreatment, killing of people.  I talked about the ways in which people

 7     were killed.  I told them that active-duty officers of the public and

 8     state security were displeased with such kind of treatment.  And those

 9     who were in charge of bringing in people, these people, are the people I

10     had in mind.

11        Q.   It's quite -- quite --

12             MR. ZECEVIC:  I'm pretty sure -- I don't -- I'm not wearing my

13     earphones, but I'm pretty sure that the translation of the answer of the

14     witness is not recorded properly because that is not what he said.  If --

15     if can you ask him to repeat his answer, please.

16             MR. OLMSTED:

17        Q.   All right.  Just very briefly, Mr. Radulovic, did you tell

18     Mr. Zupljanin and Mr. Bulic at this meeting everything or at least the

19     most important details of what you had observed at Omarska and Keraterm

20     camps that day?  You don't have to go into all the details, as we've

21     heard what you observed yesterday.

22        A.   Yes, I did.

23        Q.   And it's probably quite obvious that this was an emotional time

24     for you, having witnessed what you had seen.  How did Mr. Zupljanin react

25     to the information you provided at that meeting that day?

Page 10876

 1        A.   My understanding was that he was surprised that he didn't trust

 2     my words then.  He told me something along the lines of he will look into

 3     it.  And that was mostly what he said.

 4        Q.   Do you recall someone at the meeting saying to you, Radule, it's

 5     a war?

 6        A.   Yes, Stojan Zupljanin did, and that this is happening.

 7        Q.   And when Mr. Zupljanin told you, Radule, it's a war, after you

 8     had told him what was happening at the camp, how did you respond to that?

 9        A.   I will remember the scene until I'm alive -- until the day I die.

10     It was the first time in my life that I cried in front of my senior

11     officer.  I started crying after Djuro Bulic started telling

12     Mr. Zupljanin that they should hurry because they have a football game

13     scheduled.

14        Q.   And did they then leave and go to that football match?

15        A.   They did.  And I started crying in front of the building of the

16     CSB in Banja Luka.  Goran Sajinovic was with me, and he behaved the same

17     as I did.

18        Q.   May I ask you, when Mr. Zupljanin made this comment to you,

19     Radule, it's a war, you said that you began crying.  But did you respond

20     to that statement that he made; and, if so, what did you tell

21     Mr. Zupljanin?

22        A.   I cannot repeat -- or I don't even want to remember the feelings.

23     But I remember insisting that something has to be done about it,

24     something -- some kind of reaction should come immediately.   I simply

25     believed that no game of soccer, even if it was world championships, can

Page 10877

 1     be more urgent than stopping this kind of criminal activities of people

 2     who were in Omarska and Keraterm.

 3        Q.   Well, did you think that -- that what happened in Omarska and --

 4     or did you tell them - Mr. Zupljanin and Mr. Bulic - that what happened

 5     in Omarska and Keraterm wasn't justified by this war?

 6        A.   Yes, I did.  If I my quote myself, which is something I don't do

 7     gladly, I reported it in one of my reports.  I even described it as

 8     genocide and fascist behaviour, the things that were happening in the

 9     camps.  I think can you find this report of mine.  I cannot find a more

10     serious word to describe the events than this one, especially in 1992.

11        Q.   Now, after this meeting that you had on the day that you visited

12     Omarska and Keraterm camps, did you speak with anyone in Belgrade about

13     the Omarska camp?  I think you mentioned yesterday a conversation you had

14     with Marko Lazarevic --

15        A.   Yes.

16        Q.   Was that around the time of this meeting?

17        A.   Yes, Mr. Prosecutor, but it's Marko "Lazovic," not "Lazarevic."

18     I had a word with him.  But before that, before I went to Keraterm and

19     Omarska, he had called me and told me that he had some information about

20     things happening in Omarska and Keraterm and that I should go and look

21     into it and then report to him.  And then when I returned, I first

22     informed him first verbally or, rather, over the phone, telling him what

23     was going on there, and then I put it into a report, a more detailed

24     report, where I repeated all I'd said on the phone.

25             After that, I went to Belgrade, where, together with other

Page 10878

 1     members of the Milos Group, I briefed, in detail, Mr. Marko Lazovic about

 2     all we've seen in the area of Omarska, Keraterm, and Prijedor.

 3        Q.   Did you also tell Marko Lazovic about how Mr. Zupljanin had

 4     reacted to the information that you had provided him about the camp -- or

 5     let me -- perhaps I should say lack of response?

 6        A.   I told him everything.  I didn't cover up anything just as I'm

 7     not covering up anything now, neither the reaction of Stojan Zupljanin

 8     nor the one of Djuro Bulic.

 9        Q.   Some days later, did you have another conversation with

10     Mr. Zupljanin about the detention facilities in Prijedor?

11        A.   Yes, I did.

12        Q.   And at that meeting with Mr. Zupljanin, what did he tell you?

13     What did he inform you?

14        A.   He told me he received information that indicate roughly that my

15     words, my -- what I told him was, indeed, so, and that a commission is

16     going to be formed that will go and see first-hand.  At the time, I

17     didn't know who will the members of the commission be, and later on I

18     found out who these people were, and I found out what their reaction was.

19        Q.   You said that Mr. Zupljanin had received confirmation of the

20     information you provided him.  Did he receive that from Vojin Bera?

21        A.   I'm not certain whether he received them from Vojin Bera.

22     However, being an operative, I looked into what information Vojin Bera

23     might have had.  And now I can say here, in front of all the people who

24     are here in the courtroom, Vojin Bera lied to Stojan Zupljanin - and this

25     is how we would put it in the Balkans - he lied to him about events in

Page 10879

 1     Omarska and Keraterm because he, among other things, claimed that what I

 2     wrote and reported wasn't true.  I would like to invite Vojin Bera to

 3     tell me where are the dead people I had seen, one among whom I could even

 4     identify, one of those people down there on the grass.  If he can bring

 5     that man back here to this courtroom, then I'm a liar.

 6        Q.   Now, who were the members of this delegation or commission that

 7     visited the detention facilities in Prijedor?

 8        A.   It was a combined delegation.  I know for a fact that

 9     Mr. Stojan Zupljanin was part of it, Mr. Predrag Radulovic, Dr. Vukic,

10     the man who was a self-proclaimed and duke, Vozd.  I think

11     Radoslav Brdjanin was there.  And a person from the area of Prnjavor; I'm

12     not concern about that.  A man who came to the fore in the political

13     leadership, either of Republika Srpska or Krajina.  I can't remember his

14     name; I do remember that he was a teacher of German language, and he

15     didn't even have qualifications for that.  I guess he might have worked

16     in Germany before and that's why they employed him because they didn't

17     have qualified people to employ.

18        Q.   This commission that consisted of Dr. Vukic and

19     Radoslav Brdjanin, amongst others, did you later arrive at any

20     conclusions about why this commission was formed?

21        A.   No.  It boiled down to just me knowing that the commission was

22     established and that they went to see what was going on in Keraterm and

23     Omarska.  I -- I used to live above the flat of Mr. Radic, Predrag Radic,

24     and we called each other neighbour.  This is something that people do in

25     the Balkans when we want to establish and show that we're on friendly

Page 10880

 1     terms.  Mr. Radic took me to his apartment, to a room of his, and he was,

 2     at the time, preparing his doctor's dissertation and he told me, This

 3     what I have seen is much worse than what you've told us.  I don't know

 4     what he had seen.  He described some of the scenes, and he was quite

 5     depressed after that.

 6        Q.   You didn't mention Predrag Radic is amongst this delegation.

 7     First of all, is he the mayor of Banja Luka and also he was part of this

 8     delegation that went to the camps?

 9        A.   That's correct.  He was the mayor and he did go, according to my

10     information, together with a group up there.

11        Q.   And did he tell you anything he observed about what Dr. Vukic was

12     doing while they were visiting the camps?

13        A.   Yes, he did.  He told me that Dr. Vukic had forced some of the

14     prisoners to raise three fingers up and to sing pro-Serbian or

15     pro-Chetnik songs.  And than didn't surprise me much because I believed

16     he was a madman.  Nothing Dr. Vukic would do wouldn't surprise me.  I was

17     an intelligence officer, and I kept gathering information about people

18     who were of intelligence interest.  And if I would present you with a

19     true picture of Dr. Vukic, you'd be surprise that he had could find his

20     place anywhere expect in the mad house.

21        Q.   [Previous translation continues] ... that's fine.

22             MR. OLMSTED:  Let's take look at 65 ter 2347.

23        Q.   Now, you had an opportunity to look at this article during your

24     interviews as well as, I think, again during proofing.  And it's an

25     article from the Kozarski Vjesnik newspaper entitled:  "It's Difficult

Page 10881

 1     for Everyone."  And it's dated 17 July 1992.  This article reports on a

 2     visit to Prijedor by Krajina representatives including Radoslav Brdjanin,

 3     Radoslav Vukic, Predrag Radic, and Mr. Zupljanin.

 4             Is this the delegation that you just were talking about that

 5     visited the camps?

 6        A.   Yes.  That's the delegation.  I don't remember this article in

 7     its entirety.  I don't know whether even I've read it or whether I was

 8     told about it about some of my associates.

 9             What I remember is that Radoslav Brdjanin claimed, among other

10     things, that that was the best example of proper behaviour or actions of

11     the authorities in Republika Srpska or local authorities.  In other

12     words, that the way they're acting in Prijedor should be a model for the

13     rest of Republika Srpska.  I don't remember this text really.  I don't

14     see it.  I do think that this text should contain a statement of Brdjanin

15     to that effect.

16        Q.   And I believe it does.

17             MR. OLMSTED:  If we can scroll down a bit in the English version.

18     I won't be able to identify in the B/C/S, but it says -- at the bottom

19     there, it says:

20             "This state of affairs in Prijedor is an example of a job well

21     done, and it is a real shame that there are many people in Banja Luka who

22     are still oblivious to this fact as well as to other things that might

23     happen in Banja Luka at any moment now."

24        Q.   Is that consistent with what you recall?

25        A.   You read from the text and, of course, you were closer to what it

Page 10882

 1     stated there than I did.  But, yes, that's the thing.

 2        Q.   How do you reconcile what the delegation statement says with what

 3     you observed at the camps?

 4        A.   Well, it was obvious to -- it is obvious to anyone that our views

 5     were completely opposite.  Nothing from this address made by

 6     Radoslav Brdjanin can be compared or be identical to the materials that I

 7     wrote.

 8             However, after this, I found out who briefed the delegation, who

 9     had briefed the delegation, who took part in briefing the delegation, and

10     I'm not surprised at all that there is such a difference between what I

11     told the delegation and what this other group briefed them on.  Because

12     they were briefed by Simo Drljaca and Vojin Bera, and I cannot see how

13     the reports could have been at all similar, because I used my eyes and my

14     reason to view things, whereas these others probably used some other

15     means, and that's where the problem is.

16             MR. OLMSTED:  May this document be admitted into evidence?

17             MR. KRGOVIC: [Interpretation] Your Honours, the witness did not

18     confirm ever having seen or read this article and then our constant

19     objection concerning introduction of articles that have nothing to do

20     with the testimony here.

21             MR. OLMSTED:  First of all, Your Honours, this has been -- unless

22     it's not an issue.  But this has been admitted in Stakic and in Brdjanin.

23     This witness was able to confirm that this is the delegation and also

24     what was said by the delegation or at least by Brdjanin that is very

25     consist with this document, and I think it corroborates what he's

Page 10883

 1     testifying about.

 2             MR. KRGOVIC: [Interpretation] But what good is the article then?

 3             Under Rule 92 quater there was a decision concerning Mr. Radic,

 4     and there is also the testimony of this witness, what he stated.

 5             JUDGE HALL:  The -- I was going to ask, Mr. Krgovic, whether

 6     the -- notwithstanding the minimal connection between the present witness

 7     and the article, isn't the article admissible on its own?  As I

 8     understand the Rules.  Yes.

 9             Admitted and marked.

10             THE REGISTRAR:  As Exhibit P1378, Your Honours.

11             MR. OLMSTED:  Let's look at 65 ter 527.

12        Q.   Mr. Radulovic, can you confirm, is this one of your team's

13     reports?

14        A.   Yes.

15        Q.   This report is dated 22 August 1992.  And it reports that a large

16     number of Muslim citizens were killed the previous night in

17     Koricanske Stene in Skender Vakuf area.

18             It says it's insufficiently verified.  Were you able to verify

19     this information as well as obtain additional information about this

20     incident?

21        A.   Your Honours, the information which is -- you see in front of

22     you, I wrote on the following day.  That is -- that means that this was

23     the first information about the event concerned.  Because we had learned

24     that during the previous night a massacre had been carried out against

25     civilians at Koricanske Stene.  We later verified the event, and I

Page 10884

 1     discussed it most with the Zivko Bojic, a member of the SJB who, among

 2     others, at the time was chief of the crime investigation service.  As far

 3     as I know, he was charged with or he had charged somebody with dealing

 4     with this incident.

 5             We had a lot of information.  On the same day, we learned that

 6     208 Bosniaks had been killed at Koricanske Stene, and we also learned

 7     about the cruel way they were killed.  Of all this, I informed

 8     Nedeljko Kesic, my chief of SDB, at first orally.  We also wrote about it

 9     later.  But this was the very first information that the service had.

10             Before this, all this is an very short report, neither of SDB nor

11     the SJB had any information about it.  So the managers at the CSB didn't

12     know about it, as far as can I tell.

13        Q.   According to the information you were able to gather, who were

14     the perpetrators of this crime?

15        A.   The members of the active and reserve police of the police

16     station in Prijedor.  It is possible that there was -- there were people

17     among them who were not officially active-duty or reserve police

18     officers, but most of them were.  The unit was the size of a platoon.

19     That's what it's called also, a manoeuvre platoon.  They were all

20     individually identified, so the identity of the executioners is known.

21     It is known who killed the Bosniaks at Koricanske Stene.

22        Q.   Did you ever see anything in writing around this time-period

23     containing the names of the perpetrators?

24        A.   Yes.  For the first time, I saw it when Zivko Bojic showed it to

25     me.

Page 10885

 1             If you're interested, I can add that I know that the

 2     then-minister of the interior demanded additional information about it.

 3     He wanted people to be interviewed and be brought in.  He wanted those

 4     people to be held responsible for the deeds.  I know that the chief of

 5     the centre -- or, rather, the police station at Prijedor, what kind of

 6     communication they had with the ministry.

 7             I -- as far as I know, Mico Stanisic was the minister of the

 8     interior at the time, and he sent out a circular, circular dispatch,

 9     demanding that all perpetrators be held responsible.

10             I repeat that, at the time, I had much contact with Zivko Bojic,

11     as one of the most experienced officers of public security.  He was a

12     true professional, a fair man.

13        Q.   [Previous translation continues] ...

14        A.   And he didn't misunderstand my interest in the matter.

15        Q.   We're going a little bit off topic here.  Let me get you back on.

16             You did mention that the minister of interior had requested

17     information about this killing incident.  Did you provide the minister

18     with more information about the killings?

19        A.   I gave additional information directly to Zivko Bojic.  I don't

20     know how you will understand it.  But I and Zivko Bojic had good

21     relations.  I gave him all the information that I had because I knew that

22     he would forward it to the higher level institutions or officials.

23             The service was not supposed to investigate, go to crime scenes,

24     carry out on-site investigations, and the like.  So all the information

25     that I had collected, I gave to Zivko Bojic, and I saw how Zivko Bojic

Page 10886

 1     presented that to the minister of the interior.  I know about the dilemma

 2     the man was in, about the event itself.  I think that he was reluctant to

 3     accept that on-site investigations be conducted in that manner, so he

 4     wanted to have his staff do it, because he didn't approve of the methods

 5     of work.  There was some sort of disagreement about it.  He wanted an

 6     investigative judge to go there, the crime investigator, then a forensic

 7     expert; and I believe that's where the disagreement -- how the

 8     disagreement arose.

 9        Q.   Can you tell us, why did you believe that Zivko Bojic -- well,

10     let me ask you this:  You said that you saw that Mr. Bojic provided the

11     information to the minister.  Can you tell us how did Mr. Bojic provide

12     that information to the minister?  Did he do it over the phone, did he

13     use -- did he write a dispatch, or did he go to Pale?  How did he get

14     that information to the minister?

15        A.   As far as I know, he related it to the minister in writing, which

16     was by the rules.  Whether or not he had contact with the minister apart

17     from that, such as phone conversations, I don't know.  But I do know,

18     because I saw, that much evidence was collected about the event to start

19     the process of clarifying what had happened.

20        Q.   You mentioned that Mr. Bojic was displeased with how the

21     investigation, the on-site investigation, was being conducted.

22             Can you tell us, what happened to the evidence at the scene of

23     the crime?  Was there anything that happened to it that -- during that

24     time-period?

25        A.   Yes.  I know about it, and we wrote about it.

Page 10887

 1             At the level of Kotor Varos municipality, a team was set up which

 2     removed the bodies of the killed Bosniaks.  The team was headed by the

 3     current chief of Skender Vakuf municipality whose last name is Vukovic, I

 4     believe.

 5        Q.   Just to clarify the record, I think you mentioned this that team

 6     was established at the level of Kotor Varos municipality.  Was it, in

 7     fact, Skender Vakuf municipality?

 8        A.   What did I say?  Kotor Varos?  I apologise.  I maid a mistake

 9     because formerly Skender Vakuf -- or, rather, that part where Koricane is

10     belonged to Kotor Varos.  Actually it's the Skender Vakuf municipality.

11     And the chief of Skender Vakuf municipality is Mr. Vukovic today, and he

12     was the head of the team which removed the bodies of the killed Bosniaks

13     from the area of Prijedor.

14             I apologise.  I mixed up the names.  The places are close, so I

15     made a mistake.

16        Q.   No problem.  This team, were there police officers on this team

17     to remove the bodies?

18        A.   Yes.

19        Q.   Now, you mentioned that you reported all this information about

20     the Koricanske Stene incident to Mr. Kesic.  Did you also report all this

21     information to Mr. Zupljanin?

22        A.   Yes.  I really don't remember.

23        Q.   Well, I say that you did, in your written statement, say you did.

24     Do you want to refer to that to refresh your recollection?

25             MR. KRGOVIC:  I'm really -- this practice must be stopped.

Page 10888

 1             JUDGE HALL:  Yes, Mr. Olmsted.  But the damage has been done.

 2     Let's move on.

 3             MR. OLMSTED:  I'm not sure what the damage has been done.  He

 4     says -- his response was:  "Yes."  And then there was a significant

 5     pause, and then he says:  "I really don't remember."

 6             Now, I asked him if he wants to look at his statement to refresh

 7     recollection because he doesn't remember.  It doesn't -- I'm not sure how

 8     this is an issue.  I just want him to be more confident in his answer.

 9             JUDGE HALL:  I -- what I heard you to be saying was to actually

10     tell the witness what he had said in his written statement.

11             Let's move on.

12             MR. OLMSTED:  If he looks at his statement he can confirm whether

13     it is.  I apologise -- [Overlapping speakers] ...

14             JUDGE HALL: [Overlapping speakers] ... statement, yes --

15             MR. KRGOVIC: [Interpretation] [Overlapping speakers] ...

16             MR. OLMSTED:  But can we have him look at his statement and see

17     if he can give us a definite answer --

18             MR. KRGOVIC:  No.

19             MR. OLMSTED: -- because this is an important issue?

20             MR. KRGOVIC:  No, Your Honour.  It's not acceptable.  You have a

21     ruling about that --

22             JUDGE HALL:  But I thought we had moved on from this point

23     because the -- however unfortunate the question and answer may have been

24     put, it's been asked and answered.

25             Let's move on.

Page 10889

 1             MS. KORNER:  Your Honours, I'm sorry -- I'm sorry to overtake --

 2             JUDGE HARHOFF:  [Microphone not activated] ... one minute.

 3                           [Trial Chamber confers]

 4                           [Prosecution counsel confer]

 5                           [Defence counsel confer]

 6             JUDGE HALL:  Ms. Korner, you --

 7             MS. KORNER:  Can I ask to be very briefly heard on this matter.

 8     First of all, it's not proper for Mr. Krgovic to leap up and yell, No.

 9     He's supposed to be making an application to Your Honours not to allow

10     this.

11             Your Honours, this is something that is clearly a matter of some

12     importance.  And it's something that clearly we ought to sort out, and it

13     ought to be something that is not here while the witness is listening to

14     it.  Taking his earphones, unfortunately, doesn't help off -- doesn't

15     help because the translation is still continuing through the earphones.

16             I really do think that the time has come, when, as you say, it's

17     interrupting the proceedings, and we really must explain exactly why

18     we're asking the witness to do this.

19             JUDGE HALL:  Well, the -- where we are at procedurally, as I

20     understand it, is that -- and I thought that we had, at least on two

21     occasions that this had been gone into yesterday, I thought that everyone

22     understood.  There is no objection -- that's overstating it.  In the

23     Chamber's view, it is permissible for the witness on the stand,

24     particularly having regard to the complexity probably isn't the right

25     word, but how long the -- the period of time that has passed since these

Page 10890

 1     events and the details which the evidence, particularly of this witness,

 2     involves, for a witness to be invited - I indicated yesterday that I --

 3     and I'm used to it being the other way, but I have no difficulty with the

 4     witness being invited even by counsel who is leading him to look at his

 5     written statement and then be asked the question again.

 6             The reason why -- for the purpose of refreshing his memory.  The

 7     document does not become an exhibit.  The reason why I have adopted the

 8     practice of looking in the direction of the Defence is because I do not,

 9     with respect, Ms. Korner, agree that Mr. Krgovic is merely interrupting

10     the proceedings.  As I understand the position that he is -- he, at

11     least - I'm not so sure about the Stanisic Defence - has consistently

12     taken is that he objects to this and, therefore, for -- to preserve the

13     consistency of his position he would probably wish to have his objection

14     on the record.

15             But notwithstanding that - and in my view he is entitled to have

16     that objection registered in each case, notwithstanding the path that has

17     been laid out in terms of the -- of how we are approaching it.  What

18     occurred in this case is that counsel for the Prosecution, as it were,

19     leapt over the step of having the witness refresh his memory and gave the

20     answer.  And that is why I use the phrase "the damage having been done."

21     I didn't mean it in any large sense because to my mind it's a relatively

22     small point because had the -- had the intermediate step been taken by

23     Mr. Olmsted, we would have been exactly where we are now.

24             MS. KORNER:  Your Honours, can I say straightaway, then, Your

25     Honours, we accept that.  As Your Honours have pointed out, this witness

Page 10891

 1     made a lengthy and extremely detailed statement based on - and can I just

 2     emphasise this - based on answers that he gave over a -- in a number of

 3     interviews over a long period of time.

 4             So -- and the statement was simply a method hopefully of dealing

 5     with the Rule 92 application, Rule 92 ter application.

 6             So, Your Honours, are quite right.  What my objection to

 7     Mr. Krgovic's objection is he is perfectly entitled each time to register

 8     an objection.  What we say he is not entitled to do is to leap to his

 9     feet and say, No.  Can he say to Your Honours, Your Honours, I want to

10     register my objection; and that's it.  But he's aptly, at the moment,

11     directly addressing counsel and shouting, No.  And that, apart from

12     anything else, puts the witness off.

13             Your Honours, so -- but, Your Honours, we absolutely agree.  If

14     Your Honours are -- if -- provided we follow a procedure, namely that we

15     invite the witness to refresh his memory by looking at his statement and

16     then asking him whether he wants to reconsider his answer.  We accept

17     that's the proper way of doing it.

18             MR. ZECEVIC: [Interpretation] Your Honours, I would like to state

19     for the record that the Stanisic Defence supports the objection of the

20     Zupljanin Defence.  Only we have risen so far because we see no point in

21     repeating the same objection as my -- as the other Defence.

22             I completely agree with the analysis of His Honour Judge Hall.

23     If Mr. Olmsted had proceeded the same way as yesterday, that is, asked

24     the witness whether he wanted to refresh his memory and take a look at

25     the statement and then ask his question again, it would have been all

Page 10892

 1     right.  By the way it is, I think this is a matter that has been

 2     resolved.

 3             And on a different note, I believe it is improper for Ms. Korner

 4     to address Mr. Krgovic in this way because Ms. Korner has risen during

 5     this trial at least five times and said, No, or something along those

 6     lines.  So I believe we should have the same rules for everybody, and

 7     we all -- we should all be responsible for what we did.

 8             MR. KRGOVIC: [Interpretation] Your Honours, I would like to add

 9     something.

10             The problem I have with the statement - and I do not rise often

11     to object - is the way how this case is presented and how this witness is

12     led.  This is not an authentic statement of this witness given

13     immediately after the events or concerning an earlier time-period about

14     which he had a fresh recollection.  This is literally a compilation of

15     the OTP taken out of the context, that is, fragments taken out of the

16     context, and they serve to delude the witness into believing that

17     something is the way it was not.

18             The question was about the reports that supposedly went to

19     Mr. Zupljanin, and this is a -- the essence of my objection.  The OTP is

20     trying to introduce through the back door the assertion that this is

21     immediate knowledge about Mr. Zupljanin's behaviour.  When the witness

22     says that he informed Mr. Zupljanin, sometimes he means that informed him

23     directly, sometimes he means that he wrote reports.  And the OTP is

24     trying to elicit the answers that are suitable to them.

25             MS. KORNER:  [Previous translation continues] ...

Page 10893

 1             JUDGE HALL:  Mr. -- Ms. Korner, Mr. Krgovic, I admit that in

 2     terms of my own education in the procedure of this Tribunal the meaning

 3     of contemporaneity has had to be expanded.  Nevertheless, the -- the

 4     issues which you identify, to the extent that it creates a problem, I

 5     would have thought would have been -- could be dealt with by you in

 6     cross-examination.  And there the matter should end.

 7             MS. KORNER:  Your Honour, can I say this is the second time,

 8     first of all, none of this should have been said in front of the witness.

 9     Your Honours, if it comes to it, we may have to inform Your Honours what

10     happened at the proofing session.  However, the point is that very have

11     available for Your Honours to see the taped records of the interviews

12     that were conducted with this witness so that Your Honours can see that

13     contrary to the suggestion that is constantly being made by Mr. Krgovic

14     that we are putting words into the mouth of this witness, these are words

15     that he himself used during the course of the interview in response to

16     open questions.

17             JUDGE HALL:  Thank you.  Could we move on, please.

18             MR. OLMSTED:  Yes, Your Honours.  But, please, I do apologise for

19     the form of my question.  But since we're only dealing here with an

20     answer he gave and then a qualification he gave after it, can he please

21     try to refresh his recollection and see if his recollection is stronger.

22     That was the point of my question, is to see whether he could give more

23     of a definitive answer after he looked at his report.  I did not mean to

24     in any way suggest to him that he was not telling the truth or anything

25     to that regard.

Page 10894

 1             JUDGE HALL:  I didn't have that impression, Mr. Olmsted.

 2             MR. OLMSTED:  Thank you.

 3        Q.   Mr. Radulovic, I apologise for all of this back and forth.

 4             You said that you informed Zupljanin but then -- I think you

 5     commented that you weren't quite sure.  Could you take a look at your

 6     written statement at paragraph 156.

 7             And if could you just read that to yourself; and after you're

 8     done, I will just ask you the question again.

 9        A.   Yes, I can.

10        Q.   Very good.  Having reviewed this paragraph, does that refresh

11     your recollection whether you had informed Mr. Zupljanin about what you

12     had learned about the Koricanske Stene incident as well as everything

13     else that you had learned about what was going on after it?

14        A.   I remember that I spoke to Mr. Stojan Zupljanin about

15     Simo Drljaca, and it's exactly as it says in my shortened statement.

16     Stojan Zupljanin said to me that Simo Drljaca had great influence in the

17     Prijedor area and that he had a good standing with the politicians and

18     the army; also, that any involvement of his, namely, the CSB of

19     Banja Luka, along the lines that we suggested, could result in problems

20     in Prijedor.  That is, undesirable consequences.

21             Having read this, I would now say that my statement referred to

22     the overall situation in and around Prijedor; of course, also, with

23     regard to Koricanske Stene.  But I couldn't say in front of this

24     Trial Chamber what exactly it was that Stojan Zupljanin answered to me

25     with regard to Koricanske Stene specifically, or, to put it this way,

Page 10895

 1     after the massacre at Koricanske Stene.  I think that he spoke about the

 2     overall situation regarding Simo Drljaca and Prijedor.

 3             MR. OLMSTED:  May the document that's before us be tendered into

 4     evidence.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  As Exhibit P1379, Your Honours.

 7             JUDGE HARHOFF:  Mr. Radulovic, before we move on to something

 8     else, which I think the Prosecution was aiming to do, I'd like to ask you

 9     if any investigation of the Koricanske Stene incident was -- was ever

10     made?

11             I mean, you told us that there was a team established to remove

12     the bodies from the scene, and -- and so my question is: Was that it?

13     Did anything happen later on to identify the perpetrators and -- and have

14     them prosecuted or ... or was that the end of the story?

15             THE WITNESS: [Interpretation] Briefly, Mr. Vukovic, who contacted

16     the so-called sanitisation of the area, was a member of civilian

17     authorities, as far as I know.  He was chief of civil protection in

18     Skender Vakuf municipality.  Together with the assistance of the police

19     from Skender Vakuf and some workers or those who had been mobilised into

20     civilian defence, he removed those bodies.

21             As for the identification of persons who committed the crime,

22     Your Honours, each individual's was established when it comes to the

23     workers of the public security service, as well as those who were present

24     but were not workers of the SJB.  By this I mean drivers who drove buses

25     and trucks that had brought Bosniaks to the execution site.

Page 10896

 1             There were even some individuals who were members of the

 2     Army of Republika Srpska whose identity was established as well.  I know

 3     this for a fact because I saw the dispatch in which the minister of the

 4     interior of Republika Srpska - at the time it was Mico Stanisic - ordered

 5     to conduct an investigation, to conduct interviewing, and to bring to

 6     responsibility those who were responsible.

 7             I also know for a fact that someone on behalf of the police

 8     station in Prijedor replied along the lines that all of those who were

 9     present at Koricanske Stene and who were members of the public security

10     service were sent somewhere to the front line.  I think to the area near

11     Han Pijesak, Han Kolo [phoen], around that area.  And that since they

12     were now at the front line, it was impossible to get in touch with them

13     and bring them in for questioning.

14             This is all I know about the steps that were taken.  But as far

15     as I know - and I know this with rather great certainty - during the war,

16     no proceedings were instituted by police against those people who had

17     committed that -- that crime and who belonged to the public security in

18     the sense of establishing their criminal responsibility, disciplinary

19     responsibility, or any other sort of responsibility.

20             JUDGE HARHOFF:  So, if I understand you correctly, the minister,

21     Mico Stanisic, ordered that the perpetrators be brought to justice; is

22     that correct?

23             THE WITNESS: [Interpretation] Exactly so.  And I saw that in

24     writing.

25             JUDGE HARHOFF:  And despite the minister's order, the only thing

Page 10897

 1     that happened was that the perpetrators was discharged from their police

 2     duties and sent to the front line; is that correct?

 3             THE WITNESS: [Interpretation] I'm not sure that they were

 4     discharged.  They were simply sent to the front line as members of police

 5     force.  So no proceedings were launched against them in order to

 6     terminate their employment, as far as I know.

 7             JUDGE HARHOFF:  Do you know if they returned to Skender Vakuf?

 8     Or to the places that they came from?

 9             THE WITNESS: [Interpretation] They belonged to the

10     Prijedor Police Station.  I know that most of them were returned back to

11     the service, to police force in Prijedor.  And some of them, to my

12     knowledge, work there in Prijedor to this day.

13             JUDGE HARHOFF:  Thank you very much.

14             MR. OLMSTED:  May we look at 65 ter 543.

15        Q.   And, Mr. Radulovic, if you can take a look at this.  Is this the

16     order from Mr. Stanisic that you're referring to about the

17     Koricanske Stene killings?

18             And it's in the middle of the page.  I know the order -- this is

19     an 11 September 1992 dispatch and it starts out with something from the

20     chief of the CSB, but then, below that, there is something from

21     Minister Stanisic.

22             Do you see that?

23        A.   Yes, yes.  That's what I saw.  And as far as I know, this is not

24     the only document I saw pertaining to this events at the level of

25     communication between the ministry and the CSB and Prijedor.

Page 10898

 1             As far as I know, there were some additional requests sent out by

 2     the minister and the ministry relating to the task of identifying and

 3     prosecuting those who had participated in the massacre.

 4             MR. OLMSTED:  May this document be admitted into evidence.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  As Exhibit P1380.

 7             MR. OLMSTED:  Can we have on the screen 65 ter 2839.  But this is

 8     subject to protective measures, so if we could do it in private session.

 9             JUDGE HALL:  We move into private session.

10                           [Private session]

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10899











11 Pages 10899-10902 redacted. Private session.















Page 10903

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14                           [Open session]

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

16             MR. OLMSTED:

17        Q.   Mr. Radulovic, is this one of your team's reports?

18        A.   Yes.

19        Q.   If you could just take a read of the document.  It's a very short

20     one.

21             Oh we can -- [Microphone not activated]

22        A.   "We hereby confirm that Bozovic and his group are being

23     active" --

24             Shall I continue?

25        Q.   Actually I just meant for you to read it to yourself.  I just

Page 10904

 1     want to ask you some questions about --

 2        A.   [In English] Okay.

 3        Q.   It's a report dated 3 July 1992.  How were you able to confirm

 4     that Radojica Bozovic or Radomir Bozovic - whichever his first name

 5     was - and his group were active in coordinated fashion linked up to the

 6     RS MUP and your centre?  How were you able to confirm that?

 7        A.   Very simply.  I had three conversations with Radojica Bozovic.

 8     One of them took place at the Borija mount, the second one in Teslic, and

 9     the third one in Doboj.  Or, rather, the first one was in Doboj, and then

10     at Mount Borija, and then in Teslic.

11             I personally met Radojica Bozovic or, rather, I personally told

12     Radojica Bozovic that was what was happening in Doboj, what was being

13     done by local criminals, were very often attributed to him and the

14     Red Berets members.  And I informed the MUP of Serbia about it.

15        Q.   [Previous translation continues] ... I want to keep on topic of

16     my question.  I think you mentioned this earlier in your testimony, your

17     conversations with Mr. Bozovic.  Can I confirm that it was from

18     Mr. Bozovic yourself that you were able to establish this link between

19     him and the RS MUP, that they were coordinating their activities?

20        A.   Yes, I can because I know that the Doboj CSB headed by

21     Andrija Bjelosevic was in contact with the group of Radojica Bozovic, and

22     Bozovic actually worked on training with the knowledge and consent of

23     Andrija Bjelosevic.

24        Q.   May we have on the screen 65 ter 2836.

25             MR. OLMSTED:  I see it's break time.  Maybe we should take a

Page 10905

 1     break here then.

 2             JUDGE HALL:  We'd resume in 20 minutes.

 3                           [The witness stands down]

 4                           --- Recess taken at 10.24 a.m.

 5                           --- On resuming at 11.01 a.m.

 6             MR. ZECEVIC:  Your Honours, I'm sorry, just for the purposes of

 7     transcript, on page 30, line 2, I said I withdraw my "intervention" not

 8     "interrogation."  Thank you very much.

 9                           [The witness takes the stand]

10             MR. OLMSTED:

11        Q.   Mr. Radulovic, what we have in front of us is 65 ter 2836.  It's

12     a report dated 26 June 1992.  Is this one of your reports?

13        A.   Yes.

14             MR. OLMSTED:  Unless Your Honours have any questions regarding

15     it, I will seek to tender it into evidence.

16             JUDGE HALL:  Admitted and marked.

17             THE REGISTRAR:  As Exhibit P1382 Your Honours.

18             MR. OLMSTED:

19        Q.   Yesterday, Mr. Radulovic -- sorry.

20             JUDGE DELVOIE: [Microphone not activated]

21             MR. OLMSTED:

22        Q.   Mr. Radulovic, yesterday you mentioned two Bosnian Croat police

23     officers who were among the victims of the Banja Luka Special Police

24     Detachment and Red Berets in Doboj in 1992.  What about the former deputy

25     chief of SNB, Mato Krzic; did anything happen to him?

Page 10906

 1             MR. KRGOVIC:  I object to that.  It's mis -- misleading.  He

 2     didn't mention that there was a victim committing a crime by the

 3     Banja Luka Special Unit.

 4             MR. OLMSTED:  Yesterday he did mention two names.  I can look

 5     them up, if it is necessary.  But he did mention two individuals; Garic

 6     and -- there was another one that I can't recall.

 7             MR. KRGOVIC:  Yes, his name but not who committed the crime, that

 8     it was the special unit.

 9             MR. OLMSTED:  Well, then we'll clarify that matter very quickly.

10        Q.   Mr. Radulovic, yesterday you mentioned two Bosnian Croat police

11     officers who were victims in 1992 of what was happening in Doboj.  Can

12     you tell us who were the perpetrators of the crimes that were against

13     them?

14        A.   They were members of paramilitary formations active in the area

15     of Doboj.  I can tell you the names of these paramilitary or para-police

16     formations, but I never did say that these two persons were victims of

17     the actions of the workers of the special detachment from Banja Luka.

18             These gentlemen were Mr. Karlo Grgic who was the commander of the

19     police station in Doboj; he was killed.  And Dr. Ilija Tipura, former

20     chief of the CSB in Doboj, who died after he was mistreated.  And

21     Karlo Grgic was killed.  These men weren't the only victims.

22        Q.   And --

23        A.   I knew the two men really well.

24        Q.   And what about Mato Krzic?  Did anything happen to him?

25        A.   Yes.  Mato Krizic, yes, Krizic, he was arrested.  He was under

Page 10907

 1     surveillance of the National Security Service employment.  They started

 2     interrogating him, they mistreated him, and that was something that

 3     prompted us to ask the chief of the CSB at the time to take all measures

 4     necessary to protect our former employees of other ethnicities, all in

 5     order to ensure that they can leave the area of Banja Luka if they

 6     wished.  And it was done that way, this -- the Milos Group felt obliged

 7     to assist our former employees to leave Banja Luka if they wished to.

 8        Q.   You mentioned that you knew who the perpetrators of these crimes

 9     against these former police officers were.  Could you provide us who they

10     were?

11        A.   I can tell to which groups the perpetrators belonged.  I cannot

12     give you the names of actual individuals who committed all these acts.

13     But I can tell you which groups did so.

14             In Doboj, there were, according to my information, five to six

15     criminal groups.  Public knew about them.  Some of the members of these

16     groups have been tried for the war crimes they committed.

17        Q.   Did those groups include the Red Berets?

18        A.   No.  I do not have information that members of the Red Berets

19     were involved in eliminating either our former employees of other

20     ethnicities.  I have information about Red Berets but the Red Berets from

21     Belgrade, if that's who you're referring to.

22             So these Red Berets were in Doboj to provide training.  But if

23     you are talking about the Red Berets from Doboj, yes, then you're right,

24     these were the members of Red Beret on the local level, from Doboj, who

25     wanted to have people identify them with this group of Red Berets from

Page 10908

 1     Belgrade to exaggerate their importance.

 2        Q.   I want to clarify your last answer.

 3             You mention the Red Berets.  Did this Red Beret organisation

 4     include both persons from Serbia as well as locals that were from Doboj?

 5        A.   Let me repeat:  Within Doboj, there were Red Berets, people who

 6     called themselves Red Berets because they wore just these red hats,

 7     imitating the Red Berets from Belgrade.  So these members of the local

 8     Red Berets committed crimes in the area of Doboj; and our group,

 9     Milos Group, had information confirming that they were also involved in

10     eliminations of people.  I mentioned two crimes, two killings, that

11     involved two of our former employees, Karlo Grgic and Ilija Tipura.

12        Q.   During May 1992, were non-Serbs being arrested and brought to the

13     CSB Doboj building?

14        A.   Yes, they were.  Unfortunately, I must say that members of a unit

15     called special unit of the CSB also took part in bringing people in.

16     This unit was engaged there, I assume, on a basis of some kind of

17     arrangement that they were sent there because, possibly, it was of

18     strategic importance for them to be there instead of being in Banja Luka;

19     I don't know about that.  But we did notice members of this special

20     detachment from Banja Luka who committed crimes together with members of

21     these criminal groups and organisations of the local nature.

22        Q.   You said:  Unfortunately there was a special unit, the CSB

23     Banja Luka Special Police Detachment, at the CSB building, bringing

24     non-Serbs there after their arrest.

25             Why do you say "unfortunately"?  What happened to these non-Serbs

Page 10909

 1     once they were at the CSB building?

 2        A.   Mr. Prosecutor, what other term should I have used instead of

 3     "unfortunately"?  What I'm saying is that I am sorry that people from the

 4     CSB were committing such things, people who had worked in the same CSB as

 5     I did.  That's why I said "unfortunately" because these people were

 6     responsible for horrendous crimes, primarily physical mistreatment, let

 7     alone crimes that involved stealing valuables from those who were not of

 8     Serb ethnicity.

 9             During the days of their withdrawal from Doboj, they were taking

10     out items stolen, and it took them days to do it.  There were cars and

11     such.  They also looted shops and storage facilities and so on and so

12     forth.

13        Q.   [Previous translation continues] ... that's fine.  Let's get back

14     on -- to my question.

15             Besides members of the CSB Special Police Detachment, were any

16     other persons associated with the police, state security or public

17     security, bringing non-Serbs to the CSB building?

18        A.   Members of the national security and public security service from

19     Banja Luka who were assigned to assist the Doboj service.  What I know is

20     that the employees of the National Security Service did not take part in

21     bringing in people.  They only conducted interviews.  I do know that they

22     reacted to the condition of the people being brought in.  Quite -- they

23     made quite a lot of noise about it because these people were in terrible

24     states.  An investigation was carried out for several days, especially in

25     relation to Mr. Grgic and Mr. Tipura because these people had been

Page 10910

 1     employees of the security service.  I personally believed that these

 2     people need to be protected, that they need to be assisted, and that was

 3     why I asked --

 4        Q.   [Previous translation continues] ...

 5        A.    -- for them to be assisted.  And I would like to correct

 6     something.  It's not "Grgic."  I said "Krizic," "Mato Krizic."

 7        Q.   Okay.  Thank you.  But please, I want you to focus on my

 8     questions because I do have very much limited time now.

 9             Is what about Slobodan Karagic?  Was he bringing anyone to the

10     CSB Doboj building -- any non-Serbs to the CSB Doboj building?

11        A.   Slobodan Karagic, you mean?

12        Q.   Yes.

13        A.   Yes.

14        Q.   And what was he doing with the non-Serbs he brought to the CSB

15     building?

16        A.   He and the likes of him involved in mistreatment of these people,

17     and usually the victims of such mistreatment would be passed on to people

18     from national security for an interview.

19        Q.   Slobodan Karagic, what position did he have within the MUP?

20        A.   As far as I know, he was in possession of an ID document of the

21     National Security Service.  I know that because my group had arrested him

22     on one occasion, and we found among his possession this official ID, and

23     I even remember who signed this ID.  It was signed by Milan Savic.

24     Milan Savic was, at the time, deputy chief of the security service in

25     Doboj.  In other words, deputy to Andrija Bjelosevic.

Page 10911

 1        Q.   You mentioned Milan Savic.  During this May time-period, was he

 2     involved there arresting non-Serbs and bringing them to the CSB building

 3     for interrogation?

 4        A.   No.  He was at a higher level, you see, he managed -- because

 5     prior to the war, he had been a driver, so he drove really fast and

 6     reached the position of the deputy chief of the security service.  He was

 7     a big boss.  It was more difficult to reach him than it was for the

 8     people who fought in the Second World War to storm a bunker.

 9        Q.   I would like to ask a few questions now concerning the

10     CSB Banja Luka Special Police Detachment and its activities in

11     Kotor Varos.

12             Can you tell us for how long did the detachment operate in

13     Kotor Varos?

14        A.   I think for about 20 to 30 days.

15        Q.   And who was leading the detachment -- the detachment during this

16     time-period?

17        A.   Ljuban Ecim.

18        Q.   And while the detachment was in Kotor Varos, where were they

19     based?

20        A.   They were based in the premises of a company, timber company.  I

21     can't remember the name of this company for timber processing.

22        Q.   Was that also known as the sawmill?

23        A.   Yes.

24        Q.   And what intelligence information did you receive about any

25     crimes committed by this detachment, in particular at the sawmill?

Page 10912

 1        A.   In a nutshell, they committed things that were committed in other

 2     area; physical mistreatment, killing of people even, looting.

 3             If you are interested in what they did in the sawmill; namely, we

 4     received information that they were bringing in women of Bosniak and

 5     Croat ethnicity and then raped them.

 6        Q.   Yesterday you mentioned that you talked with Mr. Zupljanin about

 7     the behaviour of the detachment members in Kotor Varos.  Did you also

 8     report these rapes to him?

 9        A.   I talked to him, and I told you already that Mr. Zupljanin was

10     concerned.  I don't think he received such information only from me.

11     From this point in time, I can say that I never covered up anything or

12     concealed anything, and I don't see why I wouldn't have told him about

13     rapes.

14        Q.   Do you recall whether he said anything to minimise your reports

15     in any way?

16        A.   Most often, during our conversations, and we didn't have that

17     many opportunities to talk, he would always use the same comment:  Well,

18     it's wartime.  Such things happen.  Those were his comments.  I cannot

19     quote literally every word of his.  I can't even repeat my own words.

20     This was 20 years ago.

21             But I do know he had been in Kotor Varos area, that he received

22     complete information not only from me but also from the chief Savo Tepic,

23     and I believe he also received a complete information, although a little

24     bit belatedly, from an operative of ours, Zdravko, who was together with

25     Pejic [as interpreted] at the time when the detachment was there.  The

Page 10913

 1     situation in Kotor Varos was rather difficult.  It was not only my

 2     qualification of the situation but also by the others who reported during

 3     that period.

 4        Q.   While the detachment was --

 5             MR. ZECEVIC:  I'm sorry.  Again, an intervention in the

 6     transcript.  I believe the witness gave the name of the operative that --

 7     Zdravko Pejic.  Yes.

 8             MR. OLMSTED:

 9        Q.   MR. --

10             MR. ZECEVIC:  If this can be clarified.

11             MR. OLMSTED:

12        Q.   Mr. Radulovic, you just heard what my learned friend raised.  Is

13     the name of one of the operatives Zdravko Pejic?

14        A.   Yes, that is correct.  I see mention only of chief Savo Tepic,

15     but I also mentioned Zdravko Pejic who was an active employee of the

16     National Security Service who was, according to establishment, chief of

17     the wartime department of National Security Service in Kotor Varos.  That

18     was his full title.

19        Q.   You mentioned -- -

20             MR. KRGOVIC:  I apologise, because in this -- in his previous

21     response missing is time-frame when the report by Zdravko Pejic was

22     submitted.

23             MR. OLMSTED:  Why don't you -- I don't --

24             MR. KRGOVIC:  He mentioned time-frame, but it's not recorded.

25             MR. OLMSTED:

Page 10914

 1        Q.   Mr. Radulovic, did you mention the time frame in which this

 2     report by Mr. Pejic was submitted?  Do you recall when that was?

 3        A.   I remember well having a conversation with Zdravko Pejic in

 4     relation to events in Kotor Varos, and, as a colleague, I asked him why

 5     hadn't he informed the service about it, referring to the

 6     National Security Service and the chief Stojan Zupljanin.  I remember

 7     well; he responded, You know what they're like.  And also cursed.  Among

 8     other things, he also said it would be good if you do it.  I don't know

 9     why he passed the hot potato to me, and I informed about information I

10     received not only from him but from others, the relevant people, and I

11     also know that immediately after that, he drafted a report and that only

12     after that Stojan Zupljanin went to Kotor Varos in relation to these

13     events.  And then I also know there was some meeting held at the police

14     station in Kotor Varos, and that's why I'm saying that it was not timely,

15     his report to Stojan Zupljanin and the leadership of the service, because

16     he had had such information prior to me.

17        Q.   Would this -- would these reports have been filed in the summer

18     of 1992?

19        A.   Yes, yes.

20        Q.   You mentioned that when you had this information with Pejic he

21     said, You know what they are like, when you asked him why hasn't he filed

22     his reports with Mr. Zupljanin and Mr. Kesic.  Did you understand what he

23     meant by "you know what they are like"?

24        A.   Yes, of course, I understood.  Some members of the special

25     detachments were feared by everyone.  They were so powerful that even our

Page 10915

 1     chiefs were afraid of them.  They will not admit that to you, but, yes,

 2     they were afraid.  I was also afraid.  I -- mostly because of the

 3     children, because of the threats, and their actions in relation to me and

 4     my colleagues.

 5        Q.   Well, I want to focus on that -- my question though.  You asked

 6     Mr. Pejic why he hadn't filed his reports with Mr. Zupljanin and

 7     Mr. Kesic and he responded, "You know what they are like."

 8             He was -- are you saying that he was referring to the special

 9     police detachment; or is he referring to Mr. Zupljanin and Mr. Kesic?

10        A.   No, no.  He was referring to the special police detachment when

11     he said "you know what they are like."

12             He meant that they would be ready to avenge themselves on him.

13        Q.   Now I understand, thank you.  Did your intelligence team gather

14     any information concerning what happened to the non-Serb civilian

15     populations in two villages, Vrbanjci and Dabovici [sic], in the summer

16     of 1992?

17        A.   I believe I understood your question even though you

18     mispronounced the name of the second village.

19             We wrote about it.  We wrote about it, sir.  About the problem

20     and what was happening in that area, what kind of crimes were being

21     committed.  But we didn't conduct individual investigations to find out

22     who had committed it and which individuals were involved.  There was much

23     crime, so it was difficult for a small group to be everywhere and clarify

24     everything to the full.  It wasn't our duty, nor were we able to do it.

25        Q.   Do you recall whether the special police detachment was involved

Page 10916

 1     in the attacks on those two villages?  And I'll repeat them:  Vrbanjici

 2     and Dabovci.

 3             Were they involved --

 4        A.   [No interpretation]

 5        Q.   Wait until I ask.  There's -- we're overlapping.

 6             Were they involved in those two attacks?

 7        A.   I apologise for interrupting.  I thought that you had finished.

 8     I said, Yes.  My answer is indeed affirmative.  Yes, they did take part

 9     in the attack on those villages.

10        Q.   And what happened to the non-Serb population in those villages?

11        A.   Most all of them were expelled in various ways.  Some of them

12     went to Bosniak-controlled territory on their own; some went in groups,

13     because they were let go; but some also came to harm.

14        Q.   And when you say "came to harm," does that mean they were killed

15     or beaten?  What happened to them?

16        A.   I meant the former.  They lost their lives.

17        Q.   And you included all this information in the reports you

18     submitted to your superiors?

19        A.   Mr. Prosecutor, everything can be found in my reports.  That is

20     why I bear no moral or other responsibility for repeating it today.  I

21     think it was much less safe to say that in 1992 because of my personal

22     safety and the safety of my family than it is today.

23             I stated everything I knew about these events in my reports.

24             MR. OLMSTED:  Let's take a look at 65 ter 10199.

25        Q.   This is an Official Note dated 3 November 1992 pertaining to the

Page 10917

 1     situation in the Vecici area of Kotor Varos, and it contains your last

 2     name at the top of it, amongst your other members of your group.

 3             Is this one of your reports?

 4        A.   Yes, it is.

 5        Q.   What information did you receive from your intelligence sources

 6     regarding negotiations with the Bosniaks in Vecici for their safe passage

 7     out of Kotor Varos?

 8        A.   A group of 500 to 700 armed members of the SDA safely reached

 9     Bosniak-controlled territory.  We even had information that they were --

10     they had their personal weapons on them.

11             We also had other information that is not contained in this

12     report because it seemed to suggest that these people had negotiated

13     their departure and paid large amounts of money to be let go.  We didn't

14     mention that in the report because that would point to a possible

15     involvement of our superiors in those negotiations.

16             So we didn't want to put a noose around our own necks.

17        Q.   According to your sources, who participated in the negotiations

18     amongst your superiors?

19        A.   Mr. Prosecutor, I know that Lieutenant-Colonel or Colonel - I'm

20     not sure of his rank at the time - Peulic must have been involved.  He

21     was a military officer.  There were indications that Mr. Stojan Zupljanin

22     was also involved, and that's why we omitted to include this information.

23             But let me add you -- add this:  We didn't keep completely silent

24     about it, because we submitted that to the bodies of military security,

25     the intelligence centre of the army headed by Branko Ratic of who we knew

Page 10918

 1     that he was very close to President Karadzic.  So we didn't keep that

 2     information to ourselves after all.  We passed it on, and we considered

 3     that this route was safer than the regular route that information should

 4     have been passed on.

 5        Q.   According to your intelligence information, what happened to

 6     those Bosniaks who could not pay the fee to have safe passage from

 7     Kotor Varos?

 8        A.   They stayed in the villages.  These were mostly elderly people,

 9     women, children, and their mistreatment continued.

10             A number of persons from that village was taken toward Siprag --

11     rather, Siprage; and before they reached that place, they were all

12     killed.

13             According to our operative intelligence, which can be seen, they

14     numbered about 70 people.

15        Q.   You mentioned Siprage.  Is that -- was that in relation to

16     Grabovica?

17        A.   Yes.  It was done in the hamlet of Grabovica, but it is close to

18     the village of Siprage.

19        Q.   All right.  I want to move, finally, to Teslic.

20             Can you tell us, How did you first come to hear about the

21     Mice Group, the first time that you learned that this group was being

22     formed?

23        A.   I was in Doboj.  I had an operative presence there.  And on the

24     premises of the security services in Doboj, I met my -- I met people from

25     my town who I all knew by name.  It was the then-chief of the

Page 10919

 1     municipality, Nikola Perisic; then Predrag Markoscevic [phoen], a SUP

 2     employee; then Marinko Djukic, another SUP employee; then Vid Stojanovic

 3     from the TO; and there was Mr. Misic, whom I knew as a politically active

 4     man in the Teslic municipality.  I didn't know why they were there, so I

 5     asked them about it.  And they replied to me rather officiously that they

 6     were there to apply for assistance from Doboj because the situation in

 7     Teslic, they said, was stale.

 8             In Teslic there were many problems, so they had come to Doboj to

 9     request assistance to make people aware that there was a war on and that

10     people had to behave as appropriate for wartime.  That's what happened in

11     Doboj.

12             I didn't know then that the Mice Group would be sent there to

13     help them.  I only learnt about that later, when they began to harass

14     Teslic.  Savo and my brother, Nenad Radulovic, informed me of the events

15     in Teslic --

16        Q.   [Previous translation continues] ...

17        A.   -- and I passed on that information --

18        Q.   [Previous translation continues] ... sorry for interrupting.  You

19     passed that information on to the CSB?

20        A.   To the chief of national security, Kesic, through Vojin Bera.

21             But I mentioned Savo.  I would like to add his last name, which

22     is Stanic.

23        Q.   And I want to return to that in a second.  But just to clarify

24     your answer with regard to this meeting you had in Doboj or the -- this

25     encounter you had in Doboj with Nikola Perisic.  Just to clarify, was

Page 10920

 1     that at the CSB Doboj building?

 2        A.   That's correct.  In the lobby on the upper floor - it's a rather

 3     spacious lobby - it is still there, only the entrance is modernised.  And

 4     that's where I met them.

 5        Q.   Can you tell us approximately how many members of the Mice Group

 6     came from CSB Doboj?

 7        A.   About 20.  That was the first group that arrived.

 8        Q.   And who was the leader of this group from the CSB Doboj?

 9        A.   The leader of that group was not from the CSB of Doboj.  He was a

10     member of military security.  I know that he had the rank of captain.  I

11     can't remember his name now.

12             The Mice consisted of active-duty state security officers,

13     active-duty public security officers, reserve members of state security,

14     and a number of members of the VRS.  I don't know whether they were from

15     the security organ or another operative unit.  Among the active staff of

16     state security I saw, Culibrk; Dobrivoje is his first name.  I had worked

17     with him earlier in the SDB of Doboj.  I saw some staff of the SJB and

18     the SDB that I knew.  I'm sorry to say that among them there were some

19     people who I had known as criminals, really bad criminals from Doboj and

20     the surrounding area.

21        Q.   Were these the same individual who in May 1992 were mistreating

22     non-Serbs either at the CSB building or other places?

23        A.   Yes.  Among them, there were also these people.

24        Q.   What was Milan Savic's role with regard to the Mice Group?

25        A.   At first, I didn't know.  I found out only after they'd been

Page 10921

 1     arrested.  I heard that he was actually the commander.

 2        Q.   And where were the Mice Group members based in Teslic?

 3        A.   At several locations: One was the Barici hamlet, about 5

 4     kilometres from Teslic.  Then there was the Kardijal Hotel, 2 kilometres

 5     from Teslic.  And a number found accommodation with their lovers.  I

 6     remember that well because we arrested them all at those places.

 7        Q.   Before the Mice Group arrived Teslic, were there any armed

 8     conflicts going on in the municipality?

 9        A.   But before I reply to this question, when I say "Barici,"

10     actually, it should be "Dzulic." These are close to -- these places are

11     close to each other.  They were at the school in Dzulic.

12             And now, if I may reply to your question.

13        Q.   Yes.  My question was:  Before the Mice Group arrived Teslic,

14     were there any armed conflicts going on in the municipality?

15        A.   There were no major armed conflicts.  But there were three spots

16     where Serbs did not go, nor did Croats leave those places.  Stenjak,

17     Ruzevic, as well as Slatina and Komusina.  As earlier as 1991, Slatina

18     and Komusina were the places where paramilitary units started arming

19     themselves.  They were rather well armed.  And they called themselves

20     Ustashas.  At Stenjak, a group of extreme Bosniaks were rather

21     well-armed.  And at Ruzevic also, a group of Bosniaks was rather

22     well-armed, and they even had some artillery.

23             JUDGE DELVOIE:  Mr. Olmsted, we went from the people of Teslic

24     coming to Doboj to ask for assistance to the arrival of the Mice Group in

25     Teslic.  My question is:  Is there a link between the two?  In other

Page 10922

 1     words, was the arrival of the Mice Group the assistance -- the answer to

 2     the question of assistance?  Was the Mice Group sent in to Teslic to

 3     assist the Teslic authorities?

 4             THE WITNESS: [Interpretation] Your Honour, you understood

 5     correctly.  That is the assistance the representatives from Teslic had

 6     applied for.  So the arrival of the the Mice was the assistance provided

 7     to them.

 8             JUDGE DELVOIE:  Thank you.

 9             MR. OLMSTED:

10        Q.   In Teslic, were the Serbs also arming themselves?

11        A.   Of course.

12        Q.   You mentioned earlier that you learned about what the Mice Group

13     were doing in Teslic from Savo Stanic and your brother.  Do you recall

14     approximately when you received that information and then when you

15     reported it to Mr. Kesic?

16        A.   I received information around mid-June.  I immediately informed

17     Mr. Kesic.  Then, I did not know that members of the Mice Group had

18     killed anybody.  I only knew that they had been taking people in; they

19     had mistreated people; that they imposed a curfew from 8.00 a.m. til

20     10.00; that after that nobody was allowed to stay in the open; that all

21     lights must be dimmed, which immediately made it clear to me that they

22     didn't want witnesses, if people were not allowed to switch lights on.

23             So the Mice were doing all sorts of things but didn't want people

24     to witness that.  And that's why they wanted all windows closed and the

25     blinds down in midday.  That was my only logical conclusion.

Page 10923

 1             MR. ZECEVIC:  I'm sorry.  Just for the sake of the clarity of the

 2     transcript, the witness was talking about the -- the drapes being drawn

 3     during the day-time and not -- he was not talking about the light.  I

 4     mean, that was his answer.  So if this can be clarified.

 5             JUDGE HARHOFF:  Makes sense.

 6             MR. OLMSTED:  I think that is logical without going into it

 7     further.

 8        Q.   How did -- do you recall how Mr. Kesic reacted to the information

 9     that you first provided regarding the Mice Group in Teslic, in mid-June?

10        A.   Yes, I remember.  He reacted rather casually.  He said, What do

11     we care?  That -- that's a problem for the people in Doboj.  Let's not

12     interfere.  He said something along these lines.  As I was from Teslic,

13     he may have thought that I was more interested in this area than I would

14     have been in another.

15        Q.   Do you recall, did you also provide, at this time, in the middle

16     of June, information to Mr. Zupljanin about what was going on in Teslic

17     with the Mice Group?

18        A.   Yes.

19                           [Trial Chamber and Legal Officer confer]

20             MR. OLMSTED:

21        Q.   Please continue.

22        A.   After receiving information from Savo Stanic and my brother, I

23     sent two operatives from the Milos Group to the Teslic area.  I gave them

24     the names of the persons to talk to about the events in Teslic, and I

25     told them to inform me about what was really going on in Teslic as soon

Page 10924

 1     as possible.

 2             I must say that only Goran Sajinovic knew who our collaborators

 3     were.  Apart from him, nobody else from the group knew who our

 4     collaborators or our operative connections were, but everybody knew our

 5     friendly connections.

 6             I gave enough information about our collaborators, and he called

 7     me in the afternoon hours and told me -- he was rather upset.  He told

 8     me, Boss, the situation is much more serious than we had thought.  He

 9     was, of course, joking.  He never called me Boss except in serious

10     situations.

11             And I said, All right.  Come immediately and inform me.  And they

12     did.  We wrote a report.  And soon after that, a day or two may have

13     passed, I can't remember now, the chief of the municipality,

14     Nikola Perisic, came to see me in person.

15        Q.   [Previous translation continues] ... let me stop you because I

16     want to go into that, but I want you to answer my question.

17             And this is around the time-period of mid-June 1992.  You

18     mentioned that you informed Mr. Kesic about what the Mice Group was doing

19     in Teslic at that time.  And my question was:  Did you also inform

20     Mr. Zupljanin at that time?

21             And we'll talk about your meeting with Perisic later.

22        A.   No.

23        Q.   Well --

24        A.   I did not inform Stojan Zupljanin after receiving the first

25     information because it was only the initial operative information.  But I

Page 10925

 1     did inform him later, and I can tell you about his reaction.

 2        Q.   I'll tell you -- we'll go into that maybe in a second.  But

 3     perhaps to refresh your recollection you could look at paragraph 106 of

 4     your statement.

 5             And just read it to yourself; do not read it aloud.

 6        A.   I've read it.

 7        Q.   And I'm particularly interested in the last sentence of that

 8     paragraph.

 9             Having read that, does that refresh your recollection whether you

10     informed Mr. Zupljanin before -- well, around this time-period, mid-June,

11     about the Mice Group in Teslic?

12        A.   Mr. Prosecutor, even without propping my memory I see what --

13     what this says.

14             I remember, however, what I said.  The first day, I directly

15     informed Stojan Zupljanin about it.  On the same day, he gave approval to

16     establish a group to passivise these renegades in Teslic.  It happened on

17     the same day in the afternoon or evening hours, and that was the order

18     and the decision of Stojan Zupljanin.

19        Q.   Just hold on there for a second.

20                           [Prosecution counsel confer]

21             MR. OLMSTED:  Okay.  Yeah, just for the record, I just wanted to

22     point on line [sic] 51, 9, it's the first "day," not the first "say."

23        Q.   And Mr. Zupljanin -- I apologise.  Mr. Radulovic, we're going to

24     talk about your meeting with Zupljanin which was attended by Mr. Perisic

25     in a second.  I just wanted you to read that paragraph and see if that

Page 10926

 1     refreshed your recollection that you informed Mr. Zupljanin prior to that

 2     meeting with Perisic and Zupljanin about the Mice Group.  If it didn't,

 3     that's fine.

 4        A.   Mr. Prosecutor, regardless of how often you say, No, no, no,

 5     before that meeting, on that same day, I informed Stojan Zupljanin about

 6     the fact that the representatives from Teslic wanted to meet with him and

 7     explain the situation to him.

 8             And I remember very well that on that day Mr. Zupljanin attended

 9     the meeting of the Municipal Assembly.  And I know that I asked him to

10     come out of the meeting, and he did come out, and he told me verbatim to

11     organise that meeting in the afternoon hours in the building of the

12     security services in Banja Luka.  He basically shifted to me the entire

13     organisation of that meeting.

14        Q.   Thank you.  And, please, please, I know this is -- you want to

15     give a lot of information about this, but my question -- I think you did

16     answer, the answer was, No, that you don't recall providing him

17     information prior to that date, and that's fine.

18             My next question for you --

19             JUDGE HALL:  Mr. Olmsted, before we get too far off, I'm looking

20     at the transcript, line 8, page 51, and I need clarification as to

21     whether I correctly heard the witness say that the -- Zupljanin gave

22     approval to stabilise a group to "pacify" the renegades in Teslic.

23             MR. OLMSTED:

24        Q.   Mr. Radulovic, did you hear what Judge Hall asked?  Is that a

25     correct statement of what happened?

Page 10927

 1        A.   Yes.  But it's not the word pacify that I used.  I received

 2     consent -- or, rather, order, not a consent or approval but an order from

 3     Stojan Zupljanin.  And that was one of the first orders that he gave me,

 4     where he asked that they be arrested, "arrested," not "pacified."

 5             JUDGE HALL:  Thank you.

 6             MR. OLMSTED:

 7        Q.   Now, I want -- this meeting that you -- that Mr. Perisic

 8     attended, could you tell us who else attended this meeting with

 9     Mr. Zupljanin?

10             And, please, just list their names.

11        A.   You don't need their positions.

12             So there was Nedeljko Kesic, there was Branko Peric,

13     Nenad Kovacevic, Vitomir Popovic, Milan Stevilovic, Stevan Markovic,

14     Goran Sajinovic, I was there.  And I don't remember anybody else being

15     present.

16        Q.   Whose idea was it to have prosecutors --

17             MR. ZECEVIC:  I'm really sorry.  I believe the witness says --

18     said, 53, line 3, Branko "Peric" not "Perisic."

19             THE WITNESS: [Interpretation] Branko Peric, Nikola Perisic.

20             MR. OLMSTED:  And we got the rest.

21        Q.   Whose idea was it to have prosecutors and judges present at this

22     meeting?

23        A.   To be quite frank, I suggested to Nikola Perisic that he

24     shouldn't be alone there but that there should be the prosecutor present

25     as well as the president of the municipal or basic court in Teslic.

Page 10928

 1        Q.   Now, you said that Mr. Zupljanin gave you responsibility --

 2             JUDGE HALL:  Mr. Olmsted, if are you about to move on to

 3     something else, perhaps we should take the break at this point.  It's

 4     just about that time.

 5             We alert counsel that we are in the process of making inquiries,

 6     looking at the original estimates of time that you were given, and if my

 7     math is correct, Mr. Olmsted should have exhausted his eight hours by

 8     now.  But looking at what had been indicated for cross-examination by the

 9     other side, how much time is available tomorrow, it doesn't seem as if

10     it's going to be possible to complete this witness tomorrow.

11             And we are inquiring into the possibility of an extra session

12     this afternoon and/or tomorrow afternoon, but I'm not in position to

13     confirm that availability at this point.

14             But, the -- of course, if the estimates of time given by the

15     Defence, in light of what has happened, are now more than they need, then

16     we needn't concern ourselves with this.

17             But we don't need an answer now, Mr. Zecevic.  We are at the

18     break.  You can think about it and let us know.

19             MS. KORNER:  Your Honours, in fact, I was about to raise it

20     because of witnesses next week.  We brought up, as I said to Your

21     Honours, subject to Your Honours' ruling on Mr. Riedlmayer - he's the

22     witness, in fact, we thought Tuesday - we had estimated that with the

23     length of cross-examination as well as examination-in-chief,

24     Mr. Radulovic would certainly go into Monday.  No question about that.

25             But we did bring up a further -- or were going to bring up a

Page 10929

 1     further witness, although Your Honours aren't sitting on Friday, just a

 2     short 92 ter witness, but if Mr. Radulovic is likely to continue into

 3     Tuesday, well then there's no need for that witness to attend.  So

 4     obviously the timing is something of importance because we need to stop

 5     that final witness being brought up.

 6             JUDGE HALL:  Yes.  Thank you.

 7             We take the break now.

 8                           [The witness stands down]

 9                           --- Recess taken at 12.08 p.m.

10                           --- On resuming at 12.42 p.m.

11             JUDGE HALL:  Before the witness is escorted back to the stand, we

12     understand that Mr. Zecevic wished to raise something.

13             But before he does, we could indicate that we have confirmed that

14     it is possible to -- for us to do an extra session on Monday afternoon,

15     which we are considering instead of today or tomorrow.  Tomorrow is out.

16     The -- but Monday afternoon instead of this afternoon.

17             And secondly, having regard to what Ms. Korner had indicated, we

18     think that it would probably be visible for them not to bring in this

19     short witness that she had.

20             Yes, Mr. Zecevic.

21             MR. ZECEVIC: [Interpretation] Your Honours, I will try to be as

22     brief as possible with regard to what I wished to inform the Chamber of.

23             If you remember, some time ago --

24             Can we go into private session, please.

25             JUDGE HALL:  Yes.

Page 10930

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10931











11 Pages 10931-10933 redacted. Private session.















Page 10934

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7                           [Open session]

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

 9                           [Trial Chamber and Registrar confer]

10             JUDGE HALL:  You may have heard what would have passed between

11     the Court Officer and the Bench.  Have you a half-hour left, Mr. Olmsted.

12             MR. OLMSTED:  May I just beg the Trial Chamber to give me a

13     little bit more time.  And here is why:

14             This witness has been very long-winded in his responses, and I

15     have done my best to keep him short.  And I just want to get through

16     Teslic, and I just want to show that -- this video that you allowed us to

17     add to our exhibit list.  And I think I can do it in hour.

18             So if I could have the rest of this session and, if necessary, a

19     little bit of time tomorrow, that would absolutely it.  But I think I

20     might have a little bit of -- well, a bank of time from my last witness.

21     I think I saved about an hour and a half.  And maybe I could cash that in

22     at this point.  I apologise, but it's just been quite difficult.

23             JUDGE HALL:  As I quipped the other day, this notion of the

24     "bank," I don't know where that originated, but it's not something that

25     we as the Bench buy into.

Page 10935

 1                           [Trial Chamber confers]

 2             JUDGE HALL:  45 minutes, Mr. Olmsted.

 3                           [The witness takes the stand]

 4             MR. OLMSTED:

 5        Q.   Mr. Radulovic, we're going to have to go at break-neck speed

 6     right now to try to finish by the end of this session, so please excuse

 7     me for skipping over a lot of parts that you might want to talk about.

 8             Did Mr. Zupljanin provide you with in the instructions on how to

 9     commit -- or how to conduct the operation against the Mice Group?  Just

10     tell me if he did or he didn't.

11        A.   He told me that they need to be arrested.

12        Q.   And that's it?

13        A.   You asked me to put it in the shortest form.  I was ordered to

14     arrest them, that I must put myself at the head of this unit that

15     conducted the arrest, and file the criminal report.  That was all taken

16     under this order.

17        Q.   And how long after this meeting with Mr. Perisic and

18     Mr. Zupljanin did you conduct the operation?

19        A.   In the morning, at 0400 hours, we started with the operation, and

20     the preparations were conducted in the course of the preceding night,

21     starting at Teslic.

22        Q.   Before you conducted the operation, did you send any messages to

23     CSB Doboj concerning the Mice Group?

24        A.   That was two or three days prior to the arrest.  I told

25     Dobrivoje Culibrk, a person I knew from before, that they should pull out

Page 10936

 1     of Teslic and unless they do so there would be a conflict.  And when I

 2     said a conflict, I said with me, but I meant the service.

 3        Q.   Did you tell him to inform anyone at the CSB Doboj within the

 4     state security service to withdraw the Mice Group?

 5        A.   Yes.

 6        Q.   [Previous translation continues] ... who?

 7        A.   Dusan Zivkovic who was, at the time, chief of the State Security

 8     Service in Doboj.  I gave him a detailed explanation in relation to all

 9     the acts committed by Mice, and Dobrivoje knew about it and what the

10     consequences will be.

11        Q.   And what was the response that you received to your request that

12     the Mice Group should be withdrawn from Teslic?

13        A.   The result was that additional 17 people joined this group, and I

14     would characterise them as professional killers.

15        Q.   And who was leading that additional group?

16        A.   Slobodan Karaga.  Rather, Slobodan Karagic, aka Karaga.  He was

17     somebody with a criminal record and a very terrible one, criminal record

18     from before the war.

19        Q.   Now we're going skip ahead because we don't have time to -- after

20     you conducted the operation and arrested the members of the Mice Group.

21     Can you tell us, Did you release the non-Serb detainees at the detention

22     facilities after the operation?  And just tell us if you did or didn't.

23        A.   Yes, I did.  All of them on one location.  There was about 400 of

24     them; at the other, about 600; at the third, about 140.  I can't remember

25     all the locations, but I released them all, and I apologised on behalf of

Page 10937

 1     the Serbian People.  I told them that it wasn't the Serbs or the

 2     Serbian People who did that to them, but the Serbian scum.  I used very

 3     bad words when speaking about the people who were responsible.

 4        Q.   Were any of these non-Serbs that you released were they involved

 5     in organised armed resistance in Teslic?

 6        A.   To be honest, I didn't go into that issue.  I knew majority of

 7     the people.  They knew me as well.  And I believed I owe that to the

 8     people who were brought in for no other reasons but for the names they

 9     bore which were different than the names of those who brought them in.

10        Q.   Now, on the day of the operation, did you meet Milan Savic?

11        A.   Yes.  He was arrested by members of the group I was at the head

12     of.  I know that about 50.000 German marks or other currencies were found

13     on him, and then also some gold.  All of it was seised from him.  He was

14     at first arrested.

15        Q.   Do you recall if you found on him in his possession any

16     identification cards from the CSB Doboj?

17        A.   But, of course.  All of them.  All of them who were arrested, all

18     of them were in possession of the IDs, official IDs, issued by the

19     National Security Service, and all of them signed by Milan Savic the man

20     whom we arrested.

21        Q.   After the operation against the Mice Group, how long did you

22     personally stay in Teslic?

23        A.   For another month.

24        Q.   After during this month, did you conduct an investigation into

25     the Mice Group?  Just tell us if you did or didn't.

Page 10938

 1        A.   Yes, I did, detailed.

 2        Q.   During your investigation, while you were there in Teslic for a

 3     month, did you receive any threats trying to make you discontinue that

 4     investigation, originating from CSB Doboj?

 5        A.   Yes.  Quite a number of threats from a number of people.  And the

 6     worst of them was by Mr. Stankovic who was a major at the time or may

 7     have become a lieutenant-colonel.  He came personally to Teslic.  He had

 8     his arm in a cast.  One friend of mine helped him with that.  And he came

 9     and said that he would kill myself, all of us who took part in the

10     arrest, and our families, all of us who took part in the arrest of Mice.

11        Q.   How about SNB Doboj chief Zivkovic?  Did he issue any threats to

12     you?

13        A.   Yes.  Sometime -- quite some time after the events.

14        Q.   In 1992?

15        A.   Yes, in 1992.  But it -- he kept on making them for quite a long

16     while.

17        Q.   During your investigation, did you learn of any mass graves where

18     the non-Serb victims of the Mice Group were buried?

19        A.   Yes.  We found out about two such locations.  According to our

20     information, one contained bodies of 20 people; and the other, bodies of

21     48 people.  We had someone who was present at the scene who explained how

22     things came about, how the people were killed.  And for the rest of the

23     victims, where they were buried in individual graves.  It was a total of

24     58 person killed.

25        Q.   Can you tell us just generally where in Teslic these mass graves

Page 10939

 1     were located?

 2        A.   In the area of Mount Borija.

 3             MR. OLMSTED:  Let's take look at what's been marked for

 4     identification, P703.

 5             And, correction, this has been -- this is not what I wanted.

 6             Let's call up 65 ter 857.

 7                           [Prosecution counsel confer]

 8             MR. OLMSTED:

 9        Q.   Is this a letter, Mr. Radulovic, that you wrote to the CSB chief

10     in Banja Luka?

11        A.   If I could see the following page and see my signature there

12     maybe, but I do remember the content.  I'd still like to see the

13     signature.

14             MR. OLMSTED:  Let's look at the second page quickly.

15             THE WITNESS: [Interpretation] Yes, I drafted this.

16             MR. OLMSTED:

17        Q.   Okay --

18        A.   Why there's no signature, I don't know.  But, yes, yes.

19             MR. OLMSTED:  May that be admitted into evidence.

20             JUDGE HALL:  Admitted and marked.

21             MR. OLMSTED:  Well, I guess it's -- has it already been admitted.

22     Okay.  That's been clarified; it's been admitted.

23             Can we please look at 65 ter 858.

24             MR. ZECEVIC:  I'm really sorry, can we just have the number?

25             THE REGISTRAR:  It is Exhibit P703, to which the counsel referred

Page 10940

 1     to originally.

 2             MR. OLMSTED:  Here's another letter.  It's dated 10 July 1992.

 3     It's from you to CSB Banja Luka to the chief of the Security Services

 4     Center personally.

 5        Q.   Is this - if we scroll down on the B/C/S - is this another letter

 6     you wrote?

 7             MR. OLMSTED:  Let's go to page 2.

 8        A.   Yes, yes.

 9             MR. OLMSTED:  May this be admitted into evidence.

10             JUDGE HALL:  Admitted and marked.

11             THE REGISTRAR:  As Exhibit P1383, Your Honours.

12             MR. OLMSTED:

13        Q.   Mr. Radulovic, did Mr. Zupljanin ever respond to these letters?

14        A.   I don't remember.  As far as I remember, no, he did not.

15        Q.   Do you recall, did -- did you ever have a conversation with

16     Mr. Zupljanin about these letters?

17        A.   We had a conversation about the situation in Teslic in general,

18     the conditions in Teslic.  We talked about insufficient information

19     gathered about the crimes, because, at the time, I was interested in

20     organising exhumations, post mortems, and forensic teams to do that, and

21     I asked for assistance, believing it was necessary.  So, roughly

22     speaking, we had a discussion about what was contained in the written

23     reports as well.

24        Q.   And what did he tell you?

25        A.   I was told, roughly, that it's not the right time for that, that

Page 10941

 1     there's no need for exhumations or forensic expertise.  That's all I can

 2     remember.  I didn't get proper assistance from anybody of those whom I

 3     had asked for this assistance, to have this issue resolved.

 4             Based on several reports of mine, one can see that I sent to --

 5     in to an applicant [as interpreted].  I wasn't requesting because I

 6     realised that the level of cooperation following my requests wasn't

 7     something that produced results, because I even asked Belgrade to assist.

 8             MR. OLMSTED:  Let's take a look at 65 ter 887.

 9             I apologise.  It's 65 ter 877.

10        Q.   Mr. Radulovic, do you recognise this article?

11        A.   Yes, I do.

12        Q.   Just very generally, is it -- is it -- what it contains in

13     it about -- well, let me tell you -- put on record what it is.

14             It's an article from Slobodna Bosna about the Mice Group in

15     Teslic.  It's dated 13 December 2001.

16             Is the information contained in this article generally accurate?

17        A.   No one from the newspaper ever interviewed me.  What is stated in

18     the article - and I did have an opportunity to read the article - is

19     partially true, but it is mostly just arbitrary guess-work by the author,

20     because I never claimed that Njegos was at the head of the action or that

21     the murder of Bosniak was ordered by the person mentioned.

22             There are some other incorrect claims in here, but as far as the

23     harassment and mistreatment and killings of Bosniaks, yes, I can confirm

24     that that part is correct.

25             MR. OLMSTED:  Let's turn to page 2 of the B/C/S; page 4 of the

Page 10942

 1     English.

 2        Q.   Now, on page 2 of the B/C/S, the article reports:

 3             "As robbers'," referring to the Mice, "appetites grew and the

 4     amount of available loot decreased, well-off Serbs also became targets."

 5             It then describes a few instances of this and states that.

 6             "... was when the time for action came, although the police and

 7     judicial organs were quite aware what was going on in the town.  Even

 8     before that, Radovan Karadzic also received detailed information."

 9             Can you verify whether that is accurate?

10        A.   I already told you I wasn't interviewed by this journalist.

11     These are not my words, my authentic words.

12             This is something that was taken from a different interview with

13     me that was published in a newspaper called Nezavisne Novine.  If you

14     make a comparison between the two articles, you will see that the article

15     in the newspaper before us is made as an arbitrary statement and

16     generalisations of some of the information I had and then making

17     conclusions that had nothing to do with my claims.

18             In other words, I wouldn't say -- I would say that when

19     journalist says that the local authorities in Teslic knew about the

20     crimes before Stojan Zupljanin, the president of the court, the

21     prosecutor, and the police in Teslic, they knew, even before Mices were

22     arrested, knew about the crimes in Teslic and that part, that part is

23     correct.

24        Q.   What about the part that as their appetites grew an amount of

25     available loot decreased, well-off Serbs were also were targeted [sic].

Page 10943

 1             Is that true?

 2        A.   That's another correct claim by the journalist, although it

 3     wasn't something I had said.

 4        Q.   And just so you know, I'm not saying that these are something

 5     that you said.  I just want to verify the accuracy of this article.

 6             If you reads further down the page, it says that:

 7             "The arrested men," meaning the Mice, "were soon released and the

 8     proceedings remained open until the present day."

 9             Is that accurate?

10        A.   Yes, that is absolutely accurate.

11        Q.   And if we read a little bit further down, it states that:

12             "The members of the Doboj CSB were led by Milan Savic, the deputy

13     of Doboj CSB chief Andrija Bjelosevic, Savic was immediately released

14     from detention at the intervention of Bjelosevic and Stojan Zupljanin

15     even though a bag with 50.000 marks was found on him when he was

16     arrested."

17             Is that accurate?

18        A.   It is partially accurate.  He was released on the same day, on

19     the day when the operation was concluded.  On that day,

20     Andrija Bjelosevic came to the police station in Teslic, Stojan Zupljanin

21     was already there, and I was told that it would not be a good idea to

22     have the criminal report including the name of Milan Savic as somebody

23     involved in the incidents, and, therefore, I didn't include him in the

24     criminal report.  As far as I can remember.

25        Q.   So I want us to be very clear about this.  You had a conversation

Page 10944

 1     with Mr. Zupljanin and Mr. Bjelosevic in which they said that you should

 2     not charge Milan Savic?

 3        A.   I wouldn't put it that way.  You're trying to make me say

 4     something.  But there was an office in which there were a dozen people at

 5     the time.  Among them, Stojan Zupljanin, Andrija Bjelosevic,

 6     Dusan Zivkovic, Dusan Culibrk, and I believe that there was

 7     Colonel Stevilovic also, people from Doboj.  And there was a

 8     communication among them, people were saying things, but Andrija and me

 9     were not on good terms then.  So whatever he said to me was an offence.

10     And when I tried to convince him of anything, to tell him what had

11     happened, he denied it.  So I understood that the man wasn't well enough

12     informed.

13             So I can't really say now, but I do know that the CSB Doboj

14     executives demanded that Milan Savic not be included in the operative

15     investigation concerning his participation in that group's activities.

16     They explained to me it wouldn't be good because he was a member of the

17     service, like the other active-duty servicemen, so this could all be

18     connected to the service.  And I believe that I said as much in one of my

19     interviews and gave a much more detailed explanation.

20             MR. OLMSTED:  May this document be admitted into evidence.

21             JUDGE HALL:  Mr. Olmsted, isn't the -- don't the answers the

22     witness has given remove one of the grounds for admissibility of an

23     article, namely its reliability?

24             You have asked him about portions of it which he has agreed with

25     and adopted, but the effect of his evidence as I understand it is that

Page 10945

 1     the article taken as a whole is unreliable.

 2             MR. OLMSTED:  I'm not --

 3             JUDGE HALL:  As an item of evidence.

 4             MR. OLMSTED:  I'm not sure that's how I interpreted his

 5     testimony, Your Honour.  I think he said that there were bits of it that

 6     were not accurate but that, you know, generally it was truthful about

 7     what happened with the Mice Group.  Maybe I can lay more foundation.

 8             JUDGE HALL:  And he has said that.  That's as far as you need go.

 9             MR. OLMSTED:  Well, I'm only giving excerpts of the article, and

10     I'd like to have the whole article admitted into evidence.

11             JUDGE HALL:  Well, that is exactly the observation that I have

12     made.  What the witness's answer to your questions have been is that the

13     article taken as a whole is unreliable.  There are portions of it

14     which -- with which he agrees and which he accepts as accurate, and you

15     having put those portions to him in -- in the form of specific questions,

16     he has answered them and thus adopted it.

17             But what he hasn't adopted in the other parts, he has said

18     something in which the Chamber cannot rely.  So why should we accept it

19     as an item of evidence?

20             MR. ZECEVIC:  Yes, Your Honours, if I may be of assistance.  The

21     witness actually said:

22             "... I did have an opportunity to read the article - is partially

23     true, but it is mostly just arbitrary guess-work by the author."

24             It's page 66, 18, so therefore --

25             MR. OLMSTED:  You know what, it's -- I'm sorry for interrupting.

Page 10946

 1     That's fine.  We won't move to admit it.  I have 15 minutes; I want to

 2     move on.

 3        Q.   You mentioned at the beginning of your testimony at the beginning

 4     of this week that criminal proceedings were initiated against you for

 5     undermining the combat spirit of the Republika Srpska and spreading

 6     brotherhood and unity by releasing non-Serbs from detention facilities.

 7             Were these criminal -- was this criminal report a reaction to

 8     your Mice Group operation?

 9        A.   Yes.

10        Q.   And when was that criminal report filed?

11        A.   In 1992.

12        Q.   And who filed it?

13        A.   The CSB of Doboj.  The CSB of Doboj.

14             MR. OLMSTED:  Let's take a quick look at 65 ter 860.

15             THE WITNESS: [Interpretation] If I may add: Not only was a

16     criminal report filed, but an indictment was also issued.

17             MR. OLMSTED:

18        Q.   What we have in front of us is a report dated 13 July 1992.  Is

19     this one of your team's reports?

20        A.   Yes.

21        Q.   It requests the replenishment of the reserve police force, and it

22     states:

23             "It notes that their engagement in the reserve police would be

24     good for preventative reasons since individuals from this company or

25     their entire company had got out of control and became a paramilitary

Page 10947

 1     formation."

 2             Are you referring to members -- people who were working with the

 3     Mice Group?

 4        A.   No.  This is a group led by Second Lieutenant Jocic.  Its status

 5     was undefined.  And before this operation, there was a -- the possibility

 6     that these people would become our worse enemies.  So we were able to

 7     persuade Second-Lieutenant Jocic to side with us and assist us in

 8     arresting the Mice.

 9             They were rather young and brave and rather well trained, and I

10     thought that they should be placed under control so they don't become

11     renegades.

12        Q.   You state here that individuals from this company had -- have

13     gotten out of control.  Can you tell us what they had been doing that got

14     them out of control?  What kind of activities they were engaged in?

15        A.   I said that this report was written to prevent them from getting

16     out of control.  We knew the composition of this units -- unit, and we

17     knew it was headed by the former JNA officer, this man Jocic.  We

18     established contact with him later.  They were drafted to the VRS.

19        Q.   Was your request granted by Mr. Zupljanin?

20        A.   I withdrew before I could get any information about this group

21     joining the reserve or active police force.

22             MR. OLMSTED:  May this be tendered into evidence.

23             JUDGE HALL:  Admitted and marked.

24             THE REGISTRAR:  As Exhibit P1384, Your Honours.

25             MR. OLMSTED:  May we have on the screen 65 ter 2838.

Page 10948

 1             I'm sorry, this is subject to protective measures.  So can we go

 2     into private session.

 3             JUDGE HALL:  Private session.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

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10   (redacted)

11   (redacted)

12   (redacted)

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Page 10949











11 Pages 10949-10950 redacted. Private session.















Page 10951

 1   (redacted)

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 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13                           [Open session]

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

15             MR. OLMSTED:  Your Honours, I have nine other Milos reports that

16     obviously I'm not going to get to.  They are all part of his 92 ter

17     package.  He all authenticated them in his 92 ter statement.  I was

18     wondering whether it would be possible simply to provide the numbers

19     of -- the 65 ter exhibit numbers for those documents to the Registrar and

20     then those can just be admitted in bulk.  We have gone over quite a few

21     Milos reports.  These are in line.  And, of course, there's a written

22     statement that can verify their authenticity.

23             MR. ZECEVIC:  I'm sorry, Your Honours, before I start the

24     cross-examination, I need to know what has been admitted.

25             Therefore, I would rather give 15 minutes of my time to

Page 10952

 1     Mr. Olmsted so can he can finish probably with this than wonder which of

 2     the documents have been introduced.  And then I offer them again and we

 3     just use the time.

 4             I'm perfectly willing to give 15 minutes of my time to

 5     Mr. Olmsted.  Thank you.

 6             JUDGE HALL:  We have the bank again.

 7             Mr. Olmsted, I haven't forgotten you also alerted us to the

 8     video.  We indicated that you had 45 minutes, which is about to expire.

 9     It's about time that we rise for the day.  The -- on the resumption

10     tomorrow, could you prove your video that you have alluded to, and the --

11     I would have thought that the -- given the adjournment, that, if the --

12     provided, of course, these -- whatever the number of the remaining

13     documents are are on the 65 ter list ... they all are?

14             MR. OLMSTED:  Yes, they are.

15             JUDGE HALL:  Yes.  So the -- I don't know that you wouldn't

16     necessarily need the 15 minutes because Mr. Zecevic could, I would have

17     thought, put himself in the position, once you would have communicated to

18     him what the numbers are, to cross-examine tomorrow.  So the only thing

19     left for you to do tomorrow morning would be to prove your video, and

20     that would bring your examination-in-chief to an end.

21             MR. OLMSTED:  Let me just put the numbers on the record.  It will

22     just take a second.

23             65 ter 871, 873, 2830, 146, 2837, 549, 203, 2842, and finally,

24     2843.  I think there are nine documents there.

25             And, of course, if one has been admitted, then -- and that's

Page 10953

 1     redundant, but I think I checked and these weren't, but ... perhaps that

 2     could be verified.

 3                           [Trial Chamber confers]

 4             JUDGE HALL:  Yes.  So the Registry would assign numbers to those

 5     five or six, whatever the number is.

 6             THE REGISTRAR:  The numbers will be Exhibits P1386 through P1394,

 7     Your Honours.

 8             MS. KORNER:  Your Honours, can I also just remind Your Honours

 9     that if Mr. Riedlmayer is not an expert, then we're not going to get him

10     here on this weekend.  So we do need a ruling tomorrow.  It's still -- I

11     reminded Your Honours two days ago that it's outstanding.

12             JUDGE HALL:  We haven't forgotten.

13             MS. KORNER:  Yes.

14             JUDGE HALL:  We were actually working on the assumption that is

15     travel arrangements have been fixed.

16             MS. KORNER:  Well, they have.  But, I mean, there's no point --

17     we can unfix them if you decide he's not an expert and therefore you

18     don't want to hear from him.  But I mean, what I mean is I want a ruling.

19             JUDGE HARHOFF:  If he's not an expert, why wouldn't you hear him?

20             MS. KORNER:  On what basis would he be giving evidence,

21     Your Honours, if he wasn't an expert?

22             JUDGE HARHOFF:  Well, I mean, a fact witness.

23             MS. KORNER:  Hardly.  I mean, he's -- [Overlapping speakers] ...

24             JUDGE HARHOFF:  He's bringing all his photos of the mosques.

25             MS. KORNER: [Overlapping speakers] ... of the mosques --

Page 10954

 1             JUDGE HARHOFF:  And so could we not see them without hearing him

 2     as an expert?

 3             MS. KORNER:  Well, I don't know, Your Honours.  I don't know that

 4     we've considered that a possibility.  We've treated him as an expert;

 5     he's been treated as an expert in other trials.  And it's -- if

 6     Your Honours decide he's not an expert -- in fact, I think we ought to --

 7     if that's -- if Your Honours are thinking about that - I must say it

 8     never crossed my mind that you were; which shows I should never take

 9     things for granted - then we'd want to argue that.

10             JUDGE HARHOFF:  What difference would it make?  I mean, we would

11     certainly wish to hear his testimony and to see his photos.  That, I

12     think, is relevant.

13             But the issue remains whether he has to be called and heard as an

14     expert with all the things that follow from that qualification.

15             MS. KORNER:  He is going to be giving opinion evidence,

16     Your Honours.

17             JUDGE HARHOFF:  Yeah.

18             MS. KORNER:  Which is something, technically, that only an expert

19     can do.

20                           [Trial Chamber confers]

21             MS. KORNER:  Well, Your Honours, so long as Your Honours can say

22     something tomorrow, one way or another.

23             JUDGE HALL:  We take the adjournment until 9.00 tomorrow morning

24     in this chamber.

25                           [The witness stands down]

Page 10955

 1                            --- Whereupon the hearing adjourned at 1.47 p.m.,

 2                           to be reconvened on Friday, the 28th day

 3                           of May, 2010, at 9.00 a.m.