Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11113

 1                           Tuesday, 1 June 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.09 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.

11             May we have the appearances, please.

12             MR. OLMSTED:  Good morning, Your Honours.

13             Matthew Olmsted, Joanna Korner, and Crispian Smith for the

14     Prosecution.

15             MR. ZECEVIC:  Good morning, Your Honours.

16             Slobodan Zecevic, Slobodan Cvijetic, and Eugene O'Sullivan

17     appearing for Stanisic Defence this morning.  Thank you.

18             MR. PANTELIC:  Good morning, Your Honours.

19             For Zupljanin Defence, Igor Pantelic, Dragan Krgovic, and

20     Jason Antley.

21             JUDGE HALL:  Thank you.

22                           [The witness takes the stand]

23             JUDGE HALL:  Good morning to you, Mr. Radulovic.  I remind you

24     you're still on your oath.

25             Yes, Mr. Krgovic.

Page 11114

 1                           WITNESS:  PREDRAG RADULOVIC [Resumed]

 2                           [Witness answered through interpreter]

 3                           Cross-examination by Mr. Krgovic: [Continued]

 4        Q.   [Interpretation] Good morning, Mr. Radulovic.

 5        A.   Good morning.

 6        Q.   I will try briefly to go through some of the topics so that you

 7     would be able to go home tomorrow.

 8        A.   Thank you.

 9        Q.   Let us get back to a topic you were asked about by Judge Harhoff

10     yesterday when he was asking you about your work for the state security

11     of Serbia.

12             While you were working for that service, you believed you were

13     working in the interests of the service and the Serbian People?

14        A.   Yes.

15        Q.   There was no awareness of you assisting a Greater Serbia in your

16     preparing of reports and doing your work, had nothing to do with your

17     beliefs as a human being and as a professional?

18        A.   That's correct.  Although I do not believe very much in various

19     statements about Greater Serbia because when compared to Russia or

20     Canada, one realises Serbia is a very small country both by the number of

21     inhabitants and its territory.  It's among the smaller countries of the

22     world.

23             Now, ideas of some individuals who believe they are greater

24     Greater Serbia, Greater Croatia, Greater Bosnia and Herzegovina, I see

25     them as fanatics.

Page 11115

 1        Q.   And all your work -- or all the work that is in the interest of

 2     the Serbian People at the time doesn't necessarily mean that you're

 3     backing the great Serbian ideas or that you have discriminatory

 4     intentions?

 5        A.   I differentiate between patriotism, jingoism, extreme

 6     nationalism, and so on.  To be a patriot doesn't mean one is an extreme

 7     nationalist or jingoist.  One can love his own country without hating

 8     other people.  People -- Holland is a very good example of that.  There

 9     are all sorts of people living here and yet they tolerate each other in

10     every aspect of their being.

11        Q.   When the Prosecutor presented to you an article about a press

12     conference during which Mr. Zupljanin stated that he would not be

13     carrying out orders by the MUP of Socialist Republic of Bosnia and

14     Herzegovina that are contrary to the interests of the Serbian People,

15     that meant that he would not be obeying and implementing decisions that

16     are harmful to the country, and all these things were already under way,

17     have been started by the republican MUP.

18             MR. OLMSTED:  I object to that question.  I mean, it's really

19     trying to get into the head of Mr. Zupljanin and what he made by a

20     statement he made to the press, and I think that this witness also

21     testified that he wasn't at the press conference even.  So I'm not sure

22     that's an appropriate question.

23             MR. KRGOVIC: [Interpretation] Your Honours, precisely because of

24     this statement by the Prosecutor, namely, I objected earlier when the

25     Prosecutor tried to link up the press conference and some interest.

Page 11116

 1     There were claims -- I made the claim that this was a leading question,

 2     and what I'm asking the witness now is to tell me how he understood the

 3     article, because we've heard in the direct examination his views on the

 4     article; and so this is directly linked up with the questions put by the

 5     Prosecutor at the time the Prosecutor was presenting the opposing option.

 6             THE WITNESS: [Interpretation] Should I answer the question?

 7             MR. KRGOVIC: [Interpretation] Let's wait for the Trial Chamber to

 8     make a ruling.

 9             JUDGE HALL: [Previous translation continues] ...

10             Mr. Krgovic, how are we assisted by the witness's impression,

11     understanding, whatever, of an article relating to an event at which he

12     was not present?  Which I understand to be the essence of Mr. Olmsted's

13     objection.

14             MR. KRGOVIC: [Interpretation] Your Honours, my colleague from the

15     Prosecution asked the witness how did this statement by Stojan Zupljanin

16     influence the behaviour of Muslim members of MUP -- MUP of the

17     Bosnia-Herzegovina at the time.  He linked this up with another document

18     and asked the witness to comment on the -- on the statement made by

19     Mr. Zupljanin.

20             I objected to that because the Prosecutor gave him a suggestion

21     as to what the answer might be, and what I'm asking the witness now is to

22     hear his understanding of the statement, how he understood this

23     statement, and how was it implemented.

24             JUDGE HALL: [Previous translation continues] ...

25             MR. KRGOVIC: [Interpretation] In his view --

Page 11117

 1             JUDGE HALL:  Sorry, could you remind me as to how the objection

 2     was resolved by the Trial Chamber?

 3             MR. KRGOVIC: [Interpretation] The Trial Chamber denied my

 4     objection and told the witness to answer the question.

 5             MR. OLMSTED:  Your Honours, I think --

 6             MR. KRGOVIC: [Interpretation] And -- and the Prosecutor is now

 7     objecting to the same approach that they had before.

 8             MR. OLMSTED:  Your Honours, that's a misrepresentation of what

 9     happened.

10             The Prosecution linked this press release or this article in the

11     newspaper to one of the Mr. Radulovic's Milos reports, and that's all we

12     did.  We didn't ask him to comment on any of the things that Mr. Krgovic

13     is suggesting.

14             JUDGE HALL:  Mr. Krgovic, let's move on.  I don't see how we

15     would be assisted by the witness's opinion on this.  It's too

16     disconnected.

17             MR. KRGOVIC: [Interpretation]

18        Q.   We'll move to a different topic.

19             During your direct testimony, you discussed your contact and

20     meetings -- contacts and meetings with Mr. Zupljanin.  As far as I

21     understood your testimony, you didn't have many opportunities to meet

22     with Mr. Zupljanin.  It was only on several occasions that you met with

23     him, and the Prosecutor asked you about them.  Is that correct?

24        A.   Yes, that's correct.  As far as I remember, I responded that I

25     had direct conversations with Mr. Stojan Zupljanin in relation to five or

Page 11118

 1     six incidents, and I added that I may have had discussion about the same

 2     incident -- I had several discussions about the same with him, but I

 3     certainly did not have an opportunity to have daily conversations with

 4     him and definitely not about every dispatch or report I submitted.

 5        Q.   And every time you drew attention of Mr. Zupljanin to some trend

 6     or something else that caused you a concern, Mr. Zupljanin always

 7     responded either immediately or after a short period.

 8        A.   Shall I be brief?

 9        Q.   Yes.

10        A.   The briefest answer would be, Your statement is correct.  But I

11     believe I should add that first such response of his was in relation to

12     Doboj, where, after about two days, members of the special unit were

13     withdrawn, that he reacted to cases related to Keraterm, Omarska,

14     Kotor Varos, Koricanske Stene, by forming a commission which carried out

15     an on-site investigation.  I stated this clearly.  That's the state of

16     fact.  I think it be superfluous for me to give more explanations of our

17     contacts related to individual incidents mentioned.

18             I even mentioned this case at the cross-roads of Teslic,

19     Prnjavor, and Doboj roads, when contact was established through hand-held

20     radio station.  At the time we didn't have mobile phones.  And I also

21     told you what his response was.  He said that at any cost, crime or

22     massacre must be prevented, and that on the basis of my very brief radio

23     reporting.  His answer was as I've just told you.

24        Q.   As far as I remember, you said that he told you that an assistant

25     is coming from Prnjavor, that you should prevent it at any cost, and then

Page 11119

 1     the people in question boarded a bus and departed from there.

 2        A.   That's correct.  You elaborated a bit on what I just told you

 3     about the incident.  But, yes, that's correct.  None of the persons who

 4     were at the location suffered any consequences.  The only problem was the

 5     time they spent waiting there during which they must have been afraid for

 6     their lives.

 7        Q.   I apologise, in your last answer when you were mentioning the

 8     cases where Mr. Zupljanin reacted to your suggestions, in the transcript

 9     we don't see mention of Koricanske Stene.  It's page 6, line 8.

10             Apart from the responses you saw or knew about, let me show you a

11     document that shows other reactions of Mr. Zupljanin to information

12     received from you.

13             MR. KRGOVIC: [Interpretation] So could we please have P198 put up

14     on the screen.

15             JUDGE DELVOIE:  Mr. Krgovic, tab number, please.

16             MR. KRGOVIC: [Interpretation] It's Zupljanin Defence binder,

17     tab 2.

18             JUDGE DELVOIE:  Thank you.

19             MR. KRGOVIC: [Interpretation] I apologise, P198.

20             65 ter 921, if that's of any assistance.

21                           [Defence counsel confer]

22             MR. KRGOVIC: [Interpretation] I apologise, P160.

23        Q.   You said that when you provided reports about the situation in

24     Prijedor, whenever you had an opportunity, you'd tell Zupljanin about

25     some events, trends, and your concern.  You would, for instance, mention

Page 11120

 1     elements of the crime who were the victims, all these things about

 2     victims, mode of perpetration.  These things were not something that you

 3     at the time.  You just gave him a general picture?

 4        A.   That's correct.

 5        Q.   And essence of your report concerning the camps was that people

 6     were put at two locations, you mentioned which ones, that the conditions

 7     there were poor, that some of the individuals guarding them are not

 8     abiding by the norms of the international humanitarian law, that the

 9     military and Crisis Staff are putting in huge numbers of people into

10     spaces that cannot fit them, and that was the essence of your report to

11     Zupljanin?

12        A.   Yes, that's correct.  I would add also that in Omarska I'd seen

13     some dead bodies.

14        Q.   Would you please look at this brief analysis from July 1992.  It

15     was a meeting of the MUP officials held in Belgrade, and all leading

16     officials of MUP were present there.

17             MR. KRGOVIC: [Interpretation] Can we please have page 5 in the

18     B/C/S version; page 8 in the English version.

19        Q.   On the Serb part, there -- present are Mico Stanisic,

20     Mr. Skipina, all minister assistants, all chiefs of various centres.  We

21     can see Mr. Zupljanin speaking here.  Petar Mihajlovic is here on behalf

22     of the -- of the Serbian -- from Serbia authorities.

23             MR. KRGOVIC: [Interpretation] Can we now have page 5 in Serbian

24     version.  Page 8 in the English version, please.

25        Q.   Please have a look at paragraph 2 where Mr. Zupljanin says:

Page 11121

 1             "The army and Crisis Staffs," that is to say the

 2     War Presidencies, "request that as many members of the Muslim population

 3     should be collected and such undefined camps are then left for the MUP

 4     organs.  The conditions in these camps are bad.  There's no food.  Some

 5     individuals do not respect international norms because such collection

 6     centres, among other things, are not adequate or there are some other

 7     reasons."

 8             In essence, let us not go into details.  That was your

 9     information, is that correct, and it reflected the situation that you saw

10     and reported about it.  Is that correct?

11        A.   Yes, I can recognise it, and it's almost a perfect match.

12        Q.   And if you know that after this, the Ministry of the Interior

13     initiated before the Ministry of the Interior of Republika Srpska that

14     Keraterm and Omarska should be disbanded later on Trnopolje as well.  Are

15     you familiar with that?

16        A.   Mr. Krgovic, I am familiar with that.  But I wish to warn you

17     that I am not familiar with all activities of Mr. Stojan Zupljanin, and I

18     want to distance myself from what he was doing in context with his

19     superiors and with the political organs at the level of Banja Luka and

20     Republika Srpska as a whole.  So please place me within my own context,

21     and that means in the intelligence activities which had nothing to do

22     with monitoring this type of Stojan Zupljanin's active, nor did it have

23     anything to do with his activities in relation with reporting to

24     political and other structures at the level of Republika Srpska.

25        Q.   Maybe my question was imprecise.  I just wanted to ask you

Page 11122

 1     whether you know that after this period of time, according to the

 2     information you had, these centres were disbanded.  I mean the ones in

 3     Omarska and in Keraterm.

 4        A.   Yes.

 5        Q.   As far as I remember, you also said that after the first

 6     disbelief which Mr. Zupljanin expressed, he called for you a few days

 7     later and told you that you were right in relation to these incidents.

 8     Is that correct?

 9        A.   Yes.

10        Q.   The Prosecutor showed you a video-clip --

11                           [Defence counsel confer]

12             MR. KRGOVIC: [Interpretation]

13        Q.   I'm referring to the events in Prijedor, and you also had that in

14     mind when you answered; is that correct?

15        A.   Yes, that's just what I had in mind.  But I have to tell you that

16     he had a similar comment about the incidents in Doboj.

17        Q.   The Prosecutor showed you a video-clip from the

18     30th of July, 1992, where you had the occasion to see certain people, and

19     I will now show you a document which is a summary of the meeting and also

20     contains some of the information that you talked about.  So I will read

21     to you some sections of this document to see whether this matches the

22     situation that existed in the Banja Luka region at the time and the

23     information that you had at the time.

24             MR. KRGOVIC: [Interpretation] So could we please see in e-court

25     Exhibit 2D25.

Page 11123

 1             THE WITNESS: [Interpretation] Mr. Krgovic, could I add something,

 2     please?

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   Please go ahead.

 5        A.   I'm not sure what Mr. Simo Drljaca showed Stojan Zupljanin and

 6     the commission which went to Prijedor in relation with Keraterm, Omarska,

 7     and Trnopolje.  You're probably aware that something can be portrayed as

 8     being nice or camouflage, so to speak, so that people who are coming from

 9     somewhere else see something else than what is the reality.  I'm

10     convinced, even though I do not have any operative information, that

11     Simo Drljaca presented to them a situation different than the actual one.

12     I wish to be completely sincere about this.

13             However, I do believe that he saw the situation, that Vojin Bera

14     saw the situation as it was.  I know that, and I checked that.

15     Vojin Bera and also others who visited Omarska and Keraterm.  I also

16     remember a colleague of mine from the public security service,

17     Mr. Obrad Despotovic, who informed me in detail about what was going on

18     in Omarska, and he did that even before I visited Omarska for the first

19     time.

20             So considering that, I believe that those who were in charge of

21     investigations did not report to the leadership in a timely fashion,

22     neither the state or public security service leaderships.  Consequently,

23     the top officials of the Ministry of Interior of Republika Srpska could

24     not receive adequate reports and neither could the political leadership.

25             So, to sum it up, there were attempts to conceal the truth.

Page 11124

 1             JUDGE HARHOFF:  Mr. Radulovic, can I just follow up on this

 2     answer that you just gave to Mr. Krgovic because it wasn't clear to me

 3     whether -- what Vojin Bera said to Zupljanin.

 4             Did Bera try to give to Zupljanin a true picture of how things

 5     were, or did he also seek to cover it up?

 6             THE WITNESS: [Interpretation] Your Honour, I am very clear.  He

 7     was not trying to do that, but he hashed it up.  The events that would

 8     follow later on will show that many things had happened.  Horrible, awful

 9     things took place before I first informed Stojan Zupljanin about

10     anything, and this is absolutely well known.  If you take a look at the

11     time-line of the events and also where these events were taking place,

12     the first man in the investigation team, Vojin Bera, was trying to cover

13     up -- he covered up the truth.  He did not say that the consequences of

14     the investigations that were conducted in Omarska and incidents in

15     Omarska were such that some Bosniaks were dead.

16             I believe I am clear.

17             JUDGE HARHOFF:  Yes.  But what's still a bit unclear to me is the

18     information that, in the end, was passed on to Mr. Zupljanin.  I

19     understand that you tried to give to Mr. Zupljanin a true picture of what

20     had happened at Omarska and Keraterm.  So, at least from you, he would --

21     Mr. Zupljanin would eventually receive some information that would point

22     to the true picture of what had happened.

23             And then my question is:  But what about all the others who also

24     reported to Mr. Zupljanin, such as Vojin Bera and Simo Drljaca?  Do you

25     know if they were able to give a similar true picture of the situation in

Page 11125

 1     Omarska, Keraterm, and perhaps other camps; or did they all together seek

 2     to, as you said, hash it up.

 3             THE WITNESS: [Interpretation] Your Honour, let me try once again

 4     to provide an answer to your question.

 5             Mr. Vojin Bera - I'm wrong again; he's just Vojin Bera - and

 6     Simo Drljaca, the two of them had much more information about these

 7     events than I did.  I only spent one day in these camps; I mean, in

 8     Keraterm, in Omarska, and in Trnopolje.  In this one single day, I saw

 9     something that I found to be awful and horrible, and I reported to

10     Mr. Stojan Zupljanin about this in the presence of Djuro Bulic,

11     Goran Sajnovic, and I already said what Djuro Bulic's comment about this

12     was.  He went away to play soccer, and he did not care about learning

13     more about the things that I had noticed.

14             However, now I'm in a position to say that somebody had probably

15     checked what I had told Stojan Zupljanin.  I suppose that, in connection

16     with this, the commission also interviewed both Vojin Bera and

17     Simo Drljaca.  It probably received from them a picture that was quite

18     different from what I had seen.

19             The mayor of Banja Luka, Predrag Radic, told me on return from

20     Prijedor that it was much worse than I had reported to the service.  I do

21     not know where he received this information from, what he was told about

22     what I had said, but I do know for certain that I was not the only one

23     who saw all this.  Other members of the State Security Service and the

24     public security service had seen the same, and it had been a trauma for

25     them to spend any more time in Keraterm or in Omarska.  I have mentioned

Page 11126

 1     one name, Obrad Despotovic.  I could mention the names of other people

 2     who told me about incidents much worse than the ones I had witnessed.

 3             So, to conclude, if I may, and if you will allow that, after all

 4     that, I believe that Simo Drljaca, Vojin Bera, and others painted an

 5     untruthful picture of the events that were taking place in the area.

 6     They painted a picture that was much softer in terms of consequences.

 7     They were doctoring information, and they could have prevented the crimes

 8     which have been established in their number and nature in both Omarska

 9     and in Keraterm and in the general area of the Prijedor municipality.

10             JUDGE HARHOFF:  Thank you.

11             Back to you, Mr. Krgovic.

12             MR. KRGOVIC: [Interpretation]

13        Q.   In connection with this question of His Honour Judge Harhoff, I

14     will ask you something else.

15             MR. KRGOVIC: [Interpretation] Could we please see exhibit

16     2D02-0199 in e-court.  It is tab 20 in the binder of Mr. Zupljanin's

17     Defence.  Could we please see the next page in the B/C/S version of this

18     document.

19        Q.   Have you talked about reports, and I will now show you one

20     report.  This is a report concerning the situation as found and questions

21     relating to prisoners, collection centres, resettlement, and the role of

22     the SJB in connection with these activities.

23             MR. KRGOVIC:  Could we please have a look at the page marked

24     0032542.  That's the ERN number in the B/C/S version because this is a

25     long document in e-court.

Page 11127

 1             THE WITNESS: [Interpretation] Can you just tell me whose report

 2     this is?

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   I will show you the last page and then you will see.  Because you

 5     talked about reports which were sent.  This is a report of a commission

 6     whose chairman was Vojin Bera, about whom you just talked.  There are

 7     some other people who signed the report, because the subject was not just

 8     Prijedor, as you will see, but also Sanski Most and Bosanski Novi.  And

 9     this is an amalgamated report about the situation requested by

10     Mr. Stojan Zupljanin?

11             First of all, do you recognise the signature of Mr. Vojin Bera?

12        A.   I do.  As for other signatures, I do not recognise these.  But

13     below the signatures I can see the names of these persons.  I know

14     Vaso Skondric and Jugoslav Rondic very well.  As for the gentleman named

15     Ranko Mijic [phoen], I don't know him so well.

16             MR. KRGOVIC: [Interpretation] Can we please go back to the first

17     page of the document.

18        Q.   As can you see, what's discussed on the first page is the

19     situation in the municipality of Prijedor.  I don't know whether you've

20     seen this document before.  I don't believe so.

21             MR. KRGOVIC: [Interpretation] But can we now please go to page 4

22     of the document where Omarska is discussed.  That's in the B/C/S version,

23     0032-52530 [as interpreted].  The next page, yes.

24        Q.   So the second paragraph from the top where conditions in Omarska

25     are discussed.

Page 11128

 1        A.   Could you please zoom in, please?

 2        Q.   Yes.

 3             MR. KRGOVIC: [Interpretation] Zoom in the second paragraph which

 4     starts with the words:  "Together with prisoners."

 5        Q.   But, in any case, you can read it, and I will summarise it for

 6     you.  It's a new facility where a larger number of people can be

 7     accommodated.  It involves drinking water, toilets, and such.  And based

 8     on this report, we can see that it's exactly opposite and -- of the real

 9     situation and just as you told us, that this is a doctored report

10     presenting things in a beautiful way.

11        A.   Let me explain.  It is correct that the facility has all -- all

12     this that's mentioned, but the question was who was using these

13     facilities.  I can tell you that people who were there in detention or

14     prisoners there did not use the showers.  I know that for a fact.  And

15     that is the layer of veneer that covered up the rotting behind it.  You

16     have corroborated my belief that Mr. Zupljanin was exposed to lots of

17     lies.

18             MR. KRGOVIC: [Interpretation] I seek to tender this document into

19     evidence, Your Honours.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  As Exhibit 2D90, Your Honours.

22             MR. KRGOVIC: [Interpretation]

23        Q.   We'll go back to the previous document.

24        A.   Please allow me to add just one more sentence.

25        Q.   Go ahead.

Page 11129

 1        A.   I just want to give you my impression upon seeing this second

 2     paragraph on this page.

 3             I do not know what the reason was for such untruthful portraying

 4     of conditions, but the conditions as described by Vojin Bera and others

 5     remind me of what I have in this hotel called Ambassador here in

 6     The Hague.

 7             MR. KRGOVIC: [Interpretation] Can we please put 2D25 on the

 8     screen.

 9        Q.   This document, dated 30th of July -- first the Prosecutor showed

10     you a video.  Now, would you please take a look at the last page of the

11     document.  It's a document by the CSB sent to all SJBs, the command of

12     the corps, and the operative duty officer.  So the last page of the

13     document, we can see the signature of Stojan Zupljanin.

14             Now, let us go back to the first page, and we'll briefly go

15     through it.

16             You will find many sentences of yours in here.  What we have here

17     is a description of security situation and events that influence the

18     situation in the centre.  For instance, it's stated that because of war

19     activities, what is pronounced is rebellion, and there's mention of

20     paramilitary formations, the most serious crimes, and looting, ignoring

21     the laws, illegal bearing of arms, and spreading of misinformation.

22     There's mention of police members.  It is stated that in some areas the

23     situation is additionally complicated because of grave violations of the

24     rules of service by the employees of the public security station who act

25     illegally and do not abide by the measures that are within the competence

Page 11130

 1     of the organs of the interior.  Furthermore, there's mention of criminal

 2     and antisocial phenomena.  This has not seized, despite the fact that

 3     centre has drawn attention to the extent and harmfulness of such

 4     occurrences.

 5             Now, this is not trying to portray things in a pink -- with a

 6     pink shade.  This is a realistic presentation of situation by

 7     Mr. Zupljanin.

 8        A.   Yes.  And the Milos Group reported often about such situations.

 9     I do not wish to sound arrogant, but this is a compilation of a certain

10     number of intelligence data collected on the ground by the Milos Group

11     and myself.  This is the first time that I get to see this text in toto.

12     I can see to whom it was submitted, this report.

13             The introductory part of this report and the second

14     paragraph under it, the second paragraph I'd seen just a moment ago, I

15     can tell you that the report really reflects the situation on the ground.

16        Q.   And when such events were noticed, it is necessary to have

17     brought the support.  That's why this was sent to several addresses

18     because they were asking for assistance to resolve the problems existing

19     on the ground.

20        A.   Mr. Krgovic, I'm sure you've understood me well.  I specifically

21     stressed that the report was sent to certain recipients, and that was

22     done because I wanted to show the importance, both of the trends and to

23     the attempts -- to find assistance that will lead the way out of the

24     collapse.

25             If I may just add one sentence.  It may be of use to you.

Page 11131

 1             On the ground, it was not very clear.  One could not distinguish

 2     easily because -- between black and white, right and wrong.  During the

 3     entire period of 1992 and a part of 1993, many groups were present about

 4     whom nobody know -- nobody knew who they belonged to, even some of the

 5     local politicians, self-proclaimed or self-appointed politicians, people

 6     without any human dignity had their own groups maybe of their body-guards

 7     or just people working on promotion of the man's interest, so it would

 8     occasionally happen that when an operation needed to be done in relation

 9     to some members of one such group, we would get comments, Don't do it;

10     they belong to you know who.

11             And the local authorities were really powerful.  They are more

12     powerful than the authorities of today's state of Bosnia and Herzegovina

13     are, both in relation to how the laws were implemented and in relation to

14     taking care about citizens' freedom and so on.

15             In some areas, there were people who were so powerful, not only

16     in case of Mr. Simo Drljaca -- or I wish to correct myself.  I'm saying

17     Mr., Mr., but --

18             MR. OLMSTED:  Sorry.  I apologise for interrupting.  I don't

19     think there's a question out there that he is answering.  And given the

20     limited time, I'm hoping that Defence counsel can keep it on track.

21             JUDGE HALL:  After three days, counsel on both sides realise that

22     they have to guide this witness.

23             Please do so, Mr. Krgovic.

24             MR. KRGOVIC: [Interpretation]

25        Q.   Comrade Radulovic - and I apologise, I almost called you Mr. -

Page 11132

 1     but thank you for your explanation, yet you were saying not only

 2     Simo Drljaca, you meant in other municipalities as well.  But we'll go

 3     through that through documents.  If you could just confirm whether this

 4     is in keeping with what you know.

 5             And I apologise.  I really started talking fast.

 6             Let us go back to the document.  It is stated here that some of

 7     the active and reserve policemen have taken advantage of the wartime

 8     situation and participate in various criminal activities and illegally

 9     confiscate objects and property from citizens for themselves.  This is

10     something that you told us during your testimony on several occasions.

11        A.   That's correct.

12             MR. KRGOVIC: [Interpretation] Let us turn the page, please.

13        Q.   These kind of activities seriously damages the reputation of the

14     profession and honorable and decent members of the service.

15        A.   That's correct.

16        Q.   The problem was basically that a group of people who came to the

17     police or who already worked for the police damaged the reputation of

18     those members of the service who did their job honourably and decently.

19        A.   That's correct.

20        Q.   Furthermore, it is stated that criminals very often in conducting

21     their criminal activities were using uniforms and insignia of the Serbian

22     army and the police.

23        A.   That's correct.

24        Q.   At the bottom of the page, we can see that some individuals in

25     the police in their attempt to use the easier path close -- or turned

Page 11133

 1     their eyes away from such incidents.  Is that correct?

 2        A.   Yes, that's correct.

 3             MR. KRGOVIC: [Interpretation] Can we see the following page,

 4     please.  Page 3 in the Serbian version where we can see that in the first

 5     paragraph, at the beginning, because there are fears related to

 6     information and in some cases because of the people's involvement in

 7     various criminal affairs, following the easier path, people do not carry

 8     out some of their duties, and the responsibility is very often something

 9     that they pass on to the centre.

10             So --

11             THE INTERPRETER:  Could Mr. Krgovic repeat his question.

12             JUDGE HALL: [Previous translation continues] ...

13             MR. KRGOVIC: [Interpretation] I apologise, I spoke very fast.

14        Q.   I will have to repeat the question.  I really speeded up.

15             So public security stations following this easier path failed to

16     implement some orders they received from the centres.  They covered up

17     criminal activities, sometimes because they were themselves involved.

18     And the responsibility, they tried to pass on to others and to the centre

19     or shift to others and to the centre.  Is that correct?

20        A.   Yes, that's correct.  We often discussed how the people

21     committing crimes were justifying their actions by claiming that they

22     received approval from the centre or maybe even Stojan Zupljanin.

23     Before -- before this particular report, we had already written about it.

24     You can check it in your documents.  I believe that this report that we

25     see is an attempt to make it known to everyone that such attempts should

Page 11134

 1     not and will not be tolerated.

 2        Q.   In the second paragraph, it is stated that precisely because of

 3     such things there is fear among other people which leads to division

 4     between ethnic groups and mistrust of the institutions of the system.

 5             Furthermore, in the text, later in the text, Mr. Zupljanin points

 6     out that situation might get out of control which will have grave

 7     consequences for the security situation and the law and order, and that

 8     risk really existed.  Am I correct?

 9        A.   Yes, that's correct.  With all due respect, this report is

10     something that is maybe up to 80 per cent compilation of information

11     received by the Milos Group.  I recognise the wording, terminology.  I

12     think this is a rather illustrative example of the situation on the

13     ground.

14        Q.   It also states here that -- you remember the sentence that you

15     frequently mentioned, that this actually leads to the bitterness and

16     indignation among the Serbian people in whose name and symbols these

17     criminal acts are being committed.

18        A.   Yes, correct.

19        Q.   Further down, Mr. Zupljanin is asking for measures to be taken to

20     stem such conduct.  And if you take a look at item 1 on that same page

21     where he orders and states that the public security stations may carry

22     out only jobs and tasks falling within their competence.

23             MR. KRGOVIC: [Interpretation] Could we now move on to page 4 in

24     the Serbian.  Page 4, please.

25        Q.   And then under item 2 it says:

Page 11135

 1             "Public security stations may not receive or carry out orders,

 2     decisions, conclusions, standpoints, et cetera, of crisis and

 3     regional staffs or other legal entities."

 4             I don't want to read the whole paragraph.  But this is

 5     essentially what you have told us during your evidence here, that these

 6     matters were resolved at the levels of the police stations and that they

 7     were acting on orders from the local authorities.  Correct?

 8        A.   Yes.

 9        Q.   And, in this manner, the functional unity of the service itself

10     was being undermined?

11        A.   Correct.  And in some cases even where you had town commands,

12     these town commands would resubordinate public security stations and

13     place them under their own authorities so that police stations literally

14     reported to town commands and not to the ministry as they should

15     according to the rules of service.

16        Q.   That was the case in Skender Vakuf, in Kljuc, in Derventa

17     specifically?

18        A.   Well, I don't want to waste any of -- more of your time.  I will

19     just answer with yes or no, and I will be as brief as I can.  Yes.

20             JUDGE HARHOFF:  Mr. Radulovic, did I understand correctly that

21     when you used the term "town commands" you were referring to the

22     Crisis Staffs?

23             THE WITNESS: [Interpretation] No.  No, Your Honours.  In addition

24     to Crisis Staffs, there was another body called the town command.  And

25     the town command had the powers -- or, rather, they arrogated the powers

Page 11136

 1     to place under their competence all armed units, for the purpose of

 2     defending the city or town, and all other activities that were linked to

 3     the -- or that had to do with the area where such a town command was

 4     established.

 5             JUDGE HARHOFF:  Thanks.  Do you know who established the town

 6     commands or how they were established?

 7             THE WITNESS: [Interpretation] They were established with the

 8     approval of -- and the -- by the powers of the political authorities at

 9     the local level.  And for this there was also the approval of the

10     superior republic bodies or organs.

11             JUDGE HARHOFF:  Do you have any information about what the

12     relations were between the Crisis Staffs and the town commands, where

13     they existed in parallel?

14             THE WITNESS: [Interpretation] Your Honours, you're asking my

15     opinion.  Of course --

16             JUDGE HARHOFF: [Previous translation continues] ...

17             THE WITNESS: [Interpretation] I will provide it --

18             JUDGE HARHOFF: [Previous translation continues] ... please,

19     Mr. Radulovic, if you don't know, then just say so, and we'll go on.

20             THE WITNESS: [Interpretation] I would not be honest if I said

21     that I didn't know.  And that is why I said that I will answer your

22     questions.  There were very close links between them.  And if I may add,

23     Crisis Staffs were the ones who appointed commanders at the town

24     commands, and they were in charge of all personnel issues -- or, rather,

25     all personnel appointments in -- into such staff commands.

Page 11137

 1             THE INTERPRETER:  Town commands; interpreter's correction.

 2             JUDGE HARHOFF:  Thank you.

 3             MR. KRGOVIC: [Interpretation]

 4        Q.   Mr. Radulovic, would you now please take a look at items 9

 5     and 10.

 6        A.   I can't see them.

 7             MR. KRGOVIC: [Interpretation] That's on page 5.

 8        Q.   Please take a look at paragraphs 9 and 10, which read:

 9             "You are to immediately take immediate, decisive, and

10     uncompromising action to throw light on all criminal activities in public

11     security stations and police stations, document them, and take

12     appropriate legal measures of criminal misdemeanour, disciplinary, and

13     material responsibility including temporary suspension and the measure of

14     detention prescribed by the Law on Criminal Procedure and with the prior

15     approval of the centre."

16             This is precisely the order, if I may call it so, that you

17     received from Mr. Zupljanin when you went to Teslic.  Correct?

18        A.   Exactly.  That is what -- this is how the work or the job was

19     done in Teslic, in keeping with this.

20        Q.   And then we see paragraph 10 where it says:

21             "Deliver documented information, facts, and evidence, together

22     with criminal reports, even against employees of public security stations

23     to the competent public prosecutor.  In cases where the public

24     prosecutors are inactive, deliver criminal reports ... directly to the

25     senior public prosecutor or the nearest public prosecutor.  After taking

Page 11138

 1     measures against members of the active and reserve forces and removing

 2     them from the organ, immediately take them off wartime duty ..."

 3             And that's exactly what you did in Teslic.  Correct?

 4        A.   Yes.

 5        Q.   And, again, in paragraph 7, it says:

 6             "Establish the existence and activity of paramilitary formations

 7     and inform the competent military security organs ..."

 8             And then it says:

 9             "Document the criminal activities of these units and

10     individuals."

11             That's exactly what did you in Teslic.  Correct?

12        A.   Yes.

13        Q.   Now, in order to carry out these tasks and orders, it was

14     necessary to launch a larger-scale action.  And in some centres, as you

15     said, there were certain difficulties, centres of public security

16     stations, because they had actually -- they had actually split from the

17     centre.  Correct?

18        A.   Yes.

19        Q.   Now I will point out a portion of this document, and I am sure

20     you will agree with me.

21             MR. KRGOVIC: [Interpretation] That will be in document

22     Exhibit P621.  That's the Prosecution's exhibit.

23        Q.   This is a report on the work of Centre of Security Services,

24     drafted by Stojan Zupljanin.

25             MR. KRGOVIC: [Interpretation] That's in tab 4 of the Zupljanin

Page 11139

 1     folder.  Page 20 -- or, rather, the ERN number is 0749643.

 2             I don't know if this is a good time for a break, or do you want

 3     me to go on?

 4             JUDGE HALL:  We're about three minutes early, but if this is

 5     convenient, I suppose we could take the break here.

 6             MR. KRGOVIC:  Yes.  It's a convenient time, Your Honours.

 7                           [The witness stands down]

 8                           --- Recess taken at 10.22 a.m.

 9                           --- On resuming at 11.00 a.m.

10                           [Trial Chamber confers]

11             MR. ZECEVIC:  Your Honours, I was reminded by Mr. Pantelic that

12     Your Honours wanted our -- the position of Defence on the videolink.

13             JUDGE HALL:  Yes, thank you.

14             MR. ZECEVIC:  And we do not object.

15             JUDGE HALL:  Thank you.

16             MR. ZECEVIC:  Both Defences.  Thank you.

17                           [The witness takes the stand]

18                           [Trial Chamber confers]

19             MR. KRGOVIC: [Interpretation]

20        Q.   Mr. Radulovic, you see the document before you.  And then I'm

21     referring to the second paragraph, and I will read out the portion of it.

22     And it says, in brief:

23             "Inefficiency, lack of professionalism, and superficiality of

24     work in a number of SJBs contributed to a large extent to the functional

25     detachment of a number of SJBs from the centre.  This has gratefully

Page 11140

 1     affected the overall unity and the social role of the security organs and

 2     services.  Parallel to that, some of the SJBs connected themselves with

 3     the local politics and local political leaders, thereby neglecting their

 4     legal obligations and powers."

 5             In effect that was one of the greatest problems that you had in

 6     the area covered by your CSB in 1992.  Correct?

 7        A.   Yes.

 8        Q.   And also, they reiterate here the conclusion about

 9     irresponsibility and political -- politique-ing.  And then in the next

10     paragraph, which confirm was you said today, it says:

11             "It occurs on a quasi-regular basis that a number of the SJBs pay

12     no attention to requests from the centre for information on certain

13     issues, that is, there is no timely reaction to certain requests from the

14     centre.  This affects the unity and action capability of security organs

15     and services as a unified security mechanism."

16             In fact, this means that it was very difficult to control the

17     overall security situation and to draw correct conclusions and

18     assessments in the area because in order to do that you needed to have

19     proper information; correct?

20        A.   Well, yes, of course.  As in medicine, the right information that

21     you get, as in medicine for diagnosing an illness that's already halfway

22     healing.

23        Q.   And, in fact - and you observed this too - this made it

24     impossible for the centre to have the real picture of the situation on

25     the ground because of such conduct by some of the SJBs; correct?

Page 11141

 1        A.   Yes.

 2             MR. ZECEVIC:  Sorry 27, line 10, after the -- the answer "Yes,"

 3     the rest of the -- that paragraph should be a question by Mr. Krgovic.

 4     After "Yes."  That's 27, line 10.

 5             MR. KRGOVIC: [Interpretation] During the examination-in-chief --

 6     I'll now move on to another topic.  When the Prosecutor asked you whether

 7     you knew whether anything had been done in order to prevent incidents and

 8     some criminal acts by certain members of the SOS, you mentioned that had

 9     you some information from Mr. Zivko Bojic who told that you that there

10     were some plans in that respect and that some action was taken but you

11     didn't really know the details.  Do you recall that?

12        A.   Yes, correct.  That's what I said.

13        Q.   Now I would like to show you a document.

14             MR. KRGOVIC: [Interpretation] Exhibit 1D198.  That's the

15     Zupljanin folder, tab 13.

16        Q.   This is an operative work-plan.  Now, you remember that on a --

17     on the 12th of May you submitted some reports which indicated that there

18     were certain criminal acts committed against Muslim small businesses

19     where some hand grenades were placed or they were mined and so on.

20             Now here we see the date of this operative work-plan is the

21     25th of May, 1992, for solving robberies, terrorism, extortion,

22     et cetera, which have escalated in the territory of the Banja Luka SJB,

23     all this being done by certain uniformed individuals and groups.  And

24     then mention is made of SOS, TO, Red Berets, and similar.

25             MR. KRGOVIC: [Interpretation] Could we now please see page 5 of

Page 11142

 1     this document in the Serbian version.

 2        Q.   As you can see, we have the signature on the left-hand side.  I

 3     believe that's Zivko Bojic's signature.  That's what you are referring

 4     to; Correct?

 5        A.   Yes.

 6        Q.   And then on the right-hand side there is the signature of

 7     Mr. Zupljanin?

 8        A.   Yes.

 9        Q.   Now let's go back to page 2 of this document where these

10     individuals are named, identified.  And here mention is made of an

11     individual that you mentioned when you spoke about those self-proclaimed

12     dukes.  There was this man called Palackovic, whose last name was

13     Palackovic.  Do you recall?

14        A.   Yes, I know who this is.

15        Q.   And then there is mention here of a Mercedes that was seized, and

16     these people were -- these people engaged in stealing vehicles and

17     throwing hand-grenades into houses.  Now -- and some other individuals

18     are mentioned.

19             MR. KRGOVIC: [Interpretation] Now, could we now go back to page 5

20     now for a moment.  Page 5, please, where it says, in the fourth

21     paragraph:

22             "... these individuals were in a way self-organised ..."

23             The fourth paragraph from the top in the Serbian version.  Begins

24     with the words:

25             "In view of the fact that these individuals were in a way

Page 11143

 1     self-organised in the guise of membership of the SOS that they were

 2     well-armed and that some of them were mobilised by the JNA ..."

 3             It talks about these persons.

 4             And then in the following paragraph:

 5             "In order to ensure an efficient implementation of this plan, we

 6     need to have prior agreement with the regular and military courts on

 7     keeping all of the arrested persons in detention to present organised

 8     resistance.  The reasons for detention exist for almost all of them."

 9             In essence, when this activity was planned, just like with the

10     one in Teslic, a similar method was envisaged here.  Is that correct?

11        A.   Well, one might say so.

12        Q.   I will now show you the next document.  This is 1D201.

13             This is sometime later because time was necessary to implement

14     the plan.

15             MR. KRGOVIC: [Interpretation]  And this is tab 14 in the

16     Zupljanin Defence folder.

17             MR. OLMSTED:  Your Honour, I object to where this line of

18     questioning is going to lead.  This witness has said that was he was

19     aware that there was an operative plan, but he has no knowledge of

20     whether it was ever carried out.  And I believe the Defence now are going

21     to try to show case files, of course, that this witness has never seen

22     before, to try to convince him that that was -- that's wrong.  And I'm

23     not -- we're not going get anywhere with that information.  And it's

24     going to take up a lot of time.

25             And I note that it's doubtful that witness has ever reviewed any

Page 11144

 1     of these case files so can really talk about what's contained in them.

 2             JUDGE HALL:  Mr. Krgovic, whereas you can take the objection that

 3     Mr. Olmsted shouldn't anticipate you, isn't it apparent that he is

 4     correct in, as he says, it's something that's not going to assist us at

 5     the end of the exercise?

 6             MR. KRGOVIC: [Interpretation] Your Honours, I just wish to

 7     refresh the witness's memory, if possible, as my learned friend would

 8     say, to present this document to him and to ask him whether any of the

 9     persons who are listed in this operative plan were, indeed, arrested.

10     Just to see if the witness remembers that.  Because a lot of time has

11     passed.  He was not specifically asked about these persons.  I just

12     wanted to ask him whether he knows whether they were -- there were

13     criminal files filed against some of these persons and whether some of

14     them were arrested or not.

15             So that was just the substance of my --

16             MR. OLMSTED:  The case files, Your Honour, speak for themselves.

17     And they are admitted into evidence.  And, you know, this is anecdotal

18     evidence of something that -- we're not contending that these case files

19     are unauthentic in any way; this witness simply is not going to have any

20     information to add with regard to these case files.  And if the Defence

21     counsel has questions regarding these particular SOS members, he should

22     just put the question to the witness; does he know what happened to

23     particular members of the SOS or paramilitary groups, et cetera.

24             JUDGE HALL:  Mr. Krgovic, I was going to suggest exactly what

25     Mr. Olmsted has just -- has just proposed.  Just put the names to the

Page 11145

 1     witness.

 2             MR. KRGOVIC: [Interpretation]

 3        Q.   Do you know that at one time, if you know, that, for example,

 4     Palackovic, Jungic, Kajkut, some of these persons whom you related to SOS

 5     were arrested and prosecuted?

 6        A.   I am not familiar that.  I did not have this information.  To be

 7     frank, I do not remember this.

 8        Q.   Because it was not your duty to follow what happened later on?

 9        A.   Yes, that's right, exactly.

10        Q.   I will move to another subject now.

11             During your testimony, you talked about the special unit attached

12     to the Banja Luka CSB.  Do you know that at one time, while the unit was

13     still in the area of Kotor Varos, that for various reasons you mentioned,

14     suggestions that you mentioned to Mr. Zupljanin, that they should be

15     disbanded, that this detachment was indeed disbanded, and that the corps

16     of this detachment came under the control of the army.  And that was at

17     some point in August 1992?

18        A.   I remember that there were certain transformations in place;

19     however, I do not remember the time-line.  And I also do not know what

20     the actual motives for doing that were.

21        Q.   Let me just show you briefly a document, 2D02-4204 [sic].

22             MR. KRGOVIC: [Interpretation] 2D02-42 -- 0424.

23             I apologise, I will repeat once again:  2D02-0424.

24        Q.   Do you know Sreto Gajic?

25        A.   Yes, of course.

Page 11146

 1        Q.   These are the minutes about his visit to the

 2     Security Services Centre in the month of July and in early August.

 3             Please have a look at the bottom.  Point 1:

 4             "The special police detachment, 100 men strong, will be put at

 5     the disposal of the 1st Krajina Corps, under the command of

 6     General Talic, as of the 10th of August, 1992."

 7             MR. KRGOVIC: [Interpretation] Could we please have a look at

 8     page 2 of this document now.

 9        Q.   The handover of the unit will be carried out at 0800 hours on the

10     10th of August, 1992, in Kotor Varos where the unit is deployed.  The

11     handover will be attended by Djuro Bulic, SJB sector chief on behalf of

12     the CSB, and by Colonel Bogojevic, military security chief on behalf of

13     the 1st Krajina Corps."

14             Does that match the time when you heard that some transformation

15     did take place?

16        A.   Yes.  I remember that it happened after the death of

17     Colonel Stevilovic.  He was replaced by Colonel Bogojevic.  And I

18     remember that the transformation took place at the time.  However, I

19     repeat that I don't know why this happened, what the motives were,

20     because I just didn't deal with that.

21        Q.   And now that you've mentioned the death of Colonel Stevilovic,

22     Stevan Markovic also killed at the same time; is that correct?

23        A.   Yes.

24        Q.   The death of these two men had a major impact on the security

25     situation in the area because they were expert professionals, especially

Page 11147

 1     Colonel Stevilovic, together with whom you participated in some actions;

 2     is that correct?

 3        A.   That is correct.  I couldn't say who was a better man and a

 4     greater professional of these two.  I couldn't give better attributes to

 5     one as opposed to the other.

 6             If I may just add, there was an idea at the level of the

 7     Security Services Centre and the 1st Krajina Corps and even wider that a

 8     mobile battalion should be set up.  It should be a police battalion that

 9     would, in fact, resolve all incidents relating to the activities of

10     renegade groups, or should I say criminals.  They would, in fact, go

11     wherever a problem arose.  It would be very mobile.  And this was an idea

12     whose proponents and advocates were the late Stevan Markovic and the late

13     Colonel Stevilovic, of course, together with the leadership of the

14     then-Security Services Centre in Banja Luka.  I believed that this was

15     harmonised with the ministry or that somebody in the ministry had the

16     same idea.

17        Q.   When you talked about the activities of the special detachment, I

18     will show now an exhibit, P591, a Prosecution Exhibit.

19             We can see that this is the report from the army Main Staff,

20     signed at the time by Mr. Tolimir.  It's the Department for Intelligence

21     and Security Affairs.

22             MR. KRGOVIC: [Interpretation] Could we please see page 5 of this

23     document.

24        Q.   The date is the 28th of July, 1992.  And on page 5, the

25     then-Colonel Tolimir deals with the SOS, and he says:

Page 11148

 1             "The Serbian defence forces from Banja Luka SOS commanded by

 2     Stevandic, Nenad who is at the same time the president of the

 3     Serbian Falconers' Society.  Private businessmen have much influence on

 4     the SOS and so do some officials from the SJB and SNB at the Banja Luka

 5     CSB."

 6             Is that correct?

 7        A.   Yes.  This is a brief version, but it absolutely matches the

 8     information I had.

 9        Q.   And then it says:

10             "One part of the SOS, that's the SOJ, has been officially

11     disbanded and became part of the establishment of the police detachment

12     of the Banja Luka CSB, but it is not under actual control of the

13     detachment and CSB command.  One part of members have joined the

14     Banja Luka TO, and another part headed by Branko Palackovic, and we

15     talked about them, are now in detention."

16             Was that how you saw this group, the mixture of the SOS and the

17     special unit?

18        A.   Yes.

19        Q.   And now, just let me show you another document.  And you might

20     help us clarify something.

21             When answering to a Prosecutor's question as you might remember,

22     you talked about a report that had to do with the meeting with

23     General Mladic in Teslic.  The Prosecutor showed you the document that

24     bears no date and which was found -- let me not say where because of the

25     confidentiality of this document.  And he asked you whether you

Page 11149

 1     remembered if the information was conveyed to Mr. Zupljanin.

 2             I will now show you another document which deals with this

 3     specific meeting.

 4             MR. KRGOVIC: [Interpretation] So if we could please see in

 5     e-court the exhibit 65 ter 871, which is marked as P1353.14.

 6             And let me just see what the tab number is.

 7             It's number 34.  Tab 34 in our folder.

 8        Q.   This is a report dated the 30th of October, 1992.  And if you

 9     have a look, these are operative workers, Radulovic, Stjepanovic, and

10     Sajinovic, three operatives.  It discusses the meeting.  And please have

11     a look who it was sent to.

12        A.   Yes, I can see it.

13        Q.   To the chief of the CSB and the chief of the SNB.

14             When you discussed about the first document which is very

15     similar, you said that it was talked at the meeting about replacing the

16     leadership of the SNB and so on.  I think that when you talked about

17     which document you had sent to Mr. Zupljanin, I think that you had in

18     mind this document which discusses the same incident but contains

19     different information and different elements.  And I think these were two

20     different documents which were sent to different addresses.

21             So if you can help us clarify this, please.

22        A.   I apologise for not answering immediately.  I'm waiting for your

23     question to be interpreted.  But I can answer.

24             I remember well this information.  The information was very

25     serious because it came from the man who, at the time, according to some

Page 11150

 1     of our assessments, enjoyed more respect than Radovan Karadzic himself.

 2     And what he said at the meeting was of great concern.

 3             We were surprised.  And considering the seriousness of what we

 4     heard, and we heard it from a source that we absolutely trusted, we later

 5     even checked that, as I say, considering the weight of that, we did not

 6     introduce ourselves as members of the Milos Group.  We, rather, said our

 7     first and last names so that we would show that personally we do not

 8     agree with such nonsense, regardless of who said that and where.

 9             If you wanted to refresh my memory, let me refresh your memory,

10     that one of you told me, Was it possible that Mr. So-and-so said that.

11     And I told you, Is it possible that Mr. So-and-so, that this information

12     has to do with, said what he said in Srebrenica in public through a

13     loud-speaker and in front of cameras.

14             So I wanted to tell you that what is noted here is terrible.  I

15     also want to say that I could see from this the problems in which the

16     state security and public security services were, because no one from

17     these two services, with all due respect, including the accused, did not

18     have such authority, such dignity, such references, so that any of them

19     could be compared with the person who said this at the meeting in Teslic.

20             And when such things are stated publicly and when fools get to

21     hear that, you may as well imagine what kind of reaction you can expect

22     on the ground.  Because if someone tells you publicly that you can do

23     whatever you want with non-Serbs and that you won't be held responsible

24     for that, I think that that's a real disaster.  I still think that today,

25     I thought so at the time, and I shall always be of the same opinion.

Page 11151

 1             Speaking sincerely, I did not have much trust in the type of

 2     generals who came to the forefront at the time throughout

 3     Republika Srpska because, by contrast to other people, I know that they

 4     were a specific kind of generals.  By that, I mean that they were not

 5     schooled regularly but they completed military academies in nine months.

 6     So I call them pregnant generals because this was the time of pregnancy.

 7     So to ridicule this we call them pregnant generals.  Eventually it turned

 8     out that they really had been pregnant and that they give birth to

 9     something that was never to be found in the dignity and honour of the

10     Serbian People.

11        Q.   And this document is your report?

12        A.   Yes.  That's -- there's no doubt about that.

13             MR. KRGOVIC: [Interpretation] I would like to ask for this

14     document to be enter into evidence because it was not part of our

15     package.

16             JUDGE HALL:  Admitted and marked.

17             MR. OLMSTED:  This -- which ... are we talking about the --

18             JUDGE HALL:  I understand it's already in.

19             MR. OLMSTED:  That's what I was about to say.  The

20     30 October document is already in.  We tendered it.

21             MR. PANTELIC:  And I do apologise.  Just a correction.  On the

22     bottom left of the English version, we have two times chief of CSB, times

23     one, so probably the other should be -- it's a typo.  It should -- SNB,

24     like State Security Service, yes.

25             MR. KRGOVIC: [Interpretation]

Page 11152

 1        Q.   Mr. Radulovic -- or, rather, Comrade Radulovic, in relation to

 2     the situation in Banja Luka at the time and around that time, there were

 3     quite a few -- there were quite a few activities of the -- not only SNB

 4     and State Security Service but there was also a great presence of foreign

 5     intelligence services, including the Croatian one?

 6        A.   That's correct.

 7        Q.   And as part of that, there were quite a lot of misinformation

 8     being placed, very often in relation to some of the leadership figures of

 9     Republika Srpska, both military and political.

10        A.   Yes.

11        Q.   And as part of that, it could occur that a National Security

12     Service would get a piece of information that was planted and which would

13     then leak out as factual information.  It was very difficult, especially

14     if the technical -- reliable technical means were used, and you, as part

15     of the intelligence work that you conducted, you used the same methods,

16     weren't you?

17        A.   Mr. Krgovic, I see where you're going with this.  You want to say

18     that it -- there was a possibility that information received by

19     Milos Group were not vary verified.

20        Q.   No, no, no.  I'm talking about a specific piece of information

21     that was not discussed up until this moment.  So I wasn't talking in

22     general terms.

23        A.   But let me just add one more word.

24        Q.   Yes, go on.

25        A.   Well, I could accept what you just put, namely, your claim; but

Page 11153

 1     facts can confirm that we were almost invariably absolutely right.

 2             And let me complete my statement by saying that you're here

 3     talking about operative tricks, and, yes, it's true that intelligence

 4     services tried to trick each other.  And, of course, it is possible that

 5     something was planted, some kind of information that was completely

 6     different to the actual state of affairs, and, in that respect, I agree

 7     with you, that such things could have happened.

 8        Q.   We have just agreed upon something, but I was not questioning the

 9     reliability of your information.  We have seen that a lot of your

10     formulations and wording found its way to the reports written by

11     Mr. Zupljanin, but there was something else that was mentioned in passing

12     by and is of great concern to our clients.

13             THE INTERPRETER:  Could the counsel please repeat the number of

14     the document.

15             MR. KRGOVIC: [Interpretation] 1D37.  It has to do with the

16     evacuation from Kotor Varos.

17             JUDGE DELVOIE:  Mr. Krgovic, what -- in which binder, please.

18             MR. KRGOVIC: [Interpretation] [Overlapping speakers] ... tab 40.

19             JUDGE DELVOIE: [Previous translation continues] ...

20             MR. KRGOVIC: [Interpretation] Zupljanin Defence binder.

21             JUDGE DELVOIE:  Thank you.

22             JUDGE HALL:  Mr. Krgovic, I should point out to you that you have

23     exhausted the four and a half hours that you had requested.  At what

24     point do you expect you would be completed?

25             MR. KRGOVIC: [Interpretation] Your Honours, this is the last

Page 11154

 1     topic I would like to present to the witness, and, therefore, in about

 2     five to ten minutes maybe.

 3             JUDGE HALL:  Thank you.

 4             MR. KRGOVIC: [Interpretation] Can we please see the following

 5     page of the document in the B/C/S version.

 6             THE WITNESS: [Interpretation] I have only one page.

 7             MR. KRGOVIC: [Interpretation] Next page, please.  Yes, that's the

 8     one.

 9             Can we please zoom in on the upper part of the document.

10        Q.   We've heard testimony here about who took part in the

11     negotiations concerning the group leaving Vecici.  What we can see here

12     is -- are the minutes of the meeting of the Kotor Varos group.  We can

13     see here who were the persons who reached the decision concerning the

14     transfer of the armed group and the evacuation of everyone from Vecici,

15     both civilians and those who were armed.  Let me repeat that

16     Colonel Vogojevic [phoen], who took place of Colonel Stevilovic, informed

17     the gathered people that he had been ordered by General Mladic that

18     nobody should leave Vecici before all the armaments were surrendered.

19             And then, further on, President Djekanovic from Kotor Varos says

20     that there are differences between the position of Karadzic and the order

21     issued by Mladic.  Mayor Trivic then presented the views of the corps

22     command, saying that nobody should leave before the -- all the weapons

23     were handed in unconditionally and asked for the ultimatum to be

24     repeated.

25             Furthermore, he also stressed that President Djekanovic should,

Page 11155

 1     in his conversation with Karadzic, inform Karadzic that his position was

 2     not -- was something that is not -- has not been complied with and that

 3     he should inform Karadzic that unconditional surrender is the only

 4     solution.

 5             MR. OLMSTED: [Previous translation continues] ...

 6             MR. KRGOVIC: [Interpretation] It's on the following page in the

 7     English version.

 8             MR. OLMSTED: [Previous translation continues] ... I'm not sure it

 9     was necessary for Mr. Krgovic to read the whole document, but it is -- I

10     believe the last -- it's -- on the English, it is page 3, I think.

11             THE INTERPRETER:  Could Mr. Krgovic also kindly read slowly.  The

12     interpreters can really not follow what he is reading.

13             JUDGE HARHOFF:  Mr. Krgovic, did you hear the interpreter's

14     comment?

15             MR. KRGOVIC:  Yeah, I heard it.  I do apologise.

16        Q.   [Interpretation] From this document that is showing who the

17     apartments were, at which level the decision was reached, and how the

18     withdrawal was agreed upon, my client, Mr. Zupljanin, is saying that was

19     in no way related to evacuation, that he didn't take part in any

20     negotiations, that he wasn't present at the site of evacuation, and that

21     the information that reached you, that himself and Colonel --

22             THE INTERPRETERS:  Another colonel whose name the interpreters

23     couldn't hear.

24             MR. KRGOVIC: [Interpretation]

25        Q.   -- and who also didn't take part in the negotiations were not in

Page 11156

 1     any way involved, that there was no mention of money.

 2             Would you -- would you accept such a claim?

 3        A.   Yes, I could accept such a claim easily.

 4             What I wanted to say was that the information wasn't something

 5     that we actually drafted and then submitted to either public or

 6     State Security Services.  I told you - if I need to remind you - that

 7     that type of reports were drafted literally by - and I will give you a

 8     full name and surname - by Branko Ratic, who later became a head of

 9     Tajfun, which this -- this brought us into a situation which could all

10     cost us our lives because that man was talking about all the most

11     important political and other leaders of Republika Srpska.  And he would

12     then show a piece of footage saying, General Talic, that is something

13     about you; General Mladic, this is what we have about you.  And he would

14     present that on the screen.  And then one after the other in the same

15     manner.  I'm not sure whether Mr. Stojan Zupljanin found himself in such

16     a situation with some kind of blackmail taking place.  And then when

17     those persons who went through this level of his complication --

18             THE INTERPRETER:  Could the witness repeat the last part of the

19     answer.

20             JUDGE DELVOIE:  Mr. Witness, Mr. Radulovic, the interpreters

21     asked you to repeat the last part of your answer, please.  They couldn't

22     follow.

23             MR. KRGOVIC: [Interpretation] I apologise.

24        Q.   The witnesses didn't hear -- or, rather, the interpreters didn't

25     hear the last part of your answer.  Could you please start from the

Page 11157

 1     misinformation.

 2        A.   Yes, I will do my best, although ...

 3             What I was saying was that such kind of misinformation that was

 4     being sent to addresses of various consumers was something that was the

 5     end of us, because some of the individuals wanted to take their revenge

 6     on Branko Ratic for collecting such information.  And then they saw that

 7     among the information there were reports by the Milos Group, and for that

 8     reason the members of the Milos Group also were being arrested,

 9     interrogated.  And that was the reason why I was forced to leave the

10     State Security Service of Republika Srpska, and so on and so forth, which

11     is, all in all, something unnecessary for you.

12             But I did want to say that precisely because of this method of

13     operation by Tajfun, which may have been a patriotic way of work, but it

14     was really not professional type of work, and it had overreaching

15     ambitions, because Mr. Branko Ratic, and we're still friends today,

16     wanted to be the number one security person in Republika Srpska.  And I

17     don't know what magic did he use, but, at one point, he did manage to get

18     the ear of Radovan Karadzic to such a degree even that on several

19     occasions, in my presence, he was establishing more direct contacts with

20     Mr. Karadzic than I do with my wife after 35 years of marriage.

21        Q.   Of course, such misinformation could occasionally be used to have

22     some people discharged for political games and that it could be used for

23     very specific purposes, if politicians would use misinformation like

24     this.

25        A.   Viewing it from this vantage point in time, my opinion would be

Page 11158

 1     different from the one in -- I had in 1992 and 1993, yet I believe I

 2     should stress that among the information provided by Tajfun and forwarded

 3     by Branko Ratic, there were also accurate information.  The only problem

 4     was that he did not hold the control mechanism in his hands, something to

 5     check up and verify his product.  He was the last person in the chain of

 6     custody.  He was the one handing in his reports to the top leadership

 7     members, very often reports based on unverified information.

 8             And now I'm coming to my point.  Because of such way -- such

 9     activities of Tajfun, after realising that nobody's heeding what we are

10     saying, nobody in Republika Srpska at least, we turned to Belgrade and

11     asked for both Tajfun and Milos Group members to be called in and to ask

12     our colleagues, professionals, from Serbia, in order to exert their

13     influence and convince Tajfun to refrain from handing in their reports to

14     institutions, organs, or important individuals in Republika Srpska,

15     without their information first being verified and submitted to myself.

16             JUDGE DELVOIE: [Previous translation continues] ...

17        A.   As the chief --

18             JUDGE DELVOIE: [Previous translation continues] ... could you

19     remind me precisely where we are going.

20             MR. KRGOVIC: [Interpretation] Your Honour, the witness actually

21     went outside my question, and he said that at one point Mr. Zupljanin did

22     not forward the information, but I won't go into this anymore.

23             I would just like to show a document that has to do with this:

24     1D03-3427.  And that's my last question for this witness.

25        Q.   This is just to give the background for the misinformation

Page 11159

 1     surrounding Mr. Zupljanin.  And please take a look at the document.  It

 2     is a report from the 3rd of August, 1992, a meeting of the Assembly of

 3     the Autonomous Region of Krajina.  And we see that there is here a

 4     certain number of members who were questioning or challenging the

 5     suitability of the members of the government.

 6             You must know -- I'm waiting for your answer to come -- to enter

 7     the transcript.

 8        A.   Yes.

 9             JUDGE DELVOIE:  Mr. Krgovic, is this your binder?  I can't

10     find it.

11             MR. KRGOVIC: [Interpretation] Yes.

12             JUDGE DELVOIE: [Previous translation continues] ...

13             MR. KRGOVIC: [Interpretation] No, I apologise.  This is

14     Mr. Zecevic's binder, tab 85.

15             JUDGE DELVOIE:  Thank you.

16             MR. OLMSTED:  The damage is already done, but we object to the

17     question.  It really just -- it's -- the question is about

18     misinformation, and the counsel asked a question about a document.  This

19     is nothing about misinformation.  And I think it's just really -- of

20     course, he is entitled to ask leading questions, but suggesting, you

21     know, theories to the witness is not the way to go.

22             MR. KRGOVIC: [Interpretation] Your Honours, I don't see what the

23     problem is.  Perhaps there is an misinterpretation of my question.

24        Q.   So, Witness, the misinformation that we mentioned earlier, that

25     Mr. Zupljanin participated in negotiations and that they were paid for

Page 11160

 1     that --

 2             MR. OLMSTED: [Previous translation continues] ... that is not

 3     what the witness testified to.  He didn't say that he was getting

 4     misinformation about Stojan Zupljanin's participation in the

 5     negotiations.  This is, again, an example of Defence counsel twisting

 6     questions to put words into the witness's mouth.

 7                           [Prosecution counsel confer]

 8             MR. KRGOVIC: [Interpretation] Your Honour, well, I will ask the

 9     witness directly.

10        Q.   Mr. -- -- or, rather, Comrade Radulovic, the information, the

11     report, please just be brief in your answer.  So the report that was

12     submitted by Tajfun -- or, rather, the information forwarded by Tajfun,

13     that Mr. Zupljanin and Prlic [as interpreted] had participated in the

14     negotiations surrounding the evacuation of Vecici and that they were

15     allegedly paid for that, that is not correct?

16        A.   Yes.  We --

17        Q.   It was not a Milos Group; correct?

18        A.   Yes.  And I don't know how many times I have to repeat that.

19        Q.   I asked you about evacuation.

20                           [Defence counsel confer]

21             MR. KRGOVIC: [Interpretation]

22        Q.   I apologise for the transcript.  I was speeding up.

23             So the information that we discussed a little earlier about the

24     evacuation of Vecici and the participation of Mr. Prlic [as interpreted]

25     and Zupljanin, that was not a report or information based on a report

Page 11161

 1     from the Milos Group.  Correct?

 2        A.   Mr. Krgovic, all our reports were written reports.  We never --

 3     the Milos Group never drafted such a report or forwarded it to anyone.

 4     But I did say that we exchanged information with members of Tajfun.  And

 5     I also said that, among other, Tajfun was in possession of such a piece

 6     of information.  And not only that, let me not elaborate on this, because

 7     I could name 5.000 other such instances.

 8        Q.   Very well.  Thank you.

 9        A.   We did not check this information.  We didn't vet it.  We didn't

10     verify it.  We did not go into checking whether the actual events did

11     occur or not.  We really did not do that.

12        Q.   And when I showed you the Milos report, I asked you, when this

13     whole issue of replacement of the leadership, there were rumours going

14     around about replacements of officials, either police officers or other

15     officials.

16        A.   Mr. Krgovic, I really don't know how I can put this succinctly.

17     But if someone were to put on the see-saw of being removed from the

18     political scene, prior to that, there would have to be a scandal created;

19     and those who wanted to remove them, they would direct this whole

20     operation, draw up these scenarios.  And after such publicly placed

21     misinformation, what followed was usually that these people who had been

22     already placed on that black-list would decide to leave their posts.  And

23     more often than not, it was explained, post-festum, that such people did

24     not follow the line of the SDS; that they did not comply with certain

25     positions that had been taken, political positions; or that they had not

Page 11162

 1     parted ways completely with the former Communist system, that they were

 2     commies, that they weren't true Serbs, and so on and so forth.

 3             And I can tell you that there were two centres of power.  There

 4     were two centres that established criteria of political correctness --

 5     or, rather, suitability for office.

 6        Q.   I apologise to you, but I really don't have any more time.

 7             MR. KRGOVIC: [Interpretation] Your Honours, could we tender this

 8     into evidence.  The one that is on the monitor.

 9                           [Trial Chamber confers]

10             JUDGE DELVOIE:  I'm a little bit lost, Mr. Krgovic.  What -- what

11     did the witness tell us about this Milos report?

12             MR. KRGOVIC: [Interpretation] The witness confirmed that this was

13     a Milos report and that there were discussions going on about the

14     replacement of Mr. Zupljanin at the time.  And I just wanted to put this

15     in context of the misinformation evidence.  And I would like to tender

16     this into evidence to support that.

17             JUDGE HALL: [Previous translation continues] ... this is one of

18     the genuine Milos reports.

19             MR. KRGOVIC:  Yeah.

20             JUDGE HALL:  Yes, admitted and marked.

21             THE REGISTRAR:  As Exhibit 2D91, Your Honours.

22             MR. KRGOVIC: [Interpretation] Mr. Radulovic -- or, rather,

23     Comrade Radulovic, I thank you, and I have no further questions for you.

24             JUDGE HALL:  I would invite Mr. Olmsted to begin his

25     re-examination after the break.

Page 11163

 1             But in the two minutes remaining, Mr. Radulovic, I would wish to

 2     return very briefly to a matter which had come up and in respect of which

 3     His Honour Judge Harhoff had asked you some questions.  And this -- this

 4     goes back to the town commands.

 5             And what I'm still a little unclear about and would invite to you

 6     expand very briefly, as I said, on, is the -- as Judge Harhoff, I would

 7     remind you, had asked you about where there was a parallel relationship

 8     between the town command and the Crisis Staff.  And refining that

 9     somewhat, I'm asking the same question with relation to the line -- how

10     the lines of responsible or authority ran, especially in relation to

11     officials such as Mr. Zupljanin.

12             THE WITNESS: [Interpretation] I'll be brief.

13             The Crisis Staff decided who was going to be in the town command.

14     The town command was mostly comprised of people who had ties with

15     military -- with the military, and individuals who were one-time members

16     of the military secretariats at the Territorial Defence, and individuals

17     who were under the direct control of the Crisis Staff, as it were.

18             As for the town command, all other bodies reported to them,

19     including police stations which had been placed under the authority or

20     competence of the town command.  So, in fact, you had a breakdown in the

21     line of and chain of command and forwarding of information from the

22     level -- the highest level of Republika Srpska, through the CSBs, and

23     down to the police stations at various towns and places.

24             Simply, the police station no longer had to report to the CSB,

25     the Centre of Security Services.  It was only responsible and primarily

Page 11164

 1     responsible to the town command.  And any other information that was

 2     provided from outside that line of command was really something that

 3     arose from their sense of their professional duty, or because, as

 4     individuals, they couldn't understand that this could be done in this way

 5     and then they would forward their information to the CSB, almost

 6     surreptitiously, secretly, keeping it secret from the town command.

 7             To be even clearer, Your Honours, the town commander could simply

 8     say that all police is to go to a front line, 100 kilometres away from

 9     their town, or 200 kilometres, without asking for the approval of the

10     minister of the interior of Republika Srpska.  So the town commander was

11     the A and Z in that chain.

12             JUDGE HALL:  Thank you, sir.

13             We'll take the break now.

14                           [The witness stands down]

15                           --- Recess taken at 12.08 p.m.

16                           --- On resuming at 12.31 p.m.

17                           [Trial Chamber and Registrar confer]

18             JUDGE HALL:  While the witness is being escorted in, we have a

19     very short -- sorry.

20             While the witness is being escorted in, there's a very short

21     housekeeping decision that we have to pronounce, which is as follows:

22             The Registry has informed the Trial Chamber that unofficial and

23     uncorrected versions of transcripts have been up-loaded into e-court

24     after having been admitted as Prosecution Exhibits even though there are

25     official corrected versions of the same.  This concerns 53 exhibits.  The

Page 11165

 1     Registry will provide the Prosecution with a list of the relevant

 2     exhibits.  The Prosecution is ordered to replace the transcripts in

 3     e-court by official corrected versions.  Furthermore, whenever the

 4     parties seek to have admitted prior testimony of witnesses, they should

 5     upload into e-court official corrected versions of the transcripts.  If,

 6     at the relevant time, an official corrected version is unavailable, the

 7     parties shall replace the unofficial, uncorrected version without undue

 8     delay.

 9             Thank you.

10                           [The witness takes the stand]

11                           Re-examination by Mr. Olmsted:

12        Q.   Good afternoon, Mr. Radulovic.

13        A.   Good afternoon.

14        Q.   Last Friday, you viewed a video that contained a meeting held on

15     30 July 1992 of the SJB chiefs headed by the CSB chief.  Is that -- do

16     you recall that?

17        A.   Yes.

18        Q.   Now, you are aware that these types of meetings occurred

19     regularly at the CSB, and I will submit that during the course of this

20     trial a number of documents have been tendered into evidence that --

21             MR. KRGOVIC:  Objection, it's leading.  Ask directly.

22     [Indiscernible]

23             MR. OLMSTED:  I haven't asked my question yet, Your Honours.

24        Q.   There's been -- we have in evidence a number of reports going

25     back and forth between the CSBs and the SJBs in the Autonomous Region of

Page 11166

 1     Krajina.  So what we want to understand is on what basis do you reach the

 2     conclusion that the SJBs reported only to these town commands in 1992?

 3        A.   I reached it on the basis of my knowledge about what the

 4     situation was like and how everything functioned in the area during the

 5     wartime and at the time when the Crisis Staff and town commands were

 6     established.

 7             I would like to add that this was put in place with -- there was

 8     certain legislation that was ushered in.  And if you like, even I, for a

 9     while, ex officio, was a member of the Crisis Staff as -- because of the

10     work that I was doing at the time.  So I know how that worked.

11        Q.   This legislation, did this come from the republic level?

12                           [Prosecution counsel confer]

13        A.   Do you want me to tell you whether they came from the republic

14     level?

15        Q.   [Previous translation continues] ...

16        A.   Mr. Prosecutor, what I'm trying to tell you is that there were

17     such laws, even before war broke out.  And those laws and certain

18     regulations were envisaged in peacetime -- or, actually, they had been

19     drafted in peacetime because they were envisaging the type of work that

20     was to be done there wartime.  And, of course, they were adapted to the

21     wartime conditions.  So all of this had already been envisaged earlier on

22     in the Socialist Federal Republic of Yugoslavia -- or, rather, the

23     Socialist Republic of Bosnia-Herzegovina.  There was such a law that

24     envisaged all this for wartime conditions.

25        Q.   And let me get back to my question.  Did the Republika Srpska

Page 11167

 1     government pass this type of legislation that you're talking about?

 2        A.   To be honest, I'm not aware that such laws were passed.  The

 3     first changes to the laws in Republika Srpska came about in 1993 when,

 4     literally speaking, Article 12 of the constitution proclaimed that all

 5     the laws and regulations of the former Socialist Federal Republic of

 6     Yugoslavia were to be accepted and applied so that there were no changes

 7     and no new laws or regulations were adopted.  I'm not talking about

 8     bylaws and certain decisions by the Assembly or similar organs, but that

 9     goes beyond what I know.

10             MR. ZECEVIC:  Your question, Mr. Olmsted, wasn't recorded in the

11     transcript at all.

12             MR. OLMSTED:  And I'm sure it will be corrected when the final

13     transcript comes out.

14        Q.   You mentioned that you were on -- you were an ex officio member

15     of a Crisis Staff.  Was that the Teslic Crisis Staff when you were a

16     temporary chief in July 1992?

17        A.   Correct.

18        Q.   I want to turn to the subject of Mr. Zupljanin's participation in

19     the negotiations with the non-Serbs in Vecici.

20             Last Thursday, I asked you a couple of questions regarding this

21     issue, and I'm going read them into the record.  And my question was:

22             "According to your sources, who participated in the negotiations

23     amongst your superiors?"

24             Your response was:

25             "Mr. Prosecutor, I know that Lieutenant-Colonel or Colonel - I'm

Page 11168

 1     not sure of his rank at this time - Peulic must have been involved.  He

 2     was military officer.  There were indications that Mr. Stojan Zupljanin

 3     was also involved, and that's we omitted to include this information."

 4             Presumably in your report.

 5             Then you continue:

 6             "But let me add you -- add this:  We didn't keep completely

 7     silent about it because we submitted that to the bodies of the military

 8     security, the intelligence centre of the army, headed by Branko Ratic of

 9     who we knew that he was very close to President Karadzic."

10             Do you confirm what you said previously, before this Tribunal?

11        A.   I said today as well that we exchanged information with the

12     security organ with which -- which, at the time, was headed by

13     Branko Ratic.  In these exchanges of information, because we forwarded

14     information to him and he forwarded information to us, he provided some

15     information that had to do with Stojan Zupljanin about him taking part in

16     these negotiations; whereas, we then provided them with what we knew

17     about those negotiations.  In other words, we said that Colonel or

18     Lieutenant-Colonel Peulic participated in those negotiations.  So we

19     exchanged information, but that was information that was not written down

20     anywhere either by individual members of the group or by the Milos Group

21     itself.

22             In other word -- so, the report that was sent by Branko Ratic to

23     the higher levels of the military and the political leadership was sent

24     like that.  Such reports - and I won't call them either information or

25     disinformation - but such reports sent by Tajfun were numerous, and this

Page 11169

 1     security group or the security organ that was headed by Branko Ratic sent

 2     numerous such reports, not only about this particular event, but about

 3     other things as well.  So there were numerous such reports, so I don't

 4     see what's at issue here.

 5        Q.   To save time, I don't want to go over the role of Tajfun anymore.

 6             I showed you an exhibit, 65 ter 10199, about the time of the

 7     Grbavica massacre and in it you had reported information you received

 8     from someone by the code-name of Japanac.  Did Japanac also tell you that

 9     Mr. Zupljanin participated in the negotiations?

10        A.   I can't recall.  Whatever relates to Grabovica was mentioned in

11     the report, including the number of dead Bosniaks and the way they were

12     executed; but asking me to recall something 17 years later, what I can

13     say is, if it wasn't written down in the report, then we weren't told

14     about it.

15        Q.   Well, how about Zdravko Pejic; did he inform you that

16     Mr. Zupljanin had participated in the negotiations at Vecici as well?

17        A.   Mr. Prosecutor, this is the first time that you put this question

18     to me.  But as I knew Zdravko Peulic [as interpreted] very well, now late

19     Zdravko Peulic, even if he had had that bit of information, he would

20     never have told me about it.

21             THE INTERPRETER:  Interpreter's correction, Zdravko Pejic.

22             THE WITNESS: [Interpretation] And he also never told me anything

23     about any crimes committed by members of the CSB, and he did not dare

24     forward such information precisely because he was afraid of the members

25     of that detachment.  So he then chose to tell me about this.  He tried to

Page 11170

 1     actually trick me into forwarding this.  And, of course, I wasn't that

 2     naive.  And I didn't do it because he tricked me but because I felt that

 3     it was important to forward that information.  And that's how I sent it

 4     on.  And we have that in the report.

 5        Q.   And let's not go over your prior testimony on -- on that

 6     particular issue.  Answering -- a simple "no" would suffice for some of

 7     these questions.

 8             Who, according to your intelligence information, on the Bosnian

 9     side did Mr. Zupljanin use to negotiate with the Bosniaks at Vecici?

10             You can just give the person's nickname.

11        A.   Yes, I can.  This is what we learned -- this is intelligence

12     information:  A certain Sprzo.

13        Q.   And did you also receive any intelligence information of Sprzo's

14     link to the Banja Luka Special Police Detachment?

15        A.   Yes, we had such information.  I think that we emphasised that in

16     some report.  I cannot quite remember what the context was, but it was

17     so.  And would you like me to tell you what the occasion was?  If you're

18     insisting, the occasion was trade.  What I mean is that at the time it

19     was very popular to trade in all goods, and in particular cigarettes,

20     liquor, foodstuffs, because their prices were exorbitant, just for

21     illustrations.

22        Q.   [Previous translation continues] ... go into illustrations.

23             Was this trade, just very quickly, legal or illegal?

24        A.   Mr. Prosecutor, would you expect to see any legal trade during

25     the war?  Nothing was legal.  It was all a matter of agreement.  Legality

Page 11171

 1     implies lawfulness, and the circumstances were such that it was not legal

 2     to trade with the opposing side.

 3        Q.   Did you ever find out why Mr. Zupljanin was using this Sprzo to

 4     negotiate with the Bosnians at Vecici?

 5        A.   I have told you that this was a piece of intelligence.  We did

 6     not elaborate on that.  We did not check it.  It was just that in the

 7     exchange of information with military security we received this

 8     information.

 9        Q.   Now, earlier today you mentioned this mobile police battalion

10     that was discussed at the CSB level as well as at the military level to

11     resolve problems of renegade groups, criminal groups, around

12     Bosanska Krajina --

13             JUDGE DELVOIE:  Mr. Olmsted, you're changing to go another topic,

14     aren't you?

15             MR. OLMSTED:  Yes, I am.

16             JUDGE DELVOIE:  What piece of information the witness is

17     referring to in his last answer?  And could you also remind me or could

18     the witness remind me what -- what is meant by participation in these

19     negotiations.

20             MR. OLMSTED:

21        Q.   Mr. Radulovic, did you understand the Judge's question?

22        A.   Yes, I did.  I said that the idea -- there was an idea to

23     establish a unit at the battalion level.

24        Q.   [Previous translation continues] ...

25        A.   Which would be exclusively --

Page 11172

 1        Q.   Let me stop you there because that is a topic I want to cover

 2     next.  But Judge Delvoie was asking about this piece of intelligence,

 3     that Mr. Zupljanin was using Sprzo to negotiate with the Bosnians at

 4     Vecici.  And his question was:  What piece of intelligence are you

 5     referring to?

 6        A.   Excuse me, you asked me a question, and I told that you we

 7     learned this through the exchange of information with the intelligence

 8     and security organ of the Army of Republika Srpska.  It was headed by

 9     Mr. Branko Ratic.

10             JUDGE DELVOIE: [Previous translation continues] ... you learned

11     what, please?  What did you learn?  That's my question.

12             THE WITNESS: [Interpretation] I'm telling you I learned that

13     Lieutenant-Colonel or Colonel Peulic took part in the negotiations and so

14     did Stojan Zupljanin.  As the Milos Group, we did not check this, this

15     information.  We did not try to check other sources and so on.

16             JUDGE DELVOIE:  I'm sorry, but I have no answer to my question.

17     The question is:  What -- how -- how is the person -- the person of

18     Bosnian of Bosniak origin you're referring to and you asked why was --

19     why was he -- why was Mr. Zupljanin using this person?

20             And then we got as an answer:  I got this information, but I

21     don't know what kind of information.

22             What -- is there an answer to that question?  To your question.

23             And then my second question is:  We are talking about

24     Mr. Zupljanin participating in negotiations.  What is -- what do we mean

25     by that?  What we are talking about?  If I only know that he is -- he was

Page 11173

 1     participating in negotiations, what do I know?  What kind of

 2     negotiations?  For what purpose was he engaged in those -- in those

 3     negotiations?

 4             MR. OLMSTED:  Yes --

 5             JUDGE DELVOIE:  As far as the intelligence went.

 6             MR. OLMSTED:

 7        Q.   Well, let's break this down.

 8             First, when we were talking about participation in negotiations,

 9     are we talking about the negotiations regarding the non-Serbs in the

10     Vecici area who were attempting to leave Kotor Varos in safety?

11        A.   Yes.

12        Q.   And this -- these negotiations occurred at the end of

13     October/beginning of November?

14        A.   I cannot remember the date, but I know that the negotiations were

15     conducted and that they yielded some result and that all able-bodied

16     Bosniak men from the Vecici village went over to the Federation

17     territory.  We had intelligence that they had left with their personal

18     weapons.  And if you like, we also had information that after only two

19     days they took part in combat operations in the area of Vlasici, the same

20     men who had left and gone over to the Federation territory.

21             So, in brief, this is all that I know about this group.

22        Q.   And this group, they had to pay a fee to have safe passage from

23     Kotor Varos; is that right?  That was your prior testimony.

24        A.   We had such intelligence, yes.

25        Q.   Now, let's talk about this Sprzo.  And my question to you was:

Page 11174

 1     What information -- well, let me put it this way.

 2             How, according to your intelligence information, was

 3     Mr. Zupljanin using this Sprzo to negotiate with the Bosniaks who were in

 4     Vecici?

 5             MR. KRGOVIC:  Your Honour, I don't know that I raised this issue

 6     relating to Sprzo in my cross-examination.  Just for the record, Sprzo

 7     was killed in summer 1992.

 8             MR. OLMSTED:  It's not for counsel to give evidence.  And I think

 9     we have to hear from this witness.

10             MR. KRGOVIC: [Overlapping speakers] ...

11             JUDGE HALL: [Overlapping speakers] ... how does this arise out of

12     cross-examination, Mr. Olmsted?

13             MR. OLMSTED:  This is all going to information -- well, first of

14     all, this is Judge Delvoie's question, and I'm just trying to clarify it.

15     But the point here is what intelligence information he had regarding

16     Mr. Zupljanin's participation in the negotiations at Vecici.

17             MR. KRGOVIC: [Interpretation] Your Honour, the Prosecutor needs

18     to know what were the testimonies about Sprzo and his death earlier in

19     this case and when it happened, rather than confuse witness by asking him

20     questions in this way.  Because we have heard testimonies about this

21     specific person in this case.  I remember persons from Kotor Varos who

22     talked about his --

23             THE WITNESS: [Interpretation] May I say anything?

24             Thank you for trying to protect me.  First of all, the Prosecutor

25     is not able to confuse me because I'm saying what I know.

Page 11175

 1             As for the Prosecutor trying to say in his words how did

 2     Stojan Zupljanin use Sprzo, I never said that Stojan Zupljanin made use

 3     of Sprzo.  I said that according to intelligence, one person, nicknamed

 4     Sprzo, participated in the negotiations on behalf of the other side.  So

 5     I understand that he was there on behalf of the Bosniak side; whereas,

 6     according to intelligence on the Serbian side, the participants were

 7     several people including, among others, Stojan Zupljanin.  That was the

 8     intelligence we had.

 9             I have told you where we received it from, and, frankly speaking,

10     we were less interested in who the participants in such agreements were.

11     We did not deem it necessary to try to document this later on.

12             JUDGE DELVOIE:  Mr. Radulovic, I can put my question in a more

13     direct way, and it comes directly from cross-examination as well.

14             Did you have intelligence that Mr. Zupljanin had a personal

15     interest in these negotiations?

16             THE WITNESS: [Interpretation] Did we have such intelligence?  Our

17     intelligence suggested that the Bosniak side seemed to be interested in

18     leaving the area of Vecici without any further combat with the Serbian

19     forces.  The reason was that their assessment was that they were

20     surrounded and that they did not stand any chance.

21             Therefore, at the moment when intelligence was received, I did

22     not have any information from the ground about any personal interest of

23     anyone.  Except that, from the security organs, I received information

24     that the group which had left had to pay very high fees in order to be

25     allowed to depart.  I did not --

Page 11176

 1             JUDGE DELVOIE:  And to whom had they to pay these fees?

 2             THE WITNESS: [Interpretation] To the Serbian side.  But not

 3     privately; personally.  To Stojan or to Peulic or to Zdravko Pejic or to

 4     Ljuban Ecim or anybody else.  I'm not even certain, and I do not have any

 5     information that the money was indeed paid.  The information that I'm

 6     talking about now is something that was publicly stated, even after the

 7     war.  There was quite a lot of misinformation and disinformation about

 8     all this, including the death of the late Stevan Markovic and Stevilovic.

 9     So I rather wouldn't go into something else that is more or less distant

10     from me.

11             JUDGE DELVOIE:  Thank you, Mr. Radulovic.

12             MR. OLMSTED:

13        Q.   Let's move to where I was going to ask you some questions a

14     moment ago.  You mentioned during cross-examination this mobile police

15     battalion, that there was some discussion about setting it up to resolve

16     problems with renegade groups around Bosanska Krajina.  Was that police

17     battalion ever established in 1992?

18        A.   No, it wasn't established.  And I said quite clearly that it was

19     just an idea.  And the idea probably died together with the late

20     Stevilovic and Markovic.  And probably also because some other

21     transformations had taken place in the meantime.

22        Q.   Now, I don't have the report in front of me, but I believe in one

23     of your reports you mention this police battalion.  In regard to

24     Kotor Varos, did Stojan Zupljanin send the detachment, rather than this

25     mobile battalion, to that municipality?

Page 11177

 1             MR. KRGOVIC:  Sorry, I don't think I ask any question about this.

 2             MR. OLMSTED:  I'm just going to clarify this -- well, actually,

 3     I'm going move on.  I'm going move on.

 4             May we see 2D02-1314 on the screen, please.

 5             And if we can turn to the second page of the B/C/S -- or,

 6     actually, page 3 of the B/C/S and page 2 of the English.

 7        Q.   Mr. Radulovic, you answered a few questions about this document

 8     last Friday.  If we look at page 3 of the B/C/S, you write -- after

 9     you've discussed the potential for crimes against non-Serbs in the area

10     of Kozarac and so forth:

11             "We suggest that you try through political structures to persuade

12     extremist individuals to respect military commands and to prevent their

13     crimes, even at the cost of taking repressive measures against them."

14             Who are you making this suggestion to?  It seems like you're

15     directing this report to someone.

16        A.   Well, certainly.  I sent every report to somebody.  I sent every

17     report, first of all, to my superior, Vojin Bera.  And Vojin Bera was

18     supposed to send it along the chain of command to the highest level.  I

19     told you that in addition to submitting it to Vojin Bera I also sent it

20     to Belgrade.  I believe that that was quite satisfactory, that all those

21     who should be informed were indeed informed.

22             From what you just read, you can see for yourself that the main

23     objective was to eliminate extremist individuals from the Serbian People

24     as persons who could commit crimes in the ground, where we already noted

25     that repressive measures, you know, any repressive measure is a measure

Page 11178

 1     which limits somebody's self-will and freedom, so that this is what the

 2     repressive measures imply.

 3        Q.   Thank you.  But that wasn't -- you answered my question, which is

 4     the important thing.

 5             You refer to political structures that should try to persuade

 6     these groups --

 7             JUDGE HARHOFF:  Hold on a minute, Mr. Olmsted.  I don't think the

 8     witness actually answered your question.

 9             Your question was:  To who was your advice to use the political

10     structures to persuade extremist individuals to respect military commands

11     addressed?  And the witness answered that the primary addressee was his

12     superior, Mr. Bera.

13             But apart from that, I didn't think we got any further.

14             So again, Mr. Radulovic, did you have Mr. Zupljanin in mind or

15     the MUP, as such, or the armed forces in mind?  I mean, you are coming

16     out with a clear suggestion and a recommendation to use political means

17     to solve these problems.  Who did you have in mind exactly?

18             THE WITNESS: [Interpretation] Your Honour, I said what the

19     practice generally was and what the regulations were.  Vojin Bera was

20     supposed to inform Kesic about this, and then Kesic was to inform

21     Stojan Zupljanin, Stojan Zupljanin was supposed to inform the

22     sub-secretary for national security, the sub-secretary for national

23     security was supposed to inform the minister of the interior, and the

24     minister of the interior was supposed to inform the president of the

25     republic and all the other structures and organs of power, that includes

Page 11179

 1     the military command, the military security, and so on.

 2             Therefore, as the first link in the chain, I was only supposed to

 3     inform Vojin Bera about this.  And then he was supposed to inform those

 4     who were above him.  Just in case, because the question of the army was

 5     still undefined at the time, I also informed Belgrade about this because

 6     I considered that with their influence they could also help to prevent

 7     such crimes on the territory of Republika Srpska and that it would oblige

 8     the military structures to deal with the situation on the ground.

 9             JUDGE HARHOFF:  And do you know -- do you happen to know whether

10     this recommendation of yours ever left Mr. Bera's desk?  Did it get any

11     further?

12             THE WITNESS: [Interpretation] Your Honour, I really had no

13     opportunity to check whether my report went any further than Vojin Bera.

14     If you remember, I said several times that it was only later that I

15     learned that much of my information - and when I say "my information," I

16     mean that coming from the Milos Group - did not reach their supposed

17     destination.

18             JUDGE HARHOFF: [Previous translation continues] ... thank you.

19             Back to you, Mr. Olmsted.

20             MR. OLMSTED:  Thank you, Your Honour.

21        Q.   You refer to political structures.  Which political structures

22     are you referring to in this report that should persuade extremist

23     individuals?

24        A.   From the Assembly as the highest organ of power and further.  I

25     meant the politicians who had the appropriate rating and authority and

Page 11180

 1     could influence the military command and all the other organs, including

 2     the judiciary and the prosecutor's office and the Ministry of the

 3     Interior.  That is to say, I was not selective.  I was just expressing

 4     myself in general terms, believing that this way of reporting deserved

 5     the attention of all institutions and organs of power.

 6             MR. OLMSTED:  May this be admitted into evidence.  It's a Defence

 7     document, and they asked questions about it as well.

 8             JUDGE HALL:  Mr. Zecevic.

 9             MR. ZECEVIC:  Well, Your Honours, I -- I do object.  If -- if

10     the -- if the Defence asked the questions about this document and didn't

11     admit it, it doesn't mean that -- that allows the Prosecution on

12     re-direct to ask for the document to be admitted.  I really don't --

13     don't think that -- that is a proper way to --

14             JUDGE HALL:  I'm not aware of any such prohibition, Mr. Zecevic.

15             The rules about admissibility begin with the basal principle of

16     relevance and it builds from there.  And as Mr. Olmsted has said, here's

17     a document which the Defence used but chose not to exhibit.  So, in other

18     words, they opened the document in -- in that sense, and Mr. Olmsted is

19     cross-examining on it.  So I see no prohibition against it being admitted

20     at his instance.

21             MR. ZECEVIC:  Well, if I'm -- I appreciate Your Honours'

22     position, and I do agree with you in part.  But, on the other hand,

23     Your Honours, then -- then the -- then the Defence is put in a -- in a

24     rather awkward position because the document has not been admitted during

25     the direct.  We cross-examined, and now it is admitted on the re-direct,

Page 11181

 1     and we -- we are not able cross-examine the witness on that particular

 2     document.

 3             That is the point of my objection.

 4             MR. OLMSTED:  And it's a bit disingenuous too because I just

 5     spoke to Mr. Zecevic about this document and he assured me that the

 6     Zupljanin Defence would be admitting it.  Because I actually asked him

 7     what he -- we actually wanted it admitted, and he said that --

 8             JUDGE HALL:  I would prefer not to involve the Chamber in

 9     out-of-court conversation between counsel.  The document is admissible.

10     And on the application of the Prosecution having tendered it, it is

11     admitted and marked.

12             THE REGISTRAR:  As Exhibit P1394, Your Honours.

13             MR. OLMSTED:  Thank you, Your Honour.

14             JUDGE DELVOIE: [Overlapping speakers] ... Mr. Olmsted, is it on

15     the list of documents of Zupljanin Defence?

16             MR. OLMSTED:  It's actually the Stanisic --

17             JUDGE DELVOIE:  Stanisic.

18             MR. OLMSTED:  Tab 49.

19             JUDGE DELVOIE:  Tap 49.  Thank you very much.

20             MR. OLMSTED:

21        Q.   Mr. Radulovic, last Thursday you testified that you had a

22     conversation with Mr. Zupljanin [Realtime transcript read in error

23     "Zecevic"] regarding the removal of Simo Drljaca.  Do you recall what

24     month, at least, in 1992 that you had that conversation?

25             MR. KRGOVIC:  I don't think I asked any question on this regard

Page 11182

 1     in my cross-examination.

 2             MR. OLMSTED:  There was quite a lot about it.  In fact, I can

 3     direct your attention -- well, it's relating to Simo Drljaca and his

 4     power over Prijedor.

 5             And I refer the Trial Chamber to T -- or page -- transcript

 6     page 11088 where the witness talks about this.

 7             MR. PANTELIC:  And I do apologise.  I do believe that it's

 8     page 66, line 20, that Mr. Zecevic was not in this conversation of

 9     removal of Simo Drljaca, like it was recorded.

10             MR. OLMSTED:  Yes, of course, we're talking about Mr. Zupljanin.

11             JUDGE HALL:  Sorry, Mr. Olmsted, this -- this first came up in

12     cross-examination?

13             MR. OLMSTED:  Yes, it did.  It came up on page 11088 of the

14     transcript.  The issue of Simo Drljaca and what he was doing, his

15     control, his power in the Prijedor municipality.

16             JUDGE HALL:  And, Mr. Krgovic, I'm not sure I followed the basis

17     of your objection.

18             MR. KRGOVIC: [Interpretation] In essence, the Prosecutor talks

19     about something that the witness talked about during the

20     examination-in-chief.  That is, the issue of the removal of Simo Drljaca,

21     which is something I never mentioned.  I did not mention the event about

22     which the witness spoke during the examination-in-chief.  And the

23     Prosecutor said, You talked about this on Thursday, so let me ask you a

24     question.  But I never raised this issue during my cross-examination.

25             MR. OLMSTED:  It might not have been a direct question, but he

Page 11183

 1     certainly allowed the witness to talk at length about it.  And so I'm

 2     going to have to deal with it on re-examination.  I mean, unless you're

 3     going to disregard the evidence that the witness gave on that issue.

 4                           [Trial Chamber confers]

 5             JUDGE HALL:  Yes, please proceed.  This matter did come up in

 6     cross-examination by Mr. Krgovic.

 7             So please proceed.

 8             MR. OLMSTED:  Thank you, Your Honour.

 9        Q.   And, again, it's a very limited question I want to -- you had a

10     conversation about Mr. Zupljanin about removing Simo Drljaca.  Do you

11     recall what month in 1992 that conversation took place; or if you don't

12     know the month, was it summer?

13        A.   What I can tell you is that I remember I had conversations, and

14     not only I, but the members of the Milos Group as well, about it, and I

15     can tell you in general terms when all this took place.  It was after the

16     departure of the commission that went -- visited Omarska and Keraterm to

17     verify the situation and after the article published in Glas magazine in

18     Banja Luka.

19             Now, exactly when all this took place, I cannot tell you because

20     all these events took place 19 years ago, but it was certainly during the

21     summer.

22        Q.   Thank you.

23             Now, you also testified that no actions were taken to remove

24     Chief Drljaca.  Can you tell us instead, What happened to Drljaca in 1993

25     and 1994?

Page 11184

 1        A.   Again, I must stress that -- that I never discussed whether this

 2     issue -- whether these issues and steps were taken or not taken with you

 3     or anyone else.  What I can say is that this conversation took place

 4     after this commission visited Prijedor, and I also know that Simo Drljaca

 5     spent some time in the republican MUP.  He was some kind of assistant

 6     there.  And he also spent some time in the Banja Luka services centre.

 7     He may have been either an assistant or a deputy there.  On one

 8     occasion --

 9        Q.   Sorry for interrupting.  Do you recall what year that was?  Was

10     it 1993 or 1994?  Of if you don't know, just tell us.

11        A.   It was before the end of 1994.  Maybe in early 1994.  Because I

12     left Banja Luka in late 1994, and I remember seeing him in Banja Luka

13     while I was still there, and that's how I managed to orient myself.

14        Q.   Do you recall whether Simo Drljaca received any commendations in

15     1993, any medals or awards?

16        A.   Mr. Prosecutor, I wasn't writing a biography of Simo Drljaca.  I

17     certainly would have picked up a better person, a smarter person, if I

18     want to write a biography.  But I do know that he received some

19     commendations and medals.

20        Q.   So beyond the local authorities in Prijedor, who supported

21     Chief Drljaca at the regional and republic level?

22        A.   If you want me to name some individuals, I know he was highly

23     respected by Biljana Plavsic; personally.  He was reputed as a person who

24     had her backing.  And I never approved of any of the person she was

25     backing, and I never approved of her either.

Page 11185

 1        Q.   What about at the regional level, at the Bosanska Krajina level.

 2     Who supported Chief Drljaca?

 3        A.   I will just give you the name.  Brdjanin.

 4        Q.   I want to move to another topic.

 5             Yesterday, you testified about efforts by the non-Serb population

 6     to arm themselves in Bosanska Krajina.  Were the Serbs also arming

 7     themselves?

 8        A.   But, of course.  If you will allow me, all three ethnic groups

 9     acted in the same manner.  All of them were arming as if they were taught

10     how to do it by the same teachers, as if all the three peoples realised

11     and understood what they were taught and then later on went to implement

12     it on the ground.  There is no difference between the three peoples in

13     that respect.

14             Unfortunately, there is no difference between crimes committed by

15     any of the three groups.

16        Q.   According to your intelligence information, who was arming the

17     Serbs?

18        A.   [No interpretation]

19             JUDGE HARHOFF:  We are not receiving any interpretation.

20             MR. OLMSTED:  Yes.  We're not receiving English translation.

21        Q.   I'm sorry, Mr. Radulovic.

22             Let me -- can you please start your answer again.

23        A.   So I will start again.

24             It's a well-known fact that the political parties, such as SDS,

25     SDA, and HDZ, were the ones who played the main role in arming their

Page 11186

 1     respective peoples.  So loyal Serbs were members of their relevant party,

 2     who were on the ground, were used as people who armed, again, loyal

 3     Serbs.  Again, members of SDS.  And the same situation applied for the

 4     SDA and the HDZ.

 5             The weapons or the armament process took place before the war

 6     broke out.

 7        Q.   Let's take a look at Exhibit 2D87.

 8             You answered some questions about this, I believe, yesterday.

 9     This report states:

10             "Interacting with such potential sources, we need to come across

11     as supporters of pro-Yugoslav option and, as such, we provoke contempt of

12     our colleagues who support the hard-line Serbian option."

13             Which colleagues are you referring to?

14        A.   Definitely the colleagues who already show their loyalty to SDS

15     within our service and who were more interested in political activity

16     than in operative activities -- than involving in what they should have

17     been doing for the service.  And I can tell you the names.  I'm not

18     afraid of naming people.

19        Q.   Please do.

20        A.   Shall I begin?

21        Q.   [Microphone not activated] Yes, please.

22        A.   I think you may find it surprising, but Ivan Figurek, a Ukrainian

23     citizen [as interpreted], was a member of this hard option.  Then Vojin

24     Bera, a person who came -- whose wife was not Serb; I know his wife.  And

25     there were other hard-liners within the National Security Service, not

Page 11187

 1     only the ones from Banja Luka but also the agents from the surrounding

 2     areas.

 3             I also know some colleagues who were members of the public

 4     security service who were part of the hard-liner group and who viewed us,

 5     who were of pacifist orientation, as traitors.  Some colleagues of ours

 6     prepared reports, demeaning reports, about us saying that we are

 7     traitors, that we are collaborating with the Croatian side or the Bosniak

 8     side.  It's all to their shame.  But thanks to you, I now had an

 9     opportunity to respond to them in public.

10             MR. ZECEVIC: [Previous translation continues] ... 16, I believe

11     the witness said Ukrainian "nationality," not "citizen."

12             MR. OLMSTED:  And I think the record will reflect that.

13             THE WITNESS: [Interpretation]  That's right.

14             MR. OLMSTED:

15        Q.   Can you tell us, What was the hard-line Serbian option?

16        A.   Yes.  The more Serbs and the less Croats and Bosniak at the

17     territory predominantly inhabited by Serbs, the better.  I can also say

18     that one option was to have below 8 per cent of Bosniaks and Croats in

19     order to make sure they don't cause troubles.

20             You're asking me questions that I never had an opportunity to

21     discuss with anyone before.  I'm sure that I didn't say anything of the

22     sort in my prior statement.

23        Q.   I want to move to another topic now.

24             Now, Mr. Zecevic asked you a number of questions regarding

25     whether your reports made it to the RS MUP in Pale.  And I want to

Page 11188

 1     clarify some of your answers.

 2             On your first day of testimony before this Trial Chamber, you

 3     gave an answer - this is at page 10730, beginning line 5 - to a question

 4     on this issue in which you stated:

 5             "But if I tried to think logically, and I know how the service

 6     operated, and I know, from practice, some of my reports ended up at Pale,

 7     I can only assume that this was done through regular channels in the

 8     service.  However, whether any of this information or these reports were

 9     halted, I don't know."

10             Do you stand by that answer?

11        A.   Yes, I stand by it.  And if you want me to give you a clearer

12     picture, let me say this:  Some of the information that we sent to Pale

13     caused some reaction from the leadership of the national security, and

14     this reaction was at our detriment.  And I'm not speaking about the

15     Ministry of the Interior; I'm talking about the leadership at the

16     National Security Service.

17             Of course, one further clarification is needed here.  Later on,

18     we, of course, ran afoul of Minister Tomo Kovac because of the reports

19     that we sent.

20        Q.   You testified that at least on a few occasions you received

21     responses from the SNB at the RS MUP level regarding information

22     contained in your reports.  Did you re --

23             MR. ZECEVIC:  Could we have the reference please.

24             MR. OLMSTED:  Page 10733.

25        Q.   Did you receive a response to your reports on the Mice Group from

Page 11189

 1     the RS MUP; and, if so, what response did you receive?

 2        A.   Well, let me say it like this:  The Milos Group did not have an

 3     address of its own.  In other words, there was no one at the upper level

 4     who would respond directly to us.  The responses or replies came via my

 5     immediate superior, and then the one above him, and those responses were,

 6     as I've already described them, to the effect of, This is not something

 7     that we should worry about; leave to that the army; that is not within

 8     your sphere of competence.

 9             So simply put, as I've already said here, it was my impression

10     that everyone was actually trying to shirk taking difficult decisions in

11     different circumstances which would have meant that they would have to

12     oppose those who had become renegades and who had actually begun to

13     behave wilfully in these areas.

14        Q.   Did the RS MUP conduct an investigation of you with regard to the

15     Mice Group operation?

16        A.   On several occasions, I was addressed or I was interviewed about

17     the events in Teslic.  I know there was a team that came, a team of four

18     authorised officials, who interviewed me about the circumstances

19     surrounding the Mice action in Teslic.  They took a statement, which I

20     never signed.  But I saw in the summary that they prepared, the summary

21     of my report, that they actually tried to portray me as the focal point

22     for -- the focal point which by -- for Mr. Milosevic, so that, then,

23     through this focal point, we would actually -- so that we would actually

24     conduct a coupe in Republika Srpska and topple over Karadzic.  And I

25     really can't tell you what my comment on all of this would be.  I don't

Page 11190

 1     know what to say.  They even managed to describe an operative action

 2     called Sigma as an attempt to topple Radovan Karadzic.

 3        Q.   Did they allege in the report that you were harming the combat

 4     spirit of the Serbian People by releasing non-Serb detainees?  Was that

 5     part of this report?

 6        A.   Yes.  But, Mr. Prosecutor, it is far more complex than what you

 7     have described it as here.  And I could repeat it from word to word,

 8     because I've read it several times.

 9        Q.   [Previous translation continues] ...

10        A.   That I actually tried to suppress the combat spirit of the

11     Serbian --

12        Q.   [Previous translation continues] ... I think you -- we don't have

13     to go into great detail because I have to move on.

14             You testified --

15             JUDGE HARHOFF:  Mr. Olmsted, if you could wrap up within the next

16     five minutes because we have a couple of questions also to put to the

17     witness before he leaves.

18             MR. OLMSTED:  Your Honour, I apologise, but we have more

19     re-examination to do.  The next witness -- I have talked to Mr. Hannis.

20     It is not going to be a problem if we go into the first portion of

21     tomorrow.  But we do have a lot of areas to cover, and there was all this

22     raised on cross-examination.  And it's quite important to us that we

23     clarify these issues.

24                           [Trial Chamber confers]

25             MR. ZECEVIC:  Your Honours, I would just kindly ask Mr. Olmsted

Page 11191

 1     to pose the question, When did this interview of the witness by four

 2     officials happened, from the MUP?  Because we have a time-frame which is

 3     relevant to the indictment, and we have the time-frame which is not

 4     relevant to the indictment.  So that we know where we are.

 5             MR. OLMSTED:  Yes, that's a very good point.

 6        Q.   Mr. Radulovic, this investigation by the RS MUP, an interview of

 7     you, can you tell us approximately when that occurred?

 8        A.   That occurred -- well, there were several interviews.  But the

 9     first came already in the second half of 1992.

10             I have to say that the greatest humiliation that I experienced as

11     a human being was when a team arrived, a number of which were some

12     inspectors and colleagues from Doboj that I knew.  They came to the

13     National Security Service offices, and they conducted a short interview

14     with me in which they de-based me, humiliated me.  And I recall very well

15     who those colleagues were, and I do not feel ashamed at all to mention

16     their names here.

17             One of them was Dusan Zivkovic, Dragan Basic, Milenko Skrobic.

18     They tried to humiliate me in this manner, not realising that I

19     considered it an honour when they called me a commie, a Communist, a red,

20     and all sorts of other names --

21        Q.   [Previous translation continues] ...

22        A.   -- but, of course, that that speaks of them, not of me.

23        Q.   [Previous translation continues] ...

24        A.   Andrija Bjelosevic, I apologise, I have to mention him, was there

25     too.

Page 11192

 1        Q.   Thank you.  And I'm sorry for cutting you short, but we're really

 2     on a time-frame here.

 3             You also testified - this is at page 10733 - that the

 4     under-Secretary of State Dragan Kijac devalued your intelligence

 5     information.  Do you recall the intelligence information that he was

 6     devaluing?  And I think you also mentioned that you were receiving

 7     threats regarding certain intelligence information.  And, again, what

 8     were these devaluations, these threats, what type of -- what was the

 9     information that was related to that?

10        A.   In short, everything that related to crimes committed against

11     non-Serb populations, and all of that, he did not consider as information

12     or intelligence, nor did he attribute any value or significance to them.

13        Q.   We need to be a little more specific than that.  Can you tell us,

14     Does this include information regarding events in Doboj, whether it

15     included events in Prijedor?

16        A.   Those events were of a late date because at the time when this

17     was happening in Doboj and Prijedor, he was not in that position.

18        Q.   We need to be specific.  This is a response that you're receiving

19     from the RS MUP level.  Crimes against non-Serbs, in which municipalities

20     were they responding to?

21        A.   What do you mean, which municipalities?  I've told you that

22     during the events in Doboj, in Kotor Varos, at the time of the events in

23     Teslic, Dragan Kijac was not the chief of the National Security Service

24     at the Bosnia-Herzegovina level.  I don't know his -- I do know --

25             THE INTERPRETER:  Interpreter's correction.

Page 11193

 1        A.   -- his career path from the time when he began working for this

 2     social security -- for the security administration up until then.  So

 3     even –– I have already told you that even the events that were happening

 4     during his time, while he was in that position, were actually minimised.

 5     Because the crimes did not cease in 1992, they occurred later on as well.

 6     And whatever we reported on that suggested that there were crimes

 7     committed against persons of non-Serb ethnicity, for the most part, those

 8     reports were not worthy of the attention of the leadership of the

 9     National Security Service at the level of Republika Srpska.

10     And as for individual descriptions out of 2750 pages of reports, I

11     apologise, but I can’t remember any specific event right now,

12     I am telling you how it was in general.

13             MR. ZECEVIC: [Previous translation continues] ... something is

14     recorded which the witness didn't say.  He was referring actually to the

15     leadership of National State Security.  I don't know how it was repeated.

16     Not to the leadership.

17             So if you can clarify this, please.

18                           [Prosecution counsel confer]

19             MR. OLMSTED:  For the benefit of time, because he was going a

20     little bit off of my question, maybe the interpreters can review that

21     with the transcript and correct anything in there.  And we're out of

22     time.

23             MR. ZECEVIC:  I'm sorry, because this is -- I believe is

24     important.  Then, Mr. Olmsted, I suggest you ask for the verification

25     report.  Because only then we know for sure that this is going to be

Page 11194

 1     listened to and entered into the transcript.

 2             JUDGE HALL:  Mr. --

 3             MR. ZECEVIC:  If you don't want to ask the witness to clarify

 4     that.

 5             JUDGE HALL: [Previous translation continues] ... regard to the

 6     time, we have to adjourn in any event.  But it seems to me, Mr. Olmsted,

 7     that the point is sufficiently important, and it would be simply

 8     addressed if first thing tomorrow you asked the witness the question

 9     again.

10             MR. OLMSTED:  Yes, Your Honour, and that's what I'll do.

11             JUDGE HALL:  So we take the adjournment.  And we are in

12     Courtroom II for the remainder of the two sitting days of this week.

13                            --- Whereupon the hearing adjourned at 1.45 p.m.,

14                           to be reconvened on Wednesday, the 2nd day

15                           of June, 2010, at 9.00 a.m.