Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11880

 1                           Thursday, 17 June 2010

 2                           [Open session]

 3                           [The accused entered court]

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

 5             THE REGISTRAR:  Good morning, Your Honours.

 6             Good morning to everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

10             Good morning to everyone.

11             May we have the appearances, please.

12             MS. KORNER:  Good morning, Your Honours.

13             Joanna Korner and Crispian Smith for the Prosecution.

14             MR. ZECEVIC:  Good morning, Your Honours.

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

16     appearing for Stanisic Defence.

17             MR. KRGOVIC:  Good morning, Your Honours.

18             Dragan Krgovic, David O'Brien, and David Martini appearing for

19     Zupljanin Defence.

20             JUDGE HALL:  Thank you.

21             MS. KORNER:  Your Honour, just before the witness comes in, I

22     just have one query.  We hope today or tomorrow to be able to provide

23     Your Honours with the cleaned up, if that's the right expression,

24     65 ter list.

25             What we simply want to know is this:  We proposed simply to send

Page 11881

 1     it to all parties via e-mail, unless Your Honours think that we need to

 2     file it as a separate motion.  But, otherwise, we're simply -- it -- it's

 3     the cleaned up -- with hopefully all duplicates removed and the like.

 4             So we're in Your Honours' hands on this.  We thought you probably

 5     didn't want another motion; but if you do, we can.

 6                           [Trial Chamber confers]

 7             JUDGE HALL:  We agree that the -- it -- we understand why you

 8     would wish to avoid the formalities, to avoid a formal filing.  But

 9     inasmuch as it is a formal document, we see no way around that.  So it

10     would be -- it's -- so -- so that's the way it would have to be.  I don't

11     expect that -- I suppose it would be an addendum to your earlier filing.

12     But it should be in that form in our view.

13             MS. KORNER:  I think it will simply be -- it'll be filed as

14     revised 65 ter, Your Honours, I would have thought.  My only hesitation

15     in saying it is -- when I say "cleaned up," I mean, something always

16     manages to escape even six people's eagle eye.  And so I didn't want them

17     to do yet another filing, if possible, to say, Sorry, we've got to

18     correct that because we've discovered yet another duplicate.

19             But if Your Honours think, as it's a formal document, it should

20     be filed, then we will do that.

21                           [Trial Chamber confers]

22                           [Prosecution counsel confer]

23                           [The witness takes the stand]

24             JUDGE HALL:  Good morning to you, sir.

25             While the blinds are being raised, I remind you, before counsel

Page 11882

 1     resumes her examination-in-chief, you're still on your oath.

 2                           WITNESS:  ST-127 [Resumed]

 3                           [Witness answered through interpreter]

 4                           Examination by Ms. Korner: [Continued]

 5        Q.   Sir, we left off yesterday looking at the report in respect of

 6     the events of 1992.  And I want you to look at one other description on

 7     the same lines.

 8             MS. KORNER:  Could we have up on the screen, please, the document

 9     which is at tab 50, which is 39 -- 65 ter 395.

10        Q.   Now, this is dated - the number isn't on it - the

11     8th of February, 1993, and it's called a record.

12             MS. KORNER:  And can we go, please, to the third page in English

13     and the second page in B/C/S.

14        Q.   Can you tell us who signed -- who signed that report

15     [Microphone not activated] ... or whose signature appears there?

16        A.   I'm not receiving any interpretation.

17        Q.   Can you hear me now?  Are you getting translation?  No.

18             MR. ZECEVIC:  We have the translation, so probably there is a --

19     some problem with the -- with the connection.

20             JUDGE HARHOFF:  Mr. Witness, can you hear us now?

21             THE WITNESS: [Interpretation] Yes, yes.

22             MS. KORNER:

23        Q.   Can you tell us, sir, do you recognise the signature there?

24        A.   Yes.

25        Q.   And whose signature is it?

Page 11883

 1        A.   The station commander, Jovan Skobo.

 2        Q.   The man you were telling us about yesterday?

 3        A.   Yes.

 4        Q.   Let's go back, please, then, to the beginning of the report,

 5     first page -- or record.

 6             This is -- it starts by saying:

 7             "This is done on the 8th of February, 1993, at the premises of

 8     Pale SJB in connection with the handover of the police station from the

 9     former chief Malko Koroman to the new SJB chief Petko Pekic."

10             And then it goes on to give some explanation.

11             Was it standard that when there was a change in the head of an

12     SJB, there would be, as it were, a briefing from someone at the station

13     on the events that had taken place?

14        A.   Yes.

15        Q.   And then, if we look at what was said -- or some of what was

16     said:

17             "Due to the security reasons, in mid-March the police station

18     disarmed the non-Serb police employees and removed them from service;

19     weapons owned by non-Serb citizens were seized, irrespective of whether

20     they had permits for them or not ..."

21             And does that, sir, accord with what you told us yesterday?

22        A.   In such situations, during the handover of the station from one

23     commander to another, usually a commission is set up in the main office,

24     in the MUP.  And that commission attends such a handover.  And this

25     record shows only the signature of Jovan Skobo, so I don't know whether

Page 11884

 1     this was a internal affair, an internal takeover, or was it an official

 2     affair, just as it should have been.

 3             MR. ZECEVIC:  I'm sorry, 4, 15, the witness says either main

 4     office in the MUP or -- and this wasn't recorded.

 5             MS. KORNER:

 6        Q.   Sir, could you repeat what you said where this handover -- where

 7     the commission is.  "It's set up in the main office in the MUP or ..."

 8             Where else could it have been?

 9        A.   During a handover from one commander to another at a police

10     station and especially in the case of the chief of that police station,

11     then either the minister or one of his associates, either a deputy or an

12     assistant, sets up a commission which includes representatives -- a

13     representative of the MUP and a representative of the public security

14     centre who attend the handover to make sure that everything is done

15     according to the law.

16             In this particular case, I don't know whether that was, indeed,

17     the case because the only signature on the document is by Jovan Skobo, as

18     the station commander.

19        Q.   All right.  All I was actually asking, sir, was whether those

20     few -- first few lines sum up what you told us had been happening in

21     1992, yesterday.  The disarming of the employees and the disarming of the

22     Muslims.

23        A.   Yes.

24        Q.   And then it says:

25             "On several occasions during the war ... police station,

Page 11885

 1     independently or with the Republika Srpska army, participated in combat

 2     operations ..."

 3             Apart from your participation in the operation at Renovica, did

 4     you take part in -- in any combat operations?

 5        A.   In the month of August, upon an order by the chief, I went to the

 6     positions on Trebinic with an inspector of mine.  We stayed there for

 7     four or five days.  There were -- there was no fighting going on at the

 8     time.  We just manned the positions in order to relieve the men who were

 9     normally there.  And that's the only occasion when I went to the

10     positions at the front line.

11             MS. KORNER:  Can we go in English, please, to the next page.  And

12     I believe -- yes, it's still on the same page in the B/C/S.

13        Q.   We see that 32 misdemeanour reports were submitted.  And then the

14     next paragraph:

15             "At the request of the competent customs organs, assistance was

16     provided 160 times mostly with moving certain persons in or out and

17     seizing items owned by Muslim citizens."

18             When it says "moving certain persons in or out," do you know to

19     whom that refers?

20        A.   I suppose that they were Muslims.

21             MS. KORNER:  And then, finally, on this document, we need to go

22     to the second page in B/C/S; it's bottom of the first page in -- second

23     page in English.

24             Do we see that -- just a moment.  Let me see if I can find the

25     actual paragraph.  Yes.  It's about halfway down the page in B/C/S.

Page 11886

 1        Q.   Do we see that:

 2             "Five interviews of police employees were conducted about the

 3     mistakes made in the course of their work.  No disciplinary measures were

 4     pronounced against police employees."

 5             Now, we looked at the long list of -- of complaints that you made

 6     in your -- in your note.

 7             Whose responsibility was it to deal with -- or initiate

 8     disciplinary proceedings at the Pale SJB?

 9        A.   The initiative for disciplinary procedures can come from anybody.

10     However, when it comes to actually launching a disciplinary procedure, it

11     is the head or the chief of the public security station who decides on

12     that.

13        Q.   In the event that the head of the public security station does

14     not take disciplinary measures that he should, was the chief of the CSB,

15     under which Pale came - in this case, Mr. Cvijetic - was he able to

16     initiate disciplinary proceedings, if he received reports of misbehaviour

17     by officers at Pale?

18        A.   He was in a position to do that, I'm sure.  And he could also

19     send his officials to establish on the spot whether there are justified

20     reasons to do so.  I'm sure he -- he and they would have gotten involved

21     in dealing with the problem.

22             On one occasion, around this time, there were several complaints

23     about the work of the various services in the station; not only mine,

24     which were in a written form, but there were other complaints as well,

25     from other people.

Page 11887

 1             A commission was set up; I don't know whether it was the minister

 2     who set it up or whether it was set up on behalf of the centre, but, in

 3     any case, it could not have been done without the consent of the minister

 4     of the interior.  All sorts of illegal doings were noticed by the members

 5     of the commission, the officials who were also employees of the security

 6     services centre where Mr. Cvijetic was chief.  And I believe that

 7     representatives of the MUP were also members of that commission.  But I

 8     don't know what the consequences those men who had been involved in

 9     transgressions or disciplinary violations were -- suffered.  The only

10     woman who was a Croat who was still there before that, she lost her job

11     at the time.  That's what I remember.  I know that.  As she was an

12     employee who worked in issuing ID, personal IDs.

13        Q.   And you said "about this time."

14             Do you mean in 1993 or still in 1992?

15        A.   I believe that that was in early 1993.  Or thereabouts.  Most

16     probably that inspection or that control that was carried out was the

17     result of the personnel shakeup when Pekic Petko took over from --

18             THE INTERPRETER:  And the interpreter didn't hear the first name.

19             MS. KORNER:  All right.

20        Q.   Took over from -- yes, took over from Malko Koroman, I think you

21     said.  Is that right?

22        A.   Yes, yes, you're right.

23        Q.   At the time when this commission was set up, was Mico Stanisic

24     still the minister of the interior?  Or was it in the period between his

25     first appointment and his second appointment in 1993?

Page 11888

 1             MR. ZECEVIC:  I'm sorry, Ms. Korner.  I believe it -- it has been

 2     established that the second appointment was not in 1993.

 3             MS. KORNER: [Microphone not activated] ... if so, I've missed

 4     that.  My understanding was he was reappointed at the end of 1993.  If

 5     I've missed a piece of evidence, then, I'm sorry.  But that's my

 6     understanding.  If Mr. Zecevic can tell me on what that's based.

 7             MR. ZECEVIC:  Well, we have -- we had a number of -- we had a

 8     number of witnesses who confirmed the second appointment was in early

 9     1994.

10             MS. KORNER:  Well, all right.  I -- can I just leave it at that.

11     I -- I withdraw the comment that I made, second appointment in 1993.

12        Q.   At the time of this commission, sir, was Mico Stanisic still the

13     minister of the interior?

14        A.   I really don't remember.  I don't.

15        Q.   All right.  That's all I want to ask about that report.

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

17     please.

18             JUDGE HALL:  Admitted and marked.

19             THE REGISTRAR:  As Exhibit P1457, Your Honours.

20             MS. KORNER:

21        Q.   Just to deal, please, with this Malko Koroman, the takeover from

22     Malko Koroman.  Could you just look, please, for a moment at the document

23     which is at tab 49, which is 1 --

24             MS. KORNER:  It's not on our 65 ter, and I'm not asking to

25     exhibit it.  But I just want the witness to deal with this.  103 --

Page 11889

 1     10373.

 2        Q.   Were you aware that on the 11th of January of 1993 that - that's

 3     the reason for the handover that we saw - Mr. Koroman was assigned by

 4     Mr. Njegus, the assistant minister, to the Administration for Legal and

 5     Administrative Affairs of the Ministry of the Interior?

 6        A.   I didn't know that.  This is the first time I see it.  I didn't

 7     know that he was assigned there.  As far as I knew at the time, he was

 8     supposed to be assigned to a police station in Novo Sarajevo, Grbavica,

 9     Lukavica where the Security Services Centre was.  He was supposed to be

10     sent somewhere down there.  And I know that he was very disappointed.  As

11     far as I know, he actually never left once he was removed from his

12     position.

13        Q.   All right.  To your knowledge, now, were any proceedings, either

14     criminal or disciplinary, taken against Malko Koroman as a result of the

15     many complaints that you put in?

16        A.   Not at the time.  After the war, however, yes.  He was subject to

17     certain proceedings; reports were filed against him.  But I don't know

18     whether anything came out of all that.

19        Q.   Now I want to, please, for a moment -- I'm going to come back to

20     the complaints that you made at the end, but I want to deal with a couple

21     of other issues, please.

22             MS. KORNER:  Actually, before I leave it, can we just -- could we

23     have up for the moment, document at tab 52, which is 2716.  And could we

24     have it not shown on the screen, please, for the public.

25        Q.   I think we can see at the head -- oh, it's a terribly bad copy

Page 11890

 1     in -- in the Serbian language.  But is that a report again compiled by

 2     you in 1993?

 3        A.   Yes.  Sometime in May.

 4        Q.   Yep.  In it, you repeat a lot of complaints from 1992 and a

 5     sufficient number from 1993; is that right?

 6        A.   Yes.

 7        Q.   All right.

 8             MS. KORNER:  Your Honours, although it is actually on our

 9     65 ter list, it does seem to me that it doesn't add anything.  I'm merely

10     adducing the fact that he went on complaining.  And, indeed, I accept

11     that in May 1993, of course, Mico Stanisic was not the minister of the

12     interior.

13             So it contains a repetition of the complaints from 1992 and new

14     ones in 1993.  But unless somebody else wants it in, I'm not proposing to

15     exhibit it.  I'm following Your Honours' directive not put in unnecessary

16     documents.

17             JUDGE HALL:  Thank you.

18             MS. KORNER:  All right.

19        Q.   Now, can I turn, please, to a couple of other matters, general

20     matters.

21             First of all, paramilitary organisations that arrived at various

22     stages in Pale.  Were you aware of Arkan's Men arriving and, at some

23     stage, staying in Pale?

24        A.   No.  I never heard that name being used for them at the time, and

25     I haven't heard of the presence of such persons, except on the occasion

Page 11891

 1     of an on-site investigation when we established that there was a group

 2     and that a member of that group had been killed nearby the Panorama

 3     Hotel.  And we found out that he was a member of either the White Eagles

 4     or the Serb National Guard.  I'm not sure.  But there are minutes -- or,

 5     rather, there is a report, and it say there to which unit he belonged.

 6        Q.   All right.  Was there also somebody called Gavrilovic and his

 7     group who were operating in Pale, Brane or Brne Gavrilovic.

 8        A.   I heard of Brne Gavrilovic.  That was his name.  I heard of that

 9     man but never saw him.  I don't know whether or not he was in Pale,

10     although he was born nearby.  And I know that at the time he was in or

11     around Ilidza with that group of his.

12             Once, I believe that I was the duty officer at the station, then,

13     a man from a nearby residential building came by and complained that two

14     hours before he came to the station, some "Chetniks" had come to call on

15     his wife.  Those were the formations or the units that belonged to Brne.

16     And they told his wife that she had to vacate the apartment by 6.00 p.m.

17     And they had been around at around 4.00 p.m.  That man was a Croat, he

18     was employed by the VRS, and his wife is a Serbian woman.  He told us

19     approximately where they had gone, and I sent the police out to take a

20     look around town.

21             In the meantime, complaints had come in from some Muslims.  And

22     the three men, I believe that there were three, were caught in the old

23     town of Pale, which is inhabited by Muslims.  I understood that they had

24     gone there to take their gold, et cetera.  And the late Mr. Koljevic went

25     there to calm down the situation.

Page 11892

 1             However, the police brought in these three men.  They were drunk.

 2     And I placed them in custody where they remained for the night.  And on

 3     the following day, Chief Koroman or one of the chiefs released them.  On

 4     that occasion, they stated that they were from somewhere around Rogatica

 5     and that they were going to Ilidza and in that van which was seized there

 6     was some live lambs.  They were very impertinent.  They even threatened

 7     me because I had put them in custody.  And that's what I know about these

 8     paramilitaries in Pale.  Never again did I see anyone nor did I hear of

 9     anyone coming or passing through.

10        Q.   [Previous translation continues] ... sir, thank you.

11             At what party did you under -- or what organisation did you

12     understand that this man Gavrilovic belonged to?

13        A.   He belonged to the Serbian Radical Party; I'm certain of that.

14        Q.   And who was the head of the Serbian Radical Party at that time?

15        A.   Well, I don't know.  I guess Seselj was the number-one man.  I

16     don't know.

17        Q.   All right.  Can we look, please, at a couple of documents about

18     the Muslims leaving.

19             MS. KORNER:  And can we look, first, at 24 -- 65 ter 24 ... oh,

20     sorry, I just want to check over my notes, if it's accurate.

21             Yes, 2470.

22        Q.   Now, we looked yesterday at the -- the Assembly meeting where

23     these decisions arose from.  And this is Mr. Koroman reporting to the

24     minister of the interior, 6th of July, about what has happened.  And on

25     the 30th of June, 88 Muslim citizens transferred.  And on the

Page 11893

 1     1st of July, 220 citizens transferred.  Then 324.  And on the

 2     3rd of July, 410.  Totalling just over a thousand people.

 3             Were aware of these transports, taking the Muslims out of Pale?

 4             MR. ZECEVIC:  Just before the -- the witness answers, Ms. Korner,

 5     you said:

 6             "And this is Mr. Koroman reporting to the minister of the

 7     interior."

 8             MS. KORNER:  Yes.

 9             MR. ZECEVIC:  I wonder based on what did you pose that question?

10             MS. KORNER:  You're absolutely right.  I read it, because it says

11     minister of the interior, but, of course, it's Pale.

12        Q.   All right.  It doesn't say to whom he is reporting, Mr. -- sir.

13     Can you -- you tell us to whom such a report would have gone?

14        A.   Are you asking me?

15        Q.   Yes, I am.  Who would -- on -- to whom would Mr. Koroman, as

16     chief of the police station in Pale, be reporting about the -- the change

17     of, as it calls, the place of residence of Muslims and Croats?

18        A.   Well, given the hierarchy, he was duty-bound to submit that

19     report to his immediate supervisor who -- and that was the chief of the

20     CSB.  But this may have been submitted to the president of the party.  I

21     can't know who he may have sent this to and whether he sent it out at

22     all.

23        Q.   When you say "the president of the party," which president --

24     which party?

25        A.   Well, the SDS party.  I suppose that Mr. Koroman was an SDS

Page 11894

 1     member.

 2        Q.   And the question I asked was -- sorry, were I aware of

 3     effectively the, all together, a total of 4, 9, 16 buses, over a period

 4     of a few days, removing over a thousand people from Pale?

 5        A.   I knew that they were leaving, but I didn't know on how many

 6     buses nor did I know how many of them had actually left.

 7             MS. KORNER:  Your Honours, may this document please be admitted

 8     and marked.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  Exhibit P1458, Your Honours.

11             MS. KORNER:  Well, I'm going to -- could we have up on the

12     screen, please, the document which is 2472.  I'll just check that.  Yep.

13        Q.   Now, sir, this is a document from the -- it looks like the

14     Executive Committee of the municipality.

15             MR. ZECEVIC:  Sorry, can we have a tab number, please.

16             MS. KORNER:  Yes, it's 31.

17        Q.   And I don't imagine that you've ever seen it before.  Had you

18     seen this document before until you looked at it --

19        A.   No.  No, no.

20        Q.   But I want to ask you about something that's contained in it.

21             It's complaining personally to Mrs. Plavsic about the fact

22     that -- it says that Muslims are moving out forcefully and wilfully at

23     their own private initiative.  And then the criminal -- the illegal and

24     criminal actions that have resulted, and so on and so forth.

25             And it goes on to say this:

Page 11895

 1             "We believe that the provisions of the law governing the

 2     competences of police stations, which are linked vertically ... to the

 3     Ministry of the Interior do not involve coordination between them and the

 4     Assembly Executive Committees, which has resulted in the above-listed

 5     problems."

 6             And the -- in effect, they're proposing that you first collect

 7     information, opinions, from chairmen of other Executive Committees and

 8     try to solve the issue of responsibility of police stations, not directly

 9     to the Ministry of Interior but to the Executive Committees of the

10     respective municipalities."

11             Now, first, sir -- I should read the last paragraph:

12             "We believe that forging the link ... could effectively prevent

13     the incidence of crimes and other -- eradicate other current problems.

14             "And we also find that no government, including a municipal one,

15     can be effective if it is not supported by an organ or institution of

16     enforcement.  That will ensure the implementation of its decisions and

17     conclusions."

18             Sir, were you aware of tensions or complaints of the lack of

19     cooperation with the Executive Committee of the Municipal Assembly and

20     Pale SJB?

21        A.   No.

22        Q.   It's asserted there that the police stations are linked

23     vertically directly to the Ministry of Interior and therefore there was

24     no obligation - that seems to be in the complaint - for them to either

25     report to or cooperate with the Executive Committees.

Page 11896

 1             Was that your understanding of how the -- the Law on

 2     Internal Affairs worked?

 3        A.   Yes.  And I can see here that they're pointing out that the issue

 4     of responsibility in the work of the police stations must be resolved and

 5     that this is their suggestion.

 6             MS. KORNER:  Your Honours, may this document please be admitted

 7     and marked.

 8             JUDGE HALL:  I understand the witness's testimony that he has

 9     commented on it.  But he had never seen it before.  He certainly wasn't

10     the maker.  What's the -- how does this come in through him?

11             MS. KORNER:  It's the actions, Your Honour, that he can comment

12     on.  That's his right, that there was a vertical chain of responsibility.

13             Your Honours, I accept that it's a tenuous link, but,

14     realistically, there isn't anybody else.  There's no other witness.  We

15     can apply to put it in through bar table, but there's no other witness

16     that we're calling that can deal with this.  So it's as simple as that.

17     If the say that the link is too tenuous, I say we'll just have to apply

18     to put it in through a bar table motion.  But we don't have anybody else.

19             JUDGE HALL:  Mr. Cvijetic, you were about to say something?

20             MR. CVIJETIC: [Interpretation] Your Honours, you have already

21     commented on one aspect of my objection.  And only upon the subsequent

22     explanation given by Ms. Korner we are convinced that there are not

23     sufficient grounds for this document to be tendered through this witness.

24     We believe that there are no conditions for that to happen.

25             And as for the system of the functioning of the MUP and their

Page 11897

 1     relations with their local bodies, there is much evidence such as

 2     regulations.  I believe that enough evidence has been tendered already.

 3     This is a rather shaky piece of evidence, whereas, we have much firmer

 4     evidence about that.

 5             MS. KORNER:  I --

 6             JUDGE HALL:  I needn't hear you in reply, Ms. Korner.

 7             I appreciate the -- taking on board Mr. Cvijetic's last

 8     observation about the -- this, as an item of evidence, being not as

 9     strong as other pieces of evidence that have been led.  I nevertheless

10     appreciate the importance of this for the case the Prosecution is trying

11     to build.  And whereas, perhaps, I shouldn't be persuaded by the argument

12     that there's no other witness to -- through whom it can go in, having

13     regard to the -- the context, and the witness has given evidence, it's

14     admitted and marked.

15             THE REGISTRAR:  As Exhibit P1459, Your Honours.

16             MS. KORNER:  Thank you, Your Honour.

17        Q.   Yes, that's all that I think I want to ask you about moving out.

18     And -- I'm sorry, there's -- I forgot to ask you -- paramilitaries, which

19     is my fault because I can't read my own notes.

20             MS. KORNER:  Can we have a look, please, at document 37, I think

21     it is.  Just a moment.  No, sorry.  No, no, no, no.

22             Yes, my fault.  Could we look, please, at document -- the next

23     document, which is 32.

24             Oh, sorry.  It's already an exhibit, but I want to ask about the

25     signature.  P317.17.

Page 11898

 1        Q.   This is a certificate that has been issued by Pale SJB.  Can

 2     you -- had you a chance to look at -- it's not really that clear on the

 3     screen, but you had a chance to look at it before.

 4             Can you tell us who signed that?

 5        A.   I haven't seen this receipt before.  This certainly is not the

 6     signature of the chief of the police station.  Somebody signed in his

 7     stead.  I can see it says "za," "for."  And the first letter is J.  It

 8     could only have been Jovicic.  But if the last letter is the Cyrillic Ch,

 9     there still is no Cyrillic letter V.  So it's difficult to say whether or

10     not he signed it.

11             But given the fact that the first letter is a J and the last

12     letter is a Ch, it could be Jovicic's signature.

13        Q.   And what -- and what position did he hold in the police station?

14     I think we saw his name yesterday.

15        A.   I think that, at the time, he was assistant commander.  I think

16     so.

17        Q.   [Previous translation continues] ... if we looked at yesterday's

18     document at the list of people at the station, he appears to be a sector

19     leader.  But by this stage he had been promoted to an assistant

20     commander, had he?

21        A.   Sector leader ...

22        Q.   You told us -- you mentioned yesterday the Yellow Wasps who were

23     operating in Zvornik.  Were you aware that Mr. Vojo Vuckovic was a member

24     of the Yellow Wasps?

25        A.   No.

Page 11899

 1        Q.   On what authority would Mr. Jovicic, if that is his signature,

 2     have been able to hand out this kind of weaponry to this person?

 3        A.   I don't know how anybody could have signed this instead of

 4     Malko Koroman, the chief.  Possibly only Jovan Skobo.  But given the fact

 5     that this is about such a person, I doubt that even he would have dared,

 6     or would -- would have been allowed to sign this.  But without the

 7     approval of the chief, I doubt that this could have been handed out.

 8        Q.   And what view do you take about the police, the authorised

 9     officials, handing out weaponry to members of a group that was neither

10     military, official military, nor members of the police, a member of the

11     police force?

12        A.   Well, that's totally unacceptable and illegal.

13        Q.   All right.  Thank you, sir.  That's all I want to ask you about

14     that document.

15             Now, finally, can I ask you to look at a group of -- some further

16     documents that really arise out of the report that you wrote.

17             MS. KORNER:  Could we have a look, please, next, at the document

18     which is 2412, 32A.

19        Q.   This is a decision of the Executive Committee of the municipality

20     on the 14th of July, where they're recognising the matters that you

21     described yesterday, that the leaving - to put it neutrally - of the

22     non-Serb citizenry, that there had been problems in listing their

23     property which resulted in theft and unlawful use of abandoned property.

24     And they have decided to create a revision committee.  And on behalf of

25     the Pale Police Station, crime inspector Goran Mumovic is to go on to

Page 11900

 1     this revision committee.

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5             MS. KORNER:  Can we just redact that before it goes out.  Thank

 6     you.

 7        Q.   Did you know that he had gone on to the commission?

 8        A.   No.

 9        Q.   Did he, in fact, join any commission, as far as you were aware,

10     to do with -- dealing with the -- the property of non-Serb citizens?

11        A.   As far as I can remember now, he did go to the municipality

12     because the chief had tasked him with something.  But I don't remember

13     whether it was about this list of property or something else.  He didn't

14     inform me, and we didn't do anything particular about this either.

15             Yes, we did do what we were able to do but not specifically about

16     protecting this property, because the crime investigation service was

17     small.

18        Q.   Thank you.

19             MS. KORNER:  Your Honour, can that be marked and admitted --

20     admitted and marked, please.

21             JUDGE HALL:  Admitted and marked.

22             THE REGISTRAR:  As Exhibit P1460, Your Honours.

23             MS. KORNER:  All right.

24        Q.   Can you look now, please, at the document which has already been

25     admitted as a Defence exhibit, I see.

Page 11901

 1             MS. KORNER:  1D00183.

 2             And can we go to the -- yep, the second page, please, in each,

 3     English and B/C/S.

 4        Q.   This is an order from the ministry itself.  It looks like the - I

 5     hope I'm right in saying this time - the crime prevention administration,

 6     dated the 6th of August.  And it's addressed, among other police

 7     stations, to yours.  And it's all about the theft of these Golfs from the

 8     factory Tas.

 9             All I want to know, sir, is, we see many complaints about illegal

10     possession of vehicles by members of the SJB; did you, as a police

11     station, conduct any investigations into these Tas thefts?

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11902

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8             MS. KORNER:  I'm afraid that answer will also have to be redacted

 9     before it goes out.

10        Q.   Was that the only time that Mr. Macar from the crime prevention

11     administration turned up at -- at Pale Police Station?

12        A.   Well, no.  That was not an only occasion.  He turned up on --

13     turned up on several occasions on different matters.  But he didn't come

14     to me.  He didn't come to inspect my work.  He paid visits to the chief

15     to discuss issues.  But in that particular case he came to deal with that

16     particular crime, and we had a discussion in my office on that occasion.

17        Q.   As far as you understood, was a great deal of the MUP manpower -

18     we see that it was addressed to a number of police stations, this

19     document - spent on investigating these thefts?  Or from -- the thefts

20     from the Tas factory?

21        A.   I don't know how many people were involved.

22             In any case, all the adjacent stations or stations around

23     Sarajevo and especially in that part around Vogosca.  I can't prove what

24     I'm saying here, but I can say that a lot of officials were involved in

25     all that.  They stole vehicles, and they sold them on.  Mr. Jovan Skobo

Page 11903

 1     also sold a vehicle to an Albanian in Kosovo during the war, and he

 2     issued him with the paperwork from the public security station,

 3     pretending that everything was legal.  Later on, the vehicle was seized.

 4     There were checks.  And when I went there and when I established that

 5     vehicle was not appropriately registered, however -- I mean, it did have

 6     a registration number, but under that registration number there is the

 7     name of a totally different owner.  After my check which I carried out on

 8     the request of the MUP and after I reported back to the MUP, I heard - he

 9     didn't say that to me personally - I heard that Chief Malko Koroman paid

10     a visit to that administration.  And he was very angry, and he forbade

11     him to ever go there.

12             The officials told me that.  I heard that.

13        Q.   Yes, thank you, sir.

14             MS. KORNER:  Next, could we have up on the screen, please,

15     document 2704 but please not to go out to the public.

16        Q.   This is an Official Note that is signed by you, and it's to do

17     with this Teletina incident, which we looked at in your full report.

18             For who -- for what purposes -- all I want to know is:  Did you

19     draft this Official Note?  To who was it going to go.

20        A.   This Official Note was sent to the Security Services Centre, and

21     I believe that I also sent it to the basic court in Sokolac.

22             MS. KORNER:  Your Honour, may that, then, please be admitted and

23     marked, under seal.

24             JUDGE HALL:  Admitted and marked, under seal.

25             THE REGISTRAR:  As Exhibit P1641, under seal, Your Honours.

Page 11904

 1             MS. KORNER:  And then could we have up, please, up next a

 2     document, 3369; but, again, not to go out to the public.

 3             MR. ZECEVIC:  I'm really sorry, Ms. Registrar, I have a problem

 4     with my computer.  I don't have LiveNote.  It says "out of memory" or

 5     whatever.

 6             So if you can please help me with that.

 7             MS. KORNER:  Your Honour, I understand Mr. Zecevic is happy for

 8     me to carry on while they try and sort it.

 9        Q.   Sir, this is, again, a document drafted by you, dated the

10     20th of December.  And this time it's addressed to Mr. Cvijetic at the

11     Security Services Centre.  And it starts off by saying:

12             "Because I opposed many incriminating activities of the

13     leadership and other officers ... you have not taken any action, although

14     you were informed about it promptly, that the leadership will probably

15     become emboldened."

16             And then you say that you were told that you weren't allowed to

17     carry -- effectively carry out your duties by Chief Koroman.  And then

18     you were actually physically -- or threatened by Mr. Skobo at a meeting

19     on the 16th of December.

20             Did -- was what you put in that note truthful and accurate?

21        A.   Yes.

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

23     seal.

24             JUDGE HALL:  Yes.

25             THE REGISTRAR:  As Exhibit P1462, under seal, Your Honours.

Page 11905

 1             MS. KORNER:

 2        Q.   Now, sir, let's come to the dealings you had with Mico Stanisic

 3     as minister.

 4             You've explained and we've looked at documents about the many

 5     complaints that you made about what was happening to Mr. Cvijetic.

 6             Did there come a time when you actually spoke directly to

 7     Mico Stanisic in 1992?

 8        A.   Towards the end of that year, I met Mr. Stanisic.  Actually, I

 9     didn't meet him -- there was a meeting on Mount Jahorina, and I took the

10     opportunity to talk to him for a couple of minutes and told him briefly

11     that I had problems.  And on that occasion, I asked him to possibly

12     transfer me to the ministry, to assign me to the position of the

13     inspector for traffic safety, which is what I did before the war.

14             We didn't talk for too long.  He was in a hurry.  But did he

15     promise me that he would do it, that I should come to the Bijeljina MUP

16     in order to see things through.  I went there on one occasion, actually

17     at the first opportunity I went there; I saw him in passing.  He was on

18     his way to Belgrade at the moment.  He told me to go to

19     Milan Zuban [phoen], who was the chief of the police at the MUP at the

20     time.  He asked me to send an application to be transferred.  I did that.

21     I handed that application to Mr. Zubin, but the transfer never

22     materialised.  And I believe that it is more -- that it was more due --

23     down to Zuban, who was not a very conscientious person, not a very

24     hard-working person who saw things through.

25        Q.   [Previous translation continues] ... so you saw him, is this

Page 11906

 1     right, first of all on Mount Jahorina, and then again in Bijeljina?

 2        A.   Yes.

 3        Q.   You told us that you told him briefly that you had problems.

 4             When you say "problems," what problems were you telling

 5     Mr. Stanisic about?

 6        A.   I don't remember what exactly I told him.  I don't think that I

 7     mentioned any specific cases.  I just spoke in general terms about my

 8     problems with -- in working with the inspectors with Malko.  I mentioned

 9     Mr. Skobo's threat.  Malko was sitting there, and he didn't protect me.

10     And then also I told him that I could not perform my job if I was

11     forbidden from entering places and making checks, official checks, of the

12     documents.  And I wasn't left my choice.  I had to go because there was

13     no room for me there.  I can't remember, but I'm almost sure that I did

14     not mention any specific cases to him on that occasion.

15        Q.   What was your understanding of his knowledge of what was

16     happening at Pale Police Station?  What had been happening over the

17     period from April to December; or November, when you saw him.

18        A.   You know what?  I assumed that he was aware of things, and let me

19     tell you why.

20             Chief Cvijetic was aware of many things.  Mr. Cvijetic hails from

21     Sokolac, and Mr. Stanisic hails from not far away from there.  They knew

22     each other.  And in terms of the hierarchy and subordination, I believe

23     that Zoran kept him posted, if not officially, then at least in his

24     private capacity.  He kept him posted about things they were -- that were

25     going on.  And I don't know that for sure; I only assumed that that was

Page 11907

 1     the case.  Unless Mr. Stanisic had his own channels of information coming

 2     from Pale to him personally.

 3        Q.   So sum that up, there were two reasons you made that assumption.

 4     The first was that there was the principle of the hierarchy and that

 5     Mr. Cvijetic was obliged to report to him, any problems; and, secondly,

 6     because they came from the same area, or roughly the same area?

 7             MR. ZECEVIC:  I'm really sorry, but I believe that is important.

 8     And, unfortunately, the last part of the answer of -- to the previous

 9     question was not recorded.  I don't know if we need to go into the

10     verification request or maybe the witness can -- can repeat.  Because it

11     wasn't recorded what he said.

12             MS. KORNER:  All right.

13        Q.   Sir, sorry, we have occasional problems with interpretation.

14             But you were -- you said you were telling me why you assumed he

15     was aware of things.  And you said:

16             "... I believe that Zoran kept him posted, if not officially,

17     then at least in his private capacity.  He kept him posted about things

18     they were -- that were going on ... I don't know --" I think that must be

19     "for sure."  Yes.  I see that the transcript -- it's gone a bit haywire

20     here.  "... Mr. Stanisic had his own channels of information coming from

21     Pale to him personally."

22             Now, in particular, I don't know if that's what Mr. Zecevic is

23     referring to, the sentence:

24             "He kept him posted about things they were -- that were

25     going on."

Page 11908

 1             And then we're not sure, and certainly what's recorded doesn't

 2     make sense.

 3             What did you say, sir?  Can you just repeat it, if you can?

 4        A.   Well, you know what?  It was only natural that the chief of the

 5     centre was supposed to inform the minister about the problems that he had

 6     in his areas where he was in command.  And judging by that principle, I

 7     assumed that Mr. Stanisic knew, that he was aware, that he was on top of

 8     things.  Both in terms of the official line and most probably in terms of

 9     their private line.

10             The two of them hailed from the same area.  They knew each other.

11     It was also possible that Mr. Stanisic received all that -- that

12     information, or maybe he checked the information that he had received,

13     maybe he had a line of information that went straight to Pale, maybe he

14     knew people who worked there.  Because you never know who works for whom

15     and what they do.

16        Q.   When you explained, however briefly, to Mr. Stanisic about the

17     problems that were going on at -- at Pale station, did he ask you for any

18     further information?

19        A.   No, no.  You know what?  He didn't ask for ... I talked to him as

20     one human being to another.  It was all in a rush.  At that time, I had a

21     place more -- most trust in Mr. Cvijetic and in Minister Stanisic at that

22     time.  I thought that they were the only ones that I could talk to.  And

23     if they couldn't solve my problem, then nobody else could.

24             So, no, I -- I'm sure that we did not take the matter any

25     further.  It was a brief encounter, only in passing.  Everything happened

Page 11909

 1     fast.

 2        Q.   You weren't, as you told us, your request to transfer was not

 3     acted on.  You remained at Pale Police Station.  And as we saw, there was

 4     a change in the head.  And as we also saw, however, there seemed -- there

 5     was still problems.

 6             So did you speak to Mico Stanisic again later on?

 7             And can I ask you straight away:  Was he, at the time you spoke

 8     to him, on the third occasion, in fact, the minister again?

 9        A.   Well, after the first encounter -- or, rather, after that

10     encounter when we discussed my transfer and after that request was not

11     met, I never requested a meeting with Mr. Stanisic.  I believe that some

12     changes occurred and that he was no longer minister.  I don't think he

13     was, actually.

14             It was only at the beginning, and I originally thought it was at

15     the end, however, it was at the beginning of 1994, most probably in

16     February.  On one occasion, Mr. Stanisic did come to Pale; and near the

17     police station there are the offices of the ministry dealing with

18     finances and accountancy.  He paid them a visit.  He has a room there.

19     If he had to hold a meeting, that's where he would hold it.  Or if he had

20     other things to do, that's where he would do those things.

21             MR. CVIJETIC: [Interpretation] I apologise.  Your Honours, just a

22     minor objection:  We are leaving the frame of 1992.  I don't know how

23     relevant will the further line of questioning be.  I don't want us to go

24     much beyond the scope of the indictment.

25             MS. KORNER:  Your Honour, this is relevant.  If there's going to

Page 11910

 1     be a discuss about it, perhaps -- I see it's time for the break.  It

 2     ought to be in the absence of the witness.  And perhaps it can be -- we

 3     can have a couple of minutes before the witness come back in.

 4             JUDGE HALL:  We will take it up after the break.

 5             MS. KORNER:  Yes.

 6             JUDGE HALL:  But I didn't -- of course, I'd hear what counsel has

 7     to say, but I thought the problem could have been addressed by Ms. Korner

 8     refining the question.  But if counsel think that that is insufficient

 9     and there has to be some determination by -- by the Chamber as to the

10     actual question, then we will do it in the absence of the witness.

11             MS. KORNER:  Your Honour, I think the objection is coming because

12     of the time-period.  However, the nature of this particular meeting is

13     relevant to various issues that have emerged in this case.

14             Now, if Mr. Cvijetic still wants to argue it, then I'm perfectly

15     prepared to.  If Your Honours want advanced information about what this

16     is about, Your Honours, it's at page 18 and 19 of the interview which has

17     been uploaded into e-court.  And we can also provide Your Honours with a

18     copy.

19             JUDGE HALL:  It only struck me, when I talked about refining the

20     question, is that the answer of the witness was more -- was less precise

21     than -- than the question, and the -- the answer that the witness

22     provided probably formed the basis of Mr. Cvijetic's objection.

23             MS. KORNER:  I don't -- I believe that Mr. Cvijetic's objection

24     is because it's outside the period of the indictment.

25             JUDGE HALL:  Anyway, we'll take it up after the break.

Page 11911

 1             MS. KORNER:  Yes, certainly.

 2                           [The witness stands down]

 3                           --- Recess taken at 10.28 a.m.

 4                           --- On resuming at 10.54 a.m.

 5             MS. KORNER:  Your Honours, my understanding - and I hope

 6     Mr. Cvijetic will confirm it - although he wants his objection to be

 7     noted, that I'm dealing with 1994, he doesn't want to argue it further.

 8             But perhaps Your Honours can confirm that.

 9             JUDGE HALL:  Well, unless he says anything to the contrary, we

10     would proceed.

11             So the witness can be escorted back to the stand.

12             For my own purposes though, Ms. Korner, I would still prefer you

13     to ask the question again with a view to seeking a more refined answer

14     than the one the witness has given so far.

15             MS. KORNER:  Sorry, in the sense that the witness has been off on

16     a tangent, I'm leading into it, as it were.

17                           [The witness takes the stand]

18             MS. KORNER:

19        Q.   Sir, can I -- we were talking about the second -- sorry, third

20     meeting you had with Mico Stanisic which was at the beginning of 1994.

21     And you were explaining how it came about.

22             Was this conversation with Mico Stanisic at Pale, and, again, was

23     it about the problems that were still persisting in Pale?

24        A.   Yes.

25        Q.   Now I'd like you to tell us --

Page 11912

 1             MS. KORNER:  I hope, Your Honours, that refines it more.

 2        Q.   What was his attitude when he came to speak to you?

 3        A.   On that occasion, we had a somewhat longer conversation.  There

 4     were just the two of us.  I told him many things.  I complained about

 5     my -- the residential status.  I didn't have a place to live.  There was

 6     a time when I slept in my office on a makeshift bed provided by my

 7     colleagues.

 8             I put him in the picture.  I told him about the problems that

 9     were happening.  The conversation was fair.  We were honest to each

10     other.  He promised me that he would certainly solve all of the problems

11     and that there would be personnel shake-ups very soon.  That's what he

12     told me "soon."  And that was not the last conversation we were having.

13     It was a somewhat longer conversation early in the afternoon, as far as I

14     can remember.

15        Q.   All right.  Then tell us now, then, about the last conversation.

16        A.   Well, a few days later, five or six days, maybe not even five

17     days, his driver called me up from Jahorina and told me that the minister

18     had ordered me to wait for him in the room where we had met last.  And I

19     was there at the time.  He came.  He was extremely angry, furious, which

20     surprised me greatly.  I was flabbergasted.  I entered the room where he

21     usually holds meetings -- or held meetings when he was there.  He told me

22     to sit down, and I did.  Then Mr. Stanisic - I don't know how to put it.

23     It would be a bad thing for me to say that he shouted or hollered.  But

24     it was terrible for a highly educated man in such a high position, the

25     way he behaved.

Page 11913

 1             And, thirdly, I felt like a slave.  I didn't dare move.  He

 2     walked up and down -- down the room, shouting, accusing me of obstructing

 3     this or that.  I don't even remember what he was saying.  And I didn't

 4     know what to -- could happen at any moment.  And it went on for an hour

 5     at least.  And I know that, once it was over, nobody could be found in

 6     the neighbouring offices.  In that angry outbursts -- in those angry

 7     outbursts and in issuing threats to me, he went on, and I noticed that he

 8     was armed.  He had a pistol in a holster.  And he touched that holster

 9     several times.  And I didn't know that -- what he might be able to do.  I

10     had never known him like that.  I met him for the first time when I

11     entered the service.  And I knew the man, I thought -- and finally he

12     said to me, extremely angrily, that on the following morning I would be

13     out in the trenches with the military, somewhere on Mount Jahorina.  And

14     I said, No problem; I'll go to the trenches.  But I'm sure that one day

15     it will be known who did what, and that none of his accusations were

16     founded.

17             It went on for quite a while, and once he -- his anger subsided,

18     I started talking, because I couldn't earlier.  He wouldn't let me.  And

19     then I mentioned some specific cases that he had mentioned, that, let's

20     say, investigator Milomir Gavrilovic had done that.  And I asked him to

21     have that man come and to see whether I was responsible or somebody else.

22     And he, indeed, agreed.  Milomir Gavrilovic was called to come, and he

23     had a talk with him later.  I wasn't present then.  But before I finished

24     my conversation -- actually, I left, and Gavrilovic arrived.

25             I don't know whether it was on that day, because it was evening

Page 11914

 1     already, whether I met my chief.  But I'm sure that I met him on the next

 2     morning.  And I acquainted him with what had happened.  And I told him

 3     that the cases that Stanisic had spoken about must be completed.  It was

 4     about, among other things, the theft of a Golf vehicle that was the

 5     property of some dentist from Pale.

 6        Q.   [Previous translation continues] ... thank you very much, sir.

 7             Just one other question about this meeting:  You say that he

 8     uttered threats and one of them was that you would be out in the trenches

 9     the next day.  Did he utter any other threats?

10        A.   Well -- well, there were no other threats.  Only he reached for

11     his pistol two or three times, and I wasn't armed.  And given the state

12     he was in then, I thought, He might as well kill me, possibly.  Who

13     knows?  I had a hard time processing that, because I had known him for

14     some 15 years before that incident.

15        Q.   Yes.  Now, finally, sir - thank you - I just want to ask you

16     about the record of the log-book.

17             JUDGE HARHOFF:  Ms. Korner, before we leave this subject, I'd

18     like to ask you, Mr. Witness, what the argument was really about at that

19     occasion, between you and Mr. Stanisic.  Because I'm not sure that I have

20     fully understood what Mr. Stanisic's concerns were.

21             He was accusing you, you said.  But what did he accuse you of?

22             THE WITNESS: [Interpretation] I suppose that the reasons were the

23     following:

24             A Golf was stolen from that dentist.  He was able to recover the

25     vehicle by paying for it.  I think that he paid 5.000 German marks.  He

Page 11915

 1     had reported the theft of the vehicle, and Milomir Gavrilovic, the

 2     investigator, had received the report.  And he was in contact with the --

 3     the man about finding information about the perpetrators.  It was in

 4     early December 1992.

 5             In mid-January, possibly around the 20th, I learned on the street

 6     from citizens by mere chance that the doctor had found his vehicle.

 7             JUDGE HARHOFF:  But, Mr. Witness, it is still not quite clear to

 8     me what the development was, because if I recall correctly, you started

 9     out by saying that you met with Mr. Stanisic a couple of times prior to

10     the meeting in early 1994.  And at the first occasion when you met him,

11     you told him that you were unhappy with the way things were going in

12     Pale, because your cooperation with your staff was not going well, and,

13     as I understood it, there were crimes committed which were not - and

14     deliberately not - investigated, and that was to your dissatisfaction.

15             And so, if I understood you correctly, this was the subject of

16     your concerns when you addressed Mr. Stanisic the first time.

17             Now, what you have just told us now about your last meeting with

18     Mr. Stanisic appears to me to be something completely different; namely,

19     an issue about the theft of -- of a car from a dentist.  And in -- I'm

20     surprised that this could take Mr. Stanisic to such a level of rage that

21     he would scold you for an hour about this.

22             So was there anything else at the meeting in December -- in

23     January 1994 which links back to your original complaints about the

24     conditions in Pale?

25             THE WITNESS: [Interpretation] Well, you know what?  That doctor

Page 11916

 1     wouldn't cooperate with us, even after his vehicle was returned.  He

 2     didn't want to tell us who the perpetrators were.  He said that they were

 3     MUP employees with stockings over their heads, that he knew some of them

 4     but he didn't dare say their names.  And he went to Mr. Karadzic and told

 5     him about it.  And I suppose that later on Mr. Karadzic called up

 6     Mr. Stanisic and that that was the reason.

 7             Apart from that vehicle, there was another vehicle which was a

 8     problem.  I mean, there were more vehicles.  But let me mention this one:

 9     It was a military vehicle which had gone off the road and landed in a

10     ditch; and in a very short time, it was stolen.  Although it was very

11     heavy, so you needed actually a crane to pull it out of the ditch.  I

12     know that it was with the director of the radio television,

13     Mr. Ilija Guzina, but he couldn't do anything about it.  And that was

14     also a problem.  Maybe Mr. Karadzic demanded the minster that he do

15     something about that too.

16             JUDGE HARHOFF:  Thank you.  Mr. Witness, did any of this have

17     anything to do with investigation of crimes committed against non-Serbs

18     in the Pale area?

19             THE WITNESS: [Interpretation] No.

20             JUDGE HARHOFF:  Thank you very much.

21             MS. KORNER:

22        Q.   Sir, finally, can I ask you to deal with the crime register from

23     Pale Police Station.

24             MS. KORNER:  Your Honours, can I explain.  This is exactly like

25     the documents that Mr. Olmsted was dealing with yesterday.  It's a

Page 11917

 1     ledger.  It's not been translated.  There are certain statistics which

 2     have been extracted, which this witness - that's why we asked for the

 3     extra time yesterday - was able to confirm.  And I'm just going to go

 4     through them.  The Defence have them.  I'm going to ask just that a page

 5     of the book be put up so that we can see what it's like.

 6             The book itself is 10388.  And can we go, in it, to -- it should

 7     be - one, two, three, four, five - the sixth page, which bears the number

 8     at the top:  0700-7401.

 9                           [Prosecution counsel confer]

10             MS. KORNER:

11        Q.   And is that the --

12             MS. KORNER:  I'm sorry, you will have to move it to the

13     right-hand side so I can see the page number at the top.  0700 -- a bit

14     more, please.  Oh, all right.

15             Well, can I -- I don't think it's the right page then because

16     after the fourth entry there should be writing.

17             The date -- the first date that one should see at the top of the

18     page is 6/3/92.  Now, I can't read a thing on the screen.  But it doesn't

19     look -- it's certainly not the right page, no.

20                           [Prosecution counsel confer]

21             MS. KORNER:  I just want the one page.  I'm sorry, there seems to

22     be a -- seemed to have not told the Case Manager, which is our fault,

23     that -- what page -- [indiscernible].  We're going to put the actual

24     document.  I just want identification of the writing.

25             Oh, we're going to put it on the ELMO?  How are we going to

Page 11918

 1     do that?

 2                           [Prosecution counsel confer]

 3             MS. KORNER:  Yes, could the usher come and pick up the document,

 4     and we'll put it on the ELMO.

 5             JUDGE DELVOIE:  Ms. Korner, this 10388 is not on your list of

 6     documents.  No.

 7             MS. KORNER:  It is.  Yes.  It was on the revised list.  It's the

 8     last document.

 9             JUDGE DELVOIE:  Okay.  Thank you.

10             MS. KORNER:  And it's not -- it's not on our 65 ter, and we've

11     never had them translated, so -- expect for headings, which isn't -- all

12     right.

13             Got it, yes.  But I'm afraid my -- it's my copy, so I scrawled --

14     but I didn't think of it.

15        Q.   Sir, the writing in the middle of the page, this log-book, there

16     was clearly a gap between the end of the joint MUP and the beginning of

17     the new MUP, the Serbian MUP.

18             Whose writing is that in the middle of the page?

19        A.   You mean where it says "concluded"?

20        Q.   Yes.  It's after the entry -- we can see there's a break in the

21     entries and then we start again at number 1 in the entries, and there's

22     some writing in the middle of that page, that writing.

23             Can you just read out what it says?

24        A.   "Concluded or closed with entry number 37."

25             I wrote that because, until that time, there was no war and there

Page 11919

 1     was no division of the MUP.  With new criminal reports, these new reports

 2     were dealt with by the Serbian MUP.

 3        Q.   Before I deal with the statistics - sorry - what was the system

 4     in Pale Police Station?  When would entries be made in that book?  At the

 5     time a report was written?  Or immediately on opening -- starting an

 6     investigation?

 7        A.   This log-book of criminal reports would contain only such reports

 8     which were duly completed and forwarded to the prosecutor's office at

 9     Sokolac.

10        Q.   All right.  Thank you.  Can I just, then, deal with these

11     statistics that you were asked to check and went through.

12             I think there were a total number - and, indeed, when one goes to

13     the end of that year, one can see - there were a total number of

14     60 criminal reports, but there were 65 that dealt with a total of

15     65 different allegations of crime?

16        A.   Yes.

17        Q.   There are only three criminal reports that you were able to

18     find - and, indeed, so was the other gentleman that looked at it - where

19     the victims of the crime were said to be that of Muslim ethnicity,

20     judging by the names.  And that was numbers 8, 11, and 30 in the book,

21     the charges being, respectively, aggravated theft and two cases of

22     murder.

23             And in each case, the perpetrators were said to be unknown.  Is

24     that correct?

25        A.   Yes.

Page 11920

 1        Q.   And there were no cases where Muslims were said to be the victims

 2     recorded and where -- or, in fact, there were only three, and the

 3     perpetrators were unknown; so it's obvious.

 4             The remaining 60 reports have Serb perpetrators and Serbs as the

 5     alleged victims.  Is -- is -- is that right -- no, not the remaining 60,

 6     the remainder of the reports, once you've taken off those three?

 7        A.   Yes.  But there were also murders of Serbs committed by unknown

 8     perpetrators.

 9        Q.   Right.  Thank you.  Yes.  Sir, thank you very much.  That's all

10     that I ask.

11             JUDGE HALL:  Before Mr. Cvijetic begins, I would remind -- I

12     would point out to the witness and remind counsel that inasmuch --

13     especially because you speak the same language, to allow a gap between

14     question and answer for the purpose of interpretation.

15             MR. CVIJETIC: [Interpretation] May I start, Your Honours?

16             JUDGE HALL:  Yes, please.

17             MR. CVIJETIC: [Interpretation] Thank you.

18                           Cross-examination by Mr. Cvijetic:

19        Q.   [Interpretation] Good morning, Witness.

20        A.   Good morning.

21                           [Trial Chamber and Registrar confer]

22             JUDGE HALL:  Mr. Cvijetic, you are reminded to switch off your

23     microphone after your question.  Thank you.

24             MR. CVIJETIC: [Interpretation] Yes, I know.  I only wanted to ask

25     the witness to pause, among other reasons, for me to be able to switch

Page 11921

 1     off the microphone so that it doesn't pick up the witness's voice.

 2        Q.   I must address you as Witness.  We've already agreed on that.  I

 3     will mostly proceed along the questions asked to you by Ms. Korner.

 4             So I'm going to ask you about your appointment.

 5             The decision on your appointment was shown to you yesterday.

 6     That's 65 ter 2719.  And you explained that this decision was -- bears an

 7     earlier date, namely that the 1st of April is mentioned as the date,

 8     although the decision was actually issued later.

 9             MS. KORNER: [Microphone not activated] ... he said he didn't get

10     till later.  He didn't say it was issued later.

11             MR. CVIJETIC: [Interpretation] Clearly my questions go in that

12     direction.  The witness knows what I'm talking about.  But I would like

13     to clarify with the witness the following:

14        Q.   On the 1st of April, you were not able to receive such a decision

15     because the ministry existed only on paper, it only had a minister and

16     nothing else, and no services that could have drafted such a decision.

17             Correct?

18        A.   Yes.

19             MS. KORNER:  Your Honours, I -- can I -- I'm sorry to interrupt

20     Mr. Cvijetic, but it is something I want to raise now and not have to get

21     up and do again.

22             We've discovered that when we're trying to analyse the evidence

23     it's very difficult to find out what exactly the witness is saying

24     because we have - and we're as much to blame sometimes as Defence, can I

25     say straight away - it's compound questions.  There are more than one

Page 11922

 1     fact contained in each of the question.

 2             So, for example, in this last question:

 3             "On the 1st of April, you were not able to receive such a

 4     decision because the ministry existed only on paper, it only had a

 5     minister and nothing else, and no services that could have drafted such a

 6     decision.  Correct?"

 7             That's at least three propositions in one single question.  And I

 8     am going to ask - and we're going to try and do the same - that we stick

 9     to one fact per question asked.  It just makes it much simpler to work

10     out what the witness is either saying or agreeing with.

11             So if I can just make that point now so that I don't have to keep

12     getting up and saying that.  But it has really become a problem, as we've

13     discovered, when analysing the evidence.

14             JUDGE HALL:  Thank you.  So, in other words, we all have to

15     discipline ourselves.

16             Please proceed, Mr. Cvijetic.

17             MS. KORNER:  I wouldn't suggest for one moment that Your Honours

18     should -- should follow this.  I'm simply saying for counsel.  I wouldn't

19     be so bold as to suggest that.

20             MR. CVIJETIC: [Interpretation] I'll try to discipline myself.

21        Q.   Witness, then, on the 1st of April, as I've already said, the

22     ministry practically existed only on paper and had only a minister.  And

23     that minister had nothing at his disposal in the ministry apart from

24     himself.  Correct?

25        A.   I didn't know about that.  Even later, when I dealt with issues

Page 11923

 1     of -- concerning my years of service.  I was officially employed by the

 2     MUP of BiH until the 6th of April.  I don't know that there was a

 3     minister appointed as early as the 1st of April.  No idea about that.

 4        Q.   I'll explain to you the crux of my issue.

 5             You will agree with me, will you not, that such decisions were

 6     issued to employees of the ministry in their interest for them to be --

 7     to have their years of service acknowledged, and that's why the decisions

 8     bore earlier dates; am I right?

 9        A.   I believe so.

10        Q.   Thank you.

11             Answering to Ms. Korner's question, you spoke about your

12     appointment in the earlier MUP of the Socialist Republic of

13     Bosnia-Herzegovina.  And you even said, I believe, that on the same day,

14     together with Mr. Koroman, you attended a reception with representatives

15     of the MUP of Bosnia-Herzegovina because you were appointed together with

16     them.  Do I remember that correctly?

17        A.   Yes.

18        Q.   I'll ask you directly.  I don't need to remind you of your

19     answer.  That was in 1991.  Do remind me of the name of that official of

20     the MUP of the Socialist Republic of Bosnia-Herzegovina.

21             Wait a minute before you answer.

22        A.   I believe that I -- that was in March that I was transferred, but

23     I really don't remember the name of the man.  But he was a Muslim, I

24     think.

25        Q.   So Mr. Malko Koroman was chief before the establishment of the

Page 11924

 1     MUP of the RS; am I right?

 2        A.   Yes.

 3        Q.   And now let me ask you about something that happened in Pale.  I

 4     would like to see whether you remember the event.  Do you remember a

 5     protest rally which was organised in Pale after the attempt to remove

 6     Mr. Malko Koroman from his position by Mr. Mico Stanisic, at the very

 7     beginning?

 8        A.   Yes, I remember some activity of that kind, but I don't know what

 9     it was all about.  I know that Mr. Stanisic was involved.  Yes, I do

10     remember, vaguely, that things likes that did happen.

11        Q.   Can you also remember how big that rally was, how big the turnout

12     was in Pale?

13        A.   The meeting -- the rally was really huge, and that Jovicic and

14     Skobo and other men and a few others went around and recruited people to

15     join the rally.  I myself did not participate in that.

16        Q.   According to the -- the information that the Defence has, there

17     were several thousand people, and they unanimously provided support to

18     Mr. Malko Koroman and effectively prevented Minister Stanisic from

19     removing him from his position.  Do you know anything about that?

20             MS. KORNER:  Don't answer, please.

21             Look, there are three propositions in that one question, please.

22     Firstly, was the rally really huge, several thousand people; second, did

23     they unanimously provide support to Mr. Koroman; third, did they

24     effectively prevent Mr. Stanisic from removing him.

25             Now if you split those three things up, then we'll know what he

Page 11925

 1     is answering.

 2             MR. CVIJETIC: [Interpretation] Very well.

 3        Q.   Witness, is it true that several thousand people attended that

 4     protest rally?

 5        A.   I heard that there had been a lot of people, and I saw a group

 6     myself on the way to the town centre.  They were passing by the police

 7     station.  And as they were passing by, there may have been about

 8     500 people in that group.

 9        Q.   Very well.  And that was just that one group that you saw, and

10     there were 500 people in that group?

11             My next question is this.  And, now, let me ask you this:  What

12     was the purpose of that rally?  Was it a protest against the removal of

13     Mr. Koroman and support to Mr. Koroman [as interpreted]?

14        A.   Yes.

15        Q.   Did he receive the support at the local level?  Did he remain in

16     the position, despite the attempt to remove him?

17        A.   Yes, at that moment, he did stay in the position.

18        Q.   Witness, within the context of that same question, let me just

19     ask you one more thing:

20             In Pale municipality, there was a Crisis Staff, right, there --

21     you heard of its existence?

22        A.   I heard that there were Crisis Staffs everywhere, in all the

23     municipalities.

24             MR. ZECEVIC:  Just one intervention in the transcript.  It's

25     line 18.  I believe the witness's answer was:

Page 11926

 1             "Yes, at that moment, he did stay in that --" [Microphone not

 2     activated]

 3             I said:  "He did stay in that position."

 4             That is what I heard the witness say.

 5             MS. KORNER: [Microphone not activated] I agree.

 6             MR. CVIJETIC: [Interpretation]

 7        Q.   Let me take you back to a document that was shown to you

 8     yesterday.

 9             MR. CVIJETIC: [Interpretation] P650 is its number.  There we

10     have it.

11        Q.   Let me just jog your memory.  You saw the document yesterday.

12     This is a statement provided by a Muslim police officers -- officer about

13     their removal from Pale and -- and -- and their transfer to Sokolac.  You

14     do remember the document, don't you?

15             MR. CVIJETIC: [Interpretation] Can we go straight to the

16     following page in the same document.

17                           [Trial Chamber and Registrar confer]

18             MR. CVIJETIC: [Interpretation]

19        Q.   First of all, do you remember the document that was shown to you

20     yesterday?

21        A.   Yes, I do.

22        Q.   On page 2, you can see where reference is made in the second

23     paragraph from the bottom the decision of the Crisis Staff for all Muslim

24     policemen to hand in their weapons and the uniforms and equipment issued

25     to them.

Page 11927

 1             And further on it says that the chief of the public security

 2     station explained the reasons.  And that was a reciprocal measure for

 3     what had happened at the Stari Grad Public Security in Sarajevo.

 4             My question is this:  You owe an explanation to us from

 5     yesterday.  What had happened in Sarajevo in the public security station

 6     there, which provoked such a counter-measure, as it were?

 7        A.   I believe that at the beginning of the month much March, the Serb

 8     police officers in the Stari Grad Police Station in Stari -- in Sarajevo

 9     were no longer desirable, were no longer wanted in that police station.

10     They went to a place called Hresa.  In other words, there was a division.

11     A division took place.  They were no longer allowed to work there.  They

12     went to Hresa, a place called Hresa, which is close to Pale, and for a

13     while they were active there.  And then after some time they joined the

14     officers at the Pale station.

15        Q.   Are we talking about two municipalities that border on each

16     other, Stari Grad and Pale?

17        A.   Yes.

18        Q.   Thank you.

19             And as you have told us, both events took place in March of that

20     year?

21        A.   Yes.  For a while, the police officers from Stari Grad performed

22     their duties and tasks in the territory of that municipality, at the

23     check-point, at the entrance into Sarajevo on the main road.  They did

24     not perform their duties in Pale; that's what I'm saying.  They were

25     still there.

Page 11928

 1        Q.   Within the context of your statement about the Crisis Staff, you

 2     see that this was done pursuant to a decision of the Crisis Staff.

 3             My question is this; and it has to do with the local authorities,

 4     and I am referring to the Assembly, the Crisis Staff, and others:  To

 5     what extent did they have the power, the Crisis Staff and municipal

 6     authorities, to what extent did they have the power to influence events

 7     in -- in their areas at -- at the beginning?

 8        A.   I believe that those decisions had to be handed down from the

 9     highest political level, and they had to be implemented.  Having said

10     that, there are two different -- or three different lines.  There's

11     civilian authority, military authorities, and police authorities.

12        Q.   We see here that the police security station also had to

13     implement the decisions of the local authorities, like, for example, the

14     Crisis Staff or the Municipal Assembly if the decisions concerned the

15     activities of the public security station.

16        A.   I don't know.  I'm not sure of that.

17        Q.   Very well.  And now I'm going to move to another question, a

18     different question.  You told us that you had been involved in defence

19     preparations at one point in your career, and you said that Mr. Koroman

20     worked at a bank, that -- but that he was also involved in similar tasks,

21     in defence tasks.

22             Now just one general question:  How do you mean that?  How do you

23     know what he did, at the bank that he was involved in?  Defence

24     preparations and regulations with this regard?

25        A.   I heard it only later -- heard that he had graduated with a

Page 11929

 1     degree and that he was involved in those tasks.  It may not be correct,

 2     but that's what I heard.

 3        Q.   My question concerned the application of regulations concerning

 4     All People's Defence and civilian protection.  Do you know that all legal

 5     subjects in the former Yugoslavia had to be -- prepared for defence, that

 6     they had to have books of rules and things like that?

 7        A.   Yes.  I myself had friends who were assigned to perform those

 8     jobs and duties in different companies.

 9        Q.   Very well.  And now I'm going to show you another document also

10     shown to you yesterday, which is minutes from the 14th Session of the

11     Municipal Assembly of Pale.

12             MR. CVIJETIC: [Interpretation] It is 65 ter 2459.  I don't know

13     whether it was given a new number yesterday.  I apologise if it was.

14             Can we immediately go to the end of the document.  More

15     precisely, to bullet point 2.  I believe it's page 5 -- or actually, no,

16     one page before that.  Page 4 in the B/C/S version.  At bullet point 2.

17     And we will need the corresponding page in the English version.

18             Could somebody assist me with that?  Now we have it.

19        Q.   Yesterday you provided your comment upon the session in question.

20     I'm going to draw your attention to the part where it says:

21             "In order to water down the discussion ..."

22             Do you see the passage that starts with those words?

23        A.   Yes.

24        Q.   A Working Group was set up in order to deal with the problem of

25     immigration of Croats and Muslims and so on.  And so a forth Working

Page 11930

 1     Group was established and so on and so forth.

 2             My question is this:  Yesterday in answering Ms. Korner's

 3     questions, you said that you were not aware of the document about how

 4     Muslim citizens could change their place of residence and that was to be

 5     done at the public security station.  And now you can see that it does

 6     stem from a decision of the Assembly, because the Assembly did deal with

 7     the issue?

 8        A.   I never saw this.  I was not aware of that.

 9        Q.   Very well.  I'm going to ask you something from your profession.

10             Keeping records about the change of residence is one of the jobs

11     of police stations; right?

12        A.   Yes.

13        Q.   However, here, at the -- local body of authority orders the

14     public security station to deal with the issue of mass emigration or

15     change of residency of members of just one ethnic group, but you say you

16     were not aware of this decision, so we will not invite any more comments

17     from you.

18             Do you remember, since we're talking about emigration, that a

19     special MUP unit of the Socialist Republic of Bosnia-Herzegovina in 1991

20     and 1992 ill-treated Serbs in an action to seize weapons when the

21     Kezunovic house in that area was set on fire.

22             Do you remember that incident?

23             MS. KORNER:  Again, Your Honours, a slightly different point.

24     What is this -- what's the relevance of this other than tu quoque?  What

25     has, indeed, any of this got to do with -- with either this witness or

Page 11931

 1     anything?

 2             MR. CVIJETIC: [Interpretation] Well, I tried to answer -- ask the

 3     witness whether he knew anything, just to know whether he had any

 4     knowledge; and if he didn't, then I would have dropped the issue

 5     altogether.

 6             MS. KORNER:  It doesn't matter whether he has got any knowledge

 7     or not.  What's the relevance?

 8             JUDGE HALL:  Move on, Mr. Cvijetic.

 9             MR. CVIJETIC: [Interpretation] I'm moving on.

10        Q.   You answered questions with regard to keeping people confined in

11     the cinema hall, and you said that you are not aware of any details, that

12     you only have second-hand information that you learned subsequently.

13             Since you worked at the police, I can ask you this:  Keeping

14     people in the cinema hall, could this have -- provide from the documents

15     of the Crisis Staff and the Municipal Assembly, just like things were

16     done pursuant to the other two documents that I have just shown you?

17             MS. KORNER:  Anything could have happened.  This witness has

18     dealt with his knowledge.  Now, unless he knows, it's no good him

19     answering this question either because it's pure guess-work.

20             MR. CVIJETIC: [Interpretation]

21        Q.   Do you know anything about this or not?  Just tell us briefly,

22     yes or no.

23        A.   No.

24        Q.   You participated in the Renovica operation personally; right?

25        A.   [No interpretation]

Page 11932

 1        Q.   Could you just briefly explain how the two policemen got killed?

 2     They were policemen, were they not?  But just be brief, please.

 3        A.   I know how Goran [indiscernible] got killed.  He was in the same

 4     vehicle where I was, and he was in the same group that was supposed to go

 5     with me to that village.  As he was getting off the truck, shooting

 6     already started in Renovica, we were just a little before Renovica where

 7     we pulled -- when we pulled over.

 8             As we were getting off the truck, the first group got off and

 9     took the lower, the southern, path, and I got off and I jumped into a

10     trench on the upper path, together with a few colleagues.

11             As we were getting off the vehicle, there was shooting from all

12     sides from the mountains that surrounded us.  And at one point, at the

13     place where Goran left on the southern side, there was a piece of tin,

14     and you could hear the bullets, the sounds of bullets, on that piece of

15     tin.

16        Q.   I apologise, I did not want all those details.  I'm interested in

17     an agreement about the voluntarily surrender of weapons, had that been

18     reached, and how all that transpired.  Was there an ambush; were you

19     ambushed?

20             That was the gist of my question.

21        A.   That's what I was told, that there had been an agreement between

22     Malko Koroman and Alija Prazina, the president of the SDA.  But when we

23     went up there, we were caught unawares; whereas, the Muslims were

24     organised.

25        Q.   Very well.  Thank you.

Page 11933

 1             And it only remains for me to deal with your report.  That's

 2     65 ter 317.  There are some details that haven't been commented upon.

 3             MR. CVIJETIC: [Interpretation] Can we immediately turn to the

 4     following page of the report.  I need the fifth paragraph from the top.

 5     So in the English version, we also need the fifth.

 6        Q.   Sir, in this part of the report, you speak about a problem that

 7     arose due to the migration or the departure or the change of residence of

 8     this or that part of the population which was a result of the war.

 9             You will agree with me, won't you, that this made the security

10     situation on the ground more complex.  And it also gave rise to an

11     increase of inter-ethnic tension.  Am I right?

12        A.   Yes.

13        Q.   You even say here that in such a situation the staff the SJB

14     couldn't do much to prevent that.  Does that mean that you consider this

15     to be force majeure, that you couldn't -- upon which had you no

16     influence?

17        A.   Yes.  Because all the other relevant services had failed, and the

18     police itself couldn't do much.

19             MR. CVIJETIC: [Interpretation] Let us now go to, I believe,

20     page 4 in e-court.  And we'll need the third paragraph; could we please

21     zoom in on it.

22        Q.   Here you speak about a situation that, I suppose, was a general

23     problem.  Namely, that you weren't able to reach the injured party, but,

24     in spite of that, you drafted Official Notes and, thus, documented the

25     perpetration of such an offence.

Page 11934

 1             Is that the meaning of this paragraph?

 2        A.   Yes.

 3             MS. KORNER:  I'm so sorry, Your Honours.  I don't know which

 4     paragraph -- he says paragraph 4 in the B/C/S, but I'm not sure that the

 5     English is reflecting that.  Could we just ...

 6             Could you read out the beginning of the paragraph or tell us what

 7     page it is in English?  No ...

 8             MR. CVIJETIC: [Interpretation] The last paragraph of this page in

 9     the English translation; whereas, in the original, it's the third

10     paragraph from the top.

11             It starts with:

12             "In addition to ..." this number of criminal reports submitted.

13             MS. KORNER:  Okay.  Thank you.

14             MR. CVIJETIC: [Interpretation]

15        Q.   Witness, in this context, I just want to ask you:  No matter

16     whether the perpetrator was known or unknown, whether the injured party

17     is there or not, it was your duty under the law to document such a

18     criminal offence.  Am I right?

19        A.   Yes.

20        Q.   Is that what you did?

21        A.   Yes.

22             THE INTERPRETER:  Could unused microphones be switched off.

23             MR. CVIJETIC: [Interpretation]

24        Q.   With regard to the implementation of the regulations, did you

25     also receive instructions from the headquarters of the ministry to

Page 11935

 1     proceed that way.  Am I right?

 2        A.   I don't remember whether we were receiving any at the time.  But

 3     that was the procedure, so I don't remember whether we had special

 4     instructions to that effect.

 5        Q.   You will agree with me, then, that the first authority in your

 6     work was the law, so you didn't have to ask many questions in doing

 7     about your -- in going about your job; right?

 8        A.   Yes.

 9        Q.   Then the law doesn't distinguish between perpetrators based on

10     ethnicity, and the same applies to injured parties or victims.  So that

11     means that you had to treat all these the same way; right?

12        A.   Yes.  And that's how I treated them too.

13        Q.   I'm asking you this because in this report of yours, pointing out

14     the problems that you faced in the work of the police station, you

15     efficiently observed laziness and irresponsibility, even when the victims

16     are Serbs and the cases were not duly processed.  Am I right?

17        A.   Yes.

18        Q.   This duty of yours included the uncovering and documenting of

19     even the most serious criminal offences, such as war crimes.  I mean in

20     the sense that you didn't distinguish, depending on who the perpetrator

21     and the victim was, and it was your duty to process all this the same

22     way.  Am I right?

23        A.   Yes.

24        Q.   I'll show you a document, because I believe you mention it in

25     your statement, and that's the RZ form.

Page 11936

 1             MR. CVIJETIC: [Interpretation] Could we please see document 1D63.

 2             MS. KORNER: [Microphone not activated] ... tab number, please, in

 3     your documents.  Oh, I've got it.  That's all right.

 4             MR. CVIJETIC: [Interpretation] 11.

 5        Q.   Do look at this accompanying letter, before I show you the form,

 6     and the introductory part states what I have just said; in paragraph 2:

 7     That this is done in equal manner, irrespective of the ethnicity, being a

 8     Muslim, Croat.

 9             Do you see that?

10        A.   Yes.

11        Q.   Let's go to the next page so we can see the form.

12             MR. CVIJETIC: [Interpretation] We'll have to go further back.

13     Yes, this is the form.

14        Q.   Take a look at entries -- or lines 5 and 6.  They read "ethnicity

15     and religion."  This is blank, and it is expected that these data be

16     filled in on the spot, and that no distinction is made, depending on the

17     ethnicity of the person in question?

18             Do you agree with me?

19        A.   Yes, I do.

20        Q.   Witness, in your work, you said, I believe, that this is exactly

21     how you proceeded; correct?

22        A.   Yes.

23        Q.   Finally, sir, let me remind you something you said.  You said

24     that you had -- trusted your chief, Zoran Cvijetic, fully, and also the

25     minister, Mr. Stanisic.  What does that stem from?

Page 11937

 1        A.   Well, I didn't know Mr. Cvijetic before, but after the initial

 2     contact, and subsequently -- well, I don't know.  The man always was

 3     willing to see me and hear what I had to say.  And, well, I'm not saying

 4     that it was all up to him but possibly to his subordinates who were my

 5     superiors.

 6             I also knew Mr. Stanisic before.  I knew him very well.  And we

 7     were on good terms when he worked at the city SUP and then went to the

 8     economy and then came back to the city SUP.

 9        Q.   Do you trust him now?

10        A.   Well, I don't know how to put it.  Do I or don't I trust him?  I

11     am really offended by [as interpreted] a human being because of what

12     happened to me.  I don't hate him because I don't hate people, generally

13     speaking.  But now, well, my attitude has changed.

14        Q.   All right.  I'm going to ask you something else.

15             Do you know about the meeting of the executives in the crime

16     investigation area from the CSB of Romanija-Biska [phoen], which was

17     attended by the SJB Pale representative?

18             I'll show you the report to jog your memory.

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 11938

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8             MR. CVIJETIC: [Interpretation] I will not mention the witness.

 9     This document is about a meeting that dealt with problems at Pale.

10             But since it's time for the break now, I can accept your

11     suggestion that we should go into private session and -- in order to

12     protect the witness's identity.

13             JUDGE HALL:  Yes.  When we return.

14                           [Trial Chamber and Registrar confer]

15             JUDGE HALL:  So we take the break.

16                           [The witness stands down]

17                           --- Recess taken at 12.07 p.m.

18                           --- On resuming at 12.30 p.m.

19                           [The witness takes the stand]

20                           [Defence counsel confer]

21             JUDGE HALL:  Yes, Mr. Cvijetic, please proceed.

22             MR. CVIJETIC: [Interpretation] Thank you.

23             Before the break, I called up a document.  Could it be returned.

24     65 ter 1273.

25        Q.   In the middle of that document or in the middle of page one,

Page 11939

 1     Mr. Tusevljak points to certain objective difficulties in the work of the

 2     crime services of all centres, not only in Pale.  There's a lack of

 3     technical equipment, there's no communication between the SJB and the

 4     CSB, lack of personnel in numerous SJBs, and so on and so forth.

 5             You can see it for yourself, if you look at the screen.

 6             Do you see it?

 7        A.   Yes.

 8        Q.   Tell me, did you have some, if not all, of the problems in your

 9     work in Pale?

10             THE INTERPRETER:  Could the witness please repeat the answer.

11             MR. CVIJETIC: [Interpretation]

12        Q.   I apologise, your answer was not recorded.  Could you please

13     repeat it.

14        A.   Yes, we had the same problems.

15             MR. CVIJETIC: [Interpretation] Could we please go to the

16     following page in the B/C/S version.  I'm interested in the last

17     paragraph.

18             In the English version, it will probably be page 3.

19     Nikolic Radomir was the next speaker.  In the English version, I believe

20     we have to go to the following page; the one after this.

21             MS. KORNER: [Microphone not activated]

22             MR. CVIJETIC: [Interpretation] That's it.

23        Q.   On both pages there - it is the last paragraph - your colleague

24     from Ilidza points to the problem of the report of the damaged party in

25     cases, they experience a burglary or a theft, and the service having

Page 11940

 1     problems with finalising a criminal report.

 2             Did you have similar problems?

 3        A.   Yes.

 4        Q.   In my question, there's something lacking.  "When it comes to

 5     injured parties who are Muslims."  Can this be added?

 6             And when you said "Yes," you had in mind the same situation, when

 7     the injured parties were Muslims and there were no reports or no

 8     documents, you had a problem in finalising your criminal report and

 9     forwarding it to the prosecutor.  Wasn't that the case?

10        A.   Yes.

11        Q.   And now I don't want to dwell upon this document because all of

12     your colleagues pointed out their own problems, but I would like to move

13     on to the last page with the conclusions.

14             MR. CVIJETIC: [Interpretation] Could we move to the last page in

15     the document, please.  In B/C/S version, it's page 5.  Actually, on the

16     last page with the conclusion.

17        Q.   Could you please look at the conclusions, and we will probably

18     provide just a brief comment upon all -- upon them.

19             Did you read the conclusions, please?

20             From what you have told us already, it seems that you pointed to

21     the most part of the conclusions in your written documents and letters

22     about the problems in your work.  Am I right.

23        A.   Yes.

24        Q.   I still need to ask you this:  Did you have any problems in

25     communicating with the centre?  Because a reference is made here to the

Page 11941

 1     lack of communications and lack of telephone lines and things like that.

 2             Did you experience the same problem in Pale?

 3        A.   Yes.

 4        Q.   And, finally, as can you see under 6:

 5             "Maximal engagement of all the operational workers is required

 6     for the tasks of documenting war crimes, and the injured parties and

 7     perpetrators are not segregated in terms of their ethnicity."

 8             Am I right?

 9        A.   Yes.

10             MR. CVIJETIC: [Interpretation] Your Honours, since this document

11     has not been admitted and there are no objections, I would like to tender

12     the report -- or, rather, the minutes of the meetings of officials in

13     charge of the line of the witness's work be admitted into evidence.

14             JUDGE HARHOFF:  Before we take a position on that, Mr. Cvijetic,

15     could we inquire from the witness the information contained in point 2 of

16     the conclusions.  Because my question is, to the witness, whether this

17     was actually functioning in practice.

18             In other words, were the CSB and the SJBs able to bring

19     information back and forth on every Saturday, as it is proposed in the

20     conclusion?  Do you know?

21             THE WITNESS: [Interpretation] I remember that I took our official

22     car to attend meetings on Saturdays, meetings where we discussed such

23     problems.  And on other days as well, whenever a need arose, because

24     there was hardly any other way to communicate.

25             JUDGE HARHOFF:  So if I understand you correctly, Mr. Witness, at

Page 11942

 1     least once a week, on Saturdays, you were able to exchange information

 2     between the CSB and the SJB?

 3             THE WITNESS: [Interpretation] I don't remember whether that

 4     happened every Saturday, but it was frequently.

 5             JUDGE HARHOFF:  And do you recall how many SJBs were present in

 6     those meetings with the CSB?  Just roughly, if you can.

 7             THE WITNESS: [Interpretation] Some couldn't attend.  It all

 8     depended on the conditions on the roads.  It was not easy to get from

 9     Ilidza, sometimes even impossible.  But most of us were there.  We always

10     had a majority present.

11             JUDGE HARHOFF:  Can you name some of the SJBs who were normally

12     present in those meetings?

13             THE WITNESS: [Interpretation] People came from Sokolac.  I came

14     from Pale.  People came from Han Pijesak as well.  Ilidza and Rajlovac

15     attended as well but not regularly because of the problems on the road,

16     but they did come.  I'm not sure about Zvornik; I don't know whether they

17     attended.  Zvornik, Milici, Sekovici, Skelani, Vlasenica; I'm not sure

18     whether anybody came.  Because I know that there were meetings in those

19     areas with their respective heads of crime prevention and detection

20     services.

21             JUDGE HARHOFF:  Thank you, Mr. Witness.

22             JUDGE HALL:  Admitted and marked.

23             THE REGISTRAR:  The document will become Exhibit 1D328,

24     Your Honours.

25             MR. CVIJETIC: [Interpretation]

Page 11943

 1        Q.   And finally, I believe that Ms. Korner drew our attention to the

 2     fact that we did not provide precise explanation as to the pensionable

 3     years and how they were combined.  I'll try to put a very precise

 4     question to you, and let's help the Trial Chamber understand what

 5     happened.

 6             When the employees of the former MUP of the Republic of

 7     Bosnia and Herzegovina who were of Serb ethnicity moved to Pale, most of

 8     them did not join that service on the 1st of April.  They joined later.

 9     However, in their decisions on appointment, the 1st of April is indicated

10     as the day when they started working in the Ministry of the Interior of

11     Republika Srpska.  I have just put things to you, and let me say that

12     this was done in order for them to have the pensionable years in the

13     former MUP of Bosnia and Herzegovina with the pensionable years in their

14     next job, to avoid a 15-day gap which would have reduced their pension

15     prospects.

16             Was my explanation good?

17        A.   I suppose that that was kept in mind.  I know that, for myself,

18     that the period from the 1st to 6th was not recognised as pensionable

19     years because I was still on the record in Sarajevo where I remained

20     working until the 6th of April.  From the 6th of April, I started working

21     in the MUP of Republika Srpska; that's when I formally joined.

22        Q.   You will agree with me that that was in the interests of all of

23     us, of all of you MUP members that might have suffered from the temporal

24     gap in the pensionable years?

25        A.   I don't know.  I can't confirm that.  For me, the war started on

Page 11944

 1     the weekend of the 5th.  And as of the 6th, I could no longer go back to

 2     my apartment.  So I don't know whether the MUP of Republika Srpska

 3     started working on the 1st.  I don't know.  I -- I don't know that.

 4        Q.   Very well.  Thank you.  In your case, there could not have been

 5     overlapping, in terms of those six days.  Those six days could be

 6     recognised only in one place:  Either in the MUP of Bosnia-Herzegovina or

 7     the MUP of Republika Srpska.  So there was no way that that period could

 8     have been duplicated, so things were done properly in your case?

 9        A.   Yes.

10        Q.   Thank you very much.  I have no further questions for the

11     witness.

12             MR. CVIJETIC: [Interpretation] Thank you, Your Honours.

13             JUDGE HALL:  Is the position of the Zupljanin Defence as was

14     previously indicated, that they don't intend to cross-examine this

15     witness?

16             MR. KRGOVIC:  Yes, Your Honour, we don't have questions for this

17     witness.

18             JUDGE HALL:  Thank you.

19             Re-examination?

20             MS. KORNER:  I've just got one question, Your Honours.

21                           Re-examination by Ms. Korner:

22        Q.   Sir, where exactly was the CSB Sarajevo for the Serbian Republic

23     based?

24        A.   It was based in Lukavica, in -- in a factory; the factory was

25     Energoinvest.  That was in one part of Sarajevo which was under the Serb

Page 11945

 1     control.

 2        Q.   And roughly how far was that from Pale?

 3        A.   Roughly, perhaps, 20 kilometres.  But it was not easy to get from

 4     one place to the other.

 5        Q.   In Pale, however, as far as communications were concerned, if

 6     necessary, did you have access to the government communications?

 7        A.   I don't know.  I didn't know that.  I had no contacts with the

 8     government, so I wouldn't know.

 9        Q.   Did you, in fact, have someone at Pale SJB whose job it was to

10     deal with communications?

11        A.   Well, there were two police officers there.  We saw them on one

12     of those lists that you showed me.  And their job was encryption.  But

13     those were special communications.  They were in charge of

14     communications.  But, as I said, those were special lines of

15     communication.

16        Q.   All right.  Thank you.  And, finally, in respect of your reports

17     to the CSB, in particular, the ones we looked at which contained the

18     complaints, how were they sent?  Did you deliver them personally, or were

19     they sent via the dispatch system?

20        A.   What we saw was delivered by me personally.  If it had gone along

21     the lines of hierarchy, Chief Koroman would have had to see it.  But, in

22     that case, it wouldn't have been dispatched.  So I gave it to

23     Chief Cvijetic on the occasion of those meetings that we mentioned a

24     short while ago.

25        Q.   Yes.  Thank you very much, sir.  I've got no further questions.

Page 11946

 1             JUDGE HARHOFF:  Mr. Witness, could I put to you just one

 2     follow-up question in relation to the meetings that we talked about just

 3     a while ago between the CSB and the SJBs.

 4                           Questioned by the Court:

 5             JUDGE HARHOFF:  First of all, did the meetings take place in

 6     Lukavica?

 7        A.   Some meetings were held in Lukavica, for those who were near and

 8     able to come.  But I remember meetings at Han Pijesak, for that region.

 9     And where I was, at Pale, I was -- I went to a meeting to Milici.  That

10     was also far away.  But the rest of them were at Lukavica.

11             JUDGE HARHOFF:  Thank you.  And at those meetings, were the MUP

12     also represented, or was it just the CSB who, sort of, chaired the

13     meetings?

14             MS. KORNER:  Sorry, does Your Honour mean MUP

15     headquarters -- [Overlapping speakers] ...

16             JUDGE HARHOFF:  Oh, so sorry.  Yes.  Yes, from the ministry, MUP

17     headquarters.

18        A.   Yes.  As far as I remember, somebody was always present.

19             JUDGE HARHOFF:  Do you remember who?

20        A.   Well, I remember Investigator Ratko Kapetanovic.  Goran Macar was

21     also there; he was the chief of the crime investigation service.  I don't

22     remember any others.

23             JUDGE HARHOFF:  Was it your impression that the representative

24     from the minister would report back to the ministry and bring back the

25     information that he had picked up at the meetings?

Page 11947

 1        A.   That's how it was supposed to function; that was the logic.  The

 2     minister, through his services, along the lines of work, was supposed to

 3     be informed of all problems.  Whether that was, indeed, the case, whether

 4     that really functioned that way, I don't know.

 5             JUDGE HARHOFF:  And did the representative from the ministry

 6     offer information to the participants in the meetings with the CSB and

 7     the SJBs?

 8        A.   I can't recall now to what extent they participated.  But I know

 9     that all of us discussed some problems.  Of course, some of us had more

10     problems; some -- others had fewer, depending from where they were.

11     However, it was -- although it was good to talk, the problem was that the

12     situation on the ground didn't really change.  Why, whether for objective

13     or subjective reasons, is another matter.

14             I could not have films developed because there was no lab.  I had

15     to ask a private photographer to come to a room and do that for me.  It

16     was a -- a private request from me to him.

17             JUDGE HARHOFF:  I see.  My question was merely to -- to discover

18     if the representative from the ministry was able to provide instructions

19     or information from the ministry to the participants in those meetings so

20     as to ensure that whatever decisions were made at the central level in

21     the ministry would be communicated down to the CSBs, and, from there, to

22     the SJBs.

23             So that's why I asked you if the representative did take the

24     floor and -- and provide you with information from central headquarters.

25        A.   Yes, he did take the floor.  And that's how we got some

Page 11948

 1     information.  But, otherwise, it was communicated to the chief of any

 2     station, and the station would inform us, depending on the line of

 3     service we were in, about what we were supposed to do and how we were

 4     to -- supposed to behave.

 5             For example, the movable property:  That was a matter that was

 6     with a government decree, outlining what was to be done and how; so there

 7     couldn't be any anarchy in which anybody could do what they deemed right.

 8             JUDGE HARHOFF:  Thank you, sir.  That's all I have to ask.

 9             MR. ZECEVIC:  I'm sorry, Your Honours, again, an intervention in

10     the transcript:  66/5.  On Your Honours' question, the witness was

11     mentioning something about the instructions, and that wasn't recorded.  I

12     don't know if that was translated at all.  Maybe ... maybe can he --

13             JUDGE HARHOFF:  Mr. Witness, could you please repeat the last

14     part of your answer to me.

15        A.   We had some instructions in the form of documents received from

16     the Ministry about how we should work.  It was all in accordance with the

17     law.  These documents only explained how certain matters were to be dealt

18     with most easily.  And also, it was also about the implementation of

19     other rules and regulations as well as decrees.  There was this very

20     important decree, namely, the government decree about the treatment of

21     the spoils of war; and that was mostly about immovable property that was

22     left in the area, abandoned and what have you.

23             JUDGE HALL:  We thank you, sir, for your assistance to the

24     Tribunal.  And you are now released as a witness.  And we wish you have a

25     safe journey back to your home.

Page 11949

 1             THE WITNESS: [Interpretation] Thank you.

 2             JUDGE HALL:  I don't know if there are any housekeeping matters

 3     that need delay us, because, if so, the usher can wait until we rise to

 4     escort the witness from the courtroom.

 5             MS. KORNER:  Yes.  No, there aren't, Your Honours.  Except

 6     that - it's the same situation - the estimates for the Defence are -- are

 7     slightly excessive at the moment, and we haven't got a witness here for

 8     tomorrow because the estimate was four hours, I believe, from Stanisic,

 9     and there was also something in for the Defence of Zupljanin.

10             I know it's difficult.  And we normally run over what we say.

11     But I think, rather than having days off which haven't been organised, as

12     it were, this is one that Your Honours will and we will have to have, it

13     might be an idea if, after the Defence have given their original

14     estimates, which we've asked for so we can start planning, if those

15     estimates change, they could let us know so we can bring up more

16     witnesses.

17             Clearly, we're anxious to move this case on, as Your Honours are,

18     as quickly as possible.

19             MR. ZECEVIC:  If I may respond.  Your Honours, we under fully the

20     situation, but when we have a viva voce witness, the only indication for

21     us is the length of direct examination because at that point we do not

22     know which of the documents will the -- will -- will the Office of the

23     Prosecutor use with the witness.

24             So in order to be on the safe side, we have to give the

25     estimates.  Only when we hear the witness and the documents are presented

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 1     to him can we only then say -- that is -- that is the first point in time

 2     when we can really give a roughly estimate which -- which we are going to

 3     actually keep.

 4             I hope you understand our position.  I -- I'm sure Ms. Korner

 5     does.

 6             Thank you.

 7             JUDGE HALL:  The -- the -- whereas, I suppose, everybody is

 8     frustrated by these dies nons, if we look at the -- what has happened

 9     over the past several months, an occasion like today is really

10     exceptional.  So the Chamber is not yet alarmed by overestimates or -- or

11     overbooking of time, as it were, by the Defence.  But if it -- if, as we

12     progress, it appears to be a problem, then we would invite counsel to

13     look again at the way that they -- they do these things.

14             So we take the adjournment, to reconvene in this courtroom on

15     Monday -- Monday morning.  And I trust everyone has a safe weekend.

16                           [The witness withdrew]

17                            --- Whereupon the hearing adjourned at 1.03 p.m.,

18                           to be reconvened on Monday, the 21st day

19                           of June, 2010, at 9.00 a.m.