1 Wednesday, 30 June 2010
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.08 a.m.
5 THE REGISTRAR: Good morning, Your Honours.
6 This is case IT-08-91-T, the Prosecutor versus Mico Stanisic and
7 Stojan Zupljanin.
8 JUDGE HALL: Thank you, Madam Registrar.
9 Good morning to everyone.
10 May we have the appearances for today, please.
11 MR. DEMIRDJIAN: Good morning, Your Honours.
12 Alex Demirdjian on behalf of the Prosecutor, with Senior Trial
13 Attorney Tom Hannis and our Case Manager Mr. Crispian Smith.
14 JUDGE HALL: Thank you.
15 MR. ZECEVIC: Good morning, Your Honours.
16 Slobodan Zecevic, Eugene O'Sullivan appearing for Stanisic
17 Defence this morning. Thank you.
18 MR. KRGOVIC: Good morning, Your Honours.
19 Dragan Krgovic for Zupljanin Defence.
20 JUDGE HALL: Thank you.
21 [The witness takes the stand]
22 JUDGE HALL: Good morning to you, sir. Before Mr. Demirdjian
23 resumes his examination-in-chief, I remind you you're still on your oath.
24 WITNESS: DRAGAN RALJIC [Resumed]
25 [Witness answered through interpreter]
1 JUDGE HALL: Yes, Mr. Demirdjian.
2 MR. DEMIRDJIAN: Thank you, Your Honours.
3 Just before I resume with my questions, a little correction for
4 the transcript: Yesterday at page 12394, line 8, we were talking about
5 uniforms, and it was registered as "SNB uniforms." That's wrong. It's
6 "SMB," M as in Mary. That's how it should be recorded, and that's the
7 camouflage -- the olive-grey uniform.
8 Examination by Mr. Demirdjian: [Continued]
9 Q. Good morning, Mr. Raljic.
10 A. Good morning.
11 Q. I'd like to talk about the communication devices available to the
12 various units present in Kotor Varos. And yesterday you mentioned to us
13 one group which was Ljuban Ecim's special police that was present in
14 Kotor Varos. To your knowledge, how would they communicate with their
16 A. As far as I know, they only had hand-held radio stations. Which
17 model, I cannot say. Whether it was Motorola or something else, I really
18 wouldn't know. But they were hand-held radio stations for VHF
20 Q. And do you know if they ever used the communications system at
21 the SJB?
22 A. Generally speaking, they would use the phone line when it was
23 functional, but that unit was not in a position to use that communication
24 system. If they worked on simplex communications, they would use their
25 hand-held radio stations. And as far as I know, that was their basic
1 means of communication, or their main means of communications.
2 Q. And were you present -- were you ever present when they made a
3 call from the police station?
4 A. I cannot say for certain.
5 Q. Okay. You told us that they would use the phone lines when it
6 was functional. Which phone line would they use, and which part of the
7 SJB building would they go to use the phone line?
8 A. As far as I remember, it was mostly at the duty officer's office.
9 They had their phone lines. And that room was in the -- on the ground
10 floor, very close to the entrance into the building.
11 Q. Now, I'd like to move to the subordinated units of the SJB. I
12 believe there were smaller police stations in the municipality. Could
13 you tell us how they communicated with the SJB?
14 A. As far as I remember, they weren't police stations, really; they
15 were station departments. We had one at Siprage, but that was closed
16 down. And there was a smaller department at Maslovare and another at
18 As for communicating with them, if the repeater was functional,
19 or, in other words when there was electrical power, we could use
20 semi-duplex through the repeater and we could establish communications
21 with Vrbanjci and Maslovare, but it was a problem to establish
22 communications with Siprage because that place was some 30 kilometres
23 away from Kotor Varos and the -- the terrain didn't allow for
24 establishment of VHF communication with them. So we couldn't communicate
25 with the station department of the police at Siprage.
1 Q. And to your knowledge, would these smaller stations send reports
2 to the police -- to the SJB?
3 A. Oral reports were not sent by radio communication. They also
4 couldn't send dispatches. Whether or not written reports, that is,
5 typewritten reports were made and subsequently transmitted, I wouldn't
7 Q. And, ultimately, how did you communicate with substations such as
8 Siprage, where you told us that for a period of time you couldn't
9 communicate with them? What would be the best way to communicate with
11 A. As far as I know, the only way was going there in person. That
12 is, sit in a car and driving there. That was the only way. Occasionally
13 maybe, with the weather conditions permitting, we were sometimes able to
14 establish communication with Siprage, but the quality of the
15 communication was very poor.
16 Q. Now, you mentioned the repeater. Where was the repeater located?
17 A. It was on Mount Obodnik. That's some 12 or 13 kilometres from
18 Kotor Varos, in the direction of Maslovare.
19 Q. And who controlled the area around Mount Obodnik?
20 A. I don't know which area you mean. You mean the immediate
21 vicinity around the repeater or the wider area?
22 Q. The immediate vicinity around the repeater.
23 A. Nobody actually secured that.
24 Q. And that area was -- around Mount Obodnik, who would main -- who
25 was responsible for the maintenance of the repeater?
1 A. If there was something that must be repaired, there were the guys
2 from the encryption department, encryption and maintenance department,
3 from Banja Luka. They had an organisational unit in charge of system
5 Q. And to your knowledge, in 1992, was that repeater ever damaged?
6 A. The repeater often didn't work. It had -- it needed 220 volts to
7 function, but I don't remember anyone going there for repairing anything
8 in 1992. I really don't remember.
9 Q. And just so we're clear on this, the repeater was used for what
10 type of communications exactly?
11 A. It was used for the same kind of communication as the hand-held
12 radio stations when you work on simplex. When you work in simplex, there
13 is a direct communication between two parties. Whereas, the repeater is
14 actually an intermediary means of communication between the two parties,
15 so we used the repeater when we wanted to establish communication between
16 two points that were further away.
17 Q. Now, you told us that under normal conditions you would use the
18 repeater to communicate with Siprage, which was about 30 kilometres away.
19 And you told us that Banja Luka was also 30 kilometres away. So under
20 normal conditions, would you be able to establish communications between
21 Banja Luka and Kotor Varos with this mean of communication?
22 A. No, I didn't say that under normal conditions we were able to
23 communicate with Siprage because we couldn't, by means of that repeater.
24 But under specific conditions, because radio waves are very particular,
25 depending on ionisation and the ionosphere and so on, so when the
1 conditions were favourable, we, on rare occasions, were able to
2 communicate with Siprage; that's what I said. But we couldn't connect
3 with Banja Luka through that repeater because it's also some
4 30 kilometres away from Kotor Varos. But the Obodnik repeater is in the
5 opposite direction, which means some 43 or 44 kilometres from Banja Luka.
6 That was not a network through which we would communicate with
7 Banja Luka.
8 Q. Within the municipality of Kotor Varos itself, we have come to
9 learn that there were various detention centres after the 11th of June.
10 I'd like to ask you, first of all --
11 JUDGE HARHOFF: Mr. Demirdjian, before we change the subject,
12 could we just explore with the witness what the situation was when there
13 was a power cut. I think you touched on it yesterday, but since we are
14 now speaking about the repeaters --
15 MR. DEMIRDJIAN: Yes.
16 JUDGE HARHOFF: -- and I think that Mr. Raljic already mentioned
17 that sometimes the repeater didn't work, because they were out of power.
18 How often did that happen, and what did they do when the power
20 MR. DEMIRDJIAN: Yes. Yes, Your Honours.
21 Q. Mr. Raljic, you heard Judge Harhoff's question. What would
22 happen when the repeater was off? What would you do? First of all,
23 maybe a first question: Would there be an attempt to fix the repeater?
24 A. That wouldn't be considered a failure of the repeater. There is
25 no need to go out there and repair anything because there isn't anything
1 to repair. As I said, the repeater needed 220 volts AC to function.
2 When there was a power failure, the repeater would switch off and we
3 couldn't establish communication.
4 Q. And what was the alternative to using the repeater? If you
5 wanted to communicate, let's say, with Banja Luka, what was left for you
6 in the police station?
7 A. As I said, we didn't communicate with Banja Luka through that
8 repeater. We were able to communicate with Vrbanjci and Maslovare
9 because these places are some 10 to 20 kilometres from Kotor Varos and
10 the repeater is between Vrbanjci and Maslovare. So it was used mostly
11 for communicating with these two branch police stations. The alternative
12 was to sit in a car and drive to Maslovare or Vrbanjci if needed.
13 Q. I'd like to clarify something in relation to the communications
14 with Siprage. You remember, when you arrived on Sunday, we gave you the
15 opportunity to listen to the audio tapes of your interview in, in 2007.
16 Do you recall that?
17 A. Yes, we spoke about that.
18 Q. And the following day you had some corrections to make to that
19 interview, or some clarifications; correct?
20 A. Yes, correct.
21 Q. And you told us that the rest of the interview was quite
23 A. Well, yes. I listened to about 80 per cent of the recording,
24 which means I didn't listen to all of it.
25 Q. Do you remember the part of the interview where communications
1 with Siprage was discussed, and this was towards the end of the
2 interview, and you were discussing a macro network?
3 A. I remember that we spoke about that.
4 Q. And during the interview, do you remember telling us that you
5 used this network mainly to communicate with Siprage which was
6 30 kilometres away from Kotor Varos?
7 A. Well, yes, that's what I said, but I didn't say that we were
8 constantly able to communicate that way. Only with weather permitting,
9 as I have just explained. Then we would be able to communicate with
10 Siprage. But not otherwise. That's why I said that we communicated with
11 Siprage that way because there was no other alternative.
12 Q. And at the end of your answer you also said that you could
13 establish communication through CSB Banja Luka. Maybe there is a
14 misunderstanding here of what network you used, because you were talking
15 about a macro network to communicate with Siprage. And then you said, We
16 could also establish communication with CSB Banja Luka.
17 Could you clarify that for the Trial Chamber, please?
18 A. Yes, of course, sir. There was another frequency that could be
19 used for communicating with the CSB and that was the macro network, the
20 largest network that we could use. But the repeater was not on Obodnik,
21 it was on Mount Kozara; we didn't speak about that. And that repeater
22 either worked on channel 44 or channel 60. I'm not sure. And that's how
23 we could communicate with Banja Luka, but not through the Obodnik
24 repeater. That's the difference.
25 MR. DEMIRDJIAN: Your Honours, does that clarify or ...
1 JUDGE HARHOFF: Yes. Except one little thing; namely, in the
2 months between April and September 1992, roughly speaking, how often did
3 you experience power cuts?
4 THE WITNESS: [Interpretation] On average, daily. Sometimes we
5 would have electricity for five or ten days, but on other occasions there
6 would be failures five to ten times a day. There were power failures all
7 the time. I don't really remember a period of ten to 15 days with
8 electricity. And speaking about the period from the 11th of June on.
9 And in April and May, there were also power failures but not as often as
11 JUDGE HARHOFF: Do you recall by any chance the longest period
12 that you experienced without any power at all? In other words, how long
13 would the power cuts normally last?
14 THE WITNESS: [Interpretation] I think up to ten days. Because
15 even the batteries would die that were used for feeding the VHF radio
16 stations in the duty officer's room, and those batteries were strong
17 enough for four to five days. Then we would take the battery to the
18 adjacent where building where the military was and we would charge the
19 battery using their generator so that we could use the battery again
20 for -- to feed the radio stations.
21 So the longest period was up to ten days.
22 JUDGE HARHOFF: Thank you.
23 MR. DEMIRDJIAN: Thank you, Your Honours.
24 Q. Mr. Raljic, I would like to turn to the topic of the
25 communications that were available at the various detention centres in
1 the municipality of Kotor Varos. And it is an established fact in this
2 case that there were detention centres.
3 Can you tell us what communication means were available there?
4 And perhaps, when discussing it, if you can specify which detention
5 centres you're talking about.
6 MR. ZECEVIC: Well, Your Honours, I believe my learned friend
7 should establish first the knowledge of this witness concerning the
8 detention centres and only then ask the -- the question along these
10 MR. DEMIRDJIAN: That's fine. Fair enough.
11 MR. ZECEVIC: Because it was my understanding that you wanted to
12 establish that at the very beginning and then His Honour Judge Harhoff
13 posed a question.
14 MR. DEMIRDJIAN: All right. Fine.
15 Q. Mr. Raljic, you heard the question. Were you aware of the
16 existence of detention centres in Kotor Varos?
17 A. Well, I am not really familiar with the terminology. I cannot
18 really tell whether it -- what there was -- can be called a detention
19 centre or something else. But passing by the primary school or, rather,
20 the gymnasium of the primary school, I saw a group of civilians, up to
21 100 persons, who were standing there. I don't know what they were doing
22 or who had brought them there.
23 We spoke about the building behind the pharmacy and some people
24 were detained there. But I never saw them; they were behind closed
25 doors. And that's what I know about that. I mean, first hand.
1 Q. And to your knowledge, who was guarding these various locations?
2 A. I don't know who the guards were. Around the primary school,
3 there were many people wearing different uniforms because the triangle
4 that -- that's made up of the prime school the police station and the
5 university building as it was called, held by the military, are in a
6 circle of 50 metres [Realtime transcript read in error "kilometres"] in
7 diameter. There were many soldiers there those days in olive-drab
8 uniforms and camouflage uniforms. There was police, special police.
9 Many people. And by the entrance, and there's a hallway between the
10 primary school building and the gymnasium the one through which I went, I
11 think that there was a young man wearing an olive-drab uniform standing
12 by the entrance. But whether or not he was a guard, I cannot say for
14 MR. DEMIRDJIAN: At page 10, line 17, the witness said
15 "50 metres," and it is recorded as "50 kilometres" in diameter.
16 Q. To your knowledge -- now, you said there was all these various
17 people guarding these locations, now, to your knowledge, was anyone using
18 any device from the SJB at these locations to communicate with the police
20 A. Yes, I said that various people moved about in the triangle
21 between these buildings. But I don't know that anybody used means of
22 communication from our station there.
23 Q. And were there -- well, let me raise it this way.
24 If have you -- if you have a patrol on the ground, what kind of
25 communications means do they have?
1 A. Police patrols, if they went out on the beat, they would merely
2 have hand-held radio stations, nothing else.
3 Q. And you told us yesterday that in the police chief's office he
4 had a fax machine, a telephone line, and a hand-held radio. Would he be
5 able to communicate with his hand-held radio to the police patrol on the
6 ground who had a hand-held radio?
7 A. Yes. As long as we're talking about the town itself.
8 Q. Now, in the town itself, were you aware whether any member of the
9 state security was present in Kotor Varos?
10 A. As far as I remember, I would sometimes meet Zdravko Peic, and I
11 think that he was a state security man.
12 Q. Was he stationed in Kotor Varos?
13 A. No. He travelled from Banja Luka to Kotor Varos by car, as far
14 as I know. Because, at the time, Zdravko lived in Banja Luka. I believe
15 that he had an apartment there. But he hails from Kotor Varos.
16 Q. And to your knowledge, how often would he come to Kotor Varos
17 from Banja Luka by car?
18 A. I cannot say with any degree of certainty, but I would see him
19 maybe once a week or twice a week, depending on which period we're
20 referring to.
21 Q. Referring to a period after the takeover, the 11th of June, 1992,
22 until the end of the year. How often would you see him in Kotor Varos?
23 A. Well, I meant that period, but what I -- what I had in mind was
24 whether we're talking about July or August or September or -- or any
25 other time, until the end of the year. I -- sometimes I would meet him
1 more often, sometimes less often.
2 Q. And to your knowledge, how would he communicate -- or was there
3 ever a need to communicate with Banja Luka; and, if so, how would he
5 A. If he wanted to communicate in that way, he would call us on the
6 phone, if the phone lines were functional.
7 Q. I'd like to move to another topic --
8 MR. DEMIRDJIAN: Yes.
9 MR. ZECEVIC: I'm really sorry. 12, line 13, I don't think it
10 was recorded as witness said. I believe the witness said that he would
11 come to them and use the telephone if the telephone line was -- I don't
12 know if it's important for you.
13 MR. DEMIRDJIAN:
14 Q. Mr. Raljic, if you would like to repeat your answer, how would
15 Mr. Peic communicate with Banja Luka, if he needed to? Just for the
17 A. Well, yes, if he needed to, he would drop by and use the phone,
18 if the phone was functional, because of the frequent power failures.
19 Q. Next topic. Your chief, Mr. Savo Tepic, was responsible to the
20 CSB Banja Luka chief, Mr. Zupljanin. To your knowledge, did
21 Mr. Zupljanin visit or inspect the SJB in 1992?
22 A. As far as I remember, Mr. Zupljanin, at sometime in the spring of
23 1992, did come. I think I saw him once in front of the SJB. And after
24 the 11th of June, he may have been there, but I didn't see him.
25 Q. To your knowledge, if he came to the SJB, would he have meetings
1 in the SJB with the police chief?
2 A. If he came to the SJB, it was logical for him to meet with the
3 chief of the SJB. But if they really met at the SJB, I don't know. As I
4 said, I didn't see him there.
5 Q. To your knowledge, what was the relationship between Mr. Tepic
6 and his superior, Mr. Zupljanin?
7 A. As far as I know, because I drove the chief to Banja Luka to
8 meetings in the previous period rather often, I know that they had good
9 relations as professionals, but I believe that also they were in good
10 relations personally.
11 Q. And to your knowledge, did Mr. Tepic follow his boss's orders?
12 MR. KRGOVIC: Your Honour, the witness said it -- well, first of
13 all, which period of time is covered by. And I think it's calling for
15 MR. DEMIRDJIAN: The question is to his knowledge, from what he
17 JUDGE HALL: I see Mr. Krgovic's -- the reason for his objection.
18 But I suppose the witness could attempt to answer the question, but I --
19 MR. DEMIRDJIAN: Maybe if I can rephrase it then.
20 Q. Mr. Raljic, being in the communications department yourself,
21 during the year 1992, you were receiving dispatches from CSB Banja Luka;
22 is that right?
23 A. Yes.
24 Q. You told us you forwarded those dispatches to Mr. Tepic, your
1 A. Yes, that's right.
2 Q. From what you observed, did Mr. Tepic implement those orders or
3 those dispatches that were coming in?
4 A. I can only say that Chief Tepic was a professional and that he
5 acted in coordination with subordination in the Ministry of the Interior.
6 Now whether he specifically carried out certain orders or not, it was not
7 my task to know that. But I was never issued an order by Chief Tepic
8 which had to do with any specific dispatch, so I wouldn't know that.
9 Q. And was there ever a situation, to your knowledge, where
10 Mr. Tepic did not follow orders?
11 JUDGE HALL: Again, isn't this -- it's -- I think you've gone as
12 far as you can with that with the witness's previous answer,
13 Mr. Demirdjian.
14 MR. DEMIRDJIAN: I'll move on then.
15 Q. Mr. Raljic, we know that in 1992 there was in existence a
16 Crisis Staff in Kotor Varos. You were aware of their existence?
17 A. Yes.
18 Q. Would anyone from the police station attend meetings of the
19 Crisis Staff?
20 A. Chief Tepic would sometimes go to the meetings of the
21 Crisis Staff. Whether he went there regularly or just occasionally, and
22 under what circumstances, is something that I do not know.
23 Q. And to your knowledge, what was the relationship between the
24 police and the Crisis Staff?
25 A. Do you mean relations between Chief Tepic or police in general?
1 Q. The police in general.
2 A. I cannot answer this question because I cannot say what was the
3 relation of the entire police force with the Crisis Staff. The question
4 is somewhat abstract.
5 Q. I understand. To your knowledge, did the police have to submit
6 any reports to the Crisis Staff?
7 A. As far as I know, we did not. There was not a single report sent
8 out to the Crisis Staff through the communications centre. Now, whether
9 Chief Tepic would tell them anything orally is something that I do not
10 know because I did not attend any of the Crisis Staff meetings.
11 Q. And do you know of any situation where Chief Tepic would receive
12 orders from the Crisis Staff?
13 A. No, I'm not aware of such a situation.
14 Q. You told us earlier about a few detention centres that you were
15 able to observe. Do you know what was the ethnicity of the people
16 detained there?
17 A. I can only suppose that these were people of Muslim and Croatian
18 ethnicity. But that is just something I'm supposing.
19 Q. And the police station itself, did it have any cells?
20 A. The police station did not have cells. It did not have a prison
21 department, but it had a detention unit which is close to the entrance of
22 the building, and it is a detention unit that exists to this day.
23 Q. And after the 11th of June, did you know whether anyone was
24 detained there?
25 A. There were some people who were held in this room. Now whether
1 they were imprisoned or detained, that's questionable. But I did see
2 some people there when I was entering the building.
3 Q. And did you ever hear anything about the conditions of the
4 detention in the police station?
5 A. Generally speaking, I cannot say anything about the conditions of
6 detention except for the fact that it was a small room, not more than
7 10 square metres. So you can judge by yourself how many people could be
8 placed there, maybe five or six or seven. Five or six metres from this
9 room is a toilet. And I cannot say with any certainty how long these
10 people spent there and what the sanitary and other conditions of their
11 stay were.
12 Q. Being yourself in the police station, did you hear anything about
13 the way they were treated?
14 A. There were rumours going around that some of the specials were a
15 bit more brutal with these peoples. But this was just the talk going
16 around, as it is a small town.
17 Q. Were there any notorious cases in these occurrences of being
19 A. I cannot mention any specific example from the police station
20 where some of the people were detained. I cannot mention any such
22 Q. Were you aware of an event that happened on the 25th of June in
23 front of the hospital in Kotor Varos?
24 JUDGE DELVOIE: Mr. Demirdjian, before you go on to another
25 incident, could the witness explain what he means with "the specials."
1 MR. DEMIRDJIAN: Yes.
2 Q. Mr. Raljic, could you clarify once again for us what you meant by
3 "the specials."
4 A. Yes. In this period, we called the men who wore camouflage
5 uniforms and had hats on their heads, we used to call them "specials."
6 Q. Is this the unit that you described to us yesterday as wearing
7 light camouflage uniforms?
8 A. Yes, the light camouflage uniforms.
9 Q. And is this the group that you told us yesterday that was led by
10 Mr. Dubocanin?
11 A. Yes.
12 MR. DEMIRDJIAN: Does that clarify the matter, Your Honours?
13 JUDGE DELVOIE: Yes, thank you.
14 And just one other detail. The witness says that in that room
15 there could be normally five, six, to seven people. Would it be possible
16 to accommodate more -- more or less normally 12 people in there?
17 THE WITNESS: [Interpretation] Well, you see, the detention unit
18 is meant to hold two to three people under normal circumstances. Now,
19 whether you could put as many people in there, yes, if they were all
20 standing, there could be a dozen of people in there. Ten people could be
21 there. They couldn't sit down and they couldn't lie down, but if they
22 were all standing there could be ten of them. I never counted them
23 though, so I cannot be specific about the numbers.
24 JUDGE DELVOIE: Thank you.
25 MR. DEMIRDJIAN:
1 Q. Mr. Raljic, were you --
2 JUDGE HALL: Mr. Demirdjian, I alert you that you have 15 minutes
4 MR. DEMIRDJIAN: Thank you, Your Honours. I plan on finishing
5 within those 15 minutes.
6 Q. MR. Raljic, were you aware of an event that occurred in front of
7 the hospital in Kotor Varos on the 25th of June, 1992?
8 A. There was talk going around the town on the following days about
10 Q. And to your knowledge, what occurred exactly?
11 A. I cannot tell you what exactly happened. I heard that some
12 people lost their lives, that they were killed; but what the number was,
13 I wouldn't know, and I couldn't say.
14 Q. You told us that the following days there was talk in the town.
15 Was there any talk about who committed the crime?
16 A. I don't know. Some specials were mentioned, once again, but ...
17 Q. With regard to these events - not only the hospital but also the
18 detention - to your knowledge, was this ever reported by your chief?
19 A. You mean the specific incidents that we mentioned; or, generally
20 speaking, did he report anything?
21 Q. Well, generally speaking, did he report any of the behaviour
22 you've been describing to us so far, by the specials?
23 A. Yes. At one point, I cannot say with certainty when that was,
24 whether it was in the second half of June or so, as far as I remember,
25 the chief sent a dispatch in which he noted that the specials had
1 resorted to violence against some people and against himself personally.
2 He said that he had some problems with them.
3 Q. And to your knowledge, where was this sent to, this dispatch?
4 A. As far as I remember, that dispatch was sent to the public
5 security centre.
6 Q. And you told us that "the specials had resorted to violence
7 against himself."
8 Did that occur before the dispatch was sent?
9 A. I believe that he said that they behaved in a nasty manner
10 towards him, even before the dispatch was sent, and there were problems
11 with the specials. On one occasion, one of them kicked him in the belly
12 in -- on the premises of the police station and seized his official
13 pistol and so on, and all of this was done in front of other employees.
14 Q. And was there any consequence after he sent this dispatch?
15 A. Consequence for whom?
16 Q. Were, first of all, any measures taken, to your knowledge,
17 against these specials?
18 A. I don't know if any specific measures were taken, because these
19 were armed men who were ready to do anything, and I'm not sure who would
20 have been able to take any measures about that at the time.
21 Q. And to your knowledge, until when did the specials remain in
22 Kotor Varos?
23 A. I think it was until around the month of September or so.
24 Q. And when you sent that dispatch, you said maybe towards the
25 second half of June; to your knowledge, was that dispatch received in
1 Banja Luka? Was it a successful dispatch?
2 A. The dispatch was received by the communications centre in
3 Banja Luka. Now where it was then sent further on from the
4 communications centre is something that I couldn't confirm.
5 Q. You remember yesterday you were talking about the ethnic makeup
6 in the police station. I want to ask you what was the situation after
7 the 11th of June. You told us that it was mixed. What was it after the
8 11th of June?
9 A. After the 11th of June, there were fewer people of other
10 ethnicities who remained employed. As far as I remember, everything was
11 blocked, and everything stopped for a couple of days. I cannot remember
12 whether some people started working immediately or later, but I can
13 remember that Sejdo Tatar and Jasmin Bajic continued working. I cannot
14 remember when others began coming to work once again after the
15 11th of June.
16 Q. Do you recall a man by the name of Ilija Dragulic?
17 A. Yes, I remember him.
18 Q. What was his role? What was his position?
19 A. Ilija Dragulic was a policeman who most frequently worked in --
20 was in charge of the traffic, as far as I can remember.
21 Q. Do you know if anything happened to him after the 11th of June?
22 A. Yes, I heard that Ilija was killed. I'm not sure how long after
23 the 11th of June that was, whether it was 20 days or a month later, but I
24 heard that he was killed.
25 Q. And you told us that Kotor Varos was a small town. Was there any
1 word as to who perpetrated the crime?
2 A. Well, there were some rumours about that. But I can connect that
3 with an incident which took place in the Kotor settlement. It was still
4 peaceful at the time in this settlement, as far as I remember. Some
5 people were handing over weapons their weapons, and there was a group of
6 young men from some surrounding villages from the area around Kotor Varos
7 who were standing guard there. One night someone through a hand-grenade
8 in the room where they were. Some of these young men were killed on that
9 occasion. And I think that the incident can be connected with Ilija
10 Dragulic's death because on the following day, or soon thereafter, he
11 lost his life and there were rumours going around that that group was
12 involved in the incident of his death.
13 Q. You told us about the actions of the specials. To your
14 knowledge, are you aware of any events in which the special police of
15 Mr. Ecim were involved in?
16 A. I cannot remember any specific incident.
17 Q. Did you see him at the police station after the
18 11th of June, 1992?
19 A. Yes, I did see Ecim there.
20 Q. Were you able to observe his behaviour?
21 A. Well, he was a bit arrogant. It was not a man that you could
22 just come up to and talk to him. He was acting in a military fashion.
23 Q. And to your knowledge, what was his relationship with Mr. Tepic?
24 A. I'm not aware of their relations because I cannot remember that I
25 ever saw Mr. Tepic and Mr. Ecim together at a meeting or anything, so I
1 wouldn't know that.
2 Q. I have one last question, Mr. Raljic. In relation to an answer
3 you gave us yesterday, when we were talking about the communication lines
4 being cut off during the first seven to ten days, do you remember you
5 were asked the same question in your interview?
6 A. You mean during our interview three years ago?
7 Q. yes.
8 A. Yes, I think I remember that.
9 Q. Yesterday at page 12399, you answered that after those initial
10 days there were constant shortages of power, almost daily. You repeated
11 it again today. And you told us that in relation to the dispatches the
12 communication lines were unreliable, so you couldn't really be sure that
13 we would be able to send a dispatch at any given moment.
14 You remember you said that yesterday?
15 A. Yes, we did discuss that.
16 Q. In your interview, you told us that the dispatch communications
17 functioned, although with some difficulty, but under the circumstances,
18 it functioned.
19 Now, could you clarify to the Trial Chamber what was the
20 situation. There was some power outages during the day; but, generally
21 speaking, did the dispatch communication function?
22 A. The communication mostly did not function. So most of the time
23 throughout this period the communication was not functional. I think I
24 said here yesterday that there was a series of circumstances under which
25 we could not send a dispatch. It did not just depend on whether we, at
1 the police station, had power. We depended on the post office and on
2 whether there was power in Banja Luka at any given moment, and,
3 therefore, there were various causes, because of which we could not
4 establish communication. It was just when we had power outages. When I
5 said that we had difficulties, that was precisely what I implied, that
6 sometimes we could not send a dispatch because of all these reasons.
7 Q. Okay. So let me just understand this. You have power outages
8 during the day, and you answered to a question of Judge Harhoff about
9 that. But did we understand you correctly? In the interview you said
10 that generally and understand the circumstances it functioned.
11 So can we understand that even though you had periods during the
12 day when there was no power, after trying or -- during the course of the
13 day you were able to send dispatches?
14 A. No. In this period, the communication line mostly did not
15 function. Most of the time it was not functional. If there were power
16 cuts during the day, for example, it depended on the contents of
17 dispatches. There were some dispatches with which we could not wait for
18 five or six days to have the lines functional because it was urgent to do
19 something in connection so then we would send dispatches by other means.
20 Mostly, during this period, the communication lines that we used for
21 sending dispatches did not function properly.
22 Q. And to wrap it up on this, when you say you would send by other
23 means, what was the other means you would send a dispatch through?
24 A. We would tell the chief that we could not send a dispatch, and
25 then it was probably sent as part of the courier mail.
1 Q. Very well. Thank you, Mr. Raljic. I have no further questions.
2 MR. ZECEVIC: Your Honours, we agreed with Mr. Zupljanin Defence
3 that they would go first for this witness.
4 Cross-examination by Mr. Krgovic:
5 Q. [Interpretation] Good morning, Mr. Raljic.
6 A. Good morning.
7 Q. My name is Dragan Krgovic. On behalf of the Defence of
8 Stojan Zupljanin, I will ask you some questions today and they are
9 connected to your testimony.
10 As the two of us speak the same language and in order to
11 facilitate other participants to follow the trial and because of the
12 needs for interpretation, please, when you hear my question, take a short
13 break of a few seconds and only then answer the question so that both the
14 question and the answer would be adequately interpreted. You can also
15 follow the transcript in front of you on the screens, so when you see
16 that the line stops, take that into account. I will also try to do that
17 because I speak very quickly and I see that you do so as well. We have
18 to enable the interpreters to do their work properly.
19 Mr. Raljic, when answering to the Prosecutor's questions a while
20 ago, you talked about the relations between Mr. Tepic and the police and
21 the Crisis Staff. You never attended any of the Crisis Staff meetings,
22 did you?
23 A. No, I did not.
24 Q. Whether Mr. Tepic submitted any reports or received any orders or
25 any other of the superior members of the police is something that you
1 don't know; right?
2 A. Yes. I already answered this question to the Prosecutor. I'm
3 not aware of this.
4 Q. And you never saw any minutes from the Crisis Staff meetings?
5 That was never submitted to you? When I say this, I imply the year 1992.
6 A. No, I never saw that.
7 Q. When you answered the Prosecutor's questions yesterday, you
8 mentioned a meeting held at the old pensioners' home, when there was talk
9 about signing a loyalty oath which the policemen were supposed to do.
10 You said that the meeting was short and that it was interrupted.
11 The Prosecutor didn't ask you anything further about that specific
12 moment, but I wish to ask you that now.
13 Was it an incident when a group of armed Muslims and Croats came
14 to the meeting and interrupted it? It was a group headed by a Croat
15 called Sprzo. This is the incident that I have in mind.
16 A. Yes. That was the reason why that meeting didn't come to its
17 logical end. That group of people led by Stipo Maric called Sprzo
18 forcibly entered the room where the meeting was held at the senior
19 citizens' home they were armed with long-barrelled weapons, and no police
20 officers at the time had such weapons. They had all come to the meeting
21 unarmed. It was a very unpleasant situation. Everybody was afraid for
22 their lives. And everybody ran from that meeting. Everybody ran away.
23 Q. And that was basically the exerting of pressure of police
24 officers who were Muslims or Croats so as not to join the MUP of the RS?
25 A. I cannot say with certainty that it was indeed their motive, but
1 I can assume as much.
2 Q. The result was that a number of Muslims and Croats did not sign
3 the solemn declaration and did not join the Serbian MUP; correct?
4 A. As far as I remember, at the meeting itself, there was no signing
5 of declarations because the meeting was interrupted by this display of
6 force. It was interrupted violently.
7 Q. When the Prosecutor asked you about Muslims and Croats who
8 continued working at the SJB of Kotor Varos, do you know that a number of
9 Muslim -- of Muslims and Croats joined the armed units headed by
10 Mr. Sadikovic and that they established their own unit outside of
11 Kotor Varos?
12 A. Yes, I know that there were such members.
13 Q. While you were speaking about the situation yesterday, answering
14 the Prosecutor's question about the situation in Kotor Varos prior to the
15 11th of June, 1992, you mentioned that the situation in Kotor Varos was
16 tense. Isn't it true that in that period before the 11th of June, 1992,
17 there were some incidents in Kotor Varos and the surrounding area where
18 the victims were Serbs?
19 A. I cannot know -- remember precisely the particular incident.
20 Maybe you can remind me. But I cannot remember that any Serbs were
21 killed before the 11th of June.
22 Q. Do you know that some members of the army were disarmed by
23 Muslims and Croats at check-points set up around Muslim and Croat --
24 Croatian villages?
25 A. Yes. There were such cases. One of them on Mount Rujka [phoen]
1 when some guys came from the theatre of war in Croatia, I believe. They
2 were attacked verbally and physically, and the group of armed persons
3 from that village up there, Kotoriste and those villages, came and
4 assembled in front of the police station. They had long-barrelled
5 weapons and protesting why the people had come there. These people had
6 come back from the front line in Croatia. Why they were bothered by
7 that, I don't know.
8 I also remember another incident from May 1992 when, following an
9 agreement with the commander, the deputy, and the chief of the SJB, which
10 was about patrolling the town to provide for security of the citizens
11 because all three ethnic groups wanted that, and we had a van to patrol
12 the suburban settlements in the evening hours. And I remember us going
13 to the village of Vecici which was around 11 p.m. It was dark already.
14 And at a point in time there were some branches, some logs on the road,
15 and the van had to stop. I was present. It was a very unpleasant and
16 tense situation. It was night-time. We were all sitting inside. And I
17 know that in front of the van on the left and on the right there were two
18 armed persons. I remember how one of them looked. He had a beard and
19 long hair. And they pointed their weapons to our van. The driver was a
20 Muslim, a reserve police officer of ours, and they were saying that we
21 had no business entering their village, that they were guarding it, and
22 that we shouldn't come back again.
23 Q. You also know that immediately before the 11th, in the territory
24 of Kotor Varos municipality, there was a unit, a joint Croatian/Muslim
25 unit which was armed and had radios?
1 A. I am not sure that, before the 11th of June, there was such an
2 organised unit. But people were armed, and they were constantly arming
3 themselves. Because the police, at the time, organised raids at pubs in
4 the villages, and we would often seize weapons.
5 Q. Do you know that these Muslims and Croats, apart from the
6 weapons, also had radios to be able to communicate with each other?
7 A. Yes, of course, I do. At the beginning, I didn't know that they
8 had such equipment. But while I was a civilian, I was a ham radio
9 enthusiast, and I scanned VHF frequencies. And I came across such a
10 radio communication. I intercepted it. As far as I remember, the
11 code-names for the two parties were Skija [phoen] and Zmajl [phoen], and
12 they were exchanging information.
13 Later, I found out that this call-sign of Skija was on
14 Mount Skaljine [phoen], whereas Zmajl was the call-sign of a guy whose
15 name was Mario from Gradiska, which I learned only later. I mean Stara
16 Gradiska in Croatia.
17 There were other radio stations too. It was a developed radio
18 network with call-signs. Their call-signs Vezir, Bedem, Jabuka, Kula,
19 and so on. They had a good network, and I can also add another detail:
20 After Maric, Stipo Maric called Sprzo, was killed in combat, one of the
21 guys brought a piece of paper and gave it to me at the police station.
22 It was their -- it was a table showing the frequencies they used and the
23 hours when they would communicate. And this made my work much easier.
24 Later I was able to track them. But, at any rate, they were
25 well-equipped with radios.
1 Q. Just another question before the break.
2 You mentioned this man Sprzo. He was killed in the
3 summer of 1992; correct?
4 A. Yes. I believe in the second half of July.
5 MR. KRGOVIC: [Interpretation] Your Honours, I don't know whether
6 this may be a convenient moment for the pause because I'm about to pass
7 on to another topic, or perhaps we should use another few minutes
8 available to us.
9 JUDGE HALL: We could as easily take the break at this point.
10 The break this morning is going to be 30 minutes, not 20 minutes, because
11 there may be a technical problem dealing with LiveNote which has to be
12 fixed during the break.
13 So just in case it takes a little longer than 20 minutes, we'll
14 break for 30 minutes, which break we can take now, if that's convenient.
15 [The witness stands down]
16 --- Recess taken at 10.21 a.m.
17 --- On resuming at 10.59 a.m.
18 MR. ZECEVIC: I just want to state, for the record, that
19 Mr. Cvijetic joined the Stanisic Defence. Thank you very much.
20 [The witness takes the stand]
21 MR. KRGOVIC: [Interpretation]
22 Q. Mr. Raljic, let us continue. The break was a bit longer, due to
23 the problems with the transcript.
24 Yesterday and today, answering the Prosecutor's questions about
25 the number of dispatches received at the centre and about the problems
1 with sending them via the teletype machine, you provided answers.
2 MR. KRGOVIC: [Interpretation] And now I would like to show
3 65 ter 393. I believe it's an exhibit already, but I don't have the
4 number handy. It's at tab 11. So it's 65 ter 3193. 3193. It's the
5 Prosecution's tab 11.
6 [Trial Chamber and Registrar confer]
7 MR. KRGOVIC: [Interpretation]
8 Q. Take a look at it, sir. Yesterday, answering the Prosecutor's
9 question, you commented on the last paragraph and said that concerning
10 the communication with Kotor Varos, your -- you were referring to the day
11 of the sending of this report. And that was the 16th of January, 1993;
13 A. Yes, the 16th of January, 1993.
14 MR. KRGOVIC: [Interpretation] Let us go to page 3 of this
15 document in both the English and the Serbian version -- versions.
16 Can we see the bottom of the page in Serbian.
17 Q. It is stated here that in 1992, as we can read in the
18 last-but-one paragraph, the number of telegrams received and sent is
19 stated, that is, from the 1st of January through 31st of January, 1992;
21 A. Yes, that's what it says.
22 Q. And this includes the five months of peacetime; correct?
23 A. Yes, the entire year 1992 is taken into account.
24 Q. And there is your comment at the end. It can be observed that --
25 MR. KRGOVIC: [Interpretation] Can we see the following page.
1 Q. -- the number of dispatches has significantly dropped in relation
2 to the previous year, which, in turn, has been caused by wartime
3 operations in the former BiH, that is, SFRY.
4 That's what the report says; correct?
5 A. Yes, that's what it says.
6 Q. In the period until the 11th of June, 1992, what was the average
7 daily number of incoming and outgoing telegrams, let's say, until the
8 1st of April?
9 A. Well, I cannot give precise numbers for that period, but I can
10 give you an example from which we may draw a conclusion.
11 On average, and now I'm referring to the period before the
12 11th of June to -- 1991 [as interpreted], we had a daily average of about
13 30 dispatches, which, monthly, would amount to 800 to 1.000 dispatches.
14 So from that we may draw a conclusion as to the time-period you referred
16 Q. We can see from this report that there are about 3500 dispatches
17 for the entire year. If we subtract the four or five months of
18 peacetime, this certainly reflects a significantly reduced number of
19 dispatches from the 11th of June on.
20 A. Yes. The language used here is significantly reduced. So it
21 isn't a slight drop but a sharp drop.
22 Q. The Prosecutor asked you about individual events today; more
23 specifically, the murder of Ilija Dragulic, then the killings in front of
24 the health centre, medical centre. The information about these events
25 was not sent out through your communications centre; right?
1 A. No. We didn't send out such information from our communications
2 centre at all.
3 Q. When it comes to the events in the Kotor Varos municipality, such
4 as the burning of the Catholic church and the destruction of some
5 mosques, to the best of your recollection, reports about that were not
6 sent to the CSB through your communications centre; correct?
7 A. That is correct, they weren't.
8 Q. The Prosecutor asked you today about the conduct of Chief Tepic
9 when he would receive an order or some sort of letter through the
10 communications centre, whether he acted upon it or not.
11 Let me ask you, as far as you know, did you send detailed reports
12 to multiple recipients? I'm referring to the period after the
13 11th of June in which you would describe events such as the ones you have
14 just mentioned such as murders, arsons, et cetera?
15 A. Such information about such matters was not sent out through our
16 communications centre.
17 Q. I would like to show you Exhibit P734.
18 MR. KRGOVIC: [Interpretation] That is Defence tab 3; I mean the
19 Zupljanin Defence.
20 Q. Mr. Raljic --
21 MR. KRGOVIC: [Interpretation] No, this isn't the document.
22 65 ter 430; and, according to my notes, it's 374.
23 Q. The police station in Kotor Varos was faced with a loss of
24 personnel so that after the 11th of June they didn't have many
25 professionals; correct?
1 A. Yes, there was a loss of personnel.
2 Q. Which was reflected in the functioning of the SJB; correct?
3 A. Yes, certainly. And talking about communications, our centre
4 didn't have as many staff as there should have been according to the
5 then-job classification.
6 Q. Take a look at the -- this letter from the centre in Banja Luka
7 which was sent to all chiefs. And please take a look at page 2 of this
8 document, and will you see Stojan Zupljanin's signature.
9 MR. KRGOVIC: [Interpretation] Could we go back to page 1, please.
10 Q. Here, we see a letter that deals the problem of failures or
11 mistakes made by the SJB:
12 "There are considerable omissions and shortcomings in the daily
13 reports by SJB to the Banja Luka CSB operative duty section on major
14 incidents, which consist of the following ..."
15 And if goes on to say that not all significant event are
16 included, that some information about some events is often incomplete.
17 Then events that -- about which information is received subsequently are
18 not being registered; the offices in charge are practically not even
19 checking the reports.
20 So these are problems that were present not only in Kotor Varos,
21 in their territory, but in the entire territory of the CSB. And then it
22 is stated which elements such reports should include. A template is
23 given. And regard -- with regard to the conditions in Kotor Varos and
24 the combat operations, you didn't apply this template?
25 A. I'm not familiar with the templates. In that period, after the
1 11th of June, 1992, we never sent anything that was composed in this way.
2 Q. If you have a look, it says here what a public security station
3 should send in its reports. And if you have a look at items 18 and 19,
4 which are at the bottom, explosions in various facilities, what damage
5 was caused. And then the last line where it says:
6 "Attacks of people of one ethnicity against people of other
7 ethnicity, provide a short description."
8 MR. KRGOVIC: [Interpretation] And then, please, if we could move
9 on to the next page where Mr. Zupljanin requests information under
10 item 24. The number of cases of desecration of monuments, cemeteries and
11 so on.
12 Q. So such reports were not sent from the Kotor Varos SJB; right?
13 A. I do not remember that I sent any reports that were made in
14 accordance with this form and with so many items. And the date given at
15 the beginning, as far as I could see, is from the month of May. But I
16 could not see the date.
17 Q. It's the 26th of May. I'm sorry.
18 A. Yes, the 26th of May. So this is just ten or 15 days before the
19 beginning of the conflict. And during the summer, as we already
20 mentioned here, we were not able to send, in the morning, the daily
21 reports as I would note, because I think this refers to daily reports.
22 This has to do with daily reporting. And it would be logical for us to
23 send daily reports only 10 or 15 days later.
24 Q. If you specifically have a look at the last page in item 30(e),
25 Mr. Zupljanin requests that there should be specific reports about war
1 crimes. And through the communications system, in this period, such
2 reports did not pass through your hands, did they?
3 A. No, they did not.
4 Q. Today, when answering the Prosecutor's questions, you talked
5 about the behaviour of certain groups in Kotor Varos. And when you
6 talked about the reputation which they had, which the specials had, you
7 also had in mind the way they behaved to Chief Tepic. The specials whom
8 you mentioned and who were not behaving properly were the group headed by
9 Slobodan Dubocanin; right?
10 A. Yes, I had them in mind.
11 Q. So they are different from the members of the special police who
12 were also present there?
13 A. Yes, certainly. Members of the special police unit, as far as I
14 know, wore blue camouflage uniforms.
15 Q. Thank you, Mr. Raljic. I have no further questions for you.
16 Cross-examination by Mr. Zecevic:
17 Q. [Interpretation] Good morning, Mr. Raljic.
18 A. Good morning.
19 Q. Excuse me. I only have a few brief questions for you.
20 I wish to clarify one thing with you and to use your professional
21 knowledge to clarify one thing that we need for the transcript and in
22 order to assist the interpreters in future in this case when it comes to
23 interpreting expert matters.
24 My question is the following: Short waves, which is "KT" in
25 B/C/S, are the waves that have frequencies between 3 and 30 megahertz.
1 A. That is correct, yes.
2 Q. In our language, the abbreviation used for them is "KT."
3 A. That is correct, KT.
4 Q. With the help of interpreters, and primarily at their initiative,
5 I managed to find out that the English abbreviation for KT is "HF," which
6 stands for "high frequency."
7 Now, the ultra short waves are those whose frequencies are
8 between 30 and 300 megahertz; is that correct?
9 A. Yes, that's the UKT.
10 Q. For this abbreviation that we use in our language, namely, "UKT,"
11 the abbreviation which is used in English is "VHF," which stands for
12 "very high frequency."
13 A. Yes. VHF stands for very high frequency. That's right.
14 Q. Thank you so much. I think that we have clarified that now.
15 Let me ask you this: I think that during your interview with the
16 Prosecution you discussed this. Do you know what was the ethnic
17 composition of the Dabovci village which is situated in the vicinity of
18 Kotor Varos?
19 A. Mostly yes.
20 Q. Was it a Muslim or a Serbian village?
21 A. The very centre of Dabovci is a Serbian village. It's located
22 along the main road. Dabovci, yes.
23 Q. Do you know that in mid-August 1992 the Serbian army attacked the
24 Dabovci village razed it to the ground?
25 A. No, I'm not aware of that. My grandfather used to live in
1 Dabovci. My uncle is living in Dabovci today, together with his family.
2 It's along the main road. And all these houses in Dabovci are in tact.
3 Now whether this is just a hamlet which is in the outlining areas of
4 Dabovci, I wouldn't know. But as for the Dabovci village themselves,
5 it's a place populated by Serbs.
6 MR. ZECEVIC: [Interpretation] For the transcript, this is a
7 Adjudicated Fact 943.
8 Q. Please tell me, do you know someone called Predrag Markovic from
9 Kotor Varos?
10 A. I cannot remember that with any certainty.
11 Q. How about Marinko Djukic?
12 A. No. I know one Marinko Djuric but not Marinko Djukic.
13 Q. If Mr. Markovic and Mr. Djukic were members of the police, you
14 should know them or at least be familiar with their names; correct?
15 A. Yes, certainly.
16 Q. Therefore, we can say with a high degree of certainty that
17 neither Mr. Markovic nor Mr. Marinko Djukic were members of the police or
18 that they had any command positions or authority within the police?
19 A. Yes, that is certainly so.
20 MR. ZECEVIC: [Interpretation] For the information of -- to the
21 Trial Chamber, this is Adjudicated Fact 515.
22 Q. Sir, I think that it was yesterday during the
23 examination-in-chief when you talked about the 11th of June, 1992, in
24 Kotor Varos. If I understood your testimony correctly, you said that on
25 the 11th of June the situation was as it was but that there were no
1 conflicts which took place on that date.
2 A. Yes, that's correct.
3 Q. On that day, the 11th of June, or in the month of June in
4 general, did the Bosnian Serb army mount any attacks on the town of
5 Kotor Varos?
6 A. Not on the entire town of Kotor Varos at the very beginning. So
7 counting from the 11th of June and on the following few days there was no
8 armed conflict at all. As far as I know, people were handing over their
9 weapons, especially in the village Zabrdje, Podbrdje, and Slatina,
10 because all the houses located there remained intact and no one harassed
11 these people at all.
12 In the first few days, there was no conflict. I think that the
13 main conflict began after the incident that I mentioned after a hand
14 grenade was thrown at the young men in the Kotor settlement. I think
15 that the conflict escalated somewhat after that incident.
16 Q. And the conflicts had to do, as you said, with the Kotor
17 settlement, so it is a place that is, in fact, outside Kotor Varos?
18 A. It is in Kotor Varos, but it is located across the Vrbanja river.
19 Q. Do you know that if there were any attacks against the
20 Vetici [phoen], Hrvacani, Ravne, and Hanicici [phoen] villages in the
21 month of June 1992 and that these attacks were carried out by the Serbian
23 A. I'm not certain if there were any during the month of June.
24 Later on during the summer there were such conflicts, but I think that
25 there were no situations like that during the month of June. I know that
1 some men were sent to these villages during June in order to talk to
2 these people because the villagers were armed. So some people were sent
3 over there to suggest to these people that they should hand over their
4 weapons and so that the situation would be resolved in a peaceful manner.
5 MR. ZECEVIC: [Interpretation] To inform the Trial Chamber that
6 this is the Adjudicated Fact 519.
7 JUDGE DELVOIE: Mr. Zecevic.
8 MR. ZECEVIC: Yes.
9 JUDGE DELVOIE: In line 38 [sic] 5, the name of the village is
10 not on the record. People were handing over their weapons especially in
11 the village ... and Slatina. Could we clarify that, please?
12 MR. ZECEVIC: By all means, Your Honour.
13 Q. [Interpretation] Witness, please be so kind to repeat your
14 answer, which has not been recorded. I asked you if on 11th of June or
15 during the month of June, in general, the members of the Bosnian Serb
16 army mounted any attacks against Kotor Varos, the town itself. You said:
17 Not against the whole town in the beginning. And if we count
18 from the 11th of June and on the following several days, there were no
19 conflicts at all. As far as I know, people were handing over their
20 weapons, especially in the villages - and the villages have not been
21 recorded - the names of the villages and Slatina village, because all the
22 houses there remained intact and no one harassed these people at all.
23 Can you please just repeat the name of this village?
24 A. Yes. These are villages Podbrdje, Zabrdje, and Slatina. These
25 are villages located along the main road leading from Kotor Varos to
1 Banja Luka. There may have been isolated incidents in which some house
2 or other was torched, but there were no conflicts.
3 JUDGE DELVOIE: Thank you.
4 MR. ZECEVIC: Thank you, Your Honours.
5 MR. DEMIRDJIAN: I apologise. Just for the record, Mr. Zecevic
6 was referred to Adjudicated Fact 515. That one refers to another
7 municipality, not to Kotor Varos. I believe it's Teslic, just for
9 MR. ZECEVIC: I'm sorry.
10 Q. [Interpretation] Can you please tell us if you're familiar with a
11 certain Goran Zaric from Kotor Varos, if you know that name?
12 A. I don't know of any Goran Zaric, no.
13 Q. He has a nickname: Dziba or Djiba.
14 A. Djiba. That can be Goran Zaric, not Goran Zharic.
15 Q. All right. So are you familiar with the name of Goran Zaric?
16 A. Yes.
17 Q. Was he a member of the police?
18 A. I'm not sure, but I think that he was in the police reserves, as
19 far as I can remember. Or he could have been in active service, an
20 active policeman; I think so.
21 Q. What about Zdravko Zutic?
22 A. Zdravko Zutic, I am familiar with that name, but he wasn't an
23 active-duty policeman. I think he was in the reserve force.
24 Q. All right. Very well. And do you know a certain Dusko Vujicic
25 from Kotor Varos?
1 A. Yes, but he's actually from Banja Luka. He worked in
2 Kotor Varos.
3 Q. And what did he do?
4 A. He worked as a policeman.
5 Q. Can you tell me -- actually, I already asked about the village of
6 Dabovci and you explained that this was a mostly Serb-inhabited village
7 and some members of your family also live in that village. Do you know
8 that Bosnian Serb forces frequently robbed Bosnian Muslims' homes in the
9 village of Dabovci?
10 A. Not in the village of Dabovci, no.
11 Q. Well, you probably went to visit your family and you stayed in
12 touch with them during 1992. Did they tell you that Muslim homes in the
13 village of Dabovci would be frequently robbed?
14 A. No, we never talked about that. Nobody ever said anything about
15 that. None of my relatives ever did.
16 MR. ZECEVIC: [Interpretation] For the Trial Chamber, this is
17 Adjudicated Fact 542.
18 Mr. Raljic, thank you very much. I have no further questions.
19 Re-examination by Mr. Demirdjian:
20 MR. DEMIRDJIAN: Just a few questions for re-examination,
21 Your Honours. I will be brief.
22 Q. Mr. Raljic, you were asked at the beginning of the
23 cross-examination by Mr. Krgovic about a man nicknamed Sprzo. Can I ask
24 you, first of all, was he a local from Kotor Varos?
25 A. Yes, he was.
1 Q. You told us - I don't know if the transcript is correct - that he
2 was killed in combat. Do you know the exact circumstances of his death?
3 A. More or less, I do.
4 Q. What were those circumstances?
5 A. Stipo Maric, Sprzo, was killed in armed conflict at Stara Kula,
6 the old tower in Kotor Varos, where the army and the specials had a
7 conflict with the Muslim/Croat forces. I know that on this occasion
8 Serbs who fought there got killed, and as far as I know, 10 or 12 members
9 of the Muslim/Croatian forces were also killed. So it was armed conflict
10 and as far as I know, they were all killed in conflict.
11 Stipo Maric, Sprzo, was a member of some Croatian units. I once
12 intercepted a conversation in which he requested from the person he was
13 talking to in Gradiska that he should get in touch with some different
14 brigade of theirs that he was a member of, which was located in Dugo Selo
15 in Croatia.
16 Q. You didn't take part in that armed conflict, did you?
17 A. No, I didn't.
18 Q. You didn't see whether Mr. Maric was killed right there, did you?
19 A. No, I didn't. But I can explain, if you wish.
20 Q. What I'm interested in finding out is: You were not present when
21 he was killed?
22 A. Physically I was not present. It wouldn't have been logical
23 either because he was on the other side. But on the next day I saw him
24 dead, after that clash.
25 Q. Where did you see him dead?
1 A. When the army took control over that part of town, they brought
2 in the people they found there and among them there was a Maric, also
3 known as Sprzo. I saw him lying on the road on a ground-sheet. And
4 among the people who were killed -- who were killed, there was a
5 Marko Jelasic, also known as Bato, who went to school with me. He got
6 killed on that day. And a man by the name of Jadranko. There was a list
7 of ten or 12 people, and, among them, they mentioned also the name of
8 Stipo Maric, also known Sprzo, as having been killed.
9 MR. ZECEVIC: I'm sorry. I don't think witness's answer was
10 recorded properly because I believe he mentioned that some of the
11 information he got, he got from the intercept.
12 So maybe you can clarify that.
13 MR. KRGOVIC: Also on clarification, the status of this guy, his
14 fellow, friend from school, because he mentioned he was member of some
16 MR. DEMIRDJIAN:
17 Q. In relation to the first intervention, not quite sure the issue
18 about the intercept. You received some information about this Maric
19 through an intercept; is that right?
20 A. Yes. That's what it's about, and that was the information I
21 learned in the evening hours of the same day. I believe it was late
22 July. A short while ago, we discussed this topic, and I also engaged in
23 electronic surveillance or reconnaissance, and that's how I found out,
24 when they mentioned the list of all people who got killed there. Among
25 them there was there person called Marko Jelasic, nicknamed Bato, which
1 Mr. Krgovic wanted me to explain.
2 He was a member of the reserve police force. But there was also
3 Nedim Zehir, nicknamed Bajs; he also attended primary school with me, and
4 I believe he was also a reserve police officer.
5 Q. Now, when the name of Sprzo was mentioned, it was in relation to
6 the signing of the loyalty oath which you said was, at that point,
7 interrupted. Did there come a time when eventually the loyalty oaths
8 were signed by the members of the SJB?
9 A. I don't know that. This all happened in a very short period of
10 time. That incident took place maybe in mid-May, and I -- in the
11 following days, the situation was very tense. So I don't know whether or
12 not the loyalty oath was signed at any given moment.
13 Q. All right. And just to be clear, did you yourself ever sign that
14 loyalty oath?
15 A. It was a long time ago. I may have. But it was a formality,
16 something that I simply don't remember. I may have. I don't know.
17 Q. You were asked by Mr. Krgovic about the individual events that we
18 spoke about this morning, the killing of Mr. Dragulic and the killings in
19 front of the hospital, and he asked you whether you sent any dispatches
20 about those events and your answer was that you couldn't remember sending
21 any dispatches for those events.
22 The chief of the police station, was he duty-bound to report
23 killings to the superiors?
24 A. Well, you know, in such a situation, I don't know; it's difficult
25 to say whether he was duty-bound, from today's vantage point. It was --
1 there was a war on. People were getting killed. So it was -- it would
2 have been naive to expect for the police to go out in the field and
3 conduct on-site investigations with bullets flying around. And so I
4 don't know whether he was duty-bound to report such incidents.
5 Q. Very well. Maybe if I question it this way: In relation to the
6 rules within the police, is the police chief to report any important
7 events, such as a murder, in your municipality?
8 A. Under normal circumstances, yes, certainly.
9 Q. And you said that you didn't send -- you don't remember sending a
10 dispatch. Do you rule out the possibility that a report may have been
11 sent by courier?
12 MR. KRGOVIC: And he's calling for speculation.
13 MR. DEMIRDJIAN: The issue is whether a dispatch was sent or not.
14 I'm just asking the witness to see if he rules out the possibility.
15 MR. KRGOVIC: Ask him directly: Did he have any knowledge about
17 JUDGE HALL: In other words, Mr. Demirdjian, anything is
19 MR. DEMIRDJIAN: Right. That's all the questions I have,
20 Your Honours. Thank you.
21 JUDGE DELVOIE: Mr. Zecevic, you mentioned fact --
22 Adjudicated Fact 943 in regard to Dabovci village. You were asking the
23 witness whether he knew about destruction of that village, but
24 adjudicated fact -- I suppose, you mentioned it because you're
25 challenging it? 943.
1 MR. ZECEVIC: That is correct, Your Honours --
2 JUDGE DELVOIE: Yes.
3 MR. ZECEVIC: -- but I don't think I mentioned number 943.
4 JUDGE DELVOIE: Oh, then it's -- then it's not good in --
5 MR. ZECEVIC: Oh, yes, yes --
6 JUDGE DELVOIE: Okay.
7 MR. ZECEVIC: -- that's correct. Yes, 943. Yes.
8 JUDGE DELVOIE: Okay. Okay. But --
9 MR. ZECEVIC: That's the first adjudicated fact that I was
11 JUDGE DELVOIE: Yes, but -- so you asked the witness about the
12 destruction of that village --
13 MR. ZECEVIC: Yes.
14 JUDGE DELVOIE: -- but adjudicated facts -- the adjudicated fact
15 is about a killing; when people were taken to a nearby place and where
16 somebody executed, by the soldiers. I mean --
17 MR. ZECEVIC: Yes, I understand that. But obviously the witness
18 was not aware, so I didn't push it --
19 JUDGE DELVOIE: Okay. So it's only --
20 MR. ZECEVIC: I didn't went that far. But, Your Honours, with
21 all due respect, it says:
22 "At least three Bosnian Muslim men from Dabovci were killed after
23 Bosnian Serb soldiers had destroyed their village in mid-August 1992."
24 So that is why --
25 JUDGE DELVOIE: So your challenge is about the destruction.
1 MR. ZECEVIC: That is correct.
2 JUDGE DELVOIE: Thank you very much. Then I have no questions.
3 MR. ZECEVIC: Thank you very much.
4 MR. KRGOVIC: [Interpretation] Your Honours, if I may, something
5 was recorded in the transcript when I requested an explanation.
6 This witness spoke about people being killed as members of the
7 reserve police force. Perhaps it would be good to ask the witness on
8 which side these people, his school-time friends were killed, were -- on
9 which side they were at the moment they got killed. That wasn't
10 reflected in the transcript. So maybe that could be elicited from the
12 Because he merely needs to finish his answer, because he was cut
13 off by the Prosecutor.
14 JUDGE HALL: [Previous translation continues] ... well, you -- you
15 could put the question, Mr. Krgovic.
16 MR. KRGOVIC: [Interpretation]
17 Q. Mr. Raljic, when you were speaking about those school-time
18 friends of yours who were members of the reserve police force and got
19 killed, they were members of the reserve police force before 11th, the
20 reserve police force of the SJB of Kotor Varos, and then later on they
21 joined the Muslim Croat armed units and they were killed as members of
22 the Muslim Croat armed units; correct?
23 A. Yes, that is correct.
24 JUDGE HALL: Mr. Raljic, we thank you for your testimony before
25 the Tribunal. You are now released as a witness, and we wish you a safe
1 journey back to your home. Thank you, sir.
2 THE WITNESS: [Interpretation] All right. I thank you. And if I
3 may say that I cooperated well, both with the Prosecution and with the
4 two Defence teams, and I hope that my testimony here will contribute to
5 finding the truth and passing a fair judgement. Thank you.
6 JUDGE HALL: Thank you.
7 [The witness withdrew]
8 JUDGE HALL: Yes, Mr. Hannis.
9 MR. HANNIS: Your Honour, I had asked to have five minutes at the
10 end of day to raise a couple of matters, and one of those matters relates
11 to the scheduling. The next witness is being proofed and I understand is
12 not ready to begin testifying until tomorrow morning at 9.00.
13 We had a Defence estimate, I think, of a total of five hours for
14 cross-examination. And as you've seen, it was much reduced. Ms. Pidwell
15 tells me by e-mail she had asked the Defence to review their estimates
16 just to help us with scheduling, but that's the situation we're in.
17 So my first request is that we adjourn for the day and resume
18 with the next witness tomorrow morning at 9.00.
19 JUDGE HALL: You said that's your first request. You have
20 another request?
21 MR. HANNIS: Yes. The other matter, Your Honour, I wanted to
22 raise something in conjunction with the order issued by the Trial Chamber
23 yesterday in relation to the Mladic notebooks.
24 [Trial Chamber confers]
25 JUDGE HALL: Sorry, could you repeat what you just said,
1 Mr. Hannis?
2 MR. HANNIS: Yes, Your Honour. I wanted to raise something in
3 conjunction with your order issued yesterday in relation to the Mladic
5 JUDGE HALL: Yes, please proceed.
6 MR. HANNIS: Your Honours, you've given the Prosecution an order
7 to provide certain materials by the 12th of July, or, if we're unable to
8 do so, to provide you a report. The first matter is to provide English
9 translations of the portions of the notebooks that we submit are prima
10 facie relevant and that we seek to add to our exhibit list, and the
11 second is to provide information and material supporting that prima facie
13 Well, certainly, number two we will certainly do. We have some
14 additional materials we can provide to you immediately. And I'll check
15 and see if we have even more beyond that. That's not a problem.
16 The first part, relating to identifying -- relates to the part of
17 the order asking us to identify with specificity the portions of the
18 notebooks we seek to add. And in your order at page 4, the
19 paragraph says:
20 "Considering also that the Prosecution has not identified with
21 the required specificity the portions of the notebooks that it seeks to
22 add to the exhibit list."
23 And then the footnote is footnote 18; it makes reference to the
24 Prlic case.
25 We do note there's a difference in the status of this case from
1 Prlic. Prlic is in the status where the Prosecution has rested its case
2 long ago and is now seeking to reopen its case and introduce this
3 evidence. We say that's a distinction that should make a difference.
4 Here, the Prosecution case is ongoing. We haven't completed our
5 case yet. And we think, as evidence develops, it may change our views
6 about which portions of the notebooks we need to use. You've seen from
7 the submission the notebooks covered, I think, the period from 1991 to
8 1996. It's my understanding I think we now have complete English
9 translations for 1992. And, in our view, the entire set of notebooks for
10 1992 is something that we would seek to add to our list. Perhaps
11 portions of 1991 and 1993. But we haven't been able to fully review the
12 translations that are available up to date to give you that entire
14 I understand the Trial Chamber's reluctance to have thousands of
15 pages that may not be necessary or pertinent. But the nature of these
16 documents, contemporaneous accounts kept by one of the members of the
17 JCE, a high-ranking member of the JCE, we think, for example, the 1992
18 notebooks should come in, in their entirety. Because it's likely that in
19 the course of trial - bear with me - it's likely that in the course of
20 trial matters -- if we only select excerpts, I can tell you,
21 Your Honours, from my experience with other similar kinds of things like
22 meeting notes of the army that I had in another case with Mr. Zecevic and
23 Mr. O'Sullivan, that if we only have excerpts it will become apparent
24 during the trial that additional excerpts now need to be added because
25 something of a witness said or another new document that came in. We
1 would be having repeated requests probably by both parties to add
2 additional portions.
3 I would suggest the better course is to have the entire document
4 in. The parties will make their submissions at the end of the case about
5 which portions are relevant, pertinent, and should be relied upon by you,
6 but you can ignore the rest or give it no weight. But it's -- it puts it
7 in context and it relates to the matters that were going on at the time.
8 Be that as it may, Your Honour, however, at this point what we're
9 asking is simply to add these to our exhibit list. We're not seeking to
10 introduce them into evidence yet. I think that time will come for
11 certainly some portions of the diary, probably not all. But, at this
12 stage, we think all you need to decide is whether or not we can add them
13 to our list. And in your order I think you have found that we've shown
14 good cause for the late discovery and presentation of this evidence,
15 something clearly outside our control; they were only found earlier this
16 year, and we've tried to move expeditiously to bring them to your
17 attention and to the Defence.
18 I see Judge Harhoff has a question.
19 JUDGE HARHOFF: Well -- thank you, Mr. Hannis. My comment was
20 that in your motion you had requested admission to the 65 ter list of all
21 the notebooks covering the entire period from 1991 to 1996. And the
22 Chamber ruled that that is simply too much; you have to select. If you
23 are seeking now to select the portions from 1992, I think that would be
24 well within the limits of the order.
25 JUDGE DELVOIE: Well, I would say that 1992 is -- is a portion of
1 the notebooks.
2 MR. HANNIS: Thank you. That --
3 JUDGE DELVOIE: That could be a portion of the notebooks.
4 MR. HANNIS: Okay. Thank you. That's helpful. I think one
5 reading that we took was that it was to go through 1992, it's 383 pages,
6 find me two pages and two lines, et cetera.
7 Thank you, that's helpful.
8 And --
9 JUDGE HALL: And if I may add, Mr. Hannis, the other thing that
10 we sought to convey in the ruling in the language we chose was to point
11 out the obvious, that the -- after you would have overcome the handicap
12 of having to have the material translated, you would then be in a
13 position to know, even within, say, 1992, that time-frame, what is
14 helpful. So the language, we thought, was sufficiently liberal to erase
15 any apprehensions that you have now expressed.
16 MR. HANNIS: That's all very helpful, Your Honour. And I
17 think one of our concerns was not being able yet to have English
18 translations of the entire collection. And perhaps there's a possibility
19 there might be something in 1994, 1995, or 1996 that were retrospective.
20 But we were concerned that if it's not on our list and by the time we get
21 it translated and analysed and we have something, then we'll be up
22 against a tougher argument to say, Oh, now we want to add something from
24 But I think we've aired the matter. I have -- I certainly,
25 personally, have a better understanding of what you intended.
1 JUDGE DELVOIE: Mr. Hannis, even if that would happen, wouldn't
2 that eventually not be a good cause to ask an additional [indiscernible]?
3 MR. HANNIS: Yes, I would certainly argue that, and I hope so,
4 and I'm happy to hear that. Thank you. Thank you.
5 JUDGE HALL: [Microphone not activated]
6 MR. ZECEVIC: Very briefly, Your Honours.
7 We cited our concerns already in our submissions on the subject.
8 However, there is one thing that -- that I'm aware of and I know my
9 friends from the Office of the Prosecutor are aware of, but -- but it
10 is -- it is causing some additional concern for the Defence. Namely, we
11 are informed that the -- that from the same source we are to expect a
12 number of video and audio material, and it has been disclosed to some
13 other Defences in this Tribunal.
14 Now, I am -- I'm really concerned about the amount of that
15 material. And I mentioned that with my talks with Ms. Korner on a number
16 of occasions, and she informed me that -- that the material has been
17 received in the -- in the Office of the Prosecutor, but -- but at that --
18 at that point - I think it was almost a month ago - the Office of the
19 Prosecutor was asking a Dutch forensic lab to help them -- I don't know,
20 something technologically -- help to copy that material or something
21 along those lines. I'm not really sure. And I ask for your pardon for
22 that because I'm not -- I wasn't really prepared for this.
23 But I'm just -- I'm just making this observation. And maybe we
24 can hear if my learned friend Mr. Hannis can give us an update on this --
25 on the status of this material. If -- if not today, maybe in the -- in
1 the course of next few days.
2 Thank you.
3 [Trial Chamber confers]
4 JUDGE HARHOFF: Mr. Hannis, the Chamber is only aware of an
5 application for introduction of the notebooks. And now Mr. Zecevic
6 informs us that, apparently, in the process of seizing those notebooks,
7 some other material also came to light and that this other material is
8 also in the picture. This is news to us.
9 Can you clarify?
10 MR. HANNIS: Yes, Your Honour.
11 I have to proceed with the caveat that I'm not fully informed
12 about the full extent of this. But it's my understanding that at the
13 time the notebooks were found there were additional materials found
14 including some audio tapes like some of the, sort of, mini-cassettes that
15 were used in little Dictaphone recorders that were popular many years
16 ago. And I believe there was some video as well. They appear to be
17 related -- at least some of that material appears to be related to the
18 notebooks. It's my understanding that some of the notebooks, where
19 there's a meeting recorded, on occasion there is a reference,
20 handwritten, that makes reference to "tape-recorded." So -- and some of
21 the tame recordings have a label on them that suggest they may be related
22 to some entry in the written notebook.
23 As Mr. Zecevic indicated, that material, because it's old and
24 there's a concern about the integrity of the actual tapes themselves,
25 that's why the OTP has consulted with the Dutch forensic institute to
1 help analyse that material, see if it can be copied without destroying
2 it, et cetera. And that's what's in process.
3 It's my understanding that some of the that material, perhaps a
4 copy of it, I'm not even sure, was disclosed in Prlic because of the
5 urgent nature of the status of that case and the Prosecution's request to
6 open the case. I -- I certainly will try and investigate what the status
7 of that is and inform the Defence and -- as well as the Chamber.
8 At this point in time, we didn't know enough about that material
9 to include it our application. Although, on the face, it seems it may be
10 related, and we may want to make that application.
11 But, frankly, I just don't know yet.
12 I hope that answers your question, Judge Harhoff.
13 JUDGE HALL: I -- sorry.
14 I was going to say, the last observation that you made,
15 Mr. Hannis, about communicating with the Defence is exactly what I was
16 going to suggest, in terms of Mr. Zecevic's request, that one would think
17 that, as with everything else, that counsel on both sides continue their
18 working relationship outside of court. And the Chamber need only be
19 involved when it has to make a formal pronouncement on these matters.
20 MR. HANNIS: Yes, Your Honour. And I should indicate, with
21 reference to my remarks about what was disclosed in Prlic, in relation to
22 the audio and video materials, was a list of those materials, not any
23 actual recordings. I think it was just an indication of what they
24 appeared to be.
25 JUDGE HALL: Thank you.
1 So if there's nothing else, we'll take the adjournment to -- I
2 think we're still in this courtroom tomorrow.
3 Yes, 9.00 tomorrow morning.
4 MR. HANNIS: Thank you.
5 --- Whereupon the hearing adjourned at 12.05 p.m.,
6 to be reconvened on Thursday, the 1st day
7 Of July, 2010, at 9.00 a.m.