Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15148

 1                           Friday, 1 October 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.07 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  Good morning to

 6     everybody in and around the courtroom.  This is case IT-08-91-T, the

 7     Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Mr. Registrar.

 9             Good morning to everyone.  May we have the appearances, please.

10             MS. PIDWELL:  Good morning, Your Honours.  Tom Hannis,

11     Belinda Pidwell, and Crispian Smith for the Prosecution.

12             MR. CVIJETIC: [Interpretation] Good morning, Your Honours.

13     Mr. Stanisic's Defence comprises of Slobodan Cvijetic, Tatjana Savic,

14     Ms. Deirdre Montgomery.

15             MR. KRGOVIC:  Good morning, Your Honours.  Dragan Krgovic, Igor

16     Pantelic, and Aleksandar Aleksic for Zupljanin Defence.

17             JUDGE HALL:  Thank you.  Before we call the witness to continue

18     his testimony, the Trial Chamber notes that the first witness subject to

19     the Prosecution's 15th motion for protective measures filed on the 20th

20     of September is scheduled to appear on Friday, the 8th of October.

21     That's today week.  The Defence is hereby instructed to file their

22     response by Tuesday, the 5th of October.

23             Thank you.  And if there's nothing else, could the witness be

24     escorted back to the stand, please.

25                           [The witness takes the stand]

Page 15149

 1                           [Trial Chamber confers]

 2             JUDGE HALL:  Mr. Miskovic, good morning to you, sir.  Before

 3     Ms. Pidwell continues, I remind you you're still on your oath.

 4                           WITNESS:  SIMO MISKOVIC [Resumed]

 5                           [Witness answered through interpreter]

 6             JUDGE HALL:  Yes, Ms. Pidwell.

 7             MS. PIDWELL:  Thank you, Your Honour.

 8                           Examination by Ms. Pidwell: [Continued]

 9        Q.   Good morning, sir.

10        A.   Good morning.

11        Q.   Yesterday you were telling us about the Prijedor 2 police

12     station.  And if you can please tell us now where that station is

13     actually located in Prijedor.

14        A.   The police station was in the local community office,

15     Prijedor Dva.  It was there ever since it was established.  That was the

16     seat, and that was the place where everybody gathered.

17        Q.   Is that in Prijedor town itself?

18        A.   Yes.  That is the outskirts of Prijedor, a suburb of Prijedor,

19     but now it's all become one.

20        Q.   Are you familiar with the Keraterm factory in Prijedor?

21        A.   It was also in the area of the Prijedor 2 local commune on the

22     Prijedor-Banja Luka road.

23        Q.   So how far from the Keraterm factory was this located?

24        A.   Perhaps 2 or 2 and a half kilometres.  2 kilometres, as the crow

25     flies.  About 2 kilometres.

Page 15150

 1        Q.   Thank you.  Now, we heard yesterday that your wartime assignment

 2     was to become the commander of the Prijedor 2 station.  About how many

 3     police officers were under your command in that role?

 4        A.   I've already forgotten.  But I think not more than 100.  Up to

 5     100.  Between 80 and 100, approximately.

 6        Q.   And when you worked at the Prijedor main station before your

 7     retirement, how many active police officers worked based out of that

 8     station?

 9        A.   About the same number, as far as I can remember.  It was quite a

10     while ago.  20 years ago, or more.

11        Q.   And when you held the post of commander of the Prijedor 2

12     station, who did you report to?

13        A.   Along the line of reporting, the police station commanders would

14     report to the chiefs of the SUP.  So yesterday when we talked about the

15     stations, I said that there was the centre and the Ljubija police

16     station.  And then the substations were Omarska and Kozarac.  So they

17     were directly connected to the MUP chief, the stations, and the

18     substations were reporting to the stations and the patrol sectors that

19     the station used to cover certain areas, specific areas.

20        Q.   And when you say that you were -- you reported to the chief of

21     the SUP, who was that in 1991 in Prijedor?

22        A.   In 1991, I was retired.

23        Q.   I'm referring to the period of time, sir, when you held the

24     position of commander of the Prijedor 2 station.

25        A.   Oh, when it was activated, that was our wartime assignment in the

Page 15151

 1     reserve Prijedor 2 station when the station was activated in the second

 2     half of 1992, then everybody reported, including myself as the commander

 3     of the station, and the station as the station was reporting to the chief

 4     of the Prijedor MUP.  That's how the organisation was anyway.

 5        Q.   Yes.  If we go back, sir, it's been recorded that the Prijedor 2

 6     station was activated in the second half of 1992.  Was that recorded

 7     correctly?

 8        A.   Yes.  The second half, yes.

 9        Q.   But, sir, your -- the position that you took at the Prijedor 2

10     station was in 1991, was it not?

11        A.   I -- I explained already.  The reserve police stations were

12     formed in the early 1970s, as far as I can remember, and their main

13     function was to prepare a certain number of cadres for possible war

14     circumstances and these were mostly people working on completely

15     different jobs in different organisations, so it was a regular thing to

16     have training from the 1970s, lectures, shooting target practice.  All

17     these things were done by these members of the reserve police forces

18     since that time.

19        Q.   Sir, you were not -- did you not hold the position of police

20     commander of the Prijedor 2 police station in 1992, did you?

21        A.   That is correct, no, I did not.

22             The commander of the reserve police station, Prijedor 2, was

23     something that I did for two months, because then I became the president

24     of the Serbian Democratic Party in Prijedor and I was not able to perform

25     both functions, both the political and the police duty, so there was a

Page 15152

 1     suggestion and an agreement was reached for someone else to take the post

 2     of the commander of the Prijedor 2 police station, and that I should

 3     withdraw from that post and that's what happened.  So Knezevic, Zivko

 4     succeeded me in that post.  Up until that time he was one of the deputy

 5     police commanders in Prijedor.

 6        Q.   Thank you.  And what was his nationality -- ethnicity?

 7        A.   Zivko was a Serb.

 8        Q.   And was he a career policeman, or was he a political appointment?

 9        A.   He was a professional policeman.  He was deputy police commander

10     and he also -- was already retired.  He retired before I, did but he also

11     had his wartime assignment but it was not in the area of Prijedor 2.

12     That was me.  I don't know where he was assigned but after I withdrew, he

13     came and succeeded me in that particular post.

14        Q.   If we just go back a little way, sir, if we can clarify when you

15     held this post as the commander of Prijedor 2, who was the chief of the

16     Prijedor SJB at that time?

17        A.   At the time the party elections were held, there was a change of

18     the leadership cadre structure and some institutions, including the MUP

19     in Prijedor, it was headed by Telundzic.  This was pursuant to the

20     agreement among parties.  Earlier you saw that later there was some

21     problems about the division of power between the parties in Prijedor and

22     this later escalated to certain aggravated situations.

23        Q.   What was the ethnicity of Mr. Telundzic?

24        A.   He was a Muslim.

25             I apologise, I'm using the term "Muslim" throughout this time

Page 15153

 1     because, at that time, that was the term that was used.  I don't know if

 2     there are problems or not with me using that term, but I would like to be

 3     quite clear about that.

 4        Q.   Thank you.  In 1991, did you know Simo Drljaca?

 5        A.   It just happened that I know Simo Drljaca from boyhood.  His

 6     father, Pero, was a police commander throughout that whole time, after

 7     World War II this was how he was appointed by decree.  Actually, that was

 8     my father.  His father, Veljko, was a policeman under my father, so it

 9     just happened in these circumstances that we knew each other.  But we

10     didn't really meet or see each other or socialise after that boyhood

11     period.  He worked in the social community for high school education and

12     he was in the education profession.  He was a -- dealing with teachers,

13     professors.  That was his profession.

14        Q.   And it's correct, sir, isn't it, that he lived not far from you

15     in the town of Prijedor?

16        A.   He lived in the centre of town.  I lived in Urije.  We -- I have

17     a family house there.  My father had a house there, and I built myself a

18     house behind it.  So whether it was close or -- or far, it's a relative

19     thing.  He lived in the centre of town, and I lived in Prijedor Dva.

20     It's about 2 kilometres from the centre.

21        Q.   In 1991, what position did Simo Drljaca hold?

22        A.   In 1991, Simo was the secretary of the self-interest community

23     for high school education.

24        Q.   During the -- during the two months that you held the position of

25     commander of the Prijedor 2 station, what -- what -- what was your

Page 15154

 1     obligation to report matters to the chief of the -- the SUP?

 2        A.   Nothing particular.  Regular daily activities, everything that is

 3     part of police work, anything that is recorded out in the field.  This

 4     would be reported to me by the policemen, and then I would report back to

 5     the chief.  And it -- this also applied if there were any kind of

 6     problems that happened.

 7        Q.   And what form did the reporting take?

 8        A.   Well, mostly often this was at the collegium meetings where the

 9     commanders of the police and other cadres were called.  For example, you

10     had the inner collegium and the broader collegium in Prijedor.  The inner

11     collegium was the top leadership, and the broader collegium consisted of

12     lower-ranking leaders in the Prijedor MUP.

13             MR. KRGOVIC:  Why this is relevant?  It's 1991.  It is out of

14     scope of the indictment.

15             JUDGE HALL:  Ms. Pidwell.

16             MS. PIDWELL:  It's background information, sir.  This police

17     station was operational during the indictment period, and it's the

18     Prosecution's case that this is relevant to what happened a few months

19     later in this municipality.

20             JUDGE HALL:  Yes.  Please proceed.

21             MS. PIDWELL:  Thank you.

22        Q.   Now, sir, were you involved in the -- in the multi-party

23     elections that took place at the end of 1990?

24        A.   Yes.

25        Q.   And --

Page 15155

 1             THE INTERPRETER:  Interpreter did not understand what the witness

 2     said.

 3             MS. PIDWELL:  Sorry --

 4             JUDGE HALL:  The witness -- Mr. Witness, could you please repeat

 5     your answer.  The interpreters didn't get it.  Thank you.

 6             THE WITNESS: [Interpretation] I did take part in the elections in

 7     1991, as a citizen.

 8             MS. PIDWELL:

 9        Q.   And please correct me if I'm wrong, but there were 90 seats.

10        A.   1990 or 1991.  The elections were either in 1990 or 1991.  I

11     don't recall exactly whether it was 1990 or 1991.  The multi-party

12     election.

13        Q.   Sir, please correct me if I'm wrong, but there were 90 seats in

14     the Municipal Assembly of Prijedor; is that correct?

15        A.   I don't recall that.  I wasn't directly involved in the work of

16     the electoral commission.  I took part in the elections as a citizen.

17        Q.   Are you aware that after the elections the key positions in

18     Prijedor were distributed according to party positions?

19        A.   This was done in the municipality.  This was an agreement that

20     was not of something that we had any influence on.  They agreed and took

21     certain posts on the basis of results of the multi-party elections.  And

22     the citizens, we were informed about that, who took which post, who was

23     the president, who was the secretary, the vice-president, the president

24     of the Executive Board.  That is when we were informed about it as

25     citizens.  But these were talks that were conducted within and among the

Page 15156

 1     political parties, and as citizens, we didn't know about it until they

 2     informed us about the situation.  We didn't know how this was done.

 3        Q.   I have just received a message, a request from the interpreters

 4     that if possible, you could slow down so they could catch what you are

 5     saying.

 6        A.   No problem.  One speaks in the usual way that I'm used to, but I

 7     will just try to pause a little bit.

 8        Q.   Thank you.  Now after these elections, some commissions were set

 9     up by the individual parties to try and negotiate those positions that

10     couldn't be agreed upon.  Do you recall that?

11        A.   That's what I find as a situation which means that the

12     commissions had existed before but they couldn't agree on anything.  When

13     I became party head, that was one of the crucial problems that could --

14     could have generated a crisis in the area.  And as the head of the party,

15     I wanted to have proper information, and that's why I placed myself as

16     the leader of that commission that was supposed to negotiate with the

17     other parties.

18             And let me just finish this.  Our first talks with the

19     representatives of the SDA in -- on the premises of the tax authorities

20     were one of the representatives of the SDA and the member of their

21     commission was also an official of the tax administration was successful.

22     There was a lot of goodwill and we managed to distribute positions

23     amongst ourselves within the first half an hour.  And we agreed that on

24     the following day, we would continue distributing the other 50 percent of

25     the functions and positions, but that meeting, on the following day,

Page 15157

 1     actually never materialised.

 2        Q.   And just to clarify, sir, which party were you representing?

 3        A.   Of the Serbian Democratic Party, because I was also its

 4     president.  And there was a lot of goodwill on both sides, in both

 5     commissions, and within the first two hours we managed to distribute 50

 6     per cent of the functions.  We were supposed to continue the following

 7     day, however, the SDA commission was blocked by their political

 8     leadership.  Therefore, the talks never continued after that.

 9        Q.   Were you a member of this commission before you became the party

10     president in September?

11        A.   No, I did not know that it existed.  I was not involved.  Only

12     when I became party leader I learnt about that.  And in order to gain

13     proper information, I put myself at the head of the commission and our

14     first task was to distribute functions and positions in the territory of

15     the municipality of Prijedor.

16        Q.   Right.  Let's have a look at some those functions and positions.

17             What position was held by Muhamed Cehajic in 1991 when you became

18     party leader?

19        A.   Cehajic.  Muhamed Cehajic was president of the Municipal Assembly

20     of Prijedor, according to the party results that ensued as a distribution

21     of political positions in the authorities, in the government.

22        Q.   And which party was he a member of?

23        A.   The SDA.

24        Q.   What about Milomir Stakic?

25        A.   Milomir Stakic was vice-president of that same Assembly,

Page 15158

 1     Cehajic's vice-president.

 2        Q.   And which party was he a member of?

 3        A.   The SDS.

 4        Q.   What about Milan Kovacevic?

 5        A.   Milan Kovacevic was the president of the executive board, the

 6     president of the executive power on behalf of the SDS, the Serbian

 7     Democratic Party.

 8        Q.   Do you recall Dusan Baltic?

 9        A.   Baltic.  Yes, I do remember him.  He was the secretary of the

10     assembly.  He was a lawyer by profession.  He a degree in law.

11        Q.   Which party was he a member of?

12        A.   I don't know if he was a member of any party, but if he was, then

13     he was a member of the Serbian Democratic Party.

14        Q.   What was his ethnicity?

15        A.   Serb.

16        Q.   Let's turn now to Milorad Milakovic?

17        A.   Milakovic?  He was nothing.  Did he not hold any positions either

18     in the police -- or, rather, he was the first president of the

19     Serbian Democratic Party, and then he was replaced by Srdjo and then

20     there were problems, I don't now what problems, and then I followed as

21     the third in that sequence.

22        Q.   When you say Srdjo, do you mean Srdjo Srdic?

23        A.   Srdjo Srdic, yes.

24        Q.   Can you tell us who Radomir Neskovic was and his position?

25        A.   Radomir Neskovic was a member of the Main Board of the

Page 15159

 1     Serbian Democratic Party of Bosnia and Herzegovina; later on, Republika

 2     Srpska.

 3        Q.   And Colonel Arsic?

 4        A.   Colonel Arsic was an active JNA officer, and he was deployed in

 5     Prijedor.

 6        Q.   What was his ethnicity?

 7        A.   Serb.  And he also hailed from Serbia.  He was not a native of

 8     our area.

 9        Q.   Who was Dragan Savanovic?

10        A.   Dragan Savanovic was a member of the Serbian Democratic Party

11     from day one.  He became a member even before me.  He participated in the

12     multi-party elections and he was a deputy in the municipality.  And there

13     were Serbs in other parties who also participated in the work of the

14     Assembly but he was also the president of the group of Serbian

15     representatives in the Municipal Assembly of Prijedor.

16        Q.   Thank you.  Mirza Mujadzic.

17             Sir, who was Mirza Mujadzic?

18        A.   Mirza Mujadzic was a physician in the health centre in Prijedor,

19     and after the multi-party elections, he was elected as the president of

20     the SDA, the Party of Democratic Action of the Municipal Board of

21     Prijedor.

22        Q.   And, finally, if you could tell us who Slobodan Kuruzovic was?

23        A.   Slobodan Kuruzovic was a teacher in one of the primary schools.

24     I don't know in which one.  And his war assignment was to be the

25     commander of the TO.  He was a reserve major.  That's the rank that he

Page 15160

 1     held.

 2        Q.   What was his ethnicity?

 3        A.   Serb.

 4        Q.   Now, sir, we know that you became the president of the SDS party

 5     in September of 1991.  I want you now to have a look at a document.  It's

 6     65 ter 10284/50.

 7             MS. PIDWELL:  P1236.

 8        Q.   While that's coming up on the screen, sir, over the last couple

 9     of days, do you recall listening to the audiotape of two intercepts, two

10     telephone conversations?

11        A.   I apologise.  Repeat your question.

12             MR. KRGOVIC: [Interpretation] Your Honours, once again I would

13     have to object to this line of questioning.  Again we're in 1991.  The

14     intercept between Radovan Karadzic and other participants, why is that

15     relevant for this case?  Why are we dealing with 1991 and we're not

16     dealing with anything that is relevant for this indictment and for this

17     trial.

18             JUDGE HALL:  1991 intercept, Ms. Pidwell?

19             MS. PIDWELL:  Yes, Your Honour.  It's an intercept between this

20     gentleman, two others and Radovan Karadzic.  Your Honours are aware that

21     JCE forms a large part of our indictment, and it shows the relationship

22     between the two, the arrangement that were put in place by the SDS in

23     1991 or the events that took place in 1992, and in my submission it is

24     fully relevant.  It is already an exhibit, Your Honour, and this man was

25     involved in the conversation.

Page 15161

 1             JUDGE HALL:  I see.

 2             MR. KRGOVIC: [Interpretation] Your Honours, but what has it got

 3     to do with this indictment and with the police and with this trial?  This

 4     is not the Karadzic trial, is it?

 5             JUDGE HALL:  Mr. Krgovic, isn't it the rule of evidence that --

 6     and procedure, that, whereas, an indictment has to be drawn with a

 7     certain measure of precision in order to make a trial manageable, the

 8     events which -- out of the context of which that indictment or the

 9     allegations come, doesn't exist in isolation and therefore it is

10     permissible as a matter of evidence to set the context in which the

11     relevant charge is laid.

12             Isn't that the well-settled rule, Mr. Krgovic?

13             Please proceed, Ms. Pidwell.

14             MS. PIDWELL:  Thank you, sir.

15        Q.   Sir -- do you recall listening to an audio version of this

16     intercept a couple of days ago?

17        A.   I have to inform the Trial Chamber about that conversation.

18             During that conversation, I was not the president of the SDS.

19     They had approached me four or five times with a proposal but I refused.

20     I didn't want them to deal with my name.  I didn't know the people that I

21     was supposed to work with.

22             On the fourth or fifth occasion, they managed to convince me to

23     join the party.  I felt at that time that it was my obligation to help as

24     much as I could.  They thought that I met all the requirements, that's

25     how I accepted, and within that context there was a conversation between

Page 15162

 1     Srdjo Srdic who was the president of the party at that time, myself, the

 2     representative of the Main Board, Mr. Neskovic, and Radovan Karadzic as

 3     the president of the party.

 4        Q.   Thank you, sir.  And just on that, when you say "they approached

 5     me," who do you mean?

 6        A.   Well, a commission, a delegation on behalf of the SDS, Savanovic,

 7     Milomir Stakic.  I can't remember them all.  A few of them, in any case,

 8     were members of that delegation.  They had problems and they thought that

 9     I might be able to deal with all the problems in the party, and I

10     accepted eventually and that's when the conversation took place.  I was

11     still not the president of the party.  Srdjo Srdic was the president of

12     the party.  He participated in the conversation, I did as well.  Neskovic

13     was a member of the Main Board who was in charge of dealing with the

14     situation in the party in Prijedor and the president of the party,

15     Radovan Karadzic.

16             THE INTERPRETER:  Could the witness please be asked to slow down

17     and articulate.  Thank you.

18             JUDGE HALL:  Mr. Miskovic, again, the interpreters are asking you

19     to pace yourself so that they can -- I can empathise with you.  I have

20     the same problem.

21             THE WITNESS: [Interpretation] It is very difficult to control

22     what I want to say, my conversation, and the obligation towards others.

23     That's a very difficult thing to do.

24             MS. PIDWELL:

25        Q.   Sir, do you recall listening to this conversation on an audio

Page 15163

 1     cassette in the last couple of days?

 2        A.   Yes, the complete conversation reflect what the conversation was

 3     all about at the time.

 4        Q.   Did you recognise your own voice?

 5        A.   Yes.  I also recognised the context of the conversation.  When I

 6     listened to it, I remember the context of the conversation.

 7        Q.   Where was this call made from?

 8        A.   From Srdjo's apartment.  From Srdjo Srdic's apartment.

 9        Q.   And you've referred to the context and given us a little bit of

10     information about that.  But can you summarise for us why this

11     conversation was made to Dr. Karadzic at this time?

12        A.   The conversation took place because there had been problems in

13     the party.  Neskovic explained that.  There were two streams in the

14     party.  I didn't know all that.  But I suppose that had been the reason

15     why they asked me to join the party because they thought I would be able

16     to deal with all that.  There were confrontations between two streams or

17     two different parties within the party.  One was led by Srdjo Srdic,

18     followed by some older cadre in the party, and the others were all

19     younger, and young people wanted quicker changes and they probably felt

20     animosity toward the older -- the older -- the old being old wanted to

21     control everything in the party and that was the conversation.  And

22     that's why things had to be unified in order to prevent the breakup of

23     the party and modalities had to be found as to how to deal with the

24     situation and how to secure all that, to secure the smooth functioning of

25     the party and not its division.  And from the context of this

Page 15164

 1     conversation, can you see that President Karadzic said if they want to do

 2     so, they can establish their own party.  They can't be on the list on the

 3     SDS and use that to further their own goals.  From that, I can see that

 4     there was a confrontation between the two groups, and I don't know who

 5     was right and who was wrong.

 6             MS. PIDWELL:  If we can turn to the page 3 on the English,

 7     please.  I think it's the same page in the B/C/S.  It's -- sorry.  The

 8     B/C/S is the preceding page, 3006.  Yes, thank you.

 9        Q.   Sir, this is the portion of the conversation between Dr. Karadzic

10     and Neskovic.  And if you --

11        A.   Yes.

12        Q.   And Neskovic is saying that:

13             "They do not recognise any authority here, especially if you

14     mention Sarajevo."

15             Can you see that portion?

16        A.   Yes.

17        Q.   And Karadzic then continues and says:

18             "Whoever refuses to obey Sarajevo should resign.  Write papers

19     for them tomorrow and say this is a party which has its top and its

20     bottom and nobody will fuck under our name, fuck about under our name."

21        A.   Yes.

22        Q.   What do you think he meant by that?

23        A.   I really don't know.  You have to ask him.  As a layman I would

24     say that he's talking about the party policies and that everybody has to

25     subscribe to those.  Either you fall in or you leave, and that's the case

Page 15165

 1     all over the world.  You can't be against the party and be a member of

 2     it.

 3             MS. PIDWELL:  If we now go to the next page in the English,

 4     page 4.  The next page in the B/C/S.

 5        Q.   This is a portion where you see you come onto the line.  And

 6     Karadzic says:

 7             "Put Miskovic on, please."

 8             Did you know Dr. Karadzic at this time?

 9        A.   No.  I knew him from the press.  I knew all of them after the

10     pre-election campaigns and the activities that they were involved in.

11        Q.   So this was the first time you'd actually spoken to him?

12        A.   Yes, yes, yes, the first time.

13        Q.   And he -- sorry.  You start talking about the Main Board.  Which

14     Main Board are you talking about when you say:

15             "I'm not a member of the Main Board?"

16        A.   The Main Board of the Serbian Democratic Party in Prijedor, or,

17     rather, not the Main Board but the Municipal Board.  I said the

18     Main Board because I was not aware of the organisation that was in place.

19     I had just joined.  So this referred to the Municipal Board most probably

20     I had been informed in the meantime that the president is elected from

21     the Municipal Board and that's why I perhaps said that I was not a member

22     of the Municipal Board but the Main Board and it was my mistake that -- I

23     misspoke and that's the context in which the words were used.

24        Q.   And when Dr. Karadzic says:

25             "They cannot give them carte blanche.  They are implementing the

Page 15166

 1     policies of the party, not the other way around."

 2             What was he referring to?

 3        A.   I was there, and he said that they should further the party

 4     policies not some other policies.  If they wanted to pursue other

 5     policies they had to change their party membership and that's typical of

 6     all parties in the world.  Those who don't like the party they're with,

 7     change things.  They establish new parties.

 8             MS. PIDWELL:  If we go now, please, to page 12 of the English

 9     transcript.  And in the B/C/S, it's the page headed 3013.

10        Q.   This is the portion of the conversation, sir, when Dr. Karadzic

11     is once again talking to Srdja.  That's Srdjo Srdic.

12        A.   Yes.

13        Q.   And he says, Karadzic says:

14             "Srdja, you see it is not working.  The party is stuck.  It is

15     not working.  You have to yield and let someone finish it."

16             Do you see that portion?

17        A.   Yes, I do.  Yes, I do.

18        Q.   And did Srdja Srdic yield?

19        A.   I don't know what they meant.  I was listening to this and I did

20     not hear the conversation or, rather, the words of President Karadzic,

21     but I heard what Srdjo Srdic was saying because I was there.  I don't

22     know what the yielding was all about, and I know that eventually I was

23     elected the president of the party and that Srdja also remained in the

24     party and that the dissidents, as it were, also remained in the party so

25     I really don't know within that -- within what context was this word

Page 15167

 1     used, what was the meaning the word, when he said yielded.  And he must

 2     have yielded since he accepted me as the president of the party.  Did he

 3     not object.  He did not put up any resistance together with the group of

 4     the members of the party that supported him, that was case.

 5        Q.   And you became the president of the SDS party the very next day,

 6     did you not?

 7        A.   11 September 1991.  I was elected at an assembly meeting -- or,

 8     rather, that was the party assembly which held place in the Prijedor

 9     theatre.

10        Q.   And after you took over as the role of the president, did you

11     have regular meetings?

12        A.   Well, my principle was to hold regular meetings, to inform each

13     other, to keep abreast of the problems, to find solutions to certain

14     problems, to find people who will be dealing with problems.  I thought

15     that was the best type of communication for anybody who wanted to do

16     things right.  That was my principle that I adhered to.

17        Q.   How often, on average, would these meetings take place?

18        A.   Once a week.  Once in seven days.  I believe that we even had a

19     regular slot on Thursdays, as far as I can remember.

20        Q.   Were minutes taken of these meetings?

21        A.   Yes, handwritten minutes.  Before me there were no minutes.  No

22     minutes were taken of any of the meetings, so I was forced to give a task

23     to the secretary to write notes, to write the minutes.  I replaced the

24     secretary that I found when I joined and I brought in a new person who

25     was very professional and who kept the minutes of all of the sessions of

Page 15168

 1     the Municipal Board.  His name was Zoran Stanic.

 2        Q.   Sir --

 3             MS. PIDWELL:  Could I please have 65 ter 2662 on the screen?

 4        Q.   Do you see that document before you, sir?

 5        A.   Yes.

 6        Q.   And the title is -- I think we've got the -- go to the next page

 7     on the English, please.  The book of minutes of the Prijedor SDS

 8     Municipal Board meetings, archive book number 7, 1991 volume.

 9             MS. PIDWELL:  And if we just flick to page -- the first page in

10     the B/C/S where it's handwritten; page 3 perhaps.

11             The next page, please.  Thank you.

12        Q.   If you have a look at that, just -- do you recognise the

13     handwriting, sir?

14        A.   This is the 23rd, is that right, 1991?

15        Q.   Yes.  You can see that at the top.

16        A.   That was before my time, before I came to the head of the party.

17        Q.   All right.  Do you remember -- you said there were no minutes

18     taken before you became president.  Is my recollection correct?

19        A.   I didn't find any, and this is why I insisted on it and I even

20     replaced two of the secretaries.  There were two secretaries, and I

21     brought this Zoran Stanic who did the job professionally.

22             As for this one, these minutes, I wasn't there at the time, so I

23     don't know.

24        Q.   Let's go, for example, to a period of time when you were there

25     which is further on.

Page 15169

 1        A.   Yes, after the 11th of September.

 2        Q.   Let's just take a look.

 3             MS. PIDWELL:  Perhaps if we go to page, in the B/C/S, headed

 4     10 -- sorry.  01021655.

 5             And the English is 1 -- 00916443.

 6        Q.   If we just take this as an example, sir, you will see this is a

 7     headed 31 January 1992.  Do you see that?

 8        A.   1992, yes, yes.

 9        Q.   Minutes of the SDS Municipal Board meeting with you presiding.

10        A.   Yes, yes, presiding, yes.

11        Q.   And there's an agenda with three items underneath it.

12        A.   Yes.

13        Q.   Agenda was unanimously adopted.  Says Miskovic gave a briefing on

14     the session of the Bosanska Krajina Assembly.  Do you see that?

15        A.   Yes.  Meeting of the Assembly of Bosanska Krajina, and the

16     Serbian Assembly, and the Serbian Assembly of the B and H.

17        Q.   Does that mean that you had actually gone to an assembly session

18     yourself?

19        A.   I don't remember.  I can see that it says here Bosanska Krajina

20     and the Serbian Assembly of Bosnia and Herzegovina.  I don't know the

21     context.  It says both, Serbian Krajina and the Serbian Assembly of the

22     B and H.  I don't know whether organisation was discussed or something.

23     I cannot remember that now.  But, yes, the information, you can see that

24     it's there.  It says assemblies, in the plural.  The Bosnian Krajina and

25     the Serbian Assembly of the B and H.

Page 15170

 1        Q.   In your role as president of the SDS for Prijedor, did you

 2     attend, on occasion, assembly meetings of the Krajina?

 3        A.   Yes.  I did go from time to time, yes.

 4        Q.   And would you then report back to your own -- to your own region

 5     on whatever was occurring in the assembly session that you attended?

 6        A.   Not the region but members of the Main Board.  I informed them

 7     about everything, you know.  When I was looking at the material I said

 8     that my principle was since the Municipal Board was comprised of members

 9     of the local board, I wanted everyone to be acquainted in the region

10     about what's going on so that everybody would be informed of what is

11     going on.  That was my principle.  Well, as for how much people actually

12     reflect -- respected that request, I don't know.  But, anyway, that was

13     my principle, my approach to these matters.

14        Q.   Thank you.  And if we go to the end of those minutes on that day,

15     which is, in the English, five pages on to 00916447.  And in the B/C/S,

16     it's the page headed 01021662.

17             So this looks like the end of the meeting, and you can see there

18     at the -- the bottom it says:

19             "Minutes drafted by ..."

20             And can you work out who drafted those minutes?

21        A.   It doesn't say here who drafted it.  At least I don't see it.

22     It's not there.

23        Q.   My apologies, sir.

24             MS. PIDWELL:  I need the next page in the B/C/S.

25        A.   Vinko.  Vinko, the secretary.

Page 15171

 1        Q.   Do you know that man?

 2        A.   Yes.  He was one of the secretaries of the Municipal Board.

 3        Q.   What was his full name?  Vinko ...

 4        A.   I've forgotten his last name.  I might remember it later.  And as

 5     for the other one, I have forgotten both his first and last name.  He was

 6     an economist by profession.  Kos.

 7        Q.   Vinko Kos?

 8        A.   Yes.

 9        Q.   If we go back to the preceding page in the B/C/S only, please.

10             Do you see there, sir, where it mentions that Simo Drljaca is

11     appointed the head of the Committee for Internal Cooperation?

12        A.   I do.

13        Q.   What was the Committee for Internal Cooperation?

14        A.   The Committee for Internal Cooperation was a commission that was

15     supposed to monitor the conduct and activities of members of the party.

16     And then later, Simo will be proposed as chief of the MUP from this post

17     here.

18        Q.   And he was -- was he a member of the SDS Municipal Board at this

19     time?

20        A.   No.  He was proposed by Milan Babic, who was a teacher and who

21     was on good terms with him.  Milan Babic was a member of the

22     Municipal Board.

23             MS. PIDWELL:  If we turn to the next page, please, in the

24     English, which is the next meeting, just to give a further example.

25             JUDGE HALL:  Ms. Pidwell, perhaps it is my own impatience, but it

Page 15172

 1     seems to me that, whereas it appears that you're meticulously laying out

 2     a path to take us somewhere, that is it necessary to stop at every street

 3     corner and every feature on the road?  Could we rapidly get to where you

 4     are taking us?  You just prefaced your question about to ask for another

 5     example, the last example which took us about ten minutes, I'm not sure

 6     how illuminating it was.

 7             MS. PIDWELL:  Well, Your Honour, if you will allow me to tender

 8     the book of the minutes of the Prijedor SDS at this juncture, I will

 9     simply do that and carry on.  But if you -- I was laying the foundation

10     to show that this corroborates his testimony that meetings were held

11     every week, minutes were taken, he presided, and obviously we've got a

12     document which show which shows what occurred at those meetings, agendas,

13     minutes, decision made.  If you are happy for me to tender it at this

14     juncture, I will do so and move on to another issue.

15             JUDGE HALL:  Before we rule on that, coming back to the exchange

16     earlier with Mr. Krgovic's intervention about the relevance of these

17     events back to 1991, and remembering well your explanation, would we need

18     all those minute books to be incorporated into the body of evidence?

19             MS. PIDWELL:  If my submission, yes, sir.  And I wonder if the

20     witness could take off his headphones while I provide my explanation.

21             JUDGE HALL:  Yes.

22             Mr. Miskovic, could you kindly remove your headphones.

23             Yes, Ms. Pidwell.

24             MS. PIDWELL:  Your Honours, it's the Prosecution's position that

25     the takeover of Prijedor was meticulously organised from a high level

Page 15173

 1     down through the ranks of the SDS, through to the Municipal Board, down

 2     to the police and the army working in close co-operation together.

 3     The -- the organisation and the minutes which preceded the actual

 4     takeover in April are extremely relevant to the Prosecution proving, not

 5     only that the accused Zupljanin was involved in those events, but also

 6     that the accused Stanisic was involved in terms of the JCE principles and

 7     the involvement of the high-level members of the SDS.

 8             JUDGE HALL:  Could we hear the Defence on this issue.

 9             MR. KRGOVIC:  Your Honours, I find this particular -- this

10     evidence is irrelevant for this case.  And precisely this evidence from

11     1991, the Prosecution must be focussed on particular meeting where this

12     plan was done or prepared.  Not generally put the -- this kind of

13     evidence.  Look at this evidence shown this.

14             So the Prosecution must be focussed on particular meeting when

15     the plan was developed, for example.  Allegedly.

16             JUDGE HALL:  Which was essentially my question, Ms. Pidwell.  Is

17     it possible, is it practical to be more precise in terms of the portions

18     of the minutes on which you are relying rather than just putting the

19     whole -- I -- I don't know what volume of material this is we're talking

20     about it.  It may be that it is so relevantly small that it is

21     insignificant.  But just on the chance, and we're dealing with being

22     burdened with a -- extra paper, is it possible for the Prosecution to be

23     more precise in terms of what it's going to tender?

24             MS. PIDWELL:  Your Honours, I was attempting to be precise and

25     take you through particular meetings as examples of what was incorporated

Page 15174

 1     in the greater context, and then, at the end, to tender the entire book

 2     to show the consistency of these meetings with these examples and

 3     dispersed.

 4             I'm really in your hands as to how you would like me to do this.

 5                           [Trial Chamber confers]

 6             JUDGE HALL:  Ms. Pidwell, what we would invite you to do, what we

 7     would require you to do, is to bring the witness who is presently on the

 8     stand home to the various portions of the minutes which are relevant to

 9     what you are trying to prove, rather than tendering -- just putting the

10     whole book of minutes in, or books of minutes in.

11             JUDGE HARHOFF:  Sir.

12             MS. PIDWELL:  Can we have, please, page 00916397 - it's back - on

13     the screen, please.  Page 62 in e-court.

14             And it's page 1002 -- sorry.  01021594 in the B/C/S.  Page 91.

15     Sorry, I need to start with the commencement of that session.  So that

16     would be 01021591 in the B/C/S.

17             JUDGE HALL:  Ms. Pidwell, although we're about four minutes ahead

18     of the usual time for rising, it seems that this might be a convenient

19     point to take the break, since you're likely to send some time on this.

20             MS. PIDWELL:  Yes.

21             JUDGE HALL:  And I alert counsel that when we take the next break

22     at 12.05, it will be a 35-minutes duration.  We will be resuming at

23     12.40.

24             We rise.

25                           [The witness stands down]

Page 15175

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

 2                           --- On resuming at 10.50 a.m.

 3             JUDGE HALL:  I just wish to modify briefly what I said about the

 4     time for the next break.  We will rise at 12.10 and resume at 12.40.

 5                           [Trial Chamber confers]

 6                           [The witness takes the stand]

 7             JUDGE HALL:  Ms. Pidwell, I suppose this is an reason why you're

 8     taking us back to the meeting of the 11 of September, 1991?

 9             MS. PIDWELL:  There is, Your Honour.  It is the day he was

10     appointed as the SDS president and on his own evidence was the day that

11     he was involved from -- as the party's president from then on.  I will

12     then take you to -- I have selected five additional entries, 11th of

13     September, 27th of December, and then three entries in February from this

14     book of minutes.

15             JUDGE HALL:  Thank you.

16             MS. PIDWELL:

17        Q.   So before the break, we were reviewing entries from the book of

18     minutes from the Prijedor municipality, municipal organs of the

19     Serbian Democratic Party.  You will see on your screen the minutes of the

20     11th of September, 1991.

21             MS. PIDWELL:  And if we go to the third page in the English, so

22     headed 6399, and in the B/C/S, it's the page headed 1594.  Sorry, the

23     English should be 6399.  6399.  64.  And the B/C/S should be headed 1594.

24     That's it.

25        Q.   We see your name there, sir, under number 1, about halfway down

Page 15176

 1     the page, being proposed as a candidate for the post of president of the

 2     SDS.  Do you see that?  And --

 3        A.   Yes, yes, I see it.

 4        Q.   And at the bottom of the page we see the conclusions of the vote,

 5     with you receiving 121 votes and your opponent 13.

 6        A.   The second candidate, 13.

 7        Q.   Is that a true reflection of the voting at the time, to your

 8     recollection?

 9        A.   Yes, yes.

10        Q.   I want to take you now to the minutes of the 27th of December.

11             MS. PIDWELL:  Page 103 in e-court for the English, and page 144

12     in the B/C/S.

13        Q.   Do you recall attending the -- this meeting on the 27th of

14     December in your role as president?

15        A.   Yes, yes, of course, as the president, I must have done, for

16     sure.  And I presided over the meeting too.

17        Q.   And we see there, after the agenda, under number 1, that you read

18     out the instruction delivered to the Prijedor Municipal Board of the SDS

19     by the Serbian Assembly.  Do you see that?

20        A.   Yes.

21        Q.   What instruction is that referring to?

22        A.   From what I can see at the end, this is Variant B that was

23     involved, and then it says:

24             "Variant B."

25             I assume that that's that.

Page 15177

 1        Q.   From your perspective of the president of the Prijedor SDS, could

 2     you explain what Variant B -- what the instruction was that we know as

 3     Variant A and B?

 4        A.   Well, Variants A and B existed as instructions for the conduct of

 5     the SDS in two different situations.  The first -- in the -- in

 6     municipality.  The first situation was -- would be the one where the

 7     Serbs gained the majority in a general election.  And the other when

 8     somebody else gained a majority.  In Prijedor, those would be Muslims.

 9             So in Variant B applies to Prijedor.

10             What does it imply, actually?  It's about the Serbian People led

11     by the Serbian Democratic Party as the movement for Bosnia who -- and the

12     Serbian People should be protected from any unpleasant surprises that

13     might again lead to the hardship of the Serbian People.  In that context

14     and from the instructions set out in Variant B, you can see that it

15     concerns the preparation of the cadres of the representatives of the

16     Serbian People to react in a case of any danger that might lead to the

17     escalation of violence or confrontations and conflicts in that area.  In

18     such a situation, or in that situation, Variant II envisaged the

19     establishment or authorities that would assume responsibility for

20     preventing any confrontations.  In that -- with that view, the shadow

21     cabinet was formed that composed of Serbian members of the government and

22     others who were not government members.  The Territorial Defence

23     functioned along the same principle as a military formation.  The head of

24     the Territorial Defence in Prijedor was Slobodan Kuruzovic.  And the

25     chief of the MUP was Simo Drljaca who was appointed at Babic's proposal.

Page 15178

 1     That was all on paper, as it were.

 2             That's how it was until -- for as long as there was a threat of

 3     confrontations in the territory of Prijedor.

 4        Q.   From whom did you receive these instructions?

 5        A.   Received those at a meeting in Sarajevo -- or, rather, in Pale, a

 6     meeting that we attended, but I can't be sure of the exact location.  All

 7     party presidents were present at the meeting, as well as deputies in the

 8     National Assembly.  The paper was distributed, and we were asked to act

 9     accordingly and to convey the instructions to the Municipal Boards and

10     inform them about the existence of the two variants.

11        Q.   Who presided over that meeting in Sarajevo?

12        A.   The president of the party, Radovan Karadzic.

13        Q.   I want to take you now to the minutes of the meeting on the 7th

14     of February.

15             MS. PIDWELL:  And if we can have, please, page P113 in e-court in

16     English.

17             THE WITNESS: [Interpretation] 7 January, or, rather, 7 January.

18             MS. PIDWELL:  Just one moment.

19             THE WITNESS: [Interpretation] Can you take another look?  I

20     believe it is the 7th of January, 2002.  That's, I believe, what you have

21     in mind.

22             MS. PIDWELL:

23        Q.   Well, if we are doing it chronologically, yes, sir.  But I'd like

24     to take you to the meeting on 7 February meeting.  Which is on page P113

25     in English.

Page 15179

 1        A.   I apologise, I apologise.

 2             MS. PIDWELL:  And in the B/C/S, it's 161.

 3        Q.   So we see here the minutes from the 7th of February with a note

 4     that every Thursday at 1700 a meeting of the SDS Prijedor Municipal Board

 5     is held.

 6             Do you see that?

 7        A.   Yes, yes, yes.  I have already told you, as far as I can

 8     remember.  You can see that is what has been established, that we would

 9     be meeting once a week.  And it is a Thursday, just as I told you it was,

10     that there was a slot on Thursdays.

11             MS. PIDWELL:  And can we go, please, to page 6452 in the English.

12     And 1671 in the B/C/S.

13        Q.   I know it's difficult to read, sir, but there is a portion there

14     which in the B/C/S - it may be on the preceding page - but it has got

15     your name above it, Miskovic and it starts:

16             "Since no specific accusations have been brought up ..."

17             The portion I want to draw your attention to is where you say --

18     or it's recorded as you saying:

19             "Our option is to create a Serbian state.  There is also the

20     constitution of the Autonomous Region of Krajina and we are waiting for

21     the final solution.  Block what we can, until the Serbian state is

22     defined under any option.  That is why it is demanded of all of us to as

23     people do our best for the salvation of the Serbian People."

24             Do you see that portion, sir, in the minutes?

25        A.   No, I don't.  I can't find it.  I'm looking, but I can't find it.

Page 15180

 1             Where is that?  Am I looking at the right page?  Ah, now have I

 2     got it, our -- yes, "option."  Our option is to create ...

 3             Where does it say that I'm the one who says this.

 4        Q.   Sir, if you look at the top of the page --

 5        A.   I don't see it.  I can't find it here.  Aha, Miskovic here, okay.

 6        Q.   Do you accept, sir, that's a --

 7        A.   I have got it now, yes.

 8        Q.   Do you accept, sir, that that's a true record of what you said at

 9     that meeting?

10        A.   Probably, yes.

11             Well, I can't read everything.  I would like to be able to see

12     the context and the reason why I said what I did, why this was said in

13     the first place.  What was the context of the whole thing.

14        Q.   Sir, I want to take you now to the -- a meeting the next week on

15     the 13th of February.

16             MS. PIDWELL:  In the English --

17             THE WITNESS: [Interpretation] Because it says here three options.

18             MS. PIDWELL:  In the English, it's page 119 in e-court.

19             And -- sorry.  The B/C/S is page 170.

20        Q.   This is minutes of a meeting a week later, on the 13th of

21     February.  Once again, at 1715, chaired by you?

22        A.   Yes, yes.

23        Q.   Do you see that?

24        A.   Yes.  I chaired every one of them.  There's no dispute about

25     that.

Page 15181

 1             MS. PIDWELL:  Can we turn now to the next page, please, on each.

 2     Thank you.

 3        Q.   I just want to draw your attention to item number 3, if you can

 4     make it out.

 5        A.   Among --

 6        Q.   Sorry, in the B/C/S, it's the next page.

 7             Just after halfway down the page, sir, there's an item, number 3

 8     which is headed any other business.  Do you see that?

 9        A.   Any other business, yes, yes.

10        Q.   And it states there that:

11             "Meeting of the Main Board in Sarajevo is scheduled for tomorrow

12     and the local board members and the vice-president are going."

13             Do you see that?

14        A.   No, I don't.  Under 3, I can see any other reasons meeting of the

15     Main Board in Sarajevo is scheduled for tomorrow and as standing for --

16     deputies are going and the vice-president.  And the vice-president.  I

17     don't know who the vice-president is.  I don't know who went.

18        Q.   Sir, do you recall a meeting which took place on the 14th of

19     February at the Holiday Inn in Sarajevo?

20        A.   I do.  That was in 1991, or thereabouts, I think.  I think it was

21     in 1991.  Or maybe 1992, at the beginning.  Or in 1991, I -- I believe.

22     When communication was still normal, when relations were still normal.

23             MS. PIDWELL:  I have one more entry to go, but just -- I'm going

24     to move to another document and I'll come back to the last entry in this

25     series of minutes.  If I could have 65 ter 01725.  It's P1358-17.

Page 15182

 1                           [Prosecution counsel confer]

 2             MS. PIDWELL:  Sorry, that's the wrong document.  It's P1353 --

 3     sorry.  I said 58.  1353.17.

 4             MR. CVIJETIC: [Interpretation] Just the table number, please, or

 5     the tab number.

 6             MS. PIDWELL:  Tab 13A.

 7             I apologise, Your Honours.  This is an ERN range.  It's a series

 8     of receipts and trying to identify the particular one which relates to

 9     the witness.

10                           [Prosecution counsel confer]

11             MS. PIDWELL:  I'm told that the quickest way is to put it in

12     Sanction, if Your Honours are happy with that.

13        Q.   Sir, do you see this -- this document in front of you, and are

14     you able to read it?

15        A.   Not really.

16        Q.   Would you expect that it's a receipt from the Holiday Inn hotel

17     in Sarajevo in your name?

18        A.   Well, I can see it is.  But I can't see my name.  But that

19     doesn't mean I wasn't there.  I was.  But I can't see it in here.  I

20     don't see my own name on this receipt, and I can't see the date well

21     either.  But I did spend the night at Holiday Inn.  I was there.

22             Now I can see it in this receipt.  I can see Miskovic,

23     15 February, but I don't know what year.  Well, I -- I certainly was at

24     Holiday Inn.  I attended a meeting of the Main Board.  I also overnighted

25     at the hotel.  There's no dispute about that at all.

Page 15183

 1        Q.   Let's move on then.  Back to the book of minutes, please, and

 2     we'll go to the last entry that I want to deal with, which was on the

 3     17th of February.

 4             JUDGE HARHOFF:  Mr. Miskovic, while we're waiting for the next

 5     document to come up, I think there's still an outstanding issue of

 6     exactly which year you were at Holiday Inn.  Was it from the 14th to the

 7     15th February, 1991, or 1992?

 8             THE WITNESS: [Interpretation] I can't remember.  I only remember

 9     that the relations were still normal, which means that all parties and

10     party representatives communicated, and I know that after having spent

11     that night in Holiday Inn, in the morning, I met Mirza Mujadzic, an SDA

12     member.  He had come in a Golf II car of green colour.  I asked him where

13     he got the car from, and he says, Alija gave me, and then we joked and I

14     told him, Well, we don't have the money to buy cars, why don't you get us

15     the money to buy a car for us.  Then relations were still normal.  We

16     still joked together.  We joked around, and things were quite differently

17     then.  And I'm still not sure about the date.  And I'm not disputing the

18     fact that there was a meeting, that we overnighted at the hotel.  There

19     is nothing in dispute about that.

20             JUDGE HARHOFF:  Of course, it makes a great difference whether

21     this meeting took place in 1991 or 1992.

22             But I give the floor back to Ms. Pidwell.

23             MS. PIDWELL:

24        Q.   Sir, when you attended this meeting, was it in your capacity as

25     president of the SDS Prijedor?

Page 15184

 1        A.   Yes, as the president of the Municipal Board of the SDS in

 2     Prijedor, and members of the National Assembly from Prijedor also

 3     attended.  Srdjo Srdic and Timara Teser [phoen].

 4        Q.   And we know that you were elected on the 11th of September, 1991;

 5     is that correct?

 6        A.   Yes.

 7        Q.   So by natural common sense, if you attended this meeting after

 8     your election as president, it would have been in the year 1992; is that

 9     correct?

10        A.   I said that that either was in late 1990 or early 1991.  But I

11     don't know exactly when it was.  All I know is that the relations were

12     normal and that we were still able to crack jokes together.  And that's

13     the only time that I spent a night at Holiday Inn.  That was the only

14     occasion for me.

15        Q.   Sir, you said late 1990 or early 1991.  In late 1990 and early

16     1991 --

17        A.   No, no, late 1991.  I misspoke, I'm sorry.  1991 or early 1992.

18     I misspoke, I apologise.

19        Q.   Thank you.  Let's go back to the book of minutes and this may

20     clarify things once and for all.

21             MS. PIDWELL:  Let's go to the 17th of February.  English, it's

22     page 122; and the B/C/S, in e-court, it's 174.

23        Q.   Sir, the first item on the agenda we see is the briefing on the

24     meeting of the Main Board and the Serbian Assembly of BH.  And then it

25     reads:

Page 15185

 1             "After adopting the agenda (28 items) Simo Miskovic,

 2     president, ... gave a briefing on the meeting held in Sarajevo."

 3             Do you see that?

 4        A.   Yes, I do.  Yes, that's all right.  You see that was an assembly

 5     meeting.  I thought it was a Main Board meeting, but it was an assembly

 6     meeting, as can you see.

 7        Q.   And --

 8        A.   Of course, I'm talking about party meetings.

 9        Q.   And there's a report there, your report, that Dr. Karadzic was

10     the main speaker; do you see that?

11        A.   Yes, yes.  As the party president.

12        Q.   And you report that there's been an act of cessation of the BH --

13     do you see that?

14        A.   Cessation of Bosnia-Herzegovina on the part of the SDA.  And in

15     that sense, we were forced to create national or ethnic communities.

16     That's how I read it.  National communities on -- on problems.

17        Q.   So you're --

18        A.   I don't know.  I can't ...

19             The position of the European community was stated.  The European

20     community will not interfere with internal solutions of the -- that's all

21     in the minutes, the discussion on the Serbian, so on and so forth.

22        Q.   Yes, sir.  Do you recall that you're relaying, or are you

23     relaying what -- what was -- what occurred at the meeting in Sarajevo

24     back to your Municipal Board?

25        A.   That was a rule I followed, and I did it at that time.  I always

Page 15186

 1     informed the Municipal Board and since Municipal Boards were also

 2     composed of presidents of local boards, I asked them to inform members at

 3     local levels.  That was the principle of work I always followed.

 4        Q.   Thank you.

 5             MS. PIDWELL:  Now we can move -- I think the English is the same.

 6     But if we could move, please, to the next page in the B/C/S.  It's about

 7     halfway -- the second paragraph in the B/C/S, so halfway down the page.

 8        Q.   You see it's a continuation of your report on this meeting.  And

 9     it stated there that you reported:

10             "That Serbs shall not participate in any way in the referendum

11     conducted by the SDA."

12             Do you see that?

13        A.   I can't find that, but I know that that happened.  His

14     participation in -- or in the aspect in the referendum, which has been

15     conducted by the SDA ... in view of that.

16        Q.   What referendum --

17        A.   To activate the second page of the position stated by the SDS BH

18     Main Board.  Or, rather, to activate the territory and the population,

19     Serbs, in brackets, by activists.  It -- I don't know.  I can't read it.

20     I can't --

21        Q.   I appreciate it's difficult, sir.  But do you -- my question is:

22     Was there a direction for the Serbs not to participant in the referendum

23     which was being conducted by the SDA at that time?

24        A.   Well, of course, it was.  Because the goal was to secede Bosnia

25     and Herzegovina from Yugoslavia and that's the context of the entire

Page 15187

 1     story, and, in that regard, the Serbs thought that it would be

 2     threatened, and for that reason they refused to participate in the

 3     referendum because the decision on the referendum was worded in that

 4     sense, and it was made by the rump assembly of Bosnia and Herzegovina and

 5     they excluded representatives of the Serbian People from any of that.

 6        Q.   And was there also a direction to activate the second stage of

 7     the Variant A and B instruction?

 8        A.   I don't know if it was at that point in time, but you can see

 9     from the document that it was activated at the point in time when there

10     was a threat that there could be a confrontation, a conflict, escalation

11     of the conflict.  In that case the Variant B would go into effect.  And

12     as you could see, following the entire course of the events, and after

13     the takeover of power, that there were no confrontations.  It -- they

14     didn't happen before or after that until the incidents that led to the

15     escalation of events.  I'm talking about the genesis of events, actually,

16     until this formation.

17        Q.   The minutes that we're looking at, sir, say -- or report that

18     it's necessary to activate the second stage of the position stated by the

19     SDS, BH Main Board, namely, Variant A and B at this time.

20             Do you accept that at this meeting --

21        A.   Variant B, yes.

22        Q.   Do you accept that at this board meeting the conclusion was made

23     to activate the second stage of Variant B, by the Prijedor Municipal

24     Board?

25        A.   You mean was that a decision by the Municipal Board at the time

Page 15188

 1     that work should be done on the activation of Variant B?  Is that what

 2     you meant?  If that's what you meant, then, yes.  Preparations.

 3             MS. PIDWELL:  And if we turn to the next page in the English.

 4     And in the B/C/S it is the page headed 160, so two pages on.

 5        Q.   There's some discussion there headed by Srdjo Srdic about the

 6     Serbian coat of arms anthem and flag which was unanimously adopted by the

 7     Municipal Board.  Can you see that in your version?

 8        A.   Yes.  I can see that it says Srdjo Srdic here.  An important

 9     argument about our transformation is our plebescite which we implemented,

10     yes.  The creation ... there was a ... directives emigration, migrations

11     and moving in and the substitution of territories is inevitable.

12             I -- I can't read this.

13        Q.   Just pause, please, sir.

14             MS. PIDWELL:  Your Honours, I've come to the conclusion of the

15     extracts from this book of minutes.

16             JUDGE HARHOFF:  But before we leave the page here, Mr. Miskovic,

17     do you recall what was meant by the substitution of territories?

18             If you read again the last lines of what you just read out from

19     the minutes, do you know --

20             THE WITNESS: [Interpretation] Srdjo Srdic was a deputy from the

21     Prijedor municipality.  Most probably, with a reserve here.  Most

22     probably this was something that was discussed at the Serbian Assembly of

23     Bosnia and Herzegovina in which he took part as a deputy and that he is

24     then informing the Municipal Board about that in this context.  I don't

25     know if, at the level of the B and H, there was a conversation among the

Page 15189

 1     party representatives, I don't know.  He was a deputy, so this is

 2     probably something relating to that, something in which he took part.

 3             JUDGE HARHOFF:  I understand that, sir.  My question to you is:

 4     If you recall, what exactly Mr. Srdic meant when he referred to the

 5     substitution of territories.

 6             THE WITNESS: [Interpretation] Territories.  From this perspective

 7     I can only assume that this was a question of exchanging territories with

 8     the concentration of one population with those -- with the concentration

 9     of the other population.  I mean, I am just assuming that.  I cannot

10     recall that, really, on the basis of this.

11             JUDGE HARHOFF:  But, sir, you were there.  You took part in the

12     discussions about this.  You must have had some sort of an idea what was

13     going to happen and, actually, in light of what later on did happen.

14             THE WITNESS: [Interpretation] What happened later are the

15     consequences.  As I said, most probably, this conversation might reflect

16     something that possibly was a conversation at the top of the leadership

17     in the parliament between party members.  I don't know that, and I assume

18     that Srdjo Srdic was reporting this at our meeting of the Municipal Board

19     because at our meetings, this item was never something that was on the

20     agenda at the Main Board in which -- in the work of which I participated.

21     I know that.  I don't know whether this took place some -- at the

22     parliament or the Serbian Assembly that had split off so I assume that

23     Srdjo Srdic is informing about this as a parliament reporting back the

24     information that has to do with these proposals relating to the exchange

25     of territories.  Everything else that I could say would be incorrect.

Page 15190

 1             JUDGE HARHOFF:  When you -- when you say that there was supposed

 2     to be an exchange of territories, just how was that supposed to -- to

 3     take place?  Do you mean that -- that Muslims would give up territories

 4     in one place in return for getting territories in another place?  Is that

 5     what you mean by the expression "exchange of territories"?

 6             THE WITNESS: [Interpretation] When I said this earlier, this is

 7     precisely what I meant, that this was something discussed and agreed at

 8     some other level.  This was not put on the agenda on the party and it was

 9     never discussed in the Main Board or the Municipal Board.  This is an

10     idea that Srdjo Srdic, as a people's deputy, probably discussed at the

11     Serbian Assembly where suggestions may have been put forward on one and

12     the other side perhaps.  I don't know about that.  He was relaying back

13     information here about that, but I don't know anything specifically about

14     that report.

15             JUDGE HARHOFF:  And just to clarify before I give the floor back

16     to Ms. Pidwell, you are saying that this issue of exchange of territories

17     was never discussed at the Municipal Board in Prijedor?

18             THE WITNESS: [Interpretation] Yes, yes.  Yes, yes.

19             The Main Board where I participated, as far as I know, never

20     discussed that.  It was never on the agenda.

21             MR. KRGOVIC:  Your Honours, just one small clarification for the

22     transcript because it is not properly recorded what the witness say.

23     It's page 42, line 7, witness said when I said this is precisely what I

24     said and it was discussed on the republic level, and after that, this is

25     the ... .

Page 15191

 1             JUDGE HARHOFF:  I'm not sure what to make of your observation,

 2     Mr. Krgovic.  I suppose that what we --

 3             MR. KRGOVIC:  Just maybe please can repeat the answer.

 4             JUDGE HARHOFF:  Please --

 5             Right.  Mr. Miskovic, following the intervention by Mr. Krgovic,

 6     I would kindly ask you to repeat your last answer, if you could.

 7             THE WITNESS: [Interpretation] The party meetings, meetings of the

 8     party of the Municipal Board and the Main Board where I was present, the

 9     topic of exchange of territories was never on the agenda.

10             JUDGE HARHOFF:  Thank you, sir.

11             Back to Ms. Pidwell.

12             MS. PIDWELL:  Thank you, Your Honour.

13             Your Honours, I have, as you see, extracted five or six -- six, I

14     think, days of the minutes from this book.  My submission is that the

15     whole book should be tendered to provide the overall context and

16     continuity of the meetings that were held by the board.  It's one

17     document, if we're talking about a hard copy document and the relevant

18     portions have obviously been highlighted in the transcript.  But in my

19     submission, it's more appropriate for the entire document to be exhibited

20     because there may be other portions of it that become relevant at a later

21     date.

22             JUDGE HARHOFF:  Thank you, Ms. Pidwell.

23             I think you set out to identify the portions of this book of

24     minutes in which the planning of the takeover of Prijedor was discussed

25     or mentioned, and having now seen the five or six passages to which you

Page 15192

 1     have referred, I'm not sure that this refers directly to the takeover of

 2     Prijedor.

 3             So my question to you is:  Are there other passages in the book

 4     of minutes which do address, or mention, or refer to the possible

 5     discussions in the SDS Municipal Board in Prijedor in 1992 to take over

 6     the municipality of Prijedor?

 7             MS. PIDWELL:  Your Honour, it's not as simple as identifying one

 8     or two conversations in this book of minutes about the takeover.  The

 9     takeover was -- perhaps if the witness could take off his headphones,

10     please.

11             JUDGE HARHOFF:  Mr. Miskovic, would you be good enough to take

12     off your headphones, just for a second.

13             MS. PIDWELL:  It's the Prosecution's position that the -- the

14     takeover was planned meticulously at several different levels.  What was

15     happening was instructions were coming from above as -- and there are

16     some examples in the book of minutes of that.  Instructions being

17     received, the Variant A and B, which he then reads out to the board and

18     then is implemented in various ways which are not directly recorded as we

19     are now implementing X, Y and Z of Variant B but within the minutes can

20     you see examples of it actually occurring.  So it's the Prosecution's

21     position that by reading the entire set of minutes, you get a sense of

22     what was happening in the area at the time and the planning that was

23     going on, the discussions that were taking place, the shadow government

24     that was being set out and was waiting in the wings, and this all

25     happened --  and what the witness will say was an extremely successful

Page 15193

 1     bloodless takeover because the -- of the planning that was involved.

 2             Now, we have this book of minutes.  It is contemporaneous with

 3     the meetings that were taking place.  He was authenticated it to the

 4     point where he says, yes, those meetings took place with even the detail

 5     being the time and the place, and so forth, and it's my submission that

 6     this would assist Your Honours greatly when considering the background to

 7     what is -- what took place in Prijedor.

 8                           [Trial Chamber confers]

 9             JUDGE HALL:  Ms. Pidwell, the witness may -- may --

10             You may replace your headphones.

11             The Chamber, by a majority, agrees that the book -- that -- that

12     the minutes, as a whole, could and should be admitted.  However, as a

13     purely practical matter, we are concerned, less immediately than down the

14     road, when we must assess the evidence as to how to -- and I'm trying to

15     avoid the use of the word highlight because it has such a variety of

16     meanings.  We can highlight what it is we ought to be directed to beyond

17     what you have already done by the viva voce evidence you have led from

18     the witness.  Perhaps you are not in a position to answer that particular

19     question now.  We're only saying the book may be admitted.  But we alert

20     you that there is a practical problem which we would need your assistance

21     with.

22             JUDGE HARHOFF:  And for the record, may I add that my dissent was

23     that I think we should admit only the parts that you have shown to the

24     witness and nothing more.

25             MR. HANNIS:  I'm sorry, Your Honour, if you would permit me.  I

Page 15194

 1     know I'm not the lawyer leading this witness, but as one of the two

 2     Senior Trial Attorneys on the case, this is a matter of general concern

 3     and I would like to speak briefly on it, if I may.

 4             These kind of documents, minutes of meetings, for example, I

 5     think I made a similar argument in connection with some of the Assembly

 6     sessions.  I understand your point.  And I understand your fear that

 7     we're giving you 5.000 pages of something and you don't want to have to

 8     read 5.000 pages, and we're not asking to read 5.000 pages.

 9             At the end of the case, when we're making our submissions, we

10     will point to you the portions of collections like this that we think are

11     important, but part of the reason we ask they come in in their entirety

12     at this stage is because at this point we don't even know what may be

13     important.  At the end of the case it may important that on January 2nd,

14     so-and-so was at a particular meeting, made reference to having attended

15     a meeting two days before, and corroborates another document and another

16     witness, something that may come into being a contested issue between now

17     and the end of the case.

18             But then we will address that in our final submissions, and the

19     Defence will address in their final submissions what parts they think are

20     important.  And that's why, as a general matter, some of these things we

21     think it's important take in their entirety so that you don't lose

22     context that may be important at the end of the case.

23             Thank you.

24             JUDGE HARHOFF:  Thank you for this clarification.

25             My immediate observation, speaking only for myself and not on

Page 15195

 1     behalf of the Chamber in this matter, is that we have the witness on the

 2     stand, and I think that the primary evidence to be elicited about the

 3     planning of the takeover of Prijedor, of course, is the witness.  So

 4     let's put the questions to him and see how much he is able to provide us

 5     in terms of evidence of discussions or plans or considerations that may

 6     have been taken place at the time.  And if the witness's testimony can

 7     then be corroborated by reference in the minutes, then that's fine.  If

 8     not, then what we have is the witness.

 9             THE REGISTRAR:  Your Honours, for the record I need to indicate

10     that 65 ter 02662 shall be given Exhibit P01610.  Thank you,

11     Your Honours.

12             JUDGE HALL:  Thank you.

13             Please continue, Ms. Pidwell.

14             MR. CVIJETIC: [Interpretation] Your Honour, I apologise.  If

15     nothing else, then can I just state my objection to the transcript.  I

16     think the Prosecution was obliged to identify the relevant parts now, not

17     in their closing arguments so that we are able to follow the proceedings.

18     I would like to object to the relevance of the document, because I have

19     not established a link with the indictment and what my client is being

20     charged with.

21             JUDGE HALL:  Of course, Mr. Cvijetic, we've already ruled.  But

22     you would have gathered from what has passed between the Bench and

23     counsel for the Prosecution, that we, too, share the concern that the

24     evidence of the -- from the -- from the body of material that the

25     evidence on which they are relying has to be highlighted in some manner.

Page 15196

 1             So we share your concern.

 2             Yes, Ms. Pidwell, please --

 3             MS. PIDWELL:

 4        Q.   Sir, I'm going to take you back in time to a second conversation

 5     you had with Dr. Karadzic in November 1991.

 6             MS. PIDWELL:  And it's tab 6, P1557.8.

 7             JUDGE DELVOIE:  That's not tab 6, Ms. Pidwell.  Sorry.

 8             JUDGE HARHOFF:  In our papers, tab 6 is P1238.

 9             JUDGE DELVOIE:  And unless --

10             MS. PIDWELL:  I appear to have a different version, but it is

11     the -- Your Honour is correct; it is P1238.  It's the transcript of the

12     intercept on the 15th of November that I'm looking for.

13             JUDGE DELVOIE:  Thank you.

14             THE WITNESS: [Interpretation] This is the minutes.

15             MS. PIDWELL:  Sorry, that's P1238.

16        Q.   Do you recall, sir, listening to the audio of this telephone

17     intercept a couple of days ago?

18             JUDGE DELVOIE:  Can we have an English version, please.

19                           [Trial Chamber and Registrar confer]

20             THE WITNESS: [Interpretation] I do remember, yes.

21             JUDGE DELVOIE:  There seems to be no English version,

22     Ms. Pidwell.

23             MS. PIDWELL:  Well, I certainly have one, Your Honour.

24             JUDGE DELVOIE:  Okay.

25             MS. PIDWELL:  There doesn't appear to be one in e-court.

Page 15197

 1             JUDGE DELVOIE:  In e-court, yes.

 2             MS. PIDWELL:  What I might do, Your Honours, is I'll leave that

 3     for a later stage, we'll upload one, and I'll come back to it.

 4             I'd like to go to tab 11, which is 65 ter 399, please.

 5        Q.   You see the document on your screen, sir, is dated the 8th of

 6     January refers back to --

 7        A.   The 7th of January.  The 7th of January.  The 7th of January,

 8     1991.  Yes, I see that's what it says here.

 9             And the date is at the bottom on the left-hand side.  The 8th of

10     January, 1992.  And at the top, it's ...

11        Q.   Yes.  The document is dated 8th of January, 1992.  And it's a

12     decision of the Assembly of the Serbian People of Prijedor, as a result

13     of the session on the 7th of January, 1992.

14             And do you recall that this session on the 7th of January was

15     the -- the session which was the first time that the Serbian

16     municipality -- or the Assembly - sorry - met formally?

17        A.   Yes, yes.  7th of January.

18        Q.   And you elected a president of the assembly at that time?

19        A.   No.  The president of the assembly.  The fax is for the

20     president.  He was already -- the fax was for the elected president.  And

21     also the presidents of the local councils, boards, in order to complete

22     the number of the board members.  It says the 28 representatives of the

23     Serbian -- of the boards and 41 presidents of the local boards of the

24     SDS.

25        Q.   So you're saying -- sorry.  Presidents -- the president was

Page 15198

 1     Milomir Stakic; is that correct?

 2        A.   Yes, yes, yes.

 3        Q.   And are you saying that he was already the president and that

 4     this was simply being formalised in the assembly session when it met for

 5     the first time?

 6        A.   Stakic was vice-president in the joint government.  He was given

 7     that position after the division of powers of the parliamentary

 8     elections.  However, when the Serbian Assembly was established, he was

 9     vice-president, so automatically he became president of that assembly as

10     a Serb, and all the Serbian deputies, whether they were members of the

11     SDP, or whatever it was called at the time, the Social Democratic Party

12     they also became members of that assembly and Milomir Stakic became the

13     president of that assembly, and that assembly was made up by presidents

14     of the local boards in local territories in keeping with the instructions

15     that we had been given.

16             So, in Prijedor, there were 41 of them in total, plus those

17     eight.

18        Q.   And just to clarify, the Stakic who you are referring to is the

19     same one that was indicted by this Tribunal?

20        A.   Milomir Stakic.

21        Q.   Who was the vice-president of the assembly?

22        A.   I can't remember.  I can't remember.

23        Q.   And do you recall what positions the other leaders of the

24     community took at this time?  For example, Kovacevic.

25        A.   Kovacevic was already the president of the Executive Board and he

Page 15199

 1     remained the president of the Executive Board in the Serbian Assembly.

 2             Let me inform the Chamber so that the Chamber knows.  The

 3     establishment of the Serbian Assembly was in case that they were supposed

 4     to take over power, in case we were supposed to secede, we had to have

 5     bodies that functioned already.  They were not functioning.  The joint

 6     bodies were still functioning so this was just the establishment of the

 7     assembly according to Variant B and the Serbian presidents, and Serbian

 8     bodies were established and elected in case there was a cessation of the

 9     Serbian territories from the rest of Bosnia and Herzegovina.  We always

10     wanted to have authorities in place and that's how they had been created

11     and that's how they were composed of, from the cadre that has just been

12     shown.  The joint government still functioning properly at the time in

13     question.

14        Q.   And just to clarify, once again, the Kovacevic that you're

15     referring to is the same one that was also indicted by this Tribunal?

16        A.   Yes, Mile Kovacevic.  After parliamentary elections, he was the

17     president of the Executive Board, and here he was appointed as the

18     president of the Executive Board of the Serbian Assembly.

19        Q.   What role did Simo Drljaca take at this time?  What position?

20        A.   Simo Drljaca, this Drljaca, Drljaca, Simo, was appointed the

21     chief of the MUP.  But as I've told you, did he not perform the duties

22     just like nobody else did.  Those were just bodies that were established

23     just in case.

24        Q.   And just to clarify, the Drljaca that you're referring to is also

25     the same one that was indicted by this Tribunal?

Page 15200

 1        A.   Simo Drljaca, yes, yes.  Simo Drljaca, yes.

 2        Q.   Were there other appointments similar to these where people were

 3     given positions just in case?

 4        A.   The complete authorities, the old institutions, were established

 5     and each of the institutions had its people.  Mr. [indiscernible] was,

 6     for example, appointed the president of the court.  He was a judge in the

 7     basic court, and so on and so forth, so all the institutions had been

 8     covered with physical people.

 9             MS. PIDWELL:  If I could tender that document, please, at this

10     juncture.

11             JUDGE HALL:  Admitted and marked.

12             THE REGISTRAR:  As Exhibit P01611, Your Honours.

13             MS. PIDWELL:  If I could go to tab 12, please.  65 ter 400.

14        Q.   Sir, you see that document on your screen.  It's a decision of

15     the newly formed assembly --

16        A.   Yes.  Based on the book of rules, the assembly, and so on and so

17     forth, very well ... emerging of the -- yes.

18        Q.   And you see it's the decision to join the Autonomous Region of

19     Bosnia Krajina?

20        A.   Yes.  Yes.

21             MS. PIDWELL:  I seek to tender that at this stage, Your Honours.

22             JUDGE HALL:  Yes, admitted and marked.

23             THE REGISTRAR:  As Exhibit P01612, Your Honours.

24             THE WITNESS: [Interpretation] But this decision was not made by

25     the Municipal Board.  It was made by the newly established assembly of

Page 15201

 1     the Serbian People, and the signatory of the document is

 2     Dr. Milomir Stakic.

 3             MS. PIDWELL:  Thank you.

 4             Your Honour, I'm not sure of the timing of the break.  I thought

 5     it was round about now.

 6             JUDGE HALL:  Yes.  So we resume at 12.40.

 7                           --- Recess taken at 12.09 p.m.

 8                           --- On resuming at 12.46 p.m.

 9             MS. PIDWELL:  Yes, if I could have P1238, please.

10             Once again, Your Honours, I think I might come back to that.

11     That's the intercept which we thought we had -- ah, we do have.  I'll

12     stay with it while we have it.

13        Q.   Sir, do you recall listening to the audiotaped intercept

14     conducted on the 15th of November, 1991, between yourself and

15     Radovan Karadzic, a few days ago?

16        A.   Yes, I did listen to all of them.

17        Q.   Did you recognise your voice on the recording?

18        A.   I did.

19        Q.   And did you recognise the voice of Dr. Karadzic?

20        A.   Yes.

21        Q.   And this is an occasion shortly after the plebescite where you

22     instigate a call to Dr. Karadzic; do you recall that?

23        A.   I remember I called him and then they told me that he was asleep.

24     And later on when I called, my first question was, is he still asleep,

25     and then I introduced myself, they told me hang on and they put me

Page 15202

 1     through.

 2        Q.   And do you recall what prompted you to make this call to

 3     Dr. Karadzic at this time?

 4        A.   I wanted to inform him about the plebescite and the result

 5     thereof as there was, indeed, a plebescite in the territory of Prijedor

 6     municipality.

 7        Q.   Yes.

 8             MS. PIDWELL:  And if we can go to the next page, please, on each.

 9        Q.   You'll see at the top of the page in English and in B/C/S you --

10     you say:

11             "Over 60 per cent almost.  We are stronger."

12             What was that in reference to?

13        A.   It was in reference to the ratio of the Serbs versus the Muslims.

14     According to the 1991 census, there were 1 per cent Muslims more than

15     Serbs, and when we were taking names for the plebescite, we listed the

16     entire electoral body for Prijedor and when we ended up with this number.

17             Therefore, I'm informing Mr. Karadzic that, according to that

18     list, there were more Serbs in Prijedor than Muslims.  And I hedged that

19     number a little by about 10 per cent for any mistakes or double names,

20     any mistakes made by those who were compiling the lists.

21        Q.   And you go on to talk about the deadlock that has been in place

22     in your party in Prijedor for the preceding eight months.

23        A.   Not in the party.  Look here, when I presented the data, as you

24     can see in this conversation, when I presented the data, I had consulted

25     with the president of the party in order to see if he has any proposals

Page 15203

 1     for any activities with regard to the situation we established on the

 2     ground.  And then he told me to -- or, rather, he -- I draw his attention

 3     to the fact that the work of the Municipal Assembly of Prijedor was

 4     blocked because of the -- the inability to divide the powers and sectors

 5     in the municipality between the parties.  I'm telling him the work of the

 6     Municipal Assembly has been blocked for eight or nine months.  I suppose

 7     that this due to the division of powers.  That's what I'm saying.  And I

 8     ask him -- and I don't understand why I said this.  Government elections

 9     that is what I meant.  I wanted to consult you, Simovic, and Krajisnik.

10     I wanted to see with you, to analyse everything, to see exactly and to

11     know what, who, and how.  I don't want to do anything before we analyse

12     things.  I want to be sure when I do something.

13        Q.   What exactly were you -- what information or direction were you

14     seeking from Dr. Karadzic at this time?

15        A.   How to move on.  The facts are there, the numbers are there.  The

16     assembly has been in a deadlock for eight months.  We cannot go on living

17     like that.  There's a threat of new conflicts because there was no legal

18     authorities, and that's why I'm consulting the president to see what to

19     do, given the situation as it was.  Because all of our efforts had fallen

20     through.  And the plebescite had been organised in order to see what to

21     do next.  The Serbs were against seceding from Yugoslavia, and in my

22     proofing session, I told you that some of the Muslims had also voted in

23     the plebescite and were in favour of Bosnia and Herzegovina remaining in

24     Yugoslavia.

25        Q.   And what -- do you recall what instruction you actually received

Page 15204

 1     from Dr. Karadzic?  What were you to do with this result?

 2        A.   I don't know.  I don't know what he told me.  You can't see it in

 3     this conversation.

 4             He referred me to Simovic.  He told me to talk to him.  Simovic

 5     was a lawyer and he could probably advise me better.  But whatever they

 6     gave me, whatever they told me, they asked me to comply with the

 7     constitution and with the laws, that I shouldn't do anything that went

 8     beyond the constitution and the laws that were in effect.

 9        Q.   Did you hold fresh elections in the municipality?

10        A.   No.

11        Q.   You go on in this conversation to discuss an issue that has

12     arisen in the police.

13             MS. PIDWELL:  And if I can turn, please, to the next page in the

14     English.  And in the B/C/S, it's also the next page.

15        Q.   About halfway down you say:

16             "And another thing ..."

17             Do you see that?

18        A.   Okay.

19        Q.   "... separate issue we have policemen coming to us from various

20     courses without vacancy announcements or anything."

21             What was the issue there?

22        A.   I don't see that.  What -- where?  It's not on my screen.  No --

23        Q.   If you go halfway down, sir, where it says -- you say and another

24     thing, Dr. Karadzic says yes.  And then you say:  "I am treating it

25     as" --

Page 15205

 1        A.   No, no, not on my screen.  No, no, not on my screen.  I don't see

 2     this.  Oh, yes, yes, yes, yes.  Yes.  Aha.  Yes, and another thing, yes.

 3     Because -- I don't know whether you're -- if you have been update on it

 4     and its progress:

 5             "We have policeman coming to us from various courses, without

 6     vacancy announcements or anything.  Who is behind this?  Who bringing

 7     in ..."

 8             Here we have information that new men were joining the police

 9     without any training, without any degrees, and we didn't know what system

10     was behind that, whether it was a party system, a professional system,

11     whether there was a need to increase the number of police officers and

12     that was the contexts, yes.

13        Q.   And Dr. Karadzic says, responses, by saying:

14             "Check this with Stojan, please."

15             Do you see that?

16        A.   Yes.

17        Q.   Who is he referring to?

18        A.   Stojan Zupljanin, I suppose.  There was no other Stojan.  No

19     Stojan in my police.

20        Q.   And then you go on to say that you called him at home.  Are you

21     referring to Stojan Zupljanin then?

22        A.   Yes.

23        Q.   And did you actually make conduct with Stojan Zupljanin on this

24     issue?

25        A.   No, no.  No, I did not.

Page 15206

 1        Q.   You didn't follow that up in any way?

 2        A.   No.

 3        Q.   Was that because it was something that was outside of your area

 4     of control and -- and a pure police matter or was there some other

 5     reason?

 6        A.   It was not a party matter.  It was a professional matter.  As the

 7     party president, I received information about that, and I informed my

 8     president because he needed to be abreast of the situation.  But that was

 9     a police matter.  I always tried to look into all sorts of problems and

10     how to deal with them, but that's a different matter.  But when it comes

11     to getting in touch with Stojan, no, I didn't get in touch with him.

12             MS. PIDWELL:  I'd like to turn now to another document.  It's

13     tab 13.  It's 65 ter 786.

14        Q.   You'll see, sir, this document is dated the 3rd of February.

15     It's from the assembly of the Autonomous Region of Krajina, Banja Luka,

16     concluding that the municipal assemblies of the ARK should not organise

17     any activities regarding the referendum which was scheduled for late

18     February/early March, on the basis that that referendum was

19     unconstitutional and illegal.

20             Do you recall receiving this conclusion from the ARK Assembly?

21        A.   It's very difficult to say whether I received it.  Are you

22     referring to the entire government or -- I don't really know if the party

23     was even supposed to receive this.  Because this is along the

24     authorities' line and if anybody received it, it may have been Stakic.

25        Q.   In -- in the Municipal Assembly of Prijedor, were any activities

Page 15207

 1     put in place regarding the referendum?

 2        A.   No.  Are you referring to the Serbian population?

 3        Q.   Yes, I'm referring to the Serbian population.

 4        A.   Yes.  No, no.  No, we didn't do that.  We had a plebescite, and

 5     we expressed our position by means of the plebescite.  We didn't

 6     participate in the referendum.

 7             I don't know if any individuals participated in the referendum

 8     because, for example, there were Muslim individuals who took part in

 9     the -- in the plebescite, so I really don't know whether there were any

10     Serb individual who is decided to vote in the referendum.  I don't know

11     that.  I can't tell you that.

12             MS. PIDWELL:  I seek to tender that document, Your Honour.

13             MR. KRGOVIC:  Your Honour, I object to that.  There is no proper

14     link for that because the witness has -- had no knowledge about this

15     document about this [indiscernible].  He never received it.

16             JUDGE HALL:  Ms. Pidwell, I'm trying to put this in the context

17     of events.

18             MS. PIDWELL:  Your Honour --

19             JUDGE HALL:  What is your response to Mr. Krgovic's objection?

20             MS. PIDWELL:  It's accepted that he is not the author of this

21     document and he did not receive it.  However, he was on the Municipal

22     Assembly of Prijedor and this is an instruction from above, from the

23     ARK Assembly in order to -- well, not to participate in the plebescite

24     that was being arranged towards the end of the month.  And on his

25     evidence, he said that he did not participate in the plebescite, the Serb

Page 15208

 1     population did not participate in the plebescite.

 2             So in my submission, he is -- he has spoken to the body of the

 3     text by essentially saying it was followed in the municipality of

 4     Prijedor and I'm seeking to tender it on that basis.

 5             JUDGE HALL:  I suppose it's relevant, but is there any nexus

 6     between the document and the witness?

 7                           [Trial Chamber confers]

 8             MR. KRGOVIC:  And the other thing, he was not member of municipal

 9     assembly, what Ms. Pidwell quoted.  He was not part of local assembly.

10                           [Trial Chamber confers]

11             JUDGE HALL:  We -- we heard your submission that he admitted, he

12     knew about the effect of this.  But, still, there is no -- you haven't

13     establish any closer connection between him and the instruction.

14             MS. PIDWELL:  I'm unable to establish a connection between him

15     and the document.  He said he didn't know about the instruction in

16     particular, which is formulated in this.  But he knew that -- he -- he --

17     gave evidence that that -- it was followed on the ground, so to speak in

18     Prijedor that when the referendum took place, the Serbs did not

19     participate.

20             JUDGE HALL:  That it was followed or that the event happened?

21     Because I didn't understand him to say that it was followed.  After all,

22     his evidence was that he didn't know about it.  But admittedly, he agrees

23     with the result.

24             It seems to me that you would need a witness who is more closely

25     connected with this document in order to tender it, not through this

Page 15209

 1     witness.

 2             MS. PIDWELL:  If that's Your Honours' ruling, then I would ask

 3     for it to be MFI'd at this stage.

 4             JUDGE HALL:  Marked for identification.

 5             THE REGISTRAR:  As Exhibit P1613, marked for identification,

 6     Your Honours.

 7             MS. PIDWELL:  65 ter 48, please, on the screen.  It's tab 15.

 8        Q.   Sir, you see on your screen a document dated 13th of March, 1992

 9     from the Executive Board of the Serbian Democratic Party addressed to all

10     Municipal Boards of the Serbian Democratic Party.

11             Now, firstly, do you see the handwriting at the top of that

12     document?

13        A.   I do.  Titova 7 a.

14        Q.   What does that mean?

15        A.   That's an address, but I don't know whose.  It may have been the

16     party address or some other address in Prijedor.  I really am not in a

17     position to tell you what this address represents.

18        Q.   And whose handwriting is it?

19        A.   Mine.

20        Q.   And this document says:

21             "In accordance with the stance adopted, you are required to

22     assess the possibility of establishing a Serbian municipality in your

23     [sic] area of activity."

24             Do you see that?

25        A.   I do.

Page 15210

 1        Q.   So this is an instruction to the Municipal Boards to establish or

 2     to assess the possibility of establishing Serb municipalities.  Do you

 3     accept that?

 4        A.   Yes.

 5        Q.   And you obviously received this document in order to write on it.

 6     What did you -- do you recall when and how you received it?

 7        A.   Not only because I drafted it but also because it is addressed to

 8     the Municipal Board and since I was its president, it's only normal that

 9     I received it.  I don't know when I received it.  But I do remember that

10     this document did arrive and this refers only to the areas inhabited by

11     the Serbian population.  Those areas had to establish their municipal

12     assemblies or municipalities.  We did not even go into the areas where

13     Muslims resided, and that's why the wording here is to assess the

14     possibility.

15             MR. KRGOVIC:  I do apologise.  Just one small correction for the

16     transcript because it is not properly recorded what witness said in the

17     page 61, line 21.  Not only because -- he says -- it says not only

18     because I drafted it, also because it addresses ...

19             That's not what the witness said, so ...

20             MS. PIDWELL:  Perhaps I will clarify with the witness.  It is a

21     matter of interpretation.

22        Q.   Sir, correct me if I'm wrong, but you didn't draft or write this

23     document, did you?

24        A.   No, I didn't.  You see, it says the Serbian Democratic Party

25     Executive Board.  It is probably the republican and letter was sent to

Page 15211

 1     all the Municipal Boards including mine.  That's why I received it.  I'm

 2     sure I received this document.  That document was signed by Rajko Dukic,

 3     the president of the Executive Board of the SDS.  So this document

 4     reached me along the party line, and the fact that the document reached

 5     me is confirmed that I wrote this address in my own handwriting so there

 6     is nothing in dispute about all that.  The top leadership of the party

 7     sent this document down to us.

 8        Q.   Thank you.

 9             JUDGE HALL:  I confess I was confused by what was recorded -- he

10     was recorded as having said that he drafted it, in the context of the

11     remainder of ...

12             MS. PIDWELL:  Is that sufficient clarification for Your Honours

13     now?

14             JUDGE HALL:  Thank you.

15             MS. PIDWELL:

16        Q.   Are you able to recall, sir, which territories of the Prijedor

17     municipality would fall within the definition of those which would become

18     parts of the Serbian municipality?

19        A.   You can see in the document that those were the areas and parts

20     which means local communes inhabited by Serbs and parts of local communes

21     inhabited by Serbs which means that we will only be dealing -- we will

22     not be dealing with areas inhabited by Muslims and Croats.

23             If I could be given the map that I saw yesterday, local communes

24     are depicted in that map, and it would be easy to see which areas we're

25     talking about.

Page 15212

 1        Q.   Well, let's pull that map up.

 2             MS. PIDWELL:  Tab 1.  P1526.

 3             Right.  Perhaps the usher can assist the witness with marking the

 4     map.

 5        Q.   Sir, you are able to do some markings on the screen.  And perhaps

 6     if you could indicate on the map which areas would form part of the

 7     Serbian municipality pursuant to this -- this direction.

 8        A.   I don't see those areas.  I can see just small parts thereof.

 9     For example, Brezicani is one of then.  Cejreci no, that's Muslims.

10     Omarska, most of them Muslims.  Kozarac, Mostar, Muslim.  Kozarac,

11     [indiscernible] Trnopolje, Kevljani.  Omarska, yes.  Omarska, yes.

12     Aracici, no.  Bicavana, no Croats.  [Indiscernible] Zecavina [phoen],

13     Rakocini, [indiscernible] Bicani [phoen].  Biska Glava would be, but

14     Palanciste is missing.  Prijedor 2 is missing, Cirkin Polje is missing,

15     and those areas which were predominantly Serb territories.  Or, rather,

16     they were not Serb territories, but those were areas predominantly

17     inhabited by the Serb population.  I apologise.  The map is not complete.

18     It doesn't depict all the local communes in the area.

19        Q.   That's accepted, sir.

20             Could you perhaps mark on the map with an X the Serb areas and --

21     just -- I appreciate this will not be exact -- the Serb areas --

22        A.   [Previous translation continues] ... this map.

23        Q.   Yes, on this map.  That are not listed on that map?

24        A.   Everything above the railroad and the main road, the area above

25     that, and some of the other local communes in --

Page 15213

 1             THE INTERPRETER:  And the interpreter missed the last word.

 2             MS. PIDWELL:

 3        Q.   Could you repeat, the local communes in ...

 4        A.   Local communes.  Suburban local communes, suburban.

 5        Q.   Would you accept, sir, that the Serb communes that you were

 6     referring to are predominantly north of Prijedor town above the railway

 7     line, on the one hand?

 8        A.   As far as Prijedor is concerned, that would be the case, but we

 9     have Omarska here and Miska Glava, you understand, don't you?

10        Q.   Yes.  So you have -- on the one hand, north of the Prijedor town

11     above the railway line.  Additionally, you have Miska Glava?

12        A.   Omarska.

13        Q.   And finally from Omarska, the area around Omarska and west of

14     Omarska?

15        A.   Yes.

16        Q.   Up to --

17        A.   Yes.

18        Q.   Just south of Trnopolje?

19        A.   Let me just tell you this to make understand.  All the places

20     here, all the local communes here, save for Miska Glava and Omarska,

21     predominantly inhabited by Muslims or exclusively by Muslims.  Berzicovi

22     [phoen] is mixed.  Barska [phoen], 90 per cent Muslims.  Kozarusa,

23     Brdjani, Kamicani, Kevljani, Trnopolje, there were some Ukraines [as

24     interpreted] in there and some Serbs, but I'm talking about predominant

25     populations, Arasici [phoen], and so on and so forth, and those are

Page 15214

 1     mostly local communes which were predominantly inhabited by Muslims, save

 2     for Kranska Glava [phoen] and the local commune of Brezicani and Omarska,

 3     of course.

 4             JUDGE HALL:  Yes, Mr. Cvijetic.

 5             MR. CVIJETIC: [Interpretation] Your Honours, the witness has

 6     almost foreseen my objection or, rather, intervention.  I wanted to ask

 7     my learned friend to ask the witness whether all the local communes are

 8     depicted in the map or not.  I believe that he has already partially

 9     answered that but maybe he should be given an opportunity to extend his

10     answer.  He already started answering.

11             THE WITNESS: [Interpretation] Am I supposed to start saying

12     something now, was that a question for me?

13             JUDGE HALL:  Just a moment.  Ms. Pidwell, having heard counsel's

14     intervention, may wish to pose another question to you.

15             MS. PIDWELL:  There is one easier way of doing this, Your Honour.

16     We have another map.  It's not in my binder.  I'm in your hands if you

17     want to permit me to use it, but it may expedite this process.

18             THE WITNESS: [Interpretation] Can I be of assistance, please?

19                           [Trial Chamber confers]

20             JUDGE HALL:  Would the practical result be, building on your

21     suggestion, to use the other map which we assume is more detailed and

22     have him mark all the other areas and then the marked map could be

23     tendered as an exhibit.

24             MS. PIDWELL:  It's part of the binder that Your Honours received

25     at the outset of the trial, one of the composition maps to Prijedor.

Page 15215

 1     It's got all of the towns marked on it, and I'll simply ask him to

 2     confirm whether it's correct or not.

 3             JUDGE HALL:  Yes, thank you.

 4             MS. PIDWELL:  So it's P10 -- sorry, oh, 65 ter 10137.6.

 5                           [Trial Chamber confers]

 6             MS. PIDWELL:  It's map 6 for Your Honour.

 7             JUDGE HALL:  I understand the map is in the process of loading.

 8             MS. PIDWELL:  Sometimes paper is a little bit quicker.

 9        Q.   Sir, you will see on your screen another map of the municipality

10     of Prijedor, and there are additional towns marked on there.  They're

11     colour-coded.  And I'd simply ask you to look at the towns which are

12     marked in blue and confirm for me whether you agree that they were

13     predominantly Serb villages?

14        A.   Yes, precisely.

15        Q.   And if we do the same exercise with the villages marked in red,

16     are they predominantly -- would you agree that they were predominantly

17     Croatian villages?

18        A.   Correct.  Yes.

19        Q.   And, finally, with the green villages marked on there, would you

20     agree that they were predominantly Muslim villages?

21        A.   Again, correct.  Somebody did a -- a very good job.

22        Q.   And, sir, going back to the issue that we were discussing with

23     the document from the Executive Board, which areas on this map would

24     become part of the Serbian municipality?

25        A.   Serbian settlements with a majority Serbian population.  Gradina,

Page 15216

 1     Omarska, Lamovita, Petrova Gora, Mrakovica, Busnovi, Miska Glava, the

 2     areas in the town, predominantly inhabited by the Serbs, and so on and so

 3     forth, and later on after the takeover of power that will materialise.

 4        Q.   So clear that the town of Kozarac, for example, didn't fall

 5     within this -- the Serb municipal area, or the proposed Serb municipal

 6     area.

 7        A.   It's a Muslim area, is it not, Kozarac was -- 99 -- or 98

 8     per cent Muslims, Brdjani, Babici, there were a few Serbs in Babici,

 9     however but not that many.

10             MS. PIDWELL:  I don't know if Your Honours want to formally

11     tender that.  He hasn't marked it but he hasn't confirmed it is correct.

12     And --

13             THE WITNESS: [Interpretation] I apologise, I apologise.  I would

14     like to say that Mrakovica -- there is nobody living in Mrakovica and

15     it's here.  Mrakovica is a memorial site from the Second World War and

16     nobody is living there.  Dera, on the other hand, is settled.  Mrakovica

17     is just hotels, a few ski slopes, and the rest is all correct.

18             MS. PIDWELL:

19        Q.   Thank you sir.

20             JUDGE HALL:  This is now an exhibit.

21             MS. PIDWELL:  Well, it's unclear to me, Your Honours.  It is on

22     our 65 ter list and it is part of the maps, and so forth, that were

23     handed to Your Honours at the beginning of trial.  I don't think it is

24     formally an exhibit yet, so I guess --

25             JUDGE HALL:  The reason why I ask is that I thought that -- once

Page 15217

 1     the map book had been prepared that it would, at some point, be exhibited

 2     in its entirety but my recollection is that pieces of it have migrated

 3     into the trial as separate exhibits, so consistent with that, I suppose,

 4     we would -- we would exhibit this page.

 5             MS. PIDWELL:  Thank you, Your Honour.

 6             THE REGISTRAR:  As Exhibit P1614, Your Honours.

 7             MS. PIDWELL:  And I'd like to tender at this stage the previous

 8     document, which was the direction from the Executive Board which he said

 9     he received and wrote on the top, which was --

10             JUDGE HALL:  Yes.

11             MS. PIDWELL:  -- 65 ter 48.

12             JUDGE HALL:  Admitted and marked.

13             THE REGISTRAR:  As Exhibit P1615, Your Honours.

14             MS. PIDWELL:  Could I have 65 ter 408, please, on the screen.

15        Q.   Sir, you'll see come up on your screen some minutes of the

16     Municipal Board of the SDS held on the 23rd of April, 1992, in the

17     Prijedor 2 local commune room with you presiding.  Do you see that?

18        A.   I do.

19        Q.   And directly under the agenda, there is a report that you -- you

20     reported on the situation in the municipality.  Do you see that?

21        A.   I see that.

22        Q.   What was the situation in the municipality at that time?

23        A.   These are talks relating to the division of power that I talked

24     about, that an agreement was not possible to be reached on, so the

25     situation was a status quo.

Page 15218

 1        Q.   This is the situation that hadn't -- that had been in place for a

 2     series of months this difficulty --

 3        A.   For eight months, yes.  Yes.  And I also tried, I appointed

 4     myself as the president of the commission for negotiations and we tried

 5     to divide 50 per cent of the functions.  We agreed to continue the

 6     following day, but then the SDA in Prijedor did not allow their part of

 7     the commission to continue working, so we never finished the job.  And I

 8     said why I appointed myself at the head of the commission, to gain proper

 9     insight into the blocking or not blocking the work of the assembly.

10        Q.   Now we have got a number of other participants in this meeting,

11     including Simo Drljaca.  Do you see that?

12        A.   I do, yes.

13        Q.   And that most of the contributions to the discussion were

14     concerned about security matters.  What were the security matters that

15     were being discussed at this meeting?

16        A.   As for security in the Prijedor municipality and the obligations

17     of the Serbian Democratic Party, besides the universal fight to preserve

18     some healthy relations, and you could see through all the documents and

19     all the addresses that the main objective was to protect the Serbian

20     people, in the sense that tragedies from the past would not be repeated.

21     So all the philosophy and the entire police was based on them not again

22     them experiencing the tragedies that they had experienced earlier.  So

23     you can see in all the documents that the activities were guided along

24     this line.  That was the main idea behind the activities.  I also

25     explained about the fears and why we are there in my conversation with

Page 15219

 1     you so that things don't look as if this was just a matter of somebody

 2     doing something -- wanting to do something and then doing something on

 3     their own accord, taking measures of their own accord.  This was in this

 4     context -- there was a danger because the assembly was blocked.

 5     Everything was at a standstill.  People were tense.  Not only the Serbs,

 6     but Muslims also, Croats.  Everybody wanted to move forward, of course,

 7     except those who were more extreme.  But everybody wanted for things to

 8     move along.  They wanted for things to start function.

 9        Q.   Sir, you referred to the -- the fears that were behind these

10     discussions, and if you could, briefly, elaborate on that for the benefit

11     of the Judges, within this context, please.

12        A.   I don't know in which sense.  Which part are you interested in?

13     Can you please tell me?

14        Q.   Well, you've talked about the security concerns of the Serbian

15     people at this time and that there were fears and so wanted it understood

16     that the - let me get this right - that it didn't look like it was just a

17     matter of something happening of its own accord, measures of their own

18     accord.

19             Can you just please explain briefly the -- your background

20     thought to this?

21        A.   I'm talking about the policy of the party here and documents to

22     which we are referring, and I said that can you see this main lining of

23     activity that the main objective was the protection of the Serbian people

24     so that the tragedies that it experienced previously are not repeated.

25     Especially in the area of Prijedor and Kozarac which went through a major

Page 15220

 1     tragedy during World War II and these wounds have just healed.  New

 2     generations came, new relations were established, and then suddenly we

 3     were go into this situation where people are finding it hard to find

 4     their way around.  This is what I was talking about.  And if you look

 5     into that, you will see that everybody was surprised by that within

 6     relationships that have been re-established as normal.  But these were

 7     fears, not only among the Serb people but among other people as well.

 8     I'm talking about the Serb people here and the reason why these fears

 9     existed, and the main objective was to prevent the tragedy from occurring

10     again.  We kept repeating for 100 times on the radio and everywhere,

11     please, tell us one reason why there should be a confrontation in our

12     area.  There was no reason at all.  So we kept repeating that over and

13     over again, because of fears, not because of some particular policy.

14        Q.   Thank you, sir.  Now going back to the document, this is -- and

15     provide some context.  This is a week before the takeover of the Prijedor

16     municipality.  There's a decision listed at number 4 to convene a meeting

17     of the SDS Municipality Board on Saturday, 25th of April.  Do you see

18     that?

19        A.   I do, yes.  Yes, item 4.  1800 hours.

20        Q.   Why was there --

21        A.   [Indiscernible] Zeljaja, and police representatives, deputy head

22     of the garrison.

23        Q.   Why was it necessary for the police and army representatives to

24     be at that meeting?

25        A.   For the reasons that we have just talked about, including the

Page 15221

 1     ones that I just referred to later.  We will see that in this

 2     paragraph 2, we sought to be protected from any conflict that could

 3     possibly break out and we asked the JNA to do this, the official army.

 4     That is why we asked for Zeljaja to be present from the garrison, as a

 5     representative of the military, and also representatives of the police.

 6     They were the only ones who could protect us from those who were having

 7     weapons.  You couldn't have people without weapons with their bare hands

 8     protect themselves.  That's why their presence was required and then in

 9     the second paragraph, it is already -- says Zeljaja, as personification

10     of the JNA, does not declare that the JNA is going to protect the Serbs.

11     The SDS will call upon all Serbian soldiers to leave the JNA and take all

12     their weapons and to form the Serbian army that would protect the Serbian

13     people in that area.

14             I think that this is clearly stated.

15        Q.   And the reference to the police --

16             MR. CVIJETIC: [Interpretation] I apologise, just a small

17     intervention to the transcript.  I'm not going to suggest anything.  But

18     the witness said, at that point in time, he said what the status of the

19     JNA was.  I would like to ask him to repeat that answer of his because

20     that part of his answer is not in the transcript.

21             MS. PIDWELL:

22        Q.   Sir, did you, in your previous answer, say or mention what the

23     status of the JNA was?

24        A.   I didn't mention status.  All I said that was Zeljaja was the

25     personification of the Yugoslav People's Army.  He was the deputy of the

Page 15222

 1     garrison commander, and we asked them for protection because all ethnic

 2     groups are part of the JNA, except for those who refused to respond to

 3     the call-up.  So we requested them to respond to a call for protection of

 4     the Serbian people and if they would not do that then the Serbian

 5     Democratic Party would call up on all the Serbs who were in the JNA to

 6     step out with their weapons in order for them to be able to protect the

 7     Serbian people because all of them were children from that area.

 8     Actually, we wanted them to protect their children, to protect their

 9     parents.

10             Yes, that was the context.

11        Q.   Thank you.  The -- just to clarify, what was the ethnicity of

12     Zeljaja?

13        A.   Serb.

14        Q.   And the police representatives that you asked to be present at

15     the meeting two days later, who were you referring to?

16        A.   I was referring to Simo Drljaca and, of course, these commanders

17     of police stations who were active.  So the leadership, yes.  And Simo,

18     here.  Because of his post.  Because I said when we were talking about

19     the earlier document that he was the chief of the MUP Prijedor.

20        Q.   At the time of the takeover, a week later, who was the chief of

21     the MUP Prijedor?  Just before the takeover.

22        A.   Before the takeover, it was a Muslim, an engineer from Celpak.  I

23     think that he was from Celpak, Telundzic.  I don't know his first name.

24     I forgot.

25        Q.   So at this point in time, namely the 23rd of April, the head of

Page 15223

 1     the SJB Prijedor was not Drljaca, was it?  It was Telundzic.

 2        A.   No.  Telundzic, yes.  That's correct.

 3        Q.   Was Telundzic invited to this meeting on the 25th of April?

 4        A.   No.  Because it was a matter of the Serbs, of protecting the

 5     Serbs.  We call the representatives of the JNA and said if they were not

 6     willing to protect us, we would call the Serbian soldiers to come and

 7     take their weapons and form their units in order to protect the Serbian

 8     people.  That's why he wasn't invited.

 9        Q.   And finally with this document, sir, number 5, there's a

10     conclusion or a decision, sorry, to immediately start working on the

11     takeover.  Do you see that?

12        A.   Yes, yes.

13        Q.   And what did that mean?

14        A.   Well, you know what that meant.  It meant that certain

15     preparations had to be made because the blockade was still ongoing in

16     order to take over power.  Something had to happen there.  We had to let

17     the water out, conditionally speaking.  In that sense, that is what it

18     means.  There were armed soldiers in the JNA.  If the JNA was not willing

19     to do it, then we would take the Serb soldiers, and then in the police,

20     we would have the policemen and the reserve forces, so from both sources

21     we had armed people, and in that way we would protect the Serbian people.

22     So it was in that sense, and that's what actually was -- that's actually

23     what happened later.

24        Q.   Thank you, sir.

25             MS. PIDWELL:  I seek to tender that document now.  And I think

Page 15224

 1     that is an appropriate time, Your Honour.

 2             JUDGE HALL:  Admitted and marked.  Yes.

 3             THE REGISTRAR:  As Exhibit P1616, Your Honours.

 4             JUDGE HALL:  We've reached the point where we must take the

 5     adjournment for the day.  We will resume in this courtroom, according to

 6     the last version of the calender I've seen.  We're in this courtroom,

 7     mornings, for the entirety of next week.

 8             So I trust that everyone has a safe weekend.

 9                           [The witness stands down]

10                            --- Whereupon the hearing adjourned at 1.46 p.m.,

11                           to be reconvened on Monday, the 4th day of October,

12                           2010, at 9.00 a.m.