Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18191

 1                           Tuesday, 7 December 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.24 p.m.

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

 6     everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.  And I must add, welcome

10     back from your surgery and then other parts.

11             Good afternoon to everyone.  May we have the appearances, please.

12             MR. DI FAZIO:  Good afternoon, Your Honours.  Gramsci Di Fazio,

13     Joanna Korner, and Crispian Smith for the Prosecution.

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

15     Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Merinda Stewart appearing

16     for the Stanisic Defence this afternoon.  Thank you.

17             MR. KRGOVIC:  Good afternoon, Your Honours.  Dragan Krgovic and

18     Aleksandar Aleksic appearing for Zupljanin Defence.

19             MS. KORNER:  Your Honours, I'm here just to make an application

20     in respect of Witness ST-065.

21             Could we go into private session while I make the application.

22             JUDGE HALL:  Yes.

23                           [Private session]

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21                           [Open session]

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

23             MR. DI FAZIO:  If Your Honours please, while the witness is being

24     brought in, yesterday I showed him a map, 65 ter 3121, but forgot to ask

25     that it be tendered.  I apply for it to be tendered into evidence.

Page 18194

 1             JUDGE HALL:  So that may be admitted and marked as an exhibit.

 2             THE REGISTRAR:  As Exhibit P1748, Your Honours.

 3                           [The witness takes the stand]

 4             JUDGE HALL:  Good afternoon to you, sir.  Before I invite

 5     Mr. Di Fazio to resume his examination-in-chief, I remind you you're

 6     still on your oath.

 7             Yes, Mr. Di Fazio.

 8             MR. DI FAZIO:  Thank you, Your Honours.

 9                           WITNESS:  KEMAL HUJDUR [Resumed]

10                           [Witness answered through interpreter]

11                           Examination by Mr. Di Fazio: [Continued]

12        Q.   Just to wrap up from yesterday, you -- you said that the -- I

13     think it was Prazina had obtained -- Alija Prazina had obtained a small

14     number of M48s, and of the 150 to 200 men who were doing guard duties,

15     they only had their own personal weapons.

16             Apart from the M48s and their personal weapons, did any villagers

17     have any other weapons of any description whatsoever?

18        A.   You have now mentioned 150 men being armed, but that is not

19     correct.  There were only about two dozen rifles and a good dozen of

20     hunting rifles.  That's all the weapons I knew about, which would make a

21     total of about 30 or 35 rifles, which -- part of which were M48, and the

22     others were hunting rifles.

23        Q.   Thank you for that clarification.

24             Up until the morning of the 22nd of May, 1992, were you aware of

25     any calls for you and your fellow villagers who were part of this loose

Page 18195

 1     defence of the -- of the village being called upon to surrender your

 2     weapons?

 3             Are you aware of any calls from any quarter, from anywhere, to

 4     hand in your weapons?

 5        A.   There was only one telephone in all of Renovica, so it wasn't

 6     possible to contact us, really.  But the only thing I know is that

 7     Malko Koroman said that there was some conversation about those rifles.

 8     But I wasn't present.

 9        Q.   When did you learn that?

10        A.   It was during that period.  The war broke out on the 4th in

11     Sarajevo, and until the 20th - I'm not sure of the exact date.  It may

12     have been about two weeks before Renovica was attacked.

13        Q.   As far as you're aware, had there been any arrangements made for

14     you and your fellow villagers to surrender your weapons?

15        A.   No.  I'm not aware of that.

16        Q.   Thank you.  All right.  Now turn your mind to the

17     22nd of May, 1992.

18             At the time, were you still residing in Renovica?

19        A.   Yes.

20        Q.   On the evening of the 21st to the 22nd, what had you been doing

21     during the night?

22        A.   That night, with my neighbours and relatives - I don't know if

23     their names matter to you - we went out to guard the village.  But that

24     group of ours only had one M48 rifle.  And we were on guard behind our

25     houses.  I could describe the exact spot to you, but I don't know if it

Page 18196

 1     would mean much to you.  It's called Cetici.

 2        Q.   Okay.  Thanks, that's all I needed to know.

 3             Did the night pass uneventfully and did you eventually go to bed

 4     in the morning of the 22nd of May in 1992?

 5        A.   Yes, exactly.  It was a beautiful May night, and the other guys

 6     went to sleep about 2.00.  And I remained there with my uncle,

 7     Esad Hujdur, until 5.00 or quarter after 5.00.  And there was -- and then

 8     a bus passed by, a bus of the Centar Trans company.  It still ran on that

 9     road.  And once the bus passed, then we both also went to sleep to our

10     respective houses.

11        Q.   Can you now tell the Trial Chamber how you awoke, what woke you,

12     and describe events.

13        A.   On that night, Mr. Rasim Suceska also slept in my house.  He was

14     a lad and it was just after the month of Ramadan.  He was studying to

15     become a Muslim priest, but he couldn't go back to Sarajevo because the

16     war had started there in the meantime, and he spent the night in my

17     house, just as did my father and mother.  And I came back around quarter

18     after 5.00 and went to bed, and I was aroused by some shooting but I

19     didn't get up immediately.  And then my mother entered the room and said,

20     Get up, kids, there are soldiers outside.  And I put on a track suit and

21     some socks and I tried to get out of the house.  But as soon as I peeped

22     out the door, my gaze went right and on the cross-roads, at the

23     cross-roads where my house is, there was a Pinzgauer vehicle with a

24     machine-gun mounted.  And they were shooting from that machine-gun at the

25     roofs of the houses in the village of Turkovici.

Page 18197

 1             I was scared, and went back to the house immediately.  And my

 2     mother also insisted that we return.  And you could hear bullets flying.

 3     One bullet flew through our window into our house.  And she called us to

 4     come to the hallway because it was a sort of shelter; there were no

 5     windows there.  And we stayed there maybe ten minutes or so.  We were

 6     lying down and all the while there was shooting outside.  The hallway --

 7     from the hallway there is also a door to the bathroom.  And the door was

 8     open, and I could see part of the village.  Some houses were already

 9     burning.

10             Some -- we lay there about ten minutes and somebody was calling

11     from a megaphone, was calling out to all people to come out and surrender

12     their weapons but nobody dared come out.

13             After this appeal from the megaphone, the firing resumed.  I'm

14     not sure what kind of weapons they used.  Probably automatic rifles.  And

15     for some ten or 15 minutes, but I'm not sure about the exact duration,

16     there was shooting.  Then it subsided again and stopped.

17             After some five or ten minutes, I'm not sure, Reuf Jusic, a

18     neighbour, came to the door and he called at my father, Father, come out.

19     Our police from Pale has come to check if we have weapons.  They won't

20     harm us.

21             I don't know if this is enough for the time being?

22        Q.   Thank you.  It's a good start.

23             Can you tell us, during the events that you've just described,

24     right up until the time the man came and called out to your father, did

25     you return fire?  Or did anyone in your house offer any resistance?

Page 18198

 1        A.   Resistance couldn't be offered from my house because I didn't

 2     have any weapons.  Nobody in my house had any weapons, so we couldn't

 3     open fire, nor was anybody present expect for myself, my father,

 4     Rasim Suceska, and my mother.

 5        Q.   All right.  Now the man came and called to your father, called

 6     for surrender.  Did you and your family surrender yourselves?

 7        A.   My father went out first, and my mother, and then myself and

 8     Rasim Suceska.  Once we stepped out, five to ten men were standing there

 9     pointing their rifles at us.  As soon as we appeared in front of the

10     house, they ordered us to put our hands up, which we did.  They said,

11     Hands up, and one of them or two, I'm not sure, approached us and

12     searched us.  And at the same moment, a number of them entered the house.

13     I don't know what they did there because we were outside.

14             After that search, they took us to -- toward the house of

15     Pasija Milic.

16        Q.   Did you eventually arrive at Milic's house?

17        A.   Yes.  There were four of us, one behind the other.  And that

18     house is about a hundred metres from mine.  In the basement and on the

19     ground floor there were already neighbours of mine.  Five or six people

20     were standing in front of that house.  They were dressed in camouflage

21     uniforms and in reserve police uniforms.  My father recognised some

22     people and some even greeted him.  We were all put in the basement or in

23     the ground -- or on the ground floor of that house.

24        Q.   Okay.  Thinking back, how many people were in the house when you

25     first arrived, and did the numbers increase during the course of the day?

Page 18199

 1        A.   I cannot be certain, but ten, 15, or 20 people were detained in

 2     that house when we were there.  After some time, a man ordered

 3     Velija Hujdur and Reuf Jusic to go and tell the other neighbours to

 4     surrender.  Or else, since Velija Hujdur's daughter and Jusic's son were

 5     already there, they would.  If they didn't -- didn't return, they would

 6     shoot their children.  And I think they came back and brought Ramiz

 7     Hujdur to that basement.  And, again, I'm not sure of the exact number

 8     but there were maybe 20 or 25 people there in all.

 9        Q.   All villagers of Renovica and the surrounding hamlets?

10        A.   No.  What I've described so far, first we were taken from

11     Turkovici to that place.  And after a time that we spent in

12     Pasija Milic's house, they would take us to the military apartments at

13     Renovica.  We spent about an hour in the basement of that house, and all

14     us, 25 or 30 - I'm really not sure of the exact number - we were taken to

15     Renovica, which is about 300 to 400 metres away, where there were

16     military apartments where the officers of the former JNA used to live.

17             Once we were brought to that building and into one of those

18     apartments, we found people from the surrounding villages, Petovici,

19     Vinca, Lunje, and there were about 40 or 50 people there.  But, again,

20     I'm not sure about the exact numbers.

21        Q.   Men, women, and children?

22        A.   Men, women, children, and elderly folks; everybody.

23        Q.   Okay.  Thanks for giving us that description.

24             Now I want you to go back to the period of time when you first

25     came out of your house and surrendered to the period of time when you

Page 18200

 1     ended up in Milic's house.

 2             So far you've described one Pinzgauer that was firing.  On that

 3     day, did you see any other Pinzgauers?  Was it just one or were there

 4     more?

 5        A.   At that moment, or, rather, while they were taking us there,

 6     there was constant shooting at Renovica, and barns were burning.  The

 7     Pinzgauer was still standing there when we were coming back, and the

 8     column was at least a kilometre long.  I was able to conclude that they

 9     had arrived with a greater number of vehicles and many weapons.  But they

10     deployed.  So one group went to Turkovici, one group to Renovica, the --

11     another to Petovici, because they attacked all villages at once.  One

12     group went to Kaljani; one went to Lunje.  And once we set off in the

13     direction of Pale, I noticed that the column was about a kilometre long.

14        Q.   Now, column -- column of what?  Column of villagers or column of

15     vehicles, of -- of Pinzgauers?  What are you talking about here?

16        A.   I'm talking about the column of military vehicles.  Pinzgauers,

17     Pragas, and there were also two buses full of soldiers where they put

18     also the prisoners and -- who they took toward Pale.  That's the column I

19     mean.

20        Q.   Okay.  We'll get to those events in just a while.  In the

21     meantime, I want to focus on the -- again, on the period of time --

22        A.   [In English] Okay.

23        Q.   The period of time when you come out of your house and before you

24     get to the Milic house.  That period of time.

25             You've told us about the Pinzgauers.  What about the men who were

Page 18201

 1     there, these men who were involved in this -- in this episode?  Were they

 2     dressed in uniform?

 3        A.   [Interpretation] Yes, they all were.  But I may have left out

 4     that at the entrance to Pasija Milic's house there were about five to ten

 5     soldiers.  I'm again not sure about the exact number.  They were all

 6     dressed in camouflage uniforms and reserve police uniforms.  And I can

 7     tell because I lived there and they patrolled all the time.  The uniform

 8     did differ from military uniforms.  The colour of the uniform was blue,

 9     which -- by which I can tell that they were reserve police.

10        Q.   Can you remember - if you can't, that's fine - but if you can

11     remember, can you tell us how many or approximately how many reserve

12     police uniforms you saw that morning when you first came out to

13     surrender?

14        A.   I don't quite understand the question.  The number of uniforms or

15     the number of men?

16        Q.   Sorry.  Yeah, that's my fault.

17             What I meant was the number of men dressed in reserve police

18     uniforms.

19        A.   Well, at the outset, by my house, around ten and another ten down

20     at Renovica.  But when we left Pasija Milic's house toward Renovica,

21     toward the military apartments, we were in a group, and the soldiers

22     were -- walked with us.  My father and I were ordered to carry a box of

23     ammunition.  And with that group of ours that went toward Renovica, there

24     must have been 20, 25, or 30 of them.  But I cannot be sure of the exact

25     number.

Page 18202

 1        Q.   Okay.  Think back.  Were they all soldiers?  Were any of them

 2     policemen?

 3        A.   There were policemen.  My conclusion was that half of them were

 4     police officers, because they all wore reserve police uniforms, and they

 5     were probably all police officers.  But the people wearing camouflage

 6     uniforms, not all their uniforms were green.  Some were blue and white,

 7     like police uniforms.  On that day, I saw these three kinds of uniforms.

 8        Q.   Thank you.  And the -- can you tell us, if you know, the

 9     ethnicity of the men who wore uniforms and who participated in the

10     attack?

11        A.   I didn't know all those men, but I can mention one man whom I

12     recognised.  Zeljko Cvoro.  He was an acquaintance of mine.  I was a

13     sportist and that's how I know him.  And I know that his name is Zeljko

14     Cvoro, but I didn't know the rest of them.  Talking about the group that

15     was taking us to the military apartment at Renovica.

16        Q.   Have you got any idea what Zeljko's Cvoro's job was back then in

17     1992, who he worked with, or ...

18        A.   I think that he was a waiter in a pub at Praca.  But he was a

19     member of the reserve police, because at that time everybody was drafted

20     either to the army or to the reserve police.

21        Q.   Okay.  You've told us about being taken to the Milic house and

22     then from there to the barracks, the Renovica barracks; correct?

23        A.   No.  Not to the barracks.  To the apartments where the officers

24     of the former JNA lived.  Those were their apartments.  But apartments

25     built for military personnel at Renovica.

Page 18203

 1        Q.   I see.  And thanks for that clarification.  And were they close

 2     to the barracks or part of the barracks system?

 3        A.   No, they weren't part of the barracks system.  They about 300 or

 4     400 metres from the barracks.

 5        Q.   And it's not in -- we know that you eventually were taken to

 6     Pale, or at least that's what -- the evidence we expect.  But what I'm

 7     interested in is the period of time in this -- these apartments.

 8             While you were being held there, approximately how many villagers

 9     would you say eventually were gathered up into those apartments?

10        A.   I may have skipped a detail.  When we were walking from

11     Pasija Milic's house to the military apartments, in my statement I

12     mentioned that in front of those apartments there were more soldiers, and

13     later we concluded that their headquarters was there and that they

14     actually managed the attack on Renovica from there.  In front of those

15     apartments we saw another ten or 20 soldiers, and that's where I first

16     saw Radomir Kojic.  When we were approaching that house, one of the

17     police officers who was also dressed in a reserve police uniform came up

18     to me, and I mentioned already that my father and I were carrying a box

19     of ammunition because we were ordered to do so, and he asked me, Balija,

20     where is your rifle?  And hit me in the face.

21             After that, we were taken into the apartment, and there I saw

22     50 to 60 persons.  It was a two-room apartment, and it was full of

23     people.  They were sitting on the floor and so there may have been 50 or

24     60 of them.

25             I don't know if this is enough for you.

Page 18204

 1        Q.   Yes, thank you.  Just one detail I want to clarify.  You said

 2     that you -- when you got to the front of the apartments you saw another

 3     10 or 20 soldiers.  All I want to be clear about is - doing the best you

 4     can and thinking back - tell us this: Were they soldiers or policemen?

 5     If they were soldiers, that's fine.  But I just want to know how exactly

 6     they were dressed or what exactly -- which organisation they were members

 7     of.

 8        A.   Well, I think it was more likely that they belonged to police.

 9        Q.   Okay.  Now can you -- do you have any basis for saying that?  I'm

10     talking about the ten or 20 that you saw in front of the apartments.  Do

11     you have any basis for saying that?

12        A.   The only base that I can have, that I can conclude about, is that

13     those people who were there, as I have told you, wore the reserve police

14     uniforms.  They had camouflage uniforms as well, and blue camouflage

15     uniforms.  The ones I used to see special MUP units wear before.

16             So that was the only basis for me making this conclusion that

17     they belonged to police.

18        Q.   All right.  So you described being gathered in the -- the

19     apartments, the officers' apartments, 50 or 60 of you.  And how long were

20     you there for?

21        A.   We stayed there -- let me see.  The attack started at 8.00 and we

22     stayed there perhaps until 4.00 or 4.30.  And I don't know if you're

23     interested in this detail, but at around 2.00, approximately, they

24     released the elderly, women, and children, including my father, and they

25     kept some 30 of us there.  So we could have stayed there until 4.00 or

Page 18205

 1     4.30 p.m.

 2        Q.   And who did they keep?  Just the men?

 3        A.   Only the men.  That is to say, just us.  The men were kept in

 4     that room.

 5        Q.   Thank you.  Describe now how you came to leave the room, how you

 6     came to leave Renovica, and how you got to Pale.

 7        A.   Most likely some of the people who were in command of that unit

 8     ordered for us to get up.  A guy approached us, told to us put our hands

 9     up in the air so they could tie our hands with a rope, and they ordered

10     us to move toward the bus.  All of us were boarded on the bus, and there

11     could have been 25 to 30 of us there.  I think the exact number was 26,

12     that 26 men were taken from Renovica to Pale.

13             The soldiers got on the same bus, that is to say that we were on

14     the same bus with the soldiers.  And then the column was established.

15     And as I have said earlier, that column was about one kilometre long.

16     There were at least three Pragas there, Pinzgauers, trucks, 110 trucks,

17     and this is how I am able to tell you that the column was about one

18     kilometre long.  So we got on the bus and the column started moving

19     towards Pale.

20             Then the column stopped in front of the house of Prazina Alija.

21     The second or third vehicle behind us stopped in front of that house and

22     they started firing on the house and basically it was bullet-ridden after

23     that.  Then we continued our trip to Pale.

24             As for the people on the bus with us, reserve police forces and

25     so on, we talked to them and it had an encouraging tone, the

Page 18206

 1     conversation.  They kept telling us that we were going to Pale, that they

 2     wanted to interview us there, and this is how we arrived to Pale where

 3     some 200 to 300 people awaited us.  There were civilians there and ...

 4        Q.   Thank you for that.  Just -- just -- I realize there's just one

 5     more detail I want to get before we get to events at Pale.

 6             Earlier in your evidence you described some of the dwellings in

 7     your hamlet of Turkovici burning.  Can you give the Trial Chamber an idea

 8     of how many buildings you saw burning or being destroyed by fire and when

 9     you saw that.

10        A.   At the very outset, in the morning, I can claim with certainty

11     that in my immediate neighbourhood two stables were set on fire and one

12     or two houses.  Esad Hujrija's [phoen] house and perhaps another house.

13             As we were transported from Milic, Pasija's house to the military

14     apartments, I can't give you the exact number but we saw a lot of houses

15     burning.  At least a dozen houses were on fire in the neighbourhood.

16     Hujdur, Alija's house, stable, and so on.  I passed by his house and this

17     is how I know for a fact it was on fire.  Safet's stable was also on

18     fire.  And I saw all this.  This is how I'm able to claim this.

19        Q.   Thank you.  And lastly, on -- on -- still dealing with Renovica,

20     you describe being struck or hit once.  Do you know if any other

21     prisoners were assaulted in any way?  Now -- I'm talking now back at

22     Renovica and in the surrounding hamlets.

23        A.   I can't tell you anything about the surrounding hamlets.

24             As for Renovica itself, before going into the apartment, I saw

25     that Kasim Sipovic was being beaten at the very down-town of Renovica.

Page 18207

 1     At the main intersection there he was being beaten by young men.  I don't

 2     know why.  So when Kasim was brought to that apartment, he was already

 3     all bloody.

 4        Q.   Thank you for that clarification.  And I'm sorry to interrupt

 5     your narrative.

 6             Now, go back to the point where you arrive in the convoy in Pale.

 7     Where exactly in Pale were you taken?

 8        A.   In Pale, the column stopped in front of the MUP building.  That's

 9     how we referred to that building.  This is where over 200 people awaited

10     us.  I can't give you the exact number, but there were civilians there

11     and people wearing reserve police uniforms.  There were soldiers.  And

12     there were over 200 of them altogether in that group.

13             They ordered us to get off the bus.  And as we were entering the

14     MUP building, they told us to stand up against the wall.  And in the

15     meantime they started swearing at us, Balijas, you killed one of our men.

16     All of them need to be shot.

17             And then this mob moved toward us to beat us.  As they started

18     beating us, I was hit a couple of times.  There were two or three of them

19     to each one of us when they were beating us.

20             After some time, somebody ordered - most likely Malko Koroman -

21     to take us to the culture hall, which is a sports hall nowadays.  There

22     was a gauntlet that they established, and we walked in pairs through the

23     gauntlet towards the building.  And as we walked, they hit us whenever

24     they could.  When we entered the old culture hall, or the sports hall

25     nowadays, we saw some 15 to 20 people there who had been imprisoned

Page 18208

 1     before us.  This mob that beat us in front of the MUP building and in

 2     that gauntlet entered the building as well and continued beating us.

 3             I described this in my first statement.  And there was a man -

 4     I'm not sure about his name, but it could be Guja, Radomir - who wore the

 5     uniform of a reserve policeman.  He beat the daughter of Sevko Suljevic

 6     with a table leg.  Sevko fell to the ground.  And back in -- in my 1992

 7     statement I described how he beat him directly on the head.  So this

 8     beating continued for some ten to 15 minutes after they brought us into

 9     the building, and then Malko Koroman showed up and he ordered them to

10     leave the premises of the old culture hall.

11        Q.   Okay.  Just a few more details about this.

12             The mob that menaced you and tried to attack you, who -- who made

13     up the mob?

14        A.   I will repeat once again.  When we came up there, there were

15     civilians waiting for us there, as well as men in the former JNA

16     uniforms; also men wearing reserve police uniforms and camouflage

17     uniforms which were blue/grey.  I suppose these were some special

18     MUP units.  There were also people wearing green camouflage uniforms.

19     This group numbered over 200 people.

20             I don't know if this is sufficient for you.

21        Q.   Did any of the policemen who were present, reserve policemen or

22     otherwise, do anything to protect you?

23        A.   I don't remember anything except for the entrance of

24     Malko Koroman, who came in after they beat us.  He came into the old

25     culture hall and in a strict voice he ordered them to leave.  So the only

Page 18209

 1     person who intervened was Malko Koroman, who ordered them to leave the

 2     premises.

 3        Q.   How long were you imprisoned at the culture hall near the Pale

 4     SJB?  For what period of time?

 5        A.   50 days.  After that time, we were transferred to Kula and

 6     remained there for another 50 days.  I was exchanged after being in

 7     prison for 100 days.

 8        Q.   And when you were in the -- in the culture centre in Pale during

 9     the period of your imprisonment, who guarded you?  Who secured the place?

10        A.   At the very entrance there was always a guard wearing a reserve

11     police uniform.  I knew one of them personally because he used to play

12     football with me.  His name is Savic.  I also knew another guard who was

13     a teacher in our place.  I think his last name was Bosovic.  Both of them

14     wore reserve police uniforms.

15        Q.   All right.  Were you and your fellow prisoners beaten during the

16     time that you were imprisoned?

17        A.   Your Honour, while we were imprisoned there, four men died as a

18     result of beatings.  They were beaten brutally.  I can give you the

19     names.  Nasko Smajic was beaten and died as a result.  Edhem Hrvo, as

20     well, died under shady circumstances.  Selim Pandzic was also beaten

21     brutally in front of my eyes by allegedly special police units from Pale.

22     And actually that was a unit under the command of Rajko Kusic.

23        Q.   Anyone commit suicide?

24        A.   As for Edhem Hrvo, I can't claim with certainty how he died.  He

25     died down there.  I don't know how he died, whether he committed suicide

Page 18210

 1     or he succumbed to the injuries he received during the beating.  I'm not

 2     sure.

 3             As for the two men Pandzic and Smajic, I can assure you that they

 4     were brutally beaten and died as a result.

 5        Q.   Thank you.  Yes.

 6             MR. DI FAZIO:  Sorry, would Your Honours just bear with me for a

 7     moment.

 8        Q.   You touched upon this earlier -- not -- not long ago you

 9     mentioned that I think when you were being threatened by the crowd, or

10     mob, that you were being blamed or connected somehow with the death of

11     some Serb men at Renovica that day.  Do you know who was killed?  Which

12     Serb men were killed, if any, at Renovica on that day, the 22nd of May?

13        A.   Among the people that were with us on the bus, the reserve

14     policemen, soldiers, and so on, as I have described to you, we heard from

15     them that, allegedly, a tenant [as interpreted] was killed and somebody

16     else.  That's what we heard while on the bus.  I don't know whether this

17     is true.  We had no contact with anybody ...

18             MR. ZECEVIC:  I'm sorry, 20 -- page 20, line 2, it's recorded as

19     tenant, which is the -- which is the translation of the surname -- the

20     exact translation of the surname of that person.  But I think it's -- his

21     surname is Stanar.

22             MR. DI FAZIO:  I'm grateful for that clarification.

23        Q.   Let just go back.  What I'm asking you about is not you or your

24     fellow villagers but any of the Serb men who came to Renovica that day,

25     the 22nd of May.  Were any of them killed?

Page 18211

 1        A.   You probably misunderstood me.

 2             Those two Serbs that the men on the bus mentioned had allegedly

 3     died, had been allegedly killed.  Their names were Stanar and another

 4     man.  I'm now referring to the people who came to Renovica on that day.

 5        Q.   Do you know how they were killed, if they were killed?

 6        A.   I truly don't know.  I really don't know.

 7        Q.   Thank you.  And were any of your fellow villagers from Turkovici,

 8     Renovica, or the surrounding hamlets killed on that day?  I'm talking

 9     about there, at Renovica or -- or the hamlets, not in Pale.

10        A.   As far as I know, nobody was killed on that day, but they were

11     wounded.  Milic, Sipovic, Munib Salispahic [phoen].  And then Cutuk as

12     well; I don't know his first name.  The three of them were wounded on

13     that day.  It was at the very beginning when they opened fire.  As the

14     residents were fleeing towards the forest, they opened fire, and three

15     people were wounded on that day.

16             MR. DI FAZIO:  Can the witness be shown P1450.  It's a

17     photograph.

18             And can I ask for the usher's assistance in asking the witness to

19     mark the screen.

20        Q.   Witness, I want you to look at this photograph and I'm going to

21     ask you some questions about it.  And the usher will help you.  You can

22     actually mark the screen with a special pen that he'll give you.

23             What I want you to do is to see if you can see in that photograph

24     the Pale SJB building.  If you can, circle it.

25        A.   I think it's this building here.

Page 18212

 1        Q.   Only touch the screen when told to, please.

 2             Can you see ...

 3        A.   All right.  I apologise.

 4        Q.   No, no, that's fine.  Perfect.  Thank you.  Can you see the

 5     place, is it visible, this place that you've referred to as the culture

 6     centre?

 7        A.   May I?  May I circle it?

 8        Q.   Yes, please go ahead and circle it.

 9        A.   It's here.

10        Q.   Thank you.

11             MR. DI FAZIO:  If Your Honours please, I seek to tender that into

12     evidence.

13             JUDGE HALL:  Admitted and marked.

14             THE REGISTRAR:  As Exhibit P1749, Your Honours.

15             MR. DI FAZIO:

16        Q.   Mr. Hujdur, thank you very much for answering my questions.

17             JUDGE HALL:  Yes, Mr. Cvijetic.

18             MR. CVIJETIC: [Interpretation] Thank you, Your Honours.

19                           Cross-examination by Mr. Cvijetic:

20        Q.   [Interpretation] Mr. Hujdur, we just have one, perhaps two,

21     questions at the most.

22             You spoke about the preparations for defence, as you called them,

23     in Renovica.  Within those preparations, some of the residents of

24     Renovica went to Croatia for training; right?

25        A.   Yes.

Page 18213

 1        Q.   You also were invited to go to Croatia; right?

 2        A.   No.  I was not invited.  I was told this verbally.  The Defence

 3     teams probably know that I was into sports.  I was a sportsman, an

 4     athlete.  And allegedly seven of us from Renovica were supposed to go to

 5     this training in Croatia.  And out of seven, only two went.

 6        Q.   Asko Prazina and Fadil Sifovic [phoen] went; right?

 7        A.   Yes.  Asko Prazina, is --

 8        Q.   Is it the same person as Alija?

 9        A.   That's the son of the late Alija.

10        Q.   Did they all come back?

11        A.   Yes.

12        Q.   Did they tell you what this training in Croatia comprised?

13        A.   I never saw Asko after the training.  He lived in Sarajevo.  As

14     for Fadil Sifovic, he and I were never on good terms.  So I never got in

15     touch with him, and he never told me anything.

16        Q.   You didn't go to this training because you had work obligation to

17     perform; right?

18        A.   I had work obligation to perform, and I was also an athlete

19     during that period of time.  I was a football player, and I attended

20     football training and preparations in Ucina.

21        Q.   I'm following your statement.  And in the statement you gave to

22     the OTP, you claim that you had work obligation.  Is that right?

23        A.   Yes, I did have work obligation.  But at the same time, I went to

24     Ucina for soccer, for football training.

25        Q.   Very well.  Since you have been a member of the SDA since 1991,

Page 18214

 1     do you know that the SDA sent its members to Croatia for training to

 2     become policemen, members of specialist forces.  Do you know about that?

 3        A.   Sir, you can check my files.  I was a football player.  And I did

 4     become a member of the SDA but nothing more than a member.  I did vote in

 5     elections for the SDA; but other than that, I never attended any meetings

 6     nor do I know about these people going for training.  You can check this

 7     for yourself.  You can check all my files, and you'll see that I'm

 8     telling the truth.

 9        Q.   I'm just asking you to receive an answer from you.  You don't

10     have to be concerned about my questions.

11        A.   I really don't know about this.

12        Q.   Do you know that there's a village called Bare where a family of

13     ten was killed, a family called Vukasinovic, men, women, children.  Do

14     you know about this incident?

15        A.   I know these place called Bare.  However, these people were not

16     killed during that period of time.  They were killed after we had been

17     imprisoned in Pale.  It could have been in early June or late May,

18     because we heard it while in prison.  It didn't happen while we were

19     free.

20        Q.   And I am putting it to you that this was in early April 1992.  It

21     is possible that you heard about this later.  Would you allow for this

22     possibility?

23        A.   No.  This was in my neighbourhood after all.  And during that

24     period of time, in Renovica -- in Renovica and in Bare, there was not a

25     single murder.  I can assure you of that.

Page 18215

 1        Q.   Very well.  At the very end, something that we typically see with

 2     witnesses and I will tell you about it.

 3             I have a statement that gave to the Sarajevo SJB, the

 4     State Security Department.  You remember giving this statement on the

 5     30th of August, 1992; right?

 6        A.   Yes.  As soon as I left the camp.

 7        Q.   For the Trial Chamber, the ERN number is 0021-6896.  And the last

 8     ERN number is 0021-6900.

 9             JUDGE DELVOIE: [Previous translation continues] ... Is it on the

10     document list, Mr. Cvijetic?  No?

11             MR. CVIJETIC: [Interpretation] No, Your Honours.  And I will not

12     use it -- I will not ask that it be tendered into evidence.  I will just

13     use it to put questions to the witness.

14        Q.   Sir, I'm comparing this to the statement you gave.

15             In that statement, you say that there were policemen there and

16     the first time that you saw them was when you arrived in front of the MUP

17     building and up until that time you only saw one sort of uniforms.

18     Whereas today you seem to say that you had seen a number of different

19     uniforms.  Why this discrepancy?

20        A.   Sir, I don't know whether you know about the condition in which

21     we left the prison.

22             Your Honours, we left the camp on the 28th and this is when we

23     were exchanged.  I gave the statement on the 30th.  Most likely I skipped

24     a number of items in that statement.  And as for these uniforms, believe

25     me, you don't need to rely just on me.  Any resident of Renovica can

Page 18216

 1     confirm this to you.  There were different uniforms there.  There was a

 2     diversity of uniforms.  There were camouflage uniforms, blue/grey.  There

 3     were reserve police uniforms, military uniforms.

 4        Q.   All right.  So it is your position that the statement that you

 5     gave, when you arrived on the Muslim territory, is not entirely true;

 6     right?

 7        A.   No, everything there is true.  But perhaps I did not go into

 8     great details in that statement.

 9             MR. DI FAZIO:  If Your Honours please, I'm not objecting, but

10     I -- just in order to be able to follow this evidence, I need to know

11     where in the statement the witness said that when he arrived in front of

12     the MUP and up until that time he had only seen one sort of uniform.

13             I can't find that in the statement.  If Mr. Cvijetic would be so

14     kind as to direct me to it, then I can ... I can sit down.

15             MR. CVIJETIC: [Interpretation] No, you misunderstood my words.

16        Q.   I said that if we read the statement and reach the section where

17     you come in front of the MUP building and you mentioned a Pinzgauer

18     there, which is on page 2 of your statement, that there were about a

19     dozen soldiers in camouflage uniforms.  And you go on to say - that's on

20     page 4 - that a soldier in camouflage uniform kicked you in the belly.

21     Correct?

22        A.   Yes.  He did that when I came to Pale, when I was taken to the

23     MUP building allegedly to make a statement.  And when the guy was taking

24     me from the former cultural centre to the MUP building, some youngster

25     kicked me in the belly.

Page 18217

 1        Q.   But your statement says a soldier.  That's why I'm asking.  Is it

 2     correct that it was a soldier who did it?

 3        A.   [No interpretation]

 4        Q.   [Overlapping speakers] ... okay, I -- it doesn't matter all that

 5     much to me.  But speaking about that particular incident, you said that

 6     an acquaintance protected you and that you were not mistreated while you

 7     were giving a statement in the MUP building and when you left the MUP

 8     building.  Is that correct?

 9        A.   I'm really here to -- just to say the truth.

10        Q.   Did -- did he protect you?  Just say that.

11        A.   Yes, he did.  But I still don't know who he is.  But I'm -- I am

12     grateful to him.

13        Q.   You failed to say today that you were later taken to Kula which

14     was an official prison.

15        A.   After 50 days in prison, we were taken to Kula.

16        Q.   You said that you were treated fairly there and that you even had

17     four meals a day when you had to work physically; correct?

18        A.   Yes.

19        Q.   Furthermore you spoke about this special unit of sorts.  But I

20     see that this unit was led by one Slavica Jovanovic, a woman.  That's

21     what you say.

22        A.   Slavica Jovanovic brought those guys.  But it was our conclusion

23     later that Rajko Kusic actually was the leader of the unit.  They were

24     Rajko Kusic's men.

25        Q.   And you say you've heard that he also wore a camouflage uniform.

Page 18218

 1        A.   Yes.  He also had some sort -- I cannot state with any certainty

 2     though.

 3        Q.   We are speaking about Slavica Jovanovic?

 4        A.   Yes, Slavica Jovanovic.

 5        Q.   You cannot be sure who she belonged to?

 6        A.   She mostly came with that group.  I don't know if you want to

 7     know the names of the people I knew.

 8        Q.   I'm only interested in her.

 9        A.   She was always came with that group that belonged to Rajko Kusic.

10             MR. CVIJETIC:  It has been pointed out to me that one cannot tell

11     from the transcript that we're speaking about a woman.

12             THE WITNESS: [Interpretation] Yes, about a woman.

13             MR. CVIJETIC: [Interpretation] Very well.  I have no more

14     questions.

15             JUDGE DELVOIE:  Mr. Witness, you were speaking about a woman.

16     Was that woman wearing a uniform?

17             THE WITNESS: [Interpretation] Yes, she was dressed in a uniform.

18     I have been speaking about uniforms a lot.  There were three or four

19     kinds of uniforms.  The people who came to the prison on the occasion of

20     the attack on us and everything else, there were uniforms of the reserve

21     police which I know well.  They have this characteristic blue/grey

22     pattern.  Then there were green camouflage uniforms.  Then there were

23     blue and grey uniforms, which makes me think that they were police

24     officers.  I really can't be sure about Slavica Jovanovic.  I think that

25     she wore some sort of an overall.  Whether it was blue/grey or

Page 18219

 1     green/grey, I'm not sure now.

 2             JUDGE DELVOIE:  And when you speak in general about soldiers or a

 3     soldier, what kind of uniform can they wear, in your opinion?  When

 4     you're talking about a soldier, what uniform do they wear?

 5             THE WITNESS: [Interpretation] I also served in the former JNA, so

 6     I was a soldier of that army.  And the regular uniform of a JNA soldier

 7     is green.  And I never saw camouflage uniforms until the war.  While I

 8     was serving in the JNA, the uniforms were plain green, actually

 9     olive-drab, if we're speaking about soldiers, proper soldiers.

10             JUDGE DELVOIE:  So in -- proper soldiers as you say.

11             So in what you were telling us today, when you speak about

12     soldiers, you speak about military men?  You mean military men.  Not men

13     in blue uniforms, not men in police uniforms.  For instance, the man who

14     kicked you in the belly was a military man, because in your statement,

15     you said:  "Soldier."

16             THE WITNESS: [Interpretation] I said that he was a soldier.  He

17     probably was.  I -- I really don't know.  I was being taken from the room

18     where we were detained to the MUP building and then a man dressed as a

19     soldier kicked me.

20             JUDGE DELVOIE:  Thank you.

21             JUDGE HALL:  Is there cross-examination on ... on behalf of -- of

22     the Zupljanin Defence?

23             MR. KRGOVIC:  No, Your Honours, we don't have a question for this

24     witness.

25             JUDGE HALL:  Thank you.

Page 18220

 1             Do you have anything in re-examination, Mr. --

 2             MR. DI FAZIO:  Just two very brief matters.

 3                           Re-examination by Mr. Di Fazio:

 4        Q.   In your statement given on the 30th of August, 1992, to the

 5     Security Services Centre Sarajevo, did you say -- I can show it to you if

 6     you wish, but if you have any memory tell us, when describing the

 7     military -- you were going into the military apartment building, did you

 8     say this, or words to this effect:  "We formed a column, and the

 9     aggressors's soldiers mixed among us because they were afraid of sniper

10     fire.  As I entered" --

11             JUDGE HARHOFF:  Where are you quoting from?

12             MR. DI FAZIO:  I'm sorry.  If Your Honours please, page 3.

13     Page 3, first paragraph.

14        Q.   "As I entered a military building, a reserve policeman whose name

15     I do not know hit me in the head in front of my parents" --

16             MR. ZECEVIC:  Sorry, I understood Mr. Cvijetic was not -- didn't

17     want to quote from the statement.  We cannot follow the statement -- or

18     the accused, actually, cannot follow the statement on the monitor because

19     it -- it's not on the 65 ter list or uploaded in the transcript -- in --

20     in the e-court.  I'm sorry.

21             MR. DI FAZIO:  It's 65 ter 9145.

22             MR. ZECEVIC:  Thank you very much.

23             MR. DI FAZIO:  And if we can -- if everyone would prefer me to

24     put it on the screen, I'll do that if that -- I was trying to save time,

25     but I think that, given the circumstances, it's best if we put it up on

Page 18221

 1     the screen.

 2             So can we have that up on the screen, please.  And the B/C/S

 3     version as well so -- for the witness.

 4        Q.   Now, Witness, I don't know exactly where this portion is in the

 5     B/C/S.

 6             MR. DI FAZIO:  If Your Honours please, and Defence counsel are

 7     pleased, it's page 3 of the English.  So if we can go to page 3 of the

 8     English, it's at the top.  Right.  And I think it would have to be into

 9     the next page of the B/C/S at least, and it appears to be at the

10     beginning of the paragraph.

11             So could we go to page 2 of the B/C/S.

12             MR. CVIJETIC: [Interpretation] If I may help.  On the following

13     page, the last paragraph.  The following page of the B/C/S.

14             MR. DI FAZIO:  Thanks.

15             MR. CVIJETIC: [Interpretation] Toward the end of the page -- or,

16     actually, the bottom.

17             This is not in dispute.  The witness said as much while he was

18     answering your questions today.  I'm not sure whether it is really

19     necessary to quote that.

20             MR. DI FAZIO:  Thank you.  I'll just wrap this up.

21             In the last paragraph that you can see there in the B/C/S, you

22     should find words to the effect that I was quoting to you.

23             You were talking about forming a column, aggressors' soldiers

24     being mixed up amongst you because of fear of sniper fire, entering a

25     military apartment building, and being hit in the head by a reserve

Page 18222

 1     policeman.

 2             Do you see that?

 3        A.   Yes, I can see now.  And that's what the statement says.  But we

 4     seem to be mixing things up, the kick I received at Pale and the hit I

 5     received here.  What is referred to here happened at Renovica.

 6             MR. CVIJETIC: [Interpretation] The witness is right.  If this is

 7     what you're looking for, then -- I mean the incident with the soldier and

 8     the kick, that's on page 4.  The witness is right.

 9             MR. DI FAZIO:  Yes, he is.  But what I'm concerned about is a

10     suggestion that it was only a failure to mention policemen at all until

11     they got to Pale.  That's what I'm concerned about.  And it's here in the

12     statement.  I think I've made my point, and I don't need to go any

13     further with this at this point.  So thank you.

14        Q.   You do see the part in the B/C/S where you say - still talking

15     about Renovica, not Pale, Renovica - where you say:  "A reserve policeman

16     whose name I do not know hit me in the head in front of my parents."

17             You see that?

18        A.   Yes, I see that.

19        Q.   Thank you.  I've done with that.

20             And the last issue I want to ask you about just very quickly.

21     You were asked by Defence counsel about a family from Bare, I think, who

22     were killed.  At any time on the 22nd of May or in the time that you were

23     in the Pale culture centre imprisoned, did any official or guard, or did

24     you find out from any other source if your predicament, your situation

25     being imprisoned there, was somehow contacted with Bare, what had

Page 18223

 1     happened at Bare?

 2        A.   Well, you see, I can only repeat that the incident at Bare

 3     couldn't have happened before the 22nd.  I don't know what happened after

 4     the 22nd.  But I can say for certain that after some time spent at Pale,

 5     I'm not sure I -- I'll -- I remember the name of the persons killed

 6     correctly.  I think it's Vukasinovic.  But I know that Vukasinovic guy

 7     from sight and my -- because my father was a bus driver, and the father

 8     of the Vukasinovic family was on good terms with my father.

 9        Q.   I don't want to go into the ins and outs of -- it's a simple

10     question.  In the time on 22nd of May or in Pale, when you were

11     imprisoned in Pale, did anyone, a guard, security, other prisoners,

12     anyone, ever suggest to you or say to you that your situation, the fact

13     of being taken from your home and imprisoned, was connected somehow with

14     what had happened in Bare?

15        A.   No.

16        Q.   [Previous translation continues] ... thank you, I --

17        A.   I obviously misunderstood.  No, that wasn't the case.

18             MR. ZECEVIC:  I'm sorry, Your Honours, the witness was

19     interrupted in the middle of his answer on 32 -- page 32, 10.  He was

20     explaining that some member of Vukasinovic family came, so -- and then he

21     was interrupted.  I would really appreciate if he could finish his -- his

22     answer in full.

23             MR. DI FAZIO:  If I interrupted, then I apologise and I shouldn't

24     have.

25        Q.   And, Witness, is there anything further that you wanted to add

Page 18224

 1     when you were taking about the Vukasinovic family and when I interrupted

 2     you?

 3        A.   If it's interesting to you, Your Honours, I can continue the

 4     story.

 5             My father and Mr. Vukasinovic -- well, my father was a bus driver

 6     and he hung out with Serbs a lot, and he was well respected by people.

 7     And when that Mr. Vukasinovic came to the camp or the prison at the

 8     culture centre at Pale - he must have been the son of the people killed

 9     up there - he came to take it out on us.  He really didn't beat me.

10     Whether it was owing to my father, I don't know.  But on that day, he

11     came.  He brutally beat up Hajrudin Karic.  And when I say "he," I mean

12     Mr. Vukasinovic.

13             If you're interested in anything else, ask me.

14             JUDGE HALL:  Thank you, sir.

15             We thank you for your assistance to the Tribunal, sir.  You are

16     now released as a witness, and we wish you a safe journey back to your

17     home.

18             THE WITNESS: [Interpretation] Thank you too.

19                           [The witness withdrew]

20             JUDGE HALL:  Mr. Di Fazio, this brings us conveniently to the

21     ordinary time for the break.  I assume your next witness, your next

22     scheduled witness, is ready to come on?

23             MR. DI FAZIO:  I believe that is so.  And I have been asked to --

24     yes, that is so.  And if we take the adjournment now, that will really

25     serve -- assist us in getting that witness ready and producing him

Page 18225

 1     immediately after the break.

 2             JUDGE HALL:  So we return in 20 minutes.

 3                           --- Recess taken at 3.43 p.m.

 4                           --- On resuming at 4.10 p.m.

 5             MR. HANNIS:  Good afternoon, Your Honour.  Now, for the

 6     Prosecution, I'm Tom Hannis, along with Belinda Pidwell, Selma Sakic, and

 7     Crispian Smith.

 8             Our next witness is Manojlo Milovanovic, ST-260.  He has no

 9     protective measures.  He is testifying openly, and we're ready to start

10     with him.

11             JUDGE HALL:  Thank you.

12                           [Trial Chamber and Legal Officer confer]

13                           [The witness entered court]

14             JUDGE HALL:  Good afternoon to you, sir.  I would first of all

15     ask you to read the solemn declaration on the card that the usher has

16     handed to you.

17             THE WITNESS: [Interpretation] Good afternoon.  I solemnly declare

18     that I will speak the truth, the whole truth, and nothing but the truth.

19                           WITNESS:  MANOJLO MILOVANOVIC

20                           [Witness answered through interpreter]

21             JUDGE HALL:  Thank you.  You may be seated.

22             And from your responses so far, I take it that you are hearing me

23     in a language that you understand.

24             THE WITNESS: [Interpretation] I am.

25             JUDGE HALL:  I would first of all point out to you that the

Page 18226

 1     solemn declaration that you have just made imposes upon you an obligation

 2     to speak the truth, under pain of the penalties for perjury which this

 3     Tribunal is empowered by its Statute to impose on witnesses who give

 4     false or misleading testimony.

 5             Welcome to the Tribunal.  And you have been called as a witness

 6     by the Prosecution.

 7             Could you, first of all, tell us your name, please.

 8             THE WITNESS: [Interpretation] Manojlo Milovanovic.

 9             JUDGE HALL:  What is your date of birth, what is your

10     ethnicity --

11             THE WITNESS: [Interpretation] 21st of November, 1943.  I'm a

12     Serb.

13             JUDGE HALL: [Microphone not activated] ... and what is or was

14     your --

15             THE INTERPRETER:  Microphone, please, Your Honour.

16             MR. CVIJETIC: [Interpretation] I don't think we had

17     interpretation of your last question.

18             JUDGE HALL:  Thank you, Mr. Cvijetic.

19             Are you hearing me now, sir?

20             THE WITNESS: [Interpretation] I am.

21             JUDGE HALL:  What is or was your profession?

22             THE WITNESS: [Interpretation] I was a general, lieutenant

23     general, in the Army of Republika Srpska.

24             THE INTERPRETER:  Interpreter's correction: colonel general.

25             JUDGE HALL:  Have you testified previously before this Tribunal

Page 18227

 1     or before any of the courts in any of the countries that comprise the

 2     former Yugoslavia?

 3             THE WITNESS: [Interpretation] This is the third time I'm

 4     testifying before this Court.  I also testified once before the

 5     War Crimes Court of Bosnia-Herzegovina.

 6             JUDGE HALL:  Thank you.

 7             I need then only remind you of the procedure that is followed

 8     here, that is, that the side calling you begins.  The side opposite would

 9     have an opportunity to ask questions of you.  The side calling then wraps

10     up.  And, at that stage, or indeed at any earlier stage, the Bench may

11     have questions of you.

12             The -- your appearance before the Tribunal is in its afternoon

13     sittings, because we share the courtroom space with other trials, and it

14     is expected that your testimony would not be completed today but would in

15     fact extend into tomorrow.

16             We would rise for the day at 7.00 and resume tomorrow afternoon

17     at 2.15.

18             The sessions for each day's sitting are divided into intervals of

19     90 minutes each and that is primarily to allow for the tapes that record

20     the proceedings to be changed, but it also allows for the convenience of

21     the witnesses, counsel, the Bench, and -- and the support staff to have a

22     break.  Those breaks are of 20 minutes' duration.  But notwithstanding

23     those set breaks that I have indicated, if at any time during your

24     testimony you have a need for a break, we will, of course, accommodate

25     you.

Page 18228

 1             The Prosecution has indicated that they expect that their

 2     examination of you would last for three hours.  And counsel for the

 3     Accused Stanisic has indicated an hour for cross-examination.  And

 4     counsel for the Accused Zupljanin has indicated an hour and a half.

 5             And I would now invite Mr. Hannis, for the Prosecution, to begin.

 6     Thank you.

 7             MR. HANNIS:  Thank you, Your Honour.

 8                           Examination by Mr. Hannis:

 9        Q.   Good afternoon, sir.

10             I understand that you were a professional soldier.  Can you tell

11     us how many years you served in that capacity?

12        A.   If we count the schooling I had, I spent a total of 42 years in

13     the army.

14        Q.   Can you tell us what year that career began.

15        A.   In 1959, I enrolled into the school for non-commissioned

16     officers.  I graduated in 1961.  Then I worked as non-commissioned

17     officer in Benkovac garrison, near Zadar, for 14 months.  Following that,

18     I went to the Military Academy in Belgrade; it lasted for four years.

19     And I graduated in 1966.

20             After that, I served in Banja Luka.  Up until 1975, I was a

21     platoon commander, company commander, and I was head of the School of

22     Reserve Officers for Armoured Units.  In 1975, I went to the higher

23     Military Academy, as it was known at the time.  It was the Command Staff

24     School for Tactics.  I graduated in 1977 and went to serve to Prilep

25     garrison where I served as battalion commander for four years.  In 1981 I

Page 18229

 1     moved to the Titov Veles garrison, where I served as an operative in the

 2     motorised brigade.

 3             From there I went to the War School in 1986.  I graduated the

 4     following year, in 1987.  And then I returned to the garrison in

 5     Titov Veles, where I served as commander of the 212th Motorised Brigade.

 6     I remained brigade commander until the 30th of January, 1989, when I was

 7     transferred to the command of the 3rd Military District in Skopje as an

 8     operative in the army command.

 9             I remained there until the 3rd of March, 1992, when I withdrew

10     the combat part of the JNA from Macedonia to Serbia, to the command of

11     the Nis garrison.  I remained in Nis until the 11th of May, 1992, when I

12     was transferred to the Sarajevo garrison, to the same post I held in Nis.

13     However, I never reached Sarajevo.  I reached as far as the Han Pijesak,

14     near Crna Rijeka, because the command of the 2nd Military District

15     withdrew from Sarajevo on the 3rd of May, after the events in

16     Dobrovoljacka Street.

17             From the 11th of May until the end of the war, I was

18     Chief of Staff of the Main Staff of the Army of Republika Srpska and

19     deputy commander.

20        Q.   Thank you.  General, can you tell me, what rank did you hold in

21     early 1992 when you were in Macedonia?

22        A.   While in Macedonia, I was a colonel.  Upon withdrawal of the JNA

23     from Macedonia, I was given a decree dated the 25th/26th of April, 1992,

24     promoting me to major-general.  That is to say, that I arrived in Bosnia

25     as major-general in the JNA.

Page 18230

 1        Q.   And how was it that you were sent to Bosnia in 1992?  Upon

 2     whose -- whose order or whose decree?

 3        A.   On the 8th of May, 1992.  I found myself in the Pec garrison when

 4     I was touring the units that had withdrawn from Macedonia.  I was told

 5     then to return immediately, urgently, to Nis.  I arrived there and I was

 6     given two presidential decrees.  The one on promoting me into

 7     major-general, and the second one on my transfer.  The presidential

 8     decrees were signed by the rump Presidency of the SFRY.  The second

 9     presidential decree transferred me to the command of the

10     2nd Military District, Sarajevo garrison, as chief of the operations and

11     training organ, the same position I held in Nis.  The decree was to be

12     implemented by the 11th of May.

13             I set out from Nis and I was first supposed to report to the

14     General Staff of the Army of Yugoslavia to pick up the transfer

15     documents, and I was then told that the first presidential decree on

16     transfer was being changed and that my new position was Chief of Staff of

17     the army.

18             In addition to that, I was given another order; namely, that the

19     JNA was to withdraw from Bosnia by 19th of May, inclusive of the same

20     year.  This confused me.  I couldn't understand why I was being

21     transferred to the position of the chief of the 2nd Military District if

22     the JNA was to withdraw from Bosnia, because there was a prior agreement

23     between the Presidency of the JNA and the Presidency of Bosnia about the

24     JNA remaining in Bosnia for the -- for another five years to protect

25     equally the interests of all three nations in Bosnia.

Page 18231

 1             The chief of the personnel administration of the General Staff,

 2     General Gojko Krstic, told me that I would be given more detailed

 3     explanations by General Ratko Mladic once I see him in Bosnia.  We met in

 4     the afternoon in Bosnia, and Mladic explained to me that given that the

 5     JNA was to withdraw, the remaining two nations in Bosnia, that is to say,

 6     Muslims and Croats, already had their armies, and as a result of that,

 7     the Presidency of the Serbian Republic of Bosnia-Herzegovina decided to

 8     establish the Army of the Serbian Republic and that we were to remain in

 9     that army if we wanted.

10        Q.   Let me ask you a couple of questions and then we'll return to

11     May of 1992.

12             How -- what year did you retire from the army?

13        A.   I retired pursuant to my own request, and I received my first

14     pension on the 1st of May, 2001.  That is to say, that I did it sometime

15     in March of 2001 after being removed from the position of the minister of

16     defence of Republika Srpska.

17        Q.   And since that time, have you been fully retired, or have you

18     done other work?

19        A.   I've been mostly retired since that time.  However, for my own

20     needs, I conducted some analyses of the war.  I also cooperated with the

21     editorial board of the Academy of Arts and Sciences of Serbia in drafting

22     their encyclopedia.  And I have also served as the Republika Srpska

23     senator since --

24             THE INTERPRETER:  The interpreter didn't hear the year.

25             MR. HANNIS:

Page 18232

 1        Q.   I'm sorry, sir, the interpreter did get the last part of your

 2     answer.  You said you had served as a Republika Srpska senator since ...

 3     and we didn't catch the time, the year.

 4        A.   Since May 2009.  And my term is for five years unless I'm removed

 5     due to some errors I may commit.

 6        Q.   Thank you.  Now, you've mentioned that in May, when you were sent

 7     to Bosnia, that you were supposed to meet with Ratko Mladic.

 8             Did you know Ratko Mladic before May of 1992?  And, if so, how

 9     did you know him?

10        A.   I have known Ratko Mladic since April 1981.  We met at the

11     Titov Veles garrison when I served as an operative in the motorised

12     brigade.  He was the training clerk in the command of the

13     3rd Military District, and he came to conduct an inspection in my

14     brigade.  I was assigned to escort him on that day.  We did not get along

15     well the day we met; however, we cooperated well afterwards.

16        Q.   And in 1992, in May, when you arrived in Han -- I'm sorry, I

17     can't pronounce the name.  When you arrived, you said you met with

18     Ratko Mladic and he told you that the Serb Republic of Bosnia was going

19     to have its own army.  Did you decide to join that army?

20        A.   Yes.

21        Q.   That army which eventually came to be known as the VRS.  What

22     position did you hold, and what was your rank?

23        A.   I arrived there in the rank of Major-General.  I was Chief of the

24     Main Staff of the Army of Republika Srpska and, at the same time,

25     deputy commander of the Main Staff, that is to say, Mladic's deputy.

Page 18233

 1             I was promoted to Colonel General on the 28th of June, 1994, and

 2     I was promoted to the rank of Colonel General as minister of defence, I

 3     think in 1999.  Also on the 28th of June.

 4        Q.   Could you tell us what the abbreviation or the acronym is in

 5     Serbian for the position of Chief of Staff?

 6        A.   NGS, or "Sh" in B/C/S.  And in abbreviated form it was "N Sh,"

 7     Chief of Staff.

 8        Q.   Thank you.  And how long did you work in that position as

 9     Chief of Staff for General Mladic?

10        A.   From the 11th of May until the 23rd of December.  From the

11     11th of May, 1992, until the 23rd of December, 1996.  However, I remained

12     at the location of the Main Staff until the 27th of April, 1997, when we

13     disbanded.

14        Q.   And can you tell the Judges briefly what was your role or your

15     duties as -- as Chief of Staff vis-ā-vis General Mladic?

16        A.   My job was to organise the work of the staff.  That is to say,

17     that I was the head of the staff.  I was the Chief of Staff.  I was the

18     first assistant of the commander in charge of military operations of the

19     army.  That is to say, that the preparations and conduct of military

20     operations as well as planning of military operations and typically the

21     beginning of implementation of each operations was under my jurisdiction.

22     Later on, the conduct of the operation could have been assigned to

23     another person, or the commander could have left it under my command.

24     That is to say, that I was in charge of the practical use of the Army of

25     Republika Srpska.  In addition to me, he also had six other assistants:

Page 18234

 1     For morale, for logistic, security, finance, chief of air force

 2     administration.  I don't know if I skipped anything.

 3        Q.   That's fine for my purposes today.

 4             You mentioned earlier the Main Staff.  I think I have also seen

 5     in documents and heard the terms, General Staff; sometimes

 6     Supreme Command Staff.  Can you tell us what the differences are between

 7     those three terms in regards to the VRS?

 8        A.   When an armed conflict erupts, regardless of who the opponent is,

 9     whether the opponent is a foreign occupying force or it transpires in a

10     civil war, as was the case in Bosnia and Herzegovina, a state that is not

11     entirely properly organised can only be proclaimed by means of the

12     constitution but does not have all elements of statehood - military,

13     police, and judiciary.

14             Republika Srpska was proclaimed on the 9th of January, 1992.  It

15     had its constitution but not its own army.  In such cases, military

16     leadership is established and is known as the Main Staff.  They function

17     as the Main Staff up until the state is completely legally properly

18     organised, at which point it is transformed into General Staff.  All

19     countries have General Staffs in peacetime.  All countries that are

20     recognised as independent countries.

21             During wartime, General Staff is -- is transformed into the Staff

22     of Supreme Command.  Our Staff of the Supreme Command was to be

23     transformed into the General Staff or during the war it was supposed to

24     be known as the Supreme Command Staff, as the Muslims had.  However, we

25     couldn't have it for two main reasons.  The first reason is that the

Page 18235

 1     newly established command that was established in early December of 1992,

 2     the commander of the Main Staff -- or General Staff was not included, who

 3     was supposed to become a member of the command as chief of the

 4     General Staff.  In this case, this was General Ratko Mladic.  So we

 5     remained as Main Staff.  That is to say, we were neither General Staff or

 6     Supreme Command Staff.

 7             That is the genesis -- rather, these are the origins of the

 8     Main Staff.

 9        Q.   Thank you for that explanation.  In 1992, your staff consisted of

10     approximately how many people, how many generals, on the Main Staff?

11        A.   In the VRS on the 12th of May when the assembly adopted the

12     decision to establish the VRS, there were five of us generals from the

13     JNA.  Ratko Mladic, General Gvero, General Djukic, I, and General Talic,

14     who, until that time, was commander of the 5th Corps of the JNA, which

15     was later renamed the 1st Krajina Corps of the VRS.  There were five

16     generals, including me.

17        Q.   And by December of 1992, what was the makeup or the size of the

18     Main Staff of the VRS?

19        A.   The Main Staff was established on the eve of the Assembly session

20     of the 12th of May.  There were 12 of us on the staff.  Four generals,

21     the ones I mentioned, except for Talic.  Then there were six colonels and

22     lieutenant-colonels.  And two lower-ranking officers.  That is, one

23     lower-ranking officer, Captain Pecanac, Miodrag was his first name, who

24     was chief of security of the commander of the Main Staff who was -- and

25     that was Ratko Mladic.  And there was an NCO who was soon promoted to the

Page 18236

 1     rank of lieutenant, Dusan Todic [as interpreted], who became chief of the

 2     security detail of the chief of General Staff on the Main Staff, which is

 3     me.

 4             May I mention the site where this took place?

 5        Q.   [Previous translation continues] ... yes, please.

 6        A.   I'm asking because you failed to mention the site a minute ago,

 7     so I thought it may be confidential.

 8             It was Crna Rijeka, 9 kilometres southeast of Han Pijesak.  After

 9     that, the Main Staff was manned additionally, especially after the

10     withdrawal of the JNA, because in these eight days until the withdrawal

11     of the JNA we hired some officers from the command of the

12     2nd Military District and then we continued to man the Main Staff with

13     our own personnel.  However, the manning level never exceeded 36 level --

14     per cent during the war.  We didn't want to take out officers from the

15     units on the front line because which wanted them to be as well manned as

16     possible.

17        Q.   Is my understanding correct that in the VRS the Main Staff was

18     the highest echelon?

19        A.   Yes, it was the highest command.  It was a command of strategic

20     significance.

21        Q.   Thank you.  And during 1992, in your position as Chief of Staff

22     and deputy commander, can you tell the Judges what was the nature and the

23     frequency of your contact with General Mladic?

24        A.   To save space in the facilities where we were put up,

25     General Mladic and I had a joint office, shared an office.  Among other

Page 18237

 1     things, that we were rarely present at the same time in the Main Staff.

 2     When he was there, I wasn't, and vice versa.  We had daily contact

 3     whenever General Mladic was in Bosnia-Herzegovina.

 4             I must also explain something that you asked me to but I failed

 5     to do so.  The position of deputy commander.  When General Mladic was not

 6     in Bosnia-Herzegovina, I automatically become commander of the army and

 7     could remain in that capacity for up to 30 days.  If General Mladic fails

 8     to return within 30 days, then the Supreme Command appoints a -- appoints

 9     somebody to stand in, but he never stayed away for longer than 30 days so

10     that the Supreme Command didn't have to intervene.

11             And now if you could repeat the second part of your question.

12        Q.   I think you've answered enough for present purposes.  It was

13     about the nature and frequency of your contact with General Mladic.

14             I wanted to ask you if during the time that you knew

15     General Mladic from -- from 1981, and particularly during your time as

16     Chief of Staff, did you have the opportunity to become familiar with his

17     personal handwriting?

18        A.   Yes.

19        Q.   And you've testified -- you've told us that you have testified

20     in -- in -- in another case in this Tribunal.  I think you testified most

21     recently in April of this year.  Is that correct?

22        A.   Yes.

23        Q.   Thank you.  And I understand that in connection with that

24     testimony you reviewed a number of handwritten diaries to see if you

25     could identify the handwriting therein.  And I would like to start by

Page 18238

 1     showing you, on the screen in a second, it's 65 ter number 3699.  And

 2     this is a copy of a chart that was used in connection with your testimony

 3     earlier this year.  I think it's two pages.  We'll have a look at the

 4     first page.  And I will ask if you can recognise it.

 5             Are you able to see it on the screen?

 6        A.   I can see it.  It was the -- the letters were a bit small.

 7        Q.   Are you able to read it now?

 8        A.   Yes.

 9        Q.   Okay.  And on this first page, there are five diaries, or

10     notebooks, that you looked at and indicated that you recognise the

11     handwriting.  And recognised it as that of Ratko Mladic.  Is that

12     correct?

13        A.   It both is and is not correct.

14        Q.   [Previous translation continues] ...

15        A.   It is correct that I reviewed five notebooks of General Mladic

16     the first time around.  I didn't read them all through, but I asked for

17     permission to read those sections of the notebooks that referred to me,

18     where my name is mentioned or the abbreviation that refers to me, either

19     "N Sh" or "Milovanovic."

20             It was 14 years ago in late 1996 when I first saw Mladic write.

21             THE INTERPRETER:  Could the witness please repeat.

22             MR. HANNIS:

23        Q.   I'm sorry, the interpreters ask you if you could repeat.  And

24     when you do, I wanted to ask you, you said:  "It was 14 years ago in late

25     1996 when I first saw Mladic write," and I'm told by my language advisor

Page 18239

 1     that what you said was:  "last saw him write."

 2             Can I confirm for me if that's correct?

 3        A.   It was the last time, 14 years ago.

 4        Q.   Now I know -- well, let me ask you this:  Do you recall how many

 5     notebooks or diaries in total that you've looked at in connection with

 6     your preparation to testify in that earlier case?

 7        A.   I looked at a total of 23 notebooks:  Five in Banja Luka and

 8     18 here.

 9        Q.   Thank you.  And it's my understanding that you looked at the five

10     in Banja Luka in July of -- of 2009, when an investigator named

11     Alistair Graham came to see you.  Is that right?

12        A.   That is right.  His name was Graham, but that's all I know about

13     him.

14        Q.   Thank you.

15             MR. HANNIS:  And if we could go to page 2 of this exhibit.

16        Q.   You've seen on page 1 there are five notebooks.  And on the

17     second page we see an additional 13, to add up to a total of 18 on these

18     two pages.

19             Do you recall when you looked at this group of 18 for the first

20     time?  Was that in April of this year?

21        A.   I think that at the bottom there should be a date, the

22     22nd of April or the 23rd.

23             On the previous page, the date indicated was the 22nd of April.

24        Q.   Yes.

25             MR. HANNIS:  I think -- if we could go to a landscape view, I

Page 18240

 1     think on the far right side of the bottom we'll see it is the 22nd of

 2     April.

 3             I would note, Your Honours, that the English translation says

 4     22nd of August, but I think on the original and as the General said is --

 5     the date is the 22nd of April, 1992.

 6        Q.   Also, on this second page, we see that you've written in column

 7     number 4, which it's headed:  "I do not recognise the handwriting of

 8     Ratko Mladic."

 9             Could you explain that for us?

10        A.   I added a handwritten comment.  It is not Mladic's handwriting,

11     and the numbers 0668-1136, -1137, -1138, -1139, -1140, -1141, -1142.

12             I have not answered the question under column 6 because I didn't

13     have the time to study each document.

14             I don't know what -- what's unclear here.

15        Q.   Yeah, let me try and assist.  I have seen the handwritten note at

16     the bottom where you mention certain ERN - that's our acronym regarding

17     the numbering of evidence documents - certain page numbers, and I note

18     that all of those page numbers are within the range of the diary that is

19     listed as number 18 on this list.  However, on this page, in column 4,

20     which is a column that says: "I do not recognise the handwriting," you

21     put your name.

22             When you testified in the Stanisic and Simatovic case in April,

23     at page 4407, Mr. Groome went through with you what had happened there.

24     Because it's my understanding that you had identified all of the

25     18 notebooks as containing the writing of Mr. Mladic?

Page 18241

 1             MR. O'SULLIVAN:  Your Honour, I wonder if my friend could not

 2     lead the witness.  He's testifying viva voce.  This is leading.

 3             MR. HANNIS:  Your Honours, he's testified under oath in the other

 4     case.  It's clear to me that there's some confusion seeing this document.

 5     I'm just trying to refer to him to his previous clarification of this

 6     document.

 7             JUDGE HALL:  Please proceed, Mr. Hannis.

 8             MR. HANNIS:

 9        Q.   Did you understand my question?

10        A.   Yes, I did.  And, I beg your pardon, but I also understand what

11     you failed to understand.

12             On page 2 which we see on screen now, while I was giving evidence

13     to the Trial Chamber I admitted that I made a mistake on page 2.  I

14     wrongly filled in columns 3 and 4.  In column 3, I should have entered

15     "Ratko Mladic"; and in column 4, "MM."  I didn't look at the first page

16     carefully where there was a heading, so I got it mixed up.

17             And what -- but my handwritten remark below which reads: "It is

18     not Mladic's handwriting," this refers to the pages where the handwriting

19     is not that of Ratko Mladic.  Because you or somebody here marked each

20     page with a number.  And in the diaries, we found somebody else's

21     handwriting on several pages of Mladic's diary.  Mladic obviously

22     consulted somebody else present.  And since he had no slip of paper at

23     hand, which was his way of communicating with me, by writing on a slip of

24     paper, write to me what you think about it, and I couldn't answer him

25     aloud in the meeting.  But in some cases there were no slips of paper at

Page 18242

 1     hand, and then he would write it in his -- in his notebook and give it to

 2     his assistant whom he asked for his opinion.

 3             All the notebooks have been identified, generally speaking, as

 4     Mladic's handwriting, with the exception of the -- these numbers stated

 5     here, and I believe they refer to pages.

 6        Q.   Thank you.  That's what I understood, was that those seven pages

 7     listed to the bottom were the only pages in the 18 diaries that were not

 8     Mladic's handwriting, based on your review.

 9        A.   It can be put that way.

10        Q.   Thank you.  I want to ask about the general practice in the VRS,

11     and I guess, before that, in -- in the JNA.  Was it standard practice for

12     yourself or for high-ranking officers to keep notebooks?

13        A.   We were made to do so, or taught to do so, at military schools.

14     We had to follow the lectures of our teachers and make notes.  That was

15     useful for us because when we are preparing for the examinations, we had

16     sort of shorthand textbooks, and it became the -- a habit for all of us

17     to make notes when somebody is speaking.

18             There was a system in the JNA to supply each officer with a

19     so-called work book.  There were two kinds: One was of a smaller format

20     that fit in your pocket and you can use it in the field, and the other

21     was a bit bigger and was mostly used to take notes during meetings where

22     there's a table, at commands and staffs and so on, a table and chairs.

23             Most all of us worked that way.  We were issued these notebooks.

24     And once they were full, we were obliged to return them.  If the head of

25     office did about his job conscientiously, he would ask them back and

Page 18243

 1     issue us a new one in return.  But it wasn't always done.

 2             However, the principle was that you can't get a new one before

 3     you return your old one.

 4        Q.   And what was the standard practice, your practice, in terms of

 5     writing in the book?  Is that something that did you on a dial basis,

 6     once a month, once a week?

 7             MR. ZECEVIC:  I'm really sorry to interrupt.  It's just the part

 8     of the witness's answer was not recorded, and I think it's important.  He

 9     was saying something about the archiving of these work books.

10             MR. HANNIS:  May I inquire was that after his last recorded

11     answer about you can't get a new one before you return your old one?

12             General, I think the interpreters didn't catch the last part of

13     your answer where you told us you couldn't get a new one before you

14     returned your old one.

15             What happened when you returned your old one?  Can you tell us

16     about that.

17        A.   It was like this:  Lower-ranking officers couldn't get a new

18     notebook before they returned their old one which was full.  However,

19     high-ranking officers were commanders already, and then the NCO who

20     issued work books didn't dare oppose a request from that high-ranking

21     officer to be issued a new work -- a new notebook.  So when I came there

22     as a commander, he would certainly issue me a notebook without asking

23     questions.

24        Q.   I assume that the case would be the same for General Mladic.  If

25     he wanted a new notebook before turning in an old one, he would get it.

Page 18244

 1        A.   During the war we were not obliged to return the old notebooks.

 2     We used the ones that we had brought from the JNA or then we would make

 3     do with the notebooks or diaries from companies and enterprises.  And

 4     there are several notes that Mladic made that were not in the standard

 5     JNA notebooks.  I believe that there are note pads of the petrol industry

 6     of Serbia, which we received from the director of that company because

 7     they were friends, and the like.

 8             So that we didn't have to return our notebooks because we hadn't

 9     received them from the army in the first place.

10        Q.   Thank you.  We'll come to -- I think, one of those later on.

11             MR. HANNIS:  Before I get too far, Your Honour, I wanted to

12     tender 65 ter 3699.

13             JUDGE HALL:  Yes, it is admitted and marked.

14             THE REGISTRAR:  As Exhibit P1750, Your Honours.

15        Q.   Thank you.  In 1992, while you were working as Chief of Staff,

16     did you observe General Mladic writing in one of these diaries or

17     notebooks or work book, however you called it?

18        A.   I saw him write.  But I cannot say that on this day he wrote in a

19     standard format notebook, and on another day on a note pad of a different

20     type.

21             But I know that he had several notebooks.  One he would carry

22     around with him, another that would remain in the staff.  It was -- it

23     depended on the occasion, whom he was supposed to meet and where.

24     However, each of his working day during the war was full, but not

25     necessarily -- but that doesn't mean necessarily that there were entries

Page 18245

 1     for every day, because on -- there may have been days when he didn't have

 2     any meetings.

 3        Q.   In your experience, how frequently did you see him writing in his

 4     work book or notebook?

 5        A.   Every day when were at a meeting together.

 6        Q.   I think we'll see it in one of the notebooks later on there's --

 7     sometimes there is a page or a couple of pages where a meeting appears to

 8     be recorded.  There's a date and then notes.  And there are two or

 9     sometimes three different colour of ink on the same page.  Red and blue;

10     or red, blue, and black.  Can you explain that for us?

11        A.   Yes, I can.

12             Let me first say that the Main Staff, in its original

13     composition, existed for 1687 days.  Whenever I was with Mladic, on any

14     one of these days, he was writing something.  Red, blue, and black ink.

15     On one occasion, a retired colonel who was born at Romanija,

16     Tomo Mijatovic came to visit us.  He would supply us with note pads,

17     paper, felt-tip pens, pencils, and whatever stationary material we needed

18     for the staff and didn't have it.  He organised some pensioners in

19     Belgrade to buy that for us.

20             On one occasion he brought us, among others, these pens that --

21     three-colour pens - red, blue, and black multi-colour pens.  So press

22     down one button then you write with blue ink or press another -- down

23     another button, then it would be black ink, and so on.  I didn't use them

24     because they were clumsy to use.  You press the wrong button and then

25     your note is in red ink and you don't want it.

Page 18246

 1             I remember that he wrote the headings at the beginning of each

 2     meeting with red ink, and he would continue to make notes in blue or

 3     black.  Or when there was an important personality, such as Lord Owen,

 4     then he would write down his naming in red ink and continue writing in

 5     blue.  Or maybe if the supreme commander was present and spoke.  So he

 6     used different colours to indicate the importance of the various persons

 7     who spoke.  So it isn't a code or anything.  He just wanted to highlight

 8     things.

 9             When he used regular pens to write and wanted to highlight

10     something, he would put an asterisk.  And he did that in texts when he

11     prepared in advance what he should say at an upcoming meeting.  Or if

12     during the meeting he considered something especially important which

13     could become a task for the military, he would mark that with an asterisk

14     as well.  And it was my conclusion that whenever an asterisk was at the

15     beginning of any section of text, that was a reminder for him what to say

16     at the meeting.  And if the asterisk was embedded in the text, then it

17     marked a section of text that he considered especially important.

18        Q.   Thank you.  I'd now like to show you a portion from one of the

19     diaries and notebooks you've looked at.

20             MR. HANNIS:  This is 65 ter 3581.  And if we could put up page 1

21     of the B/C/S in e-court and page 7 of the English.

22        Q.   I want to ask you, to your experience --

23             MR. O'SULLIVAN:  Excuse me.

24             MR. HANNIS:  Yes.

25             MR. O'SULLIVAN:  Your Honour, I'm wondering if there's a

Page 18247

 1     connection between the document we see, the B/C/S, and the documents that

 2     were shown to the General on the 22nd of April, 2010.  I note that the

 3     ERN is different.

 4             MR. HANNIS:  Your Honour, this is indeed item number 4 on the

 5     chart in Exhibit P1750.  The difference in the ERN is -- you will see the

 6     English ERN is the same number as the B/C/S ERN that's on the chart.  The

 7     J000 ERN is reference to a colour scan that was made of the document.

 8     The first time the document was scanned, it was scanned in black and

 9     white.  And then a colour scan was made --

10             MR. O'SULLIVAN:  Well, Your Honour, I don't think we have

11     evidence of that.  We have Mr. Hannis's representation; we have evidence

12     that item number 4 in the chart is a different ERN; and now on the screen

13     we have a -- a different ERN than the document that was shown to the

14     witness last April.

15             JUDGE HALL:  Isn't Mr. Hannis entitled to give that explanation.

16     This isn't the type of information which the witness can testify to, is

17     it, Mr. O'Sullivan?

18             MR. HANNIS:  Well, Your Honour, this is -- this is the

19     difficulty.  We had requested to have investigator Tomasz Blaszczyk

20     testify regarding the -- the chain of custody, how these documents were

21     seized by the Serbian authorities and came into our possession, but he

22     would also testify about some of those things, about some markings that

23     are on the documents, in terms of ERN numbers, handwritten page numbers

24     that were put on there by someone.  But Your Honours decided when we

25     sought to add him as a witness that we didn't need him.

Page 18248

 1             Now, if the Defence is going to challenge based on those kind of

 2     things either I would request that you allow me as an officer of the

 3     court to indicate to you what the testimony of Mr. Blaszczyk has been

 4     under oath in another case, or allow us to call him to testify to those

 5     things.  But it's clearly a procedural, logistical, technical matter.

 6     This is the original.  This is a colour scan of the document that is item

 7     number 4 on the list that you looked at before.  And I can simply ask him

 8     if he can look at this page and tell us if he recognises the writing on

 9     the B/C/S page that's on the screen in front of him.

10             JUDGE HALL:  Mr. O'Sullivan, unless I'm wholly missing something,

11     with respect, I don't understand the basis of your objection.

12             MR. O'SULLIVAN:  If I'm understanding Mr. Hannis, he has made the

13     assertion that this is a document that this witness has previously looked

14     at.  And based on Exhibit P1750, that's not apparent.  Now if he can

15     establish that he has seen this document before, that may be different.

16             But so far, that hasn't been established.

17             JUDGE HALL:  Thank you.

18             Foundation, Mr. Hannis?

19             MR. HANNIS:  Your Honour, he has seen this document in black and

20     white --

21             JUDGE HALL:  Ask him.

22             MR. HANNIS:

23        Q.   General, could you look at the page in Cyrillic that's on the

24     page in front of you.  Do you recognise the handwriting on that document?

25        A.   Although this document in front of me has nothing to do with me,

Page 18249

 1     I can recognise the handwriting.  This is Mladic's handwriting.

 2     Especially since I know that on this date he became the commander of the

 3     Knin Corps, which is what he wrote down here.  And he also added in his

 4     particular style: "Another complex and difficult task."

 5        Q.   When you say "in his particular style," what are you referring

 6     to?

 7        A.   I am referring to this sentence: "Another complex and difficult

 8     task."  Or one more complex and difficult task.  Because in the previous

 9     year, 1991, he suffered a number of such difficult tasks in Knin.

10        Q.   [Microphone not activated] ... thank you.  I would also like to

11     show --

12             THE INTERPRETER:  Microphone.

13             MR. HANNIS:  I'm sorry.  Thank you.

14        Q.   I would also like you to take a look at another page from this

15     notebook which covers the time-period from 31 December 1991 through

16     14 February 1992.

17             MR. HANNIS:  If we could have page number 111 in e-court of the

18     B/C/S, and page 117 of the English.

19             If we could scroll to the bottom of the page in B/C/S.

20        Q.   General, you will see a reference to a meeting from 1700 to 1800

21     hours.  Do you know anything about that individual named there?

22        A.   Meeting with Marrack Goulding, emissary from the

23     General Secretary of the United Nations.  I heard of this Goulding, but I

24     don't know anything about him.

25        Q.   Thank you.  I'd like to show you now Exhibit 65 ter 10595.

Page 18250

 1             And, Your Honours, in light of his identification of the

 2     handwriting, I would like to tender 65 ter 3581.

 3             MR. O'SULLIVAN:  We object, Your Honour.

 4             JUDGE HALL:  On what basis, Mr. O'Sullivan, beyond the objection

 5     that was a part of the Defence's response which has been incorporated in

 6     the -- which has been disposed of in the Chamber's ruling?

 7             MR. O'SULLIVAN:  The -- the discrepancy between the two versions.

 8     The one that the witness -- the ERN range that he said he looked at in

 9     April is different than what's on the screen now.  And he's only looked

10     at the first page of the document with the ERN number J00.  So we say

11     there's no basis here to admit this entire document.  He's identified the

12     first page of the document he's seeing now, but he hasn't looked through

13     this entire document and said that it's what it purports to be.

14             JUDGE HALL:  Thank you, Mr. O'Sullivan.

15             Mr. Hannis, what is your application?

16             MR. HANNIS:  Your Honours, my application is to admit the entire

17     document.

18             We have disclosed to the Defence the ERN range 0668-3598 through

19     3695 which is item number 4 listed on the chart that the witness

20     indicated he looked through.  That is the black and white scan of the

21     identical document that is a colour scan here.  And the English version

22     has this same ERN range 0668-3598 through 3695 with the ET designator,

23     identifying it as an English translation.  So it's the identical

24     translation --

25             JUDGE HALL:  I appreciate, Mr. Hannis, that it is necessary for

Page 18251

 1     you to thread your way carefully between yourself giving evidence on the

 2     one hand and the explanation such as the -- we -- we dealt with when

 3     Mr. O'Sullivan made his last objection.  But do I understand your

 4     response to be that, to use the common expression of connecting all the

 5     dots, that the witness has testified that he has had an opportunity to

 6     compare the entirety of the document which you are now seeking to tender?

 7             MR. HANNIS:  Your Honour, I can't stand here and tell you that he

 8     has looked at colour page 1 through 400 and compared to black and white

 9     page of 1 through 400 of this document.  And if I need to go through and

10     show him each page of this document, I'm going to have to request a lot

11     more than three hours to do it, because I have 11 or 12 notebooks I want

12     to show him.

13             Your Honours, I would tender the whole thing in.  Your Honours

14     can look at it as easily as anybody else in the courtroom and judge for

15     yourself whether it appears that it was all written by the same person.

16     I think those arguments go to weight and not admissibility.

17             JUDGE HARHOFF:  Mr. Hannis, would it be a solution, in order to

18     get around the objection from the Defence, simply to show the witness the

19     black versions which the witness has seen and -- I mean, I realize that

20     the blue version is nicer to look at, perhaps, but if --

21             MR. HANNIS: [Overlapping speakers] ... well, Your Honour --

22             JUDGE HARHOFF: [Overlapping speakers] ... for the Defence, then

23     let's work to with the black.

24             MR. HANNIS:  I thought I would get an objection to not using the

25     originals if I used a black and white copy because you've already heard

Page 18252

 1     there was instances where he wrote in three different colours on the same

 2     page.  So I thought it was important to have the colour version so you

 3     could see him highlighting or underlining in red in some places and

 4     writing in blue or black in others.  It's the identical document,

 5     Your Honour.  The problem could be solved by your ruling in my favour and

 6     admitting the document.

 7             MR. O'SULLIVAN:  Your Honour, Mr. Hannis always provides

 8     practical solutions.  I appreciate that one.

 9             At the risk of my giving evidence, I submit that the documents

10     with the ERN beginning J000, the one that was on the screen, is not

11     identical to the ERN beginning 0668, which the Prosecutor chose to show

12     the witness in April of last year and which is reflected in the Exhibit

13     P1750, which is my point.

14                           [Trial Chamber confers]

15             JUDGE HALL:  It is time for the break.  Mercifully.  And we will

16     consider this over the break and seek to come back with a ruling at 5.40.

17                           [The witness stands down]

18                           --- Recess taken at 5.23 p.m.

19                           --- On resuming at 5.48 p.m.

20             JUDGE HALL:  While the witness is on his way back to the stand,

21     we considered the issues canvassed during the break.  And to put it in

22     its simplest form, there is no really issue in the Chamber's view as to

23     the admissibility, in essence, of the document in question.  The problem,

24     as we understand it, is that, as Mr. O'Sullivan has alerted the Chamber,

25     there may be a discrepancy between the colour scan of the original and

Page 18253

 1     the monochromatic scan to which the witness would have been referred in

 2     his earlier testimony.

 3             This requires the Prosecution, who is seeking to tender the

 4     document, to satisfy the Chamber as to the accuracy of the intended

 5     exhibit.  And, therefore, we will mark both copies, both versions, that

 6     is, the colour version and the monochrome version, for identification.

 7     And when we would have heard submissions, when counsel would have had an

 8     opportunity to look at it again, as to which should be de-MFI'd, it will

 9     be done at that stage, and then we will have the accurate version as the

10     exhibit.

11             Yes, Madam Registrar.

12             THE REGISTRAR:  Your Honours, therefore, the colour version and

13     the black and white version will become Exhibit P1751 and Exhibit P1752,

14     both marked for identification.  Thank you.

15                           [The witness takes the stand]

16             JUDGE HALL:  Thank you.

17             Mr. Hannis, before you continue, could you break at five minutes

18     before the time of the adjournment so that we can deliver a brief oral

19     ruling.  Thank you.

20             MR. HANNIS:  Certainly, Your Honour.  Thank you.

21        Q.   General, I'd shown you an entry in the diary where there was a

22     person named Marrack Goulding?

23             JUDGE HALL:  Sorry, Mr. O'Sullivan, you had something ...

24             MR. O'SULLIVAN:  I have an objection to the use to 65 ter 10595,

25     which is on the screen.  This exhibit, this document, was not on the

Page 18254

 1     65 ter exhibit list.  It had not -- it has not been previously disclosed

 2     to the accused.  I think yesterday in your oral ruling you drew the line

 3     in the sand on the issue of due diligence on the Prosecution not being

 4     timely in its disclosure and being diligent in its approach to these

 5     matters.  We submit that this 65 ter 10595 cannot be used.

 6             MR. HANNIS:  Yes, Your Honour.  I wasn't here yesterday when the

 7     oral ruling was delivered.  But I had read it and I did want to make one

 8     remark.

 9             I was concerned about the Trial Chamber's view that we had not

10     acted with due diligence.  What had happened was our initial application

11     was to have this witness called pursuant to 92 bis and Mr. Blaszczyk as a

12     92 bis -- or 92 ter as well.  Trial Chamber issued its decision, I think,

13     about ten days ago - I don't have the specific date in front of me -

14     where you decided that we would not be allowed to call Mr. Blaszczyk and

15     that we could call this witness but we needed to call him live rather

16     than 92 bis.

17             If he was going to be 92 bis, there were certain documents that

18     we anticipated coming in from his prior testimony and his statement.  Now

19     that we have to call him live and the challenge is alive to the

20     authenticity of these documents, we thought we could bolster the evidence

21     by showing documents that reflect the entries in the diaries indeed did

22     take place.  That there were meetings, that there were reports made of

23     those meetings, that certain persons were in certain places at certain

24     times as recorded in the diary.

25             That was the reason for our request.

Page 18255

 1             I understand that you may have decided it was too late, but our

 2     position is we didn't know it was going to be necessary to do that when

 3     we thought and hoped that your decision would be for this witness to be a

 4     92 bis witness and Mr. Blaszczyk to be a 92 ter.

 5                           [Trial Chamber confers]

 6                           [Trial Chamber and Legal Officer confer]

 7             MR. HANNIS:  It's not on our -- it was not on our 65 ter list,

 8     Your Honour.  We put it on our list of documents to show the witness,

 9     with the idea that we were trying to corroborate an entry in the diary by

10     showing him that document but not moving to admit the document.

11             JUDGE DELVOIE:  Mr. Hannis, the procedural background, so to say,

12     that you are giving is a little bit more complex.  You first asked -- OTP

13     first asked to -- made an application for 92 bis for the witness.  We

14     decided to call him viva voce weeks ago, not ten days ago, or a few days

15     ago.  You -- after that, after we viva voce'd him, I think, a month ago

16     or more than a month ago, you asked recently to 92 bis him -- to 92 ter

17     him, to call him under 92 ter, and that's what we refused a few days ago.

18             MR. HANNIS:  Your Honour, I trust that you have it correct and I

19     have it wrong.  I don't have in front of me, but I have no reason --

20             JUDGE DELVOIE: [Overlapping speakers] ... and that's -- and

21     that's the reason -- that's the reason for the ruling we gave yesterday,

22     if I'm correct, that it was yesterday.

23             MR. HANNIS:  I know, Your Honour, part of the ...

24                           [Trial Chamber confers]

25             JUDGE HALL:  So there's no difficulty with the Prosecution using

Page 18256

 1     the document, but it can't be admitted.

 2             MR. HANNIS:  Yes, Your Honour.  And ...

 3                           [Trial Chamber confers]

 4             JUDGE HALL:  Mr. O'Sullivan, the -- do we understand that

 5     although the disclosure was, in your view, late, it has been disclosed?

 6             MR. O'SULLIVAN:  Well, it was uploaded yesterday, I believe, when

 7     we received the documents that were going to be used with this witness.

 8     We received it either yesterday or today.

 9             And, Your Honours, the fact that he was a 92 bis or ter doesn't

10     support the Prosecution's submission, because they would have provided a

11     package then.  And there was no -- these documents, this particular

12     document was not on any previous bis or ter package.

13                           [Trial Chamber confers]

14                           [Trial Chamber and Legal Officer confer]

15             JUDGE HALL:  This is a remedy which the -- which may be open, if

16     absolutely necessary to the Defence, to remedy any prejudice that they

17     would have suffered by the late disclosure of the intention of the

18     Prosecution to show this document to the witness.  But at this point, the

19     point where we are in the trial, the document may be shown to the

20     witness.  But as I said earlier, it certainly could not be admitted as an

21     exhibit.

22             MR. HANNIS:  Thank you, Your Honour.  I did want to indicate one

23     more thing with regard to the issue of our diligence or lack of.

24             You will recall an earlier decision about these diaries and

25     the -- what would happen with this witness, and -- I don't have the exact

Page 18257

 1     ruling in front of me but Your Honours had indicated that if there were

 2     public testimony about the authenticity of the documents or the

 3     handwriting, then you would make a decision in light of that.  There had

 4     been testimony in private session that did not get released until some

 5     time very recently.  And when we did that, we thought it would not be

 6     necessary to have this witness come live or even 92 ter but as 92 bis.

 7     But even though there has been live testimony in the Tribunal here,

 8     Your Honours decided to have him come here live, and here he is.

 9             So that's all I wanted to say about that.

10             Could we show the witness 65 ter 10595.

11        Q.   General, you see on your screen a document dated the

12     28th of January, 1992.

13             Can you tell us what kind of document this is?

14        A.   This is a report of General Mladic, I believe, because I cannot

15     see the signature, but I can see in the letterhead the 9th Corps command.

16             It's a report of the corps commander to the command of the

17     2nd Military District of which the corps was probably part, about

18     political talks of the president of the Republic of the Serbian Krajina,

19     Milan Babic, and this Mr. Goulding who has recently been mentioned.

20             Mladic reports to his --

21             JUDGE HALL: [Previous translation continues] ... Mr. Hannis,

22     please phrase a question to the witness so that we don't end up having

23     the witness indirectly put into evidence the contents of the document

24     that you can't put in directly.

25             MR. HANNIS:  I'm sorry, Your Honour.  I'll stop him there.

Page 18258

 1     That's -- that's all I wanted to indicate.

 2        Q.   That there was this document and it's dated 28th and it refers to

 3     a meeting on what date?  With Mr. Goulding.

 4        A.   The 27th of January, which is the day before the date mentioned

 5     here.

 6        Q.   Thank you.  That's all I wanted to ask about that.

 7             I'd like to move on now to tab 4, which is 65 ter number 3582.

 8             MR. HANNIS:  If we could start by showing the witness page 1 of

 9     the B/C/S.

10        Q.   General, can you tell us what that is?

11        A.   I see in front of me, labelled 39, I see the cover of the regular

12     work book that was used by the JNA.  And I believe this is a pocket

13     format work book.

14        Q.   And the words at the bottom, what does that mean:  "Radna

15     beleznica"?  Pardon me pronunciation.

16        A.   Every institution in a society, including the JNA, have their own

17     note pads or notebooks where records are kept of some -- records are kept

18     of something.  It's kept on a desk at the workplace or wherever, and

19     people write in it about things that must be done.

20        Q.   Thank you.  And is this the type of book that you told us about

21     earlier in your testimony that was used by yourself and other

22     high-ranking officers in the VRS during 1992?

23        A.   Yes.

24        Q.   And actually had been used by you and other officers in the JNA

25     before you switched to the VRS.

Page 18259

 1        A.   Yes.

 2             MR. HANNIS:  Now, if we could go to page 306 in the B/C/S in

 3     e-court, or -- and 361 in the English.

 4        Q.   First of all, General, do you recognise the handwriting on that

 5     page?

 6        A.   Yes.  It's the handwriting of General Mladic.

 7        Q.   Okay.  And we see this is about the Session of the SRBH Assembly

 8     on the 12th of May, 1992, in Banja Luka.

 9             Do you know whether General Mladic attended that session?

10        A.   Yes.  The newly established Main Staff was represented by

11     General Mladic and his assistants, but not me.

12        Q.   [Microphone not activated] ... were you aware --

13             THE INTERPRETER:  Microphone, please.

14             MR. HANNIS:  I'm sorry.

15        Q.   Were you aware before the 12th of May that General Mladic was

16     going to attend that session?

17        A.   I found out in -- at night, from the 11th to the 12th of May.

18        Q.   And how did you find out, and what did you do in connection with

19     that?

20        A.   I've already said that on the 11th of May, in the afternoon,

21     12 of us gathered, and Mladic first informed us that on the following day

22     the Assembly of the Serbian Republic of Bosnia-Herzegovina would sit and

23     probably the decision on the establishment of the Army of

24     Republika Srpska would be taken.  And that night, the 12 of us discussed

25     what that army must do.

Page 18260

 1             We formulated 21 principles about the functioning of the future

 2     army.  We couldn't -- they can't be called rules because we didn't know

 3     who the commander would be.  We assumed it would be General Mladic.

 4     Tolimir, Gvero, Djukic flew from Han Pijesak to Banja Luka by helicopter

 5     on the following day.  And I believe that this is Mladic's note from that

 6     Assembly session.  He must have known about the Assembly session earlier,

 7     from before that night, and he made speaking notes for himself so -- to

 8     remind him what he should say here.  And what we see here is the

 9     beginning.

10        Q.   Thank you.

11             MR. HANNIS:  Your Honours, I'd like to tender 3582.

12             MR. O'SULLIVAN:  The same objection as to the previous document,

13     Your Honour.

14             JUDGE HALL:  And our previous ruling applies here.

15             THE REGISTRAR:  The document will be become Exhibit P1753, marked

16     for identification, Your Honours.

17             MR. HANNIS:  I'm sorry, were we giving two numbers, one for

18     colour and one for black and white?

19             THE REGISTRAR:  Additional number, Your Honours, will be P1754.

20     I apologise.

21             MR. HANNIS:  Could we have an indication as to which is which, or

22     are we always going to do colour first and black and white second or

23     vice versa?

24             JUDGE HALL:  Colour first.

25             MR. HANNIS:  Thank you.

Page 18261

 1        Q.   Let me -- I would like now to show you -- I'd like now to show

 2     you exhibit --

 3             JUDGE DELVOIE:  Mr. Hannis.

 4             MR. HANNIS:  Yes.

 5             JUDGE DELVOIE:  I don't know whether it would be useful to have

 6     the ERN number of the black and white version on the screen -- on the --

 7     on the record.

 8             MR. HANNIS:  Your Honour, it may be -- it may be easiest -- I

 9     mean, I can read it out, but it will be the -- it will be the ERN that's

10     listed on my use of -- documents to be used with the witness under the

11     English ERN.  Just take off the ET.

12             JUDGE DELVOIE:  Yes.  Okay.  Thank you.

13             MR. HANNIS:  Okay?  Thank you.

14             Could we show the witness 65 ter 2324.

15        Q.   General, this is a video I want to show you just briefly.

16             MR. HANNIS:  And, Your Honours, I would indicate, with regard to

17     this Assembly session, that you already have in evidence documents P74

18     and P1318.18 reflecting such a session on such a date at that location.

19                           [Trial Chamber and Registrar confer]

20             MR. HANNIS:

21        Q.   I'm just going play a couple of seconds, and I want to ask you if

22     you recognise who's pictured sitting at the table.

23                           [Video-clip played]

24             MR. HANNIS:

25        Q.   Do you recognise those gentleman on the front row?

Page 18262

 1             MR. HANNIS:  If we could pause it.

 2             THE WITNESS:  I don't recognise the one on the right.  The second

 3     from the right is General Momir Talic.  The third from the right is

 4     General Ratko Mladic.

 5        Q.   Okay.

 6             MR. HANNIS:  And if we could forward just a bit and pause there.

 7                           [Video-clip played]

 8             MR. HANNIS:

 9        Q.   You see what General Mladic has in front of him.  Can you tell us

10     what that is?

11        A.   A work book, a large-format work book.

12             MR. HANNIS:  Your Honours, that video --

13             THE INTERPRETER:  Microphone.

14             MR. HANNIS:  Sorry.  That video is Exhibit P1295.15 in evidence,

15     but I would also like to have a still photo, which has been marked as

16     65 ter 2324.1, tendered at this time.

17                           [Trial Chamber confers]

18             JUDGE HALL:  Mr. Hannis, we don't see the utility of marking this

19     still from this video separately, because it doesn't advance anything

20     beyond what is in the video.

21             MR. HANNIS:  Your Honour, if I may make a submission.

22             It's just simply -- and maybe I should ask the witness to take

23     his headphones off.  Sorry --

24             JUDGE HALL:  Yes, yes.

25             MR. HANNIS:  Your Honour, it's the Prosecution's position that

Page 18263

 1     the notebook that he has in front of him at the Assembly is the one that

 2     is in evidence here.  You will see the approximate location of where it's

 3     opened to, and when you see the real notebook, we'll ask you to make a

 4     comparison and draw a conclusion based on that.

 5             JUDGE HALL:  How is that -- sorry.  Isn't that a leap from --

 6     from this photograph, Mr. Hannis?

 7             MR. HANNIS:  I don't believe so, Your Honour.  I'll -- I would

 8     prefer to save my submissions for the end of the case, but I'm certainly

 9     willing to make them now.

10             JUDGE HARHOFF:  Mr. Hannis, the witness wasn't present at this

11     meeting, and so as much as we see General Mladic with a book in front of

12     him that may look like the notebook, there is no way in which we can see

13     that.  It might as well be an army manual or something else.  I mean, so,

14     I think that other than what --

15             MR. HANNIS:  Your Honour, you heard the witness testify that the

16     book was written -- it's General Mladic's writing, that what is written

17     on that date, the 12th of May, for the Banja Luka Assembly session is

18     what appears to be speaking points for the General.  We know from the

19     minutes in the transcript of the Assembly session that General Mladic

20     spoke at some length.  We will, at the end of the case, ask you to

21     compare what's in the -- the diary, what he wrote regarding speaking

22     points and what he actually said as recorded in the Assembly and, with

23     this picture, perhaps reach a not illogical conclusion that that, indeed,

24     is the very same diary that we have here.

25                           [Trial Chamber confers]

Page 18264

 1             JUDGE HALL:  We've heard you, Mr. Hannis, and in the Chamber's

 2     view this should not -- this still should not be separately admitted as

 3     an exhibit.

 4             MR. HANNIS:  I understand, Your Honour.  Thank you.

 5             Next I would like to show the witness 65 ter 3583.

 6             MR. ZECEVIC:  I guess the witness should be instructed to put his

 7     earphones on.

 8             JUDGE HALL:  Thank you -- thank you, Mr. Zecevic.

 9             MR. HANNIS:  Yes, thank you.

10        Q.   Witness, next I want to show you a document that's

11     65 ter number 3583.

12             MR. HANNIS:  And could we start by showing the witness the cover

13     page in the B/C/S.  Thank you.

14        Q.   You see that, General?  Is that the same type of JNA work book

15     that we've been talking about and looked at before?

16        A.   Yes.

17             MR. HANNIS:  If we could go to page 123 of the B/C/S in e-court

18     and page 124 in the English.

19        Q.   Do you recognise the handwriting on that page?

20        A.   Yes.  It's Mladic's.

21        Q.   Okay.  And the bottom half of that page refers to a meeting in

22     Pale on the 9th of June with the Presidency, apparently attended by

23     Mladic, Gvero, and Tolimir.

24             Did you know about that meeting?

25        A.   I probably did.  But somebody had to stay at the Main Staff.

Page 18265

 1        Q.   Okay.

 2             MR. HANNIS:  Thank you, Your Honour.  I would indicate for the

 3     Court that Exhibit P260 in evidence is a document reflecting a meeting of

 4     the Presidency on that date.  And I would like to tender 3583.

 5             Before I do, I should indicate, Your Honour, that with the

 6     Witness ST-215 some time ago I introduced an excerpt from this diary.  I

 7     think it's page numbers -- page numbers 246 to 272 of the English

 8     regarding a meeting in Zvornik on the 30th of June, and it was admitted

 9     as an MFI at the time.

10             What I want to do is put in the whole diary that covers the

11     time-period from the 27th of May to the 31st of July, 1992.  So I don't

12     know what your preference would be, whether to give this that same number

13     and take an MFI on and have the whole document in or if you want to give

14     this a new number.  I guess, since it's going to be MFI for colour and

15     black and white, we should give it two numbers, one for colour and one

16     for the black and white.

17             JUDGE HALL:  You're suggesting the old MFI number?

18             MR. HANNIS:  Well, I don't know if that's more convenient or

19     confusing for the Court.  I hate to lose the old number because that was

20     discussed with Witness ST-215 and there are references to it.

21                           [Trial Chamber and Registrar confer]

22             JUDGE HALL:  We're advised by the Registrar that the simpler

23     course would be just to issue two new numbers.  If anything, the old MFI

24     number would be overtaken and would fall away eventually.

25             MR. HANNIS:  Thank you, Your Honours.

Page 18266

 1             THE REGISTRAR:  Your Honours, therefore the colour version is

 2     Exhibit P1755 and the black and white one is P1756, both marked for

 3     identification.  Thank you.

 4             MR. HANNIS:  Okay.  One follow-up point concerning this meeting.

 5             If we could show the witness page 126 -- I'm sorry.  It's -- it

 6     would be page 125 for the witness in B/C/S and 126 in English.

 7        Q.   There's a reference to presidential decrees for three individuals

 8     at the bottom of the page.  Can you tell us anything about that?  Did you

 9     know about that?

10        A.   It was requested that presidential decrees for General Grubac, I

11     can't read the second name, and for Sipcic not be drafted.

12             I remember that.  Mladic issued me the order over the phone on

13     the same day from Pale, because the Ministry of Defence of the RS didn't

14     have the capabilities to provide supply to the army and to do

15     administration work, and that's why we drafted the presidential decrees

16     in the Main Staff and sent them to Karadzic to sign them.  And I remember

17     this because I was against appointing Sipcic corps commander.

18        Q.   Thank you.  General, if we could go next to page 373 in the

19     B/C/S, in e-court, and 373 in the English as well.

20             Again, this is from the same notebook, General.  And it reflects

21     a meeting on the 27th of July.

22             MR. HANNIS:  I'm sorry, I'm not sure I have the right B/C/S page.

23             Yes, that's it.

24             THE WITNESS: [Interpretation] 371.

25             MR. HANNIS:

Page 18267

 1        Q.   Yes.  Do you recall this meeting?

 2        A.   Yes.  I was present, although Mladic didn't -- doesn't mention

 3     me.  It was a meeting with the Ministry of the Interior,

 4     Mr. Mico Stanisic, and the deputy prime minister in charge of interior

 5     policies, and that was Mr. Milan Trbojevic.  The two of us represented

 6     the cabinet; and Mladic, Tolimir, and I represented the Main Staff.

 7        Q.   Thank you, sir.

 8             MR. HANNIS:  In the interests of time, I want to move on to

 9     tab 11, which is 65 ter 3584.

10             I don't know if I indicated to Your Honours that P260 is a

11     reflection of that earlier June 9th meeting.

12             And if we could start by showing the witness page 23 of the

13     B/C/S.  It's page 16 of the English.

14        Q.   Do you recognise the handwriting on that page, General?

15        A.   Yes.  It's Mladic's.

16        Q.   And it's recording a meeting on the 2nd of August, 1992, with the

17     Presidency.

18             MR. HANNIS:  Your Honours, if we could go next to 65 ter 1246.

19             This is, again, a document that was not on our 65 ter list, but

20     I'm showing it for the purposes of trying to authenticate this particular

21     diary.

22             JUDGE DELVOIE:  Mr. Hannis.

23             MR. HANNIS:  Yes.

24             JUDGE DELVOIE:  Perhaps I'm missing something, but the previous

25     one, tab -- tab 11, is not tendered yet; is that right?

Page 18268

 1             MR. HANNIS:  Your Honour, I hadn't asked to have it tendered yet

 2     because this document relates to a meeting referred to.  The next

 3     document that I had asked to be called up --

 4             JUDGE DELVOIE: [Overlapping speakers] ... okay.  I'm sorry.

 5             MR. HANNIS: -- refers to it.

 6        Q.   General, do you see that document refers to minutes of a meeting

 7     of the Presidency on the 2nd of August?

 8        A.   Is that a question?

 9        Q.   Yes, yes.  Do you see that?

10        A.   I can see the introductory part, and it matches the list of

11     persons present in Mladic's handwriting; whereas, I'm unfamiliar with the

12     rest.

13        Q.   Okay.  Thank you.  And in this document -- I'm sorry, back to the

14     notebook.  I wanted to ask you about a certain portion at page 89 of the

15     B/C/S.

16             MR. HANNIS:  And I believe it's at page 23 of the English.

17     That's in 65 ter 3584, tab 11.

18             [Microphone not activated] General --

19             THE INTERPRETER:  Microphone, please.

20             MR. HANNIS:

21        Q.   On your screen you have a document that shows a conversation

22     occurring on the 20th of August, 1992.  Do you recognise the writing on

23     that page?

24        A.   Yes.

25        Q.   [Previous translation continues] ... I'm sorry -- thank you.

Page 18269

 1        A.   Yes.  Mladic's.

 2             MR. HANNIS:  I'm sorry, we have the wrong page in English.  I

 3     think I need page 82; I misspoke.  And it's about a conversation with

 4     officers from the BiH in the 2nd and 3rd armies.

 5             If we could go to the next page in B/C/S.

 6        Q.   Do you recall having looked at this during proofing and noted the

 7     difference in the writing on this page from the last page?

 8        A.   I remember this document.  This is not Mladic's handwriting.

 9     This is the handwriting of Captain Pecanac, as Mladic noted at the end of

10     the document.

11             MR. HANNIS:  If we could go forward to page 93 of the B/C/S in

12     e-court.

13             MR. O'SULLIVAN:  While that's happening, can I inquire, if there

14     was proofing of this witness, was there a proofing note produced?

15             MR. HANNIS:  No, there was not.

16             MR. O'SULLIVAN:  Your Honour, can I ask why?  If there's been

17     changes to or additional evidence that's just come up right now.

18             MR. HANNIS:  Because it came up about an hour before we started

19     the session today.

20        Q.   And, General, can you tell us about the handwriting on this page.

21             MR. O'SULLIVAN:  I'm sorry, Your Honour, I mean, I don't think

22     the disclosure of a proofing note is contingent on when the proofing took

23     place.  I submit we're entitled to a proofing note if there is, as we've

24     just seen, some substance to what was discussed during proofing.

25             MR. HANNIS:  Your Honour, this witness is being called for the

Page 18270

 1     limited purpose of authenticating a document.  I did not believe it was

 2     necessary to notify the Defence of any minor change including one that

 3     arguably goes in favour of the Defence because this relates to writing

 4     that's not Mladic's handwriting in the diary I'm proposing to tender.

 5             JUDGE HALL:  I was going ask, Mr. O'Sullivan, where is -- we've

 6     heard your intervention, but what is your -- where are you inviting the

 7     Chamber to go?

 8             MR. O'SULLIVAN:  To order a disclosure of that proofing note.  Or

 9     of the notes taken during the proofing.

10             JUDGE HALL:  Mr. Hannis, can you -- we've heard you about the --

11             MR. HANNIS:  There is not a note from the proofing and there was

12     not a note taken of this.  There was a green or a red sticky put on that

13     page in the diary.  That's the proofing note.

14             JUDGE HARHOFF:  Was there any proofing?  And when did it take

15     place?

16             MR. HANNIS:  Pardon me, Your Honour?  I didn't hear you.

17             JUDGE HARHOFF:  Sorry.  We should not overlap.

18             MR. HANNIS:  I'm sorry, I see it now on the transcript.

19     [Overlapping speakers] ...

20             JUDGE HARHOFF:  My question was --

21             MR. HANNIS: [Overlapping speakers] ...

22             JUDGE HARHOFF:  Please do not overlap.

23             My question was if there was a proofing and when it took place.

24             MR. HANNIS:  Your Honour, I had some proofing with the witness

25     yesterday.  And this morning Mr. Krgovic met with him briefly, and I

Page 18271

 1     spoke with him for about 20 minutes after that meeting.

 2             JUDGE HARHOFF:  And we are to understand that no notes were taken

 3     from any of these proofing sessions that you had with the witness.  Is

 4     that correct?

 5             MR. HANNIS:  That's correct, Your Honour.

 6             JUDGE HARHOFF:  Thank you.

 7             MR. HANNIS:  This particular note was as a result of my finding

 8     what appeared to be different handwriting and asking the witness about it

 9     after our meeting with Mr. Krgovic this morning.

10             JUDGE HALL:  Please proceed, Mr. Hannis.

11             MR. HANNIS:  Thank you.

12        Q.   Witness, what can you tell us about the handwriting on this page?

13        A.   Are you asking me?

14        Q.   Yes.  It appears that there are two different writings on this

15     page.  What can you tell us about them?

16        A.   Yes.  From the top of the page onwards, we see the handwriting of

17     Captain Pecanac.  And then at the bottom, in order to disassociate

18     himself from it, Mladic wrote:  "The above was written by

19     Captain Pecanac."  That is written by Mladic.

20        Q.   Thank you.

21             MR. ZECEVIC:  I'm really -- I'm really sorry.  I didn't want

22     to ... it's just the part of the answer which might be important was not

23     recorded.

24             The witness was talking something about the time when

25     General Mladic wrote this at the end of this page.

Page 18272

 1             JUDGE HALL: [Microphone not activated] ... could the witness

 2     repeat his answer, please.

 3             MR. KRGOVIC:  Microphone, Your Honours.  It wasn't turned on, so

 4     the interpreters cannot hear your question.

 5             JUDGE HALL:  Sorry.  I was asking the witness -- thank you,

 6     Mr. Krgovic.

 7             I was inviting the witness to repeat his answer.

 8             THE WITNESS: [Interpretation] At the bottom it says, it is

 9     written in Mladic's handwriting: "The above was written by

10     Captain Pecanac."  Which means that Mladic wrote it upon seeing the notes

11     above.  It seems to me as though he had a premonition that these notes

12     would eventually end up here, so he wanted to disassociated himself in

13     advance.

14             MR. HANNIS:

15        Q.   Thank you.  I don't have any other questions about that document.

16             MR. HANNIS:  Your Honour, I would like to tender 3584.

17                           [Trial Chamber confers]

18             JUDGE DELVOIE:  Mr. O'Sullivan, the same objection?

19             MR. O'SULLIVAN:  Yes, I didn't rise because I thought there

20     was -- yes.

21             JUDGE DELVOIE:  Yes.  Well, I have a question in that regard.

22             So your position is that all these different -- well, the scans

23     of all these different notebooks, there is a discrepancy in all the

24     scan -- in the scans of all these notebooks; right?  In between the

25     coloured one and the black and white one.  That's why we're doing this.

Page 18273

 1             MR. O'SULLIVAN:  Yes.

 2             JUDGE DELVOIE:  Can you give us an idea about what the nature is

 3     of the discrepancy?

 4             MR. O'SULLIVAN:  That might be best left for me to explore that

 5     with the witness.

 6             JUDGE DELVOIE:  Okay.  Thank you.

 7             JUDGE HALL:  Yes.

 8             THE REGISTRAR:  Your Honours, the colour version will become

 9     Exhibit P1758, and the black and white one -- yes, P1757, thank you,

10     Your Honour.  And the black and white one P1758, both marked for

11     identification.

12             MR. HANNIS:  Thank you.  If we could turn now to P -- I'm sorry,

13     65 ter 3585.  And I'd like to start out by showing the witness page 41 of

14     the B/C/S in e-court.  And if we could have page 33 of the English.

15        Q.   Witness, do you recognise the handwriting on that page of the

16     B/C/S?

17        A.   Yes.

18        Q.   [Previous translation continues] ... at the bottom --

19        A.   Mladic's handwriting.

20        Q.   [Previous translation continues]... thank you.  And at the bottom

21     we see a reference to the EC team and the leader Mayhew.  Do you know

22     what that team was or who that was?

23        A.   I don't know.

24        Q.   At the top of the page you see a reference to General Lisica.

25     Lisica.  Do you know who he was?

Page 18274

 1        A.   It says Colonel Lisica.  He was a neighbour of mine.  We were

 2     both born in the same village.  We graduated together from the school for

 3     non-commissioned officers.  We served in Benkovac together and then we

 4     split.  I went to the academy, and after the academy he went to Leskovac

 5     and then to Benkovac.  I know the man very well.  Right now he's a

 6     retired general.

 7        Q.   And do you know where he was deployed in 1992, September of 1992?

 8        A.   He was the commander of Tactical Group 3 as is written here.  He

 9     participated in combat between Derventa and Brod.  At this time, as this

10     was written, Lisica was somewhere in the environment of Brod and he

11     entered Brod on the 7 of October, 1992, within the Operation Corridor.

12        Q.   And during 1992 was he ever deployed in the area of Doboj?

13        A.   Yes.  He was commander of the Operations Group Doboj upon

14     entering Brod.  Since the tactical group is a temporary formation, it is

15     established only for the purposes of a certain mission.  And you can see

16     here that three brigades were within that tactical group.  Once Brod was

17     taken, that group was disbanded and a new group was established.

18     Operations Group Doboj or Operations Group 9, and Lisica was the

19     commander of that operations group up until August of 1993 when he became

20     commander of the centre of military schools, whereas his successor was

21     Colonel Arsic.

22        Q.   Thank you.

23             MR. HANNIS:  I would like to tender 3585, Your Honours.

24             JUDGE HALL:  Does the same problem arise in this case?

25             MR. O'SULLIVAN:  Yes, Your Honour.

Page 18275

 1             JUDGE HALL:  Yes.  So as before, marked for identification.

 2             THE REGISTRAR:  Your Honours, the colour version is

 3     Exhibit P1759, and the black and white one is P1760, both marked for

 4     identification.  Thank you.

 5             JUDGE DELVOIE:  Mr. Hannis, I have, perhaps, a slight problem

 6     with the English ERN number.  There's no ET.

 7             MR. HANNIS:  Hmm.

 8             JUDGE DELVOIE:  Should there be one for the colour version?

 9             MR. HANNIS:  Your Honour, may I have just a moment.  I think

10     there should.  This document was item number 8.

11             JUDGE DELVOIE:  I don't know.

12             MR. HANNIS:  I'm sorry, item number 8 on the list of documents

13     that the witness reviewed, and its -- its B/C/S ERN was 00 -- it was

14     0668-2011 through 2080, or 81 it appears.  So I'm assuming the English

15     version should be ET.  That should be ET -- [Overlapping speakers] ...

16             JUDGE DELVOIE:  We are talking about tab 13 for the coloured

17     version; isn't that right?

18             MR. HANNIS:  Yes.

19             JUDGE DELVOIE:  Okay.  And there in the ERN -- in the English ERN

20     there should be ET --

21             MR. HANNIS:  Correct.

22             JUDGE DELVOIE: -- behind the coloured version.

23             MR. HANNIS:  Yes, yes.

24             JUDGE DELVOIE:  Okay.  Thank you.

25             MR. HANNIS:  Now if we could move to tab 15.  It's 65 ter number

Page 18276

 1     3585.1.  And first if we could show the witness the cover page in B/C/S,

 2     the first page.

 3        Q.   General, you mentioned that sometimes General Mladic used

 4     notebooks other than that JNA one we've seen.  Sorry, this is only --

 5     this appears to be black and white.  Can you recall having seen a

 6     notebook like this?  I can't tell you what colour it is in real life.

 7        A.   Mladic used up the JNA notes that he had brought with him from

 8     Knin.  Later on, as the old ones were all used up, we all started using

 9     various note pads, notebooks, whatever we got.  I don't remember this

10     cover, this particular cover, but it's possible that there was one.

11        Q.   Let's -- if we could go to the next two pages in succession, I'll

12     ask to you take a look at them and see if that helps.

13             MR. HANNIS:  Could we have page 2 of the B/C/S.

14             THE WITNESS: [Interpretation] Yes.  We can see this now.  Now,

15     this is work log-book, or work diary, sort of a civilian notebook.

16             MR. HANNIS:  And page 3.  If we could enlarge the print at the

17     bottom of the page and bring that up.

18             THE WITNESS: [Interpretation] Yes.  This is a notebook issued by

19     a company called "Savremena izdanja, Savremena administracija," which is

20     to say that Mladic received the notebook from this company.

21             I apologise.

22        Q.   No problem, General.  It's happened to me before.

23             MR. HANNIS:  If we could go to page 4 of the B/C/S and page 4 of

24     the English.

25        Q.   I see this is recording a meeting on the 14th of September, 1992,

Page 18277

 1     of the 20th Session of the Assembly in Bijeljina.  Do you recognise the

 2     handwriting on that page?

 3        A.   Yes, Mladic's handwriting.

 4        Q.   Thank you.

 5             MR. HANNIS:  And, Your Honours, I would direct your attention to

 6     Exhibit P430 as a document in evidence recording that session of the

 7     Assembly on that date at that location.  And I would move to tender

 8     3585.1.

 9             JUDGE HALL:  Yes, Mr. O'Sullivan.

10             MR. O'SULLIVAN:  We object to the admission of this document, and

11     our reasons are the following:

12             There is no colour scan of this particular document.

13     Your Honours will have noticed that the colour scan all begin with the

14     ERN J000, and there's no J000 version of this document.

15             However, the version you have on the screen was not reviewed by

16     this witness according to Exhibit P1750, which is the notes the General

17     made of -- to 18 notebooks.  I don't believe he's ever seen this

18     particular notebook before today.

19             MR. HANNIS:  Your Honours, the witness testified before that he

20     had seen 18 notebooks in April of this year, that he had seen another

21     five in July of 2009 when Alistair Graham came to see him in Banja Luka.

22     In the witness's statement, I can indicate to you that this exhibit is

23     one of the five listed in his statement at paragraph 24 as one of the

24     five that he reviewed in July 2009.

25             Now my learned friend doesn't like black and white.  I'm really

Page 18278

 1     perplexed as to what I need to provide to him.

 2             JUDGE HALL:  Admitted and marked.

 3             THE REGISTRAR:  As Exhibit P1761, Your Honours.

 4             MR. HANNIS:  And again, Your Honour, just at this point I would

 5     like to indicate to you that the explanation about why there's not a

 6     coloured scan of this one and the other four of those five shown to the

 7     witness in 2009 is something that could be explained by Mr. Blaszczyk

 8     and/or Erin Gallagher, an investigator, who dealt with these.

 9             Let me turn next to 65 ter 3585.2.

10             JUDGE HALL:  Mr. Hannis, you haven't for gotten the five minutes

11     we need.

12             MR. HANNIS:  Your Honours --

13             JUDGE HALL:  I mean, if you can finish within four -- three

14     minutes, all well and good.

15             MR. HANNIS:  Well, Your Honours, you may have noticed I'm running

16     a little ragged and my voice is running out.  I would appreciate if I

17     just stop now and we dealt with your oral ruling.

18             JUDGE HALL:  Thank you.

19             General Milovanovic, we -- as I indicated to you, your testimony

20     is going to extend into tomorrow.  We are about to take the adjournment

21     for today, but we have certain administrative matters with which to deal

22     with before we rise.  We are now excusing you as a witness, and the usher

23     would escort you from the courtroom.  But before he does, I would point

24     out that you, having been sworn as a witness, you cannot have any

25     communication with counsel from either side.  And in such communications

Page 18279

 1     as you may have outside of the courtroom, you cannot discuss your

 2     testimony.

 3             So you are now excused until tomorrow.  Thank you.

 4                           [The witness stands down]

 5             JUDGE HALL:  I'm advised that the interpreters may not have this,

 6     so I will read at dictation speed.

 7             On the 5th of November, the Zupljanin Defence orally requested

 8     the re-call of Nedjelko Djekanovic, who testified in these proceedings in

 9     October of 2009.  The request arose from the subsequent testimony of

10     ST-241, who was detained in the municipal prison at Kotor Varos in

11     October 1992.

12             On 5 November 2010, ST-241 testified that he was informed by his

13     brother who was also detained in the prison that one of the men who

14     arrived at the prison during a visit of the International Committee of

15     the Red Cross on the 3rd of October, 1992, was the

16     Accused Stojan Zupljanin.  ST-241 testified that Djekanovic and anothers

17     were also present.

18             The information was not included in ST-241's Rule 65 ter summary

19     and only became known to the Prosecution when proofing the witness prior

20     to his appearance.  Therefore, the Defence was only placed on notice of

21     this aspect of the anticipated evidence of ST-241 shortly before he

22     testified.

23             The Zupljanin Defence submits that had it been aware of ST-241's

24     description of those who were present during the ICRC visit, the

25     Zupljanin Defence would have explored this with Djekanovic when he

Page 18280

 1     testified.  As it was, neither the Prosecution nor the Defence raised the

 2     issue of this visit to the Kotor Varos prison with Djekanovic.  Hence,

 3     the Zupljanin Defence now seeks to cross-examine Djekanovic further on

 4     the limited question of the accused's presence at the Kotor Varos prison

 5     during that visit.

 6             The Prosecution opposes the request on the basis that

 7     Djekanovic's presence at the ICRC visit was known to the Defence since

 8     early stages of the trial and is not new information for which he needs

 9     to be re-called.

10             The evidence of ST-241 in relation to the alleged presentation of

11     Stojan Zupljanin in the ICRC -- at the ICRC visit is new information

12     which is directly relevant to the Defence of Stojan Zupljanin.  The

13     evidence to be elicited from Djekanovic is not cumulative in nature with

14     other evidence on record.  The Defence has, therefore, shown good cause

15     for its request, and the Chamber finds it necessary to re-call Djekanovic

16     for further cross-examination and re-examination, if any, on the sole

17     issue of whether Zupljanin was present at the Kotor Varos prison on the

18     3rd of October, 1992, during the ICRC visit.

19             The Chamber grants the Zupljanin Defence 30 minutes for such

20     examination and orders that this witness may be heard after the winter

21     recess.  Thank you.

22             So we take the adjournment to tomorrow afternoon at 2.15.

23                            --- Whereupon the hearing adjourned at 7.00 p.m.,

24                           to be reconvened on Wednesday, the 8th day of

25                           December, 2010, at 2.15 p.m.