Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18757

 1                           Monday, 17 January 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.04 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.

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

 7     Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.

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

10     please.

11             MS. KORNER:  Good morning, Your Honours.  Joanna Korner and

12     Crispian Smith for the Prosecution.

13             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

14     Slobodan Cvijetic, Eugene O'Sullivan appearing for Stanisic Defence this

15     morning.  Thank you.

16             MR. KRGOVIC:  Good morning, Your Honours, Dragan Krgovic,

17     Aleksandar Aleksic, and Igor Pantelic appearing for Zupljanin Defence.

18             JUDGE HALL:  Thank you.

19             If there are no housekeeping or related matters, could we have

20     the usher please escort the witness back to the stand.

21                           [The witness takes the stand]

22             JUDGE HALL:  Good morning to you, Mr. Brown.  I remind you you're

23     still on your oath.

24             Yes, Ms. Korner.

25             MS. KORNER:  Thank you, Your Honours.

Page 18758

 1                           WITNESS:  EWAN BROWN: [Resumed]

 2                           Examination by Ms. Korner: [Continued]

 3        Q.   Mr. Brown, if -- I'll give you a moment to get your report out on

 4     the various documents.

 5             I want to move, fairly swiftly, I hope, through the remainder of

 6     your report, Mr. Brown, beginning this morning with the section at

 7     page 88 in English, paragraph 2.77, headed "Retaliatory Actions and

 8     Killings of Non-Serbs."  And effectively, you point out in that paragraph

 9     that during and after a number of the attacks, a number of killings and

10     retaliatory actions against non-Serbs were reported in contemporary

11     military and police documents.  I'd just like to have a look at a couple

12     of those, please, as examples.

13             Could we look, first of all, please, at document P496, which is

14     at tab 41.  And it's referred to in your paragraph 2.80 where you list a

15     number of the killings that came to the attention of the military.

16             And if we look, now, at that document, which is dated the

17     7th of August of 1992, which is a regular combat report, and we'll see at

18     the bottom of that first page, and I think it's the second page in B/C/S;

19     it is.  Second page in B/C/S, at paragraph 3, at the bottom of that

20     paragraph, it says:  "About 1,460 POWs were brought from Omarska to

21     Manjaca POW camp.  There were deaths during the transport to the camp."

22             I think it's right, Mr. Brown, that you looked at, in fact, after

23     you'd completed this report, a number of documents that emerged after the

24     completion from a captain called Lukajic [phoen], who was at Manjaca.

25     And it was he, the one reporting on a number of these matters.

Page 18759

 1        A.   Yes, I think he was clearly working at Manjaca camp and most

 2     likely, at least from the documents I saw subsequent to writing this

 3     report, that he would send reports to the security organ of the corps.

 4     And I'm assuming what happened in this report was that that incident was

 5     then taken and placed in the daily combat report of the corps and sent to

 6     the VRS Main Staff.

 7        Q.   So as far as you can tell from your survey of these documents,

 8     was the corps not only reporting matters carried out by members of the

 9     corps but also matters that might affect the security, for example, such

10     as this killing outside Manjaca camp?

11        A.   Yes.

12        Q.   As I say, you list a number of incidents that appear in the

13     military documents.  The Kotor Varos incidents that you deal with at the

14     end of paragraph 2.80, and deals with killings that took place in

15     Kotor Varos, again not by the military.

16             Could we have a look, very quickly, please, at document which is

17     P81.

18             MR. ZECEVIC:  Can we have the tab number?

19             MS. KORNER:  Oh, sorry.  The tab is 20 -- tab 26.

20        Q.   This is actually a session of the Kotor Varos Crisis Staff on the

21     26th of June, which was attended, as we can see from the top, by

22     Lieutenant-Colonel Peulic.  And in fact, he -- at the beginning, he

23     presents a report.  And at this meeting, a Dr. Gajanin informed the

24     Crisis Staff of the situation as regards casualties and reporting on what

25     had been done on the premises of the health centre by the special unit.

Page 18760

 1     And he said that Mr. Djekanovic said he'd told Dubocanin about everything

 2     going on.

 3             If we now look, please, at the document which is 65 ter 3707, at

 4     tab 28.

 5             This is a daily -- a regular combat report it's described.

 6     4th of July, so some eight days later.  At item 3, we'll see there that

 7     the massacre -- it says "... of members of a Special Police detachment in

 8     Kotor Varos municipality has additionally aggravated inter-ethnic

 9     relations in the area and made the overall security situation more

10     complex."

11             It says "of," but from your examination, Mr. Brown, do you

12     believe this refers to that incident that was described in the original

13     Kotor Varos Crisis Staff document?

14        A.   Yes.  I mean, there clearly is either a typo or an ambiguity

15     there, but it would seem, in relation to the timing, that this is more

16     related to the incident from the -- that Colonel Peulic mentioned and

17     that was discussed in the Crisis Staff.

18        Q.   All right.

19        A.   Maybe it means -- should be "by" rather than "of."

20        Q.   Yes, thank you.

21             MS. KORNER:  Your Honours, this document has not yet been

22     admitted.  May it be admitted, please.

23             JUDGE HALL:  Admitted and marked.

24             THE REGISTRAR:  As Exhibit P1790, Your Honours.

25             MS. KORNER:

Page 18761

 1        Q.   Right.  Now, the -- moving through, as I say, the report, you

 2     point out that there are a number of references to these killings that

 3     appear in the report, and so it appears that the corps was on notice.

 4             Can we go specifically to one of the major killings, the Mount --

 5     the killing at Mount Vlasic on the 21st of August.  And the Court's heard

 6     a great deal about it, which you set out in paragraph 2.88.  And as you

 7     point out, there was -- and, again, we've seen that, a special report

 8     from Lieutenant-Colonel Peulic reporting on the incident.

 9             And then you reference, at paragraph 2.89, the -- there was a

10     press conference in November of 1992 where General Talic was specifically

11     questioned on the Vlasic Mountain and indeed the Keraterm killings.

12             And perhaps we can just play that, please.  That is at -- there

13     is a transcript which you will find.  It's P622 -- 622, at divider 54.

14                           [Video-clip played]

15             [Voiceover] "There are at least two incidents of alleged

16     atrocities that have occurred to refugees."

17             MS. KORNER:  Okay.  It's not playing, is it?  Your Honours, I'm

18     told there's B/C/S coming through on the English channel for some reason.

19                           [Video-clip played]

20             [Voiceover] "... at Keraterm camp and in a convoy [indiscernible]

21     of refugees [indiscernible] in Trnopolje camp to Travnik.  Does the

22     military accept any responsibility for these refugees and has the

23     military conducted any investigation of the fate of these refugees,

24     particularly those that were allegedly killed at Keraterm camp and those

25     killed on Vlasic Mountain during a convoy?"

Page 18762

 1             THE INTERPRETER: [Voiceover] "There are accusations of at least

 2     two incidents involving refugees in this area.  One involves

 3     100 people -- 50 people in Keraterm, and the other one involves Trnopolje

 4     and Mount Vlasic, where people were killed.

 5             "Did your men take part in these actions?  And the second

 6     question was whether any investigations were carried out."

 7             "Answer:  Well, the army carried out investigation in order to

 8     find out if any of our members had by any chance participated in any

 9     crimes violating moral principles.  We established that the soldiers had

10     not participated, and we criticised the civilian authorities for failing

11     to inform us that the convoy was leaving, as we would have secured it and

12     prevented any disputes about the departure of the convoy."

13             MS. KORNER:  Thank you.

14        Q.   What struck you about that, Mr. Brown?

15        A.   Well, I think from the documents, at least, General Talic knew

16     who the alleged perpetrators of the Vlasic Mountain were, and that

17     information that he had received had been passed up to the Main Staff in

18     his combat reports.  And I think that, at least from his statement there,

19     that he -- he is more interested in whether any soldiers were involved,

20     and yet he clearly knew at that time who had been allegedly involved in

21     the incident and the details of the incident.

22        Q.   When you say he was more -- he was more interested in -- sorry,

23     more interested in whether any of the soldiers were involved, what would

24     you have expected him to be saying at this stage?

25        A.   Well, I mean, he clearly knew what had gone on, and he almost

Page 18763

 1     dismisses it in a way by saying, you know, no soldiers were involved and

 2     also that, you know, he put some blame on the fact that the convoy -- he

 3     wasn't notified of a convoy.  So there's a sort of underlying implication

 4     he's aware.  But, you know, he doesn't -- doesn't really give much away,

 5     particularly.  Yet he clearly knew that there had been a significant

 6     incident.  And this wasn't just a small incident; this was a large number

 7     of people.  It began to draw some significant international attention.

 8     And, you know, maybe also echoed some of the comments in his own

 9     documents where -- where one of the references is that, you know, it's --

10     thank goodness the international community hasn't become more aware of

11     it.  You know, it's not -- he doesn't seem to show any -- I say sympathy

12     is maybe not the phrase, but anything more than just, you know, the

13     troops weren't involved, and kind of dismisses the whole thing.

14        Q.   Let's have, in fact, a look at a report that contained a

15     reference to this incident a couple of months earlier, shortly

16     afterwards, on the 3rd of September.  And it's document, please, P611, at

17     tab 51.

18             Now, this is a report dated the 3rd of September from the

19     1st Krajina Corps and it's to the Main Staff and also to the

20     psychological and propaganda activities department, state of combat

21     morale in August of 1992.  And, in fact, it went out under

22     General Talic's signature.

23             Can we go, please, first of all, to the second page in English,

24     quite on the point that's worth noting this, and the second page in

25     B/C/S.  Top of the English page, and it's a little way down in the B/C/S.

Page 18764

 1     It's reported that all units and armed formations have essentially been

 2     put under the control of the 1st Krajina Corps, although there are still

 3     resistance from the CSB.

 4             And then if we go to paragraph 2, third page in English, and it's

 5     the fourth page in B/C/S.  The overall political and security situation

 6     in August 1992 was characterised by the following:  The activities of

 7     several paramilitary governments and armed formations increased extremism

 8     towards Muslim and Croatian population, continued efforts to place the

 9     organs of the authorities and the MUP above military formations and the

10     army.

11             And then at the bottom of that page:  Certain tensions are still

12     presents in the Kotor Varos, Kljuc, Sanski Most, and Prijedor areas

13     because a large number of arrested citizens for whom there is no evidence

14     or criminal reports that they participated in the armed rebellion.

15             Pausing there for a moment.  Again, is that a -- were you able to

16     see whether that was a reflection of documents that were coming from the

17     Manjaca camp?

18        A.   This last section about individuals not ...

19        Q.   Yeah.

20        A.   Yes.  There are a number of references in the documents I saw

21     subsequently from Manjaca that that is very evident.  And I believe this

22     is not the only document from the documents I was able to review prior to

23     writing this report that the military had reservations that a large

24     number of people of whom were in detention, that there was no evidence

25     whatsoever that they had participated in armed rebellion.

Page 18765

 1        Q.   And then if we carry on.  The CSB --

 2             MS. KORNER:  And could we go to the next page in English.

 3     Thanks.  Still the same page in B/C/S.

 4        Q.   It says:  "The CSB, especially from Prijedor, is not contributing

 5     this approach.  Prijedor, headed by Stevo Drljaca, who led a convoy of

 6     people who wanted to leave the crisis area, they committed a massacre in

 7     the Skender Vakuf area of over 150 men who wanted to leave the territory

 8     of the Krajina autonomous region.  This action caused indignation not

 9     only amongst the citizens but also amongst the 1st Krajina Corps

10     soldiers, this dark stain which was created and did not have support.

11     But it is very fortunate that the international community did not find

12     out about it in more detail."

13             Now, I think that's self explanatory.  But this report went out

14     under General Talic's name.  Would he have had to approve it before it

15     went out or could it -- would it just go out under his name?

16        A.   No.  I mean, he's the corps commander.  And whether a staff

17     officer signs on his behalf, he has the -- it's his authority and it's

18     going to the Main Staff.  I don't know if this particular one had his

19     signature; I would have to look at the original B/C/S.  But clearly --

20             MS. KORNER:  The last page in B/C/S, please, I think we'll find

21     it.  It looks like somebody signed on his behalf.  If we go to the last

22     page in both, please.

23             THE WITNESS:  Yes, someone has signed on his behalf.  That's not

24     General Talic's signature.  But irrespective of that, it's one of his

25     senior staff officers.  I would imagine the -- potentially the assistant

Page 18766

 1     commander for moral and civilian affairs.

 2        Q.   All right.  You also deal, in paragraph --

 3             JUDGE HARHOFF:  Ms. Korner.

 4             MS. KORNER: -- 2.92 -- sorry, Your Honour.

 5             JUDGE HARHOFF:  I don't know if you were about to leave this

 6     document, but I have a question to Mr. Brown.

 7             If we go back to, I think it was page 2, where the author of the

 8     report states that everything -- all units have now been assembled under

 9     the control of the 1st Krajina Corps, except that there is still

10     resistance from the CSB.  And I would be curious to know how Mr. Brown

11     had interpreted that comment.

12             Do you know, Mr. Brown?

13             THE WITNESS:  Sir, the way I read that is it relates to the issue

14     of paramilitary units and potentially the document we discussed last week

15     where paramilitary units were meant to be placed under the control of

16     the -- of the VRS or the corps.  In that document, I think there is a

17     reference to the CSB.  And maybe this is a reference that, as yet, the

18     CSB hasn't been placed under control.  I don't think this reference is

19     all units, all types in the corps; I read this as relating to that

20     discussion or issue of paramilitary units potentially operating outside

21     the authority of the Serbs.

22             JUDGE HARHOFF:  But how and why would the CSB -- I suppose we are

23     speaking about the CSB in Prijedor.  How and why would that CSB offer

24     resistance to the plans of controlling and coordinating all units under

25     the umbrella of the 1st Krajina Corps?

Page 18767

 1             THE WITNESS:  Your Honour, I think this refers to this -- or

 2     potentially refers to -- the way I read it, potentially refers to the

 3     special unit, the CSB special units, not the unit from Prijedor

 4     particularly.  This may relate to this issue around Kotor Varos and the

 5     Banja Luka CSB, which was one of the units referred to in that

 6     paramilitary document.  And also I know that after -- or, I believe, I

 7     don't know the full details, but I believe that after the incident in

 8     Kotor Varos there was some discussion about resubordinating or placing

 9     that CSB under the control of the army, and it may well be that that

10     hadn't been formalised or completed or the discussions hadn't gone

11     particularly well and there was some reservation about placing that CSB

12     under the control of the army.  I think I read it as it relating to the

13     CSB special unit Banja Luka, not necessarily the -- well there wasn't a

14     CSB in Prijedor, but SJB or another police organisation.

15             JUDGE HARHOFF:  I'm not sure I fully understand what it is you're

16     saying.  I mean, I suppose that at no point had there been any plans to

17     place the entire CSB or SJB under the control of the army, so the only

18     thing that, as far as I understand it, the only thing we are discussing

19     could be the special unit, which structurally resorted under the -- under

20     the MUP, either the CSB or the SJB or whatever it is in Prijedor, and

21     those special units were placed under the control of the MUP.

22             So my question is now:  Are you suggesting that the 1st Krajina

23     Corps attempted to have these special units transferred under its control

24     from the MUP to the army and that the CSB offered resistance to that

25     plan?  Is that how you interpret General Talic's remark or, should I say,

Page 18768

 1     the remark of the author of the report?

 2             THE WITNESS:  Yes.  I think that, from my reading, was possibly

 3     what happened.  I know that the CSB special unit, Banja Luka special

 4     unit, existed.  It took part in the operation in Kotor Varos.  It

 5     obviously conducted some unauthorised activity, which is referenced in

 6     the Krajina Corps.  And I believe what happened after that was that there

 7     were discussions about whether and how the CSB should operate.  And it

 8     may well have been that one of those discussions, bearing in mind that

 9     same unit, is referenced in the paramilitary document from the

10     Main Staff, and that the paramilitary unit document makes reference that

11     paramilitaries should be placed under the control of the army, that the

12     discussions were to place that unit under the control of the army.  But

13     clearly, by this reference, that either hadn't happened or the

14     discussions hadn't gone well or it was still ongoing.  That's maybe how

15     I read it, although I'm not an expert on the issues of the activities of

16     the MUP and the Banja Luka special unit.

17             JUDGE HARHOFF:  I guess all of this boils down to the question of

18     whether, to your knowledge, the MUP regarded the special unit as a unit

19     that resorted under its control.

20             THE WITNESS:  Well --

21             JUDGE HARHOFF:  And compared to a unit that was just a

22     paramilitary unit acting more or less independently.

23             THE WITNESS:  I'm not sure I can answer that question, sir,

24     because I haven't looked at the relationships within the MUP and looked

25     at their structures and how they operated.  I would possibly read from

Page 18769

 1     this document that the CSB at this stage isn't -- special unit is not

 2     under control of the army, or at least there are problems there in terms

 3     of either trying to place it under the control of the army.

 4             JUDGE HARHOFF:  I think this is as far as we can go with this.

 5             Thank you, Ms. Korner.  Back to you.

 6             MS. KORNER:  Yes, but -- thank you.  I think we'd better go back,

 7     just briefly, to look at the Main Staff paramilitary document just so we

 8     can see what you're referring to.

 9             Could we have up again, please, P591, which is tab 36.

10             And we need to go, please, to page 4 in English, and -- let me

11     just find it again in B/C/S.  It's -- I think it's the same page, yes,

12     same page.  It's not.  It's the next page in English, sorry.  Page 5 in

13     English -- sorry, it's the fourth page in English, fifth page in B/C/S.

14             Thank you.  At the bottom of the fourth page in English, it talks

15     about the SOS under the command of Stevandic, and then it says the

16     officials in the CSB have considerable influence over the SOS, many

17     infamous Banja Luka criminals have joined, part of the SOS formation was

18     officially disbanded, joined the Banja Luka CSB Special Police

19     detachment -- oh, sorry, can we go to the next page in English, please.

20     Joined the Banja Luka CSB Special Police detachment but is not really

21     under the control of the detachment's command or the CSB.

22        Q.   Is that what you were referring to, Mr. Brown?

23        A.   Yes.  Maybe it's slightly more nuanced here and maybe I would

24     refine a little bit my position, but because clearly there is -- whether

25     it's a component of the CSB and whether this document is referring only

Page 18770

 1     to that component or the CSB as a whole, maybe it's unclear.  But I do

 2     believe that there were discussions in -- in the summer about the CSB and

 3     its position and whether it should be commanded by the MUP or whether it

 4     should be integrated into the army, I believe.  Although, as I say, I'm

 5     not an expert on the activities of Banja Luka CSB or the MUP structures.

 6        Q.   Yes.  Thank you.  Then moving swiftly through the last part.  You

 7     deal in your paragraphs 2.92, effectively till the end of the report,

 8     with the killings that took place in Vecici in November of 1992 -- or not

 9     Vecici, the -- those who had escaped from Vecici and the killings at the

10     Grabovica school.  And I think all we need to do is note that you point

11     out that originally the 1 KK reported this --

12             MR. KRGOVIC: [Interpretation] Sorry, is this incident part of the

13     indictment?

14             MS. KORNER:  Mr. Krgovic knows it's not on the indictment but

15     nonetheless it's evidence that has been led in this case and has been led

16     before because it goes to the general pattern of the events and also the

17     reporting of the events that it was known to those in authority what had

18     happened.  So if there's no further objection, I'll continue my summary.

19             JUDGE HALL:  Yes, please continue, Ms. Korner.

20             MS. KORNER:  Thank you very much.

21        Q.   If we look at your paragraph 2.96, you refer to the

22     1st Krajina Corps's report that those who had been captured were killed

23     in a massacre.  And you reference that report.  And it was a report of

24     the 4th of November.  And there, as you set out in that paragraph,

25     40 Green Beret members were killed and 200 were captured.  A brutal

Page 18771

 1     massacre of the captured members of the Green Berets started because of

 2     the wounding of four and the killing of one soldier of the Kotor Varos

 3     Light Infantry Brigade, et cetera.

 4             And you point -- then go on to point out, in paragraph 2.97, that

 5     by the following day the corps was no longer portraying this incident as

 6     a massacre but that the deaths were simply combat casualties.  And you

 7     reference your -- the report of the 1st Krajina Corps the following day,

 8     the 5th of November, where they talk about - it's the top of page 97 in

 9     English - more than 150 extremists dying in combat and later reporting

10     makes no reference to the incident.

11             It may be clear already but is this one of the themes that you

12     noted, as with the Mount Vlasic massacre, that the reporting was not

13     always strictly accurate or changed?

14        A.   Well, I wouldn't say that the reporting wasn't strictly accurate.

15     I think it is.  I didn't see this as a pattern particularly that they

16     would change the -- there would be a killing or a reference to a massacre

17     or a slaughter and then that that would be changed.  I think this is the

18     only incident that I remember that happening.  But there were a number of

19     references, as the report indicates, where the corps was clearly aware

20     that killings had occurred.  This was one of more obvious ones, and I

21     don't remember seeing any reference in the documents that anybody was

22     ever held accountable in the -- in the 1st Krajina Corps for this or

23     whether there was any significant investigation into this incident after

24     it happened.

25             And Colonel Peulic, who was the Operations Group Vlasic commander

Page 18772

 1     at the time, continued to serve on in the corps for a period of time, and

 2     I don't remember seeing anybody held accountable for that, let alone any

 3     investigation.

 4        Q.   Right.  Yes, thank you.

 5             And the next section of your report deals with the rounding up of

 6     the population, the transfer to camps and detention centres.  Again, the

 7     Court's heard a lot of evidence about this, and you've set this all out

 8     in your report.  Perhaps just a couple of things that we ought to note.

 9             You talk about the -- in paragraph 2.103, page 99 in English, the

10     conclusions of the Sanski Most Crisis Staff - I'm not going to turn up

11     the document because we've seen it - putting the prisoners into

12     categories.  And you point out that -- it ends by saying:  In view of

13     this, have a talk with Colonel Stevilovic from the 1st Krajina Corps.

14             Are you able to assist the Court:  Why would that have involved a

15     conversation with Colonel Stevilovic?

16        A.   Colonel Stevilovic was the security -- senior security officer in

17     the corps, and I assume that the issue of captured individuals would have

18     had a security implication with him.  And whether they wanted to have

19     some commonality across the corps or whether they wanted just to inform

20     him that individuals that may be coming in to Manjaca camp, for example,

21     would be classified in this manner.  So I guess it's because it has a

22     security implication that's been referenced that they want to discuss

23     that with him.

24        Q.   All right.  And then you point out in the next paragraph that the

25     classification drawn up for those who were sent to Omarska was pretty

Page 18773

 1     similar.  You deal with, as I say, I want to go through this fairly

 2     quickly, the paragraph 2.110, although the police were primarily

 3     responsibility for the running of the camp, the military were also

 4     involved in the processing of prisoners in Omarska.  And you've set all

 5     that out.  And, as I say, the Court has heard a great deal of evidence

 6     about this.  Can we, however, go to the corps's awareness, not only of

 7     what was happening in Manjaca camp but in other camps as well.

 8             You reference that in paragraph 2.122, which we've looked at

 9     already, that the corps was aware that killings had returned -- that

10     killings had occurred during the transfer of prisoners from Omarska.  And

11     then can we look at what they knew about Keraterm, paragraph 2.125?  In

12     July -- 25th of July -- sorry, it's the paragraph before 2.124.  On

13     25th of July 1992, a daily corps report informed the Main Staff that

14     prisoners attempted to escape, mass escape, and 50 prisoners were killed.

15             And then there was a general report, and I think we ought to look

16     at that, please.  That's document 2874, 65 ter 2874, at tab 50.

17             This is dated the 22nd of August, and it's sent to the Prijedor

18     operative group command, to the command in person.  Do you know who was

19     the commander of the Prijedor operative group?

20        A.   I believe at that time it was Lieutenant-Colonel Arsic who was

21     also commander of the 343rd or the 43rd motorised brigade.

22        Q.   All right.  And it sets out the situation in Prijedor can be

23     summed up in the following sentence:  Nevertheless discipline, nevermore

24     waywardness.

25             Can we go to the second page in English, please.  And the second

Page 18774

 1     page, I think, in B/C/S.  At the top of the page, it says, another

 2     interesting item:  All are now washing their hands regarding the camps

 3     and reception centres, attempting to pass responsibility for issuing

 4     orders for mass execution of civilians in the camps and centres on to

 5     someone else.  This has become particularly noticeable since the visit of

 6     foreign reporters to Prijedor, more precisely, to Omarska and Trnopolje.

 7             This report is August the 22nd.  Is it clear who the report is

 8     from?

 9        A.   No, it's not.  Not from the reading -- my reading, it's not

10     clear.

11        Q.   Right.  But it apparently comes from the command of the

12     Doboj operative group; is that right?

13        A.   No.  I think -- I think -- well, I think the information has --

14     the forward command post of the corps at this time was towards the

15     corridor area, and I think what's happened is information has come to the

16     forward command post and they've relayed that information in entirety to

17     Prijedor operative group command and maybe they've just used the stamp

18     from Operative Group Doboj because that's quite close to where the

19     forward command post was.  But it's not clear where the information

20     originated from.

21        Q.   All right.  And you say -- in fact, I think you say in your

22     report that you looked at other reports from the same day, in fact, one

23     about deserters, which is referenced in your -- which was, in fact,

24     signed by General Talic and -- but comes with a similar stamp.

25        A.   Yes.  I believe General Talic was probably at the forward command

Page 18775

 1     post at that time.

 2        Q.   And then it goes on to say:

 3             "One thing is certain:  We are already starting to feel the cost

 4     of the needless spilling of Muslim blood.  There is information that

 5     Muslims driven out of the municipality of Prijedor and those who have

 6     fled to the other side but who had done nothing against the

 7     Serbian Republic before are now taking up arms in Croatia and joining the

 8     war against us.

 9             "In addition to this, Muslims who were either driven out of or

10     fled from Prijedor to Croatia now attack everything that is Serbian, and

11     the Serbs in Croatia have thus gained fanatical enemies, bequeathed to

12     them by the civilian and military authorities of Prijedor."

13             How does this report, Mr. Brown, fit in with the army's view of

14     what was happening?

15        A.   Well, I'm not sure I can say, well, the army's view of what was

16     happening, but it's clear that the army have been made aware that --

17     about the situation in Prijedor.  That a large number of people have been

18     driven out, that their detention camps have become known in the

19     international community.  And the military clearly, or the author, is

20     clearly aware that this has now caused significant problems, not just

21     because of the incidents on their own, but because by driving people out,

22     those who had been driven out are now potentially signing up to fight the

23     republic, Serb Republic.

24             So sort of on all levels the activities of what's gone on in

25     Prijedor with the civilian and military authorities operations there has

Page 18776

 1     caused significant problems.  And it's not the only document I've seen

 2     that they were aware, I mean, we talked about killings and other things,

 3     but this would seem to crystallise what had happened, that it's come out

 4     in the international community after the visits of camps.  And what

 5     they're not doing is denying any of this driving Muslims out, the issue

 6     of camps; they're not denying that this has not gone on.  What they're

 7     saying is it's caused significant problems and that it's going to

 8     continue to cause us a military problem because individuals who have been

 9     driven out will be coming back to, in essence, to conduct operations

10     against us or to fight against us.

11        Q.   Yes.  Thank you.

12             MS. KORNER:  Could that be admitted and marked, please,

13     Your Honour.

14             JUDGE HALL:  Admitted and marked.

15             THE REGISTRAR:  Exhibit P1791, Your Honours.

16             JUDGE DELVOIE:  Ms. Korner, just --

17                           [Trial Chamber and Registrar confer]

18             MS. KORNER:  I'm sorry, did His Honour Judge Delvoie want to say

19     something?

20             JUDGE DELVOIE:  Yes, Ms. Korner.

21             Mr. Brown, at the end of the first paragraph of the document that

22     was just on the screen, it is said, if I remember correctly, the

23     impression is that the local fatherland front is behind all of this.

24     Something to that effect.  I don't have it on the screen any more, so

25     I can't --

Page 18777

 1             MS. KORNER:  Could we have it back again, please.

 2             JUDGE DELVOIE:  It's on page 2.  The impression is that the local

 3     fatherland front is involved in all this.  What is this about?  What is

 4     the local fatherland front; do you know?

 5             THE WITNESS:  I'm unaware what that is, sir.  I -- that is the

 6     only time I've seen that reference, and I'm not clear what it is.

 7             JUDGE DELVOIE:  That's why I asked.  Because it's the first time

 8     I see it.  Thank you.

 9             MS. KORNER:  I think that's the same for all of us, Your Honour.

10        Q.   Then can we just, as I say, go back to your report and very

11     quickly note, as you have dealt with already, that in paragraph 2.127,

12     the fact that the corps was aware that people were being imprisoned

13     against whom there was no evidence.  And finally, at 2.131, you point out

14     that the military were also involved in the final removal of many of the

15     prisoners who had found themselves in detention camps in the

16     Bosanska Krajina area and make the point that the transport wasn't back

17     to their own homes but out of the Serbian Republic.

18             If we look, please, at just one example of that.  It's the

19     document at -- it's 65 ter 1569, at paragraph -- at tab 60.

20             This is dated the 15th of December, and it's an order from

21     General Talic to close down Manjaca.  Prisoners for whom investigation

22     has -- so far has not determined they're committing war crimes shall be

23     handed over to the International Red Cross.  And then prisoners for whom

24     there are grounds for suspicion they have committed criminal acts or

25     crimes against humanity or war crimes shall be sent to Batkovici, in

Page 18778

 1     paragraph 3.  Some, however, of the prisoners from the first group shall

 2     be sent to Kula in order to be exchanged for Serbian prisoners.

 3             MS. KORNER:  All right.  And Your Honours, can that be admitted

 4     and marked, please.  That's not yet an exhibit.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  Exhibit P1792, Your Honours.

 7             MS. KORNER:  All right.  And can I deal with one other document.

 8     I'm sorry it's completely out of context, but I omitted to deal with it.

 9     And because it's right next door to the one we just dealt with.  Can we

10     have a look, please, at 65 ter 3706, at tab 59, which really came in, in

11     one of the earlier sections you were talking about last week.

12        Q.   This is an order dated the 26th of November by General Talic,

13     ordering the -- it's called resubordination of some artillery pieces

14     because they're required by the Banja Luka CSB police brigade.  And

15     I think we looked at the documents for that last week.

16        A.   Yes, I think it's related to that period where a large police

17     brigade is formed and for operations in the corridor, and I guess they

18     are giving them some artillery.

19        Q.   All right.

20             MS. KORNER:  Your Honour, I should have dealt with that last

21     week, but I forgot.  Could I have that admitted and marked as well,

22     please.

23             JUDGE HALL:  Yes, admitted and marked.

24             THE REGISTRAR:  Exhibit P1793, Your Honours.

25             MS. KORNER:

Page 18779

 1        Q.   Returning, then, to your report and briefly on the detention

 2     centres and camps, I think you note, finally, in the last paragraph on

 3     this section 2.133, that, effectively, this was an overlapping - and this

 4     is the middle of the paragraph - involvement of military police and

 5     civilian authorities in relation to the establishment and running of many

 6     of these facilities, and the fact that a significant number of detainees

 7     were transferred between multiple camps highlights a degree of planning

 8     and cooperation.

 9             Turning, then, next, please, to the removal of the non-Serb

10     population from towns and villages, which is at -- begins at

11     paragraph 2.134.  Again, the Court's heard a lot of evidence about this,

12     so I'm not proposing to really take you through the paragraphs of that

13     report.  You've already dealt with the fact that the corps was clearly

14     aware of the expulsion of the non-Serb population, and there are a number

15     of references in its reports.  And if we look, please, at just one of

16     these documents.

17             Could we have a look, please, at P432.17, at tab 23.  Again, this

18     is a report, this time the 14th of June, on the state of combat morale.

19     And if we go, please, to the second page in English and the second page

20     in B/C/S, paragraph 2, the effects of the political security situation on

21     the territory on combat morale.  It talks about the complex political and

22     security situation in BH in May escalating into numerous armed conflicts

23     in a large number of towns in Bosnian Krajina, and references Kljuc,

24     Sanski Most, Prijedor, and Jajce, and asserts that all these conflicts

25     were organised by the BH, TO, and in conjunction with the Republic of

Page 18780

 1     Croatia, and were imposed upon the Serbian People.  And, again, you've

 2     dealt with that aspect in some of the incidents you say which then led to

 3     these reprisals.

 4             Second part of that document, that paragraph:  In our estimate, a

 5     certain degree of chaos and total inter-ethnic war have been forestalled.

 6     This is confirmed by the continuously stable conditions in Banja Luka and

 7     many other towns, as well as by the way in which control has been

 8     established in Kotor Varos, where a real explosion of armed conflicts was

 9     threatening to erupt.

10             And then, please, the third page in English, and the fourth page

11     in B/C/S.  At the end of that paragraph, sorry, the section just before

12     we get to paragraph 3, the report asserts:  The most difficult situation

13     concerns the Muslim and Croat refugees in the area of AR Krajina, their

14     security and the provision of food.  The attempt to expel them to

15     Central Bosnia failed because of transportation difficulties and their

16     resistance to leaving their places of residence.  This is giving rise to

17     vindictiveness and revenge and is resulting in the enemy closing its

18     ranks.

19             You note in your report at paragraph 2.148 that the military were

20     not overtly critical of this policy or appeared to hold any genuine

21     sympathy for the plight of the non-Serbs.  If anything they were critical

22     that the policy of expulsion was not working, simply due to logistic

23     problems and resistance from the non-Serbs who didn't want to leave their

24     home.

25             Was that view one that you formed simply as a result of this

Page 18781

 1     document, the lack of sympathy, or from your overall review of these

 2     documents?

 3        A.   Yes, I think it is -- it is true that -- in this particular

 4     reference, that they -- they are aware, firstly, that people are being

 5     expelled, non-Serbs are being expelled, but they are not giving any --

 6     they don't seem to have any sympathy particularly, they were just saying

 7     that the logistic problems were causing that.  They were also referencing

 8     the fact that -- the fact that there are -- they haven't been expelled is

 9     giving rise to vindictiveness, presumably meaning robbery or looting or

10     attacks on non-Serbs, but they're not -- they're almost implying that if

11     they had been expelled then that wouldn't have happened.  And also,

12     again, this issue that is -- this revenge issue and the enemy closing its

13     ranks.  So there doesn't seem to be any -- well, there's certainly no

14     reference that this type of activity should stop, that it's unacceptable,

15     that we are -- we should be -- we are fighting or taking control of

16     territory for -- irrespective of ethnicity.  And it's not just this

17     incident.  There are other references.  And I think the general tenor of

18     the corps reports in this would give very little sympathy whatsoever

19     for -- for the -- for the non-Serbs.  You know, if we look at the

20     references in the documents where people are in detention centres and the

21     military are making references themselves that individuals have --

22     there's no evidence that any of these -- or many of these individuals

23     were involved in activities.  The follow-on would usually or you would

24     expect it to be that, well, these people should be released, or we should

25     make measures for those people to be taken back to their places of

Page 18782

 1     residence in -- but there's none of that.  So from the -- many of the

 2     military documents I don't see any sympathetic -- particularly

 3     sympathetic language.  Maybe this is a clear example of that.

 4        Q.   Yes.  And you then -- yes, you deal with the -- in your further

 5     paragraphs - and as I say, I'm not going to deal with them in any detail

 6     at all - the fact that the military was apparently getting reports of how

 7     many people had actually been moved out.

 8             Coming, then, to destruction and looting, which is at page 122 of

 9     your report.  You state, in paragraph 2.164, that the municipality

10     operations in Bosanska Krajina not only marked by the large-scale

11     movement of population but noted for significant levels of destruction

12     during and after military attacks and high level of looting.

13             And you point out, if we move to 2.177, that it was a -- the

14     issue was a complex one, face value, the corps appears to take action to

15     stop it, for example, as you pointed out earlier, by issuing instructions

16     to stop blowing up religious institutions.  But there was a clear

17     distinction between the cases of individual, small-group looting which

18     the war profiteering speculation which the 1st Krajina Corps were

19     critical of and the attempted to curtail and an officially sanctioned

20     policy which enabled the Bosnian Serb authorities to appropriate

21     property, et cetera.  And I don't think that we need to go into any of

22     the documents.

23             At page 131 of your report, paragraph 2.189, you deal with the

24     commendations that were handed out, as you've already mentioned.  On the

25     11th of May, General Talic congratulated the soldiers and command of the

Page 18783

 1     6th Brigade for liberating Krupa after the attacks of Hambarine and

 2     Kozarac.  The 43rd Motorised Brigade was congratulated.  And you've

 3     already mentioned the various awards handed out to paramilitaries.

 4             And then finally, your -- on this aspect, at page 133, you deal

 5     with the non-Serb armed resistance.  And that's summarised, effectively,

 6     at paragraph 2.209.  Where you say it's evident that a defensive

 7     structure was being established in some non-Serb areas, certain limited

 8     weaponry was available, and you then make the comparison between the

 9     non-Serbs and the VRS.  And I think, Mr. Brown, we really dealt with it

10     earlier when you say that the VRS, if one looks at the numbers it

11     contained and the armaments, was considerably superior; is that right?

12        A.   Yes.  Yes.  It would seem so.

13        Q.   All right.  And can I turn finally, before we get -- look at the

14     Mladic notebooks, to the question of the operations in the corridor.

15     Because that's a -- quite an important part of your report.  At page 140,

16     you deal with the operations in the corridor and Jajce.  We looked at,

17     last week, the strategic goals that were issued at the 12th of May

18     Assembly, and you point out in paragraph 2.213 that General Talic himself

19     in an interview, which I'm not going to trouble you with, set out the

20     aims of the operation.

21             We'll see some references to it but can we have a look, please,

22     in the Mladic notebooks, first of all, at the directive from the

23     Main Staff which when you wrote the report you had not seen but you have

24     now seen.

25             Can we look, please, at document 2624, at tab 19.

Page 18784

 1             Now, this is a directive -- I think if we look at the last page,

 2     please, in each document, which goes out under the name of the commander,

 3     Main Staff, Mladic.  And it's addressed to the 1st and 2nd Krajina Corps,

 4     the Sarajevo-Romanija Corps, and Eastern Bosnia.

 5             If we go, please, then, back to the second page, well, it's still

 6     the first page in English -- first page in -- sorry, second page in

 7     English, first page in B/C/S.  We see the goal of the action.  First of

 8     all, secure parts of Sarajevo in A.

 9             So this is going wider, is it, than just the corridor operation?

10        A.   Yes.  This is actually for the -- for all the corps of the VRS at

11     this stage, but in particular I think it's stressing activities in

12     Sarajevo, which was to secure the Serbian part of Sarajevo, which

13     actually was also a strategic goal.  And also the issue of the corridor.

14     And that involved the 1st Krajina Corps and also the East Bosnia Corps.

15        Q.   Right.  Now let's just look at the corridor.  It says:  B,

16     ensure -- I think we need to go to the second page in B/C/S.  Ensure

17     contact between Semberija and the Bosnian Krajina.  And then, third page

18     in English, same page in B/C/S.  First of all, it talks about, again,

19     Sarajevo at the top of that page, and it says:  Group forces to open the

20     corridor between Semberija and the Bosnian Krajina.  And in the second

21     stage, in a duration of four to six days, create the corridor between

22     Semberija and the Bosnian Krajina, reject enemy forces away from the

23     communications.  In the period to come, extend the corridor permanently,

24     providing secure traffic communication in it.

25             So there was to be approximately, what, eight days to create the

Page 18785

 1     corridor altogether?

 2        A.   Yes, to secure the -- that route initially, and then it was meant

 3     to be expanded, I think, later.

 4        Q.   Right.

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

 6     please.

 7             JUDGE HALL:  Admitted and marked.

 8             THE REGISTRAR:  As Exhibit P1794, Your Honours.

 9             MS. KORNER:  And now can we look, please, at the 9th of June

10     order that was issued by General Talic following on from that directive,

11     which is document 10641, at tab 20.

12        Q.   It says:  Order by the 1st Krajina Corps command.  Enclosed we

13     submit the order for the Defence security and active operations of the

14     command of the 1st Krajina Corps.

15             And it's actually -- it appears to be signed.  It says:  Standing

16     in for chief of operations, Colonel Krajnc.  Do you know who

17     Colonel Krajnc was?

18        A.   Yes.  He was a JNA or former JNA officer, I believe, a Croat.

19     And he -- he was in the operations department of the corps, but he was

20     removed, I believe, not long after that.

21        Q.   Right.  And then if we go on to -- it gives the distribution

22     list, done in 21 copies and distributed to ... and you can see if we

23     go ... and then can we go, please, to page -- the fourth page in English

24     and also the fourth page in B/C/S.  It's the order, the Defence security

25     and territory and offensive operations, and it begins with 1, the

Page 18786

 1     enemy -- enemy forces are deployed throughout the territory and zone of

 2     responsibility of the 1st Krajina Corps.  And it goes on to say:  In

 3     areas where armed conflicts have not yet occurred, arming of Muslim and

 4     Croatian population has already been carried out, and they can spring

 5     into action at the required moment.  All capable of bearing arms are

 6     military personnel.  And they will not refrain from using all available

 7     weapons.  Do.

 8             You have any comment on that, Mr. Brown?

 9        A.   Well, I think it sets quite a tone for the corps.  I mean, this

10     is being passed down to all the subordinate formations in the corps.  And

11     General Talic is indicating that at least he views that anybody who can

12     carry weapons is a -- should be treated as military personnel.  And I'm

13     assuming he's meaning the non-Serbs.

14        Q.   Then, organised actions by Muslim formations can be expected very

15     soon in the areas of Gradiska, Kotor Varos.

16             We know, Mr. Brown, that the takeover of Kotor Varos took place

17     in fact two days after this.  Is there any connection between that and

18     this beginning of operations that you were able to see?

19        A.   Yes.  Because he's -- he does give tasks not only to the units

20     that are going to be involved in the operation in the corridor but he is

21     making tasks for all the other units in -- in the other areas to secure

22     the territory or to continue to secure the territory, to take measures to

23     secure the territory.  And I'd have to quickly look at it, but it --

24        Q.   All right.  Well, we're going to go through it.  Can we go to

25     page -- as you say, he's setting out tasks of the 1st Krajina -- the next

Page 18787

 1     page, tasks of the 1st Krajina Corps, then the neighbouring forces.  And

 2     then if we look at page 6 in English, and I believe it's page 3 in --

 3     sorry, page 4 in B/C/S as well.  Not page 4.  I'm so sorry.  It's page --

 4     it says page 4 at the top, but it's probably the sixth - one, two, three,

 5     four - sixth page in B/C/S.  And it's the sixth page in English.

 6             At the top of the -- 4:  I have decided to continue with

 7     persistent and active defences increasing measures against possible

 8     surprise actions or creation of new flash points, speed up the clearing

 9     of the territory and the elimination of any -- any -- of any enemy

10     hotbeds in the zone of responsibility.  And then the first -- the

11     offensive parts of the operation planned out and carried out in three

12     stages.  And it talks, summarising.  It's a very long order.  It

13     effectively is the Operation Corridor, talks about widening the corridor.

14     And then the second stage of the operation beginning on the 11th of June.

15        A.   Yes.  And going back to your previous question, just having

16     quickly looked at the document.  On page 8 --

17        Q.   Yes, coming to that.

18        A.   -- it references the 122nd Brigade which was the brigade along

19     with the Kotor Varos light brigade that was dealing with Kotor Varos.

20     And Talic instructs it to continue active operations in that area,

21     closing routes from basically Central Bosnia into Kotor Varos, continue

22     eliminating trouble spots, prevent the emergence of new sources of

23     conflict, step up measures of full control over the territory, prevent

24     infiltration.  And I think that that instruction was passed on to the

25     122nd Brigade and that that -- what followed from that were operations in

Page 18788

 1     vote Kotor Varos which occurred not long after this instruction was

 2     issued.

 3        Q.   Right.

 4             MS. KORNER:  Your Honours, I see the time.  I've got two other

 5     matters to deal with on this document.

 6             JUDGE HALL:  So we take the break and resume in 20 minutes.

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

 8                           --- On resuming at 10.57 a.m.

 9             MR. ZECEVIC:  Just for the record, Your Honours, Stanisic Defence

10     has been joined by Ms. Suzanna Mohr and Ms. Alexandra Laskowski.  Thank

11     you.

12             JUDGE HALL:  Thank you.  So noted.

13             MS. KORNER:

14        Q.   Mr. Brown, just a couple of further matters on this document.

15     Can we go, please, to page 11 in English and page 9 in B/C/S.

16        A.   Sorry, Ms. Korner, can you tell me what tab it is again?

17        Q.   Oh, I'm so sorry.  It's tab 20.  Where there's a section dealing

18     with operations support where it states, in the second paragraph,

19     under A:  Monitor the activity of the Muslim and Croat population in

20     areas where there are no conflicts and detect, in time, the beginning,

21     the objectives, and the modes of involvement of these formations.

22             And under --

23             MR. ZECEVIC:  I'm terribly sorry.  We are not getting this in

24     Serbian.

25             MS. KORNER:  Is it not on page 9 -- oh, no, you're on page 6.

Page 18789

 1     Sorry, 9 at the top of --

 2             MR. ZECEVIC:  Thank you.

 3             MS. KORNER:  So it must be three pages further on.  Yeah.  Thank

 4     you.

 5        Q.   Then under B, security support, we see that it's terminating

 6     sabotage, terrorists, and spying activities by the enemy's Special

 7     Forces, especially on the axes that lead from Cazin Krajina, Lasva valley

 8     into the zone of the corps, and in areas with Muslims and Croatian

 9     population where there have been no conflicts.

10             And then finally this:  Devote -- sorry, you need to go to the

11     next page in B/C/S, please.  Yes, thank you.  Devote special attention to

12     security for protection of sensitive elements of combat disposition,

13     achieve full control and restrict movements of the population in the zone

14     of responsibility.  After they are processed by intelligence and security

15     organs of the units, take prisoners of war and persons responsible for

16     hostile activity with the required paper work to camps for prisoners of

17     war.

18             Was this a particularly wide-ranging order, Mr. Brown, in terms

19     of everything that was set out, or were there other similar orders that

20     you saw?

21        A.   No.  This was a particularly wide-ranging order.  But I believe,

22     also, after the other directives were passed, for example,

23     Operational Directive 3, which I think was in August, I believe

24     General Talic passed a similar -- you know, did the similar process of

25     passing an instruction down to his corps.  But this is quite a

Page 18790

 1     wide-ranging order to his subordinate formations.

 2        Q.   Right.

 3             MR. ZECEVIC:  I'm terribly sorry to -- but I see in the English

 4     translation that the last word "viz," v-i-z, it says "expansion unknown."

 5     I believe it refers to the military investigative prison.

 6             MS. KORNER:  You may well -- Mr. Zecevic ...

 7        Q.   Mr. Brown, do you know what it refers to?

 8        A.   I do believe that's what it refers to.

 9        Q.   All right.  Well, thank you.

10             MS. KORNER:  Thank you very much, Mr. Zecevic.

11             Yes, that's all I want to ask about that document.  Your Honours,

12     may that be admitted, please and marked.

13             JUDGE HALL:  Admitted and marked.

14             THE REGISTRAR:  Exhibit P1795, Your Honours.

15             MS. KORNER:  Thank you.

16        Q.   Now, a -- I think you also looked at, recovered from the

17     1st Krajina Corps headquarters, a map of the operation.  Can we go --

18     could we have up, please -- it's at tab 63, and it's document

19     number 3710.  And there is a translation.  Tab 63.  I think we need to

20     have the translation up as well, please, at the same time.  Try and have

21     it at the same time, anyhow.  I think we can see it says, at the

22     left-hand side, I approve, Lieutenant General Ratko Mladic; then a

23     decision, 1st Krajina Corps commander to carry out offensive operations;

24     and then, military secret, strictly confidential, corridor 92.  And then

25     we can -- there's a key to this.  Did it appear that there was any

Page 18791

 1     involvement by any kind of police brigades in this?

 2        A.   I would have to see the -- if you're asking me whether it's

 3     highlighted on this map --

 4        Q.   Yeah.

 5        A.   -- I would have to see the map itself.  It's a very large -- from

 6     what I remember, it's been a long time now, but --

 7        Q.   All right.

 8        A.   -- I think it's a very large map, but I do know that there were

 9     police -- there was police involvement.  I know specifically that there

10     was police involvement from the RSK MUP and it took part in that

11     operation, and, in fact, I think after the success of the operation,

12     there was a hesitancy or an instruction that that police formation was

13     not to be publicly congratulated, that it would be congratulated in a

14     different way.  But I know that there was an RSK MUP involvement, and I'd

15     have to check to see whether there was Krajina MUP involved.

16        Q.   Right.  Yes, I think if you look at your paragraph 2.217, where

17     you state the importance of the corridor operation and the overall

18     activity of the 1st Krajina Corps cannot be overstated, scale of the

19     operation, the high degree of planning, coordination required.

20     1st Krajina Corps, East Bosna Corps, and forces from the RSK MUP were

21     involved.  And the relatively quick success of the operation were

22     testimonies to the abilities of the VRS and the 1st Krajina Corps.

23             And, as you say, most importantly, however, with the creation of

24     the corridor link from the Krajina, one of the strategic goals was

25     achieved.

Page 18792

 1             JUDGE HARHOFF:  Mr. Brown, I think I have put the question that

 2     I'm going to put to you now already, but I'm going to bring it up again

 3     in order for you to expand a bit on the active role that the RSK MUP took

 4     in this operation.

 5             Do you know if the MUP officers took part in the tactical combat,

 6     as combatants, or did they participate in securing the civilian tasks

 7     that would follow from the completion of the military tactical operation?

 8     Do you know?

 9             THE WITNESS:  Your Honour, I would -- I have to say I've not

10     looked at the role of the RSK MUP in that operation and the detail of

11     what they had done.  I would -- I would have to go back through the

12     documents before I would make a more accurate judgement of that.  My

13     feeling is that they were involved as a formed unit to conduct operations

14     there, but the detail of what that may have meant in terms of whether

15     they were securing an area, processing prisoners, mounting check-points,

16     or whether they were operating as a normal infantry unit, for example,

17     might have operated, I am unclear, but they were a significant component.

18     And I think there are a number of documents showing gratitude by the

19     VRS Main Staff for their involvement.  And, in a way, it doesn't surprise

20     me that they were involved because one of the -- there were a number of

21     reasons why the corridor was important, and I make no bones that the

22     corridor was severed and that put the Krajina in a difficult position

23     because it was severed from other parts, but when Karadzic announced the

24     importance of the corridor, he didn't just say it was because the Krajina

25     is isolated.  He indicated, -- and he put it as the second most important

Page 18793

 1     strategic goal, he indicated that to achieve success in the corridor

 2     allowed all the Serb areas in Bosnia to be united but it also allowed the

 3     Serb areas in Bosnia to be united with the Serb areas in Croatia, and

 4     those two areas to be united with Serbia.  So in essence, it unified all

 5     the areas, and so for that -- for that reason it doesn't surprise me that

 6     the RSK MUP were there.

 7             JUDGE HARHOFF:  Thank you.  We are perfectly aware of the

 8     importance and the significance of this operation.  My question was more

 9     about the actual nature of the tasks that the RSK MUP were able to offer

10     during this operation.  And as you say, the -- either they could have

11     taken part as an infantry unit directly involved in the combat as such,

12     or they could have assisted in providing the civilian functions that

13     would normally follow from any tactical operation.

14             But I think you have made your point clear.  Thank you very much.

15             Back to you, Ms. Korner.

16             MS. KORNER:

17        Q.   If we look at the -- your paragraph 2.215, you refer there to

18     Martic's MUP forces, the RSK, attacking in two areas, the reference for

19     that being a Banja Luka documentary Operation Corridor.  Does that help

20     you at all, or not?

21        A.   Yeah, I would like to read the transcript again to refresh my

22     memory on what the video says.  And whether it's just a one-liner or

23     whether it's more expansive, I don't know, but I guess I would have to

24     review the document to be -- maybe to answer His Honour's question.

25             MS. KORNER:  Well, Your Honours, it -- unfortunately, it wasn't

Page 18794

 1     one of our -- it wasn't on our 65 ter list.  And at that stage I didn't

 2     realise that it was a matter of interest.  But we can actually get ahold

 3     of the transcript of that video and give it to the witness, if there's no

 4     objection, so he could look at it in the next break.  We'll make

 5     arrangements to do that.  Without, obviously, any comment from us or

 6     questions.

 7             Now, Your Honours, sorry, could I ask that this map be admitted

 8     and marked, please.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  Exhibit P1796, Your Honours.

11             MS. KORNER:

12        Q.   And you note in the same paragraph that deals with Martic's MUP

13     forces that there were two stages of the operation, firstly towards

14     Modrica, which they captured by the 29th of June; and then the second,

15     axis towards Derventa by the 4th of July.  And so you point out that a

16     corridor link was actually achieved with the seize of Modrica; is that

17     right?

18        A.   Yes, that's right, Ms. Korner.

19        Q.   So if the operation started -- well, the order is dated the

20     9th of June, and it says the second stage shall be the 11th of June.  So

21     roughly two weeks or so to get through the first stage; is that right?

22        A.   Yes.  Seems only a matter of weeks that they achieved their goal.

23        Q.   And you've already pointed out that it was one of the most

24     important operations, certainly in 1992.

25             I don't want to deal with Operation Vrbas in any detail.  The

Page 18795

 1     last sections of -- oh, well, perhaps I should look at one more, sorry,

 2     one more document on this.  Can we look at directive 2 which is document

 3     number 2644, at tab 33.

 4             MS. KORNER:  Your Honour, while that's being brought up, I'm told

 5     that, contrary to what I thought, it is actually already -- the video is

 6     already an exhibit, the liberation of the corridor, and it's P1293.

 7             I still think probably the easiest way to deal with this is for

 8     Mr. Brown to have a look at it in the break.

 9             This is directive number 2, dated the 22nd of July.  And, again,

10     it's fairly lengthy.  If we look at the last page, it goes out under

11     Mladic's authority, although it's apparently compiled by

12     Major-General Milovanovic.  And if we go back please to the first page in

13     both B/C/S and English, this is dealing with the cease-fire agreement.

14     And it says, in the beginning, the first paragraph:  The initiator, which

15     was the Serbian Republic Presidency, the significant triumphs of our army

16     which, in fact, encircles the whole territory of the Serbian Republic,

17     the Serbian People, and the army have achieved significant military and

18     diplomatic victories at home and abroad.

19             And then directive, under item 1, I suppose 1.1:  We liberated

20     the territory we considered ours, created conditions for political and

21     military leadership.  And then 4:  We have broken through the corridors

22     in Eastern Bosnia and the Bosanska Posavina and thus made possible the

23     centuries' long aspiration of the Serbian People from BiH and the Serbian

24     Republic of Krajina to be joined with the fatherland, Serbia.

25             So, here, the Serbian Republic of Krajina is, as you stated it,

Page 18796

 1     is the RSK, is it?

 2        A.   Yes, I think that's what he's referring to.

 3        Q.   Yeah.  And so he's noting, so that there'll be no doubt about it,

 4     is that right, the fact that this was a success -- the corridor operation

 5     was a successful one?

 6        A.   Yes.

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

 8     then, please.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  P1797, Your Honours.

11             MS. KORNER:  All right.

12        Q.   The remainder of your report, Mr. Brown, I'm not going to

13     highlight anything in particular, simply because of lack of time, but you

14     dealt with the information and communications issues, and the key themes,

15     paragraph 2.228 following it, you dealt with, in the next chapter, at

16     page 157 - and, as I say, I don't think you need turn it up - cooperation

17     with the Federal Republic of Yugoslavia.  I don't think there's any

18     doubt, is there, and I don't think there's any argument that throughout

19     this period of 1992 there was significant cooperation between Serbia and

20     the Bosnian Serb Republic; is that right?

21        A.   Yes, there was cooperation in particular with the army, the

22     requirement to have weapons, ammunition, funding.

23        Q.   All right.  And then you deal thereafter with the roles,

24     responsibility, and authority of the commander, which includes a section

25     on the disciplinary issues, and we've dealt in brief with the

Page 18797

 1     disciplinary side of that, as it affected resubordination.  And finally

 2     the laws and regulations.

 3             MS. KORNER:  And, Your Honour, I make it clear that although I'm

 4     not taking Mr. Brown through it, simply through lack of time, we do rely

 5     on those sections as well.

 6             Mr. Brown, can I now turn, please, to your examination of the

 7     Mladic notebooks, which clearly you had not seen at the time that you

 8     wrote this report because nobody had them at that stage.

 9             Now, I think you point out in the expert report - Your Honour,

10     which we are going to ask to be admitted as well - that you made after

11     you'd looked at the -- sorry -- the various amounts of material which

12     came -- yes, it's the review of the Mladic diaries.  And you set out

13     there clearly the documentation that you looked at, which was not just

14     the diaries but other matters, and those sections which you considered

15     were material and relevant to your -- some of the themes in your report.

16             Can I just ask you this, please:  Can you -- first of all, can

17     you explain what exactly are these notebooks?  I mean, obviously they are

18     compiled by Mladic, but why would a military officer be keeping these

19     sort of notebooks?

20        A.   I believe that the JNA officers or senior JNA officers were

21     required to keep a notebook.  I've seen similar types of notebooks

22     before.  And they are, as they seem to be, bullet points, references,

23     comments, on the activities of General Mladic.  And I'd seen similar kind

24     of diaries before.

25        Q.   Right.  And I want to look, please, if I may, to some of the

Page 18798

 1     references that -- not all of them but some, indeed.  Can we go, please,

 2     to, I think, the 6th of May is the first entry that I want to discuss

 3     with you.

 4             MS. KORNER:  Your Honours, may I also ask that -- as you'll see,

 5     they were all MFI'd at the time, until Mr. Hannis decided which ones

 6     should be asked to be admitted exhibits; he put in a note to the

 7     Trial Chamber, and I wonder if the MFI could be lifted now before we go

 8     any further?

 9                           [Trial Chamber confers]

10             JUDGE HALL:  Ms. Korner, we have seen the report by Mr. Hannis,

11     and it occurs to us that we may have to look at it a little more before

12     we simply lift the MFI status.

13             MS. KORNER: [Microphone not activated] Very well, Your Honour.

14     At the end of today, anyhow, there's a matter I want to raise -- sorry.

15             At the end of today, there's a matter I want to raise in respect

16     of the notebooks, in any event.  But I'll wait until then.

17        Q.   I'm sorry, I said the 6th of May.  Can we just start, just

18     briefly, on the 21st of February of 1992, and can we go, please -- this

19     is -- it's P1753, and can we go to page 42 in English and 44 in B/C/S.

20             I suppose, putting it in context, this is a -- the heading of the

21     21st of February is "Tasks."  And if we look at page 42, people for the

22     Krajina MUP give blue clothing to the MUP, they are asking for tanks,

23     armoured personnel, helicopters.  They can only get armoured combat

24     vehicles which should be repainted, a map of Krajina, map of the Krajina

25     MUP.

Page 18799

 1             Mladic is dealing there with what, the MUP in BiH or the MUP in

 2     the RSK?

 3        A.   I believe it's the RSK.  He was the Knin commander, corps

 4     commander, then.  There are one or two references, I believe, to the JNA

 5     providing men.  I think this extract at the top says provide three people

 6     for the Krajina MUP.

 7        Q.   Yeah.

 8        A.   The JNA is to provide that.  And then I think there are a number

 9     of -- one or two other references about the provision of weapons by the

10     JNA to the MUP there.

11        Q.   Right.  Well, that's what I wanted to -- the next part I want to

12     look at, then.  Could we look at page 43 in English and 45 in B/C/S.  It

13     says:  First stock TO weapons, do that publicly according to the two-key

14     system.  And the second part:  Secretly.

15             Do you know what the two-key system was?

16        A.   I believe it was a process by which weapons would be -- and

17     I forget if it was part of one of the agreements in the early part of

18     1992, one of the agreements to end the conflict in Croatia whereby

19     weapons were to be stored in TO armouries and there was to be a two-key

20     process that if these weapons were required they needed the -- then they

21     could be accessed.  I don't know the full details, and maybe it relates

22     to that.

23        Q.   And, again, this is, again, the RSK, the Croatian Krajina?

24        A.   Yes, yes.  This is in Croatia.

25        Q.   Yes.

Page 18800

 1             MS. KORNER:  Can we now move then, please, as I said, to the 6th

 2     of May.  And that's at page 250 -- P1753 still, 258 in English and 265 in

 3     B/C/S.

 4             Actually, I'm sorry, can we go back to 25 -- I'm so sorry,

 5     I missed one out, 255 first of all, in English.  I'm sorry.  It's the

 6     first entry for the 6th of May.  And so it will be, sorry, page 55 in

 7     English.  Sorry.  Sorry.  255 is the page number in the diary, I'm so

 8     sorry.  It's three pages before 58.  It should be page 55 in English --

 9     oh, no, sorry, 2 -- it's 253 in English, sorry.  Yes, my fault.  And 255

10     in -- no.  That's not right.  All right.  It wasn't on my list.

11             It should, however, say 2 -- page 255 at the top part which is

12     the diary page and 253 at the bottom.  Okay.  All right.  317, please,

13     then.

14             That's it.  Thank you.  And what's it in B/C/S?  259 in B/C/S.

15     Yes, thank you.  Brilliant.

16        Q.   This is the 6th of May, and somebody called General Mandaric is

17     reporting.  First of all, who was General Mandaric; do you know?

18        A.   I'm not sure, Ms. Korner.  I don't know.

19        Q.   No.  All right.  But he goes on, and this is Mladic recording it,

20     that in Bratunac representatives of the SDS are killing all Muslims by

21     slitting their throats.  Two detachments of the Bratunac TO and so on and

22     so forth.

23             And, again, does that show that the army was getting reports of

24     what was happening in these places?

25        A.   Yes.  And this was very much at the period when the JNA was -- or

Page 18801

 1     the status of the JNA in Bosnia had -- was being agreed.  And I believe

 2     also on this day General Mladic met with the senior SDS figures.

 3        Q.   Yes, we're coming on to that now.

 4        A.   Okay.

 5        Q.   Can we look now at what should be page 25 -- 256 in the hopes

 6     that's right.  No.  No.  258.  Okay.  258 in English.  Yes.  Is that --

 7     then we saw talks, at 1920 hours on the 6th of May, with Karadzic,

 8     Krajisnik, Adzic, and a group of generals from BH.

 9        A.   Yes.

10        Q.   And we see there, problems, Chief of Staff, et cetera, insignia

11     uniforms; what are they discussing there?

12        A.   I believe this meeting to be one of the first, maybe the first,

13     meetings on the establishment of the VRS.  And the senior generals from

14     BH are meeting with the senior SDS leadership to discuss the organisation

15     of the VRS.

16        Q.   If we can go, please, to the next page in B/C/S and English, at

17     least I hope it is.  Yeah.  Yes.  And that shows:  We control all

18     corridors except one.  We will soon be one state and one army.  And at

19     the bottom:  Later we will unite with the FRY but we will not annex

20     anything to Serbia.

21             And all of this is being said by Karadzic, is that right, as we

22     saw on the previous page?

23        A.   Yes, it would seem to be that way.

24        Q.   All right.  And then moving to the next page, 261, we are on the

25     threshold of achieving our centuries' old dream of creating our own state

Page 18802

 1     without many internal enemies.

 2             Is that a theme that we saw repeated, in fact, in the actual

 3     assembly six days later?

 4        A.   Yes, and, in fact, I think a similar phrase is used at the

 5     Assembly session.  And there are other references I noted, I believe, a

 6     small number of references to that type of language in the military

 7     documents.

 8        Q.   And then, finally, on this entry, at 262:  We are thinking about

 9     forming our armed forces and TO, we rejected any kind of joint army,

10     there will be no joint Bosnian army, the Israeli Defence system is

11     excellent and to crush the green.  And in English certainly it's put in

12     "/the Muslims".

13             All right.  Can we now move to the following day, the 7th of May.

14     And that is at page 264.  Sorry, I beg your pardon.  Can we start at 263,

15     please, first of all.  Sorry.  We see General Adzic, who was who at that

16     stage?

17        A.   General Adzic was the, in essence, commander of the JNA as it

18     was, but the senior officer in the FRY, military officer, presumably come

19     over from Belgrade.

20        Q.   Right.  And then he talks about the BH army being named as soon

21     as possible and then various other matters raised.  Until we come down to

22     quick mobilisation.  Did that happen, a quick mobilisation?

23        A.   Yes.  I mean, within a few weeks there was the mobilisation

24     instruction passed -- being passed out in relation to the VRS, and a

25     flurry of documents relate to that in the forthcoming weeks after this

Page 18803

 1     meeting.  And, of course, it was referenced as being of importance at the

 2     16th Assembly session.

 3        Q.   Right.  Then next day, 7th of May, if we just can go up the page

 4     a bit.  Then there were talks with the vice-president of the FRY,

 5     Branko Kostic, and Major General Krstic is apparently there as well.

 6             And then if we go to the next page, at 267, thank you.  This is

 7     another meeting, at 1600 hours, and apparently it's Krajisnik, and

 8     I think we can see there he -- the six strategic goals have been set out;

 9     is that right?

10        A.   Yes.

11        Q.   And can we go over the page, please.  Actually, let's go to 269,

12     skip a page.  I don't want to ask you about this one.

13             Now, can you tell us, Mr. Brown, what this appears to be?

14        A.   I would assess that this, bearing in mind the decisions and the

15     discussions beforehand in the meetings we've just looked at, that this

16     is, if you like, a provisional outline of what the VRS is to consist of

17     in relation to the corps and units, and in essence transforming the

18     already-existing or remaining components of the JNA corps into the VRS.

19     So some of the units -- where it says 1st Krajina Corps,

20     2nd Krajina Corps, that's where they assess the army should be located

21     and that it should consist of these corps and that some of these

22     formations, underneath, for example, where it says East Bosna Corps

23     Bijeljina, and says 17th underneath that, was formerly the

24     JNA 17th Corps.  5th underneath 1st Krajina Corps; that was formerly the

25     JNA 5th Corps.  So I think it's an initial sketch, if you like, or layout

Page 18804

 1     of what the VRS was to consist of.

 2        Q.   All right.  It includes at the bottom a little box that says,

 3     "town command."  Now, how many documents or what -- how often does this

 4     particular aspect of the structure seem to appear?

 5        A.   I have not seen the phrase "town command" used regularly.  In

 6     fact, I think this and possibly one other reference in a municipality

 7     Crisis Staff document in Kljuc is the only reference I've had to town

 8     commands, but I assume that or would assess that what's being sketched

 9     out here relates to the former structure of the district TO.  I think

10     I mentioned that a little bit a couple of days ago, that in the TO

11     structure, there were district TO commands, and the TO was separate to

12     the JNA, and there was -- which was based on republican level command.

13     So there was a republic-level TO, there was a district-level TO, and

14     beneath that were TOs linked to municipalities.  And there were

15     National Defence at municipalities.  And I look at that maybe in relation

16     to Mladic saying, "We need to absorb or take control or integrate the

17     former TO structure into the new VRS."

18             But in relation to the phrase "town command," I think this and

19     one other is the only reference.  There may have been some references,

20     I think, possibly - it's not something I've looked at in great detail for

21     sometime - but the All People's Defence may have references to town

22     commands.  But in relation to the documents, I haven't seen that used.

23        Q.   All right.  Yes, thank you.  That's all I want to ask about that

24     entry.

25             MS. KORNER:  Can we go now, please, to the 2nd of June entry,

Page 18805

 1     P1755, page 52, please, to start with.  Page 52.  The next page.  Yes.

 2     Thank you.

 3        Q.   This is a meeting in Banja Luka on the 2nd of June with the

 4     leaderships of Banja Luka, Bosnian Krajina, the SRK, and the unit

 5     commanders of the 1st Krajina Corps.  And Karadzic is speaking.  And can

 6     we go to the next page, which is 53.  He talks about that they ought not

 7     to proclaim linking up because it would give Tudjman a pretext to throw

 8     out the UN.  And then Radislav Brdjanin speaks, and he says, at the

 9     bottom of that page, "We have said we are in favour of everything being

10     under the command of the army and for the dissolution of all paramilitary

11     organisations."

12             Can we go to the next page, please, in English.  And then

13     General Mladic to agree tacitly, with either M or with Torb, the enemy be

14     kept as busy as possible.  The problem of the Krajina, 14,500 Muslims.

15     And then finally on that, can we go to the next page in English, 55.  And

16     it will also be 55, I think, in B/C/S.  One uniform, one insignia, about

17     prisoners and refugees, a position, please, at the highest level.

18             Were these discussions with -- between the military and the

19     political figures, if you like, the civilian, a feature of these work

20     books?

21        A.   Yes, they appear to be.  There were a lot of references of Mladic

22     meeting, actually down to quite a lowish level, down at municipality or

23     in this case at the regional level, and they do seem -- he does seem to

24     have got about, if that's a phrase, and here we have one in Banja Luka,

25     and they are obviously discussing significant issues.  The corridor crops

Page 18806

 1     up at this meeting.  I assume that the Martic reference is Milan Martic

 2     from the RSK, so they're discussing the unity between the RSK and Bosnia.

 3     And there's differences about whether unifying publicly would be a good

 4     thing or not.  I think in this meeting there's also a reference by

 5     Mr. Brdjanin about Crisis Staffs, everything's being done at Crisis Staff

 6     level because that's how it works.  Here there is a clearly a question

 7     about prisoners and refugees, and they want to know what they should do

 8     with them.

 9        Q.   Yes.  Thank you.  Can we move then, please, to the 9th of June.

10     As I say, I'm missing out a number of entries on which you have

11     commented, but that's all in your report.  Which we'll find, it's the

12     same P1755, and it's at page 121.  The 9th of June meeting of the

13     Presidency, and we see Karadzic, Koljevic, Plavsic, Krajisnik, Deric,

14     Mladic, Gvero, Tolimir, and the minute taker.  Meeting begins:  I briefed

15     the state and political leadership about the situation at the front.

16             So we don't often see this, but is it -- when it says "I," that's

17     him talking, is it?

18        A.   It would appear so, yes.

19        Q.   And then, please, over the page to -- well, actually two pages,

20     123.  Combat reports are to be forwarded to the president of the

21     Presidency in person, coded.

22             Are we talking there about combat reports from the Main Staff or

23     from the 1st Krajina Corps or from all the corps?  Do you know?

24        A.   I couldn't say from this reference.  I am -- I have not looked at

25     the Main Staff as a functioning organisation, and I don't know if they

Page 18807

 1     compiled their own combat reports based on the individual corps, or

 2     whether, to save time, they simply forwarded on combat reports from the

 3     various corps.  So I can't comment.

 4        Q.   All right.

 5        A.   But I would add that it clearly indicates that issues of a

 6     military nature are to be briefed in at the highest level.

 7        Q.   Yeah.  And then under the -- near the bottom of that, provide the

 8     army of the Serbian Republic with instructions on how to proceed with

 9     POs.  And this is -- I mean, this apparently appears to be Krajisnik

10     speaking, from the previous page.  So that's suggesting it was the

11     civilians who would be providing the army with -- the political

12     leadership, sorry, providing the army?

13        A.   I may not necessarily read it that way.  I would maybe -- if it

14     is Krajisnik saying that, or whoever is saying that.

15        Q.   Yes, sorry.  Just stop for a moment, I'm sorry, Mr. Brown.  My

16     fault.  Perhaps we could go back to the previous page, which is 122, so

17     that we can see it's Krajisnik.

18        A.   Maybe what he's saying is to the army, You are to write

19     regulations on the issue of prisoners of war, rather than the nuanced

20     where you said it.  There was a regulation subsequently passed, I

21     believe, in relation to that.

22        Q.   All right.  Can we look, then, please, at a meeting on the

23     10th of June, which is at page 127.  This one's at the Villa Bosanska in

24     Belgrade on the 10th of June, and it's a meeting with the representatives

25     of the Serbian People from BiH.  And if we go to 129, please, we see

Page 18808

 1     Karadzic begin to speak.  Is that -- above there is Miodrag Perisic; is

 2     that General Perisic?

 3        A.   I don't know, Ms. Korner.

 4        Q.   All right.  Thank you.  Karadzic begins speaking.  And if we go

 5     over the page to 130, Karadzic appears to be discussing the situation and

 6     says:  We have full control of many of our territories, we feel

 7     revealed -- sorry - revealed - we feel relieved now that we have formed

 8     our army and 40 per cent of the economy of BH and Sarajevo and the

 9     strategic goals.

10             So does it look as though Karadzic at this meeting is restating

11     the goals of the Serbian People in Bosnia?

12        A.   I would suspect so, yes.

13        Q.   Yes, can we move, then, please, to the 21st of June, I think it

14     is, yes.  Yeah, can we look at page 18 -- well, first 185 so we see where

15     we are.  This appears to be a meeting he's holding with the East Bosnia

16     Corps, does it?

17        A.   Yes.

18        Q.   And if we go over the page, just so we can see who's speaking, at

19     186, we see somebody called Racic, Miroslav.  Do you know who he was?

20        A.   No, I don't, Ms. Korner.

21        Q.   All right.  Transformation of the TO into the RSK is slow.  It is

22     carried out through the MUP which cooperates with the corps intelligence

23     officers and Lieutenant-Colonel Sajic, who is still the commander of the

24     Krajina TO, and does not intend to be under Talic's command.

25             Lieutenant-Colonel Sajic, I think we've seen in various

Page 18809

 1     documents, we're talking here about the Autonomous Region of Krajina and

 2     not the RSK; is that right?

 3        A.   Yes, it would seem so.

 4        Q.   Yeah.  And then the next page.  Nenad Stevandic, on 21st of June,

 5     political commissar of the SOS, says that Karadzic and Mladic are

 6     traitors to the Serbian People.  We only think of Sarajevo and

 7     Herzegovina.  He was an operative of the SDS, the chief of security, of

 8     the Krajina MUP, with Nedjeljko Kesic behind -- is behind him, and the

 9     SOS serves for settling scores with Serbs who are not sufficiently good.

10             And does this link in with the later report that we looked at,

11     again this morning, of General Tolimir -- [Overlapping speakers] ...

12             JUDGE HARHOFF:  Ms. Korner, we are just wondering what the

13     purpose of your examination is just now.  These parts of the diaries are

14     in evidence.  It doesn't seem to us that the witness is contributing much

15     other than confirming that this is what it says.  So if you have nothing

16     else to -- wish to add to this, then I think we should perhaps round up.

17             MS. KORNER:  Your Honours, I'm perfectly content in the sense

18     that he, in the extra report that I'm going to ask to go -- to be

19     admitted, he explains which entries support the themes that he's

20     developed through his report.  He doesn't, however, identify -- I mean,

21     it simply gives the dates.  But the specific entries are not.  So if

22     Your Honours are happy that I don't go into the specific part of what is

23     sometimes long entries with him, well, then, I won't do it, with one

24     exception.

25             JUDGE HARHOFF:  I don't think we need this.  Thank you.

Page 18810

 1             MS. KORNER:  All right.  Can I, however, just one last entry,

 2     Your Honours, if I may.  And that's for May 1993, which is P1767, at

 3     page 151.  It's 4 of the English.  Yes.  To put it in context, there's a

 4     meeting in Banja Luka on 27th of May, 1993, and Colonel Bogojevic is

 5     speaking.

 6             Can you just remind us who Colonel Bogojevic was.

 7        A.   I believe he was a security officer of the corps,

 8     1st Krajina Corps.

 9        Q.   All right.  And he's talking about Simo Drljaca arriving, being

10     the former chief of the Prijedor SUP.  And can we go to the next page,

11     please.  He talks about earlier they buried around 5.000 bodies.  And I'm

12     sure that the world knows about these released prisoners.  Drljaca came

13     to leave this with us, and they want to get rid of it by burning,

14     grinding, or some other way.  There are all kinds of bodies.  They've

15     involved Subotic in this.  The team includes Drljaca.  He was in charge,

16     even while this was being done, at the meeting where General Subotic;

17     Arsic; Drljaca; me, that's Colonel Bogojevic, presumably; and

18     Mile Matovic from the Banja Luka secretary SUP.  I ask for your position.

19     My position, they killed them so they should get rid of them.  An

20     investigation must be launched in connection with this case and the

21     information retained well to prevent it getting into the hands of

22     unauthorised people.

23             Who's saying that?  They killed them so they should get rid of

24     them.  Do you know?

25        A.   I -- I can't be sure.  It's either General Mladic himself, which

Page 18811

 1     I think is probably most likely, as he seems to asterisk his own phrases,

 2     or it's the position of the security officer, Bogojevic.  But I can't say

 3     for sure.  But if I had to put one, I believe it's probably

 4     General Mladic.

 5        Q.   Yes.  Yes, thank you very much, Mr. Brown.  Then in light of the

 6     Trial Chamber's indication, that's all I'm going to ask you.

 7                           [Trial Chamber confers]

 8             JUDGE HARHOFF:  It's just time for the break and there is another

 9     couple of minutes, but before we transfer the floor to the Defence,

10     I would like to ask you one question, Mr. Brown.  And the question

11     concerns the comment that you have added a couple of times during the

12     testimony here, namely that the army apparently deplored the

13     counter-productive treatment by the MUP and by paramilitaries against

14     Muslim and Croat civilians in Bosnia in 1992.  Do you remember that you

15     have commented on this aspect?

16             THE WITNESS:  Yes, Your Honour, there were a number of references

17     to that effect.

18             JUDGE HARHOFF:  Yes.  My question to you is:  How do you

19     interpret these indications by the army?  And more specifically:  Do you

20     consider this as an expression of frustration with the army, that they

21     are unable to do anything about it, they are unable to get through to the

22     political leadership and to have the political leadership take some

23     action on it; or on the other hand, do you see it as an indication by the

24     army that, well, this is deplorable but it's part of the war and in the

25     end it may also serve some purpose so we are not going to do anything

Page 18812

 1     about it?  Which of these two interpretations would you offer, or any --

 2     if you have a third interpretation, of these indications from the army?

 3     It's important for the Chamber to understand fully how you as a military

 4     expert view and assess these indications by the army.

 5             THE WITNESS:  The references that I do see are often linked to --

 6     or are often -- there are a number of comments that this type of activity

 7     is going to cause problems for the military in that it acts as a

 8     recruiting drive for others who may come subsequently to confront the

 9     VRS.  I think the Prijedor is one, I think there are another maybe one or

10     two other references.  So one of the components that I think the army are

11     unhappy with is not -- is not the obvious one that this is outrageous

12     behaviour that shouldn't be tolerated in a state that we are building;

13     they almost caveat it with the fact that this type of activity, the

14     fallout, is going to be on us, because we are going to have to fight

15     people who are -- who have been -- who have heard about these or who have

16     been moved out the territory and it will act as a recruiting sergeant for

17     them.  That's one area.

18             Some of the other comments, I believe, are that, say, for

19     example, in relation to looting or burning, is that they're not

20     necessarily solely discriminatory in terms of Muslims and Croats, that

21     there are some Serbs or others who are -- who are being victimised too.

22     So that is one area.

23             And then I think, generally, I see a lot of this through the

24     optics of command.  The military wants to be able to conduct operations

25     without the distraction of this type of activity coming.  In a way - it

Page 18813

 1     maybe getting back to the issue I pointed out before - the lack of really

 2     clear sympathy about -- you know, here you have, if you like, an

 3     organisation, the VRS I'm talking about, many of the staff officers who

 4     were professional military officers, the lack of sympathy for what is

 5     clearly going on seems to me very, very stark.  And so I don't see it as

 6     the military saying, well this problem is so out of control, we are

 7     simply not able to deal with it, even -- we have the utmost sympathy for

 8     the Muslims and Croats, but we can't do anything.  I don't see that at

 9     all.  I think there's quite an overwhelming feeling that they know they

10     have these -- this territory to control, they have a direction that's

11     been given to them, that territory has been marked out, the language in

12     other documents make it clear that the non-Serb population are a threat

13     and will continue to be so if they stay in the territory, and they're

14     happy to follow that.  And that -- that's how I view much of the

15     documentation.  This lack of sympathy, this lack of balance in the

16     military documents, I think, is very stark.

17             JUDGE HARHOFF:  Thank you.

18             MS. KORNER:  Your Honour, we've got a copy, if we can give it to

19     Mr. Brown, as he's got -- of the transcript of the video on

20     Operation Corridor.

21             JUDGE HARHOFF:  Yes.

22             JUDGE HALL:  So we take the break now, to resume in 20 minutes.

23                           --- Recess taken at 12.08 p.m.

24                           --- On resuming at 12.40 p.m.

25             JUDGE HALL:  While the witness is on his way back, Ms. Korner

Page 18814

 1     had -- I don't know if "applied" is the correct word, but they had

 2     referred to the matter that is still live, about lifting the MFI status

 3     of the four items in the basket that's the notebooks, where there were

 4     these discrepancies between the versions that had been tendered or laid

 5     over.  And the -- we assume that the Defence has seen the Prosecution's

 6     notice and report of the 10th of January of this year, and before we

 7     formalise what we will say about the status of these exhibits, in light

 8     of the notice, we think it would be useful if we -- if the Defence, if

 9     they care to, have any observations about these apparent discrepancies.

10     And if we could hear from them first thing tomorrow morning, we would

11     rule by tomorrow -- we will rule tomorrow on the final status of these

12     four items.

13             MR. ZECEVIC:  Thank you, Your Honours.  We will give our

14     observations tomorrow morning.  Thank you.

15             JUDGE HALL:  You had a question, Ms. Korner?

16             MS. KORNER:  Yes, is Your Honour -- are Your Honours inviting the

17     Defence to reopen their argument on discrepancies and admission?

18             JUDGE HALL:  I was hoping I wasn't.  That is why I tried to

19     choose my words carefully.  There is -- there was -- the process of this

20     matter is there was the application, the Defence responded, we ruled, and

21     the -- we thought that it would have -- once the necessary comparisons

22     were made, it would have been a fairly straightforward exercise, but it

23     appears, especially in relation to two of the entries, there is a

24     question that may be raised, and we just wanted to have the benefit of

25     any observations that the Defence may wish to make.  And I emphasise that

Page 18815

 1     inasmuch as what the Prosecution tendered on the 10th of January is

 2     merely a notice at the request of the Chamber, in other words, it isn't a

 3     motion on which we are requesting their response, but because of what is

 4     on the face of the notice itself, we just would find it useful if the

 5     Defence, if they wish, first thing tomorrow morning, indicated any

 6     observations that they have.

 7             MS. KORNER:  Yes.  Well, Your Honour, as I said, at the end of

 8     today I want to mention something that has a bearing on the notebooks,

 9     and I maybe come back to it at that stage.

10             Your Honours, I had actually completed my examination-in-chief,

11     but Mr. Brown had a look at the transcript of the corridor video over the

12     break and I don't know whether Your Honour or Mr. Brown feels there's

13     anything useful he can add to Your Honours -- Judge Harhoff's questions.

14             JUDGE HARHOFF:  Go ahead.

15             THE WITNESS:  I very briefly looked at it, Your Honour, and there

16     just seems to be a statement from Martic that his troops have been

17     involved and that they've suffered some casualties, but it doesn't go

18     into any great detail about their exact role and what they've been doing

19     there.  I would have to probably look, as well, any other military

20     documents that may have a bearing on that, but not from that video

21     extract.

22             JUDGE HARHOFF:  Suggesting that some parts of the police somehow

23     were involved in direct combat activity?

24             THE WITNESS:  Well, he does make reference to the fact he's had

25     casualties and that they're going to continue on and that they're not

Page 18816

 1     going to be distracted by -- from that.  It would seem that they've been

 2     involved in combat activities, although obviously casualties can occur in

 3     a number of ways.

 4             JUDGE HARHOFF:  Thank you.

 5             JUDGE HALL:  Mr. Zecevic.

 6             MR. ZECEVIC:  Thank you, Your Honour.

 7                           Cross-examination by Mr. Zecevic:

 8        Q.   [Interpretation] Good afternoon, Mr. Brown.

 9        A.   Good afternoon, sir.

10        Q.   I'm going to start my cross-examination by asking about your

11     qualifications.  During the examination conducted by my learned friend

12     Ms. Korner we saw that there were some matters that might necessitate our

13     going into private session.  If your reply should make that necessary,

14     please indicate that to me.  Do you understand?

15        A.   I do, sir, yes.

16        Q.   Thank you.  Sir, you have some academic titles from two areas,

17     that is, modern history and criminology; is that correct?

18        A.   Yes, sir, that's correct.

19        Q.   You acquired specific military knowledge during the course you

20     attended at Sandhurst academy; is that correct?

21        A.   Well, that was one component.  I was a commissioned officer and

22     spent time at the military academy, but obviously my specific military

23     knowledge is not just from that course but my service as a military

24     officer.

25        Q.   When I said "military knowledge," I was referring to theoretical

Page 18817

 1     knowledge.

 2        A.   Well, part of the military academy does deal with various

 3     components of military knowledge, and I did other staff courses whilst

 4     I was a serving officer so -- which, again, has both a theoretical

 5     component and a practical component.  And then obviously there was my

 6     experience in operational situations when I was serving as an officer.

 7        Q.   Tell me, sir, the course at Sandhurst military academy has a

 8     duration of 44 weeks, I believe; is that correct?

 9        A.   That may be the case now, yes.  I'm not sure exactly what it is

10     today, but it was just under a year when I did it.

11        Q.   I'm asking you this because in our country, as in some other

12     countries, military academies have a four-year curriculum such as in the

13     United States, for example, at West Point.  But that seems not to be the

14     case in the British army, or is it?

15        A.   The specific officer training is not a four-year course.  Most

16     officers nowadays are graduates who will have done some kind of graduate

17     course prior to that.  Officers in the American army can also go in and

18     join the service not solely through West Point, which is a long course.

19     They can go in through other avenues.  But in relation to the military --

20     British military, it's that length of course.

21        Q.   Thank you.  If I understood your CV correctly, then you served in

22     active duty in Northern Ireland; then in the Middle East, during

23     Desert Storm; and finally in Bosnia-Herzegovina.  Correct?

24        A.   Yes, I don't know if this is worth -- if you're going to expand

25     on that, whether this might be appropriate for a private session.  I'm

Page 18818

 1     not sure, sir.

 2        Q.   Yes.  Well, to be on the safe side, I would like us to move into

 3     private session.

 4             JUDGE HALL:  So we go into private session.

 5                           [Private session]

 6   (redacted)

 7   (redacted)

 8   (redacted)

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10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

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Page 18819











11 Pages 18819-18821 redacted. Private session.















Page 18822

 1   (redacted)

 2   (redacted)

 3   (redacted)

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16                           [Open session]

17             MR. ZECEVIC: [Interpretation] Sir --

18             I apologise.

19             THE REGISTRAR:  We are in open session.

20             MR. ZECEVIC: [Interpretation]

21        Q.   After your tours of duty in Northern Ireland, the Middle East,

22     and Bosnia-Herzegovina, you found employment at the OTP of this Tribunal

23     and you held the position of a military analyst; is that correct?

24        A.   That's correct, sir, yes.

25        Q.   And during your employment with the OTP, you were actively

Page 18823

 1     involved in the investigations conducted by the Prosecutor's Office; is

 2     that correct?

 3        A.   Yes, that is correct, sir, yes.

 4        Q.   In that sense, you took part in interviews and statement-taking

 5     from a number of witnesses; is that correct?

 6        A.   From a number, yes, I did, sir, yes, as part of - I hasten to

 7     say - a joint team, usually with a lawyer and a senior investigator.

 8        Q.   But in a number of cases it was you who directly posed questions

 9     to either witnesses or other type of interviewees; is that correct?

10        A.   That's correct, sir.  And I believe probably in a small number of

11     cases, I did, yes, under the assistance of a senior legal representative,

12     though.

13        Q.   It is a fact that you participated in interviewing and witness

14     statement-taking from witnesses pertaining or relating to this particular

15     case; is that correct?

16        A.   Well, I'm not sure what you mean by "this particular case."

17     I was asked to assist in the interview of a number of individuals from

18     the Krajina area, but whether it was related to this particular case,

19     I'm -- as you phrase it, I'm not quite sure.  I was asked to assist in

20     that process.

21             MR. ZECEVIC: [Interpretation] Can we go briefly into private

22     session for the benefit of refreshing the memory of this witness.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 18824











11 Pages 18824-18826 redacted. Private session.















Page 18827

 1                           [Open session]

 2             THE REGISTRAR:  We are in open session, Your Honours.

 3             MR. ZECEVIC: [Interpretation]

 4        Q.   If I understood you correctly, the investigating team would ask

 5     you to deal and analyse certain matters that they thought was of interest

 6     for their work; is that correct?

 7        A.   Invariably it didn't really work like that.  It tended to be

 8     I was set a task, in this case, to look at a series of documents.  A lot

 9     of the material that the military analysis team worked on was

10     documentary.  I was asked to look at what the material said in its very

11     general terms, and I would get material translated, I would

12     systematically collate material, and I would review it.  And it tended to

13     be more the passage of information down to the investigation teams or to

14     the legal teams, as the case was.

15             It may have been, on occasion, an investigator would come and

16     say, "Can you tell me are there any documents in relation to this, this,

17     or this?"  But for the purposes of my report, for example, which actually

18     ended up being a significant component of my work, that was done through

19     myself or my manager -- the team leader of the analysis team.

20        Q.   Let us please be concise in your answers so as not to waste time.

21     Now, if an investigator or a counsel for the Prosecution is, for example,

22     specifically interested, as we heard today, in the role of the RSK police

23     in the Corridor Operation; in that case, they would approach you and ask

24     you to furnish them with the document and to establish whether that is a

25     fact and to provide corroborating documents confirming the fact; is that

Page 18828

 1     correct?

 2        A.   They could do, through the team leader.  He would clearly need to

 3     know about the tasks that were being set his analysts.  So there were

 4     regular management meetings at which if that was a specific task, an

 5     analytical task, please provide me an analysis of what you believe to be

 6     the involvement of the RSK MUP in operations.  That might be set as a

 7     task to the team manager, and he would allocate that to an analyst for

 8     him to work on over a protracted period of time.

 9             There may also be a request to say, "That combat report which you

10     flagged up to me, is there anything else that would -- that are similar

11     to that around that period?"  But it tended to be -- most of the tasks

12     set to the military analysts were longish-term analysis, for example, my

13     report and similar reports that were being written by other analysts.

14     After all, the investigators normally were able to access material,

15     documentary material, that we were too.

16        Q.   That's quite clear to me.  However, it was them who suggested to

17     you which specific matters you are required to analyse for their

18     purposes; is that correct?

19        A.   Yes.  Although I would have to say there were also times, for

20     example, when I started reviewing the material in the Krajina Corps, I

21     believe the suggestion to write -- to write the report was -- was done

22     generally through a management team when it became clear that this

23     material was useful.  But the investigators had the opportunity to come

24     and speak to analysts and ask certain questions of them and, you know,

25     know if they highlighted particular documents or materials.

Page 18829

 1        Q.   Let us focus only on this document that you produced on the

 2     27th of November, 2002, and it is entitled, "The analysis of the

 3     situation."  You prepared this analysis on the basis of the request for

 4     such an analysis to be carried out and conducted; is that correct?

 5        A.   That is correct, yes.

 6        Q.   And after you had finished the analysis, you sent it to the party

 7     that had requested it - whether it was an investigation team or a team

 8     conducting certain cases, it doesn't matter - at any rate, that analysis

 9     was passed on to them?

10        A.   Yes, it was.  I mean, there was a process before it was

11     disseminated out to others, a peer review process, internally, within the

12     team, and it was reviewed by my manager.  And then once that happened, it

13     was disseminated to -- to the team that had -- was interested in it, and

14     more widely, I have to say, within the OTP.

15        Q.   And surely, after this initial analysis has been discussed at

16     length within the analytical team and it was thereafter sent to the

17     requesting party, the requesting party would come back to you with some

18     feedback in terms of additional requests or additional clarifications and

19     things of that nature; is that correct?

20        A.   Yes.  I believe there were some discussion after the report was

21     produced.  I'm not sure that there was too much of a request or too many

22     requests, after I had completed it, to -- to clarify or add in anything.

23     I don't really remember too much of that.  But, yes, there were meetings

24     after the report had been finished about whether -- you know, its

25     content.  I was not asked to change anything after that -- it was

Page 18830

 1     published, I hasten to add.

 2        Q.   Well, that's perfectly clear.  Once it's been published and

 3     distributed to the Defence teams, there was no reason whatsoever for any

 4     alterations to be made in the document because, as you said, during these

 5     meetings within the OTP, its content had been finalised; is that correct?

 6        A.   Yeah, I think that's true.  I'd accept that.

 7        Q.   On page 18632 of the transcript, you confirmed that this report

 8     is based exclusively on the documents that is in the possession of the

 9     OTP.  And the day before yesterday, you confirmed that this primarily

10     refers to the documents popularly known as the 1st Krajina Corps document

11     collection.

12        A.   Yes.  It is predominantly from military documents of that corps.

13     There are one or two -- there are a few, quite a few, documents which are

14     not from that collection, but it's predominantly from that corps

15     collection.

16        Q.   When you previously agreed with me that this document was first

17     finalised within the OTP before its being published and disseminated to

18     the Defence teams, you would agree with me, wouldn't you, that that has a

19     considerable impact on the impartiality of this report; is that correct?

20        A.   I don't think I would agree with you there, sir, at all.  The

21     report, when it was written initially, at least from my perspective, was

22     not one that was destined for court use.  It was a document that I'd been

23     asked to look at these -- this collection and compile a report on what I

24     believed to be some of the salient issues that came from it.  How the

25     Prosecution decided to use it was up to them.  But I wouldn't agree with

Page 18831

 1     you that it necessarily has a -- or necessarily has an impact on its

 2     impartiality.  There are limitations to the report, undoubtedly, and I'm

 3     very open to say that there are limitations.  It is a document

 4     collection, for one, document-heavy report.  It's predominantly from, as

 5     you said, from the documents of the 1st Krajina Corps.  That has a

 6     limitation.  It's limited in terms of its time.  It looked at areas from

 7     round about late 1991 and end of 1992, predominantly.  It has limitations

 8     in that I don't speak B/C/S, so I'm relying very heavily on the

 9     translations.  So there are limitations to the report, and I'm happy to

10     accept those.  But I don't necessarily agree with you at all that the way

11     that it was compiled or given to the Defence teams somehow impacts on its

12     impartiality.

13        Q.   Very well.  We'll get back to this when we come to specific --

14             JUDGE HALL:  Mr. Brown, in the first part of your answer, you

15     said that the report was, as it was written initially, you didn't

16     consider that it was destined for court use.  You prepared it at the

17     request of the Prosecution and it was up to them to make such use of it

18     as they did.  Had you anticipated that it would be quote/unquote, "for

19     court use," would anything have changed, either in the way you -- either

20     in the analysis itself or in the way that you presented the analysis?

21             THE WITNESS:  Not at all, sir.

22             JUDGE HALL:  Thank you.

23             THE WITNESS:  My training in the military and the reports I've

24     had to write there, to military commanders, reports I've written in the

25     past, you know, I hope that they stand for what they are.  Whether they

Page 18832

 1     were going to be used in court or not, this report, I believe, was one of

 2     the early reports that was really written in the team, large reports,

 3     that is.  And I didn't necessarily think it was going to be used in court

 4     or not, and -- but that wouldn't have affected the way I had written it

 5     at all, sir.  You know, I stand by what I wrote at the time and to the

 6     best of my ability compiled a report that I thought reflected what the

 7     corps documents said.

 8             JUDGE HALL:  Thank you, sir.

 9             Yes, Mr. Zecevic.

10             MR. ZECEVIC:  Thank you, Your Honour.

11        Q.   [Interpretation] I said we would go back to this matter when we

12     come to comment specific parts of your report.  But it's a fact that the

13     report has three parts, the political-military situation, military

14     operations, and the role and the powers of the corps commanders; is that

15     correct?

16        A.   That's correct, sir, yes.

17        Q.   I hope you will agree with me when I say that a familiarity with

18     the military tradition and the military doctrine, as well as the rulings

19     and regulations upon which the organisation structures of the armed

20     forces, is something one must know in order to compile such a report

21     and/or understand it.

22        A.   By that do you mean you have to have been in the VRS or the JNA

23     to understand that?  Is that your position?  Is that the question?  When

24     you say "familiarity," does that mean you have to have been in that

25     organisation?  I'm a little bit unclear on the question.

Page 18833

 1        Q.   I apologise.  I may not have been clear enough.  I'll try to

 2     phrase it differently.

 3             If I, for example, should want to write an analysis about

 4     something in the British army, and supposing that I had the

 5     qualifications that I don't have, for me to be able to do that, I would

 6     certainly have to be familiar with the basic rules and regulations in

 7     force in the British military, such as the law on the armed forces, I

 8     believe it's called the NSS, namely the National Security Strategy, and

 9     some other documents; am I right?

10        A.   Well, I guess it depends on what the purpose of your analysis is.

11     If your analysis is to look on the law of the army, then, you know, if

12     you're a researcher or a talented researcher there's no reason why you

13     can't, you know, do work that would be -- that would be -- would stand up

14     to peer review in that area.  I guess it all relates to your skills as a

15     researcher.  And clearly, a familiarity, for example, my own experience

16     in the military -- British military, would stand me in some stead if I

17     had to write about certain aspects of the British military; that might be

18     greater than someone who had not searched in the British military.

19        Q.   Sir, I'll try for the third time.  If I wanted to write an

20     analysis of the military operations of the British army, such as carried

21     out in a certain time period, I would have to be familiar with the Law on

22     the Army, study it thoroughly, then the rules of service in the British

23     army, its strategy, its tactics, and so on; isn't that correct?

24        A.   Well, not necessarily.  If your analysis of operations in a

25     particular zone were limited, then your report would be limited.  You

Page 18834

 1     don't have to know every single issue related to the British army.  If it

 2     was to do with the Law on the Army, legal issues, then clearly you would

 3     have to know.  I guess it depends on what the definition of your task is.

 4     It's a somewhat rather large -- an analysis of military operations of the

 5     British army; it's a rather large topic.  Maybe what I'm saying is it

 6     depends on what you've been asked to do.

 7        Q.   I'm proceeding by the sections into which you divide your

 8     analysis.  Section 2 is entitled, "Military Operations of the

 9     1st Krajina Corps in 1992."  Section 3 is called, "Roles,

10     Responsibilities, and Authorities of the Commander of the Corps."  Are

11     you trying to say that even for this third section it is not a must to

12     know the rules of service as well as the other rules and regulations in

13     force and pertaining to the roles, responsibilities, and authorities of

14     corps commanders?  Is that what you're trying to say to me?

15        A.   No, I'm saying that that section of the report was in there as

16     the documents in the corps collection reflected.  Of course it was -- it

17     is of value to know about the law of the army or doctrinal issues and it

18     does help, but your question seemed to be somewhat general.  I'm saying,

19     if you have to conduct an analysis or research, what goes in depends on

20     what the task that has been set is, it would seem to me.

21        Q.   All right.  Let's simplify things.  In your opinion, to carry out

22     the task that you were assigned within the OTP, namely the drafting of

23     this analysis of the situation in 1992, which is divided into three

24     sections, namely political military developments, military operations,

25     and rules, responsibilities, and authorities, do you think that to carry

Page 18835

 1     out this task it is necessary for you to have analysed and familiarised

 2     yourself with the military tradition, rules and regulations in force in

 3     the JNA, rules in force for combat operations, strategy and tactics of

 4     the former JNA?  Is that necessary to accomplish such a task or not?

 5        A.   Well, I analysed the materials I was able to get from the

 6     1st Krajina Corps on those topics.  Are you asking me am I an expert in

 7     every issue relating to the JNA and its traditions, rules, and

 8     regulations, the answer would be, not necessarily, no.

 9        Q.   I'm asking you this, Mr. Brown, because I noticed, in the entire

10     document which is about 200 pages long, at least in the Serbian version,

11     that very rarely, if at all, you refer to any rules of engagement or any

12     regulations to explain an event or an activity carried out by the

13     1st Krajina Corps or its subordinate units.

14             Do you agree with what I've put to you?

15        A.   I'm not sure I do agree with you, actually.  I think there are

16     references explaining an event or activity by the 1st Krajina Corps.

17     They themselves make a lot of references to that.  And there are

18     references in the report to doctrinal issues.  I haven't seen,

19     specifically, a document that discusses what I would know to be rules of

20     engagement, which are a very specific military regulation, I guess.  But

21     there are documents in here that talk about wider regulations.  There are

22     documents that were in the collection that talked about doctrinal issues.

23     For example, provisional Law on the Army and others.

24             So I wouldn't agree with you, I think, in your question.

25        Q.   While you were drafting this analysis of yours, did you rely on

Page 18836

 1     or read the corps rule of the JNA, which is a kind of combat rule?

 2        A.   I read the regulations.  I'd have to refresh my memory.  I

 3     believe there was a 4th Corps regulation, a provisional regulation, from

 4     late 1991 which I believe I read.  I think it's referenced, but I would

 5     have to look at it again.

 6        Q.   Did you use in your analysis, or do you refer to, the rules of

 7     service in the JNA or the armed forces of the former SFRY?

 8        A.   I'm not sure I did.  I'd have to check my references again,

 9     though, to be sure.

10        Q.   While drafting this analysis, did you use the law on All People's

11     Defence and social self-protection of the former SFRY?

12        A.   I believe I referenced it.  I maybe didn't footnote it, but

13     I think I have referenced it.  You're talking about the Law on All

14     People's Defence, sir?  I believe I referenced it in the report.

15        Q.   While you were drafting this report, did you use an additional

16     document, the name of which I'm going to quote now:  "The Strategy of All

17     People's Defence and Social Self-Protection of the SFRY from 1987"?

18        A.   No, I don't think I believe that I used that document or reviewed

19     it, sir.

20             MR. ZECEVIC:  Your Honours, I remember that Ms. Korner was asking

21     for two minutes before we break, and I think this is a proper place where

22     I could break and continue tomorrow.  Thank you.

23             JUDGE HALL:  Thank you, Mr. Zecevic.

24             Yes, Ms. Korner.

25             MR. ZECEVIC:  Thank you, Mr. Brown.

Page 18837

 1             MS. KORNER:  Your Honour, we needn't trouble the witness.  The

 2     witness can leave.

 3             JUDGE HALL:  Yes, Mr. Brown, you are excused, to continue

 4     tomorrow morning.  The usher will escort you from the courtroom.

 5             THE WITNESS:  Thank you, sir.

 6                           [The witness stands down]

 7             JUDGE HALL:  Yes, Ms. Korner.

 8             MS. KORNER:  Your Honours, the matter is this:  In the

 9     Seselj Trial Chamber, publicly announced was the report that the

10     Seselj Trial Chamber sought on handwriting in respect of the Mladic

11     notebooks.  Your Honours, the situation is this:  Your Honours declined

12     to let us call surrounding evidence as to the authenticity, for example,

13     from the investigator who took the books and the like.  And we're

14     assuming that therefore, and indeed you've ruled, that you're satisfied

15     the Mladic notebooks are authentic.  But we feel it right, so that it's

16     on the record, to say particularly in the light of your -- the invitation

17     to the Defence to respond to Mr. Hannis's notice, that there is further

18     evidence which we would be applying to call if there is any further

19     challenge to the authenticity of the notebooks.  That's just so it's

20     plain for everybody to see.  We haven't put it -- sought to put it in

21     because we're reluctant to increase the number of outstanding matters at

22     the moment, and, as I say, you have already ruled.  But I think we ought

23     to put it on the record.

24                           [Trial Chamber confers]

25             JUDGE HALL:  Yes.  Thank you, Ms. Korner.  And let me say that we

Page 18838

 1     would be surprised if the observations which the Defence makes in -- at

 2     the invitation of the Chamber are in effect a challenge to the

 3     authenticity of the notebooks.  It's merely, I would have thought, a

 4     question of what precisely it is that has been admitted, because the

 5     Chamber has, in fact, admitted the documents.  It's merely a question of

 6     which is the ones that are going to be -- which of the actual ones that

 7     have been admitted, as opposed to the MFIs it would formulate.  Thank

 8     you.

 9             So we take the adjournment to tomorrow morning.

10                           --- Whereupon the hearing adjourned at 1.46 p.m.,

11                           to be reconvened on Tuesday, the 18th day

12                           of January, 2011, at 9.00 a.m.