Tribunal Criminal Tribunal for the Former Yugoslavia

Page 20998

 1                           Friday, 20 May 2011

 2                           [Open session]

 3                           [The accused entered court]

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

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

 6     everyone in and around the courtroom.

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

 8     Stojan Zupljanin.

 9             JUDGE HALL:  Thank you, Madam Registrar.

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

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

12     Alex Demirdjian, and this morning we're joined by Stephen Bailey, and, as

13     usual, Crispian Smith.

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

15     Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Tatjana Savic appearing for

16     Stanisic Defence this morning.  Thank you.

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

18     Aleksandar Aleksic appearing for Zupljanin Defence.

19             JUDGE HALL:  Thank you.

20             Before the witness comes in, we've been alerted by the

21     Court Officer that Mr. Zecevic has something to raise.

22             MR. ZECEVIC:  Your Honours, yesterday, on page 95, I understand

23     Your Honours' comments and is an invitation to provide the authority for

24     the submission on the -- on the objection I made, if you remember,

25     concerning the introduction of new evidence by the Office of the


Page 20999

 1     Prosecutor at this stage of the proceedings.  And I did research, and

 2     there is the Appeals Chamber decision dated 26th February 2009,

 3     Prosecutor versus Prlic et al. case.  It's a decision on the

 4     interlocutory appeal against the Trial Chamber's decision on presentation

 5     of documents by the Prosecution in cross-examination of Defence

 6     witnesses.

 7             Since we are pressed with time, I don't think that there is any

 8     need at this point to make additional submissions, but I just wanted to

 9     give this reference to the Trial Chamber.

10             Thank you very much.

11             JUDGE HARHOFF:  What was the date again?

12             MR. ZECEVIC:  26th February 2009.  The Appeals Chamber decision

13     in Prosecutor versus Prlic et al.

14             Thank you very much.

15             JUDGE HALL:  Thank you.

16             MS. KORNER:  Your Honours, because, as Mr. Zecevic says, the

17     pressures of time, Your Honours, I'd ask Your Honours to adjourn this

18     particular argument to sometime next week or possibly on Monday,

19     depending on how much re-examination Mr. Zecevic has, because although

20     we've dealt with and we've argued and we're awaiting a ruling on the

21     Defence request for early disclosure of any documents that we propose to

22     use in cross-examination, this is a slightly different point which hasn't

23     really been argued; namely, whether the Prosecution, in its

24     cross-examination, is limited to cross-examination as to credit or can

25     advance its case through cross-examination, in other words, by producing


Page 21000

 1     evidence that hasn't been used before.

 2             So if I may, if I could ask Your Honours simply to adjourn that

 3     to a convenient moment next week.

 4             JUDGE HALL:  Of course.  We weren't expecting you to respond

 5     immediately.

 6             MS. KORNER:  Thank you.

 7             JUDGE HALL:  Mr. Zecevic having cited the authority, you would

 8     need an opportunity to yourselves to consider it and --

 9             MS. KORNER: -- exactly.

10             JUDGE HALL: -- reply.

11             MS. KORNER:  Thank you very much.

12             JUDGE HALL:  So would the usher please escort the witness back to

13     the stand.

14                           [The witness takes the stand]

15             JUDGE HALL:  Good morning to you, Mr. Bjelosevic.  Before

16     Ms. Korner resumes her cross-examination, I remind you you're still on

17     your oath.

18             Yes, Ms. Korner.

19                           WITNESS:  ANDRIJA BJELOSEVIC [Resumed]

20                           [Witness answered through interpreter]

21                           Cross-examination by Ms. Korner: [Continued]

22        Q.   Mr. Bjelosevic --

23        A.   Good morning.  Thank you.

24        Q.   Mr. Bjelosevic, I'm going to return to the prison book in a

25     moment.  But there is one other document that I should have asked you


Page 21001

 1     about in relation to Mr. Jorgic yesterday.

 2             MS. KORNER:  Could we have up, please, 65 ter 20026, which is at

 3     tab 77.  No.  That's definitely not right [Microphone not activated] ...

 4     I see the B/C/S is not right, clearly.  The English is right, but not the

 5     B/C/S, I don't think.  Yes.  Thank you.

 6        Q.   You told us yesterday, and I'm afraid I haven't got any page

 7     numbers because we haven't got yesterday's transcript, that Mr. Jorgic

 8     had appeared from somewhere and was a member of the reserve police.

 9             In November, you -- you wrote to the ministry with completed

10     forms of the individual IL-P and IL-R sheets.  What are IL-P and IL-R

11     sheets?

12        A.   IL-P means individual sheet of the dead, of those killed.

13        Q.   [Previous translation continues] ... so IL --

14        A.   LP.

15        Q.   Okay.  And IL-R is wounded, is it, then?

16        A.   That's right.

17        Q.   And is number 8 on that list the same Nikola Jorgic that we saw

18     in that video yesterday?

19        A.   No.  The last name is the same, however, look at this: Jorgic,

20     Stefan's son, Slobodan.

21        Q.   No.  Could you look at number 8, please.

22        A.   Oh, 8, sorry.  It is possible.

23        Q.   Well, you see, Mr. Jorgic, despite what he had been doing,

24     despite his activities, was retained by you in the police, wasn't he?

25        A.   Not by me, Mrs. Prosecutor.  He was at the public security


Page 21002

 1     station for a while in the capacity of volunteers who were admitted into

 2     public security stations pursuant to that dispatch that we discussed

 3     which came from Mr. Pusina and Mr. Jasarevic.  It was in keeping with

 4     that document that they would admit men into the station when choosing

 5     who was to be part of the police force, in addition to those who went

 6     through the regular procedure.

 7        Q.   Let's take this in stages.

 8             You received this dispatch in April from Mr. Jasarevic, about

 9     which you've complained and which we've been through.  By May the 3rd,

10     you had taken the view, as I understood it, that there was no point in

11     further communications because you couldn't communicate with the old BiH

12     authorities and the CSB and the SJB in Doboj had been taken over by the

13     Serbs.

14             That's what you told us yesterday.  Do you agree?  Can you just

15     say yes or no.

16        A.   It wouldn't be a full answer if I just said yes or no.

17        Q.   [Previous translation continues] ... I --

18        A.   Partly yes; partly no.  Can I explain?

19        Q.   No because unless you say that my summary is in error in some

20     way, then can we move on.

21             MR. ZECEVIC:  That is precisely what I wanted to say.

22             MS. KORNER:

23        Q.   You tell me where I've made an error in my summary of what you

24     told us yesterday.

25             MR. ZECEVIC:  Well, perhaps it would be easier that the witness


Page 21003

 1     explains.  I don't want to --

 2             MS. KORNER:  No, no, no, I'm inviting -- I'm not inviting you,

 3     Mr. Zecevic.

 4             MR. ZECEVIC:  Oh, I'm sorry.

 5             MS. KORNER:  I'm inviting the witness to tell me.

 6             THE WITNESS: [Interpretation] You said that when the

 7     communications were down, we weren't able to communicate with the old BiH

 8     authorities.  Well, we weren't able to communicate with anyone because

 9     the communication lines were severed and we had no contact either with

10     the former SRBiH organs or with the organs of the Serbian Republic of

11     BiH.

12             As of the 3rd of May, the CSB did not exist, as I put it.  And,

13     as you put it, you said that both these organisational units were not

14     working.  That's why I had to make this clarification.

15             MS. KORNER:

16        Q.   I understand entirely what you're saying, that the CSB, for the

17     reasons you've given, did not operate.  But nonetheless, whether

18     operating or not, from the 3rd of May onwards the SJB and the CSB were

19     part of the Serbian MUP, weren't they?

20        A.   Formally, yes.  But some of it was operational and some of it

21     wasn't.  That's the key difference.

22        Q.   So Mr. Jasarevic's illegal order, which you have said was

23     illegal, from the 3rd of May onwards had absolutely no effect, did it?

24        A.   What was created was a certain state of affairs which I

25     repeatedly claimed was unlawful, and I stated the reasons.  TO could only


Page 21004

 1     have been engaged as assistants to the police in situations where public

 2     law and order was seriously disrupted.  But this was the situation that

 3     had been taken over from before, where some of the stations would obey

 4     the orders coming from Mr. Pusina and Mr. Jasarevic, and that was the

 5     head count that they had already had.  And I can't even call the force

 6     that they had the police force, in proper terms.

 7             What else would happen?  When an order would arrive that the MUP

 8     forces should be deployed to the front, the commander and the chief

 9     would, together, establish who was to be dispatched.  They would draw up

10     a list, and deploy them.  On their return, they would produce an analysis

11     of what had happened and would send a report to me that such and such a

12     number of individuals were wounded or killed on such and such a day.  And

13     that's a matter of fact.

14        Q.   I'm sorry, I suggest you're trying to sidetrack everybody from

15     the original question that I'm asking you.

16             Why, when you returned, as you say you did, at the beginning of

17     July to the Doboj CSB, and after the 11th of July when all the question

18     of these criminals who were in the police was discussed, why didn't you

19     make it one of your first tasks to get rid of the murdering thugs who

20     were part of the police?

21        A.   And who's to say we didn't?  And I'm specifically referring to

22     what the minister was asked to do and what I asked that be done out in

23     the field.

24             If you want to, we can go back to some of the notes from the

25     meetings with chiefs of stations when such requests were made, on how


Page 21005

 1     many occasions, and what sort of information they reported back to us.

 2        Q.   You knew --

 3        A.   We can take it by individual dates.

 4        Q.   No, thank you, Mr. Bjelosevic.  As I say, I suggest you're trying

 5     to sidetrack everybody, and me in particular.

 6             Why didn't you, knowing, as you did, that Jorgic was a murdering

 7     thug, why didn't you insist to your chief, Mr. Petricevic, that this man

 8     should be thrown out, and as Mr. Stanisic, in his order, said, suspended,

 9     pending criminal proceedings, and put at the disposal of the army.

10             Why didn't you do that?

11        A.   Let's take it one by one.

12             I'm truly not sidetracking you.  I'm trying to elucidate things.

13     I'm not shying away from anything.

14             It was requested on several occasions verbally and in writing

15     that the matters regarding to the force be sorted out.  But let me tell

16     you what the reality was and how things worked.  A chief, not even today,

17     would not have an insight into who happens to be where at what point of

18     time.  And let me speak in the first person, just as it was.

19             If a chief of a station tells me at a meeting that the purging of

20     the ranks, if you will, is ongoing, and then at the next meeting he tells

21     me that it's all been sorted out, what was there for me to do?

22             And later on - let me remind you of one event where notes were

23     made as a result of one of these supervisory inspections, and I think it

24     was Rajko Bilic who produced that report, where he, as an inspector,

25     would make a fact-finding mission, not me, and then he would find that


Page 21006

 1     among the members of the reserve police there were such individuals who

 2     had criminal records and were prone to criminal conduct.  But what was

 3     there for me to do?  And I've stated this on a couple of occasions.  When

 4     I spoke on this subject with the then chief of station Petrovic, he said

 5     that he was busy implementing this task but that he was fearful of these

 6     individuals.  He tried to approach the matter with caution.

 7             As for suspensions, suspensions and disciplinary proceedings

 8     related only to the active-duty police force, not the reserve force, the

 9     reserve force would originate from the documents that were wartime

10     assignments.

11             I don't know if I've managed to explain clearly how things

12     worked.

13        Q.   The reason for this notification to the MUP, I take it, with

14     these forms was so that the named police officers could receive the

15     appropriate benefits.

16        A.   My view of it was that we were given information.  Now, to what

17     end the information was used by those who received them, I don't know.

18     But the information that we received from the ground, from public

19     security stations, were processed and forwarded to the MUP, and that's

20     how it was done.

21        Q.   So do we take it that in November, when you wrote this,

22     Mr. Jorgic was still a member of the police?

23        A.   No, I don't think that he was there by that time.  But look at

24     the period; it was the 9th of August that he was wounded.  I don't know

25     where he was, but apparently he was out somewhere at the front line and


Page 21007

 1     wounded, as a member of the police.

 2        Q.   You see, isn't it the fact that you, Mr. Bjelosevic, and not only

 3     you, but I suggest your senior officers, superiors, were perfectly happy

 4     for the purposes of defeating, as you saw it, the enemy, to put these

 5     people into uniform and let them stay in uniform.  That's the reality,

 6     isn't it?  You made no effort because you were using these people.

 7        A.   Excuse me, but I think that you are crystal clear on everything

 8     that I said.  You've been dealing with this matter for a long time and

 9     you know that what I'm saying is absolutely true.  You evidently have

10     reasons for trying to deny it.

11             Secondly, my position vis-ā-vis the police and their moral

12     integrity was clear and has not changed over the years.  If you think

13     that it was quite the opposite, then why don't you point me to a specific

14     example where my conduct proves what you're saying?  And the same goes

15     for the then minister, Mr. Stanisic; I claim that his position was quite

16     specific and clear.  And anyone who intends to make a serious analysis of

17     this, I would like to say that there is a number of documents confirming

18     what I say, starting from the Belgrade meeting, to the notes made at the

19     meeting, to a number of orders that followed the meeting where we

20     established the MUP out in the field, in keeping with the law, to a

21     number of reports coming from stations as to how this was done, to the

22     various statements made at meetings.  For instance, the meetings I held

23     with chiefs of stations, where - and we can find specifically which

24     meetings these were - when chief of the Doboj station Petrovic said the

25     crime service has started making a record of crime.


Page 21008

 1             Does this say nothing to you?

 2             MS. KORNER:  Your Honours, may I ask that this document be marked

 3     and admitted.  Admitted and marked.

 4             MR. ZECEVIC:  It is again the same objection, Your Honour.  I

 5     would -- I would suggest that we mark the document for identification,

 6     pending the -- the argument that we are going to -- to present to

 7     Your Honours about the -- the authority that I just cited at the

 8     beginning of this session.  Thank you.

 9             MS. KORNER:  Well, Your Honour, I think that's totally wrong.

10     But, again, this is the problem:  I don't want to waste time on it.

11             Your Honours, this is not, in a sense, new evidence.  It couldn't

12     have been produced until this witness gave evidence --

13             JUDGE HALL:  Ms. Korner, insofar as the Chamber has before it for

14     consideration the -- this issue and it has yet to decide on the relevance

15     of the authority cited by Mr. Zecevic this morning, it seems that we have

16     no other course than what he has suggested.  We mark it identification

17     pending the --

18             MS. KORNER:  All right.  Well, yes, Your Honours, I just don't

19     want to get lost, and we'll have to come back to that when Your Honours

20     have heard full argument.

21             THE REGISTRAR:  Your Honours, that would be P2326, marked for

22     identification.

23             MS. KORNER:

24        Q.   I'd like to go back now, please, to the book we were looking at

25     yesterday and the three people that you were able to identify.


Page 21009

 1             MS. KORNER:  And that is - just a moment - it is P -- no, it's

 2     not.  Yes, it's P1315.  At tab 15.

 3        Q.   Now, we dealt with yesterday the law which you agree was that no

 4     one could be held in detention unless -- certainly by the police for more

 5     than three days, and, otherwise, if they went to a judge for an order.

 6             And you agree with that, do you?

 7        A.   Yes.  The procedure is clearly stipulated by law.

 8        Q.   Now, I don't want to waste time taking you through each of the

 9     entries.  And if what I put to you is wrong, I will be corrected by the

10     other side.

11             But if one went through the book, Mr. Bjelosevic, we would find

12     that Mr. Jovo -- Jozo Mandic, who you agreed you knew to be the president

13     of the HDZ, is shown as being taken in and out to the MUP for interview

14     on no less than 15 separate occasions between the 7th of May and the

15     23rd of June.

16             Would you describe that as normal?

17        A.   I don't know how it came to be that Jozo Mandic was in detention

18     and on the basis of whose decision.  I really don't know that.  I do

19     know, however, that when a person was detained, then if any of authorised

20     officials, officials from the police, had the need to conduct an official

21     interview, such a person had to submit an official request.  It meant

22     that the person who made the decision on the detention was the person

23     that had to allow such interview.

24             In this particular case, I don't know how it went.  I don't even

25     know how many times he was interviewed or by whom.


Page 21010

 1        Q.   You found out, however, that he was in detention, didn't you?

 2        A.   Well, yesterday you showed me the prison book and I simply saw

 3     that his name was recorded in it.

 4        Q.   Yes, I'm sorry.  Forget about the prison book.  Are you saying

 5     that when you returned from your sojourn with the military you didn't

 6     discover that Mr. Mandic had been held in custody since the 7th of --

 7     7th of May, I think.  Yes, 7th.  He's number 3 on the list, 7th of May.

 8             MS. KORNER:  Sorry, we should go to -- I'm so sorry, we should

 9     have gone to the page.  It's, in B/C/S, at second page.

10             Your Honours, I say the English doesn't help very much because it

11     just shows what happens to them and the dates.

12        Q.   We see there he's number 3 on the list, brought in to custody on

13     the 7th of May.

14             And just so that we understand what the entries are at the side,

15     we've got -- I think somebody's been through it already, but we've got

16     the date and time he's taken out and the time that he's returned.

17             And does that show - just let's take that very first entry - that

18     on the 7th of May he was taken out at 2100 and returned at 2200, and he

19     was taken to the MUP?

20        A.   That's what it says here.

21        Q.   Now I'll go back to the original question I asked.  Are you

22     saying that when you returned to your police duties you did not discover

23     that Mr. Mandic was and had been in custody since the 7th of May?

24        A.   You say "discovered."  You are describing the situation as if I

25     was involved in some sort of investigation, research, discovery.  I was


Page 21011

 1     informed by chiefs of stations, and I was informed about some issues.  I

 2     was not involved in any sort of discovery.  I really don't know what you

 3     mean to say when you say that I discovered something or that I did not

 4     discover something.  That's not how things were functioning at the time.

 5     My role was not the role of an inspector who goes around researching and

 6     discovering things.  I was the chief of the centre.

 7             JUDGE HALL:  I expect, Ms. Korner, that we're dealing with a

 8     difference in -- a language problem here.

 9             MS. KORNER: [Microphone not activated] ... I'm going to -- I'm

10     going to rephrase the question.

11             Sorry.  On, off.

12        Q.   Did Mr. Petrovic or any of the prison authorities, because you

13     spoke to them, according to you, tell you that in custody since the

14     7th of May had been Mr. Jozo Mandic?

15        A.   I don't remember that anybody told me that.

16        Q.   All right.  Let's move --

17        A.   And I don't know why this one name should have been specially

18     emphasised among many names.  Why should I have been informed about this

19     particular man?

20        Q.   Well, because he was head of the Croat political party in Doboj.

21     For once I will answer you.

22             Wasn't that an important position?

23        A.   Yes, it was an important political function.

24        Q.   Let's look at the next name.  Mr. Grgic, who's number 12, in

25     custody since the 8th of May --


Page 21012

 1             JUDGE DELVOIE:  Ms. Korner, excuse me --

 2             MS. KORNER:  Sorry.

 3             JUDGE DELVOIE:  Before we move on.

 4             Mr. Bjelosevic, you answered that you didn't discover, you

 5     weren't told, about Mr. - what's his name again? - Mandic.  In general,

 6     did you learn about him?  I don't want to know whether you were told or

 7     discovered during some investigation.  I just want to know:  Did you

 8     learn, did you know, that he was in custody at that time?

 9             THE WITNESS: [Interpretation] During May and June, I did not

10     know.

11             JUDGE DELVOIE:  And he was in custody until when?

12             Ms. Korner?  I don't have it --

13             MS. KORNER:  Your Honour, I'll -- we're going to come to that.

14     He was actually in custody until September when, as you'll see, he was

15     exchanged.

16             JUDGE DELVOIE:  Okay.  Go ahead.

17             MS. KORNER:

18        Q.   Mr. Grgic, who you knew because he was the commander of the

19     police station, wasn't he, before the war?  A Croat.

20        A.   Yes.

21        Q.   He was actually retired at this time, wasn't he?

22        A.   I think he was.

23        Q.   The book shows -- and, again, as I say, I'm open to any

24     corrections, that he was taken in and out for interview to the MUP, and

25     once to hospital.  In fact, there are a number of entries - perhaps we


Page 21013

 1     better have a look at that - for people being taken to hospital.

 2             MS. KORNER:  Could we have a look at page 6 and - 1, 2, 3,

 3     4, 5 - 7.  No.  One more page then, please.  It must be page 8.

 4        Q.   On the 16th of May, was he taken out from the MUP [sic]?  And it

 5     looks like returned on the 19th.  And was he in hospital?  Is that what

 6     it shows?

 7        A.   That's what it says here.

 8             MR. ZECEVIC:  I'm sorry, Ms. Korner, you stated that he was taken

 9     to MUP and then hospital.

10             MS. KORNER:  No, I said hospital.

11             MR. ZECEVIC:  It was recorded on page 15, 22:  "On the 16th of

12     May, was he taken out from the MUP?  And it looks like returned --"

13             MS. KORNER: -- oh, I'm sorry.  From the MUP.  From -- I'm sorry,

14     from the prison.  I beg your pardon.  If I said from the MUP, I meant

15     from the prison.  Sorry.

16        Q.   And you know, don't you, that he was incredibly badly beaten up

17     whilst he was being held in the prison?

18        A.   I'm telling you that I don't know that.  I really don't know

19     that.

20        Q.   [Previous translation continues] ... but you sent, and we'll come

21     on to that a little later because you've already looked at it.  You sent

22     this direction to your officers that -- that -- you know, that people

23     were being badly beaten up in prison, because that's what you were being

24     told.  And he was one of them, wasn't he?

25        A.   Excuse me, did you say that I gave instructions that some of my


Page 21014

 1     people should go into the prison to beat up people?  Did I hear you

 2     correctly?

 3        Q.   No, you didn't.  Never mind.

 4             Did you know that the ex-commander of the police station was

 5     badly beaten up?

 6        A.   I'm trying to tell you what I found out about Karlo Grgic and how

 7     I found that out.  May I say that?

 8        Q.   Yes.

 9        A.   In the first part of my testimony, if you remember, I said that

10     once I was called through the radio communications to go to Dragalic.

11     That's where the place where exchanges were conducted.  It's close to

12     Okucani.  I went there.  I met Karlo Grgic's brother there.  He was a

13     policeman in Derventa.  I used to know him.  That's when he asked me

14     about his brother.

15             When I returned to Doboj, I inquired about Karlo Grgic and that's

16     what I was told.  This is what I was told: that he was detained, that he

17     was interrogated, that he was taken to the hospital because, as I was

18     told, he had been operated on sometime previously.  I was told that he

19     was hospitalised at the surgical department of the Doboj hospital, that

20     one of the nurses brought his clothes and that he left the hospital.  And

21     the official version was that he set out towards Prisade, towards what

22     was at the time called Usora municipality.  And that is the information

23     that I then sent to Marijan Grgic, Karlo's brother.

24             So this is what I knew at the time.

25             Now, as for when he was detained and whether I knew that he was


Page 21015

 1     detained when he was detained, well, I'm trying to convince you that I

 2     did not know that.  I assure you that I did not know that.  I told you

 3     what I knew.

 4             Much later I heard many other stories, other information, that he

 5     was killed, that he had escaped.  But rumours is one thing and verified

 6     information is another.  I really am not aware of the details.

 7             So this is how I gathered information about him, and I did it

 8     because his brother asked me to do it.

 9        Q.   Were you spoken to by Predrag Radulovic about Karlo Grgic?

10        A.   Predrag Radulovic.  I don't know whether I met Predrag Radulovic

11     during the war --

12        Q.   [Previous translation continues] ... when you say --

13        A.   All that --

14        Q.   Sorry.  I interrupted you.  Go on.

15             You did meet him because you met him in Teslic if nowhere else?

16             MR. ZECEVIC:  That is precisely what the witness said and you

17     interrupted him.

18             MS. KORNER:  Oh, I'm sorry.  Well, he said -- I thought he said,

19     I didn't meet him during the war.

20             MR. ZECEVIC:  "Until ..." and then you interrupted him.

21             MS. KORNER:  Sorry, my fault.

22        Q.   After that, the incident in Teslic beginning of July, did he

23     speak to you about Mr. Grgic?

24        A.   After the incident in Teslic, I never spoke to Radulovic.  Not

25     for one or two months, but we didn't speak for several years.


Page 21016

 1        Q.   [Previous translation continues] ... no --

 2        A.   I was really angry at that man.  We never spoke.  It took quite a

 3     while.

 4        Q.   So we take it that Mr. Radulovic, you say, never spoke to you

 5     about Karlo Grgic and that you said to him and complained that all these

 6     police officers, all these people, were being killed.  And you said to

 7     him you could do nothing about it.  That never happened.  No conversation

 8     like that?

 9        A.   I'm telling you once again.  After what happened in June in

10     Teslic, after that meeting, the two of us did not speak for a long time.

11     Later on, we discussed a number of topics, and it is possible that later

12     on we also discussed some of the events dating from the war.  And it is

13     possible that our conversation may have touched upon that subject, but

14     that was after the war.

15        Q.   Well, I suggest to you, you see, Mr. Grgic disappears from the

16     prison, or from the hospital, on the 24th of May, but at some stage

17     during this period - not after the war - Mr. Radulovic spoke to you about

18     Mr. Grgic.  We've already dealt with that.

19             All right.  Finally, can we deal, please --

20             MR. ZECEVIC:  Yeah.  But can the witness be --

21             MS. KORNER:  Well, he's already said it never happened.  And I'm

22     putting the Prosecution case on this.  Well, he can certainly answer it

23     again if you want him to.

24             MR. ZECEVIC:  Well, if you're putting something to him, you

25     should give him the opportunity to answer, I believe.


Page 21017

 1                           [Trial Chamber confers]

 2             JUDGE HARHOFF:  Ms. Korner, we're just wondering if you have

 3     brought any evidence to --

 4             MS. KORNER:  I'm reading --

 5             JUDGE HARHOFF: -- sustain your --

 6             MS. KORNER: -- suggestion.

 7             JUDGE HARHOFF: -- point that there was such a conversation.

 8             MS. KORNER:  I'm reading from the transcript page 10800 to 10802.

 9             JUDGE HARHOFF:  Thank you.

10             MS. KORNER:

11        Q.   That's my suggestion, Mr. Bjelosevic.  That you did meet.  That

12     you did meet Mr. Radulovic, who spoke to you about the death of Mr. Grgic

13     because it was a well-known notorious fact, and this was before the

14     incident involving the Mice.

15             THE INTERPRETER:  Microphone off, please.

16             THE WITNESS: [Interpretation] Now, if you want to say something

17     like that, I would like you to tell me where it was and when it was that

18     we met and had this discussion.

19             MS. KORNER:

20        Q.   It was in -- sorry.  I can't give you an exact date.  I can put

21     to you that it was before the Mice incident and it was in your office.

22        A.   No.  No way.  In my office?  Mr. Radulovic definitely did not

23     come to my office during that period of time.  Something like that I

24     certainly would have remembered.

25             MR. ZECEVIC:  Ms. Korner, you should read from the part of the


Page 21018

 1     transcript what you just said because this witness that talks about that

 2     says on the same day.

 3             So, therefore, it is probably -- the day is probably identified.

 4     So -- so.

 5             MS. KORNER: [Overlapping speakers] ... it's not.

 6             MR. ZECEVIC:  Because he says, On the same day, I met

 7     Andrija Bjelosevic.  And therefore you should put to the witness exactly

 8     what the -- what the -- the contents.

 9             MS. KORNER: [Overlapping speakers] ... [Microphone not

10     activated] ... I'm looking.  I'm looking, Mr. -- all right.  Can we --

11     can we go back ...

12                           [Prosecution counsel confer]

13             MS. KORNER: [Microphone not activated] ... On the excerpt --

14     sorry.

15             This on/off business is driving me bananas.

16             The -- on the excerpt I have, there is no reference to what day

17     it was.  But we'll go back and see if we can find ...

18             MR. ZECEVIC:  It refers, I believe, on page, if I may be of

19     assistance, 10798 the report dated 17th of May, 1992, was discussed, and

20     then it goes, Mr. Radulovic explains about --

21             MS. KORNER:  Just a moment, yes.  I'm sorry, one of the rules is

22     that you -- we shouldn't be doing it like this.  I'm putting the

23     suggestion, I've been asked what I base it on, I've given the answer to

24     that.  I will see if we can put a time and I'll come back to it, but I'd

25     like to move on because this is just time-wasting.


Page 21019

 1        Q.   Now, can we -- Mr. Tipura who - if we go back, please, to the

 2     second page of the book - he, again, was an ex-police officer, wasn't he?

 3        A.   Yes.

 4        Q.   It we went -- he, too, was first arrested on the 7th of May.  He

 5     was taken out to the MUP on eight occasions.  And he died, didn't he, of

 6     his injuries in hospital in Banja Luka in September?

 7        A.   Ilija Tipura was more than just a policeman.  Ilija Tipura had a

 8     Ph.D., and he was a dignitary.  I heard what you just said, that he died

 9     in the Banja Luka hospital, but I don't know why he died there.

10        Q.   All right.  Now --

11        A.   If you allow me, I would just like to say what my view is on

12     that.

13             Whoever brought in, questioned, detained Ilija Tipura, and

14     especially if this, what you said, happened, that person made a bad

15     mistake.  On the basis of what I know about the man, Tipura.

16        Q.   Are you telling the Court that you didn't know that he was beaten

17     up as well?

18        A.   I have said what I thought and what I know.  I say once again:

19     Whoever did that made a terrible, terrible mistake.  If he mistreated

20     persons anyway.  But especially not in this case, a person who most

21     definitely did not deserve to be treated that way.

22        Q.   Well, I don't think that's an answer, but I've been told off for

23     pursuing matters, so ...

24             JUDGE DELVOIE:  This time you should insist, Ms. Korner.

25             MS. KORNER:  Right.


Page 21020

 1             JUDGE DELVOIE:  Well, Mr. Bjelosevic, did you know - that was the

 2     question - did you know that he was beaten up or did you not know that he

 3     was beaten up?  That has nothing to do whether you knew why he died.

 4             Did you know that he was beaten up or didn't you know?

 5             THE WITNESS: [Interpretation] No.  At the time, I most certainly

 6     did not know that Dr. Tipura had been beaten up.

 7             MS. KORNER:

 8        Q.   All right.  Now let's move back, please, to Mr. Mandic.

 9             MS. KORNER:  Could we have up on the screen, please, 20138, at

10     tab 118.  It was added last night, Your Honour, because we hadn't got a

11     translation earlier.

12             MR. ZECEVIC:  Just one intervention in the transcript,

13     Your Honours.  22, page 22, 6, 7, and 8, I don't think the second -- the

14     second sentence is -- is recorded properly.  That is not what the witness

15     said.  So if this can be clarified with the witness.  I'm sorry.  I'm

16     really not trying, but this would appear that -- that -- that the witness

17     is actually agreeing with the mistreatment of, and instead he said

18     something very -- totally different.

19             MS. KORNER:  I see.  Do you mean the sentence, "If he mistreated

20     persons anyway ..."?

21             MR. ZECEVIC:  Yes.

22             MS. KORNER:  Yes, that's obviously not what he said.

23        Q.   Mr. Bjelosevic, I better correct this, although I think it's

24     clear from your evidence what you were saying.

25             "I have said what I thought and what I know.  I say once again:


Page 21021

 1     Whoever did that made a terrible, terrible mistake."  And you're then

 2     recorded as saying:  "If he mistreated persons anyway.  But especially

 3     not in this case ..."

 4             I think what you were saying was if persons were mistreated, if,

 5     in the -- is that right?

 6        A.   I said that whoever did that, if that person did that kind of

 7     thing anyway, that kind of mistreatment, I'm saying that mistreating

 8     people generally is a bad mistake.  And in this particular case, if this

 9     happened to Dr. Tipura.  It should never happen.  That's what I'm saying.

10        Q.   All right.  Can we go back then, please, to the document that's

11     now up on the screen.

12             This is a criminal report dated the 10th of August, 1992, against

13     a number of different people with number one as Jozo Mandic, born

14     9th of September, 1921.  So in 1992 he was 69 years -- sorry, 71 years

15     old.  That's right, isn't it?

16        A.   There is information about his date of birth, yes.  He was born

17     in 1921.

18        Q.   You knew him to be -- you knew him personally, didn't you,

19     Mr. Bjelosevic?  He was an old man.

20        A.   I saw him at two meetings, I think, in the Autumn of 1991, at a

21     meeting that I had initiated.  I asked Mr. Alicic to convene a meeting

22     after what happened in Brod.  I asked him to host the meeting, and I

23     asked that all relevant persons be invited so that we can discuss that

24     subject in order to have everyone work in a calming fashion.  I remember

25     that he was at that meeting then, and I may have seen him another time.


Page 21022

 1     I do not recall.

 2        Q.   All right.  Can we go to the last page, please, just to see who

 3     signed this.

 4             Is that your signature?

 5        A.   Yes, this is my signature.

 6        Q.   So by the 10th of August, 1992, at the very latest, you knew that

 7     Mr. Mandic was in custody, didn't you?

 8        A.   Why would I have to know that he was in custody?  I would most

 9     kindly ask you to go back to the first page so that it would be easier

10     for me to give an answer.

11        Q.   Certainly.

12             MS. KORNER:  Can we go -- sorry, can we go back to the first

13     page.

14             THE WITNESS: [Interpretation] Please look at the top of the page.

15     You see it says National Security.  If that service processed information

16     about certain individuals and if they said that on the basis of their

17     information, when they established the facts, et cetera, if they write up

18     a criminal report, I had to trust them.  Not going individually by name

19     into who was where at the time.  However, I believed them, if they wrote

20     this up, and if they are invoking -- look at all the articles here - look

21     at this.  Pursuant to Article so on and so forth.  I believed them.

22             MS. KORNER:

23        Q.   The question was whether you knew in August, when you signed this

24     criminal report, the -- security services -- the National Security

25     Service, the SNB having conducted an investigation, that he was in


Page 21023

 1     custody?

 2        A.   I've given you an answer to that question.  I didn't know who was

 3     where at that point in time, because I signed a report that they had

 4     processed and prepared.

 5             JUDGE HALL:  Mr. Bjelosevic, there was a part of a question that

 6     Ms. Korner had asked earlier which, implicitly, I thought you had

 7     adopted:  Did you know Mr. Mandic beforehand, before this -- the date of

 8     this report?

 9             THE WITNESS: [Interpretation] I don't know.  I think not.  I

10     think I did not know that he was in custody.

11             JUDGE HALL:  No, no.  That isn't my question.  My question is

12     whether you knew him.  I have a follow-up question, but the -- but

13     what --

14             THE WITNESS: [Interpretation] Oh, yes.  Yes, I've already

15     answered that, Your Honour.

16             JUDGE HALL:  So my question is:  Although you didn't, yourself,

17     prepare this report, it was prepared by whatever the working system was

18     that you have and you signed off on it, did the -- did it strike you that

19     among the persons listed was Mr. Mandic?

20             THE WITNESS: [Interpretation] It was a long time ago, and I

21     cannot speak about it in great detail now.  However, I will tell you one

22     thing.  Irrespective of someone's important political office, that was

23     not a reason for that person not to do something that was against the

24     law, to do something wrong.  And I would certainly not be the person to

25     say, Wait a moment, he's the president of a political party, or to


Page 21024

 1     amnesty anyone in any way.  If the service wrote up something, I would

 2     have to have strong indicia, to the effect that something was wrong, to

 3     ask for something to be revised, to put a question mark, et cetera.

 4             JUDGE HALL:  I wasn't going so far, Mr. Bjelosevic.  My question

 5     was merely:  Having regard to the fact that you knew Mr. Mandic

 6     beforehand, and knew something about him, whether, at the time you signed

 7     this report, it is something that, as it were, stood out?

 8             That's the only question I'm asking.

 9             THE WITNESS: [Interpretation] Believe me, I do not recall.  The

10     signature is placed on the last page.  After all these years, it is hard

11     for me to remember with reliability whether I looked through all the

12     names.

13             I don't know even know if I looked through all the names, to tell

14     you the truth.

15             MS. KORNER:

16        Q.   Let's go back to the last page, please, and we'll see the answer

17     to the question.

18             Just above the list of the names, do you see the words in the

19     paragraph that begins, "We remark that the charged Mandic," et cetera,

20     "are in detention at the regional prison Doboj"?

21        A.   That wasn't relevant for me either, in terms of whether I should

22     sign the criminal report or not.

23        Q.   It didn't cross your mind that perhaps it wasn't a terribly good

24     idea that a 71-year-old man should have been in prison from May through

25     to when you signed this report in August?


Page 21025

 1        A.   As for police custody, it is decided upon by the person who was

 2     in charge of the case up until then.  After the time provided for by the

 3     law for police custody, after that expires, then I could not decide about

 4     it any longer.  So I didn't even go into that.

 5        Q.   He and all the other people named were allegedly having committed

 6     the offence of armed rebellion against the Serbian state.  That's right,

 7     isn't it?

 8             If you go back -- we'll go back to page 1 -- page 2, sorry, the

 9     end of the list.

10        A.   Everything is probably as is written here.

11        Q.   That's at the bottom of the page.

12        A.   If so ...

13        Q.   If true - leaving aside the legal technicalities of how you were

14     rebelling against the Serbian state before it came into existence; that's

15     not the point, but - it is an extremely serious offence.  That's right,

16     isn't it?

17        A.   Yes.  That is how the law treated it at that time.  Who took part

18     in the creation of paramilitary formations and their arming and took part

19     in armed activity was thereby committing a crime.  That is what the law

20     said.

21             THE INTERPRETER:  Interpreter's note:  Could all other

22     microphones please be switched off.  Thank you.

23             MS. KORNER:  Let's look at what happened, please, to Mr. Mandic.

24             Could we have up, please, the video which is at 20135, and the

25     transcript is at tab 116.


Page 21026

 1             The part is at -- starts at 53 minutes -- the part that we're

 2     going to see starts at 53 minutes in, and the transcript part is at

 3     page 19 of the document.  And we need sound.

 4                           [Video-clip played]

 5             THE INTERPRETER: [Voiceover] "The petrol station in Dragalic not

 6     far from Nova Gradiska has become a place of freedom for another couple

 7     of hundred prisoners from Bosnia and Herzegovina."

 8             "I find it difficult to talk.  I can't talk."

 9             "Reporter:  What is the situation like in Doboj?"

10             "Mandic:  Very bad.  I spent 125 days in prison.  From the first

11     day.  It's hard, I can't talk."

12             "What did they do there?"

13             "Mandic:  I will tell journalists ... when I get to Kljujic,

14     Mesic and Perica.  In the last minute, from the prison onto a bus.  I

15     left two apartments, two houses, a car, 150 "dulums" of land ... from the

16     time the main committee was organised in Sarajevo and Doboj, for Doboj

17     municipality, I worked fair and square ..."

18             "Reporter:  Did you come directly from prison?"

19             "Yes, directly from prison.  There was an exchange because

20     probably Mesic or someone ... They arrested everyone ... on the

21     street ... at their houses.  I was captured the first day.  They searched

22     my house and took everything.  I had a pension.  I retired 12 years ago.

23     They seized my two apartments, two houses, 150 "dulums" of land, a car.

24     Fortunately, my son somehow managed to leave.  He immediately left for

25     Slovenia with his wife and three children.  He is an engineer.  But


Page 21027

 1     everyone has to move out."

 2             "What is the situation like in occupied Doboj?"

 3             "Very bad.  Very bad.  Very bad.  This is a tragedy."

 4             "How many Croats and Muslims remained there?"

 5             "I don't know exactly, but very few.  Many Muslims have fled to

 6     Tesanj.  Women, children, and men.  The remainder stayed in town, but

 7     even they want to leave.  There are many here in these three buses.  And

 8     Muslims."

 9             "How long were you there?"

10             "I spent 125 days in prison from the first day, from the 3rd of

11     May.  There were two detention camps - one in Usora and one in the

12     barracks in Pare where a tank unit had been located.  Perhaps about 4.000

13     people were detained.  I lost a lot of weight.  Do you see the holes in

14     my belt?  For 40 days I ate only two meals a day - 100 grams of bread and

15     some water.  Nothing else.  So I ..."

16             "How old are you?"

17             "I'm 72 years old ... but I was in good shape ... detention

18     crushed me.  I was beaten ... There was much beating there ... by the

19     army, police.  I was badly beaten too.  No questions were asked.

20     Soldiers and policemen in transit.  There are fire or six kinds of

21     troops - Arkan's Men Chetniks, and those with hats, the men from Knin,

22     and people are completely -- well, lately, when UNPROFOR apparently

23     started intervening, but they could not intervene in the prison.  I

24     managed to do a little something but through a lawyer, but now ..."

25             "Just tell us your name, in the end."


Page 21028

 1             Answer:

 2             "I am engineer Jozo Mandic.  I am from Doboj.  I lived there for

 3     45 years.  I worked for 40 years for the railways.  I was retired, and

 4     then as a retired person I was elected president of the HDZ in Doboj

 5     municipality and participated in all the forums, but in a fair and

 6     honourable way.  I think ..."

 7             MS. KORNER:  Okay.  That's all.

 8        Q.   This exchange of a man you had signed a report for saying that

 9     there was evidence he was guilty of armed rebellion, were you present?

10     Because it was apparently at the petrol station in Dragalic.

11        A.   Dragalic was a place where exchanges happened anyway.  And I said

12     that I was there only once.  It wasn't this particular time.  It was

13     before that.

14             As I watch this video, it takes me back to the time.

15     Unfortunately, this is one of the thousands of stories of people from all

16     sides.  You heard that it was an exchange.  You could see that on the

17     other side too.  I'm not underestimating anyone's suffering or sacrifice,

18     and I'm not justifying anyone's crime by somebody else's crime.  But what

19     I wish to point out is that this is one of the many stories, destinies,

20     of one particular individuals [as interpreted] within everything that had

21     happened in the area.  Believe me, you could have heard thousands of

22     stories like this, regrettably.

23             MS. KORNER:  Your Honours, in light of the legal matters we

24     discussed, may I ask that it be marked for identification.

25             JUDGE HALL:  Yes.


Page 21029

 1                           [Trial Chamber and Registrar confer]

 2             THE REGISTRAR:  Your Honours, that portion will be Exhibit P2327,

 3     marked for identification.

 4             MS. KORNER:  Your Honour, I accept that only that portion, of

 5     what is a lengthy video, is going to become the exhibit.  And, if

 6     necessary, we'll put it onto a separate --

 7             JUDGE DELVOIE:  Ms. Korner, could you remind me the tab number,

 8     please.

 9             MS. KORNER:  Yes, the tab number is 116.

10             JUDGE DELVOIE:  Thank you.

11             JUDGE HALL:  And this is a convenient time for the break.

12                           [The witness stands down]

13                           --- Recess taken at 10.26 a.m.

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

15                           [The witness takes the stand]

16             MS. KORNER:  Your Honours, Mr. Zecevic asked if we could give --

17     put a date when the meeting with Mr. Radulovic took place.  We've checked

18     the previous transcript pages, and I'm open to any corrections that

19     Mr. Zecevic wishes to make, all we can seem to be able to say is that at

20     that stage the discussion -- at an earlier stage, I'm sorry, there was a

21     discussion of a document dated the 17th of May, 1992.  The questions then

22     continued, and all we can say is it appears to have been an occasion

23     sometime between the -- well, it has to have been the 25th May, because

24     that's the last entry in the prison record for Mr. Grgic, and obviously

25     the 30th of June.


Page 21030

 1             So that's the best we can do.  If Mr. Zecevic thinks that there's

 2     any better we can do, then I'm open to suggestions.

 3             MR. ZECEVIC:  Well, I don't know if you want me to talk about

 4     that in front of the witness.

 5             MS. KORNER: [Microphone not activated] ... all right, well

 6     that's -- in which case -- well, I don't want -- again, this is my

 7     problem.  I don't want to waste time.  Is it something, perhaps, we can

 8     discuss at the next break and see if we can get something better?

 9             MR. ZECEVIC:  Definitely, yes.

10             MS. KORNER:  Well, Your Honours, we'll do that.

11        Q.   I want you now, on the -- still on the topic of this prison and

12     what was happening, for you to have another look at this document that

13     you told us about when you were giving evidence in chief.  And it is

14     tab 25 in our bundle.  It's P1305, and there's also -- it was in the

15     Defence bundle, as well, as tab 49.  It's the one I'm sure you remember

16     because you said that you found that a knife had been stuck through it.

17             It's the order that you made on the 12th of June.  And this is

18     what you said about it when you were giving evidence in chief at

19     page 19628:

20             "This is a document that I signed and I dictated so that it be

21     typed up.  And it was done in quite a bit of a hurry, as I was coming to

22     the centre.  It was either the prison warden or the deputy that I came

23     across, and this person told me that they had certain problems regarding

24     the entry of different persons wearing different uniforms, that they

25     would violently enter the premises of the prison, and that they committed


Page 21031

 1     violent acts against the prisoners there, and the prison asked for help."

 2             Now, by the 12th of June, therefore, Mr. Bjelosevic, you were

 3     aware that people were going into the prison and beating up prisoners

 4     there; can we agree on that?

 5        A.   Yes, we can.  As I said, I received the information from either

 6     the warden or his deputy.

 7        Q.   Right.  But can we just look at the first three lines of this

 8     order:

 9             "I strictly prohibit arbitrary entry into the premises of the

10     Dobrinja District Prison rooms for temporary detention of persons in

11     public security stations ..."

12             So we take it from that this is an order directed to your police,

13     that you knew also on the 12th of June that people were being detained in

14     the SUP -- the SJB, I should say.

15        A.   All the public security stations had a room set aside for persons

16     who were taken into custody but were not officially detained.  There were

17     a number of reasons for which persons could be taken into custody.  They

18     could be intoxicated and disrupt public law and order and would be kept

19     in that room until they sobered up.

20        Q.   Yes.  But, I'm sorry, you're prohibiting people coming into the

21     rooms for temporary detention of persons in public security stations.

22     Can we take it from that, Mr. Bjelosevic, that you were aware that people

23     were beating up detainees in the police stations as well?

24        A.   Yes, there were such instances.

25        Q.   All right.  And then:  "... as well as the use of physical


Page 21032

 1     intimidation and physical force against imprisoned and detained persons."

 2             Now, did you, yourself, when you got this information that people

 3     were being beaten up in the police stations, instigate immediately an

 4     investigation into how that was happening?

 5        A.   The way you put it, only I would have sufficed there, and I

 6     should have been everywhere, seen everything, and taken decisions about

 7     everything.  So I didn't need inspectors, chiefs of stations, commanders,

 8     or police officers themselves.

 9        Q.   For the moment, you said that you were engaged on the military

10     duties during this period.  But didn't you think this was an important

11     enough occasion to call together the chiefs of, at the very least, Doboj,

12     and Samac, or the commanders, to say, "I want an immediate investigation

13     in what is going on in the beating of prisoners"?

14        A.   As we can see, it's the 12th of June.  I was certainly not able

15     to invite Samac because there was no communication between Samac and

16     Doboj, as the corridor had not yet been opened.

17             On this date, the activities aimed at opening up the corridor

18     were at their most intense.  And what I was able to do on the fly, as it

19     were, during my brief visits there was the best I could do.  In my

20     evidence so far, I said that perhaps it wasn't up to speed in terms of

21     how the situation dictated it, but I did as best I could, and you saw how

22     I faired after having written this.

23        Q.   Yes, we've heard your account of what you say happened.  Were you

24     yourself ever present in the building, because it -- the building

25     contained the SJB and CSB offices, when people were being beaten up in


Page 21033

 1     that building?

 2        A.   I think I mentioned it that on one occasion as I entered the

 3     building I came across a number of people standing in the corridor who

 4     had been taken in.  They held their hands against the wall and were

 5     singing songs.  I was very much surprised by what I saw, and exclaimed,

 6     What's happening here?

 7             As I entered the room where duty police officers were located, I

 8     asked them what this was all about.  As I spoke to them through an

 9     opening in the wall, there was a person coming down the corridor -- or,

10     rather, there were two individuals coming down the corridor who held

11     their chins high and said, It was us who brought them in.  And I said,

12     Well, on whose orders was this?  And they haughtily said that they had

13     arrested, as they put it, the Ustashas.  I ordered my men to release

14     these individuals and to throw the two men out of the station.  And

15     that's how it happened.  The two armed men left.

16        Q.   [Previous translation continues] ... yes, I'm sorry --

17        A.   I was looking for the chief at the time.

18        Q.   I'm sorry, I really am going to stop you there because you did

19     talk about this before.  But my question, which I will say again, was:

20     Were you present when people were being beaten up?  Not singing songs.

21        A.   I didn't see anyone being beaten up in the corridor as I got in.

22     But I did see individuals as they were brought in.

23        Q.   Yes.  All right.  I think the answer to my question is, no, you

24     didn't see them being beaten up.  Did you see people in the SUP -- or,

25     I'm sorry - the SUP -- in the building with obvious signs of injury?


Page 21034

 1        A.   I can't recall.

 2        Q.   Well -- all right.

 3        A.   I really don't remember.

 4        Q.   All right.  Did you ever hear screams coming from the prison

 5     which was next door to the building from the people who were being - and

 6     I use the word "tortured" - there?

 7        A.   No.

 8        Q.   Well, I'd like you to have a look, please, at a document for a

 9     moment.  Another one.

10             MS. KORNER:  Could we have, please, on the screen document 20133,

11     tab 112.

12             MR. ZECEVIC:  Can I ask what is the provenance of this document?

13             MS. KORNER:  It's an article published in --

14             MR. ZECEVIC:  On the Internet?

15             MS. KORNER:  Yes, I'm not proposing to exhibit it.  I want to ask

16     one question about it.

17             MR. ZECEVIC:  I just note it.  Thank you.

18             MS. KORNER:  In fact, I don't know if it is on the -- I mean,

19     that's where it's been got from, but I think it's actually published in

20     something called BIRN, B-I-R-N.

21        Q.   This was an article, a very recent one, on the 18th of

22     November last year largely dealing with what happened in Doboj and the

23     evidence of Mr. Petrovic.

24             MS. KORNER:  Could with go, please, in English to the third page.

25     And I think it's all in one page in B/C/S.  No, it's not, sorry.  Second


Page 21035

 1     page in B/C/S.

 2             MR. ZECEVIC:  What I would suggest, Ms. Korner, just for the

 3     consistency of the -- of the presentation of evidence in this case, I

 4     suggest you pose the question.  You don't need the document.  Because I

 5     can -- I can possibly list a number of occasions where you yourself and

 6     the other members of the Office of the Prosecutor were complaining about

 7     the documents coming from the Internet, and there has been some rulings

 8     from the Trial Chamber in that -- in this respect.

 9             Perhaps the best way to proceed would be that you ask the

10     question.  You don't need this document, because you cannot show us the

11     provenance of this document.  It's obviously taken from the Internet.  We

12     don't know who wrote it or anything else for that matter.

13             Thank you.

14             MS. KORNER:  Your Honour --

15             JUDGE HALL:  Mr. Zecevic, aren't you anticipating the -- we don't

16     know what the question is.  And the issue of provenance is something that

17     we need only exercise our minds about if there were attempts to exhibit

18     it.  Isn't that where we are?

19             MR. ZECEVIC:  Yes, Your Honours, but the problem is that it is my

20     understanding that Ms. Korner was asking for the third page.  I assume

21     she is going to read from the document, and that is the anticipation, and

22     my objection was ...

23             JUDGE HALL:  Well, I would have thought -- well, I shouldn't

24     say -- I thought that the way that we dealt with documents such as this

25     is that before counsel asking the question phrases it, that the witness


Page 21036

 1     is invited to look at the document and then the question is asked.  So we

 2     avoid the -- any suggestion of the document being sneaked into the

 3     record.

 4             MR. ZECEVIC:  I understand, Your Honours.

 5             MS. KORNER:  Well, Your Honours, it's completely different

 6     because we do know the provenance and can, if required, prove the

 7     provenance.  The objections earlier have been to documents that suddenly

 8     appear on General Praljak's web site.

 9        Q.   Were you contacted, Mr. Bjelosevic, by reporters last year?

10        A.   By telephone.

11        Q.   On the telephone?

12        A.   [In English] Yes.

13        Q.   And did they ask you about what Mr. Petrovic had said?

14        A.   [Interpretation] Yes.  I forgot the reporter's name, but he said

15     that he was an investigative journalist and asked me about some of the

16     statements made by Obren Petrovic.

17        Q.   Yep.  And did he put to you the statement made by Mr. Petrovic

18     that you, your office was on the first floor of the CSB, could have heard

19     the sounds of non-Serbs being beaten in the police station in Doboj, and

20     did you reply, The essential issue is not whether this could be heard or

21     not but why it could be heard, and then saying that you did not want to

22     comment about the details?

23             Did you give that reply?

24        A.   Yes.  I said that the essential bit is not whether you heard

25     sounds of somebody being beaten but why these individuals were being


Page 21037

 1     beaten.  So that's what I said, not whether -- how far you could hear a

 2     person being tortured but why that person was tortured.  That was the

 3     essential issue in my view.  And that was the question put to me.  And I

 4     do still think that this is the essential question to be put.

 5        Q.   Well, effectively, you didn't answer the reporter's question.

 6     Because what he was putting to you, wasn't he, in effect, was whether you

 7     had heard people being beaten in the police building, wasn't he?

 8        A.   That's not what the question was.  He asked me if I was aware of

 9     the statement made by Obren Petrovic, who, in answer to what was probably

10     a question from the prosecutor, on the issue of people being taken into

11     custody and beaten, was supposed to answer the question of whether the

12     sounds of beating could be heard as far as my office, and that was what I

13     told him in this response.

14        Q.   All right.  You never heard -- and you never heard anybody being

15     beaten, any screams of people being beaten?

16        A.   No.  At the time when I was present in my office, I didn't hear

17     it.

18        Q.   Yes.  Well, that's --

19        A.   Admittedly, I spent very little time there.  But when I was

20     there, I didn't hear it.

21        Q.   Yes.  I want to move away now from the topic of prisons and

22     prisoners and look at some of the people who were on the police payroll

23     during the course of this period.

24             MS. KORNER:  Could we have a look, please, first of all, at the

25     document which I think you looked at before.  It's P1346, tab 13.


Page 21038

 1        A.   Is this the number of this tab?

 2        Q.   No, it's not.  I think it was in the Defence binder, but I don't

 3     know what number it was.

 4             Oh, I'm told it wasn't.  So you'll just have to look at it on the

 5     screen.

 6             Now, this is, which comes from the Doboj CSB, a -- what's called

 7     an advance payment payroll list for April of 1992.  And in April 1992,

 8     you are still working, aren't you, in the CSB Doboj?

 9        A.   Yes.

10        Q.   What was the Special Group Doboj that's having advance payment

11     here?

12        A.   I don't know.  I really don't know.  It's the month of April, and

13     I can see that it says that it's an advance payment of the salary for the

14     month of April 1992.  The signatures I see at the bottom are unknown to

15     me.

16        Q.   Was it part of your duties from time to time, if not regularly,

17     to check the payrolls?

18        A.   To check them?

19        Q.   Yes.  To check that -- that -- that, you know --

20        A.   No.  I did sign some payrolls, but I am unfamiliar with this.

21     I'm going through the names now and I recognise the first and the

22     eleventh name.  There is a total of 11 of them.  And what surprises me is

23     that Nenad Kujundzic was a police officer in the Doboj Public Security

24     Station, in other words within our building.  And to see this, together

25     with the words "special group," is unfamiliar.  I don't know who wrote


Page 21039

 1     this or signed it.  But it could have something to do with the fact that

 2     some -- somehow that money had to be accounted for.  It was through the

 3     months of August and September that we had to deal with the funds

 4     arriving from the SDK and the bank and a certain amount from the post

 5     office as well -- or, rather, these funds having been lost somewhere, we

 6     didn't know what had become of the money and we were trying to track it

 7     down.  So this may have been a part of it.  But I don't know.

 8        Q.   I'm sorry.  Can we stop there, please, because you say the

 9     security services station.  This is the Security Services Centre.  This

10     is not the SJB; this is the CSB Doboj, isn't it?

11        A.   That's precisely why I was telling you this, if you had been

12     listening carefully.  What I was surprised by was that the document is

13     not dated.  The only reference to time we have is the month of April.

14             Second of all, I said that Nenad Kujundzic was a police officer

15     in the SJB Doboj in April and there was no special group or special unit

16     within the centre.  Besides, I don't know these other individuals or

17     their names, if that's the Nenad I'm referring to.

18             And I know the name of Radojica Bozovic, but to my knowledge he

19     was not there in April.

20             I don't know what this document is or what it represents.

21        Q.   Well --

22        A.   I'm trying to make out the text on the seal as well, but it's not

23     possible.

24        Q.   [Microphone not activated] ... yes, this man -- thank you.

25             We saw the name of this man Bozojovic [phoen] yesterday in the


Page 21040

 1     report by Milos, didn't we?  That the activities of him and his men were

 2     causing outrage - I'm summarizing, and I don't know if anybody wants

 3     to -- amongst the citizens of Doboj.  Do you remember that?

 4        A.   Excuse me, the name I received in interpretation was Zojovic.  Is

 5     that a new name?

 6        Q.   The man we can see on the first -- as number one on this list of

 7     the Special Group Doboj.

 8        A.   You mean Bozovic.  Not Zojovic.  I received it as Zojovic in

 9     interpretation; that's what confused me.  So I suppose that's the same

10     name, yes.

11        Q.   And weren't you --

12        A.   But I don't have any information that this man was in Doboj in

13     the month of April.  And I particularly don't have any information about

14     him being in the centre.

15        Q.   But --

16        A.   The question should be put to the author of the document.  I

17     don't know anything about it, really.

18        Q.   Are you saying that somebody in your centre - and it's stamped

19     and signed - without your knowledge was authorising payment for a group

20     of people headed by this man called Bozovic, entitling it "Special Group

21     Doboj," without any input or knowledge by you?

22        A.   I don't know absolutely anything about the document.  The author,

23     the date on which it was made, I don't recognise the signatures or the

24     seal.  Nothing.  The only thing I could assist you with is with those two

25     names that I recognise, and at least they have the same first and second


Page 21041

 1     name of the individuals I know.  But as for the rest of the document, I

 2     have no idea.

 3        Q.   But all these documents which are maintained - and maintained

 4     still at Doboj - were open for inspection by inspectors from the MUP, by

 5     yourself, by anybody, weren't they, who had lawful authority to look at

 6     these documents?

 7        A.   If this may assist, I can ask to be granted access, when I go

 8     back, and try and find out at least something about the document, which I

 9     can then relate to you over the phone or via the videolink or in some

10     other way.  If you think that can help, I will do my best to see if the

11     documents are still there and, if so, to see what this is all about.

12        Q.   I can assure you the document is still there, because we acquired

13     it, Mr. Bjelosevic.  It's one of the financial documents remained.

14             Anyhow, I've dealt with that.  You don't know who this man is

15     other than, as you told us yesterday, he had something to do with the

16     JNA; is that right?

17        A.   Which man?

18        Q.   Yesterday, when I showed the report -- we can have it up again if

19     you want because we've looked this up.

20             MS. KORNER:  Can we have up document, please --

21             THE WITNESS: [Interpretation] Just tell me the name.

22             MS. KORNER:

23        Q.   The number one on your list.  The name I have such difficulty in

24     pronouncing.

25        A.   Bozovic.  Yes, we discussed him yesterday.  And I told you what I


Page 21042

 1     know about that man.

 2        Q.   Yes.  So you had no idea until I showed you this document, is

 3     that what you're saying, that this man was actually being paid as a

 4     policeman?  Is that what you're telling me -- or telling the Court,

 5     rather.

 6        A.   I don't know what exactly you said.  I received somewhat

 7     complicated interpretation of your words.

 8             Yesterday we talked about it.  And yesterday I said something

 9     about Bozovic.  And today I said, and I'm going to repeat it once again,

10     that in April there was no special group attached to the CSB, and I'm not

11     aware that those monies were paid for this period, and I don't know who

12     wrote this document.  And I am saying it once again: If the Chamber deems

13     it necessary I can, upon my return, try to figure out what is it -- what

14     this is all about.  I can really try to do that.

15        Q.   My question is: Before you saw this document, is it your

16     contention that you did not know that number one on this list,

17     Mr. Bozovic, was, on the face of it, in any event, a police officer?

18        A.   I know him as Major Bozovic.  I was told that he was a major.

19        Q.   All right.  Okay.

20             MS. KORNER:  Can we move to the next document, please, which

21     is -- oh, I'm sorry.  Your Honours, is this an exhibit?  I'm not sure.

22             JUDGE DELVOIE: [Microphone not activated] It is.

23             JUDGE HALL: [Microphone not activated] It is.

24             MS. KORNER:  It is.  Thank you.

25             Could I -- could we look next, please, at 20113, tab 26B of our


Page 21043

 1     documents.

 2             THE WITNESS: [Interpretation] Can I find it in this binder?

 3             MS. KORNER:

 4        Q.   No.

 5        A.   Okay.  Then I will look at it on the screen.

 6        Q.   All right.  Now, this is a document of actual payment, it looks

 7     like, because it's got signatures.  Can you --

 8             MS. KORNER:  Could we go, please, to the sixth page, please, in

 9     B/C/S.  And it's the fifth in -- in English.

10        Q.   Is there a signature there?

11        A.   Yes.

12        Q.   Do you recognise the signature?

13        A.   Yes.  This is the signature of Obren Petrovic.

14        Q.   All right.

15             MS. KORNER:  Let's go back, please, to the first page.

16        Q.   This is payment for the Special Unit Doboj.  What was the

17     Special Unit Doboj?

18        A.   Well, it's something -- probably something that was in the

19     station.

20             There is a document drafted by the chief of the station in

21     relation to obtaining supplies for the public security station, and this

22     document also stipulates who was in charge of that for the police.  And

23     the special police is mentioned there.  Nenad Kujundzic was in charge of

24     it, so I assume that this is a matter that you should clear with

25     Petrovic.


Page 21044

 1        Q.   Well, no.  Let's take this in stages, sir.

 2             This is clearly a relatively large unit of -- special police

 3     unit, 50 men, if we -- sorry, I suppose we better go to the --

 4        A.   Here I can see 20.

 5        Q.   Yes, all right.  Let's go --

 6             MS. KORNER:  Can we go to the third page, please, in each.

 7        Q.   All right.  We see 50 people all together listed.  I have skipped

 8     one of the pages.

 9             Now, wasn't this the equivalent of the Banja Luka Special Police.

10     This was the Doboj equivalent, Mr. Bjelosevic?

11        A.   I wouldn't say so.

12        Q.   Well, what else was it?  I mean, this is clearly something that

13     existed, isn't it?

14        A.   I'm doing my best.  Now I see the signature at the bottom on the

15     left, which I cannot recognise.  And the front page -- can I take a look

16     at the front page once again?

17        Q.   [Previous translation continues] ... I was going to go back to

18     the front page in any event.

19             Yes, you wanted to say?

20        A.   I wanted to see once again what's written here, because I'm doing

21     my best to explain it.  So it says Special Unit Doboj above

22     organisational unit, 18th of June.  I don't know.  I really don't know.

23        Q.   All right.  Well, let's take number one on the list.  You know

24     exactly who Mr. Karagic is, don't you, because you spoke about him last

25     time or when you were giving evidence in answer to questions by


Page 21045

 1     Mr. Zecevic?

 2        A.   Yes, I know him.  But there's no signature confirming that he

 3     received the money.  Have you noticed that?  I don't know what this is.

 4     And I see that there are some other names listed here without the

 5     signature that they've actually took the money.  Take a look at

 6     number 19, Starcevic, and also on the following pages.

 7             So I really don't know what this is about.  But if you're asking

 8     me who Slobodan Karagic, that I know.

 9        Q.   Yes, you've told him about him.  And you had dealings with

10     Mr. Karagic, didn't you?

11        A.   Well, I said that I was summoned to a court in a case against

12     him.

13        Q.   [Previous translation continues] ... yes, but you knew --

14        A.   I was a witness.

15        Q.   No, no.  Hang on.  You knew who he was, didn't you, in 1992, not

16     just when you were summoned to court as a witness.  I want to come back

17     to that later.  You knew exactly who Mr. Karagic was, didn't you, in

18     1992?

19        A.   No, no, no, I knew it.  I knew it.

20        Q.   All right.

21        A.   I knew -- yes.

22        Q.   And Mr. Karagic - I'm calling him Mr. Karagic - like the man we

23     looked at -- yes -- no.  Well, like Bozovic and yesterday's man --

24     Jorgic - thank you, Your Honour - was another murdering thug, wasn't he?

25        A.   I don't know that he was a murder.


Page 21046

 1             Let me just tell you one thing.  Up until the beginning of the

 2     war, I hadn't [Realtime transcript read in error "had"] been living for

 3     very long time in Doboj.  I suppose it's a sort of handicap for me, the

 4     fact that I didn't know the people well.  I began working in Doboj at the

 5     beginning of May 1991, and I came to live there sometime in November.

 6     However, I know that he was a taxi driver and that he was a rather

 7     problematic character.

 8        Q.   Well, that hides a multitude of --

 9             MR. ZECEVIC:  There is one intervention in the transcript.

10     48, 3, the witness says very short time in Doboj, not very long time in

11     Doboj.

12             MS. KORNER:

13        Q.   Well, problematic hides a multitude of sins, Mr. Bjelosevic.

14     Let's not beat about the bush.  He was a well-known criminal, wasn't he,

15     in the Doboj area?

16        A.   Well ... my information about that person is as follows:  He was

17     a taxi.  He smuggled foreign currency before the war.  Maybe this is not

18     really a proper way of saying things about him in public, but that's what

19     I know about him.  I don't know that he was a murder.

20             I am aware of a story about some activities of his - how should I

21     put it? - rather cruel activities directed at certain persons at the

22     beginning of the war.  I also known that currently he is serving sentence

23     for a criminal offence in the nature of robbery.  And if I remember it

24     well, the person who had been robbed was also wounded with a knife.  And

25     I think that he is currently serving the sentence for that.


Page 21047

 1        Q.   You're absolutely right about that, Mr. Bjelosevic.

 2             Finally, to move on, are you telling the Court, again, that you

 3     had no idea that Mr. Karagic was on the police payroll?

 4        A.   Karagic was in the military for a while, and he spent some time

 5     in the reserve police force.  I cannot tell you the exact dates, but he

 6     was part of both structures.

 7             MR. ZECEVIC:  I'm sorry, again, a part of witness's answer was

 8     not recorded and it might be important.

 9             49, 4, the witness named the -- the institution where the --

10     Mr. Karagic was in the reserve police force, and I think it's important.

11             MS. KORNER:

12        Q.   Well, you heard that, Mr. Bjelosevic.  Did you name where he was?

13        A.   Yes.  I said that he was in the reserve police force in the

14     police station in Doboj.

15        Q.   All right.  And let's now look, please, at a payroll for the CSB.

16             MS. KORNER:  Oh, Your Honours, that one's not an exhibit.  May I

17     ask that that be -- that one, can I say straightaway, we acquired

18     something like last week.  But, Your Honours, given that you say that

19     everything should be marked for identification, can we have this one

20     marked for identification as well?

21             MR. ZECEVIC:  Well, marked for identification, yes.  Nothing

22     else.

23             MS. KORNER: [Microphone not activated] I said that.

24             JUDGE HALL:  Yes.  So entered.

25             THE REGISTRAR:  That will be P2328, marked for identification,


Page 21048

 1     Your Honours.

 2             MS. KORNER:

 3        Q.   Now could you look, please --

 4             MS. KORNER:  Can we have up on the screen, I should say, document

 5     which is P1338.  Oh, tab 14F.

 6             All right.  Could we go to the next page, please, in both English

 7     and B/C/S.

 8        Q.   This is an advance -- sorry.  Yes, a list of employees to receive

 9     an advance salary, CSB Doboj.  It's stamped; is that correct?  Do you

10     recognise the stamp there?

11        A.   Yes.

12        Q.   Is that -- that's the Doboj stamp, is it?  The official Doboj

13     stamp.

14             MR. ZECEVIC:  Well, I'm sorry, if we can just specify which of --

15     because there are two stamps.

16             MS. KORNER:  Okay.  Certainly.

17             Let's take the large stamp first.  Let's enlarge it, shall we?

18     Can we see if we can get just the bottom bit.  Yep.

19             THE WITNESS: [Interpretation] Yes.  I think this is going to help

20     to explain some things.

21             MS. KORNER:

22        Q.   Can I ask questions, then you can give me an explanation, if you

23     want.

24             Is that -- please, is that large stamp the official Doboj stamp?

25        A.   Yes.  But it remains to be seen when it was legally valid.  This


Page 21049

 1     confirms what I was explaining earlier.  The lists were made

 2     retroactively.  There are several reasons for that.  If you want me, I

 3     can explain for every individual on the list who he or she is and why the

 4     name is on the list.  If that's important.  If not, it's all right.

 5        Q.   You can in a moment.  I just want, please, to establish certain

 6     things about this document and then can you tell me what you want -- or

 7     you can tell the Court, rather.

 8             There's a smaller stamp next to that.  What's that?

 9        A.   Let me take a look.  I cannot see what's written --

10        Q.   [Previous translation continues] ...

11        A.   -- on it.

12        Q.   [Previous translation continues] ... over the top, there's a

13     signature.  Is that your signature?

14        A.   Yes, yes.  This is my signature.  But you asked me to identify

15     the stamp.

16        Q.   Yes.  All right.  Is that the sort of official Doboj stamp?

17        A.   The big one, on the left, yes, it was the official stamp.  But

18     with all my effort I didn't manage to identify even the letters on the

19     small stamp.  I'm not sure whether it's Latinic or Cyrillic.  If I knew

20     the letters, then maybe I would be able to identify it.

21        Q.   All right.  Let's go back to the list and I will -- in one moment

22     can you give me the explanation you want to.  Does that show, as 1 and 2

23     yourself as the chief and Mr. Savic as the assistant chief?

24        A.   Yes.

25        Q.   Now --


Page 21050

 1        A.   That's what it says here.

 2        Q.   Explain, please, as you wish to, why it is that Mr. Savic, who

 3     you say wasn't a proper police officer, wasn't appointed until the

 4     23rd of June, is being paid for -- a salary for April 1992?

 5        A.   I'll explain it.

 6             You saw a number of documents which show that in April 1992 the

 7     centre worked with its full complement from before the war.  And

 8     according to the rules, the salaries should have been paid by the

 9     Ministry of Interior of BiH.  Due to wartime events and due to the fact

10     that the communications were cut off, the salaries were not paid.  These

11     were not paid at all during a period of time.

12             Subsequently, when some funds were acquired, it was decided to

13     pay the salaries retroactively.  Now, why did I state that it's a

14     fortunate circumstance that we identified this stamp?  This must have

15     been done at least in July.  Here you can see the names.  Jovo Josipovic,

16     that was a policeman in the traffic police station in Derventa.  And I

17     think that he arrived in Doboj sometime in May.  Then

18     Marija Cudic [phoen] was a technical secretary in the public security

19     sector.

20             So the lists were made retroactively.  This fact is confirmed the

21     new stamp which is in Cyrillic [as interpreted].  And another thing that

22     I remember from 1992 is that the lists were made, some of them very

23     orderly, some of them not so orderly, in order to justify the funds that

24     were taken from the safe of the public accountancy service and from the

25     bank.


Page 21051

 1             At the time, there was a huge inflation, daily inflation.  So

 2     after a month, this money could have been devalued, I think I'm not going

 3     to exaggerate if I say 1000 times.  So the nominal value in April, for

 4     instance, one dinar, it became 1000 times less valuable because of the

 5     inflation.  So it was convenient to justify things with these kind of

 6     documents.  You also could have seen from my notes that I wanted to

 7     explore this more thoroughly, and I don't know exactly how this story

 8     ended.

 9             As more Milan Savic, let me clarify one thing.  I believe you are

10     interested in this topic, so I would like to elucidate it.  Milan Savic

11     was the counter-sabotage technician.  However, his wartime assignment was

12     in a military unit.  As far as I know, his military booklet is in Teslic.

13     It was kept there, maybe even copied, and that's how it was established

14     that he belonged to that unit.  And he had to draw salary from somewhere.

15     And since this was made sometime in July, the person who made this list

16     simply wrote down that he was assistant commander, but we know, because

17     we saw the decision, from which date on he was the assistant commander.

18        Q.   Yes.  It's another piece of paper, I suggest, Mr. Bjelosevic,

19     that has very little to do with the reality of matters.  Why, hearing

20     what you say, that this was done afterwards to get people paid, did you

21     sign off for Mr. Savic to get paid as assistant chief in April, when you

22     say he was no such thing?

23        A.   His status in April was not as described here.  But since the

24     funds involved were so small, maybe this is going to sound incredible to

25     you, but I think that speaking in today's money this may have been 3 or


Page 21052

 1     4 euros.  This was really done to satisfy the formalities and to define

 2     status-related issues.  And as for that money's worth, it was really not

 3     significant at all.  So really no -- nothing really was gained here.

 4        Q.   But according to you it's not until June that Mr. Savic ever

 5     becomes a properly paid-up member of the police force.  Why did you agree

 6     for him not only to be paid wrongly, as assistant chief, but at all by

 7     the police, when you say he was in a military unit?

 8             JUDGE HALL:  If I may, Ms. Korner.

 9             MS. KORNER:  Certainly.

10             JUDGE HALL:  Mr. Bjelosevic, do I understand the effect of your

11     evidence to be - and these are my words, not -- I'm summarizing - that

12     this is an entirely fictitious document created for audit purposes only?

13             THE WITNESS: [Interpretation] No, I didn't say that it was made

14     for audit purposes only.  I was talking about the fact that the monies

15     were insignificant and that these payouts were more oriented towards the

16     purpose of status-related issues such as pension, social security,

17     numbers of years of service, and other things.  Because, in parallel with

18     these salaries, the contributions for social security and the pension

19     funds were paid as well, and that was the main purpose.  The amounts

20     mentioned here today would not be more than 3 or 4 euros, so nothing

21     would be gained from that.  The main purpose were status-related issues.

22             JUDGE HALL:  Thank you.

23             JUDGE DELVOIE:  Mr. Bjelosevic, is that why on one of the other

24     payrolls we saw, about the Doboj Special Unit, the amounts are, if I

25     remember well, 80.000 dinar for one month?  Or do I have that wrong?


Page 21053

 1             THE WITNESS: [Interpretation] I did not quite understand, I'm

 2     sorry.  It has to do with the previous list, does it?

 3             JUDGE DELVOIE:  Yes.  I think it was the first -- the first

 4     payroll you showed, Ms. Korner.

 5             MS. KORNER: [Microphone not activated] The first one was the one

 6     with Bozovic on it.  The second -- oh, sorry.

 7             The first one was Bozovic; the second one - I'll just need to get

 8     it out again.

 9             MR. ZECEVIC:  Perhaps we can call the document so the witness can

10     comment, because he doesn't have the documents with him.

11             MS. KORNER:  Okay.  It's 20 ... it was 20113, which has now got a

12     MFI number, but I can't remember what it was.  23 -- 2328.  Yes, 60.000.

13             JUDGE DELVOIE:  Hmm.  Yes, there it is.  80.000, 60.000, 45.000,

14     if I read that well.

15             MS. KORNER:  Yes.

16             THE WITNESS: [Interpretation] Yes.  Could you please tell me what

17     the question is now?

18             JUDGE DELVOIE:  My question is: Is the explanation you gave about

19     inflation and -- and what -- what the 6.000 or the 4.500 on the other

20     document means in real value?  Is that the explanation why, here, a

21     monthly salary seems to be 80.000 or 60.000 and not 6.000?  I mean, that

22     is a salary ten times more than the one that you received, if I go back

23     to the other document.

24             THE WITNESS: [Interpretation] Let me tell you that it all depends

25     on when this was written.


Page 21054

 1             If you followed what I was saying, one question had to do with

 2     regulating status-related issues for employees.  This was form rather

 3     than actual benefit.

 4             Secondly, as I have pointed out several times, there had to be

 5     justification for the money that went somewhere.  Then lists were made

 6     retroactively and then it said that salaries were paid out to such and

 7     such and such a person.  And given this staggering inflation, it was so

 8     convenient to justify it that way.

 9             May I tell you that for a long time everybody who lived in that

10     part of the world knew that one's salary would amount to a few drinks,

11     for example, and nothing more than that.  In those days, a salary was

12     symbolical basically, and it had to do with status-related issues.  In

13     these cases, it was also used to account for the money that someone had

14     taken somewhere.  To this day, I'm not sure whether light has been shed

15     on that properly.  And so on.

16             I don't know how useful this has been and how useful my overall

17     answer has been.

18             JUDGE DELVOIE:  I'm afraid not at all, Mr. Bjelosevic.

19             I was just wondering why a salary of one policeman on one

20     document is 60.000 and the salary of another policeman on another

21     document, pertaining to the same month, is 6.000.  I mean, that's a

22     different you can't explain unless it would be the explanation of

23     inflation, I don't know.  I just -- I just try to understand what -- what

24     was going on then.

25             THE WITNESS: [Interpretation] Now I understood you better.  It's


Page 21055

 1     not the same month.  That was made for the month of April, so certain

 2     proportions were taken into account, and you see that this has to do with

 3     the month of May.

 4             Inflation was -- I don't know.  I cannot go into the actual

 5     figures involved.  It was terrible.

 6             JUDGE DELVOIE:  Okay.  So this would be just the inflation -- the

 7     effect of the inflation in one month?

 8             THE WITNESS: [Interpretation] Yes.

 9             JUDGE DELVOIE: [Previous translation continues] ... okay.  Thank

10     you.

11             THE WITNESS: [Interpretation] Yes, yes.  Even on a daily basis,

12     yes.

13             MS. KORNER:

14        Q.   I'd just like to go back to my original question, is:  Why, for

15     whatever purpose, you signed off a document that would give Mr. Savic a

16     salary when he wasn't, according to you, even a member of the police in

17     April, let alone assistant chief?

18             JUDGE HALL:  Ms. Korner, the reason why I had intervened, it was

19     because of the question that you had asked.  Because if, as I -- although

20     the witness didn't accept my suggestion, if -- and in his later answer to

21     Judge Delvoie -- the impression I had is that this was window dressing of

22     some form or other.  And I don't know that the --

23             MS. KORNER:  But, Your Honours, window dressing -- no, no, my --

24     well, we ought to confirm this with the witness.  My understanding is

25     they didn't get paid in April when they should have got paid in April.


Page 21056

 1     And so this was a retroactive method of achieving payment.  That was my

 2     understanding of what the witness said.  Not that this was simply a

 3     document put together for the purposes of accounting for money that had

 4     gone.  He said they should have been paid by BiH; they weren't.

 5             JUDGE HALL:  And your question is specifically that among those

 6     who should have been paid, is --

 7             MS. KORNER: [Overlapping speakers] ... Mr. Savic.

 8             JUDGE HALL:  Yes.

 9             MS. KORNER:  That's exactly the point I'm trying to get across.

10        Q.   So what I'm trying to -- Mr. Bjelosevic, accepting, let's say,

11     for the moment, what you say, that this was a back-dated document, why

12     would you sign off on Mr. Savic getting paid for April when he had never

13     been paid -- sorry, he had never, in April, been a member of the police,

14     on your account?

15        A.   Obviously you have misunderstood some of the things I've said.

16             I don't know who has the document, the copy of Milan Savic's

17     military booklet.  You will see there that already in 1991 he received

18     his war assignment in that unit.  If you look at the information

19     bulletins, you will see that Milan Savic, as a technician for

20     counter-sabotage protection, went to on-site investigations in 1991 and

21     1992.

22             Now, what happened?  His regular --

23        Q.   [Previous translation continues] ... no, I'm --

24        A.   -- status --

25        Q.   [Previous translation continues] ... no, I'm sorry.  Again I'm


Page 21057

 1     going to stop this.  Was he -- no, I'm sorry --

 2             MR. ZECEVIC:  No, no, but, Ms. Korner, the witness gave the

 3     answer.  I'm trying to find it because there is -- there is obviously a

 4     misunderstanding.

 5             MS. KORNER: [Microphone not activated] ... well, can I -- that's

 6     why I want to short-circuit.

 7             MR. ZECEVIC:  No, no, no, but please ask the question -- I mean,

 8     clearly to the witness, because he already gave the answer and you missed

 9     the answer.  And that is the problem which is confusing the witness and

10     all of us, I guess.

11             MS. KORNER:  There is a simple way.

12        Q.   Was -- in April, was Mr. Savic a member of the police?

13        A.   Yes.  He never severed his employment with the MUP.  If you want

14     to be sure that what I'm say is correct, do ask the MUP of BH for lists.

15     I think that they had received copies, and you will see that for

16     January and February and March his salary had been paid out to him, but

17     his military assignment was in that -- his war assignment was in that

18     military unit.

19             Perhaps you do not fully understand it, but that's the way things

20     were.  And then in April it went on.  He did not ask for termination of

21     employment.  Disciplinary measures were not taken against him in the

22     ministry.  He was still an employee of the ministry.  You will see, in

23     April, from the bulletins and the rest, you will see that the man went to

24     on-site investigations, that he was working as a technician.

25        Q.   [Previous translation continues] ... that's fine.  That's


Page 21058

 1     absolutely fine.

 2             MR. ZECEVIC:  I just found the reference, so I can give you 53 --

 3     page 53, 3 and 4, where he says Milan Savic was the counter-sabotage

 4     technician.  And it is my understanding that he was employed by MUP at

 5     the time, as a counter-sabotage technician in the MUP.

 6             MS. KORNER: [Microphone not activated] ... I'm prepared entirely

 7     to accept that -- that I thought he was referring to the military.

 8     That's fine.

 9        Q.   So he was working in the police, but he was not, you say, the

10     assistant chief in April?

11        A.   [No interpretation]

12        Q.   Right.  I want to ask you one last -- about one last name on

13     this --

14             THE INTERPRETER:  Interpreter's note:  We did not hear the

15     witness.

16             MS. KORNER:

17        Q.   You said yes, I think, didn't you?  He was working for the police

18     but wasn't assistant chief; the answer to that is "yes"?

19        A.   That's right, yes.

20        Q.   One last question about a name -- it's a very lengthy document.

21     It seems there were a lot of employees.

22             MS. KORNER:  Can we go, please, to --

23             JUDGE HALL:  If it's a lengthy document --

24             MS. KORNER:  No, I only want to look at one name.

25             JUDGE HALL:  I see.


Page 21059

 1             MS. KORNER:  And then -- I know, Your Honours, we've gone a

 2     little past the break.

 3             Page 9 in English and --

 4             MR. ZECEVIC:  I'm sorry, I don't want to confuse or anything, but

 5     can we -- we didn't get which document.  You said page 9, but --

 6             MS. KORNER:  Oh, sorry.  We have to go back to the other.  I had

 7     forgotten we'd gone into this document.

 8             All right.  13 -- 1338.  Page 9 in English; page -- and 9 in

 9     B/C/S.  Page 9 in B/C/S, please.  There we are.

10        Q.   April, signed off by you again, is it, Mr. Bjelosevic?

11     Mr. Karagic.  And as you point out, inflation was enormous because for

12     April you're going back to 4.000.

13        A.   You said my signature?

14        Q.   Is that your signature at the bottom?

15        A.   No.  That's not my signature.

16        Q.   All right.  Whose signature is that?

17        A.   I cannot recognise it.

18                           [Trial Chamber confers]

19             MS. KORNER:  It's the same exhibit, Your Honours.  It's the

20     whole -- the --

21             JUDGE DELVOIE: [Microphone not activated] ... is that 14F --

22             MS. KORNER:  It's tab 14, yes.

23             JUDGE DELVOIE: [Microphone not activated] F?

24             MS. KORNER:  14F, which starts with the document with

25     Mr. Bjelosevic or whatever, and it goes all the way through for about


Page 21060

 1     nine pages.

 2        Q.   So whose signature is that?

 3        A.   I have no idea.  I cannot identify this signature.

 4        Q.   You still say you didn't know that Mr. Karagic was being paid as

 5     a member of the police?

 6        A.   I told you that Karagic was in the military for a while and in

 7     the reserve police, milicija, for a while too.

 8             MS. KORNER:  Your Honours, I'm just checking.  I don't think this

 9     one is an exhibit either.  So could I have that, please, marked for

10     identification.

11             JUDGE HARHOFF:  Yes, it is.

12             MS. KORNER:  Oh, right.  So it is.

13             MR. ZECEVIC:  Yes, but, Your Honours, I have -- I have -- now I

14     have a problem with this document.  Because the first -- sorry, six or

15     eight pages are the documents which have two stamps.  And the last three

16     are the documents which have -- the last three, yes, just have one stamp,

17     the small stamp, and it's obvious that the signature is different, at

18     least to me.

19             Now, maybe after the break we can come back to this and discuss

20     it a bit more.

21             MS. KORNER:  Well, Your Honours, can I say, I don't know whether

22     this is a question on the provenance, these -- we can actually call the

23     witness who seized the documents from Doboj.  So there is no problem

24     about this.  If there's a suggestion that these documents come from

25     anywhere else, these were recovered from the Doboj CSB archives.


Page 21061

 1             MR. ZECEVIC:  My problem is that this document is given one

 2     exhibit number, and it's obviously that it consists of two sets of

 3     different documents.  That is my problem.  And it's given one exhibit

 4     number.

 5             MS. KORNER:  Well --

 6             MR. ZECEVIC:  That is misleading, yes.

 7             MS. KORNER:  Well, Your Honours, I don't know whether it's

 8     separate or not.  If there's going to be a discussion about this, it's

 9     something to be adjourned.  Is this the way in which it was put together

10     as a document.  You will see that it contains continuous ERN numbers, I

11     think.  Yes, it does.

12             JUDGE HALL:  And, of course, step one would be to see how it was

13     entered -- why it was entered as one exhibit.

14             MS. KORNER:  Well, yeah, I mean, that's not -- we can't -- I

15     mean, without -- I mean, I suppose we could find out, but, Your Honours,

16     in any event, that is already an exhibit and that's all we need.

17             JUDGE HALL:  So we take the break now.

18                           [The witness stands down]

19                           --- Recess taken at 12.14 p.m.

20                           --- On resuming at 12.37 p.m.

21                           [Trial Chamber confers]

22                           [The witness takes the stand]

23             MS. KORNER:

24        Q.   Mr. Bjelosevic, I just want you to look at two more documents

25     very briefly on the question of payment, and then we will move on to a


Page 21062

 1     another topic.

 2             This is actually a Defence document with the ERN 198D1, and it

 3     was tab 62 of their bundle, so you've probably got it in hard copy,

 4     Mr. Bjelosevic.  65 ter, sorry.  Not ERN.

 5             That's apparently a payment order for the various SJBs that came

 6     within the CSB Doboj area.  Is that -- is that your signature at the

 7     bottom?

 8        A.   The lower right-hand corner?  Yes.

 9        Q.   Yes.  So, in fact, you did see payment documents, didn't you,

10     because you were obliged to sign off on them?

11        A.   Well, I saw the ones I signed.  No denying that.  But this ...

12        Q.   All right.

13             MS. KORNER:  Your Honours, I don't think it's been exhibited, so

14     can I ask that -- and this is from the Defence, so I'm not sure whether

15     this falls into the category of the same documents.

16             MR. ZECEVIC:  No objection.

17             MS. KORNER:  Thank you.

18             JUDGE HALL:  Admitted and marked.

19             THE REGISTRAR:  Your Honours, that will be Exhibit P02329.

20             MS. KORNER:

21        Q.   And, finally, can we just look at one other payment slip which is

22     the ... 20112.  And, sorry, it's tab 24J.

23             Now, this is Mr. Savic.  Salary payment for April and May 1992 is

24     how the document is headed.  Dinars, 100.000, which, from the sound of

25     it, is not as much as one might think.  But whose -- who is the


Page 21063

 1     signature?  Do you recognise that?

 2        A.   Well, I'm looking at it, and it says Milan Savic in the lower

 3     right-hand corner, but I'm not sure that this was his signature, unless

 4     he signs his name in two different ways.

 5             Cashier, I cannot identify that person's signature.  And then on

 6     the left-hand side there is another official.  I cannot recognise these

 7     signatures.

 8        Q.   Even with inflation being what it was, do you know why Mr. Savic

 9     was receiving 100.000 dinars in -- for his salary in April and May?

10        A.   I don't know who he received this from, believe me, and why.

11             Well, you see that this ... I don't know.  I see what is written

12     here.  To who, Milan Savic.  And personal income for April and May 1992,

13     and the amount, the signature cannot be identified.  Unless he signed his

14     names in two different ways, I think ...

15        Q.   [Microphone not activated] ... well, that's not -- I don't think

16     I need to see that any further.  Thank you.

17        A.   I don't know.

18        Q.   Thank you.  Now you can put that away.

19             Let's move on to a different topic, and that's really

20     instructions and orders from Mr. Stanisic.

21             JUDGE HARHOFF:  Before we leave this topic, Ms. Korner, I'd like

22     to try and sum up with the witness a bit about his knowledge of the

23     existence of this special unit.

24             Many of the documents which we saw in the last session just now

25     were making reference either to a special unit or a special group, and


Page 21064

 1     also to the special police, and I'm unsure about what your testimony is

 2     in relation to these groups.

 3             So could you please summarize to the Chamber what was your

 4     knowledge in the spring of 1992 about the existence in Doboj of something

 5     called either a special group, or a special unit, or the special police.

 6             THE WITNESS: [Interpretation] As regards certain documents that

 7     are related to that topic, I have spoken about each and every one of

 8     these documents.  But by way of a summary, I know that in the public

 9     security station there was a special purpose unit that, as such, had not

10     been prescribed within establishment as a special purposes unit.  That

11     was in all stations.  And that unit was made up of regular policemen.

12     The most able policemen were selected for certain activities and

13     specialized activity.  If there were to be a serious disruption in law

14     and order or in some other possible emergencies, they would get together

15     and go as such a unit.  They also received certain training.

16             I know that that existed within stations, and I know that in the

17     beginning of 1992 this unit was engaged in reinforced checks in town.

18     This was already in March.  And I know that the Ministry of Interior of

19     Bosnia and Herzegovina, for the purposes of those units, they brought to

20     the stations camouflage uniforms for these men.  From time to time, they

21     were engaged as this kind of special purposes unit, but, otherwise, they

22     worked as regular policemen within those stations from which they had

23     come.

24             I don't know whether I've been clear enough.

25             JUDGE HARHOFF:  You have provided some details about this.


Page 21065

 1             But let me just be sure that I understood it correctly,

 2     Mr. Bjelosevic.  Are we to understand that in -- in all or at least in

 3     most of the seven SJBs which fell under the jurisdiction of the

 4     Doboj CSB, such special purposes police units were assigned and ready to

 5     go into action whenever needed?  But outside such actions, they were just

 6     regularly -- regular policemen; but when special action, special purposes

 7     actions were needed, then these police officers would assume their role

 8     in those units?

 9             THE WITNESS: [Interpretation] Yes.  But let me correct you:

10     There were nine stations within the CSB Doboj, not seven.  For the rest,

11     that's right.  There were the regular forces dealing with ordinary

12     duties, and there was this group, a part who would be called in as the

13     need arises.

14             JUDGE HARHOFF:  And, if I understood you correctly, this was a

15     system that was already in place from before the conflict?

16             THE WITNESS: [Interpretation] Yes, yes.

17             JUDGE HARHOFF:  Very well.  Now, if we go back to the documents

18     that we saw in the last session, reference was made to something called a

19     Special Group.

20             My question to you now is:  Would the Special Group be an example

21     of these special purposes units?

22             THE WITNESS: [Interpretation] No.  The lists we were looking at,

23     which specifically mention the Special Group, I said that I only

24     recognised one of the men, Nenad Kujundzic, oh, as well as

25     Radojica Bozovic who was name number one on the list, that those were the


Page 21066

 1     ones that I knew, and the other men were unknown to me.  And I don't know

 2     that there was a special group or a special unit that was active within

 3     that structure at the time.

 4             JUDGE HARHOFF:  But, Mr. Bjelosevic, your answer to me suggests

 5     that you knew by heart all the names of the police officers in the nine

 6     SJBs who had been assigned especially to these special purposes units.

 7             Is that correct?

 8             THE WITNESS: [Interpretation] But no, no.

 9             JUDGE HARHOFF: [Previous translation continues] ... but how,

10     then -- how, then, could you be so sure about the Special Group, which

11     was referred to in this document, was not a special purposes unit?

12             THE WITNESS: [Interpretation] Since this involves a station which

13     was headquartered together with the centre, I would identify or recognise

14     the individuals on the list.

15             JUDGE HARHOFF:  Did there exist in April and May 1992 a special

16     purposes unit in the Doboj SJB?  And did you know the names of the

17     officers who had been assigned to that unit?

18             THE WITNESS: [Interpretation] As part of the active police force,

19     I did know some of the men from the Doboj Station, and they existed, as

20     such, in the month of April.

21             As for the month of May, the circumstances were completely

22     different, and the structure was significantly increased through the

23     reserve force.  As I said, I don't recognise any of the names on the

24     list, save for the names under numbers 1 and 11, and I'm referring to the

25     document which reads:  "Special Unit" -- "Special Group."


Page 21067

 1             JUDGE HARHOFF:  If we look at the other documents that were shown

 2     to us in the last session which refer to a special unit - we saw two or

 3     three payrolls to members of special units - would those units be

 4     identical to the special purposes unit to which you have now made

 5     reference?

 6             THE WITNESS: [Interpretation] If you're referring to the

 7     personnel, the police officers, I don't think so.

 8             JUDGE HARHOFF:  Excuse me for drilling around in this matter,

 9     Mr. Bjelosevic, but, you see, your evidence is crucial for us to

10     understand what the situation was in Doboj in the spring of 1992.  You're

11     telling us that there was something called special purposes units and

12     that such units were composed of members of the regularly -- of the

13     regular police forces in each of the SJBs and that these units would be

14     called into function as the need arose.

15             So this leaves the impression with the Court that in all of the

16     nine SJBs there were a small number of police officers who had been

17     assigned membership of these units and that they would enter into action

18     upon the orders of their superior.

19             Then we have evidence about something which is called a

20     Special Group.  And your evidence is that you knew the names of some of

21     the members of this Special Group but that you were otherwise unaware of

22     the existence.

23             Then yet other documents made reference to something called

24     special units.  And here again you say that you had no knowledge of any

25     such group -- or any such special units.


Page 21068

 1             This is a very confusing picture, and the assumption that would

 2     be obvious to make - perhaps wrongly - would be that the groups to which

 3     we have seen reference in these documents - special groups, special

 4     units - were, in fact, the special purposes units to which you yourself

 5     made reference in the beginning.

 6             So let me start out by asking you now again:  Is that a

 7     misrepresentation of your evidence?

 8             THE WITNESS: [Interpretation] I think that it is, and I'll tell

 9     you why.

10             If you look at the head count on the list which reads

11     "Special Group," and if you look at the head count on the list which read

12     "Special Unit," neither the head count nor the personnel themselves add

13     up.  Therefore, my conclusion is that this is not in any way the

14     prolonged or carried-over form of what was previously the special

15     purposes unit.

16             JUDGE HARHOFF:  Right.  So the Special Groups or the

17     Special Units to which the documents referred are completely different

18     than other groups than those whom we have been -- whom have been referred

19     to as special purposes units.

20             THE WITNESS: [Interpretation] Yes, that is my conclusion.  Yes.

21             JUDGE HARHOFF:  Very well then.  The next question obviously is:

22     If you then claim that you were unaware of the existence of these foreign

23     groups, for lack of any better expression, that is to say, the special

24     groups or the special units, they may have been formed at the SJB level

25     or even at the CSB level as a reaction to some of the problems that were


Page 21069

 1     imminent at the time.  But you, as chief of the CSB, were you not aware

 2     of that?

 3             THE WITNESS: [Interpretation] This was not set up at the level of

 4     the CSB because there was no one to do so in view of the fact that the

 5     centre was not operational.

 6             At the level of the station itself, there was one point where the

 7     station had around 2.200 [as interpreted] police officers at its

 8     disposal.  Given that various regrouping was going on in different

 9     periods for different purposes as dictated by various actions, I don't

10     know exactly how it all unfolded.  There were great many people.  They

11     were ten reserve stations.  Now, how they went about organising these

12     individuals and deploying them to the battlefield, that's something that

13     I wouldn't know, not in detail.

14             THE INTERPRETER:  Interpreter notes the number is

15     1.200 policemen.

16             THE WITNESS: [Interpretation] And let me add this:  Now that I

17     looked at these lists, one thing that strikes me as confusing is that I

18     can't seem to be able to recognise the signatures at the bottom.

19             JUDGE HARHOFF:  Well, let us just conclude, then, that, in your

20     evidence, it was possible that special groups and also special units

21     could have been formed at the SJB level but that you were just not sure

22     about whether this, in fact, had happened.

23             THE WITNESS: [Interpretation] That's roughly how it was.

24             JUDGE HARHOFF:  Let us then move to the last group, the

25     Special Police.  I think Ms. Korner asked you whether the group in Doboj,


Page 21070

 1     which was referred to as Special Police, was, in fact, a formation

 2     similar and parallel to the Special Police in Banja Luka, and I think

 3     that your answer was negative.

 4             So if we go back to the beginning of this matter, was there, at

 5     any point, a Special Police formed in Doboj?

 6             THE WITNESS: [Interpretation] Yes.

 7             JUDGE HARHOFF:  Do you remember when it was formed and how long

 8     it operated?

 9             THE WITNESS: [Interpretation] Yes.  I think it was in early

10     October 1992 that a Special Police detachment was set up as part of a

11     Special Police brigade of the MUP of Republika Srpska.

12             The detachment was stationed in Doboj and deployed as per orders

13     and authorisations from the commander of the special brigade, Milenko --

14             THE INTERPRETER:  The interpreter didn't catch the last name.

15             THE WITNESS: [Interpretation] Karasik.

16             JUDGE HARHOFF:  And what was the name of the head of the

17     detachment in Doboj, of the Special Police?

18             THE WITNESS: [Interpretation] At first it was Milorad Radulovic.

19     And Nenad Gojkovic replaced him.

20             JUDGE HARHOFF:  Thank you.  That was all I wanted to know about

21     this.

22             MS. KORNER:

23        Q.   Just -- just so you understand, Mr. Bjelosevic, however, we

24     suggest that, from what one can see on the papers and the evidence, that,

25     in fact, there was a Special Police - whatever name it had - led by


Page 21071

 1     Mr. Karagic operating through April through to August, whenever.  Long

 2     before -- or before the October Special Police.

 3        A.   I didn't deny that.  What I'm saying is that I don't know.  I

 4     know that Karagic did have a unit of his, which operated within the army

 5     for a while and then within the police reserve force of the

 6     Doboj Station.

 7        Q.   All right.  Well, I do want to leave the topic.

 8             I want to look now, please, at the question of orders that came

 9     from Mico Stanisic.

10             MS. KORNER:  Could we have a look, please, at a document which

11     was a Defence document.  It's 1D0046.

12        Q.   And it's actually in -- in was in their -- it's in their bundle,

13     Mr. Bjelosevic, at tab 47.

14        A.   40 ...

15        Q.   47.  This is the 15th-of-May order which is number 1 of 91 -- of

16     9 -- sorry, 92, it looks like, or it's 01, which means the minister,

17     we've been told, 1/92.  And I think you looked at it before.  And it's

18     about the setting up of war units.

19             Now, I want to understand, please, from you which orders you got

20     at the time and which you say you didn't.  Did you get this order from

21     Mr. Stanisic dated the 15th of May on or about the 15th of May?

22        A.   I did, though I don't know when it reached us exactly.  I said

23     earlier on that the deputies went to attend an Assembly meeting at Pale.

24     They flew in by helicopter, and I think that it was on their way back

25     that some of them brought it along.


Page 21072

 1        Q.   Yes.  So this -- when you say "on their way back," they went to

 2     see Mico Stanisic in his headquarters in Pale?  Or in the office of the

 3     MUP.  Is that what you're saying?  Well, not Mico -- maybe not him

 4     personally, but his assistants or whoever.

 5        A.   The deputies went to attend an Assembly session, and they were

 6     taken over there by helicopter by the army.  And their presence at the

 7     assembly session was seen as an opportunity, since the communication

 8     lines were down, the telefax wasn't functioning, et cetera, to give them

 9     copies to take along, and as they returned, among other things, they

10     brought along this order.

11        Q.   I understand that.  I know that's what you're saying.  What I

12     want to know is, Who did they tell you had given them these documents?

13     How did they get them?  Did they get them from Mico Stanisic himself or

14     from one of his assistant ministers or from his secretary?  Who?

15        A.   I wasn't given this in person either.  As I returned to my

16     office, my secretary handed me over an envelope containing a number of

17     documents, including this order.

18        Q.   All right.  Look, please, at the next document in this sequence

19     which is at -- it's back to the documents we've put in.

20             MS. KORNER:  It's at tab 18 of our documents, and it is P459,

21     thank you.  Oh, 559.  P455.

22        Q.   Now this is based on the same decision by Mico Stanisic, and he

23     appoints you to the position of chief of the Doboj CSB and then member of

24     the Serbian Republic, et cetera, of the staff, "... command and control

25     of the overall ministry of interior forces," and it puts you in --


Page 21073

 1     appoints you to the staff for command and control of the ministry's

 2     forces.

 3             Now, did you get that one?  And, if so, was that at the same

 4     time?

 5        A.   Yes.  Yes, I think the documents arrived together.

 6             If you recall, I did say that the defence exercise [as

 7     interpreted] was priority number one, and that's how matters were put in

 8     place.  That's how the structure was established, and that's how the

 9     tasks were set out.

10             MR. ZECEVIC:  I'm sorry, I note that the -- on 74, 7, it's

11     recorded "the defence exercise."  I don't ... I don't think that's what

12     the witness says.  So, please, if you can verify that.

13             MS. KORNER:

14        Q.   You said you thought the documents arrived together.  What did

15     you say after that?

16        A.   Yes, I did say that I thought the documents arrived together.

17     And that, as I said earlier, defence, as such, was priority number one.

18     And I think that it transpires from the order that this is how matters

19     were arranged.

20        Q.   All right.  And third document in this sequence, please, is P564;

21     20A of our binder.

22             This, again, refers back to that first order, 15th of May.  It's

23     addressed to the five CSBs.  Signed by Mico Stanisic, apparently.

24             Did you get that in the same batch from your deputies when they

25     returned from Pale?


Page 21074

 1        A.   I don't know.  Perhaps.

 2        Q.   All right.  Well, is it something that you've seen before?

 3     Because if we look at the top, somebody has written, "Was not given to

 4     Doboj; sent by courier."

 5        A.   Yes.

 6        Q.   What I want to know is, according to you, it was impossible for

 7     you to get to Pale except by this helicopter.  I say "you"; anybody who

 8     was in Doboj to get to Pale.  How did the courier get from Pale up to

 9     Doboj on the 18th?

10        A.   Well, who's to say that the courier did arrive?  He could not

11     have, need not have arrived.  Who knows through which routes and when it

12     reached us.  It is a generally-known fact that it was only on the

13     28th of June that passage was possible and only under armed escort.

14        Q.   [Previous translation continues] ... I don't -- may I say

15     straightaway, Mr. Bjelosevic, I don't accept that at all.  Difficult it

16     may have been, but I suggest to you that there was communication, even

17     while the corridor operations were going on, by courier and indeed by

18     phone and special radios.  And I say -- well, I say, isn't this an

19     example of exactly that?

20        A.   I have to tell that you, indeed, are not right at all when you

21     say that it was possible to get through.  I'd really like to see who took

22     that route going from Sarajevo to Doboj at the time, unless the courier

23     took a helicopter as well.

24        Q.   All right.  Now, you were shown originally a note of a meeting of

25     the Doboj Crisis Staff, and this is how you came up with -- you gave the


Page 21075

 1     account of how you received these documents.

 2             Can you give us a rough idea of when the Assemblymen, the

 3     deputies to the Assembly, went off and collected these documents, having

 4     attended the Assembly?

 5        A.   I truly cannot recall.

 6        Q.   Mm-hm.  Who were the Assemblymen who went there?

 7        A.   Well, there were a few Assemblymen from Doboj.

 8             THE INTERPRETER:  Interpreter's note:  Could all other

 9     microphones please be switched off.

10             THE WITNESS: [Interpretation] It was Mr. Joldic Miodrag.

11             THE INTERPRETER:  The interpreter did not hear the first name.

12             THE WITNESS: [Interpretation] And there was

13     Mr. Mladenko Vasiljevic.  Those were the MPs from Doboj.  There was a

14     military helicopter, and I don't think that it was only these three men

15     who were in the helicopter.  There were other Assemblymen who were taken

16     to that session who came from that area.  I don't know whether they

17     actually went.  I'm just saying who the MPs from Doboj were at the time.

18             MS. KORNER:

19        Q.   You see the -- the evidence shows that the 16th Session of the

20     Assembly of Republika Srpska took place on the 12th of May in Banja Luka.

21     The next session, the 17th Session, only took place in July, 24th to 26th

22     of July, in Jahorina.  Are you saying that you didn't get any of these

23     decisions until July?

24        A.   I don't know when I got them.  I've already said that I don't

25     know when I got them, but I found them on my desk, and the secretary


Page 21076

 1     explained to me how they were brought there, that they were brought by

 2     the Assemblymen who were in Pale and who brought them from there.

 3             Perhaps that may be important for you now, but at that point in

 4     time it wasn't really important for me.  The men were up there, and they

 5     brought this mail, and it really wasn't important for me to deal with any

 6     details and to remember it, but I'm just telling you how it happened.

 7        Q.   Well, let's take this in stages, shall we, Mr. Bjelosevic.

 8             You said on more than one occasion this helicopter went off,

 9     there was no method of getting to Pale because of the corridor, no

10     communication.

11             In July, on the 24th of July, 26th of July, the corridor was

12     open, wasn't it?

13        A.   Yes.

14        Q.   On the 11th of July, you had gone up to Belgrade to attend this

15     meeting?

16        A.   Yes.

17        Q.   So it is absolutely inconceivable, isn't it, that you didn't get

18     all these earlier decisions until the 24th -- after the 26th of July?

19        A.   Well, that's not what I said.  I am just saying that I don't know

20     the exact date when this arrived and - I repeat - how I received these

21     documents.  You are forcing me now to say a date which I simply cannot

22     recall.  And I just don't want to say anything, because that would not be

23     serious on my part.

24        Q.   Well, no.  I'm just asking you how it is that you said over and

25     over again that it was when the local deputies went to attend the


Page 21077

 1     Assembly is when you first got these decisions of Stanisic.  Because it's

 2     not possible, is it, Mr. Bjelosevic?  That cannot be the way it happened.

 3        A.   I really don't know what you wish to achieve by all of this.  I

 4     keep telling you how I found the documents in my office and what my

 5     secretary said to me on that occasion, that the documents were brought by

 6     the MPs when they were in Pale, where they went by helicopter.  I really

 7     don't know what the point is.  I don't know what you're getting at.  I

 8     really don't know what else to answer.  I don't see what the point is.

 9        Q.   The point is, Mr. Bjelosevic, that I suggest that throughout the

10     whole of your evidence, virtually from when you started, you have

11     attempted to distance yourself from any responsibility for the appalling

12     events that took place in Doboj.  That's the suggestion that I'm making

13     to you.

14        A.   And you are entitled to do so.

15        Q.   Now, you did, in fact, did you not, carry out Mico Stanisic's

16     instructions, because the police in Doboj were organised into these, what

17     I'm calling generally, wartime units.

18        A.   The police operated as a detachment.  It operated as a unit.

19     What you're trying to do is to break the continuity that started in early

20     April 1992.  The orders from the MUP of the Socialist Republic of

21     Bosnia-Herzegovina were the ones setting the course of activity.  You saw

22     the orders which said that units of the TO, volunteers, et cetera, should

23     all be admitted onto the police force.  So there is a continuity of these

24     formations from that period on.  You also have the order by Mr. Stanisic.

25     But what I'm telling is that this sort of structure was -- existed from


Page 21078

 1     before.  We also have them in the dispatches dating from April.

 2        Q.   Mr. Bjelosevic, I've already dealt with your attempt to take this

 3     back to Mr. Jasarevic's order before the MUP split.  But you, in fact,

 4     put into execution, didn't you, because you were the only person who had

 5     the authority to do it, Mico Stanisic's order that the ministry forces

 6     should be organised into war units.

 7             You yourself put that into effect, didn't you?

 8        A.   I'm saying to you again:  Look at when the minister -- when

 9     Minister Stanisic wrote the order.  Look at the date of the order.  When

10     it exactly arrived Doboj, I cannot establish the date.

11             As for the reserve police force, it had reached very high levels,

12     and I know that I discussed the subject with the chief of the station as

13     well and that that comes from these two dispatches, namely, that units of

14     the TO, volunteers, et cetera, become part of the reserve police units.

15             You see, you have ample evidence to that effect that it was so.

16             MR. ZECEVIC: [Previous translation continues] ... I'm sorry, the

17     main point of the answer was not recorded.

18             The witness said something I don't want to say because we can

19     clarify that with the witness.  "As for the reserve force, it had reached

20     very high levels," and he said when.  And it wasn't recorded.

21             MS. KORNER:

22        Q.   Is that right, Mr. Bjelosevic?  Did you tell us when the reserve

23     forces reached a very high level?

24        A.   Yes, yes.  I said that it was before that order, that this

25     increase took place in April.  And already by the end of April and in


Page 21079

 1     May, at the beginning of May, rather, it was a very large number of

 2     people.  It was the --

 3             THE INTERPRETER:  The interpreter did not hear the number.

 4             THE WITNESS: [Interpretation] I said another thing.  When I

 5     spoke -- when I saw what was going on, I talked about this to the chief

 6     of the police station and I discussed the subject.  I said it was

 7     dangerous.  I said that it was something that was difficult to keep under

 8     control.  And he said, We have the order.

 9             All the stations received the order of the then-ministry to act

10     in that way.

11             MS. KORNER:

12        Q.   Right.  So that you understand clearly, I suggest, as that

13     document we looked at that says "send by courier to Doboj," you got --

14     you were there and you got these documents at or about the time they were

15     issued by Mico Stanisic.

16        A.   I don't know exactly when it arrived.

17        Q.   All right.  Now can we look, please, at the functioning of the

18     CSB Doboj, which you say did not function between the 3rd of May and the

19     beginning of July.

20             MS. KORNER:  Can we look, first of all, please, at -- it's really

21     a continuation of the earlier documents that we just looked at.  20005 at

22     tab 22 of our documents.

23             THE WITNESS: [No interpretation]

24             THE INTERPRETER:  The interpreter did not hear the witness.

25             MS. KORNER:


Page 21080

 1        Q.   Sorry, you said something, Mr. Bjelosevic, which the interpreter

 2     didn't catch because my microphone was on.

 3        A.   I asked whether it -- oh, all right.

 4        Q.   You have to look at it on the screen.

 5             That's a document dated the 21st of May.  Handwritten:  "Sent to

 6     the Serbian MUP Security Services Centre, National Security Service" and

 7     appears to be signed.  That your signature at the bottom?

 8        A.   Yes, down here.

 9        Q.   So on the 21st of May you were asking Banja Luka, with whom you

10     had communications, to forward the telegram to the MUP headquarters in

11     Pale to check on a Dutch correspondent apparently named E.L.M. Robert.

12     And someone else called Dulmers.  Or was it the same person?

13        A.   Through the middle, along that vertical line, the letters are

14     missing and I'm trying to decipher what it says.

15             MR. ZECEVIC:  I believe the second page of the document is a

16     better or --

17             MS. KORNER:  Yes, I've just noticed.  Thank you, Mr. Zecevic.

18             It's in fact a Mr. -- I'm so sorry, it's a

19     Mr. Robert E.L.M. Dulmers, so it is the same person.

20             MR. ZECEVIC:  Yes, but I was suggesting that in fairness to the

21     witness the second page should be shown to him so he can read as well.

22             MS. KORNER: [Overlapping speakers] ... I'm still on the --

23             MR. ZECEVIC:  Of the Serbian -- of the Serbian original.  It's

24     been copied on two pages.  It's the very same document, but on the second

25     page is a better copy of the ...


Page 21081

 1             MS. KORNER:  Oh, I see.  Sorry.  Okay.  Sorry, yes, could we have

 2     a look at the second page.

 3             THE WITNESS: [Interpretation] This can be seen ...

 4             MS. KORNER:

 5        Q.   Anyhow, it's all about doing a check on some Dutch journalist

 6     called Dulmers - and I apologize to him if he's still around the

 7     place - and you're asking Banja Luka -- well, you're asking

 8     Banja Luka SNB to give you information and also asking that it be

 9     forwarded to the MUP headquarters.

10             Now, Mr. Bjelosevic, according to you, during the whole of

11     May you're off doing your vital duties with the military.  How come, on

12     the 21st of May, four days later, after the last document we saw from the

13     MUP, you're writing to the MUP?

14        A.   Well, could you please have a look at who this is addressed to.

15     Once again.  What do you think?  Why would we be sending this to the

16     Banja Luka centre if we had communication with Pale?

17        Q.   I -- I think you're -- with respect, Mr. Bjelosevic, you're

18     trying to sidetrack the issue again.

19             I want to know how it was --

20             MR. ZECEVIC:  Well, Ms. Korner, you have to understand that there

21     is an interpretation of what you are asking.  And the interpretation

22     might not be exactly what you have said.  I mean, which is only normal

23     because it's the interpretation.  Therefore, I don't think that it's

24     appropriate that you accuse the witness of trying to sidetrack you

25     because he might not have heard your actual question.


Page 21082

 1             Thank you very much.

 2             MS. KORNER:  You're quite right, Mr. Zecevic.  I accept the

 3     criticism.

 4        Q.   Mr. Bjelosevic, the question I asked - and I'll ask it slowly so

 5     that I hope there will be no misinterpretation - is what you are doing

 6     back in the CSB Doboj on the 21st of May, when, according to you,

 7     throughout May, you were off doing your vital military duties?

 8        A.   If you have followed my previous remarks, you could have noted

 9     or, rather, you could have heard that I stated then, and I repeat that

10     now, from time to time I did come to my office.  That is where I

11     familiarized myself with some security information that was collected by

12     the service, and then from there I went to the command post where we

13     compared data, conducted analyses, and so on.  I never stated that I

14     never entered the police building and my office throughout the month of

15     May.

16        Q.   Wasn't it possibly more important, given the situation in Doboj,

17     that you should be dealing with the clear and evident problems and

18     violence that was going on in Doboj, rather than being with the military?

19        A.   There are several reasons for why I behaved as I did at the time.

20             One of the reasons is that, indeed, the CSB had lost its

21     territory.  There wasn't any.  We had part of the Doboj municipality.

22             The second important reason was lack of personnel.

23             The third important reason is that defence is the number one

24     priority.  And I'm going back to Lisica's suggestions, the suggestions of

25     General Lisica, when he said, Who are you going to keep law and order for


Page 21083

 1     if there's no one there?  And the man was quite right.

 2             And the fourth I'm referring to is that the Crisis Staff -- and

 3     I'm not criticising them.  They ordered what they ordered rightly.  The

 4     municipality has its territory, the public security station has its

 5     territory, and they're the ones who are supposed to do their job ...

 6        Q.   It's clear, isn't it, that the SNB is working in May?

 7             Can we have a look at who else was working, please.

 8             MS. KORNER:  I'm sorry, Your Honours.  Could I again ask that

 9     this document be marked for identification.

10             JUDGE HALL:  Yes, so marked.

11             THE REGISTRAR:  Your Honours, that will be P2330, marked for

12     identification.

13             MS. KORNER:  Now let's have a look, please, at 65 ter 20102,

14     which is at tab 106.

15             JUDGE HALL:  How long is it going to be to deal with?

16             MS. KORNER: [Microphone not activated] I would say it will only

17     take five minutes normally, but -- sorry.  It would only take five

18     minutes normally, but it's likely to take a little longer.

19             JUDGE HALL:  Well, we've reached the point where we take the

20     adjournment for the day.  We reconvene - I believe we're still in this

21     courtroom - on Monday morning at 9.00.

22                           [Trial Chamber and Registrar confer]

23             JUDGE HALL:  In the morning, yes.  It's Courtroom III on Monday

24     morning.

25             I trust everyone has a safe weekend.  Thank you.


Page 21084

 1                           [The witness stands down]

 2                            --- Whereupon the hearing adjourned at 1.45 p.m.,

 3                           to be reconvened on Monday, the 23rd day

 4                           of May, 2011, at 9.00 a.m.

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