Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21482

 1                           Monday, 30 May 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The Accused Zupljanin not present]

 5                           --- Upon commencing at 9.09 a.m.

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

 7     everyone in and around the courtroom.

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

 9     Stojan Zupljanin.

10             JUDGE HALL:  Thank you, Madam Registrar.

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

12     please.

13             MR. HANNIS:  Good morning, Your Honour.  On behalf of the

14     Prosecution, I'm Tom Hannis, with Gerard Dobbyn and Crispian Smith.

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

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

17     Stanisic Defence this morning.  Thank you.

18             MR. ALEKSIC:  [Interpretation] Good morning, Your Honours.  For

19     the Zupljanin Defence, Aleksandar Aleksic.

20             I would also like to inform the Trial Chamber that our client

21     will not attend the trial today during the day, his written approval is

22     expected for the trial to take place without his presence.

23             JUDGE HALL:  Thank you, Mr. Aleksic.  And if there are no

24     preliminary matters, could the witness be escorted back to the stand,

25     please.

Page 21483

 1                           [The witness takes the stand]

 2             JUDGE HALL:  Good morning, Mr. Andan.  Before Mr. Zecevic resumes

 3     his examination-in-chief, I remind you of your solemn declaration.

 4             Yes, Mr. Zecevic.

 5             MR. ZECEVIC:  Thank you, Your Honours.  If the Usher would be so

 6     kind to please hand over the other binder to the witness.

 7                           WITNESS: DRAGOMIR ANDAN [Resumed]

 8                           [Witness answered through interpreter]

 9                           Examination by Mr. Zecevic: [Continued]

10        Q.   [Interpretation] Good morning, Mr. Andan.

11        A.   Good morning to everybody.

12        Q.   Mr. Andan, we broke off on Friday while we were looking at the

13     first few pages of your notes.  The document is 65 ter 831D1, tab 59.

14             MR. ZECEVIC: [Interpretation] Could we please see the fourth page

15     of the Serbian text.  Could we please get page 4.  I suppose in English

16     it's page 2.  The section where the date is 20 July 1992.  The following

17     page in Serbian -- or actually it's the same page but the right side.

18     But in English it should be the following page.  Thank you.

19        Q.   Mr. Andan, this entry is dated 20 July 1992, and it reads:

20     "Meeting with the prime minister Djeric ..."

21             Tell me, did Dr. Djeric come to Bijeljina on that date and did

22     you speak to him?

23        A.   Yes.  As you can see from this text, he was on a two-day visit in

24     Bijeljina and I spoke to him twice.

25        Q.   What was the topic of your conversation?

Page 21484

 1        A.   We spoke at Dvorovi, which is a neighbourhood near Bijeljina.

 2     You can see who else was present, and we discussed the security situation

 3     in the Bijeljina municipality.  We acquainted Mr. Djeric with all our

 4     activities and the activities planned for the coming period.

 5        Q.   Did Mr. Djeric support you in your efforts?

 6        A.   Yes, we got full support from him.  And he said that we must

 7     finish the work we had started.  We complained to Mr. Djeric that we had

 8     minor problems with the political structures in Bijeljina.  We asked him

 9     to use his authority on the meeting that was planned for the following

10     day, that is, the 21st, at the Municipal Assembly of Bijeljina to assist

11     in resolving the trouble that we had, and the paramount cause were

12     paramilitaries, and that was the same in all of Republika Srpska.

13             If you take a look at the relevant entry, then you will see that

14     he insisted that full legitimacy be given to the bodies of the MUP and he

15     fully backed up the police structures of Republika Srpska.

16             I can give you an example of the situation in Bijeljina at the

17     time.  Mr. Djeric had doubts about safe accommodation in Bijeljina, and I

18     offered him to spend the night in the house that I used at the time, and

19     that's what he did.  A Bosniak house was given to me to use there.

20        Q.   Well, since you've mentioned this, tell me, who else lived with

21     you in that house at the time?

22        A.   I lived there with my wife and two children at the time.

23             MR. ZECEVIC: [Interpretation] Could we please see the following

24     page of the Serbian text.  We don't need to change the English.

25        Q.   Could you please comment on this entry of yours, the underlined

Page 21485

 1     part that are supposedly the words of Mr. Djeric.  [Microphone not

 2     activated]

 3             THE INTERPRETER:  Microphone, please.

 4             MR. ZECEVIC: [Interpretation]

 5        Q.   I mean the last sentence on this page.

 6        A.   Mr. Djeric basically confirmed what we had come for, because

 7     there were some doubts about paramilitaries and the self-styled

 8     Chetnik Vojvodas and their units with regard to the way we arrived.

 9     There may have been some doubts in political circles why we had come to

10     Semberija and Majevica.  And he confirmed that we were there pursuant to

11     the order of the government, or, more specifically, since the minister

12     was a member of the government and we were there pursuant to his orders.

13     A conclusion must have been reached by the government for the minister to

14     exercise his authority and deploy us in an area that, according to their

15     assessments, was -- was facing much trouble.

16        Q.   When you used the pronoun "us" in your answer, do you mean the

17     unit of Mico Davidovic and the other units that were sent to Bijeljina to

18     assist in the resolution of the situation there?

19        A.   Yes, that's correct.  Apart from the police forces, and I mean

20     Mr. Davidovic's forces and Malovic's forces, we successively received

21     reinforcements from operatives because we needed them, too, in some

22     phases of our work.  And Mr. Danilo Vukovic was also appointed chief of

23     the crime enforcement service in Bijeljina because there was a shortage

24     of personnel.  I'm referring to crime police that had come from outside,

25     that were not locals from Bijeljina.

Page 21486

 1        Q.   Let us comment on the following page of your notebook.  The title

 2     is "Working Meeting."

 3             MR. ZECEVIC: [Interpretation] We're still on the same page in

 4     English.

 5        Q.   Could you please comment what this working meeting was about.

 6        A.   Okay.  We were trying to introduce a pre-war practice even under

 7     such difficult circumstances in war; namely, something that was done

 8     weekly and once a month there was a summary meeting.  And at those

 9     meetings we analysed our work, both successes and failures, and we would

10     reach conclusions for our future work.  This was one of the working

11     meetings of this kind where we analysed the activities in the previous

12     period.  We also touched upon our duties for the coming period.  And

13     since the highest-ranking officer chaired this working meeting and since

14     he was involved in all our problems in Bijeljina, it was only logical for

15     Mr. Cedo Kljajic to chair the meeting.

16             I didn't go into the minutest detail of all the discussions, but

17     I mentioned the main topics of the meeting in bullet points, as well as

18     our conclusions with regard to the focus of future activity.  You can see

19     here that 80 men were received from other areas.  Some 80 MUP members of

20     the then Bosnia-Herzegovina who were Serbs had fled Tuzla and other

21     municipalities that were controlled by the BH Army.  At one meeting we

22     decided to give them employment with the MUP, so we admitted these people

23     who had been vetted, others had been -- others were subjected to a

24     vetting process.

25             In the initial stage, we removed some 40 police officers.  And in

Page 21487

 1     August, or round about August, these latter officers were re-admitted,

 2     upon which some internal problems ensued, but I can comment on that

 3     later.

 4        Q.   [Microphone not activated]

 5             THE INTERPRETER:  Microphone, please.

 6             JUDGE DELVOIE:  Microphone, please.

 7             MR. ZECEVIC: [Interpretation] I apologise.

 8        Q.   On page 2 of the Serbian text, on the next page actually, could

 9     we look at the second bullet point.  It starts with the word

10     "preventing."  Can you tell us briefly what this pertains to?  It's the

11     same meeting.

12        A.   I see.

13        Q.   It's on the right-hand side.

14        A.   We were constantly facing the problem of the activities of the

15     paramilitary forces, and this is a continuous struggle against this

16     plague that had affected all of Bosnia-Herzegovina.  I mean, after the

17     war I found out that they also - I mean, when I say "they," I mean

18     colleagues from the Federation - had the same problem.  So I say that we

19     continue to struggle against the paramilitaries.  I said organisations

20     here, but they are formation, units.  And also I refer to organised

21     crime.  I've already spoken about that and I think that that is contained

22     in some of the written information I've provided, namely that all these

23     formations that have come had one single objective, not to protect the

24     Serb people.  They came to loot, to rape, and to cross the border with

25     their booty.  That way their "warfare" would be brought to an end.  Once

Page 21488

 1     they needed more things, they would come back to the same area and go on

 2     looting, the same problem all over again.

 3        Q.   Just the last entry now, could you please tell us what that

 4     pertains to, establishing responsibility?

 5        A.   Well, that's what I already talked about.  That was mentioned

 6     here by way of a footnote.  Please don't take my word for any date once

 7     again; I am really not very good with dates.  But I know what periods are

 8     involved; I know how things happened, in cycles.  A dispatch arrived from

 9     the Ministry of the Interior, perhaps it did not, but at any rate at this

10     work meeting we underlined that once again the responsibility of all

11     those who had committed a crime had to be established, even those who had

12     committed misdemeanours, but the rules of service prohibit even that kind

13     of thing for law enforcement officials.

14             So we made a clear differentiation between those who worked hard

15     and those who were lazy, those who were criminals, I can say that quite

16     openly, when who had wore uniform and those who did not.  During these

17     times of war, in some magical way they managed to get into the

18     Ministry of the Interior; however, we identified them and got rid of them

19     as soon as we could.

20        Q.   The next entry says the 23rd of July, 1992.

21             MR. ZECEVIC: [Interpretation] That is page 8 in e-court of the

22     Serbian text.  I assume that it's page 4 in English.  Next page, please.

23     It is page 3 in English, I've just been told, I'm sorry.

24        Q.   [Microphone not activated]

25             THE INTERPRETER:  Microphone, please.

Page 21489

 1             MR. ZECEVIC: [Interpretation] I apologise.

 2        Q.   Sir, the date is the 23rd of July, 1992, and the heading says

 3     "Discussion on going to Brcko."  Can you give us your comment.  Can you

 4     tell us whether this has to do with that trip to Brcko that you told us

 5     about on Friday, the one that you testified about on Friday?

 6        A.   Yes, that is the period involved.  I don't want to repeat what

 7     I've already said.  We had received information which we later checked on

 8     the ground, namely that these paramilitaries had threatened the security

 9     situation there; I mean, they attacked even the public security station.

10     So you can see that on the 23rd of July, 1992, with 110 policemen, we

11     went to Brcko to reinforce law and order and to do away with crime.

12        Q.   On the next page we see the 24th of July, 1992, Brcko.  Please

13     take a look at this.  We don't need to repeat any of the things you said

14     on Friday, but does this pertain to what you already told us about, the

15     situation that you found in Brcko and the clash with the Red Berets?

16        A.   Yes, that is the period involved.

17        Q.   Let us please move on to the 25th of July.

18             MR. ZECEVIC: [Interpretation] That is page 13 in the Serbian

19     version.  I assume it may be page 7 in English.

20        Q.   Sir, this is the 25th of July, 1992.  The heading says

21     "Discussion of the Bijeljina CSB about problems in Zvornik."

22             Tell me, can you give us a comment in respect of this?

23        A.   On several occasions we received information from several sources

24     stating that the security situation in the territory of the

25     municipality -- not only the municipality of Zvornik but the city of

Page 21490

 1     Zvornik itself in particular was threatened by an individual nicknamed

 2     Zuco.  He was in charge of Zvornik, legally and formally.  Before this

 3     official discussion, at a morning meeting we analysed the information

 4     that had come in, and it was agreed that I together with two or three

 5     men, one operative, that is, and two members of this unit, I think that

 6     they were members of Mico Davidovic's unit, that we change into civilian

 7     clothes and enter Zvornik and observe everything that we were interested

 8     in from a security point of view.  That is indeed what we did.

 9             We entered the town of Zvornik.  We observed all the buildings --

10        Q.   You already testified about that on Friday in relation to the

11     previous entry in your diary.  However, in relation to this particular

12     entry, could you give us a comment on that?

13        A.   It is obvious here that we had already had sufficient

14     information, and we tried to agree on how this paramilitary formation

15     could be neutralised.  You see here that Zuco entered the TO Staff

16     premises and the municipality and for a while he kept prisoner even the

17     representatives of the authorities and the Territorial Defence in that he

18     basically dictated the overall situation in Zvornik.  We had to oppose

19     that in an appropriate manner.  This has to do with a work meeting to

20     which we invited the commander of the Eastern Bosnian Corps, Mr. Ilic.

21             Now, this Blagojevic, whether he was his Chief of Staff or not,

22     that is something I don't know now.  But we tried to discuss this with

23     the military so that they would deal with these paramilitaries, not only

24     the Yellow Wasps.  On Friday we discussed Splico and some other

25     paramilitary formations that were in the area.

Page 21491

 1        Q.   Thank you.

 2             MR. ZECEVIC: [Interpretation] Can we please move on to page 15 in

 3     the Serbian.  I assume it's the next page in English.  "Discussion in the

 4     SO Bijeljina, the Bijeljina Municipal Assembly."  That is the title of

 5     that particular entry.

 6        Q.   Could you give us your comment on the second bullet point

 7     underneath this heading "Discussion in the Bijeljina Municipal Assembly"?

 8        A.   In addition to regular information that was provided to the

 9     Ministry of the Interior, of course there were periods when there were no

10     radio, teleprinter, and telephone communications, then we sent

11     information by courier at least once a week.  We regularly informed

12     political structures of government about the situation in Bijeljina.  Our

13     aim was quite simply to get the political authorities involved in

14     resolving this problem so that we could do that as quickly as possible.

15     We said, whenever we reported, that no stability could be achieved if

16     paramilitaries were there.

17             This did yield some result, and we were invited to a meeting at

18     the Bijeljina Municipal Assembly and the situation in Bijeljina was

19     discussed.  It wasn't good at the time.  You can see here that at that

20     meeting we assumed responsibility, although it was not our duty according

21     to the law, to protect various persons, namely the assemblymen from the

22     territory of Bijeljina.  That is to say that we made every effort for

23     this problem of security to be raised to a higher level, to galvanise the

24     Government of Republika Srpska into action through Bijeljina in order to

25     stop the paramilitaries from coming into Bijeljina from Serbia.

Page 21492

 1     Unfortunately, that did not happen, and we did not fully achieve this.

 2        Q.   Tell me, there is an entry here, "Dragan Djordjevic."  And then

 3     it says "Crni" under quotations marks, so it's just his name, surname,

 4     and nickname.  Can you give us your comment on this?

 5        A.   I think that I mentioned him on Friday, that that is also a

 6     member of a paramilitary formation.  Now, was he in Samac?  I think it

 7     was in Samac.  There were two extremes in these paramilitary formations,

 8     Crni and Lugar.  We thought that in the coming period, with the forces

 9     that we had available, of course, again, not at our own initiative but

10     with the approval of the minister and his subordinates, we enter

11     Bosanski Samac and disarm these paramilitary formations.  I don't know

12     what the next objective was, whether criminal reports could be filed and

13     so on, however I note that was the first time I heard that name and

14     surname and that's why I recorded it in my diary at that meeting.

15        Q.   Thank you.

16             MR. ZECEVIC: [Interpretation] Could we have the next page,

17     please, both in Serbian and in English.  It is the 31st of July, 1992,

18     and it says "Work Agreement."

19        Q.   Could you tell us about this?  It has to do with the

20     implementation of the Zvornik operation.

21        A.   Well, yes.  Although we then had contacts with the

22     National Security Service in Zvornik that was headed by the late Zugic at

23     the time, Goran Zugic, we probably hadn't received all the intelligence

24     that was relevant for our plan, so we kept meeting until the operation

25     actually started.  I think that this has to do with going to Zvornik.

Page 21493

 1             MR. ZECEVIC: [Interpretation] I think I need page 18 now.  The

 2     2nd of August 1992 in Zvornik.  The next page in English.

 3        Q.   Mr. Andan, it says:

 4             "Zvornik informing the minister of the Serb MUP about the overall

 5     security situation in the area of the municipalities of Bijeljina, Brcko,

 6     Zvornik, the 2nd of August, 1992."

 7             Did this information -- was this information provided after the

 8     Yellow Wasps were arrested?

 9        A.   Yes, I think so.  After completing this operation - and that was

10     done very successfully I must say; there weren't even any casualties

11     involved; I don't think that anyone was even seriously injured - we sent

12     a report on the action that had taken place.  In the meantime,

13     Mr. Stanisic was announced and did appear there and we were supposed to

14     provide him with information about the overall security situation.

15             To be quite frank, he was interested about certain colourful

16     details, like how policemen came to the 6th and 7th story of buildings

17     using ropes; that's where the paramilitaries were and how they were

18     ultimately overcome.  So we told him about all of that.

19             At the end of this two-hour meeting with the minister, he paid

20     tribute to our efforts and he said that we should continue along those

21     lines and said that the problems that other municipalities were facing

22     also called for such units, or perhaps we could quite specifically be in

23     the focus and perhaps we would have to count on that, dealing with

24     paramilitaries and criminals not only locally but throughout the

25     republic.  I think that what was being intimated at the time was our

Page 21494

 1     transfer to Foca that was also facing a great many problems, like

 2     Zvornik.  That is where local criminals were basically running the

 3     municipality of Foca and we were supposed to establish law and order

 4     there, but this was just by the by.  We were being informed about it --

 5        Q.   Thank you.

 6             MR. ZECEVIC: [Interpretation] Could we have the next page,

 7     please.

 8        Q.   And I would appreciate your giving us a comment.  Can you tell us

 9     whether this meeting was held in Zvornik?

10        A.   Yes.  It was held on the premises of the police station in

11     Zvornik.  There was a nice conference room there that could house some

12     20 or so people.  It was a conference room and that's where we met with

13     Minister Stanisic.

14        Q.   On the next page of this entry, we can see that it says that

15     there was a dead-line given and the dead-line was the 3rd of August.

16     Could you tell us what that relates to?  It is the second bullet point on

17     the left-hand side of the screen.

18        A.   In a short investigation that we carried out after the arrests of

19     the paramilitary unit, we learned that some of the leading officers, even

20     the police station commander, komandir, had in fact taken part in

21     criminal activities, and quite a lot, and that Zuco, in fact, in effect

22     had control over the police station by way of their commander.  We

23     informed Minister Stanisic of this and this problem and he said that by

24     3rd of August everyone who was involved in any type of criminal activity

25     that we could document should be processed, that the criminal report

Page 21495

 1     should be submitted to the Prosecutor, and that they would be issued a

 2     decision on the cessation of their work for the police station.  So we

 3     informed the minister of the situation at the Zvornik Police Station.

 4        Q.   Thank you.  We will see in a moment a document relating to that.

 5     Now, on the next page, on the right-hand side of the page which we can

 6     see on the screen now --

 7             JUDGE HARHOFF:  I don't know if you will be coming back to the

 8     response that the minister gave to the information offered by the

 9     witness, but maybe you would take this opportunity to ask if there was a

10     response, indeed, from the minister.

11             MR. ZECEVIC:  Well, I'm sorry, I wasn't checking the transcript,

12     Your Honours.

13             JUDGE HARHOFF:  The witness just told us that he made sure that

14     the minister was informed about the problems in Zvornik.  That's a useful

15     piece of information.  And I would be curious to know if the minister

16     responded to this information.

17             MR. ZECEVIC:  Well, that is precisely -- he said, on page 13,

18     line 20: "... he said that by 3rd August everyone who was involved ..."

19             JUDGE HARHOFF:  Right.  Thank you very much.

20             MR. ZECEVIC:  I assume that, because this is the entry in his

21     notebook, that it refers to the minister.  And that is how I understood

22     it, that the minister said.

23             JUDGE HARHOFF:  I probably misunderstood.  I'm sorry for that.

24     So this was the minister's response; is that correct?

25             THE WITNESS: [Interpretation] Yes, that was the minister's

Page 21496

 1     response.  And if you allow, I can expand on this by giving some

 2     additional explanation.  Can I do that?

 3             Legally speaking, the chief of the security centre was

 4     responsible for the entire proceedings involving taking disciplinary

 5     action and submitting criminal complaints within the centre that he was

 6     responsible for.  Now, the chief of administration was in charge of

 7     inspectors, and the chief of the crime administration was also

 8     responsible for his own employees within the crime police.  Now, the

 9     minister could, pursuant to a proposal by the chief of an administration,

10     take action against chiefs of centres.  So that was the procedure.  And I

11     understood the order issued by the minister at the time that we should

12     take all necessary activities to eliminate all those individuals for whom

13     we could find evidence that they were involved in criminal activity and

14     that they were -- that they had some ties with the paramilitary unit of

15     the Yellow Wasps.

16             MR. ZECEVIC:  May I move on, Your Honours?

17             JUDGE HARHOFF:  Yes, certainly.  Thank you.

18             MR. ZECEVIC:  Thank you.

19        Q.   [Interpretation] On the right-hand side that we have on our

20     screens, now we have the third bullet point beginning with the words

21     "paramilitary units."  What I would like to discuss now is that bullet

22     point.  And then there's another bullet point where it says at ... "on

23     pain of death."  So could you please comment these two bullet points.

24        A.   Well, here we are talking about what we were to do next, in other

25     words, a total and full sorting out of the situation with the

Page 21497

 1     paramilitary units and getting rid of them.  So this was something, a

 2     task that we assumed, and there was no dead-line because it was

 3     impossible to say whether this could be done within a month or two, but

 4     this was an on-going task that we had.  And finally, I said here that on

 5     the pain of death, all of this had to be handled.

 6             So all of those tasks that we had discussed, such as disarming

 7     and putting all the paramilitary units under authority, under some legal

 8     command, the restructuring of -- restructuring or, rather, clearing all

 9     our ranks as it were of all those who had managed to insinuate themselves

10     into our ranks and getting rid of them if they were criminals, and all of

11     those who had actually abused their powers as police officers should be

12     processed.  Against some there would be disciplinary action taken.  And

13     against others, criminal action would have to be taken.  But this would

14     have to be done on the pain of death.

15        Q.   Just one small question: Was that the position of the minister as

16     well?

17        A.   Well, yes.  I don't know how well you know Mr. Stanisic, but he

18     was a person who could be very, very decisive.  Sometimes he would even

19     actually conduct himself almost as a military person.  That was one of

20     the personality traits that he had at the time, and he was the one who

21     said, you know, this has to be dealt with on the pain of death.

22        Q.   Thank you.

23             MR. ZECEVIC: [Interpretation] Could we now please see the entry

24     for the 4th of August, 1992, Bijeljina SJB.  In English, that will be on

25     the next page.  Perhaps we can -- maybe it's on the next page.  I don't

Page 21498

 1     know.  The English version of the translation is a bit different.  My

 2     apologies.  That's where it should be.

 3        Q.   Now, tell me, sir, here we see that it says "discussion and

 4     briefing along the lines of work" and then "Goran Macar."  Can you tell

 5     us what this relates to and who Goran Macar was?

 6        A.   At the centre, security centre, we did not have the adequate

 7     personnel in order to process all those individuals that we had arrested

 8     in that operation.  I believe that we sent a dispatch, or perhaps

 9     Mr. Kljajic agreed on the -- in a telephone conversation with the

10     minister, that Mr. Goran Macar should come to the security centre, at the

11     time he was the chief of the crime administration, and that he should

12     bring with him five to ten crime police inspectors so that we would speed

13     up this whole process and document all of the activities that Mr. Zuco

14     was involved in, and to cap this with issuing crime reports, which is

15     what it was called at the time, and sending them to the prosecutor.

16             Here we also discussed some matters that were something that we

17     were concerned with at the time.  We had confiscated a number of

18     vehicles.  One of the issues that was discussed was where those vehicles

19     were.  And then there was also -- there were also some goods that were

20     confiscated, and we wanted to do a report listing all the things that

21     were confiscated in order to make sure that they were not abused.

22        Q.   Thank you.

23             MR. ZECEVIC: [Interpretation] Could the witness now be shown

24     page 24.  On the top of the page we see it says page 109.  And the ERN

25     number is 0605-4599.  I'm sorry, I really don't know what English

Page 21499

 1     translation page would be the appropriate page.  I hope that we can, with

 2     the assistance of the Usher or Registrar, have it.  That's the page

 3     preceding the entry for the 10th of August.  So just a page before this,

 4     please.  Toward the bottom of the page.

 5        Q.   Sir, could you please tell us what this means here.  It says

 6     "Janja manning levels up to 30," and then it says "dismiss pensioners or

 7     retirees."  Now, first of all, tell us what Janja is and what this bullet

 8     point refers to.

 9        A.   Janja was a settlement not far from Bijeljina, some 10 kilometres

10     away, and at the time, the place was predominantly Muslim and those

11     Muslims had remained in the area at the time that we are talking about,

12     and because all around it were Serbian villages and Serbian police and

13     military forces, it was our assessment at one point that we should

14     reinforce or become -- that we should have a visible police presence in

15     the area in order to prevent attacks on some of these families, the

16     Muslim families there, because there were such instances where they were

17     assaulted, and to prevent possible assaults on them, or looting or

18     murders, and based pursuant to this assessment of ours and in view of the

19     fact that there was a small police department in Janja at the time, we

20     actually upgraded it to a police station in order to enable it to

21     function normally, because in peacetime it had some six to seven police

22     officers, but once there were ten police officers or above, then that

23     would be a higher level police station or presence.

24             So based on our assessment, we decided that we had to strengthen

25     this police department in Janja and have more police officers there, and

Page 21500

 1     thus we would automatically upgrade this police department to a police

 2     station.  So we decided here to add additional 30 police officers to the

 3     Janja Police, and we had the capability to do so because there were

 4     people who had moved into our area from other parts.  And in view of the

 5     fact that there were a number of retired police officers who were still

 6     working in Janja at the police station and they had at the time already

 7     been over 60 years of age, we decided to retire them and to place them,

 8     to move them, to the reserve force because I believe at the time under

 9     the law that would -- they would be qualified for reserve forces up to

10     65 and to replace them with younger police officers.

11        Q.   Thank you.  Now, tell us, please, all this activity in Janja --

12     well, first of all, could you tell us whether this police station in

13     Janja set up check-points on the approaches to Janja village?

14        A.   Yes, there was only one road leading from Bijeljina to Zvornik

15     and Pale and that road went through Janja.  We set up check-points there

16     and our objective was to do what we had already done in Bijeljina

17     municipality at large, in other words, to prevent looting and to

18     guarantee personal security and the personal safety and security of the

19     property that belonged to the Muslims who lived in Janja at the time.  We

20     set up those check-points, and I believe we even established an

21     intervention platoon that was -- that had its seat on the premises of the

22     police station in Janja.

23        Q.   What was the role of the intervention platoon?  What was their

24     basic purpose?  Why were they in their police station in Janja?

25        A.   Well, if we look at this time, you can see it if you analyse it,

Page 21501

 1     but at the time when we strengthened the police station in Janja, we did

 2     not have any cases of looting or persecutions or any other type of

 3     crimes, so we were trying to provide for normal conditions for these

 4     people to live in, because these people were farmers at the time.  I

 5     think that was basically the structure of the population in Janja.  And

 6     even to this day they are farmers.  So we wanted to allow them to be --

 7     to make it possible for them to go to their fields and do their work, do

 8     their farming, and to have normal living conditions in the environment

 9     and under the conditions that existed at the time.

10        Q.   Thank you.  Let us take look at the entry on page 26, dated

11     11 August 1992.

12             MR. ZECEVIC: [Interpretation] That's on the following page at the

13     bottom in English.

14        Q.   Sir, here's an entry dated 11 August 1992, "Discussion on further

15     activities," and then some places are listed.  Could you please tell us,

16     we can see that Ugljevik and Lopare are mentioned, has this anything to

17     do with what you were saying on Friday?  Do comment, please.

18        A.   Yes.  We acquainted the number one man of the crime police with

19     all the problems we were facing at the time, and here it is stated that

20     in the coming period we should continue the same kind of activities that

21     we had taken in Brcko and Zvornik in Ugljevik and Lopare, too.

22        Q.   Thank you.  The next entry is 12 August.

23             MR. ZECEVIC: [Interpretation] I suppose it must be on the

24     following page.

25             THE INTERPRETER:  Interpreter's correction: 13 August.

Page 21502

 1             MR. ZECEVIC: [Interpretation] The following page in English.

 2        Q.   This is 13 August 1992, and it says "discussion with the

 3     president of Zvornik municipality."  "Zvornik SJB - urgently resolve

 4     personnel issues," and so on.  Please comment so that I needn't read it.

 5        A.   The internal personnel structure of the MUP had been changed, and

 6     we had to conduct manning with appropriate personnel and thus stabilize

 7     the situation inside the MUP.  On 13 August we scheduled a meeting with

 8     the president of Zvornik municipality.  We, of course, informed him of

 9     the activities that we had in Zvornik at the time and presented our

10     current problems to him, the internal problems of the ministry, but of

11     course it was up to us to resolve them.

12             As far as I can tell from my entry, we were somewhat dissatisfied

13     with the co-operation with the VRS.  The co-operation was not as it

14     should be.  At some difficult moments there was no information exchange.

15     And as the largest organisation and the strongest force at the time, they

16     were present there, but there wasn't much information exchange.  So we

17     requested that a different approach be taken to this problem and that we

18     should tackle these piled up problems together.

19        Q.   At the very end of this page I can see a bullet point reading,

20     "Ostoja Minic for chief of the crime service in Zvornik."

21             Who is he?

22        A.   I cannot remember who exactly he is.  He may have come from Tuzla

23     or Kalesija or some other nearby place.  We thought that this man should

24     take over the position of the chief of the crime service in Zvornik, and

25     that's probably why he was appointed.

Page 21503

 1        Q.   Thank you.

 2             MR. ZECEVIC: [Interpretation] Let's show page 33 to the witness,

 3     please.  It is not dated.  ERN is 0605-4617.  We can see that the last

 4     date mentioned before this entry is 13 August.

 5        Q.   Foca is mentioned.  Can you explain?  Let us just wait to get the

 6     English translation.

 7             MR. ZECEVIC: [Interpretation] I suppose it must be on the

 8     following page.  No, it must be the one after this.  Yes, toward the end.

 9        Q.   Could you please comment.

10        A.   As I have said already, while we were briefing Mr. Stanisic about

11     the activities in Zvornik, the same roughly applies to our trip to Foca.

12     Before making this entry, I was invited by Mr. Stanisic to come to

13     Bosanska Vila.  I think he was in Belgrade officially.  And as far as I

14     remember, he told me that he had received a dispatch or a report from

15     Foca that paramilitaries there are disrupting the functioning of

16     government and that they oppose all decisions taken by the legal

17     authorities, that the situation was basically the same as in the

18     Semberija municipalities.  They are trying to meddle with the manning of

19     the police station in Foca and also to influence other government

20     structures.

21        Q.   On page 22, line 9, it has been recorded that Mr. Stanisic was in

22     Belgrade officially, but I believe that you said something else too.

23             Did you know that Mr. Stanisic was in Belgrade officially, or on

24     a private visit?

25        A.   I cannot remember exactly.  He was probably there in an official

Page 21504

 1     capacity because he invited me to come.  If he had been on a private

 2     visit, he would probably have invited me to meet him in a pub or

 3     something.  But the way it was, it points more toward an official trip.

 4        Q.   Thank you.  This is 30 men.  The group or unit that was supposed

 5     to go to Foca was meant to be 30 strong or --

 6        A.   I believe that reference is made here to 30 uniformed police

 7     members.  And the team that was meant to go to Foca should have been --

 8     should have comprised also some crime police officers, a man named

 9     Milorad Orasanin.  And I believe, although I'm not certain, that a member

10     of state security should have come with us, and I think his name is Goran

11     Radovic.

12        Q.   Thank you.  Please take a look at page 36.  It says "draft

13     dispatches for the MUP of Serbia and that of Crna Gora."

14             Can you explain what this was about?

15        A.   I think that this is a logical sequence of events.  There were

16     two republics of the then state - I'm not sure what it was called at that

17     moment, Yugoslavia or Serbian Montenegro - and we had to contact their

18     MUPs because that was the only way that we could get to Foca, because the

19     BH Army still controlled Trnovo and Gorazde, too.  I think I informed the

20     minister that a dispatch should be sent to the MUP of Serbia and the MUP

21     of Montenegro to allow us free passage through their territories.  I

22     think that we planned to go via Pljevlja and Cajnice to Foca.

23        Q.   Tell me, Mr. Andan, what assignment did the minister give you and

24     that unit that was going to Foca?  What were you supposed to do there?

25        A.   I had to smile, but I can only repeat what he had said:

Page 21505

 1             This must be done at any cost.  The paramilitaries in Foca must

 2     be wiped out.  We must exercise all our legal powers, and that includes

 3     the use of fire-arms if the legal conditions are met.  To enable the

 4     legitimate authorities in Foca to function.  To process all members of

 5     paramilitary units, especially one Pedo, or Pedolino.

 6             I still remember their nicknames.  They were local criminals who

 7     were behind all the trouble in Foca.  Our goal was to disarm them and

 8     detain them, to search their premises, and every paramilitary formation

 9     had a warehouse where they stored their booty.  It was our task to

10     process all this and to go through the procedure all the way to the

11     public prosecutor's office.  We were also supposed to stay in Foca and

12     assist the authorities and the Foca Police Station for a while.

13        Q.   Thank you.

14             MR. ZECEVIC:  And since I'm moving to another -- another issue, I

15     would ask that we are adjourned at this moment.  But before that, I would

16     offer this document as an exhibit.

17             MR. HANNIS:  Does that mean you're through with it?

18             MR. ZECEVIC:  Yes.

19             MR. HANNIS:  No objection.

20             JUDGE HALL:  Admitted and marked.

21             THE REGISTRAR:  Exhibit 1D557, Your Honours.

22             JUDGE HALL:  So we take the adjournment, return in 20 minutes.

23                           [The witness stands down]

24                           --- Recess taken at 10.25 a.m.

25                           --- On resuming at 10.52 a.m.

Page 21506

 1                           [The witness takes the stand]

 2             JUDGE HALL:  Yes, Mr. Zecevic, you may continue.

 3             MR. ZECEVIC:  Thank you, Your Honours.

 4        Q.   [Interpretation] Mr. Andan, did you take part in the Zvornik

 5     operation?

 6        A.   Before I answer this question, I have to ask the Trial Chamber

 7     and those who are responsible for the air conditioning in this room that

 8     we are in, if you want me to finish my testimony here and if you want me

 9     to remain in good health and able to do so, could you please regulate the

10     temperature in this room?

11             I directly took part in the operation.

12             Oh, yes, and what I'm asking for is that you turn this off.  This

13     amount of air conditioning in this room is really ...

14             JUDGE HARHOFF:  So you're saying that it is too hot in here, is

15     that correct, and you want the temperature to be lowered?

16             THE WITNESS: [Interpretation] No, on the contrary.  It is

17     pleasant in the courtroom, but this other room that I'm in, it's like a

18     refrigerator.  I mean, during the breaks, the room that I'm in during the

19     breaks.

20             JUDGE HARHOFF:  Very well.  We will see to that.  Thank you.

21     Please proceed.

22             MR. ZECEVIC:  Thank you very much.

23             THE WITNESS: [Interpretation] If I understood your question

24     correctly, you asked me whether I took part in the operation of

25     eliminating the paramilitaries, the Yellow Wasps.  Yes, most directly.  I

Page 21507

 1     don't know whether it is something to brag about or not, but I am the one

 2     who directly arrested Vukovic, nicknamed Zuco.

 3             MR. ZECEVIC: [Interpretation]

 4        Q.   Vuckovic, Vojin, nicknamed Zuco; right?

 5        A.   That's right.  Since his nickname was Zuco, the unit was called

 6     "Zute Ose," the Yellow Wasps.

 7        Q.   Please tell us, briefly though, how you arrested him.

 8        A.   On the basis of all the intelligence that we had available,

 9     during the early morning hours we took all the buildings that were being

10     used by all these paramilitary units.  We arrested the persons there.  As

11     for their personal weapons and everything else, we took all of that with

12     us.  We left the police on the spot to guard the premises so that the

13     scene could be dealt with properly.

14             When we started identifying the persons involved, carrying out

15     the triage, as it is called, Vojin Vuckovic was not among them.  And

16     Rade Tanaskovic wasn't either.  He was another one of the key persons

17     from Zuco's paramilitary unit.  In the meantime, we received information

18     that the commander of the police station, a certain Maric, was in direct

19     contact with Zuco throughout, and at that point in time he was at the

20     Zvornik Police Station.

21             We put a bit of pressure on him to tell us where Zuco is.  And he

22     said that Zuco was in Celopek near Zvornik, in the house of

23     Rade Tanaskovic.  As we were preparing for the arrest, it crossed my mind

24     that we should take the commander of the police station to Celopek, which

25     is indeed what we did.  I said to him -- once we had surrounded the house

Page 21508

 1     where the mentioned persons were, I said to him that he should knock at

 2     the door, and when somebody on the other side says who it is, then he

 3     should introduce himself and say that he urgently needs to see Vojin

 4     Vuckovic, Zuco.  That's exactly what we did.  When the door was being

 5     unlocked, he stood on the side.  The door was unlocked by Zuco.  He was

 6     wearing shorts.  He had a pistol.  We reacted at lightening speed.  We

 7     took his pistol.  I don't want it to seem that we had done this mildly.

 8     There was quite a fight involved, fists and the like.  Perhaps that's not

 9     appropriate altogether, that's what we did and that was the end of that.

10             Once we were done, another man walked out of another room, again

11     he was in his underwear too.  We identified him as Rade Tanaskovic, and

12     we took them to the police station and handed them over to the crime

13     investigation service for further processing.

14        Q.   Sir --

15             JUDGE HARHOFF:  Mr. Zecevic, just when was this exactly?

16             MR. ZECEVIC: [Interpretation]

17        Q.   Can you remember when this happened?  Can you remember exactly?

18        A.   It was the same day when we entered Zvornik and when we

19     eliminated most of the paramilitaries, Zuco's paramilitaries.  I think

20     that we eliminated them by 6.00 in the morning, and then between 6.00 and

21     7.00 on that same date - I don't remember the exact date - we dealt with

22     Vojin Vuckovic and Rade Tanaskovic.

23             JUDGE HARHOFF:  On which date?

24             THE WITNESS: [Interpretation] I know it was sometime in August.

25     I've already told you, do forgive me, I'm not good at dates.  And in

Page 21509

 1     these notes of mine, it should say what date it was.

 2             MR. ZECEVIC: [Interpretation]

 3        Q.   Sir, these persons who were arrested at the time, were they

 4     remanded in custody for 72 hours?

 5        A.   Yes.  However, may I also say that because we were not able to

 6     work properly in Zvornik, these persons were taken to the CSB Bijeljina

 7     by bus under police escort, and then in Bijeljina we dealt with them

 8     individually.  Of course, all of these persons were issued with

 9     appropriate papers certifying the fact that they were remanded in

10     custody.  So all of this was dealt with lawfully, that's what I'm saying.

11     So they were given a decision on detention.

12             MR. ZECEVIC: [Interpretation] P317.18.  That is tab 74.  Could we

13     please have a look at that.

14        Q.   Sir, this is a decision on detention, Milivojevic, Slobodan,

15     nicknamed Topola.  It is signed by SJB chief Dragan Andan.  And then

16     further on in documents 4, 5, 6, 7, 8 pages and then the last one, page

17     8, there is a decision on detention concerning Vojin Vuckovic, nicknamed

18     Zuco.

19             Are those the decisions that you were thinking of when you were

20     giving your previous answer?

21        A.   Yes, this is my signature.  These were the decisions that were

22     written up by the crime investigation service.  I just confirmed that

23     these were the persons involved with my own signature, and a seal was

24     affixed, and, of course, they were remanded in custody.

25             MR. ZECEVIC: [Interpretation] 65 ter 19D1.  Can we have a look at

Page 21510

 1     that, please.  That is tab 83 of the Defence.

 2        Q.   The date is the 31st of July, 1992, and there is a signature

 3     there.  Can you tell us whose signature this is and whose report this is?

 4        A.   I do apologise because I didn't know the date earlier on.  This

 5     document shows that the operation was implemented on the 29th and

 6     30th of July.  In response to your question, I said I think the beginning

 7     of August.  I do apologise once again.  I see now that it was actually

 8     the 29th and 30th of July, and Zuco was arrested on the same day, the

 9     29th.  This is my signature, and this is a brief description of what

10     happened.  And we probably sent this to the Ministry of the Interior to

11     inform them in brief terms what it was that we had done and to what

12     extent.

13        Q.   Thank you.

14             MR. ZECEVIC: [Interpretation] If there are no objections, I would

15     like it to tender this document into evidence.

16             MR. HANNIS:  No objections.

17             JUDGE HALL:  Admitted and marked.

18             THE REGISTRAR:  Exhibit 1D558, Your Honours.

19             MR. ZECEVIC: [Microphone not activated]

20             THE INTERPRETER:  Microphone, please.

21             JUDGE DELVOIE:  Microphone, please.

22             MR. ZECEVIC: [Interpretation] My microphone is on now.  I don't

23     know if they hear me now.

24             THE INTERPRETER:  Interpreter's note:  Yes, we do.  Yes.

25             MR. ZECEVIC: [Interpretation] Thank you.

Page 21511

 1             Could you please have a look at 65 ter 166D1, tab 87.

 2             Your Honours, just one small intervention in relation to the

 3     previous document, 1D558, that was admitted a moment ago.  I have just

 4     been informed by my colleague Ms. Savic that an identical document,

 5     unsigned, was introduced as P1557.11 and admitted.

 6        Q.   Let us go back to this document.  That is --

 7             JUDGE HALL:  Sorry, Mr. Zecevic.

 8             MR. ZECEVIC:  Yes.

 9             JUDGE HALL:  I was waiting for you to, having informed us of

10     that, and?  Is the idea that this -- the signed one be substituted for

11     the exhibit that's already with us?  Or is this a supplement?  I don't --

12             MR. ZECEVIC:  No, I just wanted to relate these two documents for

13     the benefit of the Trial Chamber because they are different, since this

14     document which was now admitted as 1D558 was signed by the witness and

15     witness confirmed that.  However, the other document which is identical

16     has no signature and it was admitted as a P document, so that was the

17     only reason I raise this.  But it's up to Mr. Hannis if he wants to

18     intervene on that.

19             JUDGE HALL:  Mr. Hannis.

20             MR. HANNIS:  Your Honour, I only wanted to indicate that the

21     other document, the unsigned version, was part of the 92 ter package of a

22     witness, and therefore it was a document that was originally introduced

23     in the Krajisnik trial several years ago.  So that was a version we had

24     that didn't have a signature.  But because it was referred to, I think by

25     that witness, I would like to leave that number in evidence.  We now have

Page 21512

 1     on the record the linking between those two, and I think that's

 2     sufficient.

 3             JUDGE HALL:  Thank you.  Yes.

 4             MR. ZECEVIC:  Thank you, Your Honours.

 5             [Interpretation] Sir, could we please have on our screens

 6     65 ter 166D1, tab 87.  This is not the document.  Yes, now we have it

 7     before us.  Tab 87.

 8        Q.   Sir, this is a dispatch dated August 1st, 1992.  The document is

 9     signed or, rather, it is typed "Chief Dragan Andan," his signature is

10     typed out, and in the penultimate sentence towards the end, it says:

11             "The operation to mop up Zvornik is yielding positive results

12     with regard to the security and general situation in Zvornik."

13             Could you please comment on this.  First of all, could you tell

14     us whether this is indeed your dispatch, whether you're familiar with it,

15     and could you then briefly comment on the portion that I've just read

16     out?

17        A.   Yes, this is my dispatch, although I have to say that to this day

18     I am not clear why we informed the ministry about our operations, because

19     every time we would have to go to the ministry to receive information

20     from them and then send reports.  I asked Mr. Gajic and he just sort of

21     waved with his hand away, you know, like saying that's how we were

22     ordered to do.  And I can only say that you may find a number of

23     dispatches of this type.

24             And in the penultimate sentence, I'm actually reporting that we

25     had practically completed this operation of wiping out these and actually

Page 21513

 1     expelling them from the Zvornik municipality, these paramilitaries, and

 2     we wanted to let them know that the situation, the security situation,

 3     was now very good and that we will continue to do our jobs that were,

 4     under the law, what we were supposed to do.

 5        Q.   On page 31 in line 8, it says "I asked Mr. Gajic."

 6        A.   Yes, Cedo Gajic [as interpreted].

 7        Q.   No, could you please tell us exactly the name, the first and last

 8     names, slowly and then what his function was?

 9        A.   He was undersecretary for public security, Cedo Kljajic, who was

10     at the time with us in Bijeljina.

11        Q.   Thank you.

12             MR. ZECEVIC: [Interpretation] If there are no objection, I would

13     tender this document.

14             MR. HANNIS:  No objection to this one.

15             JUDGE HALL:  Admitted and marked.

16             THE REGISTRAR:  Exhibit 1D559, Your Honours.

17             MR. ZECEVIC: [Interpretation] The next document that I would like

18     to show you is under tab 84.  The document is marked as 65 ter 164D1.

19        Q.   This is another dispatch.  It is dated the 31st of July, 1992,

20     and it was sent to the Serbian MUP, and again we see that it was signed

21     by Chief Dragan Andan, or, rather, that name was typed out.  And this

22     dispatch is about the Vlasenica-Zvornik road and it discusses the members

23     of paramilitary units in the Zvornik area.

24             Could you just tell us, please, could you comment briefly on this

25     document with regard to these two matters?

Page 21514

 1        A.   Well, I would like to explain, since I see that you have the

 2     original dispatch, I would like to explain why the signature is missing.

 3     There is no signature because at the time we did it this way: The typist

 4     would type out the dispatch, I would sign it, but then the dispatch would

 5     have to be encoded, and then of course there could be no signature

 6     appearing there.  In other words, the dispatch would be sent on -- it

 7     would be sent encoded to the addressees, whereas the original with my

 8     signature on would remain, would be kept on files.

 9             Now, this road mentioned here, the Vlasenica-Zvornik, led over a

10     hill and then it went through Sehovici, Vlasenica, that part of

11     Mount Romanija, towards Sarajevo.

12             On several occasions, at least at the time when I was in

13     Bijeljina, members of the BH Army carried out sabotage activities, and

14     they cut off the roads, they opened fire on soldiers and vehicles, and

15     there is mention made here of one of such incidents.  The other matter

16     that you mentioned, as far as I could see here, was that we said we were

17     undertaking intensive activities to process the individuals who had been

18     committed -- who had been arrested and that we would probably in the near

19     future embark on legal proceedings.

20             This was the course of action that we did and that we took when

21     we arrested these people, these individuals, during the operation.

22        Q.   Sir, could you just answer this question:  On this road, the only

23     road that you said which connected Zvornik and Sarajevo and which ran

24     through Sehovici, Vlasenica, and Caparde, is Crni Vrh also on this road?

25        A.   I think so.

Page 21515

 1        Q.   Thank you.

 2             MR. ZECEVIC: [Interpretation] If there are no objections, I would

 3     like to tender this document too.

 4             MR. HANNIS:  No objection.

 5             JUDGE HALL:  Admitted and marked.

 6             THE REGISTRAR:  As Exhibit 1D560, Your Honours.

 7             MR. ZECEVIC: [No interpretation]

 8             THE REGISTRAR:  Could the counsel please repeat the

 9     65 ter number.

10             MR. ZECEVIC: [No interpretation]

11             THE INTERPRETER:  The interpreter did not hear counsel.

12             JUDGE HARHOFF:  Mr. Andan, the Court just has one question

13     relating to the last document, 1D560.

14             If we could have it back on the screen.

15             Because we were not quite sure about who exactly is referred to

16     in the document.  The last paragraph reads that:

17             "Intensive activities are underway to process individuals who

18     have committed crimes and members of paramilitary formations in the

19     Zvornik area."

20             And this is dated the 31st of July.

21             Are we right to understand that the members of the paramilitary

22     formations to whom you are referring in this dispatch were paramilitary

23     formations such as the Yellow Wasps, or is it Muslim paramilitary

24     formations?

25             You see, Mr. Andan, we were not quite sure of who exactly was it

Page 21516

 1     who closed the road between Vlasenica and Zvornik.

 2             THE WITNESS: [Interpretation] Well, obviously I was talking about

 3     two separate matters.  Here we report that we were taking a criminal

 4     action against the Zute Ose paramilitary unit, and in the meantime, the

 5     traffic on the road was interrupted because members of the BH Army had

 6     carried out a sabotage unit and cut off this only road leading to

 7     Sarajevo.  So these are two completely separate matters.

 8             JUDGE HARHOFF:  Thank you.  It's clear to us now.  Thank you very

 9     much.

10             MR. ZECEVIC:  May I continue, Your Honours?

11             JUDGE HALL:  Yes.

12             MR. ZECEVIC: [Interpretation] Could the witness please be shown

13     1D75, tab 107.

14        Q.   Sir, this is a report or information entitled "information on MUP

15     activities on exposing the criminal activities of paramilitary formation

16     Zute ose in the area of Serb municipality of Zvornik."

17             And the number is 02-16/92.  It is dated the 4th of August, 1992.

18     And on page 3 there is no signature.  We can only see the date.  It says

19     Bijeljina, the 4th of August, 1992.

20             Are you familiar with this report or information and could you

21     tell us who authored it?

22        A.   I am familiar with this information.  It was drafted by members

23     of the crime department.  And there is no signature because this is just

24     an information.  And a document is missing here, the cover letter, where

25     probably either I or somebody else on my behalf signed that cover letter

Page 21517

 1     and forwarded it to the Ministry of the Interior.

 2             The normal procedure was not to sign the information but to sign

 3     the cover letter that is sent to an institution or to a person, whichever

 4     the case may be.

 5        Q.   Very well.  Now, in the last paragraph of this information on

 6     page 3, there is mention of what the Serb police learned and members of

 7     national security operatives and that was that a Dusan Vuckovic,

 8     aka Repic, committed a massacre genocide over citizens of the Serb

 9     Republic Bosnia-Herzegovina of the Muslim ethnicity.  And then it goes on

10     to say verification and materialisation of this information was being

11     taken care of by the Serb armed forces, military police, in co-operation

12     with MUP national security operatives.

13             Mr. Andan, do you recall, as stated here, that you had

14     information to this effect at the time, and do you recall that this

15     problem was dealt with by the military police and state security

16     operatives or national security operatives?

17        A.   Yes.  When we gathered intelligence, and through intelligence we

18     learned that Vojin Vuckovic executed Muslims for gain, personal gain, and

19     there was a time when he executed people only because they were of Muslim

20     ethnicity, and I believe that I informed the chief of national security

21     at the time, Goran Zukic, of this, that he confirmed the information that

22     I had received and told me that they were already conducting a police

23     investigation into these events involving Repic.

24             When Repic was arrested, this whole process was finalised.  And

25     as far as I can recall, after Repic was processed he was handed over to

Page 21518

 1     military security organs in Bijeljina, and a little later I believe that

 2     he was indicted and tried, I believe in Sabac, for the crimes that he had

 3     committed in Zvornik municipality.

 4             I even learned that he was evaluated, his mental state was

 5     evaluated, and that he was declared mentally unstable, but to what

 6     extent, I really can't recall.

 7        Q.   Thank you.  Now, could we just go back to the first page of this

 8     document.

 9             MR. ZECEVIC:  The document number, let me repeat that, is

10     02-16/92, dated the 4th of August, 1992.

11        Q.   Is that what it says there?

12        A.   That's correct.

13             MR. ZECEVIC: [Interpretation] Could the witness now please be

14     shown P1557.12.  That's under tab 108.  108.

15             THE WITNESS: [Interpretation] My apologies, perhaps I've skipped

16     it, but I can't see 108.

17             MR. ZECEVIC: [Interpretation]

18        Q.   Well, could you please take a look at the screen.  My apologies.

19     It's there.

20             Sir, this document, bearing number 02-16/92 dated the

21     4th of August, 1992, and we see that it is signed by approval or with the

22     approval of the minister by Goran Macar, and it says:

23             "We are hereby submitting as an attachment a report on the

24     activities of the MUP to detect the criminal activities of Zute Ose,

25     Yellow Wasps, paramilitary unit on the territory of Zvornik Serb

Page 21519

 1     municipality."

 2             And it was sent to the minister at Pale.

 3             Is this the cover letter that you mentioned a little earlier, the

 4     cover letter that was missing from that report and which explains why

 5     that report or that information was unsigned?

 6        A.   Yes.  And in general this cover letter would actually be the

 7     first page of the entire package sent to the ministry.  I told you a

 8     moment ago that I wasn't sure whether it was me who had signed this or

 9     somebody else, but here we see it and it shows that it was on the way we

10     normally did things, according to standard procedure, and especially so

11     because we see here that it says that "we are hereby submitting as an

12     attachment a report," and then as under attachments it lists that there

13     are 65 statements attached to the information as well, and so on and so

14     forth.

15        Q.   Thank you.

16             MR. ZECEVIC: [Interpretation] Let's show the witness

17     65 ter 363D1.  That's tab 126.

18             I apologise, I have just seen something.  Could we go back to the

19     previous document, P1557, to comment on it before we continue.  I do

20     apologise.  The English text is all right.  Could we just display the

21     Serbian again, P1557.12.

22        Q.   Sir, when you mention among the attachments a photocopy of a

23     certificate by Pale SJB, do you know who chief of the Pale SJB was at the

24     time?  And I'm referring to the summer of 1992.

25        A.   I think it was still Malko Koroman.  There were still some

Page 21520

 1     problems with him, but I don't know if that's relevant here.  And if you

 2     wish, I can explain.

 3        Q.   Do you know of the case when the minister of the interior of the

 4     RS tried to remove Malko Koroman from his position?

 5        A.   Yes, you phrased it adequately.  He tried to remove him.  There

 6     was information, at least that's what I heard, that he had abused his

 7     official position, that he had links with crime, and that Mr. Stanisic in

 8     writing demanded that he be replaced and that the police station at Pale

 9     be handed over to somebody else.

10             In 1992, I forget which month it was, the authorised officials

11     from the administration came to perform the take-over.  Over 3.000 armed

12     persons had gathered.  They were armed with long-barrelled weapons.  And

13     as far as I know, they drove out those authorised officials and drafted

14     an appeal to -- or a petition to President Karadzic for Malko Koroman to

15     remain in his position.  And as far as I know, he did.  And sometime

16     later, a month, two, or three, I don't know, a compromise solution was

17     found, and he was appointed to the position of chief inspector of the RS,

18     and he went to Bijeljina.

19             THE INTERPRETER:  Interpreter's correction:  Chief inspector of

20     the RS MUP.

21             MR. HANNIS:  Looking at the English transcript, I wonder if

22     counsel could clarify what's at line 12.  It doesn't seem to make sense

23     in English the way it's translated.

24             MR. ZECEVIC: [Interpretation]

25        Q.   Mr. Andan, on that occasion when those 3.000 armed men came to

Page 21521

 1     Pale or, rather, gathered there, was it then that pursuant to Karadzic's

 2     intervention Malko Koroman remained chief of the Pale SJB?

 3        A.   Yes, he did remain.

 4        Q.   Was Malko Koroman eventually replaced from the position of chief

 5     of Pale SJB?

 6        A.   Yes, he was.  And he was transferred to another position in

 7     the -- in the police administration.  He became chief inspector of the

 8     police.

 9        Q.   And then he was transferred to Bijeljina?

10        A.   I must say that the ministry headquarters was in Bijeljina for a

11     while.  I had already left the ministry when its headquarters was in

12     Bijeljina.

13        Q.   Sir, let us return to the document that I wanted to show you

14     already.  65 ter 363D1, tab 126.  This is a letter to the Department for

15     Prevention and Detection of General Crime of the Zvornik SJB.  We see

16     your name in the signature block and your signature as well.  Tell us

17     what this document is about.  It says, in the subject line, "submission

18     of objects from the Yellow Wasps operation."

19        A.   When the Yellow Wasps were arrested, we also arrested two Simic

20     brothers.  One of them was a owner of a jewellery shop before the war and

21     we suspected him of buying gold from those paramilitaries.  There was

22     intelligence that his wife was in Banja Koviljaca in Serbia, and we

23     requested the Serbian MUP to search their family house in Banja Koviljaca

24     in co-operation with the local MUP authorities.  We confiscated

25     2.2 kilograms of gold on that occasion.  We also confiscated a BMW

Page 21522

 1     automobile owned by him.  And we initiated a verification process

 2     regarding the provenance of that gold.

 3             Mr. Simic was able to prove that he was the rightful owner of

 4     that gold, which he had obtained legally.  And then we returned those

 5     2.2 kilograms of gold jewellery and the automobile to him.  This letter

 6     shows who handed over and who received these items, and I signed this

 7     document, which is not a dispatch.  But the crime prevention services is

 8     ordered to summon Simic and return these items to him.

 9        Q.   We can read here in the second paragraph:

10             "Since most of these people reside in your area, you need to

11     return their personal belongings to them."

12             Does this letter therefore relate only to Simic or to other

13     persons as well from whom the Yellow Wasps had taken some property which

14     is now being returned as a result of the Yellow Wasps operation?

15        A.   About two-thirds or even more of the members of that unit were

16     from the Zvornik municipality, and the investigation -- and the

17     investigation couldn't be established that the property was mostly

18     illegally gained, so --

19             THE INTERPRETER:  Could the witness please repeat the end of his

20     answer.  The interpreter didn't hear it.

21             MR. ZECEVIC: [Interpretation]

22        Q.   The latter part of your answer was not recorded.  Could you

23     please repeat.

24        A.   Well, briefly, I said that two-thirds of these persons were from

25     the Zvornik municipality.  The investigation established that the objects

Page 21523

 1     found with them were not gained by criminal offences, and we ordered the

 2     crime prevention service to return these items to the persons concerned

 3     because they are no longer subject to criminal processing.

 4             MR. ZECEVIC: [Interpretation] I seek to tender this document into

 5     evidence.

 6             MR. HANNIS:  No objection.

 7             JUDGE HALL:  Admitted and marked.

 8             THE REGISTRAR:  As Exhibit 1D561, Your Honours.

 9             MR. ZECEVIC: [Interpretation] Could the witness please be shown

10     P341, which is tab 89.

11        Q.   Mr. Andan, do you remember if after the arrest of the

12     Yellow Wasps the chief of the Zvornik SJB was replaced?

13        A.   Yes.  With the consent of the undersecretary and probably that of

14     the minister, we replaced all executives at the Zvornik SJB because in

15     our opinion they had not lived up to their responsibility.

16        Q.   Thank you.

17             MR. ZECEVIC: [Interpretation] 65 ter 161D1, please, which is

18     tab 121.

19        Q.   This is a document signed by the newly appointed chief of the

20     Zvornik SJB, Locancevic [phoen].  It was sent to the MUP, the crime

21     prevention and combatting service, and the Bijeljina CSB.  I'm interested

22     in item 2 on page 1.  It says information about illegal activities and

23     the legal affairs department of the public security station.

24             Did you know about this and did you establish during the Zvornik

25     operation that there had been irregularities there and what did they

Page 21524

 1     consist of?

 2        A.   I apologise, but --

 3        Q.   Go ahead.

 4        A.   I apologise, but what we see on the screen is not what you are

 5     talking about.  This is probably a technical shortcoming.

 6        Q.   Just a minute, please.  Let us first display the right document.

 7             MR. ZECEVIC: [Interpretation] 65 ter 141D1, tab 121.  The

 8     document is dated 11 August 1992.  We are interested in page 2 of the

 9     English translation.  More specifically item 2.

10        Q.   You have a hard copy in your binder, sir.  I believe that it's

11     more easily legible.

12             Do you remember the question?

13        A.   Yes, I do.  I know of this incident.  Mr. Lazic was chief of the

14     administration and legal affairs section of the Zvornik SJB.  During our

15     investigation, we established that Vojin Vuckovic, also known as Zuco,

16     through Lazic, if only temporarily, was able to legalise stolen cars by

17     getting traffic permits from Lazic, and Zuco then transferred them to

18     Serbia and sold them there.  I believe that the investigation showed that

19     he also issued some documents by which he committed a criminal offence,

20     and we suspended the man and temporarily removed him from the MUP.  And

21     in accordance with the law, we filed a criminal complaint against

22     Mr. Lazic to the public prosecutor's office in Bijeljina or Zvornik, I'm

23     not sure about the place.

24        Q.   Thank you.

25             MR. ZECEVIC: [Interpretation]  I seek to tender this document

Page 21525

 1     into evidence.

 2             MR. HANNIS:  No objection.

 3             JUDGE HALL:  Admitted and marked.

 4             THE REGISTRAR:  Exhibit 1D562, Your Honours.

 5             MR. ZECEVIC: [Interpretation]

 6        Q.   Sir, the Zute Osa or Yellow Wasps case ...

 7                           [Trial Chamber and Registrar confer]

 8             MR. ZECEVIC: [Interpretation]

 9        Q.   At least that aspect ...

10                           [Trial Chamber and Registrar confer]

11             MR. ZECEVIC: [Interpretation]

12        Q.   So my question is, these Yellow Wasps that were processed by the

13     crime prevention and detection service, were they covered by a criminal

14     complaint submitted to the public prosecutor's office in Bijeljina?

15        A.   Yes.  It was our duty then, in addition to the criminal report

16     with the description of the crime involved, to provide all the evidence

17     that we had gathered during our operations, so all of this was properly

18     handed over to the public prosecutor's office in Bijeljina.

19        Q.   After a while were they released from custody on the basis of a

20     decision made by the prosecutor and the investigating judge of the court

21     in Bijeljina?

22        A.   Unfortunately, yes.  Once they were released, some other problems

23     came to the fore, and we are probably going to discuss that later.

24        Q.   Please go ahead.  What were these problems on account of their

25     release?

Page 21526

 1        A.   Well, because of their release, the family house of

 2     Mico Davidovic was monitored, also the house where I was staying

 3     temporarily, and also the observation of some other persons who were

 4     direct participants in that operation of ours, that is to say, the top

 5     personnel involved.

 6        Q.   When you say "observation," tell me, what do you mean?  An

 7     observation by who?

 8        A.   This problem was particularly pronounced in relation to myself,

 9     because parts of this paramilitary unit, even Zuco himself, from time to

10     time came close to the building where I was, and the information we had

11     indicated that shortly they would try not only to kill me, but also

12     Mico Davidovic and all the other key people who were involved in the

13     operation of their arrest at the time.

14             As I said, this was particularly pronounced in relation to myself

15     because I will explain later how it was that I left the ministry and I

16     was therefore without any support and any protection.  As a matter of

17     fact, I think that some persons, some individuals from Bijeljina whom I

18     had also arrested and detained, instigated Mr. Vukcevic [phoen] to commit

19     something that abominable, that is to say, assassinate me.

20        Q.   Mr. Andan, you and other persons you mentioned here who were

21     threatened by the members of this paramilitary unit that had been set

22     free, or, rather, they were provisionally released, were you concerned

23     about your own safety and the safety of your family members who lived

24     with you?

25        A.   Of course I was concerned, primarily for my family members.  I

Page 21527

 1     had two children who were under age at the time, two sons.  Then my wife

 2     was there, too, as well.  And I was the only one who could protect them.

 3     I had no other protection and I was worried.  I was so worried that once

 4     I called Mr. Davidovic in Belgrade and I said to him, because Davidovic's

 5     unit had already withdrawn from Bijeljina, I said to him that I had some

 6     information, what I already told this Court about, and that quite simply

 7     I was afraid to spend nights by the window with a cocked rifle in the

 8     fear of having my house being attacked.  He sent two young men who were

 9     guarding my house for about ten days and in that way both my family and

10     myself felt a bit less encumbered.

11        Q.   For the transcript, you said that you were concerned, worried,

12     and that that is why you spent the nights by the window with a cocked

13     rifle without any lights on; right?

14        A.   Yes, yes, that's right.  Because I can see better if the light is

15     not on in the room where I'm sitting, because that was particularly the

16     case during the night, when they would circle around the house either on

17     foot or in cars.

18        Q.   Thank you.

19             MR. ZECEVIC: [Interpretation] For the Trial Chamber, the exhibits

20     that deal with this question are P317.21, and P344, P637, P345, and P195.

21             Could the witness please be shown 65 ter --

22             JUDGE DELVOIE:  Mr. Zecevic, could we have tab numbers for those

23     documents?  That would be ...

24             MR. ZECEVIC:  Yes, I'm sorry.  I'm sorry, Your Honours.

25     Tabs 140, 142, 143, 144, and 149.

Page 21528

 1             JUDGE DELVOIE:  Thank you.

 2             MR. ZECEVIC: [Interpretation] Could the witness please be shown

 3     65 ter 22P1.  That is 118A; that's the tab number.

 4        Q.   Sir, this is a dispatch of the Ministry of the Interior of

 5     Republika Srpska, Sarajevo.  It is signed by the minister of the

 6     interior, Mico Stanisic.  In this dispatch instructions are provided as

 7     follows:

 8             "In accordance with the decision of the Presidency, the MUP and

 9     the Ministry of Justice should obtain officially correct information in

10     relation to the behaviour of the Serb authorities in terms of the

11     treatment of war prisoners and the conditions of life of detainees in

12     prisons in the municipalities where there are such cases.  All public

13     security stations are duty-bound to act in accordance with the decision

14     of the Presidency."

15             Instructions are provided here about the freedom of movement and

16     so on.  We have the entire order.  It says that with regard to the

17     measures taken and the situation as it is, you are duty-bound to inform

18     this information by the 14th of August, 1992.

19             Do you remember having received this kind of dispatch in the

20     beginning of August 1992?

21        A.   Yes, I remember.

22             MR. ZECEVIC:  Could the witness --

23        Q.   Actually, did you act in accordance with this order?

24        A.   Of course.  That is our duty by law, and we responded in an

25     appropriate manner.  In the area of Bijeljina, we did not have any

Page 21529

 1     detention centres or camps that were held by the MUP.

 2             MR. ZECEVIC: [Interpretation] 65 ter 175D1, tab 123.

 3        Q.   I'd like you to have a look at that document.

 4             Sir, this is a document from the 11th of August, 1992.  It is

 5     sent to the Eastern Bosnia Corps, and it's for the commander.  It has to

 6     do with this dispatch.  Actually, this dispatch that we looked at a

 7     moment ago is being sent to them.  Can you give us your comment with

 8     regard to this document, because it says down here "Chief Dragan Andan,"

 9     and somebody's signature is there as well.

10        A.   Somebody obviously signed this on my behalf, but this is an

11     authentic dispatch, and this is accurate.  In view of the subject matter,

12     that it was treated by the dispatch that we received from the Ministry of

13     the Interior, we did not have any information and there weren't any

14     detention camps or detention centres for non-Serbs.  Since we knew that

15     the Batkovici camp was under the control of the Army of Republika Srpska

16     or, rather, of the Eastern Bosnia Corps, we sent this dispatch to the

17     commander because they were the persons who were actually supposed to

18     respond in an appropriate manner to the dispatch.

19        Q.   Thank you.  Do you remember whether you received an answer from

20     the Eastern Bosnian Corps?

21        A.   As far as I remember, no.  However, that does not necessarily

22     mean that they did not provide a direct response to the government or the

23     Ministry of the Interior, but we did not receive any answer from them.

24             MR. ZECEVIC: [Interpretation] Could this document also be

25     admitted into evidence, please, if there are no objections.

Page 21530

 1             MR. HANNIS:  No objections.  And did you want the earlier one as

 2     well?

 3             MR. ZECEVIC:  I believe the earlier one is already exhibited as

 4     the order by the ministry, but I will have to check over the break and I

 5     will inform you.

 6             JUDGE HALL:  But this document which, according to the witness,

 7     yielded no response, what does it add to what we already know?  It's a

 8     request for information.  There was no response.  Why do we need it?

 9             MR. ZECEVIC:  Yes, Your Honours, but it clearly -- it clearly

10     indicates the fact that the Ministry of the Interior in Bijeljina did not

11     have anything to do with the Batkovici war camp and that it was under the

12     specific and exclusive authority of the army, and therefore I think that

13     for that reason this is relevant.

14             MR. HANNIS:  Well, that's a further-reaching conclusion than I

15     would say stems from it, but I think it is a contemporaneous writing by

16     this witness which reflects his state of mind about the status of that

17     camp and therefore I think it's relevant.  It goes to the weight of his

18     testimony.

19             JUDGE HALL:  Admitted and marked.

20             THE REGISTRAR:  Exhibit 1D563, Your Honours.

21             MR. ZECEVIC:  I see the time, Your Honours.

22             JUDGE HALL:  So we take the break, to resume in 20 minutes.

23                           [The witness stands down]

24                           --- Recess taken at 12.05 p.m.

25                           --- On resuming at 12.34 p.m.

Page 21531

 1             MR. ZECEVIC:  Your Honours, before the break, at page 47, line 24

 2     and -5, we were talking about the document which I showed to the witness

 3     immediately prior to the break.  It's 65 ter 22D1 and our tab 118A.  And

 4     Mr. Hannis was questioning whether this document will be exhibited, and I

 5     said that we will check, that I believe the document is already exhibited

 6     with a similar wording in it.  And we have located the document.  It

 7     bears the exhibit number P999.  This is all the information that I wanted

 8     to give to the Trial Chamber.

 9             JUDGE HALL:  Thank you, Mr. Zecevic.

10                           [The witness takes the stand]

11             MR. ZECEVIC: [Interpretation]

12        Q.   Mr. Andan, before we go on, may I just ask whether the air

13     conditioning situation has been regulated or do you still have a problem?

14        A.   Yes, it's been regulated.

15             MR. ZECEVIC: [Interpretation] Could the witness please be shown

16     653 --  653D1 is the 65 ter number.  Tab 25.  Tab 125.

17        Q.   Mr. Andan, this is a document signed by the War Presidency of

18     Brcko, Djordje Ristanic, sent on the 12th of August, 1992, to the

19     CSB Bijeljina and the corps command.  And in paragraph 2 it says that

20     it's the "decision of the War Presidency to issue an order banning the

21     population from leaving our municipality without special approval from

22     the military command in case of military personnel or approval from the

23     Brcko Public Security Station in the case of the rest of the population."

24             As far as we can see, it has do with the problem referred to in

25     the first paragraph, that they have problems with soldiers and other

Page 21532

 1     military conscripts who leave military obligation and compulsory work

 2     service without authorisation, so they say return them or arrest them.

 3     Can you give us your comment on this document and in your view which

 4     population does this document refer to?

 5        A.   This pertains to the Serb population, military age, able-bodied

 6     men who for a variety of reasons were fleeing from the front line and

 7     thereby destabilising the line.  This order is, of course, addressed to

 8     the security centre.  I think that in accordance with legal regulations

 9     that were in force we did not have the ability to arrest people, that was

10     in accordance with the law.  However, we would send them to the public

11     security station and then they would send them to the military security,

12     so that is how the cycle went.  It refers to ethnic Serbs, military age,

13     who were fleeing from the front line, at any rate.

14        Q.   Thank you.  What do you base that conclusion on, that these are

15     ethnic Serbs?

16        A.   Since it was addressed to us and the military security and since

17     special approvals were required for leaving the combat area, I assert

18     that these are ethnic Serbs who either due to the pressure of

19     paramilitary formations or due to fear or Serb heroism when you drink a

20     litre or two, I don't know, but at any rate this pertains to ethnic Serbs

21     of military age.

22        Q.   Mr. Andan, do you have any knowledge to the effect that such

23     problems that had to do with the fact that persons who had a military

24     obligation to serve in the Army of Republika Srpska -- actually, were

25     such cases frequent?  Did people often leave units of their own free will

Page 21533

 1     and did they flee from their obligations, as it were, in the area where

 2     you lived?

 3        A.   Yes.  This problem did not exist only in the area of the

 4     municipality of Brcko.  This problem pertained to a great many

 5     municipalities, especially those that were bordering with the

 6     Republic of Serbia, so mobilisation could not fully be carried out, the

 7     one that was in force at the time.  I had a few other examples of people

 8     who we arrested and took to the front line.  That was just the way the

 9     times were.

10        Q.   Thank you.

11             MR. ZECEVIC: [Interpretation] If there are no objections, I would

12     like to tender this document into evidence as well.

13             MR. HANNIS:  No objection.

14             JUDGE HARHOFF:  What do you wish to show, Mr. Zecevic?

15             MR. ZECEVIC:  Perhaps the witness can take the ...

16             Your Honours, the allegations throughout the case were that the

17     police had the role in establishing the places on the roads where they

18     were checking and maltreating the non-Serb population, checking their

19     identity papers and so on and so forth.  Now, this document shows that

20     the reason why these places were established in the first place was

21     essentially for the reasons because the Serbs were fleeing their

22     obligation to participate in the mobilisation and the

23     Army of Republika Srpska.

24             Now, that is the purpose of this document.

25                           [Trial Chamber confers]

Page 21534

 1             JUDGE HALL:  So the Chamber, Judge Harhoff dissenting, agrees

 2     that it should be admitted and marked as an exhibit.

 3             THE REGISTRAR:  Exhibit 1D564, Your Honours.

 4             MR. ZECEVIC:  Your Honours, I'm sorry, when -- before the witness

 5     was brought in, I was referring to the document which has already been

 6     exhibited as P999.  Now I'm informed that this document is MFI'd.  Now,

 7     as the witness acknowledges the receipt of this -- of the document which

 8     I showed him, which is essentially the very same document, I propose, if

 9     Mr. Hannis does not object, and I hope he will not, that the document

10     P999 be de-MFI'd at this point.

11             MR. HANNIS:  Your Honour, I'm not opposed to de-MFI'ing the

12     Prosecution exhibit, but I would like to indicate on the record I would

13     like to leave open my option, perhaps, to move in the Defence exhibit

14     upon examination if I see they're not precisely identical and there's

15     some reason that I would want to do that.  But for now I'm content to

16     have P999 become a full exhibit without the MFI designator.

17             JUDGE HALL:  It was marked for identification pending what?

18             MR. HANNIS:  I don't recall.  I assume that was Defence objection

19     at the time because we didn't have a witness who was familiar with it.

20             MR. ZECEVIC:  At this point, Your Honours, we are checking what

21     is the situation.  We just had the information that it was P999 MFI.

22     That is why I brought it up.

23             JUDGE HALL:  But Mr. Hannis having indicated his - reservation is

24     too strong a word - his caveat, I suppose, we would de-MFI it.

25             One of these days I'm going to come up with a phrase with which

Page 21535

 1     I'm comfortable, but for the moment I go along with the convention of

 2     "de-MFI'ing" it.

 3             MR. ZECEVIC:  Thank you, Your Honour.

 4                           [Trial Chamber and Registrar confer]

 5             JUDGE HALL:  We are informed by the Court Officer that it was

 6     only marked for identification because it was not on the 65 ter list.

 7             Thank you, Anna.

 8             MR. ZECEVIC:  Well, therefore we withdraw our objection in that

 9     respect.  Thank you.

10        Q.   [Interpretation] Sir --

11             P410 MFI'd.  Could that document please be shown to you.  That is

12     tab 71.

13        Q.   Sir, this is a document that does not bear a date.  On the last

14     page we just see July 1992, and we see Danilo Vukovic chief, by way of a

15     signature, and on the first page we see that this is a report on the

16     results of --

17             THE INTERPRETER:  Interpreter's note:  We do not have the first

18     page.

19             MR. ZECEVIC: [Interpretation]

20        Q.   -- in SJB Bijeljina for the period from the 26th of June until

21     the 25th of July, 1992, as well as a summary of information on certain

22     operative observations regarding criminal acts and other illegal acts in

23     the period of war and immediate post-war events in Bijeljina.

24             Sir, my first question:  Was Danilo Vukovic head of the

25     department for crime prevention and crime investigation in the

Page 21536

 1     SJB Bijeljina in the relevant period?

 2        A.   Yes, he was.

 3        Q.   Are you familiar with this report?  Obviously it's a monthly

 4     report, it includes a 30-day period?

 5        A.   Yes, I'm familiar with this report.

 6        Q.   Who was this report sent to?

 7        A.   This report had to be sent to the appropriate departments, namely

 8     the crime police department, the uniformed police department, the

 9     analysis people, and quite often such a report is sent to the

10     Minister of the Interior.  It is not compulsory, but it happened not very

11     seldom that such reports were sent to the minister as well.

12        Q.   At any rate, there is no doubt -- or, rather, is it beyond any

13     doubt that this report was sent to the ministry headquarters?

14        A.   Yes, yes, it was sent to the ministry headquarters.

15             MR. ZECEVIC: [Interpretation] I would like to tender this

16     document.  I would like to ask that it be de-MFI'd.

17             MR. HANNIS:  Your Honour, I have no objection to that promotion,

18     elevation, or whatever term we would like to use.

19             JUDGE HALL:  So we remove the MFI classification or

20     qualification.

21             MR. ZECEVIC: [Interpretation] Just one more intervention in the

22     transcript: 53/21, I think that this is a continuation of the witness's

23     answer rather than my question.

24        Q.   Sir, do you remember your answer when I asked you about this

25     report.  You were explaining - you were explaining - who these reports

Page 21537

 1     were usually sent to, which departments; right?

 2        A.   Yes.

 3             MR. ZECEVIC: [Interpretation] 53/21 should be part of the

 4     witness's answer.

 5             65 ter 139D1.  Tab 64.  Could that document please be shown to

 6     the witness.

 7        Q.   Sir, this document is entitled:

 8             "List of criminal reports submitted in the period from the

 9     26th of June to the 25th of July, 1992, which we have not reported to you

10     in dispatches owing to the interruption of dispatch communications."

11             Tell me, since it involves the same time-period, is this report

12     perhaps part of the previous document that we saw?

13        A.   Yes, it could be.

14        Q.   Could you please tell us, are you familiar with this report, with

15     this list, or not?

16        A.   Yes, I am.  The more so because I was the one who insisted that

17     such a run-down be made.

18        Q.   It says here in the title that it is a list of complaints that

19     had not been reported by way of dispatch because of an interruption in

20     dispatch communications.  Could you please clarify that or explain it a

21     bit to us?

22        A.   Well, yes, as I have already said earlier, it was frequently the

23     case that the dispatch or phone lines were down so that we had -- so that

24     we sent all urgent information by courier.  Obviously this was not a

25     matter of any urgency, so that we sent it on a monthly basis.  We

Page 21538

 1     compiled a list of criminal complaints and forwarded it to the

 2     Ministry of the Interior.  And of course because of the subject matter,

 3     this kind of communication would also be sent to the analysis department.

 4        Q.   So have I understood your words correctly:  This is an additional

 5     report with some additional criminal complaints that the ministry had not

 6     been informed of earlier; is that correct?

 7        A.   Yes, that's correct.

 8        Q.   Does this document pertain to all crimes that had been processed,

 9     as it were, or those that the police was aware of at the moment, that

10     they had been committed, and where criminal complaints had been forwarded

11     to the appropriate prosecutor at the time?

12        A.   Yes, this is the time-frame in question, and this report relates

13     to that time-period and all those complaints that had been sent to the

14     prosecutor at the time.

15        Q.   Thank you.

16             MR. ZECEVIC: [Interpretation] If there are no objections, I would

17     like to tender this document.

18             MR. HANNIS:  No objection.

19             JUDGE HALL:  Admitted and marked.

20             THE REGISTRAR:  Exhibit 1D565, Your Honours.

21             MR. ZECEVIC: [Interpretation] The next document is 1D97.  That's

22     under tab 76.

23        Q.   This document, or, rather, the cover letter attached to this

24     document, bears your signature as the head of -- or chief of the

25     Security Services Centre.  It is dated the 29th of July, 1992, and it is

Page 21539

 1     addressed to the president of the Presidency of the Serbian Republic of

 2     Bosnia-Herzegovina, Mr. Radovan Karadzic.  Do you recall it?

 3        A.   Yes, yes, this is my document.

 4        Q.   On page 2 it says that this is a report on the involvement and

 5     activities of the Ministry of the Interior of the Serbian Republic of

 6     Bosnia-Herzegovina in establishing authority under rule of law in the

 7     area covered by the Bijeljina Security Services Centre.

 8             And on the last page, page number 5, although it's probably

 9     page 4, or perhaps a page is missing from this document, we see again

10     your signature there.  Is that your signature and the date indicated

11     there?

12        A.   Yes, this is my signature.

13        Q.   Tell me, please, in the paragraph before last, where, toward the

14     end, it says:

15             "In order to provide the full information, we have to stress that

16     there were instances where members of the MUP of the Serbian Republic of

17     Bosnia-Herzegovina, we encounter severe opposition among them and

18     resistance, not only verbal but also armed," and then mention is made of

19     three unsuccessful assaults on the premises of the CSB, on the building

20     itself, could you please comment on this?

21        A.   Yes.  Well, this is basically just a description of everything

22     that we worked on and everything that we had to deal with at the time in

23     Bijeljina.  Earlier on I had already mentioned how there was a lot of

24     disaffection because of the people of Serb ethnicity who were avoiding to

25     be recruited and then they were sort of employed by the police stations.

Page 21540

 1     And then there was disaffection because of the curfew that was

 2     established.  The local authorities wanted to control the work of the

 3     Ministry of the Interior, and we opposed that.  And there were even

 4     individuals who went so far as to claim that we were the ones who were

 5     supposed to believe the Bijeljina area and just leave the paramilitary

 6     units there.  So I will not talk about the political climate there; I

 7     will just talk about the security aspect.  And I have to say that both

 8     citizens and security services employees were in jeopardy and it was my

 9     goal to try one more time to inform the highest, the top leadership of

10     the Serbian Republic of Bosnia-Herzegovina about the situation in

11     Bijeljina and Majevica.

12             Now, the second thing was, and you will -- I have to stress

13     something about myself, I am an impatient person by nature and I don't

14     like to leave things for tomorrow if they can be done today, so I was

15     never happy with the fact that there were some paramilitary units

16     entering the Republic of Republika Srpska and I deliberately addressed

17     both the president of the government and the municipal political

18     authorities, and this was an attempt to inform the highest leadership of

19     the then leadership of Republika Srpska to inform them in detail of the

20     security situation because -- and asking for their full support because

21     we again had a situation where there was a new attempt to destabilise the

22     situation in Bijeljina.  There was Mauzer who appeared there and then

23     others after him, and we were beginning to lose -- we were beginning to

24     have a lot of loose ends and there were attempts to incite people

25     against -- to opposing our orders and so on.  So our purpose was to

Page 21541

 1     inform the highest leadership of the security situation in Bijeljina,

 2     trying in that way to obtain their political support for what measures we

 3     were trying to implement at the time.

 4        Q.   Sir, in this document, we see on the last page that there is

 5     something in handwriting added on.  Could you please just tell us that

 6     what that refers to, if you know?

 7        A.   Well, obviously this information did reach the then president of

 8     Republika Srpska, Radovan Karadzic, and from what it says there, I see

 9     that he did support us, and I mean in terms of what we laid out in this

10     letter, and he says that we should continue enforcing order and the rule

11     of law in this area.  I don't know if he meant other areas as well, but

12     specifically he did mean Semberija and Majevica areas.

13        Q.   Do you have any knowledge as to what Mrs. Biljana Plavsic's

14     position was on -- and what her attitude was, what her take was, on

15     paramilitary units?

16        A.   Well, I think I do know some of what her attitude or position

17     was, and I know that there was even a written report relating to those

18     matters.  I don't know exactly where you could find it now, but it had to

19     do with the release of Vojin Vuckovic, aka Zuco.  He was released from

20     prison, from Bijeljina.  He went to Pale where he was seen by

21     Mrs. Plavsic, that she made certain promises and gave certain promises to

22     him.  I don't know the details, but I do know that we sent information to

23     that effect to the highest -- to Pale because she actually met with the

24     leader of one of the cruelest paramilitary units.

25             Now, we also handled this situation in a legal way, if I can put

Page 21542

 1     it that way.  We learned, namely, that the certain Marko Pavlovic, who

 2     was the Chief of Staff of the Territorial Defence, having false personal

 3     documents issued in Sekovic.  This Marko Pavlovic was supposed to be, and

 4     I think he was, from Backa Palanka.  We surrendered this person, we

 5     handed him over to the national security organs, I believe he was taken

 6     to Pale.  But after he was released, Mrs. Plavsic had a meeting with him

 7     as well.

 8             MR. ZECEVIC: [Interpretation] Could the witness please be shown

 9     65 ter 165D1, tab 81.

10        Q.   Sir, this is a report of the crime rate in the period between

11     1 July and 31 July 1992.  Unfortunately we only have the first page of

12     this document.  Are you familiar with this report?

13        A.   Yes, I am.  I'm also sorry that the remaining two or three pages

14     are missing.  This is not a TV commercial by any means, but we did try to

15     act in accordance with the laws and regulations of the Republika Srpska

16     at the time.  And we made snap-shots of the situation.  We never beefed

17     up these reports.  There was no need to.  And we sent these reports to

18     the ministry.  And sometimes we would also copy the local authorities.

19        Q.   Sir, I'm especially interested in the last two paragraphs of this

20     document.  Could you comment, if you remember what this is about.

21        A.   If you mean the last two?

22        Q.   Yes.

23        A.   Well, I don't know precisely now, but these people mentioned here

24     as the perpetrators of murder had ties with Salko Kukic, and we say here

25     that a criminal report was filed against them and that we took -- took

Page 21543

 1     all measures necessary against him.

 2        Q.   But the point is, is it the case that in both these cases the

 3     individuals involved are of Serb ethnicity?

 4        A.   Well, yes.  And I have to say also that we filed criminal

 5     complaints against individuals of non-Serb ethnicities.  I'm sure you can

 6     find it in our files.  But we also submitted criminal reports against

 7     some Roma because they took advantage of the situation as it was then.

 8     They pretended they were Muslims and they went looting property, so in

 9     that way we tried also to prevent their activities and stop them from

10     getting engaged in criminal activity.

11        Q.   But you said that the members of Roma ethnicity actually declared

12     themselves to be of Muslim ethnicity?

13        A.   Yes, yes, that's what I said.  They declared themselves to be of

14     Muslim ethnicity.

15        Q.   Thank you.

16             MR. ZECEVIC: [Interpretation] If there are no objections,

17     although this document is not complete and it was the best version we

18     could obtain at this time, Your Honour, I would like to tender it into

19     evidence.

20             MR. HANNIS:  Is -- have we had any further explanation about why

21     it's incomplete or if the witness knows anything about that?

22             MR. ZECEVIC: [Interpretation]

23        Q.   Well, Witness, perhaps you can answer this question.

24        A.   Well, as I sit here, I don't know why it's incomplete, why two or

25     three pages are missing.  Because if there was page 1, obviously there

Page 21544

 1     should have been pages 2 and 3.  Where they might be, I really don't know

 2     nor can I answer as I -- to that -- give an answer to that question as I

 3     sit here.  But I can confirm that there was -- that this was a report

 4     from a period of one month where we reported on our work in that period.

 5     I cannot really explain why this is incomplete because I was just shown

 6     this report here and I hadn't seen it anywhere else.

 7             MR. ZECEVIC:  I don't know if this is a satisfactory reply.

 8             JUDGE HALL:  Well, we're dealing with what we have, so I --

 9             MR. HANNIS:  May I raise one other question:  Can I ask about the

10     provenance of this document?  Is this an OTP document?  Does it have an

11     ERN?

12             MR. ZECEVIC:  I'm informed that this document was received from

13     the witness.

14             MR. HANNIS:  During proofing?

15             MR. ZECEVIC:  No, not during proofing.  During probably one of

16     the interviews.

17             MR. HANNIS:  Okay.  Could we have some further inquiry as to

18     where he got it?  Is it in his personal collection or was it received

19     from another source?

20             JUDGE HALL:  Especially in light of his answer which appears at

21     line 15 and 16 of the previous page:  "I cannot really explain why this

22     is incomplete because I was just shown this report here and I hadn't seen

23     it anywhere else."

24             THE WITNESS: [Interpretation] Well, I may have received this

25     document from Danilo Vukovic, or maybe I found it in the archives of the

Page 21545

 1     Ministry of the Interior, but as I said, I can't recall.  There were two

 2     or three pages but I can't really ascertain here how many.

 3             MR. HANNIS:  I guess, Your Honour, I'm going to object to it

 4     then.  You heard his oral testimony about this, and I think that's

 5     adequate, given the lack of further information about the provenance, the

 6     document, and what and how much is missing and why.

 7             MR. ZECEVIC:  I accept.  So I withdraw my proposition to admit

 8     this document.

 9        Q.   [Interpretation] Mr. Andan, I would like you to see now 1D392,

10     tab 63.  Sir, this document is dated 23rd of July, 1992.  It's an

11     authorisation issued to Dragan Andan.  It is signed by the minister of

12     the interior.  And then we see that it says "for Mico Stanisic" because

13     someone else signed it on his behalf.

14             Do you recall receiving this authorisation?

15        A.   Yes, I do.

16        Q.   Thank you.  Mr. Andan, I'd like to show you 65 ter 671D1.  That's

17     at tab 72A.  When we looked at your diary, you told us about the meeting

18     concerning your trip to Foca.  This is a dispatch sent to the prime

19     minister, Mr. Djeric, where he's informed that the security and political

20     situation in Foca is critical and that on 23rd July there were

21     significant, numerous incidents in the town itself in which members of

22     the MUP were assaulted, disarmed, and beaten up and their property

23     destroyed.  And there is a request that certain responsible individuals

24     headed by the prime minister should visit the town, come there in person

25     to see the situation.

Page 21546

 1             Now, tell us, in the meeting that you had with the minister, were

 2     you told anything about these events here?  Were you told anything about

 3     the situation in Foca?

 4        A.   Yes, Minister Stanisic did tell me about what he knew about this,

 5     and he also related some additional information that was not entered in

 6     this dispatch, information based on intelligence that he had received

 7     from the security organs.

 8        Q.   Did you receive any other reports on the situation in Foca, and

 9     if so, who from?

10        A.   Right before my departure to Foca -- and let me also say that we

11     didn't go to Foca because we didn't receive approval from the MUP of

12     Serbia to pass through their territory with long-barrelled weapons.  But

13     I did get additional information from Mico Davidovic who had gone to

14     Pljevlja with the same unit with which he was in Bijeljina, and there he

15     disarmed a Chetnik formation.  I believe that its leader was called Ceko

16     or some such.  And he also got intelligence from Foca there.  And

17     something I heard from him confirmed everything that we saw in this

18     dispatch and more.  And the other piece of information referred directly

19     to me and the other persons that were supposed to go to Foca.

20             Davidovic had learned that these persons knew that somebody would

21     come from Bijeljina to disarm them and implement the legal procedure.

22     They were going to ambush us outside of Foca and their primary goal was

23     to kill me.  I even think that Mr. Davidovic drafted a dispatch that he

24     forwarded to the MUP containing this intelligence.

25             MR. ZECEVIC: [Interpretation] I seek to tender this document into

Page 21547

 1     evidence.

 2             MR. HANNIS:  No objection.

 3             JUDGE HALL:  Admitted and marked.

 4             THE REGISTRAR:  Exhibit 1D566, Your Honours.

 5             MR. ZECEVIC: [Interpretation] Court's indulgence.

 6             65 ter 24D1, can we show that, please.  Tab 129.

 7        Q.   This document was sent to the public security station, and the

 8     signatory is the undersecretary of the public security station

 9     Cedo Kljajic.  Probably there is something wrong with this.  It was sent

10     to the Zvornik SJB.  Could you comment on this document, please.

11        A.   Yes, clearly the signature block is wrong.  He can't be

12     undersecretary of the public security station.  He can be undersecretary

13     for public security.  We needed a minibus big enough to transport

14     30 police officers from Bijeljina to Foca.  So this is a request to be

15     given a vehicle to transport 30 uniformed personnel to Foca.

16        Q.   Let us turn to page 3, but I believe that your page is wrongly

17     marked.  Do look at the screen.  I'm not sure that you have the right

18     page in your binder because I don't have one in mine.  This was signed by

19     Dragan Kijac, and it's dated 19 August 1992.  Is this the document you're

20     looking at?

21        A.   Yes.

22        Q.   This document was drafted to call a meeting at the Bijeljina SJB

23     on the 20th of August to organise the departure to Foca.  Do you

24     remember?

25        A.   Yes, I do.  And this meeting was indeed held.  We also discussed

Page 21548

 1     some details that were important for this operation, and Mr. Radovic also

 2     played an important role because he had fresh information about the

 3     overall security information.  He was supposed to come to Foca with us as

 4     the representative of national security.

 5        Q.   And now let me show you page 2 of the document.  It's dated

 6     19 August and in the signature block we read "Minister of the Interior

 7     Mico Stanisic."  But it seems that somebody else signed on his behalf.

 8     And we see that the document was sent to the Serbian MUP and the

 9     Montenegro MUP.  Can you comment?

10        A.   Yes.  I've already said that we were unable to reach Foca unless

11     we go through the territory of two other countries or republics.  And

12     these two are Serbia and Montenegro.  Lest they should treat us as a

13     paramilitary unit, and in order to legalise our passage through their

14     territories, we sent this official dispatch to the two MUPs.  And as far

15     as I remember, the MUP of Montenegro never replied.  And as far as I

16     remember, the reply of the Serbian MUP was negative.  The planned

17     operation had to be put off.

18        Q.   Thank you.

19             MR. ZECEVIC: [Interpretation] I seek to tender this document in

20     evidence.

21             MR. HANNIS:  No objection.

22             JUDGE HALL:  Admitted and marked.

23             THE REGISTRAR:  Exhibit 1D567, Your Honours.

24             MR. ZECEVIC: [Interpretation] I'm going to show you document

25     65 ter 23D1, dated 10 August.

Page 21549

 1             THE WITNESS: [Interpretation] Which tab?

 2             MR. ZECEVIC: [Interpretation]

 3        Q.   No, we're done with this.  We're moving on.

 4             Mr. Andan, I'm going to show you document 65 ter 15D1.  That's

 5     tab 42.  This is an Official Note dated 4 July 1992.  And it says:

 6     "Pursuant to an order from Deputy Minister of the Serbian MUP

 7     Cedo Kljajic."  It's about a poker machine.  Can you tell us more about

 8     this?

 9        A.   Yes, I can.  And I'm glad you raised this because I was afraid

10     you wouldn't.  This is an Official Note showing that I took a poker

11     machine that was deposited at the SJB and used it for operative purposes.

12     I can say to this Trial Chamber under oath what it was all about at the

13     time.

14             In the Jana municipality we found a person who we used as an

15     informant.  That person owned a small catering establishment, and I took

16     this poker machine from our storage for this person to use as a -- to pay

17     him back for what he had done to us.  And this poker machine later turned

18     into a Damocles sword above my head.  I can explain why.

19        Q.   Let's move on and then you can explain later.  But let me ask

20     you, is this document an official certificate that you took this poker

21     machine?

22        A.   Yes.  This is an official confirmation that I took this poker

23     machine from our storage.

24             MR. HANNIS:  Are you going to tender it?  I have no objection if

25     we could have some evidence from the witness about the signatures, if you

Page 21550

 1     he knows who either of those belong to.

 2             MR. ZECEVIC: [Interpretation]

 3        Q.   You heard the question.

 4        A.   On the right-hand side, that's my signature; and on the left-hand

 5     side, the signature of the warehouse manager.  I don't remember who it

 6     was at the time.  Mr. Marjanovic possibly.  But certainly on the

 7     right-hand side these are my initials or my signature.

 8             MR. ZECEVIC: [Interpretation] I see the reaction of the

 9     Trial Chamber with regard to this document.  I agree it is not directly

10     relevant for this trial and this indictment, but it is relevant when it

11     comes to the credibility of the witness and the termination of his

12     service in the Ministry of the Interior.

13             MR. HANNIS:  I agree.  I think it's part of the whole story about

14     this witness, Your Honour, and I'm not opposed to it being admitted.

15                           [Trial Chamber confers]

16             JUDGE HALL:  Mr. Zecevic, if we understand the purpose for which

17     you are relying on this Official Note, it would be in our view premature

18     to tender it at this stage.  It may very well be, depending on what

19     happens as we progress, that there may be a basis on which it then

20     becomes relevant to the credibility as you've indicated of this witness.

21     But at this point it is, on the face of it, wholly irrelevant to the

22     issues, to the live issues before the Chamber.

23             MR. ZECEVIC:  I agree, Your Honours.  I'm actually asking for the

24     instruction whether we should perhaps MFI the document or just leave it

25     like as it is, and then if the -- if the issue is raised, then I can

Page 21551

 1     re-address this issue during my re-direct examination.  I believe

 2     probably that would be the course to take.

 3             MR. HANNIS:  Your Honours, the witness had indicated he wanted to

 4     make a fuller explanation about it.  If you hear that now, then that may

 5     change your mind about whether it's timely to perhaps admit this or mark

 6     it MFI.

 7             JUDGE HALL:  I -- that did occur to me, Mr. Hannis, but speaking

 8     entirely for myself, I abandoned that for the simple reason that, as I

 9     later explained, whatever the explanation is, useful though it may be,

10     it's all irrelevant at this point to the issues before us.  That may

11     come.  And I agree with Mr. Zecevic that so that we keep track of these

12     things, we could mark it for identification and leave it at that for the

13     time being.

14             THE REGISTRAR:  It will become Exhibit 1D568, marked for

15     identification, Your Honours.

16             JUDGE HARHOFF:  Judge Harhoff dissenting.

17             JUDGE HALL:  Yes, please continue.

18             MR. ZECEVIC: [Interpretation]

19        Q.   Mr. Andan, did you return this poker machine where you had taken

20     it from on the 28th of August?

21        A.   Yes, I did.

22             MR. ZECEVIC: [Interpretation] Could we please show to the witness

23     65 ter 179D1.

24        Q.   Mr. Andan, this is an Official Note drafted on 28 August 1992.

25     We read that the Official Note was submitted by ... and your signature

Page 21552

 1     below that.  Is this your Official Note?

 2        A.   Yes, it is.

 3        Q.   Sir, in this Official Note you state that on 18 August 1992 you

 4     were summoned to Belgrade by the minister of the interior Mico Stanisic

 5     to discuss the departure to Foca with part of the special purposes unit.

 6     Since we have seen your notes and we saw them at the outset of today's

 7     work, you said then that you don't know whether there was a discussion

 8     with the minister.  Do you remember now that it took place on the

 9     28th of August, 1992?

10        A.   This is an Official Note and it -- well, there's no mistake about

11     it.  It certainly was the way it was written here.

12             MR. ZECEVIC: [Interpretation] Your Honours, I believe that the

13     date of this meeting is important, and I wish to establish that by

14     tendering this document, unless the Trial Chamber would prefer a

15     different course of action.

16                           [Trial Chamber confers]

17             JUDGE HARHOFF:  Mr. Zecevic, could you assist us in trying to

18     elucidate what this document can offer in terms of evidence?

19             MR. ZECEVIC:  Your Honours, you will remember that when we saw

20     the witness's notes at the beginning of today's session, the witness

21     testified that he met -- that he went on request of Mico Stanisic and met

22     with him in Belgrade where he was given instructions for the operation to

23     be conducted in Foca regarding the paramilitaries and the problems with

24     the paramilitaries over there.  One of the questions I posed to him was

25     what instructions were given to him on that particular occasion by the

Page 21553

 1     minister, and the witness testified about that.  I can give you the

 2     reference of the transcript if you give me some time.

 3             Now, the problem -- the problem is that his notes, his notebook

 4     where he was writing the notes, does not contain the date of this meeting

 5     in Belgrade with Mr. Stanisic.  And I just wanted -- I just want to

 6     establish which date it was when Mr. Mico Stanisic, the minister, met

 7     with Mr. Andan, with the witness, and gave him the instructions to go to

 8     Foca and deal with the paramilitary units over there.  That is the only

 9     purpose.

10             JUDGE HARHOFF:  But now we have the witness's testimony on the

11     record.  Isn't that sufficient?  Do we need an extra document?

12             MR. ZECEVIC:  Well, that is exactly the instructions I was

13     seeking from the Trial Chamber.  If the Trial Chamber is satisfied that

14     it was sufficiently established that the meeting took place on the

15     18th of August, I'm not interested in offering this document into

16     evidence.

17             JUDGE HARHOFF:  I believe that the Chamber is fully satisfied

18     with having the witness's testimony for this purpose.

19             MR. ZECEVIC:  Thank you, I understand that.

20             JUDGE HARHOFF:  May I, in general, also remind the parties that

21     because of the overwhelming amount of evidence in this trial, the parties

22     are required to show some restrictions or to show some caution not to

23     seek to tender documents that are not strictly necessary, please.  Thank

24     you.

25             MR. ZECEVIC:  It is precisely why I seek the instruction from the

Page 21554

 1     Trial Chamber.  Precisely for those reasons.

 2             MR. HANNIS:  Well, I wanted to make an intervention here because

 3     at page 69, line 22, Mr. Zecevic's question is recorded:  "Do you

 4     remember now that it took place on the 28th of August, 1992?"  As I read

 5     the document, the meeting took place on the 18th.  The document is dated

 6     the 28th.  But Mr. Zecevic's question was the 28th and then the answer

 7     was:  "... well, there's no mistake it about it.  It certainly was the

 8     way it was written here."

 9             So it's not clear to me, so that's why I would not oppose to the

10     document coming in.  But if we clarify with the witness that the meeting

11     was on the 18th, then if you don't want the document, I can live without

12     it.

13             JUDGE DELVOIE:  Mr. Hannis, the Official Note, the date of the

14     note, is 28, but -- or it is referred to -- the meeting, sir -- at

15     line 17:

16             "Sir, in this Official Note you state that on the 18th of August

17     you were summoned to Belgrade ..."

18             So I think it is clear.

19             MR. HANNIS:  I'm sorry, but the transcript portion I was reading,

20     Your Honour, was -- the question was:  "Do you remember now that it took

21     place on the 28th?"

22             That's at page 69, line 22.

23             JUDGE DELVOIE:  All right.  Mr. Hannis.

24             MR. ZECEVIC:  I'm pretty sure I said 18th, but never mind.

25             Just one question, and I see the time, or perhaps --

Page 21555

 1             JUDGE HALL:  Yes, let's tidy this up before we take the

 2     adjournment.

 3             MR. ZECEVIC:  Yes.

 4        Q.   [Interpretation] Mr. Andan, do you remember that this meeting

 5     with Mico Stanisic took place on the 18th of August 1992 in Belgrade as

 6     we see in this Official Note, on the 18th of August?

 7        A.   Yes, this Official Note is an official document, that there is no

 8     reason to doubt what it says.  That meeting was held on the

 9     18th of August, whereas the Official Note was drafted on the

10     28th of August.  I was returning items that were -- had been issued to

11     me, and I couldn't find some radios, and I contacted the man who had

12     them, and that's why I mention this in the Official Note as well.

13             MR. ZECEVIC: [Interpretation] Thank you, sir.

14             JUDGE HALL:  Thank you.  So we take the adjournment until

15     tomorrow.  And we reconvene in Courtroom II at 9.00 tomorrow morning.

16                           [The witness stands down]

17                           --- Whereupon the hearing adjourned at 1.47 p.m.,

18                           to be reconvened on Tuesday, the 31st day

19                           of May, 2011, at 9.00 a.m.