Tribunal Criminal Tribunal for the Former Yugoslavia

Page 24418

 1                           Tuesday, 20 September 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.01 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.

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

 7     Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Mr. Registrar.

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

10     please.

11             MR. HANNIS:  Good morning, Your Honour.  For the Office of the

12     Prosecutor, I'm Tom Hannis, along with Indah Susanti.

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

14     Ms. Deirdre Montgomery appearing for Stanisic Defence this morning.

15     Thank you.

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

17     Aleksandar Aleksic, and Miroslav Cuskic appearing for Zupljanin Defence.

18             JUDGE HALL:  Thank you.

19                           [Trial Chamber confers]

20             MR. ZECEVIC:  Just one very brief matter, with your leave,

21     Your Honours.

22             JUDGE HALL:  Yes, Mr. Zecevic.

23             MR. ZECEVIC:

24             Well, Your Honours, you will recall that on the very first day of

25     the sitting in September Ms. Korner brought up the matter of scheduling,


Page 24419

 1     the further scheduling in this case.  In the meantime, I spoke to our

 2     friends from the Office of the Prosecutor, and they indicated that they

 3     will be filing the motion for rebuttal witnesses.  And the assurances I

 4     got from Ms. Korner was that it would be filed by end of this month, and

 5     I would kindly like to put that on the record and ask the Trial Chamber

 6     to issue an order in that respect that -- or suggest to the Office of the

 7     Prosecutor that, indeed, they file this by the end of the month, which

 8     will give us the time to -- adequate time for prepare for these rebuttal

 9     witnesses, if, of course, the Trial Chamber decides to adhere to that

10     request.

11             Thank you very much.

12                           [Trial Chamber confers]

13             JUDGE HALL:  Yes, Mr. Hannis.

14             MR. HANNIS:  Your Honours, that's correct, and that's fine.

15     That's reasonable.  But I just want to put on the record, we would like

16     to reserve the right, however, if there is some future witness to come

17     after the end of the month that raises something that might, in our view,

18     deem it necessary to ask for a rebuttal regarding that witness, that at

19     that time we would make a proposal.

20             JUDGE HALL:  So do I correctly infer what you have just said that

21     you confirm Mr. Zecevic's understanding that you will be filing by the

22     end of this month?  Save for what you have just indicated.

23             MR. HANNIS:  Correct.

24             JUDGE HALL:  Yes.

25             MR. HANNIS:  Those that we now are aware of and have a position


Page 24420

 1     about, we will file by the end of the month.

 2             I just wanted to reserve for the possibility that something may

 3     occur with witnesses yet to come.

 4             JUDGE HALL:  We -- that's understandable.  Yes, thank you.

 5                           [Trial Chamber confers]

 6             JUDGE HALL:  There is -- there is an oversight on the part of the

 7     Chamber yesterday in terms of the pseudonym sheet.  We forgot to order

 8     that it be entered as an exhibit, which we now do.  So it's an exhibit

 9     and should be given a number under seal.

10             THE REGISTRAR:  Your Honours, pseudonym sheet shall be given

11     Exhibit 2D154, under seal.  Thank you.

12             JUDGE HALL:  Thank you.

13                           [Trial Chamber confers]

14             JUDGE HARHOFF:  We also have an another little matter to deal

15     with before the witness comes in regarding the Prosecution's motion to

16     reopen its case in-chief.

17             This motion was filed by the Prosecution on the 26th of July, and

18     the Prosecution asks to reopen in order to tender a number of documents

19     from the bar table.  The documents concerned are death certificates and

20     other documents on which the Prosecution wishes to rely in order to

21     establish the death of a number of individuals.  The documents are

22     further specified in confidential Annex A to the motion.

23             Now, before taking a decision on this motion, the Chamber directs

24     the Prosecution to provide the dates on which it sent out the Requests

25     for Assistance to the respective countries, which led it to being


Page 24421

 1     provided with the documents in question.  And we further direct the

 2     Prosecution to include information on any still outstanding

 3     Requests for Assistance pertaining to the proof of death database in this

 4     case.  And, finally, we ask the Prosecution to provide us with at least a

 5     template translation of the documents.

 6             And this is to be filed by the close of business on Friday, the

 7     30th of September.

 8             That's all.  Thank you.

 9             JUDGE HALL:  So could we go into closed session so the witness

10     could be conducted back to the stand by the usher.

11                           [Closed session]

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19                           [Open session]

20             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

21     you.

22             MR. ALEKSIC: [Interpretation]

23        Q.   Sir, you spoke about the situation in Banja Luka in late 1991

24     yesterday.  We saw some documents.  And now can you tell us what the

25     situation in the town of Banja Luka was in 1992; first and foremost, the


Page 24428

 1     security situation?

 2        A.   Well, as for the security situation, it was complex in 1992, and

 3     the economic situation was difficult.  Life was hard.  The complexity of

 4     the security situation in Banja Luka is reflected in a large number of

 5     armed members of the military, also other persons armed with

 6     long-barrelled weapons.  Automobiles without licence plates were driven

 7     or they had stolen licence plates from other cars.  There was car theft.

 8     And public security staff were unable to stand up to such groups that

 9     were armed with long-barrelled weapons, because there were many.

10             There were about 200 staff of -- at the police stations.  The

11     police officers were not trained for carrying out suitable activities,

12     appropriate activities, against these perpetrators.  They were trained,

13     like me, for routine tasks.  The core was about 4.000 men-strong, as far

14     as I know.  Then there was a large number of reserve soldiers.

15             The military police was in charge of military personnel,

16     including reserve forces.  They had the right to check their IDs and

17     carry out controls and arrest them, if necessary, as well as initiate

18     proceedings against them.

19             I said at the outset that the situation -- I apologise.

20        Q.   Excuse me, I have to interrupt you.  We'll come to this later.

21             The armed men that you mentioned, what kind of uniforms they

22     wore?

23        A.   People armed with long barrels used to wear different sorts of

24     uniforms: Camouflage, multi-coloured, all sort of uniforms with all sorts

25     of insignia on their caps, on their uniforms, on parts of their uniforms.


Page 24429

 1             As for the economic situation in town, it was complex, as I have

 2     already mentioned.  It meant that the companies were not working.  There

 3     wasn't enough of raw goods.  Markets were unavailable.  There was almost

 4     no transport of goods into the area because the roads were blocked.  The

 5     corridor was closed at the time.  Only shops were open in town.  However,

 6     the shelves were almost empty.  There was a little bit of food and other

 7     products necessary for daily life.

 8             The salaries were very low.  There was inflation.  I'll give you

 9     an example.  My salary was sufficient for me to buy some of the things,

10     some of the food, in shops today.  However, the day after, I could not

11     buy even a box of matches with the remainder of the money, or, for

12     instance, some handkerchiefs.

13             Also, public transport was not functioning properly in town.  It

14     was limited because of the lack of fuel.

15             On the positive side, schools were open, elementary schools, high

16     schools, and the university.

17             The movement in town was allowed until the moment of curfew,

18     which means that from 2200 until 5.00 in the morning nobody was allowed

19     to move through town.

20             As I said, the remuneration, or, as we say it, salaries, were low

21     while the inflation was high.  People used to take their own belongings

22     from their houses, for instance, pots or plates, sometimes even

23     furniture; those items of furniture that could be taken out of the house.

24     All this clearly paints a picture of a very hard economic situation in

25     the town of Banja Luka.


Page 24430

 1             Let me tell you another thing.  My wife worked in another

 2     company.  She's highly qualified, university education.  However, that

 3     company would work for two days.  Then it would stop working for three

 4     days.  Her salary was very low, or there was no salary at all.  And,

 5     believe me, this is a company situated 5 to 7 kilometres from the centre

 6     of the town, the part where we live.  Every day she went there on her

 7     bike, regardless of the weather conditions, rain, snow, or ice.

 8        Q.   Thank you.  Could you describe the situation regarding the

 9     electrical energy supplies.

10        A.   The situation with the electricity was variable, if I may put it

11     that way.  Sometimes there was electricity.  And when there were combat

12     actions around Jajce and the hydropower plant, there was no electricity

13     in the whole of Banja Luka.  Sometimes it was on; sometimes it was off.

14     So we, the citizens, the population, didn't know when exactly there would

15     be electricity or not, so we tried to make our use most efficient.

16        Q.   Don't mention the part of the town where you live, but could you

17     describe the composition of the position there?

18        A.   The part of the town where I live, even before the war, it was

19     mixed, as we say.  Multi-ethnic.  I'm not going to say which part of town

20     exactly it is.

21             During the war in 1992, the ethnic composition of that part of

22     town remained the same, I think.  The same as it was before the war

23     during the SFRY.

24        Q.   When the power supplies were cut, how was it done?  Was it from

25     part to part of town or in some other way?


Page 24431

 1        A.   Mr. Aleksic, I think that nobody could know which parts of town,

 2     which streets, which house, houses, housed Bosniaks or Croats or others.

 3     There were no rules related to the cut-offs.  There were some days when,

 4     for example, a part of town would be without electricity, a particular

 5     settlement or even a particular street, but there were no cut-offs or

 6     restrictions, if you'd permit me to say, for the parts in town -- for the

 7     parts of the town where only Bosniaks or Croats lived without any Serb

 8     neighbours.

 9        Q.   Thank you.  You said that there were some restrictions in the bus

10     traffic.  However, the public transport in Banja Luka did function at the

11     time?

12        A.   The public transport in Banja Luka functioned with some

13     restrictions.  Some of the lines would have daily frequency or five or

14     ten buses a day.  However, when the service was restricted.  Sometimes it

15     would be only one departure a day, or even the line would be down for

16     several days.  It all depended on the availability of the fuel.

17        Q.   Excuse me, could you describe the situation related to the

18     market-place?

19        A.   The market-place in Banja Luka was one of the best supplied

20     market-places in that part of the state.  However, due to combat

21     activities -- and, excuse me, let me tell you one more thing.  The

22     surroundings of Banja Luka is a well-known agriculture area.  In 1992,

23     the market-place in Banja Luka was not well supplied.  You could find

24     some things but not very many.

25             I think that the reason for that is the fact that many people


Page 24432

 1     were mobilised.  Fields were not tilled.  There were some vegetable

 2     gardens around houses, but the market-place was in a very difficult

 3     situation.

 4        Q.   Thank you.  You said that the movement about town was allowed

 5     except during the curfew.  Can you tell us whose decision was it?  Which

 6     organ proclaimed the curfew?

 7        A.   As I have already stated, the curfew was on between 10.00 in the

 8     evening and 5.00 in the morning.  I know that it was proclaimed by a

 9     decision by the Secretariat for National Defence.  There were some

10     exceptions to the curfew.  Members of the police were free to move about,

11     as well as the military police and also, as far as I can remember,

12     members of the Territorial Defence.

13        Q.   But then could you specify who was subject to the curfew?

14        A.   As the name itself implies, curfew, or "police hour" in B/C/S,

15     means that nobody is allowed to move around between 10.00 in the evening

16     and 5.00 in the morning, and it goes for all the citizens of Banja Luka.

17        Q.   What was the purpose of this decision promulgated by the

18     Secretariat for National Defence?

19        A.   The purpose of this decision by the Secretariat for

20     National Defence whereby the curfew was introduced was to prevent

21     movement during the night, movement of people armed with long barrels in

22     all sorts of uniforms.  I already stated that they had all sorts of

23     uniforms, all sorts of insignia, on their caps, on parts of their

24     uniforms, shooting around the town, activating of explosive devices in

25     streets, in courtyards, shooting in the air, and so on and so forth.  In


Page 24433

 1     short, in order to ensure the security of the citizens.

 2        Q.   Who was authorised to issue permits to move about the town during

 3     the curfew?

 4        A.   The permits authorising movement during the curfew were issued by

 5     the Secretariat for National Defence.

 6        Q.   Do you happen to know who was authorised to issue permits to move

 7     outside Banja Luka?

 8        A.   The movement outside of Banja Luka towards other places was also

 9     subject to the decisions and permits issued by the Secretariat for

10     National Defence.

11        Q.   Thank you.  Can you tell us whether, in Banja Luka town, there

12     were any police check-points?

13        A.   Yes.  I used to work in the relevant service.  The police

14     check-points were established and positioned on major roads, or, more

15     precisely, on all the entry and exit points from Banja Luka.

16             There were check-points on exits from Banja Luka.  First

17     location 0, as we used to call it.  That is the intersection towards

18     Mrkonjic Grad, Skender Vakuf, and Jajce.  The second check-point was

19     established in the territory of the police station -- I apologise.  There

20     was a check-point in the territory of the central police station.  Then

21     there was another check-point in the territory of the police station

22     Mejdan.  It was positioned at the Mejdan viaduct, as we call it.  I'm not

23     going to go into details about the exact position.  Then there was the

24     settlement of Vrbanja, where Muslims, Bosniaks were a majority

25     population.  And then there was also the settlement of Debeljaci, where


Page 24434

 1     Croats were majority population.  And then towards Celinac, Kotor Varos,

 2     and further on.

 3             The third check-point was established at the Prijedor

 4     intersection, or Prijedor loop, as we call it.  It was close to the

 5     prison.  The Tunjice prison.  That is the exit point towards Prijedor,

 6     Gradiska, Laktasi, and so on.

 7        Q.   Thank you.  In your estimate, how far were those check-points

 8     from the centre of Banja Luka?

 9        A.   Well, the check-points were maybe some 5 kilometres from the

10     centre of Banja Luka.

11        Q.   You stated that the three check-points belonged to the

12     territorial jurisdiction of the police stations Centar, Budzani [phoen],

13     and Mejdan.  Could you tell us to which organisational units belonged the

14     policemen manning the check-points?

15        A.   I've already stated that the check-points belonged to different

16     police stations.  Centar, Mejdan, and Budzak.  The police stations

17     Centar, Mejdan, and Budzak, belonged to the public security station

18     Banja Luka.

19        Q.   Do you know the ethnic composition of those police stations,

20     especially Budzak and Mejdan, after the 1st of April and for the

21     remainder of 1992?

22        A.   Before I address the ethnic composition of police stations, let

23     me say that the Mejdan Police Station used to cover an area with a large

24     number of Bosniaks, so the ethnic composition of this police station

25     reflected the ethnic composition of the population.  You have to bear in


Page 24435

 1     mind that the territory of the Mejdan Police Station included two

 2     settlements with majority Bosniak population, Vrbanja and Debeljaci.  In

 3     Debeljaci there was a majority of Croats.  Further on, the Budzak Police

 4     Station had a mixed composition because there were many Croats living

 5     there.

 6             The Centar Police Station was rather mixed.  There were Serbs in

 7     the previous two stations as well.  However, in the centre there were all

 8     sorts of people.

 9        Q.   Thank you.  At the beginning of your answer relating to the

10     situation in Banja Luka, you said that the police force was insufficient

11     to deal with the situation.

12             So could you tell us whether measures and activities were

13     undertaken against the perpetrators of criminal offences in this

14     particular situation, if you know?

15        A.   I know that against the perpetrators of criminal offences, as

16     well as the gravest of crimes, such as murders, throwing of explosives,

17     shooting in the air, measures envisaged by law were undertaken.

18        Q.   Which measures?

19        A.   Well, deprivation of liberty, criminal prosecution, drafting of

20     criminal reports, and reports submitted to the prosecutor's office.

21        Q.   Do you maybe remember some of the names or some of the criminal

22     groups that were prosecuted at the time for the gravest criminal

23     offences?

24        A.   Well, let me tell you, Banja Luka town consists of a number of

25     settlements.  I'm not going to say any names.  So each part of town had


Page 24436

 1     its own criminals, if I can put it that way.  It was a long time ago, to

 2     be honest.  But I do remember some of the people that were prosecuted,

 3     people who were bent on creating chaos in the town.

 4             There was Mandic, Javorac, then Java Goran, Kajkuta, Palackovic.

 5     Vedran Palackovic.

 6        Q.   Okay.  Thank you.

 7                           [Defence counsel confer]

 8             MR. ALEKSIC: [Interpretation] Your Honours, can we please move

 9     into private session briefly.

10             JUDGE HALL:  Yes.

11                           [Private session]

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22                           [Open session]

23             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

24     you.

25             JUDGE HALL:  And we return in 20 minutes.


Page 24444

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

 2                           --- On resuming at 10.49 a.m.

 3             JUDGE HALL:  We move into closed session so that the witness can

 4     be brought in.

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13                           [Open session]

14             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

15     you.

16                           Cross-examination by Mr. Zecevic:

17        Q.   [Interpretation] Good morning.

18        A.   Good morning.

19        Q.   I'm going to ask just a few questions.

20             My name is Slobodan Zecevic, and I defend Mr. Mico Stanisic.  We

21     haven't been introduced yet and I wanted to introduce myself.

22             Sir, today, on page -- I think it was page 20, you mentioned

23     check-points established in the suburbs of Banja Luka at three different

24     places.  Do you remember that?

25        A.   Yes.


Page 24454

 1        Q.   Sir, are you familiar with the action executed by the MUP of the

 2     Socialist Republic of Bosnia-Herzegovina that had the code-name

 3     Check-Point 91?

 4        A.   Yes.

 5        Q.   You should always make a short pause between my question and your

 6     answer because I have to have enough time to switch off my microphone.

 7        A.   I apologise.

 8        Q.   What do you know about this action, Check-Point 91?  Do you

 9     remember when it started and what was its purpose?

10        A.   If I understood your question correctly, the introduction of

11     check-points at certain locations in the Banja Luka town, and I mentioned

12     three locations, was aimed at the prevention of the armed formations,

13     members of the TO and other armed groups, as well as individuals,

14     carrying long barrels, as well as civilians armed with long barrels.  The

15     idea was that they should not be able to enter or exit the town or

16     certain settlements and disturb the public order by opening fire at

17     facilities and buildings, by shooting in the air, by throwing explosive

18     devices, and by other means.

19             The task of the check-point was to prevent the transfer of stolen

20     vehicles without number plates or with stolen number plates, et cetera.

21     Also, in my opinion, it was important, and an example for this was the

22     Mejdan Police Station where the majority of the inhabitants were

23     Bosniaks, it was important to prevent the arrival of armed individuals

24     wearing different uniforms, opening fire at various buildings, throwing

25     explosive devices in certain houses, and so on and so forth.


Page 24455

 1             So the check-points had a very important role.  So it was

 2     impossible for armed individuals to go around, to exercise their criminal

 3     behaviour, or even endanger human lives.  Also, various goods were being

 4     smuggled through the town, and it was also one of the tasks of the

 5     check-points to prevent that; for instance, trafficking of foods.

 6        Q.   Thank you for your exhaustive explanation.

 7             You said that some individuals were prevented from entering the

 8     town or some of the settlements and to display -- and from displaying

 9     their criminal behaviour and endangering human lives.

10             I think that you said that it wasn't possible to prevent it

11     100 per cent but that it was prevented to a large degree.  Was that what

12     you said?

13        A.   Yes, yes.  Of course, somebody will always be able to pass

14     through.  However, there was a positive reception among the population,

15     among the citizens, and it gave them a certain dose of security.

16        Q.   Thank you.  Sir, when I asked you about Check-Point 91, which was

17     the action carried out by the Socialist Republic of Bosnia and

18     Herzegovina MUP, do you remember whether the check-points were

19     established for the first time sometime in the fall of 1991?

20        A.   I think that was the first time.

21        Q.   Thank you.  The authority vested in the members of the Ministry

22     of Interior manning the check-points and the official steps that they

23     were undertaking at the check-points, was it all envisaged by the Law on

24     the Internal Affairs?

25        A.   All actions undertaken by the policemen at check-points were in


Page 24456

 1     accordance with the Law on Internal Affairs, or, in other words, they

 2     were actions undertaken in relation to non-uniformed individuals; that

 3     is, civilians.  Ordinary citizens.

 4        Q.   Let us clarify this.

 5             Was one of the actions undertaken checking of identity,

 6     establishing of someone's identity?  Was another of the actions, for

 7     instance, checking the vehicles, the trunks of the vehicles, checking the

 8     documents?  Are those the actions that you claim were in accordance with

 9     the Law on Internal Affairs?

10        A.   Exactly.  They are the actions stipulated by the Law on

11     Internal Affairs.

12        Q.   One more question on this subject.

13             Were you aware, did you have any information, or are you aware of

14     any instructions in relation to this, that at the check-points citizens

15     would be treated differently depending on their ethnicity?  Do you know

16     if anything like that happened?

17        A.   I don't know that.  But I'm certain that once the ID papers would

18     have been checked, nobody would have been accorded a different treatment

19     depending on their ethnicity.  All the official actions undertaken at the

20     check-points were strictly in accordance with the Law on

21     Internal Affairs, bylaws.  And all the citizens were treated in the same

22     way.

23        Q.   Thank you very much.  These were all my questions.

24             MR. ZECEVIC: [Interpretation] Thank you, Your Honours.

25             JUDGE HALL:  Mr. Hannis.


Page 24457

 1             MR. HANNIS:  Thank you, Your Honour.

 2                           Cross examination by Mr. Hannis:

 3        Q.   Just to follow up on that last question from Mr. Zecevic,

 4     Witness.

 5             You personally were never involved at working at any of those

 6     check-points that were set up as part of Operation Check-Point; is that

 7     right?

 8        A.   Mr. Prosecutor, I did not.

 9        Q.   Okay.  So you cannot know of your own personal knowledge whether

10     or not some individuals may have been mistreated or treated differently

11     because of their ethnicity; right?

12        A.   Yes.

13        Q.   Thank you.

14             MR. HANNIS:  I think I need to go into private session for my

15     next series of questions, if I may.

16             JUDGE HALL:  Yes.

17                           [Private session]

18   (redacted)

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Page 24458

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Page 24464

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25                           [Closed session]


Page 24465

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 5                           [Open session]

 6                           [Trial Chamber confers]

 7             THE REGISTRAR:  Your Honours, we are back in open session.  Thank

 8     you.

 9                           --- Recess taken at 12.05 p.m.

10                           --- On resuming at 12.30 p.m.

11             JUDGE HALL:  Yes, we - thanks - we go into closed session so the

12     witness can take the stand.

13                           [Closed session]

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24                           [Private session]

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Page 24466

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23                           [Open session]

24             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

25     you.


Page 24476

 1             MR. HANNIS:

 2        Q.   Witness, if you can help me with the correct terminology.  Within

 3     the Banja Luka CSB there are various units like the -- the police

 4     department or police affairs, crime prevention and crime detection.  What

 5     were they called within the CSB?  Are they administrations, or sectors,

 6     or departments?  What's the correct term I should use when I'm talking

 7     about those?

 8        A.   The right word to use is department, or sector.

 9             So police sector, crime police sector, department.  Those same

10     terms are still used today.

11        Q.   Thank you.  You named several of them when you were talking to

12     Mr. Aleksic.  But there were a couple that -- that you may have

13     overlooked.  I want to confirm whether or not these were departments or

14     sectors in the Banja Luka CSB in 1992.

15             I take it there was an analysis and information section, or

16     sector, or department?

17        A.   There's a department.  And then within the department, one level

18     lower, is another department.  Or you can have sector and then

19     department, and then the people who work on the execution of orders.

20             Today's terminology, you have police sector.  We even have

21     numerical codes for all of them.  So police sector is 01; crime police

22     sector is 02; communications department is 03; personnel and

23     legal affairs department, 04; financial department, 05.  Then there are

24     following departments:  Fire prevention department; and, of course, there

25     is the office of the chief.


Page 24477

 1        Q.   Okay.  Let me ask you a couple of questions, because I've seen

 2     those numerical designators for the different departments or sectors or,

 3     I think, as they were called at the headquarters level of the RS MUP,

 4     administrations.  And typically, I think, 01 is the police

 5     administration, police affairs and tasks; 2 is crime prevention and crime

 6     detection; 3, at least on one of the charts I saw, was for the fire and

 7     explosives; and communications was 4.

 8             Is that not consistent with your memory?

 9        A.   That's how things are today.  However, at the time, in 1992, we

10     did not have all the departments, and I think -- no, I don't think, I

11     know there were not administrations at the Banja Luka CSB.  It's not an

12     administration.  It's a department.  Police department, crime prevention

13     and detection department, section for foreigners, financial department,

14     personnel and legal affairs department, and so on and so forth.

15        Q.   No, I agree.  When I mentioned "administrations," that's the term

16     I've seen used in talking about those various units at the headquarters

17     level but not at the CSB level.  Do you understand?

18        A.   Precisely.

19        Q.   Was there also in Banja Luka CSB -- I guess you mentioned

20     financial.  Materiel and financial.  Was that one department?

21        A.   There was a department in charge of materiel affairs in the

22     Security Services Centre.

23             It was a group of people.  Whether they were a department, I

24     wouldn't know, but they were also in charge of technical matters, such as

25     maintenance of vehicles, procurement of spare parts for vehicles,


Page 24478

 1     maintaining of hygiene.

 2        Q.   The chiefs or the heads of these departments that we've been

 3     talking about, were they part of the -- of Chief Zupljanin's collegium in

 4     the CSB Banja Luka in 1992?  Were those the people who would be part of

 5     what I've heard called the collegium?

 6        A.   You know what?  We call it, in inverted commas, non-productive

 7     departments.  While the operative departments are the police department

 8     and crime prevention and detection department.  All other organisational

 9     units, be it foreigners, materiel and finance, legal and personnel,

10     technical services, they have their chiefs but they are not authorised

11     persons.  They do not have the authority.  They do not have shortened

12     working years.

13             Did they attend the collegiums?  No, they did not.  But whenever

14     a need would arise, they would come later on to discuss a problem at

15     hand, whether it would be purchase of spare parts for vehicles or for

16     communication equipment or procurement of telex machines.  And then they

17     would talk to the chief of the centre or a person authorised by him but

18     strictly about those problems.

19        Q.   If I understand you correctly, are you saying what you referred

20     to as the "non-productive departments," those are the people in the

21     police who are not authorised officials?  Does that mean people who --

22     they don't carry a gun, they don't have the power to make arrests,

23     et cetera; right?

24        A.   That's correct.

25        Q.   Thank you.  And within the 01, the police administration, police


Page 24479

 1     affairs and tasks, was the duty operations team part of that department

 2     in the Banja Luka CSB in 1992?

 3        A.   I did not understand the question.

 4        Q.   In terms of the organisational structure in Banja Luka CSB in

 5     1992, was the duty operations team under the police department, or

 6     sector, 01?

 7   (redacted)

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 9   (redacted)

10   (redacted)

11   (redacted)

12             JUDGE HALL:  Yes.

13             MR. HANNIS:

14        Q.   I'm sorry, Witness.  I had to stop you there.  We're in open

15     session and ...

16             JUDGE HALL:  The --

17             THE WITNESS: [Interpretation] I apologise.  I'm sorry.

18                           [Trial Chamber and Registrar confer]

19                           [Trial Chamber and Legal Officer confer]

20             JUDGE HALL:  Yes, we -- we would redact the relevant lines.

21     There's -- apparently there's no correspondence between the lines as I

22     read and on the other screens.

23             But should we continue -- should we revert into private session

24     to deal with this, or is the -- to continue your question, or ...

25             MR. HANNIS:  Yeah, I think we need to just so that I can get an


Page 24480

 1     answer on the record.

 2             JUDGE HALL:  Yes.  So we go into private session.

 3             MR. HANNIS:  Thank you.

 4                           [Private session]

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22                           [Open session]

23             THE REGISTRAR:  Your Honours, we are back in open session.  Thank

24     you.

25             MR. HANNIS:


Page 24482

 1        Q.   Witness, I'm going to ask you some general questions, if you know

 2     the answer, about the number of certain personnel in CSB and

 3     SJB Banja Luka in 1992.

 4             First of all, can you tell me in April/May of 1992 how many

 5     employees were there in the CSB Banja Luka?  First of all, total number,

 6     counting both uniformed and operatives and the non-productive

 7     departments.

 8        A.   In the CSB, there were about 150 employees, of whom uniformed

 9     police, i.e., those wearing uniforms, were 12 to 13.  In the

10     white-collar crime prevention and detection, there were approximately

11     40, 45 [Realtime transcript read in error "four to 45"] employees who

12     were authorised officials and who worked as plain-clothes officers.

13        Q.   Let me clarify:  The transcript has recorded "approximately four

14     to 45."  Is that what you said, or ...

15             Did you say "four to five" or "four to 45"?

16        A.   40 to 45.

17        Q.   Thank you.

18             JUDGE HALL:  Mr. Hannis.

19             MR. HANNIS:  Yes, Your Honour.

20             JUDGE HALL:  Might I interrupt you briefly.

21             Mr. Aleksic, we have been alerted that there's a matter that you

22     wish to raise.  A, do you still wish to raise it; and, B, how much time

23     do you think you would need?

24             MR. ALEKSIC: [Interpretation] Yes, Your Honour.  Five minutes at

25     the end.  And we're almost there.  I believe that the matter is very


Page 24483

 1     important and that the Trial Chamber should know about it.

 2             JUDGE HALL:  Thank you.

 3             Mr. Hannis, Mr. Aleksic says five minutes, but my experience is

 4     that you probably better allow for ten.

 5             MR. HANNIS:  Okay, Your Honour.  That will be fine.  I will stop

 6     in about five more minutes.

 7             JUDGE HALL:  Thanks.

 8             MR. HANNIS:

 9        Q.   And, Witness, what about the SJB of Banja Luka?  Can you tell us

10     approximately the total number in April/May 1992, uniform, operatives,

11     and others?

12        A.   As for the Banja Luka SJB, there were about 300 authorised

13     officials working there at the time.

14        Q.   Can you give me a breakdown, in terms of authorised officials,

15     the number of uniformed police officers versus operatives, detectives?

16        A.   There were perhaps 150 to 200 uniformed police officers.  It is

17     very difficult for me to talk about figures after such a long time.

18     However, the total number of authorised officials was about 300, 200,

19     250, 300.

20        Q.   And how about the non-authorised.  Do you have any idea of the

21     number in the SJB Banja Luka in April/May 1992?

22        A.   The Banja Luka SJB, now that we're talking about it, had the

23     so-called non-productive units that belonged to the CSB, which means that

24     the Banja Luka SJB had approximately 20 to 30 men.  Believe me, I --

25     it's -- it's a very tall order to remember exactly how many there were.


Page 24484

 1        Q.   That's fine.  Did the numbers for both the CSB and the SJB

 2     increase later in 1992?  Were additional authorised officials hired, or

 3     reserve policemen brought on board?  I'm assuming that's what happened,

 4     but you tell me.

 5             Did the numbers go up for both the CSB and the SJB later in 1992?

 6        A.   Well, Mr. Prosecutor, we know very well, based on my testimony so

 7     far, that the solemn declaration was signed, so some of the officials,

 8     some of the employees, did not sign that solemn declaration.

 9             I wouldn't be able to tell you how many employees in numerical

10     terms abandoned the service and abandoned the CSB.  However, whether new

11     people were hired, I really don't know.  I only know that in all the

12     reports that I can remember and of which I can speak from memory,

13     Chief Zupljanin always emphasised the fact that the CSB had very few

14     police officers, that -- that there were a lot of vacancies which had not

15     been filled up, according to the organisational scheme of the CSB.

16        Q.   Okay.  Thank you.

17             MR. HANNIS:  And I'll stop for today.

18             JUDGE HALL:  Yes.  So, Mr. Witness, we have reached a point where

19     we're about to take the adjournment for today, so we would go into closed

20     session so that you may be escorted from the courtroom.

21                           [Closed session]

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Page 24485

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 2                           [Open session]

 3                           [Trial Chamber and Registrar confer]

 4             THE REGISTRAR:  Your Honours, we are back in open session.  Thank

 5     you.

 6                           [Trial Chamber confers]

 7             MR. ZECEVIC:  I'm sorry, Your Honours, just for the record,

 8     before I forget, for the record, that Mr. Cvijetic has joined the

 9     Stanisic Defence.  Thank you.

10             JUDGE HALL:  Yes, Mr. Aleksic.

11             MR. ALEKSIC: [Interpretation] Thank you, Your Honours.

12             I know that this is not a simple technical procedure, but we have

13     to move into private session.  What I need to say needs to be said in

14     private session.

15             JUDGE HALL: [Microphone not activated] ... go into private

16     session.

17                           [Private session]

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19                           [Open session]

20             THE REGISTRAR:  Your Honours, we're back in open session.  Thank

21     you.

22             JUDGE HALL:  Tomorrow morning at 9.00, this courtroom.

23                            --- Whereupon the hearing adjourned at 1.46 p.m.,

24                           to be reconvened on Wednesday, the 21st day

25                           of September 2011, at 9.00 a.m.