1 Wednesday, 12 October 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.04 a.m.
5 THE REGISTRAR: Good morning, Your Honours. Good morning,
6 everyone in and around the courtroom. This is case number IT-08-91-T,
7 the Prosecutor versus Mico Stanisic and Stojan Zupljanin.
8 JUDGE HALL: Thank you, Madam Registrar. Good morning to
10 May we have the appearances today, please.
11 MR. HANNIS: Good morning, Your Honours, for the Prosecution I'm
12 Tom Hannis, along with Gerard Dobbyn and Sebastiaan van Hooydonk.
13 MR. ZECEVIC: Good morning, Your Honours. Slobodan Zecevic,
14 Slobodan Cvijetic, and Ms. Deirdre Montgomery appearing for
15 Stanisic Defence this morning. Thank you.
16 MR. KRGOVIC: Good morning, Your Honours. Dragan Krgovic and
17 Miroslav Cuskic appearing for Zupljanin Defence.
18 JUDGE HALL: Thank you. And if there are no preliminary matters,
19 may the usher -- would the usher please escort the witness back to the
21 [The witness takes the stand]
22 JUDGE HALL: Mr. Jankovic, good morning to you. Before --
23 THE WITNESS: [Interpretation] Good morning.
24 JUDGE HALL: -- counsel for Mr. Stanisic begins his
25 cross-examination, I remind you you're still on your oath.
1 Yes, Mr. Cvijetic, is it?
2 MR. CVIJETIC: [Interpretation] Thank you, Your Honour.
3 WITNESS: MILOS JANKOVIC [Resumed]
4 [Witness answered through interpreter]
5 Cross-examination by Mr. Cvijetic:
6 Q. [Interpretation] Good morning, Mr. Jankovic.
7 A. Good morning.
8 Q. I will start my examination proceeding from your answer to my
9 learned friend Mr. Krgovic's question which is at page 24842 of
10 yesterday's transcript. Mr. Krgovic asked you about the difficulties you
11 had in receiving and transmitting dispatches in the period you discussed
12 yesterday, and I will read just a part of your answer from the
14 [As read] "For instance, there is one dispatch that I saw, it was
15 shown to me by the gentleman from the Prosecution when I was giving them
16 my statement. My signature can be found on that dispatch?"
17 And you go on to say the dispatch speaks of the scope of what I'm
18 discussing now and it would be the best illustration of what I'm saying.
19 Do you recall what you said yesterday?
20 A. Yes.
21 Q. So do you recall that this is precisely what you told colleague
22 Krgovic yesterday?
23 A. Yes.
24 Q. Very well. I'll show you the dispatch. It's an exhibit. It's
25 P668. I need page 1 in both versions. Yes. That's what we need.
1 Mr. Jankovic, let me ask you first, is this the dispatch you were
2 discussing yesterday?
3 A. Yes, this is the one I had in mind.
4 Q. Please pause before answering.
5 A. Yes. This is the dispatch I had in mind. Yes. It is a good
6 copy. You can read it.
7 Q. Well, I have a hard copy if you want to have it.
8 A. Yes, please, it would be much easier. If you don't mind. It is
9 a bit tiring to read from the screen.
10 Q. I would like to clarify a point from this dispatch. So is this
11 the dispatch, please confirm that?
12 A. Yes, that's the dispatch.
13 Q. And this is the dispatch shown to you by the Prosecution during
14 the interview; right?
15 A. Yes, and that's where I remember it from.
16 Q. Tell us, we have a signature in handwriting. Whose is it?
17 A. That's my abbreviated signature.
18 Q. Mr. Jankovic, there is a note on the dispatch indicating that it
19 was impossible to transmit it to the first two addresses, i.e., the MUP
20 of the Serbian Republic of Bosnia and Herzegovina and Army of the
21 Serbian Republic of Bosnia and Herzegovina.
22 A. Yes, yes.
23 Q. And there's a bracket there and one Goran signed it?
24 A. Yes.
25 Q. This is my question: Were these precisely the difficulties that
1 you were referring to, namely, in this case, you weren't able to transmit
2 dispatches to the MUP at Pale and the army?
3 A. Yes, that's precisely why I cited this dispatch.
4 Q. Very well. You no longer need to look at the dispatch because I
5 will be putting questions of a general nature to you now.
6 A. Can I just add something? The reason, in fact, why I referred to
7 the dispatch.
8 Q. Well, perhaps I'll ask you about it in some of my questions.
9 But -- right. Go ahead.
10 A. I'll try to be as brief as possible. The contents don't matter.
11 I will not be talking about them. I saw the dispatch for the first time
12 when it was shown to me by a gentleman from the Prosecution, otherwise I
13 would have long forgotten about it. It speaks very clearly to the issues
14 we were discussing, namely, the quality of the communication links,
15 et cetera. Look at what it says at the top "dx open" and then circled
16 and then a "sh" is added and then my signature. "Open" or "sh" stands
17 for the status of confidentiality of the document and it would normally
18 be indicated by the author of the document. Apparently the author of
19 this particular document - and it is Simo Drljaca who signed - wasn't so
20 privy to these rules and didn't put it properly. And then the operator
21 who transmits dispatches and makes corrections where they are needed in
22 this case contacted me and ask that the designation of confidentiality be
23 changed, in other words, that it not be an open dispatch but that it be
24 coded and that's why I made the correction that you can see here.
25 There are three addresses to which the dispatch is supposed to be
1 transmitted, namely, the MUP of the Serbian Republic of
2 Bosnia-Herzegovina, Army of Republika Srpska, and the CSB in Banja Luka.
3 The communications operator, one Goran, indicated that we were unable to
4 send the dispatch to the two first addresses. Now, the CSB which was
5 closest to us in terms of communication links was reached and the
6 dispatch was sent. The handwritten note contains a date, the 18th, or
7 rather, 1840 Rodic and then the 3rd of August at 10.00 Milan.
8 It was standard procedure that dispatches designated as "dx"
9 would be sent no later than within two hours, whereas in reality they
10 would be sent right away. However, this dispatch indicates that the
11 dispatch was sent two days later, which indicates the length of time that
12 the dispatches had to be delayed before they were sent and in certain
13 circumstances it really defeated the purpose of the dispatches to begin
14 with, but that was the circumstance prevailing at the time. That's it.
15 Q. And at times you, or rather, you've just anticipated my next
16 question. The teleprinter system, the telex system with the various
17 coding and confidentiality designations constitute the basis of the
18 workings and the running of the Ministry of the Interior; is that right?
19 A. Yes.
20 Q. Mr. Jankovic, it was precisely that system which failed to
21 operate for most of 1992 and in most of the areas in Bosnia-Herzegovina,
22 even locally; would you agree with me?
23 A. Yes, but I cannot speak in greater detail about the links outside
24 of the routes between Prijedor, Banja Luka, and Sarajevo. I wouldn't be
25 able to speak about them with any certainty.
1 Q. Let me take you back to your yesterday's evidence. You spoke of
2 your deployment to the front line as part of that unit. Do you recall
3 talking about it as part of that police unit?
4 A. Yes.
5 Q. In that role of yours, you also dealt with communications; is
6 that right?
7 A. Yes, solely with communications.
8 Q. But at the time what you were doing had a military purpose, did
9 it not?
10 A. The way this combat unit was organised was that it was part of a
11 military organisation.
12 Q. Let me follow-up this answer of yours with this question.
13 Members of the Prijedor public security station would, as part of these
14 military purposes, be deployed to other front lines, not just this one;
15 is that right?
16 A. Yes.
17 Q. On occasions such as these, would they be part of the
18 communications system of the public security station in Prijedor, i.e.,
19 would they have been in communication with you?
20 A. No.
21 Q. I will show you two more documents now to support some of your
22 answers of yesterday.
23 MR. CVIJETIC: [Interpretation] Can we call-up 65 ter 616D1.
24 Q. Mr. Jankovic, if you need a hard copy for your easier perusal --
25 A. No, it's all right. I can read it off the screen.
1 Q. Please read it to yourself and then I'll put questions to you.
2 A. The contents?
3 Q. Yes. It's a short document.
4 A. I've read it.
5 Q. Mr. Jankovic, yesterday you said that, locally, members of the
6 public security station would receive their salaries and the equipment
7 they needed from the local level; is that right?
8 A. Yes, and this document confirms it.
9 Q. We can tell that the document is of the 16th of June.
10 A. Yes.
11 Q. Can you tell us how long this situation prevailed?
12 A. I don't know. Not just a couple of days. At least the entire
13 summer, perhaps through to the end of the year. Anyway, throughout that
15 Q. Can you recognise the signature at the bottom?
16 A. No.
17 Q. And can you read the signature block?
18 A. Well, it says Milomir Stakic, president of the municipality, but
19 I don't recognise his signature. I don't know if it's his.
20 Q. But in general, were you aware that Simo Drljaca, Ranko Travar
21 dealt with salaries, uniforms, and everything else in co-operation with
22 the Crisis Staff. Were you aware of this? You did speak about it
24 A. Well, I can tell you all of us worried about whether we would be
25 paid our salaries and we would talk about it amongst ourselves that the
1 municipality had set aside funds for this purpose, that a salary would be
2 forthcoming, et cetera. As for uniforms, there were uniforms that were
3 procured, but I don't know who paid for them. I can only assume that
4 they came from that quarter, whereas I am certain that this was the case
5 with salaries.
6 MR. CVIJETIC: [Interpretation] Your Honours, I don't know how
7 come this document hasn't been admitted yet and I don't see any other way
8 of admitting it than through this witness. The witness spoke in great
9 detail yesterday about payments and the supply of uniforms. So I do
10 believe that we have passed the threshold required for the admission of a
11 document. I think it is helpful for the case in general and it's helpful
12 for some of the submissions that the Defence will be putting in our final
13 brief. So I please -- I would like to tender this document, please.
14 MR. HANNIS: Your Honour, I have an objection or two. The fact
15 that may be helpful to Defence submissions is not a reason for admitting
16 it. The witness says it says Stakic but he doesn't recognise his
17 signature. At most it says there was a conclusion that Mr. Drljaca and
18 two others were charged with making a comprehensive review of the
19 possibilities but there's no indication from this witness or any other
20 evidence so far that a review was done or what happened. So I don't know
21 what it adds to the witness's testimony at this point and he is not able
22 to establish the foundation for the authenticity of this document. And
23 it has limited relevance.
24 JUDGE HALL: Mr. Cvijetic, do you have a response?
25 MR. CVIJETIC: [Interpretation] Your Honour, the witness described
1 how things worked in practice and this document confirms it quite
2 clearly. There's not a shred of doubt about the authenticity of this
3 document, contrary to what the Prosecution are saying. This is an
4 official document received from the Prosecution. It is not a Defence
5 exhibit. I mean, we are tendering it but we received it from the
6 Prosecution. There are no doubts about its authenticity, and as for the
7 contents, well, the witness did speak about that. So I believe that's
8 the foundation for the admission of the document.
9 THE WITNESS: [Interpretation] Can I say a word or two?
10 JUDGE HALL: I would prefer you to -- not to volunteer evidence.
11 If counsel has a supplemental question, he may proceed.
12 [Trial Chamber confers]
13 JUDGE HALL: The document is admitted and marked.
14 THE REGISTRAR: Exhibit 1D813, Your Honours.
15 MR. CVIJETIC: [Interpretation] Thank you, Your Honour.
16 Q. Mr. Jankovic, I'll show you another document which is an exhibit.
17 We will have no difficulty there. It's P803.
18 MR. CVIJETIC: [Interpretation] Can I have the usher's assistance
19 to give the document to the witness. It may be easier for him to read
20 this way.
21 Q. Please read it to yourself and then I'll put my question to you.
22 I'll give you three to four minutes.
23 A. I've read it.
24 Q. First of all, Mr. Jankovic, did you know that there was a special
25 unit in town, an intervention platoon of this kind, as it says in the
1 document? Did you have the opportunity to see these people?
2 A. No, I cannot recall seeing anything of the kind that is described
4 Q. As you can see, it states here that this was formed by the
5 Crisis Staff. Can you confirm that?
6 A. I don't know that. This is at another level that has nothing to
7 do with me, so I really don't know anything about that.
8 Q. Thank you. So my question has to do with your work. This, or an
9 intervention unit of this kind, was it in the communications system of
10 the public security station and did it have anything to do with you and
11 did you provide communication means?
12 A. No. There was an intervention platoon that was called that way
13 in unofficial talk, and I can see here that it refers to personnel from
14 existing police forces. Carry out from the existing police forces. But
15 I didn't know anybody from that so-called intervention platoon. I knew
16 them but outside of the service that Zigic, he was there but he was never
17 in the service.
18 Q. You said from the military and the police?
19 A. That's what it says here, paragraph 2, that's what it says, from
20 the police and the army. I didn't know those people. They were not from
21 the police thus.
22 Q. So the essence is that they were not from the police and they
23 were not in your police system of communication, yes or no, I mean answer
24 please whether they were in your system?
25 A. To be quite clear, they were not in our system.
1 Q. Thank you. And finally, Mr. Jankovic, now when we look at this
2 order together from which we can see that the Crisis Staff is forming
3 some sort of special unit over there that had nothing to do with the
4 public security station, and we can see that salaries for the police were
5 being -- and for uniforms were being provided at the local level. It
6 seems then that Prijedor - when I say "Prijedor," I mean the Prijedor
7 authorities - was quite independent in relation to the rest of
8 Republika Srpska. Do you share this view?
9 A. Well, the question is a little bit unclear to me, but as far as I
10 understand I can just repeat what I said yesterday. Simo didn't really
11 pay much attention to these others except for those that had brought him
12 there and that's the municipal authorities. I'm sorry, I apologise --
13 Q. I'm going to ask you directly. From these documents that I have
14 showed you -- I apologise. Or actually, I want to clarify my question.
15 When you actually say that he didn't pay too much attention to others,
16 are you thinking of Pale, for example, or Banja Luka and that he
17 actually -- actually, he did these people at the local level more --
18 well --
19 A. I said yesterday that he was going by his own mind. If he needed
20 to co-operate with somebody, then he would go to the municipality. I
21 don't know who he talked to, who was issuing what sort of assignments to
22 whom, that is something that I don't know. But I do know that what was
23 earlier was disrupted. The relationships were regular. Before the chief
24 of the police would go to Banja Luka and Sarajevo. He would also go to
25 the Komitet as well. But this one, he mostly went there across the road
1 to that municipality. When I say "municipality," I would just like to
2 make sure that we're not talking about the municipality, we're talking
3 about the building. Where he went, I don't know whether he went to the
4 municipal authorities, to the SDS, to the board, I don't know about that.
5 Q. So you mean he went to Banja Luka and Sarajevo. When you said
6 that you're thinking about the pre-war period?
7 A. Yes, the pre-war period up until the multi-party elections --
8 well, not Simo but whoever was at that post.
9 Q. So it was like that until Simo Drljaca came and then it changed?
10 A. Yes. And then it came back after that, but 1992 was turbulent.
11 Q. So when you're talking about this disruption in relations, you're
12 talking about 1992; is that right?
13 A. Yes, 1992. I -- I would just like for the sake of caution. I
14 couldn't say that in 1992 he didn't go to Banja Luka. I don't know.
15 Perhaps he did, but I'm not aware that he ever went to Pale. Perhaps he
16 did but I don't know that, I really don't.
17 Q. Very well. Mr. Jankovic, I don't have any further questions for
18 you. Thank you.
19 Cross-examination by Mr. Hannis:
20 Q. Good morning, sir. I will have a lot of questions for you. I
21 would ask that -- well, first of all, let me ask you: Do you understand
22 English? Do you read or understand English?
23 A. No, no. English texts that have to do with electronics or
24 technical texts, yes, that I can use. But as for the rest, no.
25 Q. The reason I ask was that it seemed at times you were looking at
1 the transcript and you were able to follow somewhat in English where we
2 were. That's why I asked the question. I would ask that you do try and
3 watch the transcript and see when the typing stops before you begin your
4 answers to my questions. That will make it easier for the interpreters
5 to keep up with you because you're a pretty fast talker.
6 A. I'm sorry, yes, that is why I am looking at the transcript, so
7 that when it stops I can continue. This is why I was looking at it, not
8 in order to translate. And I don't actually understand it, no.
9 Q. Okay. Thank you. I just want to ask you a few questions about
10 your background. I understand you started working in the police in 1980
11 and you retired in 2008; correct?
12 A. Yes, from late June 2008, in late June 2008, yes.
13 Q. And when were you first appointed to the position of chief of the
14 communications and cryptographic data protection section or department?
15 A. I think it was the 15th or the 20th of August, five days here or
16 there, so August 1980. 1980. It was definitely mid-August, I think it
17 was the 15th, but ...
18 Q. So you started out as the chief; is that correct?
19 A. Yes, yes.
20 Q. And was that the position you held throughout your entire career,
21 until your retirement?
22 A. Well, the official names for that post changed, but the
23 description of duties was always the same.
24 Q. And then, as I recall, you moved to Banja Luka in 2001; is that
1 A. The 1st of November, yes, yes, 2001.
2 Q. And you worked as the chief in Banja Luka from 2001 until your
4 A. Yes, but I wasn't chief of the department, but I was chief of a
5 sector, technical maintenance, whereas in Prijedor I was in charge of
6 maintenance and utilisation because the station was smaller.
7 Q. Thank you. I understand.
8 I think you told us that your wife worked at Prijedor SJB in 1992
9 as -- in the economic or white collar crime section; is that correct?
10 A. Yes.
11 Q. Did she work there throughout 1992, the whole year?
12 A. Yes, yes, in Prijedor.
13 Q. And is her name Miroslava? I've seen that on a payroll document
14 I think.
15 A. Miroslavka, Miroslavka.
16 Q. Thank you. You'll have to help me with my Serbian pronunciation
18 A. Yes, yes.
19 Q. I think you told us before that there was a Dusan Jankovic who
20 was the commander of the police at Prijedor during at least part of 1992.
21 Are you and he related in any way?
22 A. No. He is from Kozara and I'm from Eastern Bosnia from near
24 MR. HANNIS: Your Honours, could we go into private session? I
25 have a couple of questions that I want to ask that relate to a personal
1 matter that doesn't need to be discussed openly.
2 JUDGE HALL: Yes.
3 [Private session]
11 Pages 24867-24868 redacted. Private session.
9 [Open session]
10 THE REGISTRAR: We're in open session, Your Honours.
11 THE WITNESS: [Interpretation] Allow me just to say one thing to
13 MR. ZECEVIC: I'm sorry, I'm sorry --
14 THE WITNESS: [Interpretation] After that I worked normally.
15 MR. ZECEVIC: If he intends to talk about his health, maybe we
16 should go back to the closed session --
17 JUDGE HALL: Yes.
18 MR. ZECEVIC: -- private.
19 [Private session]
6 [Open session]
7 THE REGISTRAR: We're in open session, Your Honours.
8 MR. HANNIS: Thank you.
9 Q. Witness, we're back in open session. I want to ask you about
10 something that you were asked on Monday. Page 24725 you were asked by
11 Mr. Krgovic about any changes in the reporting rules or how things were
12 done in 1992 after Mr. Drljaca came into the job as chief in Prijedor.
13 And you said the reporting rules were the same in 1990 and in 1992, but
14 they were not adhered to in 1992, thus, for instance, at times it was
15 obligatory for us to hold morning briefings, where we superiors would be
16 duty-bound to report our activities and then it would so happen they
17 would tell us the meeting would not be held. Now, my question is: What
18 reporting rules were you referring to and where are those found? Are
19 there some reporting rules in the Law on Internal Affairs or are these
20 something more informal and local?
21 A. The rules on the communications where I was an official, I mean
22 there are rules, they are known, and they were held at the communications
23 centre in their place. It was like a booklet or some kind of manual. As
24 for the rules of work that I referred to a number of times and yesterday
25 I used the term "police illiteracy" -- well, I really couldn't say that I
1 read the whole thing but when I did come to the service in the 1980s as
2 an engineer, I saw how the others were working and I did the same.
3 Always those who came would learn from those who were already working.
4 For example, if I went to another station on another kind of job I could
5 see the people there working in the same way so that meant that really
6 was the way the job should be done. Each police station had its own
7 collegium, also the centre also had that. There would be a different
8 make-up, though. As for where this was written, I really couldn't tell
9 you that.
10 Q. Okay. Between the time you started in 1980 and the time that
11 Drljaca became the chief in 1992, how many different chiefs did you work
12 for at SJB Prijedor?
13 A. From 1982 until ... Simo came on the 30th in 1982 -- no, no,
14 1992, I'm sorry. Simo came on the 30th of April, 1992. Up until which
15 date are you asking me about?
16 Q. My question was between the time you began working in the police
17 in 1980 until Drljaca came in 1992, how many different chiefs did you
18 work for during those 12 years?
19 A. Stojan Panic from August until the new year, he retired;
20 Rajko Zigic after him, one mandate for four years, and then another
21 incomplete term of office for three years, that was the second one, he
22 died; then Sead Besic came for a brief period, just briefly because they
23 said that he had to go to Banja Luka to be the chief of the centre there.
24 I don't know how short his term of office was, perhaps a couple of
25 months. Then Slobodan Stojanovic came. And then the multi-party
1 elections were held and then instead of Slobodan this Hasan Talundzic
2 came. That was that. I don't think I've forgotten anyone.
3 Q. And is it fair to say that when you worked under those prior
4 chiefs at least up until Hasan came, did you have regular morning
5 meetings or regular collegiums?
6 A. Yes, yes, from day one.
7 Q. Okay. How about under Hasan, did he also have regular
9 A. Yes, but they were not regular. They were not regular.
10 Q. And then under Drljaca, it sounds like you didn't have very many
11 at all; is that right?
12 A. Yes. And "yes" meaning there weren't any.
13 Q. But one difference in addition to Drljaca being the new chief was
14 that after April 30th there was a lot of combat and fighting going on in
15 Prijedor after April 30th, 1992; right?
16 A. I don't quite understand the question. Can you clarify.
17 Q. One thing that changed after April 30th, besides getting a new
18 chief in Simo Drljaca, was that there was a lot of combat going on in
19 Prijedor in 1992; right?
20 A. Yes, there was fighting, but everything changed. A man came into
21 the police force who had never been there unless he had been brought in
22 by the policemen, and so on and so forth. There were many other reasons.
23 Q. And you mentioned after Mr. Drljaca became chief there were
24 certain personnel changes within the SJB in Prijedor; right?
25 A. Yes.
1 Q. Which you said is not unusual, that that often happens when
2 there's a change in the chief; right?
3 A. Well, not really in the Socialist system.
4 Q. Well, at page 24726 when talking about this you said -- you
5 mentioned a couple of specific changes and then you said:
6 [As read] "There were similar examples like this one. It is the
7 prerogative of a chief to move people around. The first thing that they
8 always do is they always change their secretary."
9 Do you remember that?
10 A. Yes, that is true, yes. That I said.
11 Q. But let me ask you about that. The secretary for Hasan was
12 Mira Topic; right?
13 A. I did think about it. I know that for a period of time she was
14 there, but I am 1.000 per cent sure that she was there, Mira Topic,
15 during that meeting on the 9th of April when Mr. Zupljanin came. Now I
16 can't remember, there was either Sead or Hasan, one of those, who
17 appointed a Muslim secretary who had earlier worked for the commander of
18 the traffic police. She was there, but for a short time. And I can't
19 remember whether it was Sead or Hasan who appointed her. What I do know
20 is that Mira was there in those last days and stayed on when Simo was
22 Q. Thank you. We'll talk about her some more when we look at some
23 of the communications logs because I think you indicated recognising her
24 handwriting on some of the documents and some of the entries in the
25 log-books from Prijedor.
1 A. Yes.
2 Q. At page 24726 and going on to 727 on Monday you were asked about
3 some of the outlying police units being a part of the communications
4 system, specifically about Ljubija, Kozarac, and Omarska. And you said
5 they had an ultra short-wave radio set, a stationary one, and a telephone
6 line as well. Is that right?
7 A. Yes.
8 Q. But you mentioned that none of those had a teleprinter, so you
9 couldn't send them coded written information; right?
10 A. No, that's right, that's right.
11 Q. So how was written information sent from Prijedor to Ljubija,
12 Kozarac, and Omarska? Just by courier?
13 A. Yes. A policeman would carry a great deal of things, not just
15 Q. None of these were very far away from Prijedor, right, none of
16 those three places?
17 A. Kozarac 12, Ljubija likewise, and Omarska perhaps 25 kilometres,
18 not far away. By car, not far.
19 Q. And how often did couriers go? Did they go every day? Twice a
20 week? Or just as often as necessary? How was that?
21 A. Well, officially I don't know, but let me also say that there was
22 always somebody from that police station over here in town because they
23 needed consultation, to see the commander, so there was constant
24 communication. We were in contact or so -- in physical contact because
25 we were close.
1 Q. Thank you. Then you mentioned that according to the
2 organisational chart in the MUP in 1991/early 1992 that Sanski Most,
3 Bosanski Novi, and Bosanska Dubica were under Prijedor in terms of the
4 communications. Am I saying that correctly?
5 A. I'll repeat it briefly and then you'll see if your understanding
6 is correct. Officially the organisation changed at times. At times
7 Banja Luka was a centre for all of us, Prijedor, Sanski Most, and Dubica
8 would in those circumstances be on equal terms vis-a-vis Banja Luka.
9 Under a different organisation, Prijedor would become the centre, in
10 which case the three municipalities would gravitate toward Prijedor.
11 However, the technology was always in the hands of Prijedor. It never
12 changed even though the organisational structure did, Prijedor was always
13 in a superior position in relation to the other municipalities when it
14 came to communications technology if I was clear enough.
15 Q. What I'm trying to understand is I have the understanding that
16 when Banja Luka was sending out dispatches to Prijedor and its other
17 SJBs, that communications that were intended for Sanski Most, Novi, and
18 Dubica came to Prijedor and then Prijedor forwarded them on to those
19 three SJBs. It didn't go directly from Banja Luka to Sanski Most; it
20 went through Prijedor; is that right?
21 A. If Banja Luka is sending a dispatch to Sanski Most only, then it
22 would go directly to Sanski Most. Technically speaking, it would go
23 through Prijedor, but it would not go through any person's hands. It
24 would merely go through the equipment. However, if Banja Luka was
25 sending a dispatch to all the municipalities, then it was a circular and
1 it would be sent from Banja Luka to Prijedor only and the operator in
2 Prijedor would be forwarding a circular to all equally if everything
3 worked as it should, which often was not the case.
4 Q. Okay. I understand that now. That's better. And if Sanski Most
5 or Dubica or Novi wanted to communicate with Banja Luka, they had direct
6 links to Banja Luka and they didn't have to go through Prijedor; is that
8 A. Well, what is important again is to stress that in organisational
9 terms you're right; however, technically speaking, yes, if there was a
10 malfunction in any place, like in Prijedor, again what I'm saying is it
11 wouldn't go through any physical person. It would go through the
12 technology itself.
13 Q. All right. Let me show you a document that maybe will help me
14 understand a little better. It's Exhibit P1471. It's tab 3 of the
15 Prosecution binder. This will come up on your screen in a minute. Let
16 me know if you can read it there. It's a diagram I think of the
17 telephone network in Bosnia before the war, before April of 1992. Can
18 you see that all right or do we need to enlarge it?
19 A. Yes, if text can be enlarged. I can't read it.
20 MR. HANNIS: I don't think we need the bottom half right now.
21 Q. Can you see, we have the republican SUP in the middle and in the
22 upper left quadrant you'll see CSB Banja Luka and Prijedor. Can you see
23 that? I can hand you my copy if that's easier.
24 A. It's very hard for me to read. Yes, please, if I could be given
25 a copy and if I can read from that copy. Yes, excellent. I can see
1 everything now.
2 Q. Let me ask you, have you seen that before, that diagram?
3 A. This is a very old chart. It depicts what used to be the
4 communications plan much, much earlier. It does not mean much without
5 the supporting text. But you can ask me about it and I can see what it
6 is that you've marked.
7 Q. Let me ask you this: The key has been translated for me.
8 Banja Luka has a small circle within a bigger circle and that is
9 explained to be a nodal switchboard. Do you understand that term and can
10 you explain it to me?
11 A. Yes, yes, there's the key at the bottom. Let me first note that
12 the key and the designations are not universal. They were chosen by the
13 author, but then we have the key so we can have a look at it and how it
14 is logically. So I do understand it. The main switchboard and the nodal
15 switchboard or the hub switchboard. The main switchboard was the SUP and
16 Banja Luka was a node or a hub. If we wanted to explain it in somewhat
17 broader terms, the main switchboard can get connected to anyone, whereas
18 the hub or the node is just the node. What it connects. For instance,
19 the CSB Banja Luka, how can they place a call to Vitez, CSB Zenica and
20 then Vitez. They can do so via Sarajevo. That's why I say the main one
21 can do whatever it wants, can get connected to anyone and the node needs
22 to go through the main switchboard, if this is enough for you.
23 Q. Yeah, I think so. And on this diagram Prijedor is listed as a
24 nodal switchboard as well and I take it that's because it has the ability
25 to communicate directly with Sanski Most, Dubica, and Novi. That's why
1 it's a hub?
2 A. Yes, not the main but the nodal switchboard. It is only Sarajevo
3 that is the main one.
4 Q. And --
5 A. What I was just saying corresponds to what we have here. I said
6 that Prijedor could transmit circulars to these three municipalities.
7 Q. If you needed to get -- if you needed to get a written
8 communication -- a coded written communication from Banja Luka to
9 Sanski Most, could Banja Luka send that directly without any human being
10 in Prijedor having to do anything with it?
11 A. There existed in parallel to this transmission system that we see
12 here a different system of encryption or cryptographic data protection.
13 That particular chart or system could not be as extensive as this one.
14 Why? Because every two participants have to have a document in order to
15 be able to interact. Now, imagine how many participants there are and
16 each interacting with the other. Well, there would be a roomful of these
17 and you have that yellow tape with -- that is perforated. I don't know
18 if you've seen that before.
19 Q. Actually, I have, about 40 years ago when I was in my army doing
20 something I did see some of those things. But if I understand correctly,
21 if Sanski Most and Banja Luka have the encryption device or the tape on
22 each end, they also need a connection through which to send that message;
24 A. Yes.
25 Q. And there was such a link between Banja Luka and Sanski Most?
1 A. There is a link. There is the equipment, but there is no tape or
2 ribbon under that organisational chart because what we have in
3 Prijedor -- I'll say this very briefly to make it clear to you. You have
4 two tapes or ribbons that form a pair. Let's say they are between you
5 and me. And that there's two more between me and Sanski Most and that
6 there's four ribbons or tapes, it's one I would have and then each would
7 belong to one of the three municipalities. That's it. Nothing can
8 happen unless you have a tape. You can have all the devices you want and
9 all the equipment you want unless you have that tape.
10 Q. [Microphone not activated]
11 THE INTERPRETER: Microphone, please.
12 JUDGE DELVOIE: Microphone, please.
13 MR. HANNIS: Sorry.
14 Q. If I and Sanski Most have the tape and you and Banja Luka have
15 the corresponding tape, you can send me a message directly without any
16 human being in Prijedor having to do anything with it; right?
17 A. Yes.
18 Q. Thank you. We'll talk some more about that later, but let me now
19 go on sort of chronologically based on the questions that were asked of
20 you Monday. You were talking at page 24729 about when Hasan Talundzic
21 came to work as chief and one of the problems that you had with him was
22 that he had no prior police experience; right?
23 A. That's right.
24 Q. And I think you said also that he didn't consult with you on a
25 regular basis. You said after he came you could only talk to your
1 colleagues below you. You didn't have anyone upwards to consult with
2 because he didn't do that; right?
3 A. Yes -- well, he didn't have any knowledge about it. It wouldn't
4 have made any sense to consult him because he had no knowledge of the
5 things that we are discussing right now.
6 Q. Okay. And he had -- and you said he also was doing most of his
7 consulting with the local political authorities as far as you could see
8 and not with policemen?
9 A. Yes.
10 Q. Okay. I want to ask you -- that sounds like you could say the
11 same thing about Simo Drljaca when he came, no prior police experience,
12 not consulting with you, and consulting with the local political
13 authorities; right?
14 A. I did say so yesterday.
15 Q. The only difference is Talundzic is a Muslim and Drljaca was a
16 Serb; right?
17 A. And those who they went to to be told what to do were Muslims in
18 one case and Serbs in the other.
19 Q. Correct. I think this would be a good time to take our first
20 break for the morning. Thank you.
21 JUDGE HALL: Yes, we would resume in 20 minutes.
22 --- Recess taken at 10.22 a.m.
23 --- On resuming at 10.49 a.m.
24 MR. HANNIS: Thank you.
25 Q. Witness, I'd like to spend a little time going through some of
1 the log-books, communication log-books, from Prijedor. If I could with
2 the usher's assistance hand you a binder with four or five of the
3 log-books I want to talk about. I think you were shown some of these
4 when you were interviewed by Mr. Yarmah and --
5 A. You mean in Banja Luka, yes, yes.
6 Q. And if you open the binder you will see the first one has a tab
7 number 129. That's the first one I want you to look at and I'll give you
8 a specific page in a moment. This is Exhibit Number P2080, Your Honours.
9 And, Witness, before you go could you look at the cover page of that
10 document -- yeah, that -- the very first page -- yeah. Can you tell us
11 what that word is on the cover of that notebook, the black page?
12 A. Well, I would just like to mention the basic things. In
13 cryptographic work there is no term that would be used as a register or a
14 notebook. There are books like that in other departments with the
15 cleaning department or something, but I don't know anything about that.
16 I never worked with books like that, log-books. This is a log-book of a
17 sort. I opened it. I could see right away that it was from 1985. I
18 recognised the signature of my former superior, Rajko Zigic. It says
19 here authorised staff so this is what I said in relation to 1992 --
20 Q. Staying on that page if we could. If we could go to page 3 of
21 the B/C/S in e-court. And, Witness, it's the page you're looking at
22 right now. We don't have an English translation of that. Could you read
23 to us what it says on that page that you've got open in the book there.
24 Yes. It has the big word in Serbian "delovodnik."
25 A. Log-book, "delovodnik," yes.
1 Q. Can you tell us what else is written on that page on the top in
3 A. It states Municipal Secretariat for Internal Affairs, Prijedor.
4 That was our official name at the time.
5 Q. And I think you mentioned it had a reference to 1985. I think
6 that's where the first entry begins is in --
7 A. Yes, that's what it says here.
8 Q. But I only want to talk about 1992, and I've put a yellow stickie
9 note at the place where 1992 begins in your hard copy -- no, at the top.
10 Yes, that first yellow stickie note, if you could go to that page and in
11 e-court that's -- in B/C/S that's page number 166, which matches up with
12 the English page we have in e-court on the screen. Now, Witness, on that
13 left-hand page do you see at the top I think it says "1992"?
14 A. Yes.
15 Q. Looking at this, can you tell me what this book is about, which
16 types of communications are logged in here. Is it incoming or outgoing
17 and which department is keeping this book? Are you able to tell?
18 A. That would be hard. It would be very irresponsible for me to
19 interpret anything because this is a document that I had nothing to do
20 with. Only on the basis of my experience I can see that this is the
21 handwriting of Mira Topic, the secretary. This is what I see, nothing
22 more than that. I can see that it's her signature. She did enter some
23 official documents but I don't know pursuant to what rule.
24 Q. If you would go to -- it's item number or transmission number 15.
25 Do you find that? In the left-hand column --
1 A. 14.
2 Q. -- number, do you find number 15? Yeah, okay. My English
3 translation says the subject of that is a plan for short-wave radio
4 connections for the month of April 1992 dated the 30th of March and under
5 distribution code it has your name; is that right?
6 Can you tell us about that? Were there monthly plans for radio
7 communications that were distributed to communication chiefs in the MUP
8 in 1992?
9 A. Could we zoom in a little bit. This is the KT plan so this is
10 the short wave. I'm keeping my hand here, this is the KT radio
11 connection and that connection actually is not used at all. This is just
12 there as the last reserve in case all the other systems should break
13 down, all the post offices, all the wires, then it just goes from device
14 to device via antenna and you can, for example, set up a KT connection
15 from Prijedor to Japan. And that is why the signals people, even though
16 they didn't use that connection practically, they did hold trainings in
17 order to keep up their skills to use the keyboard. So that is what the
18 trainings were for. If you lose practice or if you are out of practice,
19 you cannot use the keyboard. So, for example, the training centre would
20 refer to something which sounds quite important. It's called the
21 communication plan, but actually what it indicates is just at what time
22 we should communicate and using which signals. For example, TFS, your
23 name would be QI or whatever, I don't know. That's the plan actually.
24 Has nothing to do with actual transfer of information.
25 Q. Okay. What I'm trying to find out in regard to this under the
1 column that says "sender" it says CSB was the sender of this document and
2 then it looks like you were the one who received it. Is that a fair
3 reading of that entry?
4 A. Yes, when the secretary received it she knew it was for
5 communication, and then as the chief, as the head, I would receive that
6 and then I would issue it to the workers who were working on that. So
7 every day at a certain time we would establish communication at that
8 particular frequency and that was just for the sake of keeping up the
10 Q. We'll see in a minute, but it seems like many of the documents
11 referred to in this particular log-book are longer documents. For
12 example, this -- the one that you were just looking at, there's another
13 one that's rules on internal organisation, a plan for confiscating
14 weapons, a telephone or ultra short-wave directory. So these appear to
15 be longer documents which I think you explained to me wouldn't be sent by
16 Teletype. Those were the kind of things that would be sent by a courier
17 because they were too long. Do you understand what I'm asking?
18 A. Well, there's a lot mixed up in there. You mentioned weapons. I
19 don't know which weapons. That has nothing to do with me. But as for
20 the telephone connections and communications, yes, that has something to
21 do with me. I would like you to be just a little bit more precise.
22 Q. Yeah, I'm trying. Maybe I didn't form my question well. You'll
23 see, we'll look at --
24 A. I'm listening.
25 Q. -- we'll see on some other documents, but the nature of most of
1 the documents that are listed in this log-book, they're not short
2 one-paragraph, one-page document, like are sent as dispatches via
3 Teletype. They're the longer documents which I think you explained in
4 your earlier testimony were the kind of things that would not be sent by
5 Teletype because they're too long and they're not secret, they're not
6 urgent so they go by courier. It might be a 30-page document or a
7 50-page rule book. Do you understand so far?
8 A. Well, the question is very broad so I really need to tell the
9 story in order to answer the whole question. I don't know if you mean
10 whether it was adopted, why -- I don't know what exactly the question is.
11 Q. Okay. Fair enough. Let's look at a couple and it may be that --
12 A. I will answer -- all right.
13 Q. If you could go to number --
14 A. Just one general remark. The papers that you've seen plenty of
15 them of that particular kind, as the state of Yugoslavia we had the
16 doctrine of All People's Defence, so the concept was that if anybody ever
17 attacked us every village would have everything they needed and we would
18 defeat anybody. So I myself really wasn't that familiar with all the
19 documents, I didn't understand all of them, and I didn't use them all.
20 However, there were professional National Defence services who were
21 writing that. So they were showing the results of their work through all
22 those papers so there were so many of those papers but when there was a
23 need to use them none of them were used. Perhaps that's the sort of
24 papers or documents that you looked at. If you can show them to me then
25 I will talk about it.
1 Q. Okay. Well, let me show you a couple of documents and I'll ask
2 you some further questions. Could you look at number 19. I think it's
3 the next page on for you. Item number 19, it's -- the subject described
4 is plan for confiscation of illegally acquired or owned weapons and mines
5 and explosives from groups and individuals in the Prijedor area. The
6 date is 27 May. The sender is SJB Prijedor. It says three copies
7 delivered to the CSB. And then in the far right column it says
8 CSB Banja Luka to the CSB chief sent via colleagues from CSB, delivered
9 by M. Djenadija. Do you know who M. Djenadija was, by the way?
10 A. I think you skipped two words and those two words are very
11 important. Sent to the chief through colleagues from the CSB. So
12 evidently this was not conveyed by any kind of communication. Okay,
13 Djenadija, Marko, at the time was some kind of commander. I don't
14 know -- I don't want to mix them up. Maybe he was at the police station
15 number 2, the one in Urije. I don't know. They changed so really it's
16 been a while. I can't tell anymore but he was some sort of komandir.
17 Q. In the police?
18 A. Yes, yes, he had a uniform.
19 MR. HANNIS: If we could look on the screen for the moment at
20 exhibit P1036. This is at tab 49.
21 Q. Witness, we're going to show you a document I think may relate to
22 the log-book. You see, this appears to be a cover letter from
23 Mr. Drljaca. It's addressed to the chief at Banja Luka, and my English
24 translation says:
25 "Please find herewith enclosed for further comment and approval
1 the plan for confiscation of weapons ..." et cetera.
2 And you see at the top the number of this communication is
3 11-12-19 dated the 26th of May, 1992. Can you explain for us again ABOUT
4 the numbering system of communications within the RS MUP in 1992? What
5 does the 11 stand for in that number?
6 A. Well, I know generally but I don't want to make any mistakes.
7 But I can tell you the principle. Between the lines, the first part of
8 the number talks about the organisational unit. 11, I think was at the
9 time referring to Prijedor, that stood for Prijedor. 12 is a subunit, it
10 could be the chief that's separate, then the police station, the criminal
11 investigations police, communications, and so on and so forth. And the
12 next one, the last one should be the log-book, log number. I mean, to me
13 that's a foreign term, but I think that should be the number there. Did
14 we say 19? Yes, that's it. Let's say by hierarchy, company Prijedor,
15 for example.
16 Q. Okay. We'll look at some more. I know it's been a long time
17 since you dealt with these, but I would suggest to you that 11 seems to
18 refer to CSB Banja Luka. And 11-12 refers to Prijedor SJB.
19 A. You're most probably right because as you were speaking I
20 remembered. When we were part of the Banja Luka centre - and that's that
21 period - then the centre was the first number, so 11 then would be
22 Banja Luka and then Prijedor would be 12. But, however, here this number
23 is kind of small. There were more numbers. The number should have the
24 chief, criminal investigation police, perhaps communications. My number
25 was 04 and so on and so forth. And then the last number would be the
1 log-book number. So this number is very short. So I cannot really tell
2 what goes with what in terms of the police departments.
3 Q. I understand. We'll look at numbers that are longer. And is it
4 correct, most of the time I'm used to seeing on the end of a number on a
5 document like this a slash and the year, two-digit year, 92, 93,
6 et cetera.
7 A. Yes, that's the year, yes. And these longer ones I forgot about
8 them even more.
9 Q. If we could go back to the log-book, I want to show you another
10 one, Exhibit P2080 and for you it's item number 20, the very next item in
11 the book. You were looking at 19, if you could look at 20 -- no, it's
12 still on the same page, I think, where you were. You were looking at
13 number 19. Look at the very next one, number 20. It's -- my translation
14 says the subject is order regarding treatment of arrested persons.
15 Sender is SJB Prijedor. It's delivered to the Crisis Staff, some
16 co-ordinators, a couple words are not translated because they're
17 illegible according to our interpreters. But the name Jasic,
18 Majstorovic, Banja Luka CSB, chief of security, administrator of the iron
19 ore mines and archives. Do you see that?
20 A. [No interpretation]
21 Q. Just keep that number 20 in mind and I want to show you another
22 document and that's P1560, that's tab 58 on the Prosecution's list. I
23 can give you a hard copy of this one with some help from the usher.
24 MR. KRGOVIC: [Interpretation] Your Honours, I have a general
25 objection to the line of questioning by Mr. Hannis, because this witness
1 is being shown a document that is not a communications document and he's
2 being asked to look at the document and to read what it says. But it's
3 already been admitted so what would be the purpose of this line of
4 questioning of this witness? Just to read what it states in the document
5 and to confirm that that's what is written. It's not a communications
6 document so I don't know how that can assist.
7 MR. HANNIS: Well, Your Honour, it goes to a host of issues.
8 This witness worked in the SJB in Prijedor and although he was the head
9 of communications I believe it's fair to assume that he had some fair
10 knowledge about the general workings of the police station. He knows
11 various individuals, he recognises handwriting, and I think he can shed
12 some light on how books were kept, what kinds of information were
13 received by whom, how they were distributed, et cetera. And he can also
14 comment on the content of a number of these documents, at least as to
15 whether he knew about them or not. And the level of his knowledge is
16 going to be very important in assessing the credibility of all his
17 evidence at the end of this case.
18 JUDGE HALL: Yes, I suppose so, Mr. Hannis. One thing that
19 struck me, though, is that apart from the basis of Mr. Krgovic's
20 observation that the documents which have been admitted speak for
21 themselves, the witness's answer to some of your earlier questions,
22 having indicated his unfamiliarity with the contents, as it were, seeing
23 these exhibits for the first time, I wonder how much usefulness is going
24 to be derived from the line of questions that you propose.
25 MR. HANNIS: Well, Your Honour, perhaps I could ask the witness
1 to take his headphones off while I respond to that.
2 Q. Witness, could you take your headphones off for a minute while I
3 speak to the Judge about something. Thank you.
4 MR. HANNIS: Your Honours, communications apparently still
5 appears to be a hotly contested issue in this case, at least from the
6 Defence perspective. We think there is lots of evidence about
7 communications and although there was evidence about electric part of
8 communications not working, we say there are lots of other ways to do
9 communications, regular mail, courier, et cetera. This witness was not
10 in a position to know about all those, but he can corroborate that these
11 documents are from Prijedor, that he recognises signature of the
12 secretary of the chief on some of these documents. So they're authentic
13 and they reflect that communications were going on beyond and above and
14 outside what's in the communication log-books per se. This is not a
15 communication log-book that was kept in his centre; rather, it appears it
16 was one kept by the chief's secretary. But it reflects communications
17 that won't show up that he hasn't seen. So we need to supplement his
18 evidence about the level and quantity of communications with other
19 evidence, otherwise we're left with him saying: Oh, communications
20 didn't work and, you know, it was terrible and we weren't able to
21 communicate with anybody to the extent that he said something like that.
22 And I think we're entitled and it's necessary for me to try and establish
23 that that's not the case.
24 JUDGE HALL: I see. Please proceed, Mr. Hannis.
25 MR. HANNIS: Thank you, Your Honour.
1 Q. You can put your headphones back on. This relates to what I was
2 asking before about lengthy documents. This is more than just one or two
3 pages, this document, so I understand from your earlier evidence this is
4 not something that would have been transmitted electronically through
5 your communications system simply because of the length of the document;
6 is that right?
7 A. I remember the gentleman from the OTP asked me about this. I
8 don't remember literally what I said, but I repeat it because I want to
9 say it. The rule of transfer of written information is that half a page
10 up to one page of text can be transferred by teleprinter. Everything
11 else is conveyed by courier. That's the rule. However, often because of
12 the urgency, even two or three pages if necessary are sent, if they have
13 to be sent, but this did not constitute a rule. And usually the signals
14 operator would ask for my opinion. If it has to be sent then it would be
15 typed. It's not a problem, you could send two or three pages, but never
16 10 pages or 20 pages. If that's what you meant. I said that before and
17 I'm repeating that now.
18 Q. Did you ever see any documents from Chief Drljaca addressed to
19 the Crisis Staff? Did any of those documents ever get sent via the
20 communications centre that you know of?
21 A. Not through the communications centre. That's because the
22 Crisis Staff is nearby, and as for me monitoring or keeping track of
23 these things on any other basis, no, that was not possible.
24 Q. Thank you. I want to go now to the next tab in your binder,
25 tab number 130. Thank you. Tab number 130 and if you could tell me --
1 this is Exhibit P2088. Can you read for us what's written on the cover
2 of that book or printed on the cover of that book in Serbian because we
3 don't have an English translation of that cover page?
4 A. The book of outgoing coded telegrams.
5 Q. And could you look at the next page in B/C/S in e-court and the
6 inside cover, could you look at the next page in your hard copy.
7 A. Yes.
8 Q. Can you tell us what's there, the stamp and the printed words?
9 A. The book contains 100 sheets of paper with the numeration between
10 1 and 100 and bound and I'm -- I signed it as head of the communications
11 and KZ, that's encryption section.
12 Q. So was this a book that was kept in your communications centre in
13 Prijedor SJB in 1992?
14 A. This book is obviously an official document containing records of
15 coded documents that the centre transmitted. As I said yesterday, it
16 normally had its official designation, the form, and it does say, in
17 fact, K20, but what I see here that it's not really the book of records
18 of our centre but rather of the chief's secretary. Let me explain this
19 further, the secretary, the administrative secretary, was duty-bound to
20 keep a separate record of her own of all these coded dispatches. Since
21 she didn't have a notebook of her own to do this, I gave her the book
22 that we normally used. Since the book is one of coded dispatches
23 encrypted, it has to be bound in this way. You can't really tell it here
24 because you can't see it, but it's the way of binding a book in such a
25 way that the sheets of paper cannot be taken out, cannot be interchanged.
1 This is part of the cryptographic data protection system. And you can
2 also see that it's her handwriting here so she made the entries. And in
3 column number 7 you can see the signatures of the various individuals who
4 actually worked under me, they were various encryption operators. I know
5 their names. So she would note down the date and time of a dispatch, the
6 person who received it, and so you have all the information there.
7 Q. This particular book then, where was it kept? Was it kept in the
8 secretary's office or in the communications centre or the chief's office?
9 Physically, where was it located?
10 A. I'm sorry, the beginning of your question was cut off. I didn't
11 hear it. Can you repeat your question.
12 Q. Sure. This particular book, where was it physically kept in
13 1992? Was it in the communications centre --
14 A. It was kept by the secretary, the personal assistant. I never
15 checked this book. I gave her an empty notebook and that was all.
16 Q. And that would be Mira Topic that we've talked about before?
17 A. Well, the date here is back in 1986 and I think it was
18 Nada Markovska who occupied the post and not Mira Topic. Well, at any
19 rate, in these various times a lot of them changed. I don't know how
20 many. I don't think this is Mira's signature. It may have been Nada,
21 who if I remember correctly, was there first.
22 Q. Sorry, my mistake. Can you go to the yellow stickie note, go to
23 that one and I think that will take you to the entries for 1992 in this
24 particular log-book begin.
25 A. Yes.
1 Q. That's page number, I believe, 19 in e-court. It's ERN P0042544
2 do you recognise the writing in 1992, is that Mira Topic?
3 A. In most of them, yes, but there are entries where it is not her
4 from what I can tell. Under 19 that doesn't seem to be her, but item 6,
5 for instance, 7 as well, or rather, from 1 to 10, yes, that's Mira Topic.
6 I am certain that it is her. Maybe somebody will say that it isn't, but
7 I'm sure that that's not her under 19.
8 Q. All right. Could you go to the very next page -- or actually,
9 can you go two pages further on and two pages further on in e-court. I
10 want you to look at item numbers 49, 50, and 51 -- I'm sorry, I may have
11 sent you too far. Can you go back and find the items 49, 50, and 51.
12 Looks like telegram numbers 2023, -25, and -31. Do you see those?
13 A. Yes, 2023, and 2025 and 2031.
14 Q. Okay. The signature for item number 49, that appears to be
15 Goran. Who would that be?
16 A. One of the communications officers --
17 THE INTERPRETER: The interpreter didn't catch the family name.
18 MR. HANNIS:
19 Q. Could you repeat his family name for us.
20 A. K-o-v-r-l-j-a, Kovrlja.
21 Q. Thank you. Now is --
22 A. I apologise. I'm sorry, there is an "I" missing,
23 K-o-v-r-l-i-j-a, so his name is Kovrlija.
24 Q. Now --
25 A. Now it's all right.
1 Q. It appears that the numbers assigned to these dispatches are in
2 ascending order, numerical order. Where does the assignment of numbers
3 come from? How do you know what number to put on the next outgoing
5 A. Well, the last number -- let me think it over rather than make a
6 mistake. I'm trying to remember these things. It was a long time ago.
7 Normally the number in its entirety, which is found within the heading of
8 any typical dispatch, the former part would be written by the author and
9 the last four digits would have been added by the communications officer
10 dealing with the dispatch. And those would normally be added by hand.
11 Since this is Mira's book and the numbers are not in sequence and they
12 are not even Mira's as far as I can tell by looking at the
13 handwriting - and this is me making an inference - I believe that Mira
14 left this particular box empty whenever she prepared a dispatch and
15 wanted to take it over to the communications and encryption section, she
16 would fill in all these save for that number, time, and signature. And
17 then the communications officer would use the first next number available
18 in his book and Mira would take it over and write it in here and she
19 would write the date when she handed the dispatch over and ask the
20 operator on duty to place his signature there. That's how things should
21 have worked.
22 Q. Okay. But the book where the running list of numbers is kept is
23 in the communications centre? Do you understand?
24 A. Yes, yes, yes. In the communications centre.
25 Q. And because it appears there are only 100 coded telegrams sent in
1 1992 with the first one having a number of 141 and the last one having a
2 number of 2.580, that means there's something like 2.480 other numbers in
3 that range from 1 to 2.580 that weren't coded telegrams. What documents
4 did those other numbers go to, if you follow my question? Open
5 telegrams? Other kinds of communications that aren't telegrams --
6 A. The question is clear and now let me tell you. As I said, the
7 book was of the format which belonged to cryptographic data protection.
8 All the other rules related to encryption stemmed from those prescribed
9 by the army. We were called upon to adhere to those. We were just one
10 group of users of those. Having said that, as I said, the books were not
11 destroyed before the expiry of one year or -- well, one year at the most.
12 They could have been destroyed after six months as well. So what
13 happened next? Since we had a very low fluctuation of dispatches because
14 we were a small station, if I only filled in two of the sheets, two of
15 the pages, and the rest of the book was empty, the practice was that we
16 would if we had a lot of these books in stock, we would have this one
17 destroyed to adhere to the rules. However, it also happened that we
18 would continue using that book and that was the case with this because
19 you see that the book stretches from page 88 to, or rather, from year
20 1988 to 1996. So it was -- it had a long life and this was actually
21 contrary to the rules. Had we had an inspection come in, they might have
22 had understanding for this and perhaps not. I have not had experience
23 with the inspection looking into this sort of rules. So I can't tell you
24 what the case was in this -- with this specific book. I don't remember.
25 Q. I'm sorry, I think we had a miscommunication. I think you were
1 explaining why we have more years than just 1992 in the book, but my
2 question is: Focusing on the year 1992, just the year 1992, in there we
3 see there were 100 telegrams, coded telegrams, sent in the entire year
4 1992 from Prijedor SJB with the first number --
5 A. From the chief, but if it was the commander who was sending a
6 dispatch and believed that it had to be coded, it would be designated as
7 coded but it would not be entered into this book. Or, for instance, if I
8 sent out a coded telegram from the communications centre, it would not
9 have been entered into this book.
10 Q. Okay. Well, we'll look at your year-end report on communications
11 later and come back to this issue. But do you understand the point I'm
12 making about the -- the last number that went out on a telegram, for
13 example, before the /92 at the end of the number? It appears that in
14 1992 the first document that went out would have been 11-12-something/01.
15 But the first telegram that went out, the first coded telegram that went
16 out in 1992 appears to have been on the 6th of January and it was given
17 the number 141, do you see that, very first entry for 1992?
18 A. 6th January, 1992, yes, you're right.
19 Q. And it was number 141; right?
20 A. Yes.
21 Q. My question is: What were numbers 1 through 140 before the 6th
22 of January? What kind of documents would those numbers have been
23 assigned to, if you know? Something other than a coded telegram
25 A. Now the question is clear to me. Since I've forgotten all the
1 details, let me -- I would have said at first that these were only coded
2 dispatches. But if we have 141 -- if I look at that number I say that
3 there's not a chance that they could all have been coded. There must
4 have been open ones among them. Did I understand this now?
5 Q. Maybe. Let me ask you another question. Does that mean then
6 that in total - because you'll see the last number in that log-book is I
7 think 2.580 - does that mean to you that in 1992 the total number of
8 coded telegrams and open telegrams sent from Prijedor SJB must have been
9 at least 2.580?
10 A. Things change. It's very difficult. There are four numbers in
11 the books, those received, those transmitted, those open, and those
12 protected. And it changed. And at times during the war the total number
13 would have been over 100.000. However, at the time when this arrived,
14 there would have been a thousand at the most. So thinking about these
15 approximations, I know that we had over 100.000 dispatches, but most of
16 them were open. Those were the peaks, let's say. But I couldn't give
17 you the figures, not even approximate ones.
18 Q. Can you stay with me for a little bit. Look at the last page,
19 telegram number 100 for -- can you go to number 100 for 1992. If
20 you'll -- you'll have to keep turning your page, I think. It should be
21 the last page. There you go, on the right-hand side, the right-hand
22 page. Witness, the other -- see number 100?
23 A. Yes.
24 Q. It's been assigned the number 2580, 2.580, on the 30th of
25 December, 1992. To me that suggests that in 1992 there were 2.579 other
1 documents before this. We see by this book that 100 documents in 1992 --
2 A. Yes, that's logical, yes.
3 Q. Okay. And we see that 100 of those documents are coded
4 telegrams, the ones in that book. But you also have open telegrams. So
5 am I right in assuming that there were 2.000 -- at least 2.480 open
6 telegrams sent in 1992, to make up for all those numbers that aren't in
7 this book? Do you follow?
8 A. I understand your question clearly and I clearly understand what
9 it is that you want. And I'm trying to wrack my brains to recall all
10 these things. And I'm trying to recall the way these books were kept,
11 such as this book of outgoing dispatches. It is true to a large degree
12 that all the dispatches received by a communications operator received in
13 terms of the fact that he had to transmit them further, they would get
14 the next available number. And then there would be a designation
15 indicating whether they were open or protected. So it logically arises
16 from this book that by this date the total of 2.580 dispatches were sent,
17 of which 100 were sent only from the chief, but that does not mean that
18 they were all coded telegrams. Jankovic could have sent coded telegrams
19 to Banja Luka and they would not have been noted here. So I believe we
20 have resolved this problem.
21 Q. I think so. Thank you. Now if you could go to the tab 132, not
22 the very next one but the second one after in your book, yeah, behind
24 MR. HANNIS: And, Your Honours, that's Exhibit P2090.
25 Q. Witness, can you look at the first page. That doesn't tell you
1 much. I think it just says CSB Banja Luka on it. If you could turn
2 inside --
3 A. I had never seen them.
4 Q. And inside do you recognise any of the handwriting or the
5 numbering on those pages? It appears to be some sort of courier or mail
6 delivery log-book. You've never seen this before?
7 A. Never. Not even with your colleague who brought over these
8 things. I don't know anything about it. However, this title, working
9 lists, well, this is something that we had in our encryption work. So I
10 suppose that this is something that they used for handling their papers.
11 It is similar to what we had in our department, but this is the first
12 time I see this.
13 Q. Tell me about couriers. Did you have couriers in the police in
14 Prijedor SJB in 1992; and if so, were they part of your department or
15 were they just regular policemen who did that duty or were they part of
16 the duty operations service? Who were the people who actually delivered
17 hard copies to mail back and forth between Banja Luka and Prijedor, for
19 A. In the period before when everything was normal -- may I begin my
20 answer? Very well.
21 Earlier on, as I say, when everything was normal, definitely
22 before the multi-party elections, there was a plan for the courier
23 service and I think it was normally on Tuesdays and Thursdays that a
24 policeman from the duty service would go to Banja Luka and come back, but
25 they had nothing to do with me in organisational terms. If I needed to
1 have anything sent, I would get in touch downstairs with the secretary of
2 the chief and ask when the courier was due and I would send the envelope
3 with him and he would deliver it to whoever I needed. It was the police
4 or the commander, I don't know who it was, who decided when these things
5 would be sent out. Now there arose a huge problem of the shortage of
6 petrol. So everybody was economising on this. The chief was not able to
7 provide the sufficient amount of petrol. So everything was done to make
8 sure that the courier was not sent to Banja Luka for any little errand.
9 If I needed to have anything sent, I would then use their services, but
10 it was rarely that I would do that.
11 Q. [Previous translation continues]... I understand you started that
12 answer talking about before the war, was the system with couriers still
13 generally the same after April 30th, 1992? I take it they went as often
14 as was necessary; is that right?
15 A. Well, I just told you, the system remained the same. But even
16 where everything remains the same, if there is no petrol, then nothing is
17 the same.
18 Q. [Previous translation continues]... I'm sorry, I didn't
19 understand that. Thank you. Okay, I think I've lost my audience a
20 little bit so let's not talk about log-books for a while and switch to
21 something else.
22 A. Yes, there was no petrol and economising with petrol and vehicles
23 and personnel. There was a shortage of personnel as well so we had a
24 number of problems, not just one. Under such circumstances, the chief
25 and the commander had to organise things and it was difficult.
1 Q. Thank you. Let me ask you now about something else you talked
2 about on Monday. You were at page 24730 talking about the tensions in
3 town in April/May of 1992, both before -- well, let's talk about before
4 the Serb take-over and the first month or so immediately after. You
5 mentioned that one could feel that in the town and that there were people
6 who didn't react the same way. You had a colleague and you maintained
7 good relations. What particular colleague were you talking about that
8 you maintained a good relationship with after the Serbs took over, do you
10 A. Well, there were plenty that I maintained a good relationship
11 with. I don't know. Well, anyway, if I was thinking of my colleague
12 with whom I was on good terms with and then there was a certain cooling,
13 I think that this was perhaps Ago Sadikovic, this was an inspector who
14 worked with my wife on white collar crime. But there was also
15 Suljo Dzonlagic who was my colleague from university, he was a neighbour
16 within an engineer as well. He taught in school. Until the end I was on
17 good terms with him because those who were friends for a longer period
18 with Suljo, for example, our friendship was never jeopardised, but with
19 Ago there was a kind of cooling in relations without any quarrel or
20 conflict. It's different from person to person. It depends.
21 Q. Those that you just mentioned, do you know if any were detained
22 and taken to Keraterm or Omarska?
23 A. I don't know about Ago because he didn't sign for that thing in
24 the morning when he came. I don't know afterwards, I didn't see him
25 after that. He didn't even live close to me. As for Suljo, he didn't go
1 to Keraterm or Omarska. He managed to join some kind of convoy or
2 something and now he's in Sydney, I mean he was in Austria somewhere.
3 Q. What about Nusret Sivac, did you know him? He worked in the
4 state security in Prijedor?
5 A. Well, you can ask me about him as much as you want. I was his
7 Q. Do you know what happened to him after the -- [Microphone not
9 THE INTERPRETER: Microphone, please.
10 MR. HANNIS: I'm sorry.
11 Q. Do you know what happened to him after the Serbs took over in
12 Prijedor? Wasn't he detained and kept at Keraterm or Omarska?
13 A. Sivac was detained twice. I don't know if that's in his
15 Q. And do you know where he was detained and how he was treated when
16 he was there?
17 A. Like this, Sivac was a signals operator just like the others.
18 There is that book by Mira Topic from earlier on. I think there are
19 signatures by him there too until 1989 and then he retired. The book
20 that we had before this one, there are signatures by Sivac there. I
21 think you can check that that was until the end of 1989 and then he
22 went -- he retired because he wanted to and also because he had the legal
23 condition. Sivac was always a communications operator and I was his
24 boss, officially. Unofficially, Sivac was carrying around a film camera
25 and recorded or taped things part time and sent it to Sarajevo
1 television. He made short news items from Prijedor. Usually in the TV
2 crew there would be -- the journalist who would be the one in charge, but
3 he turned that around. So he was the main person in the crew and he
4 would always find a journalist. So the journalists would change but
5 Sivac would always be there.
6 Q. Sorry, let me stop you because my question was do you know where
7 he was detained and how he was treated when he was there? Do you know
8 about that?
9 A. I was about to say that. I was about to tell you.
10 Q. Please do.
11 A. And Sivac -- and Sivac was detained, he wasn't working those days
12 that were bad when people were being detained, I didn't have any contact
13 with him. But then later he said when we met that he was taken away - I
14 don't know who took him away - he was taken to Omarska. Omarska was
15 already set up by then. He wasn't detained before that. As far as I
16 know he wasn't brought in to the SUP, to the police, either. Perhaps he
17 was, but as far as I know he wasn't. He was taken to Omarska and there
18 was an interview with him there and then in a day or two Sivac was
19 released as not guilty. But then he was in Prijedor for a few days, I
20 don't remember how many, and then he was detained again because allegedly
21 in the investigation some new circumstances were established. And I
22 think that he told me that he was there for 40 days. Perhaps he wasn't.
23 I don't know. I can't remember that. In any event, Sivac was released
24 after his second stay and then he came to me asking me for help. He said
25 that he wanted to go somewhere, I don't know, Germany, somewhere in
1 Europe with his own vehicle. He happened to have a Ford Escort. He had
2 a wife and two children. The children were just like my children, 7 and
3 10 years old, something like that. And as I said, at the time there was
4 no petrol so these people - how shall I put it? - not from the police but
5 those people who were not respecting the laws, they would seize a car
6 from somebody for as long as there was petrol in it and then they would
7 just discard it and take a new one. So close to some creche next to the
8 SUP I saw his car just there. I just noticed it by accident. And then
9 he came to me and he said, "Boss" -- he was afraid to come, he was scared
10 to come. I mean, he had no reason to be afraid, but I guess he did. If
11 he was afraid, well then let him be afraid. He asked if I would be able
12 to somehow get this car to him because he wanted to go. I said I would
13 try. I didn't do it myself, I sent a technician, Mladen Raus to find out
14 who was driving that car, it was somebody close to the SUP, some kind of
15 reserve soldier or police officer. In any case, he found the keys to the
16 car, took the car to Sivac, and Sivac used that car to go to Europe.
17 This is it in brief. I don't know where he went.
18 Q. Well, that was -- that was more than brief I think. You've
19 indicated to us you are quite detailed and meticulous --
20 A. You mean details.
21 Q. Because I have limited time, I'll have to ask you from time to
22 time to try and keep your answers short and if I need more I will ask
23 more. Okay?
24 A. Yes, you just give me a sign with your hand and I will cut it
25 short. It's not a problem. I'm trying to adjust it.
1 Q. I understand, thank you. You said you weren't sure what
2 Mr. Sivac was afraid of. Wasn't he afraid of the kind of thing that was
3 happening to non-Serbs in Prijedor at the time, that he might be arrested
4 and detained again without any criminal charges being filed?
5 A. Yes, he was afraid. But, sir, I was also lying down on a stone
6 in front of these semi-savage Serbs. Somebody hit me a number of times
7 over here. I was afraid as well. Perhaps Sivac was a little bit more or
8 a little bit less afraid.
9 Q. I remember you telling us about the incident where you were shot
10 at as well.
11 A. Yes, yes.
12 Q. You talked --
13 A. Not just that. I was hit by a rifle when I was coming back from
14 Omarska, not hit, I was beaten by brother Serbs.
15 Q. Army? Police? What?
16 A. I think that even they don't know who they were. They had old
17 JNA uniforms from Comrade Tito times. Somebody had trousers, somebody
18 had a shirt, it was an odd combination, somebody didn't have any of the
19 uniform items. They did have weapons, though, but this was the military
20 I think, not the police. The police knew me.
21 Q. You mentioned I think before that you visited Omarska three
22 times. Which one of your three visits did this happen on, the first,
23 second, or the third?
24 A. The first, the first.
25 Q. Thank you.
1 MR. HANNIS: I see it's nearly time for our break, Your Honour.
2 JUDGE HALL: Yes. So we would return at 12.25.
3 --- Recess taken at 12.02 p.m.
4 --- On resuming at 12.31 p.m.
5 MR. HANNIS:
6 Q. Witness, on Monday when you were talking about the situation in
7 Prijedor after the take-over on 30 April, you talked about a number of
8 the non-Serbs or mostly Muslims leaving. And you talked specifically at
9 page 24735 about a communications worker under you, Mirsad Sahuric, did I
10 pronounce his name correctly?
11 A. S-a-h, Sahuric, you pronounced it well.
12 Q. Thank you. I seldom hear that. You mentioned that he was
13 probably one of the last ones to leave, but while he was there you said:
14 [As read] "I tried to the best of my ability to make it as
15 comfortable for him to stay in that environment. I tried as best I could
16 to help him. There were other colleagues and I as well who helped him to
17 get food-supplies because they were people who did not dare to walk about
18 the town."
19 What was it in Prijedor after the 30th of April, 1992, that made
20 it so uncomfortable for the non-Serbs?
21 A. It's hard to say. I'm going to try to be brief. I mean, this is
22 a complex question. One would need to write a serious study about it but
23 it's impossible to explain it in ten sentences. But I will do my best.
24 The gist, and I always say that not just here, everywhere, it's not that
25 the Serbs are no good or the Muslims are good or the other way around.
1 It's not a battery with a plus or a minus end. You cannot have a big one
2 and a small one. They're always the same but they're opposites. After
3 the 30th of April, the day this guy was killed, Japa [phoen], on that
4 night, somebody killed him, a Muslim, but we never found out who it was.
5 And the process began. Every day, every minute, there was a chance you
6 could get killed no matter who you were. For example, I concluded for me
7 it would be better not to wear a uniform because if I wore a uniform
8 before the war, I didn't have the right to one during the war. I did.
9 But if I wore a uniform there was a chance I could be hit by some
10 residential building by some Muslim. They didn't leave, they were still
11 there, they didn't reconcile them to the situation. Some people are
12 staying, some are leaving, some people want to go and there was more and
13 more shooting, there were more and more dead people of all ages from all
14 ethnic groups. And that's why I say I never took a uniform. Perhaps it
15 was better for some of my people from the police to stop me and search me
16 without a uniform rather than to be in a uniform. So that situation
17 wasn't any better or worse than any other situation. And in all of that,
18 this is the main thing, there were shortages of power. When there's no
19 electricity, you know what happens. Trade was dwindling down. There
20 were shortages. There was no petrol, there was no bread. I happened to
21 have my wife's parents living in a village nearby, some 15 kilometres
22 away, I mean it's doable by bike. I couldn't use the car, there was no
23 petrol. So I would go by bike. I would get some bread, some vegetables
24 and that's how we lived. There were no salaries being paid. So in all
25 of that some people had it good, they made it through, and some didn't.
1 As time passed, however, and then on the 30th of May when that came
2 around with that attack, then there was a selection that started to be
3 made. Before then there was no selection. They were not bringing in
4 citizens, they were just bringing in suspects for existing incidents, but
5 there was no systematic thing. Then with the 30th, with the attack on
6 Prijedor, it all began suddenly so that when I started to listen to the
7 other side through the media, then I could see how the evil Serbs
8 couldn't wait to start catching the poor Muslims. That is not correct.
9 Earlier when you mentioned Nusret Sivac, he was not an innocent lamb that
10 was brought to Omarska. He came back for the second time when he was
11 telling me about this vehicle for me to try to get it back for him, he
12 told me: "Well, boss, I spent" -- I don't know how many days he said he
13 spent in Omarska for nothing.
14 I said: "No, Nusret, that is not true. On the 30th of May you
15 were in Obala." I am telling you Obala is a restaurant around which
16 there was a large battle and one hero of theirs, one of their men was
17 killed and then Kaduc [phoen], a Serb after whom a square now is named in
18 Prijedor. So there were some battles and that's where Sivac happened to
20 And I said, "How come you were there?"
21 And he said, "Well, boss, I came to pick up the money from my
22 private personal slot machine."
23 So I don't know after all he was released twice he could have
24 encountered some fool and something else could have happened and similar
25 things happened to other people in other circumstances.
1 Q. Okay. I understood when you asked to be able to go on a bit that
2 it's not a simple question to answer and even though you did go on a bit,
3 you didn't precisely answer the question I was asking which was what it
4 was about that made it hard for the non-Serbs, the Muslims --
5 A. Ask me, yes, go ahead.
6 Q. But I think I got part of your answer that did address that. I
7 guess after the 30th of May when there had been the attack on Prijedor by
8 Muslims then it sounds like you're saying there was a much more
9 systematic rounding up of all kinds of Muslims, not just suspects. Is
10 that fair?
11 A. [No interpretation]
12 Q. I'm waiting for the translation.
13 Could you answer again. I don't think we got a translation.
14 A. The first part of the question, what happened and what is the
15 uncomfortable thing for those who are not Serbs before Serbs -- I mean,
16 it's the same answer to the question of what happened to those who were
17 not Muslims in areas where the Muslims were a majority, for example, in
18 some other location. I mean, you could write a book about it. That is
19 the essence, though it is complex. Okay. That's the first part of the
21 Q. Can I rephrase the question and maybe it will be easier -- maybe
22 it's easier to answer this way. Is it fair to say in Prijedor
23 municipality in areas where Muslims were a majority, it was difficult for
24 non-Muslims because there was the danger of harassment, discrimination,
25 even violence? And likewise in the Serb majority parts of Prijedor it
1 was uncomfortable and dangerous for non-Serbs for the same reasons,
2 because there were extremist Muslims and there were extremist Serbs.
4 A. That is right, but if you permit me, I will add something. I
5 will try to be as brief as possible. I always think that for anyone who
6 wants to look at that situation without dwelling on this, then that look
7 is incomplete. There is no town or place or area in Bosnia and
8 Herzegovina and most probably in Yugoslavia, just like the area of
9 Prijedor and Kozara, where the most recent past from World War II is so
10 horrible. According to some data, I cannot really talk about that, but
11 the numbers stayed with me. 19.472 children from that area were either
12 killed or expelled. I'm talking about children now. To the -- compared
13 to 20- to 30.000 adults. So this was during World War II. There is no
14 house in that area, in the area where I was born all of this that we are
15 talking about makes no sense because there were no casualties. In this
16 area there is no Serbian home that does not have at least one horrible
17 story to tell. And so this then arises in this semi-literate villager.
18 It would be the same thing as if I, for example, was afraid of having
19 AIDS or some sort of horrible disease because they were in a war before
20 that and before that and so on.
21 And just one more thing. I don't like to bring out examples all
22 the time, but I think it's important briefly, and I'm not going to
23 mention examples anymore, if you permit me.
24 Q. Briefly.
25 A. The moment when I took the dispatch there and read it, I wasn't
1 so crazy and unaware of the situation and many times when it was
2 dangerous, but all I had in my head was one guiding thought. I mean, it
3 wasn't a thought so much as an emotion and emotions never lead to
4 happiness in such a situation and that is the following. A few days
5 before the start of the war I went out for a walk with my son, who at the
6 time was 5 or 6 years old and I met an old fighter from World War II, a
7 Partizan, Mladjo Stanic who didn't know me, but I knew him because
8 there's only one Mladjo, and there are many such as I, myself. I didn't
9 ask him anything and he was speaking and he was already a bit off his
10 rocker, mentally. So I didn't ask him anything but he was going and
11 speaking, "These people in the municipality are fools" - and he meant the
12 multi-party assembly - "I have been telling them why are you fighting?
13 You will cause a war and they don't want to listen to me and because of
14 these" - and he showed -- pointed to my child - "in 1941 so-and-so called
15 me or let me know," he mentioned the names in Kozara, "they took away the
16 children towards the Krecane, the local Ustashas caught them. I was
17 running behind them with my fighters to catch up with them, but they had
18 already killed the children. One male child they had impaled on a small
19 pine and it was plucking at the blades of grass and I am still all shaken
20 up about it."
21 It's a horrible story and I cannot forget it to this very day and
22 it's much worse for those whose forefathers, their grandfathers, were a
23 part of that. Perhaps some of them can restrain themselves and some of
24 them cannot. Because all of this -- this is a very uncommon region and
25 everything that can be critically looked at from the side has to be
1 looked at in the light of what applies to them is one thing and that does
2 not apply to everybody else, it's just not the same situation. This is
3 how I see things.
4 Q. Okay. I understand what you're saying there.
5 But because of those -- those kinds of strong feelings, wasn't
6 it -- not only was it in Prijedor hard for your former coworker
7 Mr. Sahuric, it was also difficult for you, wasn't it, as a Serb to try
8 and help a non-Serb because that was just as dangerous in a way. Those
9 Serbs who had hard feelings about the Muslims and made life hard for them
10 in Prijedor would make life hard for you if they found out you were
11 helping a non-Serb; right?
12 A. Yes, yes. However, a person always builds a defence mechanism of
13 sorts. I believe in God and I believe that if I do good that I will fare
14 well. And I also know that a good person cannot get in harm's way, I
15 don't know why. But most of the time it turns out to be true.
16 Q. All right. Let me now go and talk about April 9th. This is the
17 meeting that you told us about that you had the notes from. Do you
18 remember that? We looked at your handwritten notes --
19 A. Yes, yes, what I said or the day before.
20 Q. I had some questions based on what you said on Monday. I wasn't
21 clear about a few things. At page 24.755 you mentioned that:
22 [As read] "Somebody brought a prototype of the badge to show what
23 it would look like."
24 I think this was the three-coloured flag, the wavy flag that you
25 mentioned. Do you remember who that was who brought that insignia and
1 showed it at the meeting?
2 A. I didn't say "someone." Perhaps you didn't hear it. It was
3 Mr. Zupljanin who brought it along. That's the feeling I have. Yes,
4 that was him. He said that that was the symbol that was proposed for
5 this police force of ours.
6 Q. Okay. Thank you. I wasn't clear on what it was. And then you
8 [As read] "I think that the chief didn't even take the badge for
9 himself. He gave it to Zijad Basic and said, 'Your wife is a Serb. Why
10 don't you take the badge?'"
11 Which chief were you talking about there, Talundzic or Zupljanin?
12 A. No, no, Zupljanin, I think it was him, yes. I do allow for the
13 possibility that I am mistaken, but that's the way I remember things.
14 After the meeting Zijad was showing us the badge and he was pleased. He
15 wasn't angry about it.
16 Q. In your note, I think one of the last notes you had a remark that
17 you said referred to your own comments and you said you spoke about the
18 concrete agreement or the specific agreement for us to be united. What
19 specific, concrete agreement were you referring to when you said that? I
20 didn't understand.
21 A. If I understood you now, it was there at the meeting that we were
22 supposed to come to an agreement, not that we were supposed to draw up an
23 official agreement. Rather, that we were supposed to come to an
24 agreement through our discussions, to be united, to have a single voice,
25 to have the Prijedor station as part of the centre. Why would we be an
1 island within a region? It was in that context that I mentioned it. I
2 don't recall these words specifically.
3 Q. Was that in relation to what I think you had reported that
4 Mr. Zupljanin said "you all," meaning you police in Prijedor needed to
5 resolve it among yourselves about whether or not you were going to go
6 with Banja Luka or go with Sarajevo. Was it in connection with that?
7 A. It's a compound question or perhaps a bit complex. I'm afraid I
8 didn't understand it. The story boiled down to the chief saying that we
9 were supposed to arrange our relations within the centre. He didn't say
10 you do it. He said, "We will set about doing it. We have the badges
11 proposed here. All the other municipalities have agreed to it. We hope
12 you will as well." That's the gist of it and then there was later on the
13 decision that Prijedor and Kotor Varos would be exempted. It was within
14 that context that the conversation took place.
15 Q. Okay. All right. Now, you explained a little bit about the
16 notes that you took and you said that you acquired a habit over the time
17 of making "... such cryptic notes that would be clear only to me and
18 nobody else. For that reason it makes no sense to seek something and to
19 read into this document. I'm the only one who can make use of that
21 I understand that way of doing things. I've done that myself.
22 But let me ask you: Have you ever had the experience of going back after
23 a long period of time and looking at some of your cryptic notes and not
24 being able yourself to remember what the cryptic parts meant? Does that
25 ever happen to you?
1 A. Yes, but in some other notes, not this set. Perhaps one in a
2 hundred, very rarely, and it doesn't apply to these notes.
3 Q. Okay. That was my next question.
4 A. When I was younger it never happened, but now it does more
6 Q. Welcome to the golden years. You said that -- then you were
7 asked after this meeting if there were any changes that occurred before
8 the end of April, and specifically about whether the Serb insignia or
9 these new tri-coloured flag insignia were used. And you said:
10 [As read] "No, they were not attached. As far as I know we
11 received a dispatch from the centre saying that Prijedor and
12 Kotor Varos" --
13 A. Surely not before the take-over. Afterwards, yes, but I don't
14 know when.
15 Q. Let me show you Exhibit 2D18. This is tab 60 in the Prosecution
16 binder. I can hand you a hard copy. Sorry, the record said tab 6-0 but
17 I meant 16, 1-6.
18 This is a dispatch from CSB Chief Zupljanin. Is this the one you
19 were referring to? It's dated the 16th of April.
20 A. The only thing I remember is that there was a dispatch and that
21 the message was what is written here. I suppose it dates back to the
22 discussions I had with a representative of the Prosecution. I don't
23 remember anything else. But it must be the dispatch. I don't think
24 there's any other. This does not refer to Prijedor and comes from this
25 time-period. That I remember.
1 Q. Okay. And you'll see in the body of the text, I think it's the
2 fourth paragraph referring to the insignia, it said that:
3 "The obligations do not apply to the Prijedor and Kotor Varos
4 SJB. They can continue to wear the current insignia until the political
5 situation in these municipalities is solved."
6 Do you see that?
7 A. Yes, I do.
8 Q. And the way the political situation in Prijedor was resolved was
9 two weeks later the Serbs took over; right?
10 A. Well, this is a political question. Please don't put political
11 questions to me. I have no knowledge of that. It would be very
12 irresponsible of me to say either way. I don't know.
13 Q. Well --
14 A. What did the take-over of power bring? Was it good or bad
15 things? Time will show. I don't know. Things were different; that much
16 is true.
17 Q. Okay. But --
18 A. As for anything else, I think people wiser than me should be the
19 ones to judge that.
20 Q. But really, Mr. Jankovic, between the 16th and the 30th of April,
21 there wasn't like any free election in Prijedor about whether or not our
22 police should wear this new insignia; right? The thing that happened was
23 that there was a take-over by the Serbs on the 30th. That's how the
24 situation was resolved and the police started wearing the tri-coloured
25 insignia; right?
1 A. I don't quite understand. Is this a question you're putting to
2 me? To me it is a political statement you're putting to me rather than a
3 question. Please ask me a question and I'll try and answer it.
4 Q. I'll ask you another question that's more in your field. At the
5 top we see a number of names written and at the very top the letter R.
6 Can you tell me what that refers to? Does that have to do with
7 distribution of this message?
8 A. Yes, precisely so. It was written by the secretary. The letter
9 R is short for "raspis," which stands for distribution. You would copy
10 this and distribute among a number of recipients. And then I can read
11 out the names for you, if this means anything.
12 Q. Let me ask you a couple of questions first. The Serbian word you
13 use, "raspis," I think has been translated into English before as
14 "circular". I don't know if I can inquire of the interpreters if that's
16 A. Well, by function it is similar, very similar. Let's say we have
17 this one document and I have to send it to five recipients, so I make
18 five copies and distribute the document to them. So in a way, yes, you
19 could say that it was a circular.
20 THE INTERPRETER: Interpreter's note: Not necessarily the
21 immediate translation of the word.
22 MR. HANNIS: Okay. Thank you, interpreters.
23 Q. And thank you, Witness. In this case, "R" refers to what? To
24 whom else was this message sent? Did this thing go to Sanski Most and
25 Novi and ... ?
1 A. Well, no. When such a handwritten note is made by the secretary,
2 it is only for our purposes. I think it was the secretary, Mira, who
3 made this note and I don't know who wrote the word "raspis." It may have
4 been Hasan.
5 Q. I thought maybe it was the secretary, Mira, but I see M. Topic is
6 listed as one of the persons on here --
7 A. This is her handwriting, whereas this other is not.
8 Q. Where you're pointing to is the top middle where it has the
9 number 11-12/363 and the date of 16 --
10 A. It is Mira's handwriting, yes, yes, for sure.
11 Q. Okay. On the right --
12 A. Whereas this other definitely is not.
13 Q. Okay. And on the right that Jankovic, that first one, is that
15 A. Yes.
16 Q. Okay. And you're the one that's M. Jankovic?
17 A. Milos, M.
18 Q. Kadiric was the commander?
19 A. Yes, Fikret, the commander.
20 Q. [Previous translation continues] ... who was Mihic?
21 A. Mihic was the head of the crime police, those who were in
22 civilian clothes.
23 Q. And the other two names under you, who were they? Temcuk,
25 A. This tells us something else. The first row above the line lists
1 the individuals who are more important, whereas those below the line are
2 not as important. Jankovic, that's me, Rada is the person from the
3 accountancy service, the one who was in charge of the payroll, works for
4 the police but is not an authorised official. That was Rada Temcuk,
5 finances Ranka Sormaz, she was charged with identity cards, passports,
6 et cetera. So she was unimportant, just as I was. And OM, 3 copies,
7 that's for the three branches or substations, namely Ljubija, Kozarac,
8 and Omarska.
9 Q. Okay. Let me show you a related document to that, it's P651 at
10 tab 17 of the Prosecution's binder and with the usher's help, I'll hand
11 you a hard copy and trade you for the one you've got right now.
12 This one is also dated the 16th of April and it appears to come
13 from Chief Hasan Talundzic and it appears that he's simply forwarding
14 that one that we were just looking at. So is this one that was forwarded
15 on from Prijedor to Sanski Most, Novi, and Dubica?
16 A. No. This is a follow-up on the story from the previous document,
17 where I said distribution or circular, where a number of copies had to be
18 made -- well, this is one of those copies. It's just that on the others
19 that were sent you wouldn't have Temcuk as the addressee but others. As
20 I said, we were the public security station and Hasan Talundzic was in
21 charge of our station only. The Sanski Most station was an independent
22 one. Perhaps they received this dispatch from the centre. I am not in a
23 position to know that.
24 Q. So who did this go to from the chief? Is this just an internal
25 memo in Prijedor SJB or who does it get circulated to?
1 A. Well, yes, of course. Within the CSB and the list of addressees
2 was contained in the previous document, you were able to see that.
3 Q. So here where it says "circular letter" it refers simply to those
4 people we saw named on the last document and nobody else in Prijedor SJB?
5 A. Yes, yes. If I can add something, we had the line in the
6 previous document where it said "3x OM," there had never been three
7 police substations. Ljubija was always a station and apparently the
8 author of the document was unaware of this. It was most probably Hasan,
9 since he had been there for a very short time and he was a superior of an
10 organisation he was not familiar with. Those who were more knowledgeable
11 and experienced would not have written something like that. Of course
12 physically it was Mira writing it up, but he chose the numbers -- I mean
13 the names that were amongst the addressees in the previous document.
14 Q. Okay. Okay. Judge Harhoff, when you were talking about the
15 April 9th meeting, at page 24768, asked you about Mr. Zupljanin exempting
16 Prijedor and Kotor Varos from having to wear the new insignia for a
17 while. And then he asked you what else Mr. Zupljanin actually did to
18 help. You said that Zupljanin was speaking in a reconciliatory tone and
19 trying, in your view, to calm the situation down. Don't you think that
20 given the circumstances of that meeting at that time, April 9th, 1992,
21 and the number of Muslims in the police department, coming to that
22 meeting with that new insignia might make some of the non-Serbs, the
23 Muslims, in the Prijedor SJB feel uneasy about the situation?
24 A. As for this issue, I wouldn't be able to tell you, even as I
25 think about it on my own without your question. I don't know how
1 millions of people feel in their own state where they wear their own
2 insignia and where is that boundary between this feeling of bearing one's
3 own insignia or somebody else's? Since I have no personal experience, it
4 is very difficult to proffer any opinion. I recall His Honour's
5 question. I did think about it later. What was the merit of
6 Mr. Zupljanin? Well, I could sum it up in the following. What is the
7 merit of head of fire brigade once that fire brigade was able to save
8 only three houses from burning down? That's how I view the situation.
9 Q. Okay. I understand what you're saying and I'm, you know, I'm
10 glad I didn't have to live through what you lived through or be in that
11 place at that time. I think it was --
12 A. Well, you were lucky in that.
13 Q. Yes. But you said you thought about what Mr. Judge Harhoff had
14 asked you. Let me ask the question this way and see if you might have an
15 answer for it. If it had been the other way around. What if it had been
16 Hebib or somebody coming from Sarajevo and telling you all in the
17 Prijedor station that from now on you were going to wear this new
18 insignia with the three lilies or the crescent moon? How do you think
19 the Serbs in Prijedor SJB would have felt about that? Wouldn't they have
20 felt uneasy?
21 A. Well, that was not an assumption. It was a reality in some other
22 areas because in our region some stayed behind, others left, and that was
23 true for other areas. All of these were lived-through realities. This
24 happened in Prijedor. The situation that happened in Zenica was the
25 inverse one as well as in Bihac. Who was right? That I don't know.
1 Q. No, my question, though, wasn't about who was right or wrong. It
2 was about how a particular group felt.
3 A. How they felt?
4 Q. Yeah, I was asking you originally how do you think the Muslim
5 police in Prijedor felt when Mr. Zupljanin came and was proposing that
6 they wear this new insignia. And you said you couldn't know that, you
7 didn't know how they felt. So I gave you sort of the reverse question
8 and said how would you and the other Serbs in the Prijedor SJB feel if it
9 had been --
10 A. Yes, I understand what you're saying.
11 Q. [Previous translation continues]... You wouldn't have felt
12 uncomfortable if somebody tried to get you on April 9th to start wearing
13 an insignia with the Bosnian emblem?
14 A. What is at stake is the feelings of every single individual. You
15 remember when I spoke of that meeting where that dispatch was received?
16 I told you that there was several hundred people present there and that
17 only few of them said that they were opposed to the idea. Everybody else
18 was in favour of us joining Sarajevo. Why? Well, the motivation was the
19 salary. Well, and then if you come up with this idea of the insignia
20 coupled with secure money, some people will fall for it. There is no
21 point in me giving you a universal answer.
22 Q. We'll talk about the 29th meeting and I wasn't trying to tie the
23 insignia to salary because I understand salary is a different motivation
24 that may motivate everybody whatever their ethnicity is. Let me continue
25 on with one more question about the 9th of April and then we'll go to a
1 different topic. One of the last things you said about the meeting was
2 that you were concerned that "... they had the opportunity to decide that
3 fate of ours, and in that context I was bit concerned by the fact that
4 these two took up such a hard line where they wouldn't desist an inch."
5 I just want to be clear. I understood there you were talking
6 about Hasan Talundzic and Fikret Kadiric?
7 A. Fikret.
8 Q. What was his last name, Kadiric?
9 A. Kadiric, right.
10 Q. That's who you meant who were taking a hard line and not --
11 A. Yes, yes.
12 Q. And then you were asked about something you said earlier where
13 you said your higher-ups did not want a war and you were asked who you
14 meant by your higher-ups. And you said:
15 "My minister, my president of the country, or my prime minister."
16 Can you tell me who you meant in that context. Who was your
17 minister? Who was your president of the country? Who was your prime
18 minister when you said that?
19 A. Yes, that's what I said. But I really have to explain that.
20 Why? For a long time, relatively long time until that time, I was in the
21 police so I had learned to be thinking in a police way. So for me it was
22 only Mr. Zupljanin there. As for everything else, I wasn't interested in
23 the name of the minister or the name of the president of the state, but I
24 know that their will was being carried out through him. This is what I
25 believe. So you cannot have the minister, for example, asking for one
1 thing and then the chief of the centre to come and to be saying something
2 else. No name was put forward.
3 Q. No, no, but this was your answer and you said --
4 A. Yes.
5 Q. Who were you referring to by name? Who was your president of
6 your country? Who was your minister --
7 A. Am I not clear? Am I not clear?
8 Q. No --
9 A. In my police system of thought there are no names, there is just
10 him and then above him those up there. There are no names. Those up
11 there. And as they say that what he says is the will of those --
12 Q. [Previous translation continues]... but the reason I -- but the
13 reason I --
14 A. What reason?
15 Q. The reason I asked the question and asked for names as to who
16 you're referring to is that on the 6th of April Bosnia had been
17 internationally recognised by European Union and United States. So in
18 essence in that area there were arguably two presidents of the country
19 and two ministers because there was Minister Mico Stanisic of the Serb
20 Republic of Bosnia and there was Minister Delimustafic of the other MUP.
21 And there was President Karadzic of the Serb Republic of Bosnia and there
22 was President Delimustafic -- Izetbegovic. So who were you referring to
23 when you said "my minister" and "my president"? By name which ones were
24 you talking about in that answer on April 9th?
25 A. Well, let me tell you, this is a political question and the proof
1 that I don't know politics and that I'm not interested in that is that
2 for three years I don't have a television and I don't even have a mobile
3 telephone. In my service I'm just listening to my superior, to my chief
4 of the centre -- not the centre, actually, the chief of the station of
5 course who's my immediate superior. And then if it should come in -- I
6 mean, if the chief of the centre would come as he would from time to time
7 and says something, I do not doubt that what he says is in accordance
8 with the official state policy and I don't think that it is. I think
9 whatever he says would be in line with that. I don't even know the dates
10 when and who was there. So what I'm saying is actually true. You can
11 check that right now I don't have a TV in my house, meaning that I don't
12 listen to any news. Perhaps I'm not like any other regular man, but
13 that's how it is.
14 Q. I believe you that you don't have a TV in your house. I won't
15 pursue that any further.
16 Let me show you another exhibit, this is tab 34. It's
17 65 ter number 20063. With the usher's assistance I'll hand you a hard
18 copy. I think you mentioned before after the take-over on the 30th of
19 April that people were required to sign a solemn declaration in the
20 Prijedor police station. Is that right? Now that you were working in
21 this new police station of the Serbian Republic of Bosnia, later called
22 the Republika Srpska, everybody was required to do a new solemn
23 declaration, right, in Prijedor?
24 A. Yes, yes.
25 Q. Did you sign one yourself?
1 A. What? You mean solemn declaration like this? Well, I don't
2 recall that I did, but I think that I had to have signed it because
3 somewhere it must state that I did. I did not sign it that morning when
4 those who came to work that morning signed it. I wasn't there. Later I
5 had to have signed it. I think that I did.
6 Q. Do you know the person named on this document, Zivko Andzic, did
7 he work in Prijedor?
8 A. I don't know, I don't know. There were many reserve policemen
9 who stayed after that. I don't know this man.
10 Q. Okay. And I take it you don't -- do you remember, did you read
11 the declaration that you signed or did you just sign it?
12 A. Yes, yes, perhaps I read it out of curiosity -- well, as but --
13 if it were important to me or not, I don't know. When everyone signed
14 it, I signed it too. Perhaps I read it. I don't remember if I did or
15 not. Perhaps I was rushing off somewhere, so I just signed and didn't
16 read it. I don't remember. Probably somebody was making lists to make
17 sure that each of the employees did sign it and I don't believe that my
18 name next to that was blank.
19 Q. Okay. And do you remember signing a similar declaration when you
20 first joined the police back in 1980?
21 A. Yes, it was almost identical to this.
22 Q. Okay. But not exactly identical; right?
23 A. Well, first of all, it wasn't in the Cyrillic script, but the
24 sense of it was -- it wasn't the same gazette, it was a different
25 gazette, and so on and so forth. But the sense of it you could say was
1 the same.
2 Q. Do you remember how many people in Prijedor declined to sign the
3 new solemn declaration? Was it very many?
4 A. As I said -- I mean, I said that yesterday more or less. A
5 smaller number stayed. Perhaps those who were working in the offices,
6 four or five. As for the police working on the ground, I don't know. I
7 don't know how many of them stayed. I didn't get that information
8 through my work and there's no need for me to go around asking who did.
9 I don't have the right or the need to do that.
10 Q. Okay. Do you know of any Serbs in Prijedor SJB who didn't sign
11 the declaration and stopped working after 30th of April, 1992?
12 A. There were those who didn't come to work and then after a day or
13 two they did come. I guess they were afraid that there would be shooting
14 so they ran away, but then when they saw that there would be no shooting
15 they came back, they came back for the salary.
16 Q. All right. Let me show you another document. This is at tab 57.
17 I'll give you a hard copy of that one --
18 JUDGE HARHOFF: Mr. Hannis.
19 MR. HANNIS: Yes, Your Honour.
20 JUDGE HARHOFF: Before we leave this document we could perhaps
21 try and clarify with Mr. Jankovic just how he understood the letter-head
22 of this solemn declaration.
23 Because, Mr. Jankovic, when you said that the gist of the
24 declaration that we have in front of us was the same as the one that you
25 had signed when you first entered the MUP forces back in the 1980s, the
1 difference would seem to me to be the very first word of the letter-head
2 of this declaration that we have in front of us. And so my question to
3 you, Mr. Jankovic, is: Are you able to tell us whether any of those who
4 refused to sign the solemn declaration, regardless of their ethnicity,
5 refused because of the allegiance that you were now supposed to pledge
6 towards the Serbian Republic of BiH? Was that the reason why some
7 members of the MUP refused to sign, do you recall?
8 THE WITNESS: [Interpretation] As far as I remember, that morning
9 when they were supposed to sign when they came to work, there was no
10 form. There was just a kind of list. The form appeared later. I think
11 that that morning the form wasn't the way it is now and these people
12 signed some paper, a list of names. As for this, who made it,
13 distributed it, signed it, I don't remember that, and the date is the 5th
14 of May, so five days later. Somebody made that later, but it was being
15 signed already in the morning, that first morning.
16 JUDGE HARHOFF: Let me put my question to you in a different way
17 then. Were you aware when you signed this declaration on that morning
18 that you were now pledging allegiance to the RS? Was that clear to you?
19 THE WITNESS: [Interpretation] Well, let me repeat this right
20 away. I said that that morning when they were signing that list, I
21 didn't come there because I was away on some other tasks and I came to
22 the station later. And I probably signed it then, maybe not the list.
23 As for this, the question whether I was aware -- well, you know what it's
24 like when the mass sets off. If everybody's going to die, I'm going to
25 do that as well. There's no question, if everybody signed, I'm going to
1 sign it too. But then as a result of that, there are other questions
2 that follow. If I don't sign, what am I going to do, how am I going to
3 manage? What am I going to do? I have two children, an apartment, I'm
4 living in a certain environment. Roughly speaking, there are two groups
5 in the population, there's the Serb side, the Muslim side. Which side am
6 I going to join? I mean, it's not a wrong question. I didn't declare
7 myself as a Serb or a Muslim myself, I mean the nature would pull me one
8 way, but as for the political and legal aspects of that question -- well,
9 I never thought about that. I don't know about the meaning of that now.
10 I mean, I was as sincere as I can be.
11 JUDGE HARHOFF: But, Mr. Jankovic, it must have occurred to you
12 by the time you signed this declaration that this would have an impact
13 because you were now choosing side, weren't you? And so since you
14 probably made those considerations yourself, I would imagine that you
15 also considered the reasons why some of the colleagues of yours did not
16 sign that declaration, meaning that they too had chosen a side but that
17 they had chosen the other side by refusing to sign. Didn't this occur to
19 THE WITNESS: [Interpretation] First of all, the events were fast
20 and furious then, so I didn't even have time to think. Perhaps now that
21 we're free and we can think about and ponder things. At the time what my
22 thing was was to organise the communications and -- well, it was I can't
23 say general chaos, but it was. At that first initial moment I didn't
24 even think of a yes or a no, but there was no paper like this either. I
25 said that I do not recall this paper. I have a feeling I'm seeing it for
1 the first time, but I believe I probably am not seeing it for the first
2 time, that it exists, that I did sign it. When I look at the date I
3 think I could not have gone without signing it then. So I simply went
4 with the majority, and for me that was the only possible thing to do at
5 the time and sufficient. As for how I would fare in the end, would I
6 die? Well, I would fare just like the rest.
7 JUDGE HARHOFF: I'm not sure we can get any further here.
8 Mr. Hannis, back to you.
9 MR. HANNIS: Thank you, Your Honour.
10 Q. Let me show you another exhibit now. This is P790. It's tab 57.
11 And if I can trade this one for that one. This is dated the 29th of May,
12 1992, and it's a list of Prijedor police station employees who signed the
13 solemn declaration and of those who did not. I think on the back you'll
14 see it has the name of Dusan Jankovic as the station commander. Can you
15 have a look at the back page. Can you have a look at the back page, and
16 you see Dusan Jankovic's name as the commander, but it looks like
17 somebody else has signed for him on the bottom right at the back page.
18 Do you find it. Is that Kecan?
19 A. Looks like that. I cannot say but it does look like Kecan as far
20 as I'm concerned.
21 Q. And who was Kecan?
22 A. Assistant commander.
23 Q. Thank you. You see, we've got I think 72 names of people who
24 signed it and 41 names who did not. Based on your own personal knowledge
25 do you have any reason to disagree with this list as far as those who
1 signed and apparently stayed on working there and those who didn't sign
2 and therefore didn't continue to work in Prijedor?
3 A. I saw this list once when the gentleman from the OTP spoke with
4 me earlier and I'm seeing it now, and since this is a list of workers of
5 the SN -- the police station of Prijedor, this is above my organisational
6 unit, I know the name -- the people by name. I don't know anything else,
7 what -- I mean anything else I would say would be superfluous. What
8 would I have to say about somebody else's organisational unit, the one
9 with this commander? At that time I had five or six workers. I don't
10 know if I had to write about anybody then. I didn't see this list
11 before, never really thought about it. I don't have much thoughts about
12 it now either.
13 Q. No, but I guess the point is you must have known several of these
14 people because they worked as police in Prijedor at the time you were
15 working there and you'd been in the police since 1980. Didn't you know
16 most of these people by name?
17 A. No, not most of them. But, for example, I know Vahid Rizvanovic,
18 Mevlida Boric, I recall her a little bit. Ermin Alagic. There were
19 stations that were outside of Prijedor. I said -- I mentioned these two,
20 but then also in Prijedor the police has their post on the street so I
21 know that it's a policeman. When I encounter him I greet him, but I will
22 say which ones I know. Are you saying those who didn't sign? Who are
23 you thinking of exactly?
24 Q. Well, of the names you know, is there anybody who is not
25 correctly listed if you understand what I mean. Do you see anybody you
1 know who is listed as having signed who did not continue to work or do
2 you see anybody who is listed as having not signed who did continue to
3 work? Do you understand my question?
4 A. Yes, well, I don't know. Why don't I know? I don't know because
5 I don't know about this action by the commander who signed and who did
6 not. As I say, I'm seeing this list for the first time. I saw it from
7 your associate.
8 Q. But what I'm saying is of the people you know do you see somebody
9 on the list who did not sign who was still working after this date, 29
10 May, of those 41? Any of those 41 who did not sign who you personally
11 know, did you see any of them still working for the police after 29 May
13 A. The actual act of signing was so significant for me that I don't
14 know whether I signed it or not.
15 THE INTERPRETER: Could the witness please be asked to repeat the
16 rest of his sentence.
17 MR. HANNIS:
18 Q. The interpreters are asking if you could repeat the rest of your
19 sentence. They didn't catch it. Could you repeat your answer, please.
20 A. I will be briefer and more slow, meaning the act of signing this,
21 as far as I'm concerned, was so significant that I don't even know if I
22 signed it or not. I think that I did but I'm not sure. Perhaps I did
23 not. And because of that fact how can I know in the police station
24 whether such and such a person signed it or not?
25 Q. No, no, that's not my question. There's a list of people who
1 Kecan or Dusan Jankovic are indicating did not sign. The practical
2 effect at that time, according to directions from Mr. Zupljanin in
3 Banja Luka was that those who didn't sign couldn't continue to work in
4 the police. Now, do you know any names on the list of 41 on that
5 document who did not sign? Do you recognise any of those names among the
6 41; and if so, tell me which ones?
7 A. Well, I have to be as specific as possible again. The commander
8 who was here, Jankovic Dusan, he made that list and then he went to his
9 superior and handed it over. For example, I have nothing to do with
10 that. For example, I meet Jankovic, Dusan, I know him, I don't ask him
11 Dusan, did you sign it or not. You don't ask people things like that.
12 Q. You don't need to talk to him or know him to answer my question.
13 Let's take it one step at a time. First of all, the names on the right,
14 1 through 41, do you know any of those people?
15 A. Yes, the right side.
16 Q. [Previous translation continues]... and if so, tell me the number
17 and name of the ones you do know or did know in 1992?
18 A. Well, I remember the name. I don't know where she was working,
19 Mevlida Boric; Ermin Alagic, I don't know; Edin Mrkalj, policeman, I
20 forgot his face, I don't know anything more; Senad Mujkanovic, I don't
21 even remember the name; Maid Bahonjic, never heard of him; Mirsad Alic, I
22 don't know about him --
23 Q. And give me the number along with the name. It will make it
24 easier for all of us.
25 JUDGE HALL: Mr. Hannis, it appears to me this is going to take a
1 little while so perhaps we should pick this up tomorrow morning.
2 MR. HANNIS: I think that's an excellent idea, Your Honour.
3 Thank you.
4 JUDGE HALL: And perhaps he can keep the document overnight.
5 MR. HANNIS: I am happy to have him do that.
6 JUDGE HALL: And if I may assist, Mr. Jankovic, as I understand
7 Mr. Hannis's question, it is this: Assuming that the document is
8 accurate in terms of those on the right as having not signed, so in other
9 words you don't have to apply your mind as to how the names got there,
10 how this was prepared, but beginning with the assumption that that's an
11 accurate list of those who did not sign, there apply your mind to
12 Mr. Hannis's question and as we said you can keep the list overnight and
13 then he will resume tomorrow morning.
14 So we take the adjournment and continue at 9.00 tomorrow morning.
15 --- Whereupon the hearing adjourned at 1.43 p.m.,
16 to be reconvened on Thursday, the 13th day of
17 October, 2011, at 9.00 a.m.