1 Thursday, 13 October 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.06 a.m.
5 THE REGISTRAR: Good morning, Your Honours. Good morning,
6 everyone in and around the courtroom. 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 take the appearances, please.
11 MR. HANNIS: Good morning, Your Honours. For the Prosecution,
12 Tom Hannis, Gerard Dobbyn, and Sebastiaan van Hooydonk.
13 MR. ZECEVIC: Good morning, Your Honours. Slobodan Zecevic,
14 Slobodan Cvijetic, and Ms. Deirdre Montgomery appearing for Stanisic
15 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.
19 We are informed that there is one matter the Defence has before
20 we call the witness back to the stand.
21 MR. KRGOVIC: [Interpretation] Yes, Your Honour, just a brief
22 procedural matter. Mr. Zupljanin's Defence submitted on the 30th of
23 September a motion asking to change the manner of testimony of
24 Witness SZ-012 and to have him testify by way of 92 bis. The Prosecution
25 responded to the motion by the Defence, seeking that the whole transcript
1 and exhibits be admitted, specifically two of them that were referred to,
2 65 ter numbers 20279 and 20280. The Defence would like to inform the
3 Trial Chamber that they have no objection to the admission of these two
4 exhibits. So I think that we can resolve this matter of having this
5 witness testify pursuant to 92 bis.
6 JUDGE HALL: So noted. Thank you, Mr. Krgovic.
7 So could the usher please escort the witness back to the stand.
8 [The witness takes the stand]
9 JUDGE HALL: Mr. Jankovic, good morning to you, sir. Before I
10 invite Mr. Hannis to resume his cross-examination, I remind you, you're
11 still on your oath.
12 Yes, Mr. Hannis.
13 MR. HANNIS: Thank you, Your Honour.
14 WITNESS: MILOS JANKOVIC [Resumed]
15 [Witness answered through interpreter]
16 Cross-examination by Mr. Hannis: [Continued]
17 Q. Good morning, Witness. When we left off yesterday afternoon --
18 A. Good morning.
19 Q. -- when we left off yesterday afternoon I think you and I were
20 both a little tired but we were trying to go through that list. It's
21 Exhibit P790 at tab 57 in the Prosecution binder. Did you have a chance
22 to look at that overnight and if so were you able to tell us now whether
23 any of the people listed among the 41 who did not sign the new solemn
24 declaration, did any of them continue to work in Prijedor SJB?
25 A. Yes, I did read it. I did read the list.
1 Q. And, first of all, let me ask it this way. How many of those 41
2 names of those who did not sign did you know?
3 A. Well, I didn't count, but if you like I can go over all of them
4 and tell you.
5 Q. It's not so important how many you know. I guess the question I
6 want to know is -- because --
7 A. 40 per cent.
8 Q. Okay. What I'm trying to understand is: It's my understanding
9 that none of them continued to work, they all left. And if I'm wrong
10 about that, tell me who stayed.
11 A. This is the date, the 29th of May, that's the day before the
12 attack on Prijedor. That's when the big mess happened so I don't know
13 where some of the Serbs were either. Perhaps I did meet some of them,
14 but I don't remember who I met and where.
15 Q. But my question is: After the 29th of May or the 30th of May,
16 are any of those 41 people still working in June and July, August of
17 1992? They were all gone, weren't they?
18 A. I don't know. I don't know. The station is physically -- is
19 actually quite far away from me, work-wise. Not physically, but as far
20 as work is concerned, it's quite remote. I don't -- I didn't co-operate
21 with those people so I really don't know.
22 Q. Okay. Let's move on to another document then, if we could look
23 at P377. This is at tab 52. And I can give you a hard copy of this one.
24 I'll exchange it for that other one, if I may. Thank you.
25 Now, Mr. Jankovic, this is what appears to be a telegram dated
1 the 28th of May, 1992, from Chief Zupljanin to all SJB chiefs. And he's
2 saying, basically informing, that all employees who did not sign the
3 solemn declaration are dismissed as of the 15th of April, 1992. Did you
4 know about this? Did you see this? What can you tell us?
5 A. I don't recall it from that time. I perhaps did see it when
6 somebody from the OTP showed it to me or from the Defence. I don't
7 remember. But I do recall seeing it recently. I don't recall it from
8 that time.
9 Q. Let me ask you a couple questions just about the handwriting on
10 this document. At the top where we see number 11-12/458 and the date, I
11 think that's probably the handwriting of Mira Topic; right?
12 A. Yes.
13 Q. Okay. At the bottom there's some handwriting which my English
14 translation records as saying:
15 "The Chief decided that employment is terminated as of 1 April
17 And a signature I guess. Do you know whose writing that is?
18 A. It was a long time ago but it's familiar. I think and I'm
19 certain of it 80 per cent that this is Milutin Cadjo.
20 Q. And who was he? Where did he work? What was his job?
21 A. Until the power take-over, he was the reserve -- not reserve, I'm
22 sorry, I made a mistake. He was a retired policeman. After the
23 take-over he was the komandir of the police that was located in our
24 building, it was Prijedor 2 and so on and so forth, Omarska, Ljubija, and
25 so on. He was in the headquarters.
1 Q. Okay.
2 A. Just some additional explanation. I cannot tell you the official
3 date that he became the komandir because he was putting himself forward
4 right at the beginning and then later he did receive the decision. I
5 don't know exactly the date that he assumed his duties, but he was at
6 that post.
7 Q. Assuming that's correct, can you tell us if he's the one who
8 wrote that then who is the chief that he's referring to? Would that be
10 A. It's a difficult question who he was referring to. I mean, I can
11 just make an assumption that that would be that.
12 Q. No, that's fine. Okay. That's all I had to ask you about that
13 one. Now, you told us about the 9th of April meeting, and then we know
14 what happened on the 29th and 30th of April. And I think you at some
15 point said between the 9th and 29th during those 20 days you said at page
16 24774 is that there were obviously some processes, something -- things
17 were going on during those three weeks. I wanted to ask you -- yeah, I
18 want to ask you about a couple of things that appear to be going on. And
19 first of all I want to show you document P354 which I need to find the
20 right page number. It's tab 12 and I'll give you a hard copy of this
21 one. As that's coming to you, sir, I'll tell you that this is a document
22 that's dated the 10th of April. And it's a dispatch from Delimustafic,
23 the minister of the BH MUP to all CSBs and all SJBs. And he's referring
24 to what he called the forcible formation of organisational units in the
25 so-called Serbian MUP being in progress and talking about in his view
1 workers being pressured or blackmailed to sign some declarations of
2 loyalty. He goes on to say that this is -- the activities of the Serbian
3 MUP are illegitimate and that workers aren't required to sign those
5 Did you see this? Because based on the number handwritten on the
6 top right, it appears this is a document that was received in Prijedor.
7 I'm sorry, what I've got on the screen is --
8 MR. CVIJETIC: [Interpretation] Different dispatch is on the
10 MR. HANNIS: I'm sorry, I've called the wrong number. I wanted
11 to look first at 1D138. I've got my numbers reversed.
12 Q. I'm sorry, witness. The one you're looking at in your hand is
13 from Delimustafic.
14 JUDGE DELVOIE: Is it tab 12 all right, Mr. Hannis?
15 MR. HANNIS: It's tab 12 in my binder. It's 1D138.
16 JUDGE DELVOIE: Thanks.
17 MR. HANNIS: I don't know if I just crossed my numbers or not.
18 My apologies to the court officers.
19 Q. Yeah, did you see this one or did you know about this back in
20 April 1992?
21 A. No, no. The way it looks, I believe that it did pass through my
22 communications centre, but unnoticed by me because it wasn't important
23 and the operator didn't inform me and neither did the chief.
24 Q. Okay. And the handwriting in the upper right-hand corner, again
25 that appears to be the handwriting of Mira Topic, the secretary for the
2 A. Mira, yes.
3 Q. Thank you. Now I want like to look at the other one I referred
4 to, P354, which is at tab 13 and I'll give you a hard copy of that one.
5 Thank you.
6 And you'll see this one is also dated the 10th of April, but it's
7 from Stojan Zupljanin. But it makes specific reference to the one you
8 were just looking at from Delimustafic, that MUP dispatch 09/4-382. I'll
9 tell you that's the number of the one you just looked at. And
10 Mr. Zupljanin is denying that anybody's being forced and that everybody's
11 free to sign up with no pressure. And the last thing he says is the
12 dispatch, Delimustafic's dispatch, does not have any legal effect in the
13 territory of the Serb Republic of BiH and is being put out of force. And
14 again this has what appears to be Mira Topic's handwriting in the upper
15 right-hand corner. So I take it this was another one that was received
16 in Prijedor?
17 A. Yes, yes, yes.
18 Q. Did you see this one or did you know about this one?
19 A. I didn't see this document either, but in view of that period,
20 April 1992, and what I said that Chief Talundzic did not, as was
21 customary in earlier times, summon a collegium and interpret the
22 instructions from the top, from the centre. This time he didn't call us
23 chiefs, so I didn't know about it because of that. But he did go to his
24 people. I said that a few times, "his people," but he went for
25 consultations where they interpreted that. But there was no collegium.
1 If there was, perhaps it was an inner circle that I was not a part of.
2 Nobody isolated me per se; I just would like to note that, though.
3 Q. Okay. So I understand that Chief Talundzic didn't call any kind
4 of collegium and have a discussion about this document, but did you hear
5 any --
6 A. No, no.
7 Q. But did you hear any informal talk about it, like among the
8 employees in your communications department? Because somebody in your
9 section must have seen it; right?
10 A. The communications personnel, including me, were already so
11 immune to the information that we were transferring and perhaps I think
12 that an employee of mine or I could have taken a dispatch to the chief
13 which said that they should kill me and we still would have done it.
14 There were too many information -- pieces of information passing through
15 for us to be able to pay attention to each one. It's -- sounds
16 incredible but that's how it was.
17 Q. Well, I understand that general practice of communication workers
18 to just be the conduit for transferring information. And I believe you,
19 what you told us before, that generally you would only look at the
20 address and then deliver the mail, basically, without reading contents.
21 Although, in certain exceptional situations sometimes communications
22 workers did read documents; right? They're human beings.
23 A. Yes, yes.
24 Q. Okay. Okay. That's --
25 A. Just one. Most often they would read the things that they were
1 interested in, for example, salary increases or decreases. Nobody read
2 the politics.
3 Q. Okay. Let me then show you Exhibit P1616 at tab 19. This --
4 I'll hand you a hard copy with the assistance of the usher. And I will
5 tell you, this is a document that I doubt that you have seen before
6 because it's the minutes of a crisis -- or minutes of a Municipal Board
7 meeting or Crisis Staff in Prijedor. It's dated the 23rd of April, so
8 this is during that 20-day period we've been talking about. Have you
9 seen that document before?
10 A. Never. If I did see it during the interview with your side or
11 with the Defence, I don't recall that either. Earlier, I definitely did
12 not see it.
13 Q. I want to point out a couple things to you. This is apparently
14 President Miskovic is running the meeting. Mr. Drljaca is one of the
15 attendees at this meeting. And if you would look at number 5 on the
16 decisions that they adopted, number 5 says:
17 "To immediately start working on the take-over, the co-ordination
18 with the JNA notwithstanding."
19 See, I think this is an example of some of the processes that
20 were going on between the 9th and the 29th of April, but I take it from
21 what you've told us before you didn't know anything about that; right?
22 You didn't know anything about the SDS working on preparations for
23 take-over; right?
24 A. That is correct. I didn't know anything. As I said already, I
25 had nothing to do with the SDS. This Simo Drljaca and the date of the
1 23rd of April is something I saw for the first time on the 29th of April.
2 In other words, I didn't know him before then, so he was unable to convey
3 anything to me or any police employees unless it was through private
4 channels but not officially.
5 Q. Okay. That -- fine. I understand that. But with that then I do
6 want to go now and talk a little bit about the 29th of April and the 30th
7 of April. You testified on Tuesday this week you mentioned that you
8 didn't have any previous knowledge about the meeting that occurred on the
9 29th. You'd been out working in the field on that day and then I think
10 you said --
11 A. Correct.
12 Q. You said at page 24777 you came back around 2.00 in the afternoon
13 and found out -- and found out about the meeting?
14 A. Correct.
15 Q. That's the first time you knew there was going to be a meeting
16 that day?
17 A. Yes. When I arrived back from the field, someone called on the
18 phone saying that all people from the communications department ought to
19 attend a meeting. We were notified by phone. It wasn't done in writing.
20 Q. And I think you said the entire active and reserve police force
21 were invited. Were they also all invited on short notice?
22 A. I don't know. I didn't bother to check, although I suppose as
23 much. The communications department alone would not be left out or not
25 Q. You went on to tell us that when the meeting started there was
1 only one item on the agenda, which was whether or not Prijedor should
2 continue to belong to Banja Luka or should it join Sarajevo. Is that
3 right? That was the topic?
4 A. Yes.
5 Q. Was there any written agenda or was this only announced orally
6 once everybody was gathered together?
7 A. The latter. It was done orally only. No one read out anything.
8 The presiding, the chief of station, Hasan Talundzic introduced the
9 meeting and announced the agenda, the topic.
10 Q. And I take it you didn't take any notes of this meeting like you
11 did of the 9th of April meeting, did you?
12 A. Because I arrived among the last people. I had nowhere to sit
13 down. I was standing, as I said in my statement, next to a pillar like
14 this. I leaned against it and I was unable to write.
15 Q. [Microphone not activated]
16 THE INTERPRETER: Microphone, please.
17 JUDGE DELVOIE: Microphone.
18 MR. HANNIS: I'm sorry. Thank you, Your Honour.
19 Q. I understand that during the meeting you got word that one of
20 your communications officers wanted to talk to you because of a problem
21 he was having sending something; correct?
22 A. Yes.
23 Q. And what was the name of that communication officer? It's
24 recorded as Dusko --
25 A. I have said already Sarac, S-a-r-a-c.
1 Q. Thank you. I wanted to confirm the spelling. And you said you
2 went to see him, he showed you a dispatch -- a coded dispatch received
3 from Sarajevo with an address that required him to send it on to
4 Sanski Most and Novi and Dubica. But he was unable to, you said, because
5 Banja Luka communications officer refused to connect him. Can you
6 explain that technology for me. Why did you and Prijedor need Banja Luka
7 to connect you to your three sort of subordinate stations in terms of
8 communications? I didn't understand that Banja Luka had to be involved
9 when you were communicating with Sanski Most, Novi and Dubica. Is it
10 because this was a coded communication? Can you explain, please.
11 A. Yes. If you recall, when the two of us discussed the schematic
12 of yesterday, I will remind you that there were two types of
13 communication between Prijedor and Sanski Most. One was a direct line
14 and then a document could be transmitted with a code. The other type of
15 connection was by way of circulars. If they wanted to use the circular
16 communication, then one had to go through Banja Luka because only they
17 had the equipment; if not, then the work you had to do tripled because
18 you would have to take one code, the next code, and the third code,
19 because every participant had its own, whereas in circular communication
20 there was only one. I hope you understand me now.
21 Q. I think so. And part of this was because it was a coded
22 communication; right?
23 A. Yes.
24 Q. But if Banja Luka -- if Banja Luka's communication officer was
25 refusing to make the connection, you could have done it yourself from
1 Prijedor. It just would have taken longer because you would have had to
2 have three separate communications?
3 A. Yes.
4 Q. Okay. Do you know -- do you know who the communication officer
5 in Banja Luka was who was refusing to connect you for purposes of sending
6 this on? Was that Rakovic, the chief?
7 A. No, he's ignorant of it. Not Rakovic, definitely not. He
8 doesn't do that work. It must have been one of his employees but I don't
9 know who. Dusko Sarac was a lazy person, that's why he refused to patch
10 him through. All the rest is excluded. The one in Banja Luka based on
11 his own previous experience of the month before or so -- well, they knew,
12 although I barely noticed it at the time, that some dispatches from the
13 then-republican SUP in Sarajevo in terms of content were such that they
14 were not supposed to arrive at the stations where the SDS was in power
15 with their own cadre. It was because of that that Banja Luka, although
16 the document says "distribute to all CSBs and CJBs," but there was this
17 written or unwritten rule up there that they circumvented them. I
18 realised that there were some such dispatches addressed to Banja Luka
19 which arrived to us and the signalsman in question must have noticed that
20 and that's what he did. If I may add anything --
21 MR. KRGOVIC: [Interpretation] A correction for the transcript.
22 Page 13, line 19 -- 18 and 19. It says that the dispatches were
23 addressed to Banja Luka but arrived to us, whereas the witness said
24 something else.
25 THE WITNESS: [Interpretation] That is correct.
1 MR. HANNIS:
2 Q. Can you tell us what you said about that.
3 A. I will repeat. A dispatch reads "to all CJBs and CSBs." That
4 means it includes Banja Luka. However, some dispatches - and this one
5 obviously ... - how do I know this one circumvented Banja Luka? Because
6 my signalsman said that this colleague of his there refused to patch him
7 in the circular communication and he said, "Why don't you ask those you
8 work for to patch you through?" He rejected him flatly. That's all I
9 know concerning the dispatch.
10 Q. Okay. So if I understand that last bit correctly, you're saying
11 the communications worker on duty at the time in Banja Luka told your
12 communications worker in Prijedor, "Why don't you contact your people" or
13 ask those you work for to patch you through, meaning he was referring to,
14 what, Muslims?
15 A. Probably. I don't know.
16 Q. Okay. But again, you told us that the reason that you read this
17 particular dispatch, contrary to your usual communications worker
18 practice of not reading the contents, this time you read the contents to
19 try and figure out how you can solve the problem of passing this on to
20 the three addressees, Sanski Most, Dubica, and Novi. But I don't
21 understand because you told me you had another way to send it on without
22 Banja Luka connecting you. You could have sent three separate messages.
23 So why did you read this one? You understand? It seems to me you could
24 have solved the problem without having to read the contents but you did
25 read the contents. So why was that?
1 A. No. First of all, not reading documents was a principle I
2 followed in my work. It would have required reading an enormous amount
3 of dispatches and this would be a great burden. I had previously --
4 Q. Sorry, let me stop you there because I think I understand what
5 you're saying, but your answer was recorded as:
6 "First of all, not reading documents" -- oh, I'm sorry, it's been
7 changed. So not reading was a principle that you generally followed;
9 A. But there was also a regulation in place which stated that an
10 employee of the coding department as well as the officer in charge can
11 read any coded document only to the extent necessary for him to do his
12 job. Whatever he reads is something he may not share with anyone unless
13 the law prescribes otherwise. If this or that document was sent to a
14 particular person, then I can convey information but only to him. That
15 is why being familiar with the situation in terms of communication and
16 knowing that it was a very urgent matter as a rule, dispatches had to
17 leave immediately, at the same moment the signalsman could contact the
18 courier to take it on to the chief because as a matter of principle
19 urgent dispatches concern state matters rather than criminal issues or a
20 fire which had taken place. Since I knew that the chief was there in the
21 meeting and I had to go back, anyway it was only logical that I took the
22 dispatch to him.
23 Q. I understand that. Let me ask you, though, about part of your
24 testimony about this. At page 24781 you said even before, whatever the
25 contents of the dispatch, where I saw that it was impossible to apply the
1 standard procedure, I would decide on what measures are to be taken on
2 the basis of contents of the dispatch."
3 I'm not sure I understand what you mean there. What standard
4 procedure are you talking about and why was it impossible to apply?
5 A. For example, if a dispatch arrived in our office and was supposed
6 to go to, say, Bosanski Novi and I know that they cannot receive the
7 dispatch because of technical malfunction, then I'll try to come up with
8 another possibility. If it's an open dispatch, it can be dictated over
9 the phone; if it's a coded dispatch and if so required by the contents --
10 for example, a dispatch actually arrived saying that this many policemen
11 ought to be provided by Prijedor, Bosanska Dubica, et cetera, to take
12 part in an operation. It was before the war. And I knew that
13 Sanski Most was unable to receive the dispatch, what to do then? You
14 dispatch a courier and a vehicle to take you to them. But I could only
15 propose that and the chief, as a matter of fact, approved. This is what
16 I meant more or less.
17 Q. On the 29th of April do you know who was in the position of chief
18 of the SJB in Sanski Most, Bosanski Novi, and Bosanska Dubica? Do you
19 know, were those chiefs Serbs or non-Serbs or do you know?
20 A. I don't know. I did know then, but I no longer remember.
21 Q. Okay. But with regard to this dispatch, given Banja Luka's
22 refusal to make the connection so a circular could be sent, it seems one
23 of the possible solutions as we talked about was to send a separate coded
24 communication to each of the three. But you didn't do that. Was it
25 because it was very urgent and time was of the essence? Is that why you
1 didn't send three separate messages to those three places? Or was it
2 because after you read the contents you decided: Oh, I don't want to
3 send that on. I better tell the chief about it and then we'll decide
4 what to do?
5 A. No. Because of the situation in the communications centre and
6 because of what I did when I referred to Prijedor, when I left I no
7 longer came back to control my employee to see what he did what he was
8 supposed to, which was to send it individually to the three addressees.
9 As for the rule that he had to do it, it is so clear he must have known
10 he was supposed to do it and he knew he would bear consequences if he
11 didn't. Concerning the topic of mobilisation, I no longer controlled
12 whether he indeed sent it on, but I am convinced he did, otherwise my
13 work, my job, would have in jeopardy as well. As a matter of fact, no
14 one raised any questions subsequently.
15 Q. Okay. I understand better now. Thank you.
16 So then you took the dispatch to -- well, you took the dispatch
17 and the book to the meeting?
18 A. Yes, yes. The dispatch log-book.
19 Q. I have one question about the dispatch. You told us -- we saw
20 the typewritten letters "dzz/m" at the bottom, which you told us you
21 understood to be the -- referring to a communications worker in Sarajevo
22 whose last name was Dzanko; correct?
23 A. Yes. And I think that. I'm positive.
24 Q. Okay. And I think you said his name was Mirsad. But my
25 information is that communications worker in Sarajevo at that time last
1 name Dzanko his first name was Muhamed. Would you disagree with that?
2 A. That is possible too. For example, today I no longer remember
3 the counsel's first name. I've forgotten already. I'm not very good
4 with names, but Dzanko is something I did remember and there were many
5 such work-mates of mine whose initials I was familiar with.
6 Q. Okay. You got back to the meeting with dispatch in hand and the
7 book and I think you said you gave it to Mirsad Sahuric to - what? - to
8 fill out in the book the information?
9 A. Yes.
10 Q. And to give it to the chief and have the chief sign for it?
11 A. Yes.
12 Q. You don't know where that communication book is anymore, do you?
13 Was it destroyed?
14 A. It's a book for the chief or by the chief. It could be the one
15 you showed me yesterday. It is only logical. However, I don't remember
16 whether the dispatch is in there. You could check. I think it should
17 be. It should be in his book. As for the communications book where
18 Sahuric made the entry, it's much the same as all the other books.
19 Q. Let me see if I understand. So the book the chief signed in
20 acknowledging receiving this dispatch on the 29th of April was the book
21 that Mira Topic kept in the chief's office. Would that be the one you're
22 talking about?
23 A. The official book according to the regulations was the
24 communications book, and it not only included the chief's dispatch but
25 all the other, including the one signed by Mirsad Sahuric. The auxiliary
1 book, so to say, that Mira kept, which I saw yesterday or the day before,
2 I expect you could find it there. I said that the books were destroyed.
3 And I have another remark about destroying books. It wasn't as if we
4 burned a single book at a time. Every month or every week -- actually,
5 every week we would have a full sack of such books to be burned. And
6 when it was this book's turn, it went in the sack as well. Two coding
7 department workers did that. They would take the sack and burn it in a
8 safe place, and it was always done by two people, not a single person.
9 Q. We did look at one book recording I think coded telegrams
10 outgoing. I have another book that I'll show you later on that appears
11 to be incoming dispatches of all kinds that went to the chief. But for
12 now I wanted to ask you, you said the reason that you spoke out at the
13 meeting on the 29th was because of the nature of what you read in the
14 dispatch made you feel as though this was the beginning of a war. Is
15 that a fair summary?
16 A. When you sum up everything I said, it boils down to that, yes. I
17 think I said yesterday too that the answer to your question would be yes.
18 I also said that I started relying on my emotions rather than my senses,
19 and the only thing I felt was this hellish fear of having to face some
20 earlier bad things that had taken place. Before that, I never used to
21 reason that way. I always relied on my rationality alone.
22 Q. The reason I ask you about that, I know you told us that you
23 didn't really watch television or read the newspapers, but I wonder were
24 you aware -- well, were you -- first of all, were you aware of the
25 existence of the Autonomous Region of the Krajina and the Crisis Staff of
1 the ARK in Banja Luka? Did you know about that political body that was
2 operating and doing things in April of 1992?
3 A. It is correct that I did not follow politics, but I wasn't
4 isolated from the world either. I knew that this SAO Krajina existed.
5 As for any Crisis Staff in Banja Luka, I was truly ignorant of that and
6 this is the first I hear of it from you.
7 Q. You didn't see any references to the Autonomous Region of Krajina
8 Crisis Staff decisions, for example, in some of the dispatches received
9 from Banja Luka? Maybe we'll look at a couple later on, but there's some
10 forwarded to Prijedor making reference to ARK Crisis Staff decisions.
11 You don't recall seeing anything like that?
12 A. If you showed it to me, I might be able to tell you something.
13 Otherwise, I don't recall anything off-the-cuff.
14 Q. We'll maybe come to that later. I wanted to stick to my line of
15 questions for right now. So did you not know or hear about a decision by
16 the ARK Crisis Staff on the 27th of April where the -- I'm sorry, it's
17 not the Crisis Staff but it's the Assembly for this point, the Assembly
18 of the Autonomous Region of the Krajina on the 27th had taken the view
19 that the JNA was to be prevented at any cost from withdrawing the
20 equipment and ordnance from the area of the autonomous region. I take it
21 you didn't know about that?
22 A. Not at the time, but I did see a document in the papers I
23 received from either you or Defence. I saw it, say, a month or two ago,
24 but I don't recall it from back then. Just another thing. I think you
25 said "Crisis Staff" the first time around and the next time around you
1 said "Assembly." That I remember.
2 Q. You're right, I did initially mention "Crisis Staff." But that
3 particular position was by the Assembly. In late April -- well, in April
4 of 1992, had you heard anything about a group of armed Serbs in
5 Banja Luka that called themselves the Serbian Defence Forces, the S-O-S,
6 did you know anything about them?
7 A. No.
8 Q. So I assume you didn't hear anything about them blockading the
9 JNA from leaving Banja Luka, starting the 27th of April, 1992?
10 A. Well, I have the feeling that I'm hearing this from you for the
11 first time, but perhaps I did hear about it earlier but it was so
12 important that I completely forgot about it. So perhaps I did hear about
13 it, perhaps I didn't. I mean, Banja Luka was so far away in a sense from
14 us that I never heard it. There was no need for me to hear it. And let
15 me correct myself, I did have a TV set then, but I very rarely watched
16 the news and I don't know if this ever was in the news.
17 Q. Thank you.
18 JUDGE HARHOFF: Mr. Jankovic, could I just ask you to clarify a
19 bit. What did you make of the information that you did receive and which
20 you did remember that the Assembly of the ARK had issued a dispatch with
21 the purpose of trying to prevent the JNA from pulling out along with its
22 weapons? What was your interpretation of that information?
23 THE WITNESS: [Interpretation] I didn't understand you properly.
24 You said the Assembly. Are you talking about the Assembly of the Krajina
25 because that was not in the dispatch? If you're thinking about the
1 dispatch that I brought, then that was on the basis of a decision of the
2 Presidency of the BiH, not of the Krajina. That's what I meant. If
3 that's what you meant. I don't know. Could you please clarify your
5 JUDGE HARHOFF: Yes, I can. And I'm glad that I put the question
6 because apparently there is perhaps a misunderstanding. From the
7 transcript of your testimony just a couple of minutes ago, it would
8 appear that you remember having seen the dispatch that was issued by the
9 ARK Assembly --
10 MR. HANNIS: Your Honour, if I may, if that's in there I don't
11 remember asking a question because the document that I was relying on
12 didn't refer to a dispatch, but it referred to a decision or a position
13 taken by the Assembly.
14 JUDGE HARHOFF: Thank you for this clarification. In any case,
15 the way I interpreted your answer, Mr. Jankovic, was that you actually
16 heard of the decision taken by the ARK Assembly on the 27th of April and
17 that this decision was designed to try and prevent the JNA from pulling
18 out its weapons from the Banja Luka area. And my question to you is:
19 Since you seem to remember this decision, what did you make of it? How
20 did you understand the purpose of this decision? Why should the JNA be
21 prevented from pulling out its weapons? Do you understand my question
23 THE WITNESS: [Interpretation] I do understand it now and I think
24 there is a misunderstanding that originates from what the Prosecutor and
25 I were saying. So I'm going to try to be as clear and as brief as
1 possible. All that I said about the isolation and everything, it all
2 refers exclusively to the dispatch of the BiH Presidency which I brought
3 to that meeting. This was the only thing that I knew. All the other
4 dispatches, documents, that are mentioned in any way, including the ones
5 from the SAO Krajina, I don't know anything about that nor did I ever
6 know. Was I clear? Thank you.
7 JUDGE HARHOFF: But, Mr. Jankovic, let me then put the direct
8 question to you. Did you hear at the time of a decision, not a dispatch
9 but a decision, taken by the ARK Assembly on the 27th of April, 1992, a
10 decision to try and prevent the JNA from pulling out along with its
11 weapons from the Banja Luka area? Did you hear of that decision?
12 THE WITNESS: [Interpretation] I didn't hear anything. That's
13 still the period when Talundzic was the chief and if any document did
14 come to the station, as I said a number of times, I was totally
15 "isolated" there.
16 JUDGE HARHOFF: Thank you.
17 Back to you, Mr. Hannis.
18 MR. HANNIS: Thank you, Your Honour.
19 Q. Do you recall -- well, let's have a look. I have a technical
20 question for you. Could we bring up Exhibit 1D150, tab 24 of the
21 Prosecution binder. And actually, I know there are two B/C/S versions.
22 It doesn't matter which one we look at first because I want to look at
24 Can you see that one on the screen?
25 A. I cannot really see this very well. Perhaps you have a better
2 Q. It's not much better, but I do have hard copies. If I can hand
3 them to you, I'll hand you copies of both B/C/S versions we have for
4 this. The copy you're going to get may not be much better, but the first
5 point I want to ask you about is: I recall, perhaps in your OTP
6 interview, you explained about the technical functioning of the equipment
7 when sending or receiving these kinds of messages. And there's a unique
8 function of that regarding how the text is oriented on the page if you
9 follow me. I understood if the letters are straight up and down that
10 tells you something about where this one came from, whether it was a sent
11 document or a received document. Do you follow me? Do you know what I'm
12 talking about? And if the letters leaned to the right, that means
13 something else; and if they leaned to the left, that means a third thing.
14 Can you explain that to us? I'm looking at the one that's on the screen
15 now and that seems to be attached -- looking at the one that's on the
16 screen now, that appears to be text that is upright, standing straight up
17 and down. So what does that say to you about where this one came from?
18 That's -- I think that's the one you were looking at in the hard copy.
19 If the letters are upright, what does that tell you about where this came
21 A. I will explain. First of all, based on my experience, I
22 recognise the device on which this was done. This is a teleprinter
23 produced by the Elektronska Industrija Nis factory. And the licence
24 is --
25 THE INTERPRETER: The interpreter did not catch the word.
1 THE WITNESS: [Interpretation] So these letters are made up of
2 dots. You cannot see it here but the letters are made up of dots.
3 MR. KRGOVIC: [Interpretation] I apologise. The interpreters did
4 not hear the licence. Could the witness please repeat it.
5 THE WITNESS: [Interpretation] Sagem, yes, that's the French
6 company. Perhaps you know it. They also make mobile phones.
7 That machine has the option of differentiating -- I'm going to
8 tell you now. When the operator is working on the machine, typing on the
9 machine, and the letters are being written, then there is one regime of
10 operation. Can you hear me? When it's being received, when he's
11 communicating with a participant and is receiving the text and directly
12 typing it, that's a second regime. And the third one is when you are
13 making a copy from memorised recorded data. So this particular format
14 indicates that this arrived from a communications line. Recently I did
15 see a document with a copy leaning to the right, recently when I was
16 working with the Defence I saw a dispatch which according to what I know
17 was not a copy but was leaning to the left. So it means that I've
18 forgotten a little bit, but right now I am convinced that the dispatches
19 that were received are straight. And so this dispatch, I think, would
20 have been received directly.
21 Q. Okay. If in e-court could we put up the other B/C/S version of
22 1D150 side by side with the one that's currently on the screen. I'd like
23 to have both B/C/S versions up and not the English because I'm just
24 trying to compare the orientation of the text.
25 You see on the screen those two documents and the two documents
1 in your hand. To me it seems -- we've got two copies of the same thing
2 on the monitor. Now, yeah. It seems to me that the darker hard copy,
3 those letters seem to be slanting slightly to the right; am I correct?
4 A. Yes, and this is now confusing me. This is opposite to what I
5 have just told you and I don't have an explanation. Why is it opposite?
6 By logic because this dispatch was recorded into the book by Mira Topic,
7 then it would be logical that the dispatch that the chief received, he
8 would hand it over for her to record in the log-book and that it arrived
9 directly, it was received directly. That was the usual thing in the way
10 we worked.
11 Q. Okay.
12 A. And the dispatch that would be a copy should be slanted. So
13 something is not quite clear to me right now. I don't know how we could
14 get to the bottom of it.
15 Q. Don't give up yet. I think you may be right still. You see the
16 handwriting at the top of that one you're holding in your hand which is
17 the one on the right side of the monitor as we're looking at it has the
18 handwriting of Mira Topic; right? Right?
19 A. Yes, yes, that's what I said.
20 Q. And it's dated the 11th -- I think it's the 11th of May, 1992,
21 that she's written there; correct?
22 A. Yes. Let me just remind you of what I said yesterday or the day
24 Q. No, I'm going to ask you because I think that's correct. You
25 told us that, after the take-over, Mr. Drljaca called you into his office
1 and introduced you to a couple of journalists?
2 A. Yes, that's it.
3 Q. And asked you whether you still had the dispatch?
4 A. Yes.
5 Q. And you went back to your workers to look to try to find the tape
6 whether it was still there?
7 A. Yes.
8 Q. And you made a copy?
9 A. Perhaps that's what it is.
10 Q. And that's why the letters lean to the right on this one; right?
11 A. Very probable, but I'm not sure.
12 Q. Okay. But that would indicate that this one is not the original
13 that Chief Talundzic had because his should have been oriented otherwise,
14 standing upright, not leaning to the right?
15 A. Yes, yes. From what I can remember on the actual device, that's
16 how it was.
17 Q. Okay. All right. Thank you. That clears up one mystery for me.
18 Now, I want to go on into the evening of the 29th. You told us
19 how after all this happened at the meeting and the hubbub you went home
20 and later on you were called by, I think, your communications officer who
21 was on duty and told to come in. So you went to the police station and
22 when you got there you were told to go to Cirkin Polje; is that right?
23 A. Cirkin Polje.
24 Q. Okay. And who told you to go there? When you got to the police
25 station who told you to go to C. Polje?
1 A. I'm just recalling this. I said that yesterday or the day
2 before. The system to summon me when I was needed by anyone, a superior
3 or anybody who really needed me officially, nobody would ever call me at
4 home. They would call the duty officer at the communications centre who
5 was there from 00.00 to 24.00 hours and they would just say: Call the
6 boss to report at such and such a place. And that's how it was this
7 time. I didn't ask him who told him that, but I was summoned to the
8 communications centre.
9 Q. Yeah, I understand that. But my question is: When you got there
10 then somebody must have told you to go to Cirkin Polje. Who told you?
11 A. The duty communications officers were already there and I could
12 see that everybody was getting ready to go, not just the communications
13 staff but the police and ...
14 Q. Yeah, but can you tell me the name of the person who once you got
15 to the police station told you: We're going to Cirkin Polje? Was that
16 somebody else in communications? Was that the deputy commander of the
17 station? Who do you remember first hearing that you were going to
18 Cirkin Polje?
19 A. Most probably, most probably the situation proceeded in this way.
20 The person who sent the duty officer didn't say: Call the boss. But he
21 said: You should all assemble. So that when I got there there was some
22 other communications personnel there. It wasn't just me. There were
23 perhaps three of them. I cannot remember who else was there. Raus,
24 Mladen, was there, Milan Batajnica, I don't know if anybody was missing.
25 There were four or five of us. And then there was an assembly already of
1 people there. The communications people were already there. We didn't
2 wait for anybody else. They were all living much closer than I was to
3 the place.
4 Q. Now, you told us before about when you got there and the number
5 of people and the kinds of uniforms they were wearing. Do you recall
6 what building specifically you went into? Had you ever been out there
7 before to know what building it was that you were in?
8 A. Yes, I'd never been there before. This was a building of the
9 local commune, as we referred to it, over there. This is the place where
10 the secretary of the local commune is. It's a low building about the
11 size of this whole area here, but there are many rooms in that building.
12 I entered an office where there were people whom I knew, perhaps the
13 komandir or I don't recall who it was. In any case, familiar faces. I
14 think that it probably was the office of the secretary himself, that was
15 his place of work. I don't know. There were two or three offices.
16 Q. And if I understand correctly, this was the very first time that
17 you met Simo Drljaca; is that right?
18 A. Yes, yes.
19 Q. And was it from him that you learned that he was the chief from
20 now on? Did he tell you that at that first meeting?
21 A. Yes, yes. He didn't tell Milos alone. We were just sitting and
22 chatting at the desk, the komandir, all of these were leading officers of
23 the station. I don't remember their names, but I saw them in the days
24 after that. I don't believe that they were all there but many of them
25 were there. And we were just chatting, nothing in particular. There was
1 no panic, then Simo comes in a multi-coloured uniform, I remember the
2 face, tall, he sat. Hello, hello. I'm Simo Drljaca, such and such a
3 thing. And that's it.
4 Q. You said he was in a multi-coloured uniform. You mean
6 A. Yes.
7 Q. [Previous translation continues]... Blue camouflage, do you
9 A. Well, the blue one came into fashion much later.
10 Q. So I take it you're saying you think it was green on the 29th of
11 April, the one --
12 A. The military one, green/brown/grey, not blue, a little bit more
13 or a little bit less blue, no, not that.
14 Q. Thank you. And when he asked you who you were, you told him you
15 were a communications officer and then he gave you, you said, a piece of
16 cardboard that said "official ID" on it; right?
17 A. [No verbal response]
18 Q. I see you nod your head, but you have to answer out loud for the
20 A. I don't know if you didn't say it correctly or it wasn't
21 translated correctly. Piece of cardboard, no. It was a stack of cards
22 this thick and it said "official ID" and that was something that was to
23 be filled in by hand. And let me just tell you, I remember it was typed
24 in a local printer shop. There were some small letters which said "vila"
25 which indicated to me that it did not come from anywhere outside. Had it
1 come from Banja Luka, the name of the printer would have been one of
2 theirs. So it was obvious that it was printed there.
3 Q. Thank you. It's time for our first break and we'll follow on
4 from that after we return. Thank you.
5 JUDGE HALL: So we would resume at 10.45.
6 --- Recess taken at 10.24 a.m.
7 --- On resuming at 10.51 a.m.
8 MR. HANNIS: Thank you.
9 Q. Witness, you were just telling us about being handed a stack of
10 blank official ID cards I think you called them. In terms of size, were
11 they about the size of --
12 A. Yes, that's what was written on them. It was paper that was much
13 lower quality than what you have, but it was the kind of paper you would
14 use for cigarette packages, but it was the size that you are showing.
15 MR. HANNIS: For the record, Your Honour, I was just showing the
16 witness my ICTY badge. It wasn't on my list of exhibits, but I trust
17 there's no objection.
18 Q. Now, did this say anything on it other than "official ID"? Did
19 it say "SJB Prijedor" or "MUP," or did it just have the words
20 "official ID" and then you filled in a name? Was there any other
21 information on these cards? Did you hear my question?
22 A. Yes, yes. It was that side, but it was a bit like this --
23 [Trial Chamber and Registrar confer]
24 JUDGE HALL: The procedural issue is that what is now being shown
25 to the witness is something that's not on the record and unless the
1 parties have some violent objection, we propose to have it assigned an
2 exhibit number at this point.
3 MR. HANNIS: Your Honour, I wasn't trying to enter myself into
4 posterity, but I thought perhaps with the agreement of the parties or the
5 Trial Chamber that we can take judicial notice of the size of the ICTY
6 badges that --
7 JUDGE HALL: No, no, not that, Mr. --
8 MR. HANNIS: Oh, okay. Good. Thank you.
9 JUDGE HALL: It's the document on the screen.
10 MR. HANNIS: The documents on the screen are already part of
11 Exhibit 1D150.
12 JUDGE HALL: This is the document where there was this difference
13 of views as to the translation.
14 MR. HANNIS: Yes, but I understood both were attached to 1D150 in
15 e-court --
16 THE REGISTRAR: If I may assist.
17 MR. HANNIS: Yes.
18 THE REGISTRAR: The second B/C/S translation the counsel is using
19 is not entered in the exhibit list yet.
20 MR. HANNIS: Well, I thought we'd had a proposal at one time to
21 give it a number of 150.1 or .01.
22 THE REGISTRAR: Thank you, Your Honours. The second version
23 uploaded by the Prosecution will be assigned Exhibit Number 1D150.1.
24 Thank you.
25 MR. HANNIS: Thank you, Madam Registrar. Thank you.
1 JUDGE HALL: Thank you, Madam Registrar.
2 MR. HANNIS:
3 Q. Witness, I'm sorry about that. Do you recall my question or
4 should I re-ask it?
5 A. No, I remember it and I was going to say that is the size but it
6 was double, it was folded over, and "official identification" was written
7 on that -- on the front. Inside something else was written. But as far
8 as I can remember, it did not say "MUP" or "Banja Luka" anywhere. Most
9 probably it said "Prijedor public security station," something like that.
10 And I have a copy, my copy, in my own personal archive. So if necessary,
11 I can provide that. 99 per cent -- well, there was very little text of
12 any kind. There were just lines for the first and last name. There was
13 no post, space for that; there was no space for a photograph or the year
14 of birth of the person to whom it belonged.
15 Q. And I take this -- I take it that this was only intended to be
16 used as a temporary document for the purposes of what was happening on
17 the next morning; is that right? This didn't continue to be your
18 official ID at Prijedor after that day; right?
19 A. No. It was used for a long time. It was quite worn from being
20 carried in my pocket. I don't know for how long, but it was months,
21 perhaps longer.
22 Q. And you filled it out, you put in the names of people as they
23 came up?
24 A. Yes. I did, yes.
25 Q. Did -- what information was filled in on the card other than just
1 the name, any other information? Did you sign on the card as the
2 issuing --
3 A. No, just the first and the last name. Just the first and the
4 last name, nothing else.
5 Q. Okay. And neither you nor Mr. Drljaca or anybody else from
6 Prijedor signed as the issuing officer, anything like that?
7 A. I definitely did not. I think that there was a small stamp, but
8 it seems that there was no signature. I really can't remember that, but
9 perhaps there was a very small stamp. I don't remember whether there was
10 a signature or not -- his signature. Mine definitely wasn't there.
11 Q. Okay. If after you're done testifying when you go home, could
12 you have a look and see if you still have yours; and if so, would you be
13 willing to furnish it to us to make a copy of and we'll return the
14 original to you? Are you willing to do that?
15 A. I can. Perhaps your staff member can call me on the phone and
16 then we can make some sort of arrangement. I do have an e-mail address.
17 I don't know it off by heart. I can send him a copy by e-mail if that is
18 acceptable to you.
19 Q. If you're willing to do that, I would ask the Judges to direct
20 the victim/witness people to co-ordinate the logistics with you on that.
22 A. It doesn't matter to me who would call me. The important thing
23 is for me to know that this is an official thing and that -- and that
24 it's for the needs of this Tribunal. Of course I will do everything
25 else. The important thing for me is to know that it's just not going off
1 somewhere without any control.
2 Q. [Previous translation continues]... That's why it will be
3 victim/witness, not me or not the other side. It will be somebody who
4 works directly for the Court.
5 A. The Tribunal, the OTP, the Defence, that is really not in
6 dispute. That will all be fine.
7 Q. Thank you. As far as you know, were you the only person who was
8 filling out those cards and giving them to people that night or did
9 somebody else help you do that?
10 A. It was only me that evening. Later on I returned whatever forms
11 were left to the secretary. Later on others received it, but I was no
12 longer familiar with it.
13 Q. Did you keep a list of the names of people to whom you had given
14 cards or did you simply fill out the card and give it to them?
15 A. No, no. This is how it was. Say you arrived, you say your name
16 was this and that, and I write it down. Then the next person came,
17 et cetera. There was no other type of control. Even the people I didn't
18 know personally were included.
19 Q. Well, that's my next question. So you gave cards -- you gave
20 official cards -- official ID cards to some people that you didn't know
21 who they were; right?
22 A. Well, yes. But whoever was there I supposed were all -- I don't
23 know. I didn't then -- well, I was -- I did what I was told.
24 Q. And you didn't ask anybody to show you an ID that they were a
25 policeman before you gave them one of those official ID cards?
1 A. No, no.
2 Q. But I take it several of the people to whom you gave cards were
3 people that you already knew and worked with as police persons; right?
4 A. Yes.
5 Q. Thank you. You said something that I thought was percipient of
6 yourself. You said that when you were thinking about this you said at
7 page 24798:
8 "So I was asking myself: How come I know nothing about that,
9 whereas there were obviously huge preparations made ahead of it."
10 And I understood you were talking about all these people gathered
11 out there and the take-over being done the next day. Is that right? I
12 mean, it seems the type of thing that must have been planned farther in
13 advance than just the 12 or 13 hours since the meeting where the dispatch
14 was read out. Do you understand my question?
15 A. I do. I remember I mentioned that I was surprised, but can you
16 tell me more about the context in which I provided that statement? I
17 think I did say that yesterday, but what was the actual context? Perhaps
18 you can expand a bit more or read out a larger portion.
19 Q. Well, the question to you was about the meeting in Cirkin Polje
20 and where it was and where the rooms where. And you said:
21 [As read] "It's a big facility. There are many rooms inside.
22 There was one officer where I sat, but since" --
23 A. Yes.
24 Q. [Previous translation continues]... "lighting was bad quite a few
25 of them were lit only if you had moonlight. So I was asking myself how
1 come I know nothing about it."
2 And I took that to mean how come you didn't know anything about
3 it before the night of the 29th about all this. That is what you were
4 referring to?
5 A. Yes, that is what I said and that is what I meant. Now I know
6 what you mean. For example, in passing I saw some crates or boxes in a
7 room and they were of the military olive-drab colour. It must have been
8 military equipment. I didn't what it was, where it had come from, who
9 brought it in, and why. It must mean that this was an ongoing process I
10 was unaware of. Of course as a signalsman I wasn't in any situation to
11 know and it's obvious I didn't. Sometimes I learned of things
12 indirectly. For example, before I used to attend collegium meetings when
13 the chief agreed on certain things with the commanders and I was there as
14 an observer and I didn't contribute. But, for example, in this situation
15 I was completely ignorant of the whole thing.
16 Q. You mentioned at page 24832 when you were asked about what most
17 of the people were wearing at Cirkin Polje, you said there were a motley
18 crew of all sorts of colours, JNA uniforms, then police uniforms that the
19 reserve forces had, the blue ones of poorer quality, there were
20 active-duty policemen in their own uniforms, so everything was there.
21 And then in the transcript I think there's an error you said:
22 "I didn't count, but there were perhaps 1350," 1-3-5-0, "to
23 200" --
24 A. No, no.
25 Q. So I thought -- did you mean 150 to 200 men?
1 A. Yes, approximately. The room was the size of this one and
2 perhaps another half of the courtroom. It wasn't completely packed, but
3 there were a lot of people. I didn't count. Let's put the figure at 150
4 or between 1- and 200.
5 Q. Did you know any of the local JNA commanders in Prijedor at that
6 time? Did you know who any of those were?
7 A. No. I did know of them, but I didn't know them personally. For
8 example, Mr. Zeljaja, I had seen him perhaps twice although I didn't see
9 him on that occasion. I'm not saying that he wasn't there, but he wasn't
10 in the same rooms where I was. There were two officers there, though.
11 One was a major and asked for my radio, hand-held radio, Motorola. I had
12 never seen him before. I didn't give it to him because per establishment
13 the military was not part of my structure and I didn't have enough
14 hand-held devices for my own people, let alone the army.
15 Q. Okay. Did you recognise any of the people that were in military
17 A. I didn't recognise anyone, but at that time or just before there
18 was fighting in Slavonia where the JNA had participated. There were
19 people from our area who went there who kept their relatively worn out
20 military uniforms. There were not police uniforms.
21 Q. And the number 150 to 200 that you told me about, is that the
22 total number of people in the room where you were?
23 A. No, no. We have to be clear. I meant the area around the house.
24 In the house itself there were -- there was a number of smaller rooms and
25 there were far fewer people inside.
1 Q. Do you recall approximately how many official ID cards you handed
2 out that night? Was it 50? A hundred? More than a hundred?
3 A. I can't recall. But that was the only thing I did, although I
4 wasn't at that task all the time. When someone turned to me, I wrote out
5 the IDs. Then there may have been people who didn't even know they would
6 have to come to me.
7 Q. All right. Thank you. Now I want to turn to another topic
8 unless the Judges have any questions about that night. Let me show you
9 Exhibit P652. This is at tab 29. I think you may be able to read this
10 one on the screen. Can you see that okay?
11 A. I can.
12 Q. This is a dispatch number 11-12 and there's a handwritten number
13 1873 at the top. It appears to be from Chief -- from Chief Drljaca to
14 Banja Luka, reporting, among other things, that:
15 "In accordance with the conclusions of the Executive Board of the
16 Serbian Assembly of Prijedor at 0400 hours in the municipality control
17 was seized over SJB and all other major facilities."
18 That is right, that is what happened on the 30 of April?
19 A. Yes.
20 Q. Handwritten at the bottom we see the date 30 April and 0720
21 hours, Dragan. Do you know whose writing that is? Is that a
22 communications officer?
23 A. Just a moment. The number of 1.587 seems enormous. I'm not
24 trying to say something there wasn't, but it just sounds out of place.
25 Q. I understand that.
1 A. And now about the note. In all dispatches where you come across
2 a handwritten note, it means the following. This is a textbook example
3 and if you remember you can apply it to all other such documents. Each
4 communications worker had their own sign. In the circle it reads BM,
5 Milan Batinica. I was his boss in Prijedor. He sent it. Once he did,
6 the equipment types out who received it. So it was received on the 30th
7 of April, 1992, at 7.20 by Dragan, a signalsman in Banja Luka. It was
8 sent to the CSB there. I don't know this person, but I know that there
9 was a Dragan there. It was standard practice. The person sending it
10 would hand-write their initials. It was much like the DZM on the other
11 document. As for the date, it should be the date when it was sent to
12 Banja Luka and received by Dragan there.
13 Q. Okay. Thank you. Can we go to another topic. I want to ask you
14 what you know, if anything, about some crimes that may have been
15 committed in Prijedor municipality after the take-over. And the first
16 document I want to look at is P659, tab 66. I can give you a hard copy
17 of this one with the usher's assistance. While it's on its way to you, I
18 will tell you this is a -- appears to be a document from Chief Drljaca
19 sent to CSB Banja Luka and dated the 13th of June. And he's complaining
20 about some of the activities of the Banja Luka special unit. Have you
21 had a chance to read that?
22 A. No.
23 Q. Let me know when you're done.
24 A. You want me to read it?
25 Q. Yes.
1 A. Okay.
2 Q. Thank you. Among other things he's complaining that these
3 special unit people were arbitrarily arresting, interrogating, and
4 abusing prisoners and taking money and jewellery from them and they even
5 got into a conflict with the Prijedor policemen who were on security
6 duty. Did you hear about that at the time, back in 1992, problems with
7 the Prijedor special -- with the Banja Luka special unit in connection
8 with Omarska?
9 A. No. I didn't hear about that. It was so far removed from my
10 tasks that I didn't even know of this "Strazivuk". I don't recall such a
11 last name. I'm not saying they weren't there but I know nothing about
13 Q. And the last paragraph there's a reference there to Mirko Jesic.
14 Do you know who he was?
15 A. He was the chief of the State Security Service office in
17 Q. Okay. Thank you. All right. The other item is he mentions that
18 there were also complaints about the conduct of the special unit and
19 looting during mopping-up operations. Was that referring to operations
20 in the Muslim villages in Prijedor municipality that was done in May and
21 June of 1992? What did you know about that?
22 A. I don't know what is referred to specifically in the document,
23 but I believe there were such incidents. There was chaos and I could see
24 it for myself. I was stopped once by someone. They weren't police, and
25 they wanted to take away my vehicle. It was an official Golf vehicle.
1 They were trying to seize it in the name of the people they said. I did
2 scare them away when I said I was a policeman, but they simply wanted to
3 take the car away. I believe there were such instances. As for what was
4 official, unofficial, or semi-official is difficult to discuss from this
5 point in time.
6 Q. I don't think you mentioned this incident before. When and where
7 did that happen?
8 A. I didn't. I didn't mention it. I was reminded by what you just
10 Q. Okay.
11 A. I think I was on official business to the radio station in
12 Prijedor. It had something to do with communications. I don't remember
13 exactly. There was a person with an old olive-drab coat and an old rifle
14 and he said, "Hand-over the keys in the name of the people."
15 Q. Okay.
16 A. Just a silly elderly guy.
17 Q. All right. Let me show you Exhibit P812. It's at tab 111 of the
18 Prosecution binder. And I'll hand you a hard copy, although it's not
19 very good either. It appears --
20 A. Oh my.
21 Q. Yeah, it appears to be to the Prijedor SJB from CSB Banja Luka,
22 forwarding a telegram from Minister Stanisic, wherein he orders that an
23 investigation be done into the fate of about 150 Muslims who apparently
24 were killed in the area of Skender Vakuf at Koricanske Stijene. Did you
25 ever hear about that event?
1 A. I did, but much later.
2 Q. Do you recall the circumstances under which you first heard about
3 it, when and where and how you heard about it for the first time?
4 A. I recall very little. Brane or Branko Siljeg was an inspector in
5 charge of property crimes and crimes related to economics. It's the
6 person I mentioned in relation to the medication in Keraterm. By that
7 time he was a ruined person, ruined by alcohol. He told me he went there
8 with someone - he never said who - and he didn't even tell me the whole
9 story. He just said, "We went," and he said, "I'm tired because I went
10 beyond Knezevo" and that some people were killed and I guess they were
11 there to clean up and that's why they went there. But at the time it
12 didn't mean much to me. The topic of death was an everyday thing at the
13 time. And I also didn't take his information seriously, having in mind
14 what kind of person he was. He died later on because he had drunk too
16 Q. Okay --
17 A. Later on when I worked in the CSB in Banja Luka, they
18 commemorated it, it seems. After the war when I moved following 2001, I
19 think Bosniaks commemorated the event; and we provided security, the
20 police. We from the communications department didn't attend the scene
21 itself, but we were around the perimeter, say almost a kilometre away. I
22 was never on the spot. I simply took part in preparing the
23 communications side of the operation.
24 Q. Okay. So in 1992 did you hear anything else about this event at
25 the Koricanske Stijene being discussed in Prijedor police department, if
1 you remember?
2 A. No, no. No one discussed it. The first news came from this
3 colleague. As I said, he said he was tired because he had been there. I
4 have a feeling it was 15 or 20 days after the crime, maybe less, 10, but
5 then it could be 30 as well.
6 Q. You're not aware of a number of dispatches back and forth between
7 CSB Banja Luka and Prijedor regarding that event? Do you remember seeing
8 any dispatches about that?
9 A. Not from that time, but you prompted me or perhaps the
10 Defence - I don't remember who - because your dispatches resemble theirs.
11 It could be one of yours. I may have seen it, and I think I even saw on
12 a dispatch that Simo -- well, I can be disrespectful and tell the -- I
13 think he said: "I didn't conduct an interview because the people were
15 In our service this was not a normal way to go about things. He
16 could have gone out in the field and find them, but I did see it when I
17 read your dispatches, not before.
18 Q. Okay. Certainly not in 1992; right?
19 A. Just one more thing in this context. The dispatch I have in my
20 hand, this one, from the minister, obviously this was not typed out on
21 any communications equipment. Perhaps a typewriter and then it was
22 faxed. If it was received by Banja Luka, I can't even read what it says,
23 but speaking from my experience, if Banja Luka received it from Sarajevo
24 by fax then this is it. I don't think this had gone through the
25 communications centre, any communications centre, including Banja Luka.
1 That's why the copy is so poor.
2 Q. Okay. Yeah, let me show you a couple other documents that may
3 shed some light on this. If we can look at Exhibit P1380, it's tab 112.
4 Witness, this one you may be able to read on the screen, it's a better
5 copy. It you need a hard copy, let me know. Can you read that one all
7 A. No, no, this is enough, what's on the screen.
8 Q. Okay. This one is dated the 11th of September, 1992, it looks
9 like, from CSB Banja Luka to Prijedor to the chief and it says:
10 "We received the following dispatch numbered 10-245/92 dated 31
11 August ... from the MUP ..."
12 And then it's from Minister Stanisic ordering you to conduct a
13 full investigation. So it looks like basically the same order that you
14 were looking at on that bad copy just a minute or two ago. And then
15 below the text of Minister Stanisic's order are some specific directions
16 from Mr. Zupljanin to the Prijedor chief. At the top we see handwriting
17 with a number 11-12-668 and a date. Is that again Mira Topic's
19 A. Yes, yes.
20 Q. And then what appears to be maybe different writing, I'm not
21 sure, the word that has been translated as the name "Marko."
22 A. I see it as Marko.
23 Q. [Previous translation continues]... Do you know what that or who
24 that refers to?
25 A. As far as I know, there was just one Marko, Marko Djenadija, who
1 I already mentioned. So at that time Marko -- well, Marko was a komandir
2 somewhere. Even later after the war he was chief of the station. But
3 right now I don't see any role for Marko. I don't know of any other
4 Marko except Marko Djenadija. I don't know what his role there is
6 Q. Do you know what position he held in September of 1992?
7 A. Well, I just said I cannot remember. For a time during the war,
8 he was the komandir of the station Prijedor 2, I think, or the traffic
9 police because they were outside of the centre building. But from when
10 to when, I really couldn't say. Cadjo, Marko, they all followed one
11 another. So I'm afraid I would make a mistake now.
12 Q. Okay. Let me show you two other documents relating to this and
13 then I think we'll move on. Exhibit P682, which is tab 113. This is
14 another one I think maybe you can read on the screen. It's dated the
15 14th of September from Simo Drljaca to CSB Banja Luka, to the chief. And
16 it's -- I think it's a response to the one -- yes, the one that you were
17 just looking at, 11-1/02-2-345. And here he's saying we can't
18 investigate because those policemen that escorted the convoy have been at
19 the battle-field since 9 September. Is this the document you referred to
20 before when you said you thought you'd seen one where Drljaca was
21 saying --
22 A. Yes, yes, I was thinking about him earlier. I don't remember
23 from what period. The first time I saw him, I don't know whether this
24 was in conversation with your people or the defence, but I did see that
1 Q. And one more, tab 114. This is 65 ter number 20268. It appears
2 to be a coded dispatch dated the 14th of September from Drljaca to the
3 chief in Banja Luka, again referring to that same dispatch number. It
5 "We're not able to conduct an investigation since all the
6 policemen have been deployed on the front since 9 September and also
7 we're unable to provide you a list of the citizens who travelled on those
8 convoys because this public security station didn't organise the convoys
9 but only assigned a certain number of policemen to providing physical
10 security." The Dusko S. and the date of 15 September, tell us about
11 that. Is he a worker in your comms centre?
12 A. Yes. That is not the S, but it's the Sh, Sarac that I mentioned
13 before who had called me about that dispatch. And then again you can
14 apply the logic that I spoke about recently in relation to these
15 handwritten parts, that means the dispatch was handed in, the chief wrote
16 the 14th of September, it was sent on the 15th of September; at a normal
17 time this would be an incredibly long time for it to be sent off to
18 Banja Luka. You see 0750 here. So I'm talking about what we talked
19 about, the difficult operation of the communications system, meaning that
20 it had stayed there all day. Then this guy, Dusko, there's a Dusko up
21 there as well. This Dusko received it from this other Dusko. There are
22 two Duskos, one in Banja Luka and one up here. Received by Dusko at 7.50
23 and it was dispatched by Dusko Sh, Sarac, that's our guy at our end.
24 Q. Okay. So it was sent and it was received in Banja Luka then
25 according to this?
1 A. Yes, this was received according to what Dusko wrote, at 7.50.
2 Q. Thank you.
3 MR. HANNIS: Your Honour, I'd like to tender that one.
4 MR. KRGOVIC: [Interpretation] Your Honours, I would object to
5 this because I believe that this document should not be admitted because
6 the Prosecutor is actually tendering new evidence and in light of fresh
7 evidence this document does not meet that criteria. The Prosecutor did
8 not give a clear reason why the document was not admitted earlier when it
9 admitted the identical document as P00682. And for those reasons, I
10 believe that the document should not be admitted.
11 JUDGE HALL: Mr. Hannis, why would -- why was not this tendered
12 at the time that the Prosecution tendered the - I will call
13 them - companion documents?
14 MR. HANNIS: Your Honours, I don't know the answer to that
15 question, but I do know I came across this in preparing for this witness
16 and trying to identify documents that dealt with what I perceived to be
17 the allegation in the 65 ter summary for this witness that Mr. Drljaca
18 was not -- was acting independently and was not responding to requests
19 for information from CSB Banja Luka and Mr. Zupljanin. And that's why it
20 was proposed.
21 JUDGE HALL: Apart from that, this is -- seems to be tangential
22 in terms of the witness who is presently on the stand.
23 MR. HANNIS: Well, Your Honour, he is able to verify that it was
24 sent and it was received based on his knowledge of how the system works
25 and recognising the handwritten information with the names of two Duskos.
1 I wasn't able to present that evidence through any other witness.
2 MR. KRGOVIC: [Interpretation] Your Honour, if I may reply. The
3 previous document was shown to the communications chief by the
4 Prosecutor. He could have done the same with this document as he had
5 with the previous one. There were several witnesses, actually, in
6 particular the communications chief who discussed it. And that witness
7 was used to introduce a number of documents through by the Prosecution.
8 They had an opportunity to deal with it. A number of other books were
9 tendered through the same witness.
10 [Trial Chamber confers]
11 JUDGE HALL: We will have the document only marked for
12 identification because one of the considerations that we would wish to --
13 upon which we would wish to reflect is the -- any degree of prejudice
14 that the Defence suffers and how it could be remedied. So for the time
15 being we -- the document is marked for identification.
16 THE REGISTRAR: As Exhibit P2394, marked for identification,
17 Your Honours.
18 MR. HANNIS: Thank you, Your Honours.
19 Q. Witness, I want to move to another topic. Did you know a police
20 officer in Prijedor named Slobodan Miljus, M-i-l-j-u-s?
21 A. No. I never heard such a name.
22 Q. Okay. Let me ask you, did you -- did you know about the
23 disciplinary procedures in the MUP in 1992, how that system worked, what
24 the rules were? Did you know anything about that?
25 A. I didn't. Actually, I was familiar with it before the war and I
1 know how things worked when I was in Banja Luka after 2002. Before the
2 war there was a disciplinary commission. The chief in question had to
3 put forth a proposal and then the commission would sit and decide on
4 one's disciplinary liability. After the war in the Banja Luka centre,
5 there was a prosecutor who was there only to deal with cases involving
6 official personnel. Upon receiving a proposal from the commander, the
7 Prosecutor dealt with it by way of an internal court of sorts. It was
8 not a state court. They ruled according to the disciplinary regulations
9 in place. When that -- the transfer occurred between the previous and
10 the new system is something I can't recall.
11 Q. Okay. Thank you for that. I'll move on to something else then.
12 I'd like to ask you in terms of communication, were you aware of -- I
13 don't know what to call it. Related to the ministry on National Defence
14 or the defence ministry, are you aware of a communications system that
15 sometimes was referred to as the, I don't know, the information and
16 warning system, something like that? Do you know what I'm talking about?
17 A. I suppose. You weren't quite precise in your definition, but I
18 think the name was centre for information, reconnaissance, and warning.
19 It was in the municipality, I think. It was used in terms of -- in cases
20 of disasters, et cetera.
21 Q. Yeah, that's -- I think you're talking about the thing I was
22 curious about. I want to show you Exhibit P179.9. This is tab 31. I'll
23 just show you the cover page and then take you to a specific paragraph.
24 This document's from May 1992 and it's called "decision on the
25 organisation and work of the Crisis Staff of Prijedor municipality." And
1 if we could go to page 4 in the English and in e-court the B/C/S is page
2 4. And at the bottom item 8 or Article 8. Can you read that okay,
3 Witness, Article 8? It says:
4 "In order to work effectively within the area of civilian
5 protection and reconnaissance and information service, the Crisis Staff
6 shall do a couple of things and the second one is:
7 "Via the Municipal National Defence Secretariat undertake
8 measures and actions aimed at ensuring the successful functioning of the
9 Communications System and the Reconnaissance and Information service."
10 Did you know about that?
11 A. Sorry? Via the municipal staff -- can you repeat again the
12 second item of Article 8. It says I think via the Municipal National
13 Defence Staff and other elements, undertake measures and actions aimed
14 at -- I can't read it. Civil protection, its tasks. I can't read it.
15 Q. Okay. Well, I take it what the interpreters have translated into
16 English is saying that:
17 "Via the Municipal National Defence Secretariat, undertake
18 measures and actions aimed at ensuring the successful functioning of the
19 Communications System and the Reconnaissance and Information Service."
20 A. Well, I understand now what the question is.
21 Q. Okay. So my question is: Did you know about the existence of
22 that service and its communications system?
23 A. Well, yes. The centre existed before I came to the police. This
24 is a centre that is located in the basement of the municipal building,
25 and they had equipment that used different frequencies from ours and the
1 purpose of that equipment was for natural disasters, floods, and that's
2 why it's called the centre for alerting and informing. So they also have
3 the sirens that you can sometimes hear in town.
4 Q. Did you know that that service and its communications system,
5 network, was sometimes used to transmit information from, for example,
6 Pale and the republican-level authorities out to Crisis Staffs and
7 Municipal Assemblies in places like Prijedor and Banja Luka? Did you
8 know about their system working and how it worked during the war?
9 A. I didn't know much about that centre because I wasn't interested.
10 I had no functional connections with them. It's true that there were
11 some links between our centre and theirs, but I didn't have any
12 particular interest work-wise. But it's true that each municipality in
13 Bosnia and Herzegovina has such a centre or had such a centre. And by
14 size and complexity, this corresponded to the size of the municipality.
15 There was a large centre in a large municipality, a small centre in a
16 small municipality. And organisationally and constructively they were
17 intended to facilitate communications within the municipality between the
18 local commune, and by virtue of that they had local connections and
19 frequencies. I don't know if they had connections that were broader than
20 that or not, and perhaps they could set up communications further out or
21 not. I don't know. I never followed that. I never visited. I never
22 was interested. It wasn't open access, where they worked just like at
23 our centre. It was only for privileged persons.
24 Q. You mean like the Crisis Staff, privileged persons like the
25 Crisis Staff?
1 A. No, no. I know who could enter our premises and who could not.
2 As for them, I don't know. I was never interested. I never asked. I
3 don't know whether the Crisis Staff entered or not. Conditionally
4 speaking, my centre where I was the chief, the only people who could
5 enter would be the operators, the staff, the chief, myself. Nobody else
6 besides those people.
7 Q. Okay. So in 1992 you never had occasion to ask for assistance of
8 that service in transmitting any documents?
9 A. We did not, no. Because we were more professional than they were
10 I think.
11 Q. Okay. Let me show you just before the break one more document,
12 Exhibit 1D397. And hopefully you can see this on your screen. This is
13 another document related to the 29th of April. This is not the one from
14 Minister Delimustafic, but it's forwarding a document from Colonel or
15 Commander Hasan Efendic. But I'm not so interested in the content. I
16 want to ask you some questions about the delivery information.
17 MR. KRGOVIC: Tab number, please.
18 MR. HANNIS: I'm sorry, it's tab number 27, Exhibit 1D397.
19 Q. Can you see it okay on your screen, Mr. Jankovic?
20 A. Yes, I can see just a bit. It's not complete. The letter-head
21 or the heading is not good and I don't see the signature.
22 THE INTERPRETER: We do not hear what the witness is saying.
23 THE WITNESS: [Interpretation] Yes, it says up here.
24 MR. HANNIS:
25 Q. Okay. You see a five-digit number 41505 and then little letters
1 SO followed by the letters PLE. Do you know what that --
2 A. I'm sorry, I couldn't see it at the angle that I was sitting at.
3 I have to stand. Yes, I can see it now really well.
4 Q. Do you want the hard copy so you don't have to stand?
5 A. All right. I mean, I can do it like this as well if it's not a
7 Q. [Previous translation continues]...
8 A. Yes, all right, you can see it really well.
9 Q. And the number 45254 SUPBL, do you know what those stand for?
10 A. I think that that is for our communications, the police ones,
11 that probably has nothing to do with that. But from what I can remember,
12 and I don't remember that very well, this YU at the end, these are public
13 PTT communications, that this was a dispatch sent through the public
14 system -- maybe, maybe. I think this 4150 would be the public telecomms
15 just like if you were sending a telegram to somebody, congratulations. I
16 think that that's that system; our system didn't have the letters YU.
17 Q. Okay. Did you ever hear of something that was called the
18 republican communications centre in the RS in 1992, located in Pale?
19 A. No.
20 Q. Okay. I think it's time for our next break, Mr. Jankovic.
21 MR. HANNIS: I see Mr. Zecevic on his feet.
22 MR. ZECEVIC: Your Honours, I note that the translation of this
23 document is incomplete, unfortunately. This is the first time I saw
24 that. Because you will see that after the words:
25 "We are forwarding this ... for SDS BiH ..." there are two lines
1 stating five numbers and then SOSMYU and then, again, five numbers that
2 say Vlada [phoen], Government of Bosnia and Herzegovina YU. So the
3 document needs to be sent to translations in order that the translations
4 are complete of the whole document. And since it is a 1D document, we
5 will do that. I just wanted to put that on the record. Thank you.
6 JUDGE HALL: Yes, thank you, Mr. Zecevic.
7 So we will resume at 12.25.
8 --- Recess taken at 12.04 p.m.
9 --- On resuming at 12.30 p.m.
10 JUDGE HALL: Before the witness comes back in, the counsel would
11 have been alerted by the Chamber through our Legal Officer about the
12 discoveries in terms of this document that was marked for identification.
13 Do you have anything to -- do you have any observations, Mr. Hannis?
14 MR. HANNIS: Yes, Your Honour. In the light of that discovery, I
15 don't think I have the same problem that I did. I understand P682 is the
16 same document minus the handwritten notations by the two communication
17 officers the witness testified about. So I think, given the fact that I
18 have P682 in evidence, which is the text of the telegram, and I have the
19 testimony of this witness about that, reflecting that apparently it was
20 sent and received based on viewing those two signatures, I don't need it
21 in. I suppose I would prefer to have -- what's been MFI'd as P2394 in
22 evidence instead of 682 because it's a more complete document. That
23 would be my preference. I understand the one with the handwritten
24 notation by the communication officers was disclosed to the Defence back
25 in 2008. Why we used the one without the signatures instead of the one
1 with signatures, I don't know. I think that was probably just a glitch
2 in the selection process. Somebody looked at it, thought it was the same
3 thing, and picked what now I would say was the wrong one.
4 JUDGE HALL: Thank you.
5 Mr. Krgovic, there appears to me to be an irresistible logic to
6 what Mr. Hannis is suggesting. We just substitute the incomplete
7 document for the complete one. Do you have a problem with that?
8 MR. KRGOVIC: [Interpretation] Yes, Your Honour, it's a problem
9 that's in principle. That's what I was talking about. This is new
10 evidence that pursuant to the instructions of this Trial Chamber should
11 not be admitted. This is a principled objection. The Prosecution had
12 the document, it was on its list, and it did not tender it, and it did
13 not provide a valid reason why they did not do this. And that is why I
14 believe a precedent like this, no matter how logical it might seem, would
15 open the door to the admission of similar documents in the future.
16 [Trial Chamber confers]
17 JUDGE DELVOIE: Mr. Krgovic, what would be new about it? You say
18 it's new evidence.
19 MR. KRGOVIC: [Interpretation] It's a new version of this
20 document. I don't have a problem with old documents in the record for
21 them to stay in the record, that would be sufficient for me, and the
22 Prosecutor has the testimony of this witness.
23 [Trial Chamber confers]
24 JUDGE HALL: The Chamber is satisfied that the document that has
25 been marked for identification should now be entered in substitution
1 for -- thank you, for P682.
2 [Trial Chamber and Registrar confer]
3 JUDGE HALL: And we vacate -- sorry, what was that number again?
4 P2394. Thank you.
5 MR. HANNIS: Thank you, Your Honours.
6 Q. Mr. Jankovic, I now want to turn briefly to a document about
7 Prijedor SJB. This is tab 74 in the binder. It's Exhibit P657 and I
8 think it will work best if I can give you a hard copy because it's
9 several pages. I will tell you as it's coming around, this is a report
10 from Chief Drljaca to Banja Luka and to the -- I guess to Banja Luka at
11 least, June 1992, and it's a report on activities in the first half of
12 1992. And the first point I want to ask you about is page 2 in e-court
13 in English and B/C/S. And for you, witness, it's that left-hand page on
14 the table in front of you, the bottom paragraph. Yeah. I think just
15 above that paragraph there's a reference to the take-over of power by
16 force which was carried out on 29 April without a single shot being
17 fired. Do you see that? It's above that paragraph about eight lines up.
18 You find the date 29 April.
19 A. Yes. It says:
20 [As read] "The incident of the 29th and beside that extremists
21 from the ranks of the HDZ have totally prepared to take absolute power
22 over and engage in unprecedented terrorism against the Serbian population
23 which necessarily resulted in intensive and continuous preparations for a
24 take-over of power by force which was carried out on the 29th of April
25 without a single shot being fired and without bloodshed."
1 Q. And two sentences after that it says, "They prevented" -- it's
2 talking about the extremists from other national parties. "They
3 prevented non-Serb SJ employees from signing statements on loyalty."
4 Did you know anything about that about HDZ or SDA extremists
5 keeping non-Serb police employees from signing the new statement of
6 loyalty or solemn declaration as it's sometimes called?
7 A. I don't know. This is too narrow. In the context of what? I
8 don't know if there were any. I don't know. It's -- I'm not aware of
9 them. Perhaps there were.
10 Q. Okay.
11 A. He's talking now about the taking over of power of the 29th of
12 April and that the extremists prevented that. When? Before or after?
13 When? Nothing is clear to me. And I don't remember any of that. I
14 don't know.
15 Q. Okay. Let me take you to something that's more in your field.
16 It's page 4 of the English in e-court. And for you, Witness, it's --
17 well, in e-court it's page 5 of the B/C/S. Yeah. You'll see a section
18 on "work and tasks and maintaining the communications system." I think
19 you've got it there. You see that?
20 A. Page 5?
21 Q. No, I'm sorry. That number -- no, I think you're on the correct
22 page because when I say "page 5," it includes the cover page so it's the
23 page number 4, yeah. And that talks about the kind of work that was done
24 to maintain the communications system. So you guys were working not only
25 in Prijedor but were you also helping assist Dubica, Sanski Most, and
2 A. Yes, yes.
3 Q. Okay. If you could turn to the next page and in e-court we have
4 to go one page further in the B/C/S but stay on the same English. If you
5 could turn to the top of the next page. My English translation says:
6 [As read] "In addition to the above ... activities, a whole
7 number of other individual ones were ... carried out, such as working on
8 power generators and power supply equipment and ... working on the UKT,"
9 ultra short-wave equipment, "in war time conditions ..."
10 And the last sentence says:
11 [As read] "It is necessary to mention that during preparations
12 for military operations, four mobile and three fixed radio stations were
13 fixed using obsolete radio stations and given to users."
14 Did you know about that? Did you participate in that activity,
15 providing four mobiles or fixing four mobiles and three fixed radio
16 stations in connection with preparations for military operations?
17 A. Well, this here is a little bit. If I understood this last bit
18 just a little bit, because Simo is talking about preparations to avoid
19 any unclear matters. What was done? I was definitely, just like all
20 bosses, producing reports for everything and submitting them to my boss,
21 who was Simo at the time. So I would look at my records and all of this
22 that is written here, how many stations repaired, and so on and so forth.
23 And then that would be done and then I don't remember now but due to a
24 general lack of - how should I put it? - lack of -- well, equipment was
25 deteriorating and then perhaps we would repair old equipment that was out
1 of commission. But it was not something that was part of a preparation
2 for a take-over of power. That was part of our regular work. And if
3 Simo - perhaps I don't see this here, perhaps I'm making assumptions
4 about all of this because I don't see if Simo wrote this or not because
5 he maybe saw that as us doing that in some sort of preparation for his
6 coming, perhaps he saw it like that, but it wasn't like that at all. We
7 were just doing that as part of our regular service. And, yes, here he
9 "It is necessary to note that during preparations for current
10 military operations ..." you could see that the technical job that was
11 done was correct that I put in a report that was done, and then when I
12 write I don't usually comment this station was nice, this one was good,
13 this one was no good. I just put the numbers there from the staff that
14 was working on them, how much was done, as you can see on the list. And
15 then you can see that Simo was evidently presenting that somewhere
16 further up as if we were doing some sort of something. This was all done
17 as part of our work. The communications centre could not have been
18 working parallel on two tracks.
19 Q. Okay. Let me ask you a few questions to clarify. That text that
20 we just read out in this report, I'm operating under the understanding
21 that that was written by Mr. Drljaca, not by you; right?
22 A. Yes, yes. His, not mine. My report perhaps has three pages and
23 then he just takes what he needs, numbers and then he puts his own
24 writing in it.
25 Q. I'm assuming these numbers on the previous page about the types
1 of equipment repaired and all those numbers came from you; right?
2 A. Yes, yes.
3 Q. Yeah. But the reason I'm asking you about this reference to
4 preparations for military operations and certain radio equipment in
5 connection with that, is that I can't remember exactly where it was but
6 you were -- you were asked about if you were aware of the Prijedor police
7 being involved in any military operations in the municipality in May and
8 June and you said something along the lines: No, that couldn't be
9 because I would have known about it, because they would have needed my
10 communications support. Do you remember that? Do you remember having a
11 question and answer like that?
12 A. I remember it hazily. Could you be more specific? What do you
13 have in mind? What operation? I'll try to be clearer. If there is a
14 one-time operation, they can ask for communications assets from me and
15 return them following their operation. Now, whether they did something
16 without asking for my equipment is something I no longer remember.
17 Q. Well, I had the impression that you were saying that as far as
18 you knew in May and June of 1992 no police were involved in combat
19 operations in Prijedor municipality because you would have known about it
20 because you would have had to have been involved in communications
21 support. And I took it your answer to mean that all those combat
22 activities in the area of the Muslim villages, Kozarac and Hambarine and
23 Biscani, et cetera, were done by the army with no police. I took that to
24 mean that was what you were saying. Is that what your belief was, that
25 the police didn't anything to do with any of those?
1 A. What you just said is something I believe I said already. I'm
2 trying to recall it now, but from the fact that I don't know you can't
3 conclude that the police did not participate. I'm simply saying that
4 they did not ask for my assistance. There were always pieces of
5 equipment that were constantly used and then if they needed a surplus,
6 they asked. They could have carried out an operation with such pieces
7 without requiring any additional ones. In any case, if they did anything
8 of the sort, I wasn't included.
9 Q. Okay. Thank you. That answers my question.
10 If we could go to page 5 of the English in e-court and,
11 Witness --
12 MR. KRGOVIC: I apologise, but I think that this part of
13 witness's response is not properly recorded. Line -- it's page 61, line
14 from 10 until 17. Witness said something different - it's not recorded -
15 about the -- he used the word "vecim operacijama" [Interpretation] larger
16 operations or more important operations. That part is missing. Could we
17 please have it repeated.
18 MR. HANNIS: [Microphone not activated]
19 THE INTERPRETER: Microphone, please.
20 MR. HANNIS: Sorry.
21 Q. Witness, you heard what Mr. Krgovic said. I understood you to be
22 saying that the police may have participated in combat operations without
23 you knowing about it because they may have been able to use radio
24 equipment that they already had or perhaps that they got from somewhere
25 else. Is that right?
1 A. Not from someone else. They definitely could not receive that.
2 They either had their own or, actually, the ones they were issued
3 with - and I'm the custodian, actually -- however, I only see such pieces
4 of equipment when they break down or when they need to be recharged by my
5 technicians. In any case, I was the boss and in charge of monitoring it
6 all. The police definitely used communication means that they had at
7 their disposal, although I don't know whether these were pieces of
8 equipment that they regularly used or if they needed something on top of
9 that. I don't remember. It could have happened that someone asked for
10 one or two hand-held radios, but it's such a small number that I wouldn't
11 remember it anyway.
12 Q. Okay.
13 MR. HANNIS: If we can go to page 5 of the English.
14 Q. And for you, Witness, it's -- in e-court it's the B/C/S page 7.
15 I think for you, Witness, it's page number 6 at the top. Yeah, I think
16 it's that page. And the paragraph that starts under the bullet point
17 that says 14 charges were filed. It says "in the second quarter," do you
18 find that? "In the second quarter, the take-over of power took
19 place ..."
20 Do you have that?
21 A. Yes, I see it.
22 Q. Yeah. "... and fighting broke out. All Muslim and Croatian
23 officers refused to sign statements of loyalty and some even actively
24 participated in the armed rebellion. Activities were focused on covering
25 the terrain, protecting socially owned and private property and
1 participating in combat operations."
2 So from that I understand that some of the Prijedor police were
3 participating in combat during this time-period prior to Mr. Drljaca's
4 report; would you agree? That seems clear.
5 A. We need to be precise. Who and in what fighting? Do you mean
6 Muslims or Serbs when you say "some"?
7 Q. Well, he's talking about -- the report is about the Prijedor SJB
8 and so he says "... activities were focused on covering the terrain,
9 protecting socially owned and private property and participating in
10 combat operations."
11 I assume he means the Prijedor police were doing that?
12 A. Yes. Keep going.
13 Q. And then it talks about the captured extremists from these combat
14 operations because there were so many three reception centres were
15 established, Omarska, Keraterm, and Trnopolje. My question is about the
16 next sentence. It says:
17 [As read] "All operative officers were engaged in carrying out
18 investigative activities."
19 One question comes to mind. You said your wife worked in the
20 department in economic crimes. To your knowledge was he involved in
21 investigations on Omarska, Keraterm, and Trnopolje? Was she an
23 A. Yes, she was, but she was also the only female among all
24 operative employees. It was probably for that reason that her boss did
25 not send her to Omarska or Keraterm to work. It was quite tiresome even
1 for men. They needed a person in the centre at all times anyway for some
2 small tasks. There were no interrogations or operative treatments there.
3 They simply needed someone who would be there on duty and it was because
4 she was a woman.
5 Q. Thank you. I think that answered my question. She didn't have
6 to go to Omarska or Keraterm or Trnopolje in 1992?
7 A. According to the rules of service, she should have. But she did
8 not have to thanks to her boss. She wasn't made to go.
9 Q. Thank you. I think that's all the questions I had for that
11 JUDGE HALL: Mr. Hannis.
12 MR. HANNIS: Yes.
13 JUDGE HALL: As you move on, appreciating that you began with the
14 comparative disadvantage of not having had the opportunity to speak with
15 this witness beforehand, the -- do you think that you would, having now
16 spent some time with him on the stand, do you think you would need all of
17 the two hours and 40 minutes that you have left of what you had required?
18 MR. HANNIS: [Microphone not activated]
19 THE INTERPRETER: Microphone, please.
20 MR. HANNIS: I'm sorry.
21 My estimate earlier today when somebody asked me I think I will
22 need one session tomorrow. I don't need time beyond the eight hours, but
23 I think I may need my full eight hours. I suppose I might finish in an
24 hour tomorrow. I know I have two particular topics and documents that I
25 want to cover tomorrow that are the most important remaining things and
1 I'll try and do everything else between now and 1.45.
2 JUDGE HALL: Thank you.
3 MR. HANNIS: Thank you.
4 Q. Witness, I want to show you now another document regarding
5 Mr. Drljaca. It's tab 30, but before I bring that up, though, let me ask
6 you this: Do you remember when Mr. Drljaca left the Prijedor SJB and
7 took up a position in the office of the Ministry of the Interior? Did
8 you know that? He held a position in I think the office of public
9 information? Did you know about that?
10 A. I don't know what he did, but I do know he was replaced. He was
11 no longer in Prijedor but in Bijeljina. I don't know what he did there,
12 though, and he did return later on. He wasn't away too long, but I don't
13 know what he did there. As far as I remember, Bogdan Delic was the
14 station chief in the interim period. It's been quite a long time ago and
15 many people rotated. I think it was Bogdan and I'm sure the other was in
16 Bijeljina, although I don't know what he did there.
17 Q. Okay. But in Bijeljina it was with the police, it was a job with
18 the police, with the Ministry of the Interior; right?
19 A. I suppose so.
20 Q. Okay. And he returned to be the chief in Prijedor, at least by
21 sometime in 1994, he was again the chief; right?
22 A. Yes, he did return and again he was the chief. I think it was
23 when I was on sick leave. I did used to see him, but I can't be specific
24 as to the dates.
25 Q. Okay. Do you remember when you began your sick leave in 1994?
1 A. In 1994 it was definitely sometime in March. I would have to try
2 and recall it all. I was in the hospital for a month and then there was
3 a recovery period of 40 days. There was an operation in June, but all
4 the medical checks they had to do took quite a long time. I think
5 sometime in March, in the spring of that year.
6 Q. All right. I think the document I have that reflects him back as
7 chief in Prijedor is from April of 1994, so you may not know about that.
8 And speaking of Mr. Drljaca, you mentioned Tomasica as a place you had to
9 drive by sometimes when you were travelling from Prijedor.
10 A. Yes.
11 Q. It's my understanding there is a mine there?
12 A. Yes.
13 Q. Did you ever hear about hundreds or thousands of Muslim bodies
14 having been placed in the Tomasica mine in 1992?
15 A. How would I know that?
16 Q. Well, it seems like --
17 A. One doesn't hear such things, and even if you do you don't want
18 to listen to it. Who killed whom where and what they did with them. If
19 I heard such a thing, I forgot it on the spot. But I'm pretty sure I
20 have never heard this.
21 Q. If we could look at 65 ter -- no, I'm sorry, tab number 143,
22 Exhibit P1767. And, Witness, I think I need to give you a hard copy of
23 this one. You will not have seen this before I'm sure. I will tell you
24 this is an excerpt from what's been identified as a diary of
25 General Mladic from 1993 and the entry we're looking at is from the 27th
1 of May, 1993, and I would like to go to page 4 of the English and page 4
2 in the B/C/S in e-court. And this is Colonel -- at the bottom of the
3 fourth page for you it's got that little green stickie on it. Yeah --
4 no, go back, go back one page. Yeah. The bottom left page you'll see is
5 highlighted in pink. It's Colonel Bogojevic speaking apparently and he
7 "4 to 5 days ago Simo Drljaca arrived, the former Chief of
8 Prijedor SUP, sent by the minister of the RS and he came about the
9 Tomasica mine."
10 And you have to go on to the next page in English and B/C/S:
11 " ... near Prijedor, where earlier they had buried around 5.000
12 Muslims bodies. I'm sure the world knows about this from the released
14 "Drljaca came to leave this with us and they want to get rid of
15 it (by burning, grinding, or some other way).
16 "There are all kinds of bodies and they have involved Subotic,"
17 who I believe is a reference to the minister of defence Bogdan Subotic.
18 "The team includes Drljaca, he was in charge even while this was
19 being done, at the meeting were General Subotic, Arsic, Drljaca, me, and
20 Mile Matijevic from the BL SUP."
21 So you never heard any rumours about this, about bodies in the
22 Tomasica mine?
23 A. To tell you the truth, I hear about something like this for the
24 first time in my life, about Tomasica. I never came across a number of
25 5.000 corpses. It's an enormous number. I would have remembered
1 something of that sort. I didn't hear of any much smaller numbers, let
2 alone 5.000. It would involve columns of trucks. I don't believe this.
3 If Simo did, there must have been reasons for it. But as for the entire
4 entry, it's something I have never heard about. The number of 5.000? No
5 way. It must be a hundred times over whatever it could have been.
6 Q. Well, did you ever hear of any smaller number of bodies of
7 Muslims being in the Tomasica mine?
8 A. Yes, not in Tomasica but, for example, what we mentioned a moment
9 ago, Koricanske Stijene, and the figure of 50 or 80. I heard about such
10 figures in different situations, but not 5.000. Not in my life. I don't
11 think even in Jasenovac there were as many people killed. I have never
12 heard of Tomasica being mentioned in this context. I know there was a
13 mine there.
14 Q. Okay. Thank you. Next I think I need to go back to one
15 log-book. I think you and I like to do that, but I'm not sure anyone
16 else does. I'd like to hand you tab 128.
17 A. I was hoping you lost them along the way, but you kept them it
19 Q. I think you're not the only one that was hoping that. I'm sorry,
20 I do want to show you this one if I may.
21 And I'll have the usher hand you a hard copy. And let me just
22 find the correct starting page for you. This is Exhibit P1025. And can
23 you tell us from the cover page anything about what it is? It simply
24 seems to say "book 91, 92, 93, 94."
25 A. I think archaeologists would be better suited. I don't remember
1 this book. Perhaps if I opened it I might be able to see something more.
2 Q. Okay. If you could go to the page I've marked, we'll look at
3 some of the documents listed in there and that may help you identify what
4 it is, the yellow tab at the top will take you to 1992. That's page 86,
5 I believe, in e-court in the B/C/S. And it's the first page in the
6 English translation.
7 MR. ZECEVIC: I'm sorry, I think the witness is having problems
8 with the clip.
9 MR. HANNIS: He's got it off now. Thank you.
10 Q. Do you see that, "1992"? I believe you were shown this book or
11 parts of this book --
12 A. Yes.
13 Q. You were shown parts of this book during the OTP interview by
14 Mr. Yarmah and Ms. Beausey and you were able to identify some of the
15 handwriting. Now, I'm not so interested in the first part of the year
16 when Mr. Talundzic was the chief. If you could begin by looking at --
17 well, first, before I take you to the first entry I wanted to ask you
18 about, could you go to the last page for 1992, which as you page through
19 you will see the last entry is numbered 828. So if you're reading the
20 numbers in the left-hand column, can you go until you get to 828, which
21 is 118 in e-court in the B/C/S and the last page of the English.
22 A. Very well. I understand it.
23 Q. And at the bottom --
24 A. I found it.
25 Q. Okay. At the bottom we see a -- some writing and a date and what
1 appears to be a signature. Do you recognise any of that?
2 A. This looks like MT, Mira Topic. But I don't remember her
3 specific signature. I'm also looking at the hand-writing. All things
4 put together it should be her. I think it's her handwriting and the
5 initials could be MT, Mira Topic, but otherwise she didn't use to sign
6 documents much. She was a secretary.
7 Q. Okay. I understand. I think when you looked at this document
8 before you identified some of the handwriting in this as being
9 Mira Topic's, but there was a portion where you indicated that some of
10 the writing appeared to be by some of your communication people. I would
11 like you to look first at page -- or for the entry that is number 300
12 and --
13 A. Which one?
14 Q. 302. And that's --
15 A. I couldn't have said that it was our signalsman. I don't
16 recognise this handwriting --
17 Q. No, right now I just have a question about --
18 A. 302?
19 Q. Yeah, right now I just have a question about some of the
20 abbreviations. Under the column "from" it says MUP of the SRBHSSR. Do
21 you know what SSR stands for in that context?
22 A. SRBH MUP, the Ministry of the Interior, the Socialist Republic of
23 Bosnia and Herzegovina. It was the official title before the multi-party
24 elections and the new constitution. That was in SFRY.
25 Q. And there's a column for urgency and it's column number 6 and
1 then column number 7, system. I think you've explained about some of the
2 designations, but I just want to be clear. The DX, that stands for
3 non-urgent; is that correct?
4 A. You're not correct. You were rushing along, so I will repeat.
5 O, DD, DX, and B are urgent. The rest are usual dispatches or ordinary
6 ones. DX in terms of context are separate. These are urgent operative
7 measures. If someone stole a bicycle or raped a woman or hit someone
8 with a car and fled, then such information would be included in DX
9 dispatches. The contents defined that type of dispatch and the dead-line
10 was two hours. DD and very urgent, these are state matters, say if there
11 was an attack.
12 Q. Okay.
13 A. These are designations for urgency depending on the type of
14 information they contain. DX, urgent operational measures.
15 Q. And the -- in the next column we'll see either I think one of
16 three designations, either O, which I understand means open; Sh, which
17 means coded; and very urgent is another designation?
18 A. There were two designations, depending on the urgency and
19 confidentiality. Both contained O's. In the first one it means plain;
20 in the second case it is open. You can have an OO dispatch, which is the
21 lowest on the list in terms of importance. They could take the most time
22 and were of least relevance. A double O would mean plain open. However,
23 they could all be coded and they could all be open. The very urgent
24 dispatches were regularly coded. DX, for example, could be very urgent
25 but open.
1 Q. If you could go to page -- in e-court the B/C/S is page 92 and it
2 has the first entry at the top as number 176, which in e-court the
3 English is page 7. Do you recognise the handwriting on that page,
4 Mr. Jankovic?
5 A. Just one moment, 199 --
6 Q. 176.
7 A. It's in the same year; right?
8 Q. Yes. 176 at the top of the page.
9 A. All right. 176.
10 Q. Can you look at that and the following four or five pages and
11 tell me, is that the writing of Mira Topic or someone else?
12 A. That first one definitely is not, but I cannot remember who it
13 is. I don't know. I know as much as you do. When you look at the two
14 handwritings, they're not the same, no.
15 Q. Okay.
16 A. It's not as far as I can see. I could be wrong.
17 Q. And if you would continue on to page 98 in e-court in the B/C/S
18 and go to document number 320 and in English in e-court that's page 13.
19 Do you find that one?
20 A. I think that's it, 2266, is that it?
21 Q. That's it, that's it. The top five or six entries appear to be
22 by someone else, and from number 332 on, that looks like the writing that
23 we've come to associate with Mira Topic; do you agree?
24 A. Well, that's what it looks like to me too.
25 Q. And from what -- take all the time you need and if you want you
1 can take this home with you at the end of the day. But would you take a
2 look at the nature of the dispatches and in the right-hand column the
3 indications as to who signed for it or for who it went and tell me if you
4 can draw any conclusion about whose book this was, who kept this book,
5 and what it is. Is it incoming documents? Is it outgoing documents? Is
6 it a book that was in your comms centre or was it a book that Mira Topic
7 kept in the chief's office, if you can say based on looking at the
8 documents. And if you want more time, we can set that aside and you can
9 take it home with you when you go home this evening and tell me in the
10 morning or if you think you only need a couple of minutes right now, we
11 can do it right now. I leave it up to you.
12 A. I leave here so tired, I don't recall when I felt so tired the
13 last time, when I was taking my final exams at school or university. So
14 perhaps we can have an extra ten minutes and we can finish that together
15 with the Prosecutor. So I might have a tendency to go off on a tangent
16 and perhaps if we go through this by talking, point by point, then I can
17 deal with that. Otherwise, I have to worry about if I take the document,
18 where would I take it, what would I do with it. Perhaps then we can just
19 have your permission to stay just ten minutes longer and just complete
20 this right here. I mean, if I have to, I will take it with me. I would
21 put it somewhere.
22 Q. Okay. The reason I ask was maybe I should go back and look at
23 your OTP interview because I know it was shown to you and talked about
24 with you and maybe if I can point you to some parts of that interview
25 that will refresh you memory. That might be a more efficient way to do
1 that. I can do that in the morning. I can go home, even though I'll be
2 tired too, because this is hard work for both of us, I think and try and
3 identify those parts that will make it easier. Let's do it that way
4 because I know at this time of day, I think both you and I were a little
5 tired yesterday and I'm starting to feel that way now. Is that all
7 A. Yes, that is better. But I would like to say something else what
8 is most tiring to me here. Right now, this third time at the Tribunal, I
9 am getting the most tired. Why not? Because I gave several statements
10 to the same circumstances and now I'm afraid, because I'm tired, I might
11 not say exactly the same thing and I don't want it to be -- to seem as if
12 I was not telling the truth or anything like that. But in any case my
13 intentions are not bad.
14 Q. I understand that and I believe that's absolutely true. I know
15 you're meticulous and you've expressed several times, not only here but
16 in your prior testimonies and in your interview, that it's important to
17 you not to make a mistake. So I understand that and I don't want to push
18 you into a situation like that. Do you want to go on for another 10 or
19 15 minutes today or would you like to recess now?
20 A. Whenever you wish.
21 Q. Okay. Let me then go away from that document for now and I'll
22 take you to Exhibit P1615. It's tab number 4. And let me actually skip
23 over that one and go to tab 5, that's more important. Witness, tab 5,
24 Exhibit Number P531. And I'll hand you a hard copy because it's two
25 pages. I'll tell you as that's coming around to you, it's dated the
1 23rd of March, 1992. We need to get the -- yeah. It's from
2 President Radovan Karadzic to all municipal presidents, I guess SDS
3 presidents. And in paragraph 2, it says:
4 [As read] "Assessing that an important condition for the
5 protection of the Serbian people in the current situation is the rapid
6 and timely transmission of data and information of significance for
7 defence and security, and the passing on of decisions, directives, and
8 instructions from the administrative organs, we have established a
9 Republican Operations Centre and have decided that, besides the district
10 centre in Banja Luka, municipal centres in other areas will assume the
11 role of district centres."
12 I think you told me before you had not heard of the republic
13 communications centre or how about this term, the republican operations
14 centre --
15 A. [No interpretation]
16 THE INTERPRETER: Interpreters kindly ask that the witness repeat
17 what he said.
18 MR. HANNIS:
19 Q. I'm sorry, I talked over you. The interpreters ask if you can
20 repeat your last answer.
21 A. I never heard of it. I'm looking at this paper and seeing this
22 for the first time. This is the first time that I'm hearing about this
23 operations centre.
24 Q. Okay. If you would go down two more paragraphs it says:
25 [As read] "The district centres in Banja Luka, Trebinje, Sokolac,
1 and Bijeljina are already linked with the Republican TT, telephone and
2 telegraph centre, and by radio link, while the district centres in
3 Sekovici and Petrovo will be connected by 26 March 1992."
4 Did you know about this communications system in March of 1992?
5 A. No, no. I didn't know anything about that.
6 Q. Let me show you another document that may relate. This is tab 69
7 in Exhibit P1725. I think you can work off the screen on this one. It
8 will be up in a minute and you should see it's dated the 18th of June,
9 1992, from Minister of Defence Colonel Bogdan Subotic. It's addressed to
10 the ministries of the government advising them that:
11 [As read] "The communications centre at Pale can send telegrams
12 to the Serbian Autonomous Region of Bosanska Krajina and to other Serbian
13 autonomous regions, which can be used for notifications and requests."
14 Did you know about that communications system which apparently
15 was associated with the government or with the Ministry of Defence?
16 A. First of all, it's not defined here what communications centre?
17 Communications centre is the official name and it's known who that refers
18 to, the communications centre of the Ministry of the Interior and this is
19 some communications centre at Pale. This is an amateur thing. Which
20 communications centre? I never heard of a communications centre in Pale
21 through which us communications personnel were supposed to -- I don't
22 know, what sort of a communications centre in Pale? This was municipal,
23 military, police type of centre? I don't know what it refers to. We had
24 nothing to do with it. I said at the time that they -- my operators had
25 some phone number which if they managed to get through, they did; if
1 not -- this was a number to Pale. So sometimes it would succeed and
2 sometimes not. It did not matter.
3 Q. Okay. You talked about --
4 MR. KRGOVIC: I do apologise.
5 MR. HANNIS: Sorry.
6 MR. KRGOVIC: There is one mistake in the transcript. 77,
7 line -- paragraph -- no -- page 77 and line 2 and 3. Because what was
8 recorded was it was said -- 5 and 6.
9 "This was military, police type of centre," but that's not what
10 the witness said.
11 MR. HANNIS:
12 Q. Mr. Jankovic, did you hear that. The transcript says:
13 [As read] "I don't know what sort of a communications centre in
14 Pale? This was military, police type of centre."
15 Is that what you said or did you say something different?
16 A. No, no. I said the first line right away after the heading it
17 says the communications centre in Pale is possible. Everything else to
18 me makes no sense. If you don't know who it is, then I don't care what.
19 You know, communications centre, communications centre of what?
20 Military? Police? The ham radio operators? We had ham radio operators
21 during the war. I don't know. So for me, that means nothing. Had I
22 received that then -- I am seeing this paper now for the first time and I
23 have nothing to say now other than what I have already said. If there is
24 no name, then it's nothing, that communications centre has no name,
25 communications centre in Pale. Only God knows what could have been in
1 Pale. Said the MUP communications centre, the CJB communications centre,
2 the communications centre of the police in Pale, then I would have known
3 what we had here, but this I have no idea. So it makes no sense to make
4 any further assumptions.
5 Q. I take it then that you weren't aware of the provision under the
6 Law on Defence from 1 June 1992 in the Republika Srpska provided that the
7 Ministry of Defence was to establish communications for the purposes of
8 command and control in the case of war or imminent threat of war. Did
9 you know about -- okay.
10 A. No, no.
11 Q. Did you know a Mr. Vukovic who worked in the republican centre
12 for that body that you described in Prijedor that dealt with the early
13 warning system for disasters and floods and sounding the air-raid siren,
14 that kind of thing? Did you know that there was a central office for
15 that organisation in Pale?
16 A. I didn't know. It's possible that it was there and possibly it
17 was not -- I did not convey any information to them. I don't know. I
18 don't know Vukovic. There are a number of Vukovic's. The only Vukovic I
19 knew was an engineer who worked in Banja Luka in the state security
20 before the war -- security, Vukovic, Drago, I think.
21 Q. No, different guy. What about -- did you know a Nebojsa Savic
22 who had some dealings in working with communications?
23 A. I knew something. He was a ham radio operator. Before the war
24 he worked in the SUP of Sarajevo. He was a policeman before, then he
25 joined communications, I don't know when, then he was this guy who writes
1 the dispatches like those guys of mine, Sarac and others. And then
2 shortly before the war he went into the maintenance and repair of radio
3 equipment. And all of that was as part of the Sarajevo city SUP.
4 Q. Okay. You weren't aware of any work he did in setting up a
5 clandestine communications system for the SDS before the start of the war
6 in 1992? Did you know anything about that?
7 A. Before the war? No, I don't know what he could have done. He
8 was a ham radio operator, that's true. But I don't know what he was
9 doing in Sarajevo. I have no idea.
10 Q. In Prijedor after the 30th of April, 1992, during 1992 did you
11 ever have any occasion to try to communicate directly with MUP
12 headquarters, whether it was in Pale or somewhere else in Sarajevo or in
13 Bijeljina? Did you have any direct communication with them in 1992?
14 A. I gave the example earlier of that director, the Laki [phoen]
15 award recipient. I didn't really talk about that. After the 30th of
16 April, a large number appeared in schools and all over the place of those
17 who wanted to be directors. For example, a Muslim was a director before
18 so others wanted to be directors. And so one of them addressed me, I
19 didn't know him before, his name was Milenko Vracar, I think, if he could
20 send a fax to Pale to the ministry, their Ministry of Education, so that
21 they would agree that he could be a director. He was brought by some guy
22 from the SDS Dusko -- I don't know what his name was. Well, it doesn't
23 matter. I knew the person from security who had brought him. And
24 knowing that these communications were not really going well, not
25 operating, and I said: Well, there's no chance. But then I thought I
1 don't want to refuse you so just leave that paper and we will send it.
2 And can you imagine, he had the luck and in about two or three minutes
3 there was approval for him -- that came back for him to be a minister --
4 no, I mean, not a minister -- I mean, it was like winning the lottery as
5 far as I was concerned. So judging by his example, we concluded that the
6 communications were really working. Sometimes it would take a few days
7 for something to get through to Pale, but in his case it was very quick.
8 So the communications went through very poorly, but then again you have
9 this factor of probability. Some important things did not get through
10 and something that was not important did. And there you have it.
11 Q. Thank you, witness.
12 MR. HANNIS: Your Honours, I know it's five minutes early, but I
13 think this would be a good place for me to break, organise myself and try
14 and finish everything else in one session tomorrow.
15 JUDGE HALL: So we resume at 9.00 tomorrow in this courtroom.
16 --- Whereupon the hearing adjourned at 1.38 p.m.,
17 to be reconvened on Friday, the 14th day of
18 October, 2011, at 9.00 a.m.