Tribunal Criminal Tribunal for the Former Yugoslavia

Page 25017

 1                           Friday, 14 October 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.04 a.m.

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

 6     everyone in and around the courtroom.  This is case IT-08-91-T, the

 7     Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Thank you, Madam Registrar.  Good morning to

 9     everyone.

10             May we have the appearances, please.

11             MR. HANNIS:  Good morning, Your Honours.  For the Prosecution,

12     I'm Tom Hannis along with Sebastiaan van Hooydonk.

13             MR. CVIJETIC: [Interpretation] Good morning, Your Honours.  On

14     behalf of Mico Stanisic, Slobodan Cvijetic and Ms. Deirdre Montgomery.

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

16     Miroslav Cuskic appearing for Zupljanin Defence.

17             JUDGE HALL:  Thank you.

18             And could the witness be escorted back to the stand, unless there

19     is --

20             MR. HANNIS:  While he is coming in, Your Honour, just regarding

21     scheduling.  I said yesterday I thought I would finish at the end of one

22     session.  Having assembled my notes last night and finding a couple

23     things I missed, I may request an additional 20 to 30 minutes.  I'm still

24     confident that we will finish this witness completely today, and we may

25     finish early.  We may finish an hour early, we may finish by noon, but in

Page 25018

 1     that regard I've had discussions with Mr. Krgovic about the next witness

 2     and I think he's not feeling particularly well, and we would prefer not

 3     to start the next witness until Monday if that's agreeable with the

 4     Trial Chamber.

 5                           [Trial Chamber and Registrar confer]

 6             JUDGE HALL:  And, Mr. Hannis, we are advised that you would still

 7     be within your eight hours even with the extension, but the important

 8     thing is that this witness is finished today.  Thank you.

 9                           [The witness takes the stand]

10             JUDGE HALL:  Mr. Jankovic, good morning to you.

11             THE WITNESS: [Interpretation] Good morning.

12             JUDGE HALL:  As usual, I remind you of your solemn declaration

13     before I invite Mr. Hannis to continue.

14             MR. HANNIS:  Thank you, Your Honour.

15                           WITNESS:  MILOS JANKOVIC [Resumed]

16                           [Witness answered through interpreter]

17                           Cross-examination by Mr. Hannis: [Continued]

18        Q.   Good morning, Witness.

19        A.   Good morning.

20        Q.   I wanted to start this morning with just a brief question about

21     the time-period between the take-over by the Serbs on the 30th of April

22     and the attack on Prijedor by Muslim forces on the 30th of May.  On

23     Tuesday when talking about that, you mentioned that when you were

24     providing some additional information you said:

25             "This is connected with the attack itself.  If I talked only

Page 25019

 1     about it, then it would seem that it came out of the blue, and that's not

 2     true.  There were preparations ongoing."

 3             And you went on to talk about seeing Dr. Sakovic or Sadikovic,

 4     I'm not sure what name is in the transcript here.

 5        A.   Sadikovic.

 6        Q.   Yeah, travelling up the -- every day the hill so that the Muslims

 7     would organise themselves.  I want to show you a document that I think

 8     relates to that.  It's Exhibit P653, tab 41 in the Prosecution binder.

 9     Can you read that on the screen all right or do you need a hard copy?

10        A.   Yes, I can.  I can read this copy.

11        Q.   And you'll see this is dated the 18th of May, 1992, from Chief

12     Drljaca to Banja Luka, and apparently it's reporting on I would -- what I

13     would call intelligence about the Muslim forces and what weapons they

14     might have.  So that seems to kind of support what you were saying that

15     there were preparations ongoing by the Muslims, but it also indicates

16     that Prijedor SJB was monitoring the situation.  Would you agree with

17     that?

18        A.   Before answering, I'd like to say the following.  You mentioned

19     the last name of Sadikovic and failed to mention the first name.  There

20     were two Sadikovics.  Two days ago I mentioned

21     Avdo Salihovic [as interpreted] who worked alongside my wife but this is

22     not the Sadikovic.  The one who was an inspector whom I mentioned in the

23     context of the police, that is Avdo Salihovic in the police.  The other

24     one was a physician, Eso Sadikovic, and they seem to be holding him in

25     high regard these days.  When I said that Sadikovic went across the

Page 25020

 1     bridge and up the hill, I didn't mean the policeman but the doctor, just

 2     in order to avoid any confusion.

 3             Let's go back to what you asked me about initially.  Let me have

 4     another cursory look.  I was listening to your question but let me just

 5     go through the dispatch briefly.

 6             Can you tell me exactly what is it that you want me to discuss,

 7     just your question briefly.

 8        Q.   No -- your previous answer that we talked about, you were saying

 9     preparations were ongoing, and I'm saying this document suggests to me

10     that the police in Prijedor were aware that the Muslims were preparing

11     something.  And this is an example of the fact that they were trying to

12     keep an eye on them and know what was going on.  Would you agree?

13        A.   Yes.  They both knew, both sides.  Let me give you an example.  I

14     just thought about it the other day.  It resembled when the United States

15     and the Soviet Union were trying to reach the moon first.  They both knew

16     they were on the right track, but they couldn't exactly pin-point how far

17     ahead each of them was.  We all knew -- well, conditionally I say "we all

18     knew," I mean the people knew that there were preparations underway, but

19     there was no direct communication between the sides.  One could observe

20     the preparations, but I don't think anyone had complete information about

21     the other side.

22        Q.   I accept that.  I think you mentioned also in the communications

23     centre before the attack on the 30th of May, you were hearing some --

24     over the radio some information about negotiations that were going on

25     between the Serbs and the Muslims.  Is that right?

Page 25021

 1        A.   I didn't say that.  What I did say is that on the 9th of April,

 2     the chief arrived and he summoned the two of us.  I don't think I ever

 3     said that I listened to the radio.  I know that he gave them the task of

 4     broadcasting that and I could hear it, but that's it.

 5             MR. KRGOVIC:  There is a problem with the interpretation, so can

 6     Mr. Hannis pose the question again.

 7             MR. HANNIS:  Okay.

 8        Q.   It was my understanding that you had said earlier between --

 9     between the 29th of April and -- or the 30th of April and the 30th of May

10     that in the communications centre on occasion you overheard some talk on

11     police radio about negotiations that were going on between the Serbs and

12     the Muslims; is that right?

13        A.   Yes, but I wasn't clear about your initial question.  When you

14     said "radio," I thought you had in mind the radio station in Prijedor,

15     but this is the ultra high frequency radio waves of the police.  I wasn't

16     listening in all the time --

17        Q.   [Previous translation continues]...

18        A.   -- I don't know what exactly you want me to explain.

19        Q.   No, that's all.

20             MR. HANNIS:  Thank you, Mr. Krgovic.

21        Q.   But speaking of Radio Prijedor, I think you told us you don't

22     have a radio at home and you didn't listen to the radio in 1992, 1993,

23     1994?

24        A.   Yes, at home.  But I never turn it on.  I have one in my car, but

25     I usually listen to music.

Page 25022

 1        Q.   I take it then you never heard a radio broadcast in 1994 where

 2     Simo Miskovic, the former SDS president, president of the municipality,

 3     talked about the events regarding the take-over on 30th --

 4        A.   Simo Miskovic.

 5        Q.   Yeah.  You didn't hear him on Radio Prijedor talking about the

 6     take-over and that happened on May 30th?

 7        A.   No.  Definitely not.

 8        Q.   Now I want to ask you about Keraterm and Omarska.  At page 24815

 9     you mentioned that after the attack on the 30th of May a number of

10     Muslims had been taken prisoner, and pretty soon the numbers were so big

11     that there wasn't room to keep them in the detention facilities available

12     in Prijedor at the SJB.  And Keraterm and later Omarska were used for

13     that purpose.  I have a question based on something you said when you

14     testified about this in the Stakic case.  Do you remember testifying in

15     2003 in the Tribunal here in Mr. Stakic's trial?

16        A.   I do remember being at the Tribunal, but I no longer remember

17     what I said then.  Perhaps you can jog my memory.  In any case, I always

18     try to say what I think and what I know.

19        Q.   Okay.  Fair enough.  At page 10695 on the 20th of January, 2003,

20     you were asked by I think the Defence lawyer, Mr. Lukic:

21             "Was an investigation centre set up because of the increased

22     numbers of detainees, that is, Omarska and Keraterm?"

23             And your answer was:

24             "Yes, I know that they were set up.  I didn't participate in

25     that.  I don't know who set them up and how, but yes, at that time, they

Page 25023

 1     were set up.  Personally I didn't believe that that was the reason for

 2     setting that up -- for setting them up, but I can't tell you."

 3             My question was:  Why did you not believe that was the reason for

 4     setting them up?  What did you think the reason was?

 5        A.   First of all, I believe you when you say that this is what's in

 6     the transcript.  First of all, I no longer remember what I said, but I do

 7     believe it is true and I maintain that opinion.  I can repeat everything

 8     I said then and then we can go back to what you mentioned.  First of all,

 9     I don't know what I said then.  I never read the transcript.  I do know

10     that the opinion I had then has not changed.  Nothing influenced any

11     change of that opinion.  I know that neither at the time nor nowadays

12     anyone tried to influence my opinion, any of the parties here.  I have no

13     reason to tell you something that is not true.  Given all that and given

14     the fact that my opinion has not changed, I can tell you that -- I'll try

15     to be more precise so do bear with me.  Maybe I'll go off on a tangent

16     and you can bring me back.

17             First of all, why were there no arrests before the attack on

18     Prijedor?  There were only a few arrests, but there were no collection

19     centres in existence yet.  Whatever premises existed before were used at

20     that time until the 30th of April -- sorry, May, when the attack on

21     Prijedor occurred.  What happened then?  There was the attack and the

22     army arrived driving those Muslims out, those who had attacked.  I saw

23     women and children going the other way led by some Kiki, the barber, he

24     was asking for assistance.  So there were no gathering or collecting of

25     population en masse.  I could hear fighting in the distance, but close to

Page 25024

 1     the market, which doesn't really tell you much, anyone who knows Prijedor

 2     knows what I'm talking about, I could see a hundred women and children

 3     coming there, not small children but teenagers I would say.  So they were

 4     moving.

 5             Following that I could observe -- I wasn't informed because there

 6     were no collegium meetings.  Decisions were being made at lower levels

 7     and this is what I could observe in the field.  The extent of my

 8     inclusion was, for example, Simo arriving telling me, "Go and set up a

 9     phone line in Keraterm," and I did.  The network was down and I didn't do

10     that directly because it was part of the work of the telecommunications

11     company.  However, I needed their permission, et cetera, et cetera.  So I

12     was there to provide a service, and I could see a lot of people gathering

13     there.

14             I didn't analyse the situation, but I couldn't go through without

15     noticing.  That is why I know -- let me digress a bit.  When you

16     mentioned Nusret Sivac, we moved on to another topic but there is one

17     thing which is very important.  He is a typical example of some things

18     which took place concerning this context.  Nusret Sivac was taken not on

19     the first day but a few days later.  And then he stayed for one night

20     only and came back or maybe two days and then came back.  Then he spent a

21     period at home and then was taken again and then returned, say, a month

22     later.  It was then that I helped him to go to Germany or wherever it was

23     that he went to.  What does it mean?  It means that they were being

24     processed.  It means that he wasn't taken away the first time around, but

25     he was taken away when information arrived that he should be

Page 25025

 1     interrogated.  After that he was released because I guess their

 2     conclusion was that he was not guilty.  Later on they concluded that he

 3     should be brought in yet again.  Let me try to slow down for the sake of

 4     the interpreters.

 5             And then Sivac left again, which means that there must have been

 6     gauging going on as part of the application of the Law on Criminal

 7     Procedure.  There may have been mistakes, transgressions, people even

 8     being killed.  There was unrest, but another thing.  Why is Nusret Sivac

 9     a typical example --

10        Q.   Let --

11        A.   -- just one moment.  Please bear with me.

12        Q.   All right.

13        A.   Nusret Sivac was a civilian officially, and whoever wants to use

14     his example will say that they didn't only bring in soldiers but citizens

15     as well.  But once I asked Sivac:  "Why were you in the cafe Obala when

16     the attack occurred?"  This was the epicentre of fighting.  And he said,

17     "Boss, I had my own poker machine in the bar.  I came to collect."  It

18     may be true, it may not be true, but he was in the wrong place at the

19     wrong time.  So he wasn't just another ordinary civilian at the time.

20     Now perhaps we can go back to your question.

21        Q.   Well, let me ask another question because what I was trying to

22     understand was what you thought was the reason for these camps being set

23     up.  But let me ask you this:  This is something -- I'm going to read you

24     something that Mr. Zupljanin is reported to have said on July 11th, 1992,

25     at a meeting of the RS MUP senior officials.  This is from Exhibit P160,

Page 25026

 1     tab 77, and he said:

 2             "The army and Crisis Staffs or War Presidencies are requesting

 3     that as many Muslims as possible are gathered, and they are leaving these

 4     undefined camps up to the internal affairs organs.  Conditions in these

 5     camps are bad, there's no food, some individuals do not observe

 6     international norms because, among other things, such collection centres

 7     are not adequate or there are other reasons."

 8             Now, that sounds like a fair description of what was happening in

 9     Prijedor with the setting up of Keraterm and Omarska.  Would you agree or

10     not or do you not have enough information to say one way or another?

11        A.   The last thing you said, the last few sentences when you quoted

12     Mr. Zupljanin.  I'm not 100 per cent familiar with it, but it does

13     partially tally with my opinion.  As for the last thing you asked me

14     about, let me try to explain.  I know I'm trying to tell the truth.

15     Perhaps, though, there may have been a detail that I related to in the

16     sense of expanding and I may have said that.  I'll try to go back and

17     recall what I said or perhaps you can remind me.  I hope I'm not going

18     insane yet, but I don't know exactly what happened.  I am convinced,

19     though, that that was true as is what I'm saying now.  I speak a lot and

20     I don't wrap things up nicely.  And even now I get corrections in

21     rhetorical sense.  I will try again to recall if you can read out the

22     last sentence again.

23        Q.   The last sentence of what Mr. Zupljanin said?

24        A.   Not Zupljanin, what I said in the previous trial.

25        Q.   Yes.  Again, reading from Stakic at 10 --

Page 25027

 1        A.   Just the last thing.

 2        Q.   10695.

 3             "Personally, I didn't believe that that was the reason for

 4     setting them up, but I can't tell you."

 5             And the question that was put to you was --

 6        A.   All is clear.  All is clear.  I understand the question now.

 7        Q.   Okay --

 8        A.   Just a minute.  I'll try.  From this point in time I can see that

 9     the collection centre, as they referred to it, was simply used because it

10     was a larger area where they could exercise their legal authority.  I

11     told you there was a small detention room and then there was a larger

12     area.  And it strikes me as the situation being exactly that.  I guess I

13     said what I said.  No one made it up.  I have no doubts about that.  But

14     I'm trying to say what it was that I was trying to say at the time.  I

15     don't see it.  I don't see the logic.  There -- it's a larger area and

16     the processing continued.  It's another matter in what ways and whether

17     those involved were of sufficient professional background to do it

18     properly.  In any case, at a first glance it seemed that everything was

19     in keeping with the law, but they did have more work on their hands.  I

20     no longer know exactly what I meant when I said that.  Perhaps if I had

21     time to ponder I'd be able to recall and if I do, I'll certainly tell

22     you.

23        Q.   Okay.  Thank you.  Let me ask you a couple more things about the

24     camps from your Stakic testimony.  At page 10698 you were talking about

25     the investigations in Omarska and Keraterm and you said, talking about

Page 25028

 1     Omarska:

 2             "I saw in Omarska our inspectors.  And when I say 'our,' I mean

 3     the employees of the public security station in Prijedor."

 4             And then about eight lines on you say:

 5             "In Keraterm, now likewise, but fewer of them all together, a

 6     fewer number of people."

 7             So if I understand correctly, police inspectors from Prijedor SJB

 8     were working in Omarska and Keraterm in 1992; right?

 9        A.   Yes.  I do believe I said what you just quoted because I still

10     think that way.  When I was in Keraterm, I was by a telephone set and

11     there was somebody coming - was it the Red Cross or UNHCR? - at any rate,

12     the whole thing was a bit window-dressed, if you know what I mean.

13     Everybody appeared in a much nicer light than was the case.  I can't say

14     that everybody enjoyed their stay there because that would not have been

15     the truth, but it wasn't as bad as that.  They spent some 20 minutes

16     there.  I don't know if that day that I spent in Keraterm there was

17     Omarska already as a camp because Keraterm predated Omarska.  I do know

18     that there were larger accommodation premises in Keraterm.  And when I

19     mentioned inspectors I meant, of course, those from the Prijedor station,

20     but there were a great deal of those others who were either members of

21     the army or came from elsewhere and were not members of the SJB Prijedor.

22        Q.   The other inspectors who were not from the army but came from

23     elsewhere, do you know where they came from?  Were any of them from

24     Banja Luka CSB, if you know?

25        A.   Well, I did say that in my last answer, that they were people I

Page 25029

 1     didn't know.  So I would be mistaken now to tell you anything further.

 2        Q.   One other question from your Stakic testimony, the Prosecutor,

 3     Mr. Koumjian asked you at page 10739, he said:

 4             "Sir, it was common knowledge in Prijedor that in July there was

 5     a massacre at the Keraterm camp; isn't that correct?"

 6             And your answer, Mr. Jankovic, was:

 7             "I heard that it had happened.  That's what I heard.  I didn't

 8     witness anything nor did I go there at this time.  Who I heard it from, I

 9     don't remember.  But the way people talked about those things -- you

10     know, at work, no one talked about this.  Everyone just sort of kept

11     silent.  But there was a general sense of horror.  And then whenever

12     someone brought the subject up they would just say, 'Yeah, it happened,'

13     and then people would just be very worried, concerned.  No one was

14     enthusiastic about this."

15             That's what you said then.  Is that still the way you remember it

16     now?

17        A.   I don't recall it at all, but when I do read it now, I see that I

18     explained it much better than I would be able to explain it now to you.

19     Sorry, if you can just look at what I'm motioning now.  This is the way

20     everybody said, motioning to their mouth, as in stay mum.  Don't speak

21     about it.  So that is how everybody motioned, this way.  That was the

22     sort of information that was passed around.  Somebody was there, but I

23     didn't -- it didn't even cross my mind to go and ask who was on the list

24     because I might end up on it.

25        Q.   For the record the motion you were indicating to me is you were

Page 25030

 1     holding up your hand in front of your mouth vertically like this or now

 2     you're holding up one finger, and keep quiet, don't say anything?

 3        A.   Yes, one finger in front of your mouth, and that's a sign for

 4     keep quiet, shut up, and that's what a colleague would say to a

 5     colleague.  I'm not saying it to you.

 6        Q.   Okay.  I understand.  All right.  Continuing on on page 24817 of

 7     our transcript, on Tuesday you mentioned when you went out to Omarska to

 8     install a radio and when you got ready to go back it was already dark.

 9     You said:

10             "The police told me that I couldn't leave at that time because

11     the buses with the detainees were just arriving."

12             So you parked and waited until that operation was completed and

13     then you travelled about midnight back home.  Do you remember

14     approximately when that was?  Do you know the month?

15        A.   That was the first day of Omarska.  Now what date was that?

16     Well, after the 30th of May.  It must have been early June.

17        Q.   Okay.

18        A.   I didn't keep track of dates.  At any rate, the date when Omarska

19     came into being such as it was.

20        Q.   Okay.  Do you remember how many buses of detainees were brought

21     and unloaded that night?  Any idea?

22        A.   I never got out of my car, the Golf I had.  And of course I'm

23     saying "I" all the time, but there was a technician who had been there

24     with me and he followed in my every footstep and he was a driver

25     normally, but this once I was behind the wheel.  And since I expected

Page 25031

 1     that there would be a lot of traffic there, I switched into reverse and

 2     parked by a bus.  I had this Golf, blue one, of the police anyway.  So I

 3     parked behind the bus and darkness was setting in already.  And as I

 4     parked behind the bus, I was out of any artificial illumination because

 5     the building itself had its lighting.  And -- just a moment, let me give

 6     you this one detail.  Let's say this is the gate.  Two buses were parked

 7     in like this, and those that were arriving were passing this way by them,

 8     and I was unable to see who was coming in because I was at the other side

 9     of the bus.  I never saw those who were coming in.  I didn't see where

10     they were coming from, and to tell you the truth I didn't really feel the

11     need to count how many buses there were.

12             I saw at one point a person in a blue T-shirt bolting away from

13     there.  He was fleeing.  And then I heard gun-fire, and that of course

14     caused me to duck, in fact, and stay motionless.  And as I said, I stayed

15     there -- well, I told you about it.  It wasn't midnight, it was before

16     midnight.  I probably came home at midnight.  And let me be precise.  I

17     may have been a bit vague about it the last time.  The prisoners were not

18     done getting off the buses yet and the -- there was this -- next to mine

19     there was this blue police Golf.

20             At one point I could see that the lights were on and a charge --

21     or the commander was in the car.  He started the car and went out of the

22     compound.  I couldn't see but I could sense that he was going out of the

23     main gate and I wanted -- at one point I thought perhaps I should follow

24     him because he had his rotating light on, and I did that.  As I quickly

25     started my car, he was perhaps already 50 metres away from me because he

Page 25032

 1     was driving pretty quickly.  And since I wasn't really familiar with the

 2     area, I came across a junction, an intersection.  There were no houses

 3     there, and I turned left and realised that this was a blind alley because

 4     at some point the road simply disappeared.  And you don't go to Prijedor

 5     through Omarska, or rather, through Kozarac.  And as I missed the right

 6     turn, because I told you there were two turns there, I came across some

 7     farmers there, peasants, and that's where we were mistreated.  That's the

 8     bit that I related.

 9             So I may have seen half or a third or perhaps two-thirds of the

10     prisoners as they were coming out.  It's difficult for me to assess the

11     amount of time I spent there.  And since it was an uncomfortable

12     situation, it seemed to me like an eternity.

13        Q.   And in your answer on Tuesday you said:

14             "The police told me:"  You "couldn't leave."

15             So was it the police who were dealing with the arrival of the

16     buses and taking the prisoners off, do you know?

17        A.   There were all sorts there.  Some of them were members of the

18     local Omarska substation, so I knew them.  There was also Cigo with some

19     of his men.  I'm sure that I saw him for the first time then, and I don't

20     think I ever saw him after that.

21        Q.   Who was he?

22        A.   Sorry?

23        Q.   The name you just mentioned, who was he and who he was working

24     for?

25        A.   It was one of their lot, a villager of Omarska.  I suppose he

Page 25033

 1     worked in the mine, though he did wear a camouflage uniform at the time.

 2     I suppose he was deployed to the front line in Slavonia and it was a

 3     pretty frayed uniform and there were two more men with him.  They were

 4     more of his -- they were more his escorts rather than anything else.

 5     Cigo was swearing at our policemen.  "Why have you come here?  Who is it

 6     you have brought here?  Give us a list.  You don't have a list."  He

 7     wants to kill them.  And he asked me, "Who are you?"  I was in civilian

 8     clothes.  He [as interpreted] said, "I am a communications officer."  He

 9     says, "What the hell are you doing here?"  So I just kind of slunk into

10     my car.  He was shooing everyone away.  I was -- I felt a bit privileged

11     for being a communications officer.  But there you are.  How is it that

12     you can feel in such circumstances?  There were far fewer policemen

13     compared to all manner of individuals who were there.

14        Q.   Okay.  Let me ask you a couple more questions on camps.  I want

15     to show you some documents.  The first one is tab 88, it's Exhibit P668.

16     I think you can see this one on the screen.  It's a short document.

17     Mr. Jankovic, this is -- I'm sorry, could we go to the next page in the

18     B/C/S.  It's dated the 1st of August from Simo Drljaca to Banja Luka CSB.

19     I think you might have been shown it before.  It has a --

20        A.   Yes, but from a different perspective.  We looked at the format,

21     at the heading, and signature.  And I didn't know it then.  I don't know

22     it now.

23        Q.   The information is from Mr. Drljaca that at a meeting on 24 July

24     the War Presidency of Prijedor adopted a decision where the reserve

25     police force that was presently employed should be greatly reduced and

Page 25034

 1     security for Keraterm, Trnopolje, and Omarska be provided by the army

 2     with a dead-line of the 31st of July.  He goes on to say the army refused

 3     to assume security duties which our station supplies with a staff of 300

 4     police officers every day.

 5             Did you realise that there were that many police officers working

 6     at Keraterm, Trnopolje, and Omarska providing security?  Did you know

 7     about that?

 8        A.   I really don't know.  I don't know what the actual numbers were.

 9     But as I'm looking at it, I have this feeling that individuals such as

10     Simo -- well, yesterday I heard about 5.000 a day -- 300?  Well, a

11     station had roughly 120 men at all times, and then Prijedor 2 was a

12     smaller station, under 100 -- well, this means that all of the police

13     force should have been there, which isn't true.

14        Q.   Let me ask you this:  Do you know how many reserve policemen were

15     activated by or after the 30th of April in Prijedor municipality?  Do you

16     have any idea about what those numbers were?

17        A.   It's not just I that don't have an idea, nobody does.  Why?

18     Let's say a commander would take on his neighbour to make sure that he

19     isn't deployed to the front line somewhere, so it changed frequently --

20        Q.   I --

21        A.   -- and I really don't know how it was that they were officially

22     admitted.  There were an official list, an earlier list, that had been

23     agreed to by the Muslims, as I said.  Later on that list was --

24        Q.   I understand.  But you would agree with me, wouldn't you, that

25     the chief, Mr. Drljaca, was in a better position than you were as the

Page 25035

 1     comms chief to know how many reserve policemen Prijedor had because that

 2     was his job; right?

 3        A.   He was a boss.  He was reported to.  Nobody reported to me.  I

 4     was only asked to provide a radio set and a battery.  Regardless,

 5     this yesterday's figure of 5.000, and this today's figure, I don't think

 6     that they are realistic at all from how I viewed the situation.

 7        Q.   Well, we'll look at some documents later and I'll ask you some

 8     further questions.  But for now, if you would just note the number of

 9     this dispatch at the top, 2169, remember that number because I want to

10     show you the next one --

11        A.   Which number?  How would I remember it?  Why?

12        Q.   No, I want you to remember it right now for the next minute

13     before I show you the next document.  Okay.

14        A.   Very well.  2169.  Fine.

15        Q.   Because there's a note on here about --

16        A.   My memory's full already, but all right.

17        Q.   I want to show you tab 93.  This is Exhibit P1682.  And I will

18     tell you, this is dated the 4th of August, 1992, from Chief Zupljanin to

19     Prijedor SJB to the chief.  And you see it says regarding your dispatch

20     11-12-2169/92.  Do you see that?

21        A.   Yes, I do.  11-12-2169 --

22        Q.   Yeah --

23        A.   -- which number is it you're reading?  There's quite a few of

24     them.

25        Q.   No, that's the one --

Page 25036

 1        A.   A moment -- 11-12-2169/92.  Fine.  That's the one from before.

 2        Q.   Right.  And the chief, Chief Zupljanin, says:

 3             "Regarding your dispatch, number above, we agree that, for the

 4     reasons cited in said dispatch, you may postpone the obligation of

 5     co-ordinating the number of reserve policemen ... until further notice,

 6     that is, until adequate solutions are found together with the appropriate

 7     commands of the army of the Serbian Republic in accordance with the

 8     decisions of the War Presidency of Prijedor ..."

 9             So it seems like chief Zupljanin is agreeing in Prijedor

10     Mr. Drljaca doesn't have to reduce the number of reserve policemen yet

11     because they're still needed to do the security duty at Keraterm,

12     Omarska, and Trnopolje until something can be worked out with the army.

13     That's what it means, isn't it?  Is that how you read it?

14        A.   Please, let's not talk about how things seem to me.  You probably

15     know them now better than I did at the time.  What they were doing, what

16     sort of information they were handling, what sort of respect they had for

17     each other, I don't think they had respect -- much respect for anyone,

18     including Mr. Zupljanin.  What was in their mind -- well, I wasn't able

19     to and I'm not able to assume anything.  And to ask me about how things

20     seemed to me now, let me not talk about it.  What it seemed to me is that

21     this was just Simo's rattle.  That's all.

22        Q.   Okay.  But he did inform his chief and request permission to not

23     reduce the police force and Zupljanin wrote back and said "okay."

24        A.   What is your question?

25        Q.   Well, my question is:  Your 65 ter summary that we got from the

Page 25037

 1     Defence indicated that you were going to provide evidence that

 2     Mr. Drljaca was, in effect, acting independently, a lone wolf, not taking

 3     instructions, not reporting to his boss.  And I'm trying to show this as

 4     an example where he is informing his boss of the situation and asking

 5     permission to do something and getting permission.

 6             I guess let me ask you this question:  Is it your permission that

 7     Mr. Drljaca did not follow directions from Mr. Zupljanin or that he did

 8     not report when he was asked to?  And if that is your position, can you

 9     point us to a specific document or example that shows that?

10        A.   I am -- I have the habit of speaking figuratively always.  I see

11     that as my children asking for money but then not asking me what they

12     will spend their money on.  So are they listening to what I have to say

13     or not?  Well, the same was with Simo.  Whenever he needed to relieve

14     himself of the burden of responsibility, then he will consult and ask

15     around.  Otherwise, if he needed something done, well then -- that's the

16     gist of it in my view, if you agree.

17        Q.   I understand what you're saying.  But from --

18        A.   And we can say that what we've been discussing here just now is

19     in that same context.

20        Q.   Okay.  But from how you've described your relationship with

21     Mr. Drljaca, it sounds to me as though you weren't in a position to know

22     exactly when and how often and the contents of whatever all his

23     communications with Mr. Zupljanin were because he could have been talking

24     to Mr. Zupljanin on the phone, he could have sent him communications by

25     courier or directly by some other form of hard copies that you didn't see

Page 25038

 1     in the communications centre.  So you weren't really in a position to

 2     know exactly what happened between Mr. Drljaca and Mr. Zupljanin.  Would

 3     you agree with that?

 4        A.   Well, yes.  Here is an example.  The dispatch 2169, I had it in

 5     my hand and there's my signature.  Now, the dispatch we have on our

 6     screens now was typewritten.  So what was it?  It was a fax.  My

 7     communication links weren't operating and Simo had a Telefax machine as

 8     did the Chief Zupljanin -- I mean, I didn't see it, but if I had one,

 9     then he must have had one for sure.  So evidently the dispatch that we

10     have on our screens now was transmitted by fax.  So I had the question in

11     my hand without ever seeing what the answer was.  So the information I

12     had was inaccurate, incomplete, et cetera, when we're talking about this

13     issue.

14        Q.   Okay.  Different topic.  At page 24823 you told us about the

15     occasion where some -- someone who was I think probably under the

16     influence of alcohol, you said, asked you for your ID, thought you were a

17     Muslim.  He fired a shot at you, actually.  You remember that, I'm sure?

18        A.   Yes.

19        Q.   My --

20        A.   Of course.

21        Q.   My question is:  You didn't report that crime to the police.  You

22     didn't file any kind of complaint or make an official report about it,

23     did you?

24        A.   Well, no.

25        Q.   Why not?  I mean -- aren't --

Page 25039

 1        A.   But of course not.

 2        Q.   Why not?

 3        A.   [No interpretation]

 4             THE INTERPRETER:  Can the witness repeat his answer.

 5             MR. HANNIS:

 6        Q.   The interpreters asked if you could repeat your answer.  I think

 7     it was too fast or they didn't understand.

 8        A.   Yes.  Such cases were so frequent at the time, not just involving

 9     me, that if I mentioned it nobody would have paid it any attention.  It's

10     as if I were here reporting about it raining in The Hague -- well, it

11     rains all the time.  And the individual was Dragan Fustar.  I didn't know

12     his name at the time.  I learned it later.  He passed away in the

13     meantime and it was because of alcohol.  He wasn't that old.  I saw him

14     for the first time then and I only learned his name later.

15        Q.   Dragan Fustar, is that the name you said?

16        A.   Yes, yes.

17        Q.   All right.

18        A.   Yes, it's spelled correctly here.  It's not an S but a Sh, but

19     fine.

20        Q.   Okay.  Thank you.  Do you know who he was affiliated with in

21     terms -- was he a policeman?  Was he in the army?  Was he in the

22     intervention platoon?  Do you know?

23        A.   No.  He had a camouflage military uniform.  I have no idea what

24     unit he belonged to.  He was definitely not with the police, definitely

25     not.

Page 25040

 1        Q.   You also mention another man I think the other day, Zoran Zigic,

 2     am I pronouncing his name correctly?

 3        A.   Yes, you are.  If you said Z, Z with a diacritic, then it's

 4     correct.

 5        Q.   That's what I meant to say.  I don't know if I did it correctly.

 6     Did you ever see him --

 7        A.   Never mind.

 8        Q.   Did you see him around or in the Prijedor SJB in 1992 on a

 9     regular basis?

10        A.   I used to see him a lot in the vicinity of the SJB as well, but

11     never on a regular basis.  That guy must have been everywhere.  He did go

12     to the SJB at the beginning in the course of the first few days, but who

13     it was that he worked with and what he was doing, that's something I

14     don't know.  I do know, though, that the policemen beat him once.  They

15     beat him up well, but he didn't seem to mind.

16        Q.   Okay.  Just a couple of questions about salary.  You mentioned at

17     page 24827 that the municipality was where the police were being paid or

18     by whom the police were being paid.  I want to ask you, I know you're an

19     electrical engineer and not an accountant, but what do you know about the

20     SDK, the public accounting service in Prijedor?  Do you know how moneys

21     were channelled to or through the SDK from higher levels of the

22     government like the republic level or the regional level?  Do you know

23     anything about that?

24        A.   I really don't.  From all -- out of all aspects of life, that's

25     the one I understand the least, not even today.

Page 25041

 1        Q.   Thank you.  Now I want to touch on a few communications documents

 2     before I go to the last two reports.  Tab number 55 is Exhibit P468.

 3     This is just a technical question about means of communication.  I think

 4     you can just look at the screen because I only have a question about the

 5     headings and addresses.  This is a document that appears to be sending

 6     conclusions of the ARK Crisis Staff, and it appears to be going through

 7     Sanski Most.  Do you see that stamp in the upper right-hand corner?  Can

 8     we enlarge that.

 9        A.   I see it.

10        Q.   Now my English translation says that ECV, those first three

11     letters stand for the Electronic Communications Centre.  Is that correct?

12        A.   I don't know.  I don't know what the abbreviation stands for.  As

13     for any electronic communications centre, I don't know whether it

14     existed.  Even nowadays they're not on good terms with the electronics,

15     let alone back then.  I don't know what it means.  I do know that OSNO

16     means the Municipal Secretariat for All People's Defence in Sanski Most.

17     It was sent by Telefax.  This had nothing to do with me.  It never did,

18     not documents like this one or similar.

19        Q.   Okay.

20             MR. HANNIS:  And could we zoom out so we can see the entire width

21     of the top of the page.

22        Q.   You see there's a fax header with a telephone number and then the

23     abbreviation COB, Bosanski Novi.  Do you know what the abbreviation COB

24     stands for there?

25        A.   Where is that?

Page 25042

 1        Q.   Do you see the line with --

 2        A.   I can see it all well, but I can't find COB.

 3        Q.   You see the -- there's the date and time and a telephone number

 4     and then straight across COB BOS NOVI?

 5        A.   I can see it.  The entire line, including the COB, is the data

 6     that the piece of equipment prints out.  It's either in the -- in its own

 7     memory or in the memory of the switchboard.  The COB is something that

 8     the fax machine is affiliated with, a particular office.  We can see the

 9     sending time, page 1, the date.  It was all done by the machine.  Here is

10     the number.  I don't know, though, what COB means.  Obviously the Telefax

11     machine was part of that institution.

12        Q.   Thank you.  So that's what I call the fax header on the top of

13     the page?

14        A.   Very well.  If that's what you call it, then that's fine.

15        Q.   I only show this to you because we had some discussion before

16     about whether you were aware of the existence of other communications

17     systems in the municipalities and it seems the Ministry of Defence or the

18     National Defence, whatever it was called, in Republika Srpska at the time

19     had a system separate and apart from the police communications system;

20     right?

21        A.   I don't know about other systems.

22        Q.   Okay.

23        A.   Let's take Prijedor.  I don't know anything about them.

24        Q.   Okay.  That's --

25        A.   I had nothing to do with them.

Page 25043

 1        Q.   That's fine.  Let me show you tab 56 which is Exhibit P656.  I

 2     can hand you a hard copy of this one.  It's a little longer.  It's dated

 3     the 29th of May, 1992, the day before the attack.  And it's from Chief

 4     Drljaca to Banja Luka CSB, responding to some communication from them the

 5     day before, the 28th.  And it's providing information about the various

 6     activities of the police and the number of policemen and the number of

 7     police stations, et cetera.  I want to ask you about the last paragraph.

 8     It says:

 9             "The previous war structure anticipated 630 policemen.  The new

10     war structure, which is functioning now, was prepared during secret

11     preparations for the take-over."

12             And we talked about this before.  I think you said when you got

13     to Cirkin Polje on the night of the 29th and you saw all the people there

14     and you got the stack of ID cards that had already been printed out, you

15     thought to yourself:  How long has this been going on?  Why wasn't I

16     aware of this?  This is consistent with that - right? - that there were

17     secret preparations that had been going on for some time before the

18     take-over.  That just confirms what you thought, doesn't it?

19        A.   Yes.  What was your question exactly?  I answered yes to the very

20     last part of what you said.  Is there anything else?

21        Q.   No, that's all.  I just wanted to ask if that was consistent with

22     the conclusion you had reached.  Let me show you one more, this is tab --

23        A.   I don't want to have any miscommunication.  The number of 1.342

24     members, in my view it's nonsense, it's impossible.  Next he says that

25     there were 180 active-duty police officers.  And before the war the

Page 25044

 1     number never went beyond 150.  If some of them were Muslim, how could

 2     they have had so many active-duty policemen?  Some did arrive from

 3     Croatia after leaving the police force there, but this figure is

 4     unrealistic.  Perhaps you can documents to corroborate this that I'm not

 5     familiar with.  I wasn't interested in that and I wasn't at any meetings

 6     where this was discussed.  But in my view, this is ...

 7             From my point of view as a communications person, I can tell you

 8     that each pair of policemen had one hand-held radio, which means that

 9     there should have been 650 hand-held radios to cover all these men --

10     well, no, there weren't as many in the time of war.  Maybe there were 60

11     or 70 of them.  Certainly not a hundred men with hand-held radios.

12     That's speaking from my point of view.  This seems a gigantic figure, but

13     I don't know what the real situation was.

14        Q.   I understand.  Let me show you one more or two more before the

15     break.  Tab 85.  I think this is 65 ter number 491.  I think you can read

16     this one on the screen.  It's fairly short.  Now, this is Chief Drljaca I

17     guess noting that they had received a particular dispatch from

18     Chief Zupljanin from Banja Luka CSB, in which Zupljanin ordered all SJB

19     chiefs to do their best to establish and maintain communications systems.

20     It says:

21             "Resolve all problems relating to this order with the Banja Luka

22     CSB comms department and KZ, cryptographic protection, and the local ...

23     post office."

24             It goes on to say:

25             "I especially insist that a KT, short wave, communication be

Page 25045

 1     established and maintained daily with IC-751 radio stations which all

 2     municipalities have ..."

 3             Did you know about this and was that done in Prijedor?

 4        A.   I don't recall this.  I guess this dispatch did arrive.  I can

 5     only presume what it's all about, nothing more.

 6        Q.   Did you have --

 7        A.   Let me say this.  This type of device, IC-751, it's a Japanese

 8     short wave piece of equipment.  And yesterday I explained what a KT or

 9     short wave equipment is.  It's something that we fell back on when all

10     else failed.  I suppose Rakovic proposed this because he wasn't well

11     acquainted with communications, although he was a chief of

12     communications.  I'm surprised that Simo Drljaca took his word for it.

13     Using this would be like having policemen train in riding bikes with the

14     war looming from my point of view.

15        Q.   Okay.  My question is, though:  Did you have those daily

16     communications?

17             MR. KRGOVIC:  I apologise.  I think part of the witness's answer

18     is missing because he mentioned that -- something about implementation of

19     this.

20             MR. HANNIS:

21        Q.   Did you hear that, Witness, and could you answer for us if that

22     was implemented in Prijedor?

23        A.   Yes.  My fault.  I got tangled up a bit.  No importance was

24     attached to it because it made no sense.  It couldn't cover functional

25     realities.  There were very few people working in communications and they

Page 25046

 1     couldn't even handle the tasks they already had.  Let me illustrate.  It

 2     would be as if you were making construction workers do pushups.  It was

 3     nonsensical.

 4        Q.   Okay.

 5        A.   Illogical.

 6        Q.   All right.  Let me show you one more before our break.  It's tab

 7     92, the Exhibit number is P669.  And I'll hand you a hard copy of this

 8     one.  When you have this in your hand you'll see it's dated the 4th of

 9     August, 1992, from Chief Drljaca to Banja Luka CSB.  Certain information

10     being provided pursuant to a request that originally came from the

11     Ministry of the Interior examine and then from a dispatch from CSB.  I

12     want to ask you about item number (b), it's on page 2 of the B/C/S, so

13     it's the next page over.  And Mr. Drljaca is reporting that:

14             "Members of the active and the reserve police force, practically

15     alone and without a fight, took over in Prijedor, sealed off the town,

16     and organised the security of all vital structures."

17             And the next paragraph says:

18             "After the outbreak of fighting, they took an active part and

19     showed an impressive level of cohesion and synchronisation with members

20     of the military.  In May, almost all of the policemen from Prijedor,

21     Omarska, Lamovita, and Tukovi participated in the fighting, first in

22     Hambarine then in Kozarac and Prijedor ..."

23             Now, I think you told me before that you believe that police were

24     not involved in fighting in those areas in May because you didn't see any

25     evidence of it from your position in the communications department.

Page 25047

 1     Nobody was asking you for communications support.  But here the chief

 2     says almost all the police from Prijedor were engaged in the fighting.

 3     Certainly he would be in a better position to know about that than you

 4     were; right?

 5        A.   Irrespective of the fact that I talk a lot, I seem to omit

 6     things.  First of all, when I discussed the take-over, I told you there

 7     were all sorts of uniforms.  I may be colour-blind, but I couldn't go

 8     wrong about the crates.  None of it belonged to the police.  I told you

 9     about the major and the other guy who asked for a hand-held radio, they

10     were not police.  I can give you many examples in a brush-stroke way.  If

11     I sat down I would come up with many more.  On the other hand --

12        Q.   Let me stop you there because I don't disagree with you about

13     that.  I think Mr. Drljaca is pumping up the role of the police in the

14     take-over and failing to admit the involvement --

15        A.   Certainly.

16        Q.   Yeah, ignoring the involvement of the army --

17        A.   Who, he the boss?  Yeah, he'd say:  "I freed Prijedor alone."

18        Q.   Yes, yes.  Yes --

19        A.   But the police was far smaller in numbers.  But when all this was

20     ongoing it wasn't that the military was doing all the work and the

21     policemen were sitting back having a cigarette.  They had their own tasks

22     but I didn't know which.  I wasn't privy to that, I wasn't interested.  I

23     do know, however, that they didn't sit in their living-rooms and they

24     were not looking for chicken thieves.  However, I really can't say what

25     it was that they were doing.  It would be irresponsible of me.

Page 25048

 1        Q.   Okay.  One last question before the break.  If you could go to

 2     page 3, the last paragraph, paragraph (g), Mr. Drljaca is saying the

 3     following:

 4             "A more organised participation of the police in executing

 5     possible combat activities is recommended so that police units and

 6     formations would in future be subject to the command of the military unit

 7     in charge of the combat activities."

 8             You see that?

 9        A.   I can see it.

10        Q.   You personally don't have any knowledge about the nature of the

11     co-ordination between the police and the army during those operations in

12     Hambarine, Kozarac, and Prijedor earlier in the summer of 1992, do you?

13        A.   I did tell you that the military took part.  The very fact that

14     there were two tanks there on the 30th of May confirms that.  Yes, they

15     were there generally although I don't know how many.  Please do bear in

16     mind that --

17             THE INTERPRETER:  Could the witness please repeat this part of

18     the answer.

19             MR. HANNIS:

20        Q.   Stop.  The interpreter just asked if you could repeat that part

21     of your answer, I guess after the fact -- after you said --

22        A.   I will.  I apologise.

23             When trying to analyse what he said or thought, one needs to bear

24     in mind that Simo came from the kindergarten.  He was a lawyer who worked

25     in kindergartens and schools and then came to the police.  No one knows

Page 25049

 1     what that man thought.

 2        Q.   All right.  Thank you.

 3             MR. HANNIS:  Time for our first break, Your Honour.

 4             MR. KRGOVIC:  Last sentence which witness said is not recorded.

 5     He said it's not real, or something like that.  So can you ask the

 6     witness to repeat the last sentence.

 7             MR. HANNIS:

 8        Q.   Witness, the last sentence we have from your last answer is:

 9             "No one knows what that man thought."

10             Mr. Krgovic says there was something additional you said.  Can

11     you tell us if there was and what it was?

12        A.   Well, yes.  I said perhaps he is the only one who could know what

13     he thought.  All this seems to me to be unrealistic in my view.

14        Q.   Thank you.

15             JUDGE HALL:  So we return in 20 minutes.

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

17                           --- On resuming at 10.53 a.m.

18             MR. HANNIS:  Before the usher goes too far I'll hand her a copy

19     of the first document I want to show the witness, which is 65 ter number

20     3517, it's at Prosecution tab 140.

21        Q.   Mr. Jankovic, while this is on the way to you I'll tell you it's

22     dated the 18th of January, 1993.  And it's a -- it's the annual report on

23     the status and organisation of crypto graphic data protection at the

24     Prijedor public security station for 1992.  And it has your name at the

25     end on the last page.  Do you recognise that document?

Page 25050

 1        A.   Yes, of course.

 2        Q.   Is that the report that you prepared in 1993 to cover the work

 3     that had been done in 1992?

 4             JUDGE HARHOFF:  Mr. Hannis.

 5             MR. HANNIS:  Yes, Your Honour.

 6             JUDGE HARHOFF:  I hope I'm not mistaken, but your tab 140 is --

 7             MR. HANNIS:  I'm sorry --

 8             JUDGE HARHOFF:  -- a different number.

 9             MR. HANNIS:  [Microphone not activated]

10             THE INTERPRETER:  Microphone for the counsel.

11             MR. HANNIS:  I misspoke, Your Honours, it's tab 138.

12             JUDGE HARHOFF:  Thank you.

13             MR. HANNIS:  My apologies.

14             JUDGE HARHOFF:  Yes, there it is.

15             MR. HANNIS:

16        Q.   I'm sorry, sir, I don't know if you were able to answer while the

17     Judge and I were talking.  Do you recognise that?  Is that a report you

18     prepared covering the work in 1992?

19        A.   Yes, it's my report.  I wrote it and signed it and I know it.

20     You can ask me about it.

21        Q.   Okay.  I understand that these kind of reports were fairly

22     typical in the MUP, both I think before the war and after April 1992 when

23     the RS MUP was formed.  Often I see them -- there were quarterly reports

24     every three months but there was always an annual report as well; is that

25     correct?

Page 25051

 1        A.   Yes.

 2        Q.   Okay.

 3        A.   Only I need to give you an additional explanation so you know

 4     everything about it from the start.  The document relating the state of

 5     affairs and the way encryption was organised, nothing else.  It's about

 6     people charged with it, equipment, and documents, and I mean these codes,

 7     for a given year.  The format of the report was prescribed in a military

 8     booklet.  So you would know that under 1 you need to relate the state of

 9     affairs with regard to encryption personnel.  And everybody used the same

10     format in the pre-war period because they had gone through training, as

11     had I.  And it was something that we took over from the JNA.  However,

12     during the war people were admitted who had not been familiar with these

13     issues and may not have applied the format that I always adhered to.

14        Q.   The item number 1 is the status of personnel and that lists the

15     people working there and their jobs.  Were all the people listed here

16     Serbs?

17        A.   Yes.

18        Q.   Are all of them Serbs?

19        A.   Rankovic, that's I, the technician, yes.  Devan [phoen] Djukic

20     maintenance technician, yes.  Sarac Batinica, Kovrlija Radanac [phoen],

21     Pasic Mackovic [phoen], yes.  That's as at the 18th of January, 1993; in

22     other words, it's a report for 1992 -- just a moment.  It was written on

23     the 18th of January.  It says 18 January and it says here charged with

24     encryption duties with -- in 1992.  So it is a report for 1992.

25             Now, the personnel as listed here were present in the beginning

Page 25052

 1     of 1992, where Kapuric [phoen] and the Ukrainian who I said fled just

 2     before the war were present, but there were some on this list here who

 3     were not there at the time.  So you could say that sometime in the middle

 4     of the year there was a mixed composition of personnel, but the personnel

 5     listed here were present at the time of the writing of the report.  And

 6     one of the men here was from a mixed marriage, but of course this isn't

 7     something that would be stated here.

 8        Q.   I understand.  And then you list the various cryptographic data

 9     protection devices and documents and the instructions that you have.  If

10     you could go to the last --

11        A.   That were used under the system.

12        Q.   Yes.  If you could go to the last page, item number 5 is -- in my

13     English translation says:

14             "Communications via telegram in 1991."

15             But then the next line says:

16             "Communication via open and encoded telegrams in 1992 ..."

17             So I'm thinking that's a typo, a typographic mistake, the line

18     that is underlined after number 5.

19        A.   I think so as well.  It must be a mistake, my mistake because I

20     wrote it.

21        Q.   Okay.  And this is -- so I take it this is the total number of

22     open and encoded telegrams received and sent by Prijedor SJB for the

23     entire year of 1992 going back to 19 -- going back to January 1st?

24        A.   Yes.

25        Q.   Okay.  Thank you.  Now, because it says "telegrams," and I

Page 25053

 1     understand that to mean it's telegrams only.  There may have been other

 2     kinds of communications from Prijedor SJB and to Prijedor SJB that

 3     weren't telegrams.  For example, someone may have sent a 20-page manual,

 4     instructions about something, by courier.  So that's not a telegram but

 5     that is a communication.  Would you agree?

 6        A.   Yes, but it's got nothing to do with the communications centre.

 7     It wouldn't go through us.

 8        Q.   Yes, I understand.  There were some --

 9        A.   Only the items listed here were the ones handled by us.  We had a

10     fax machine as well, but they had one as well so they could use it

11     directly.  We did not list the uses of the Telefax here, but besides they

12     would be used by the chief and commander independently of us.  And it

13     says here that the total traffic in telegrams in 1992 was reduced by

14     62 per cent compared to the previous year, to the year before, which

15     wasn't a very busy one either.

16        Q.   Okay.  I understand.

17             MR. HANNIS:  Your Honours, I'd like to tender this document.

18     It's not an exhibit.  Back in February 2010 when we had a communications

19     witness from Banja Luka testify, the Prosecution had sought to add this

20     exhibit to our list at that time.  But because we hadn't made a motion,

21     Your Honours on the 25th of February, 2010, gave an oral ruling and did

22     not permit the Prosecution to add some 23 end-of-the-year communication

23     reports from various SJBs.  But given that this witness is here now and

24     he was called by the Defence to testify about communications in Prijedor,

25     it's his report, I think it's not prejudicial to the Defence and it's not

Page 25054

 1     unfair to allow the Prosecutor to tender it as an exhibit at this time.

 2             JUDGE HALL:  Mr. Krgovic.

 3             MR. KRGOVIC: [Interpretation] Your Honours, I have no objection

 4     to the document being admitted.  Regardless of the objections I may have

 5     stated before, what the Prosecutor said does warrant the admission of the

 6     document.

 7                           [Trial Chamber confers]

 8             JUDGE HALL:  Admitted and marked.

 9             THE REGISTRAR:  As Exhibit P2394.  Thank you.

10             MR. HANNIS:  Thank you.

11        Q.   Now, Mr. Jankovic, the last document I think that I'm going to

12     show you -- and it's not a log-book, you'll be happy to hear.  It's tab

13     number 137, the Exhibit number is P689, and it's a long one so I need to

14     hand you a hard copy of it.  Thank you.

15             You'll see by the cover this is a report on the work of the

16     Prijedor SJB during the last nine months of 1992.  And it's dated January

17     1993.  If you go to the very last page you'll see it's from

18     Chief Simo Drljaca, maybe on the back side.  Have you ever seen this

19     report before?

20        A.   Somebody showed it to me.  Was it the Defence or you?  Perhaps

21     both.  I can't remember.

22        Q.   Would you have seen it in 1993?  I mean, was it common practice

23     for the chief to circulate a copy of the final report to the various

24     department heads so you could see what it looked like or do you remember?

25        A.   No, no.  Nobody informed us of their own report.  We would be

Page 25055

 1     copying our report to others, not the other way around ever.

 2             MR. HANNIS:  Okay.  If we could have up in e-court so we can

 3     follow along P689, and if we could go to page 2 in e-court in both the

 4     English and the B/C/S.

 5        Q.   And, Mr. Jankovic, if you could turn the cover page and look at

 6     the first page of text there, yes, on your left-hand side, I want to

 7     start with a couple of things from those paragraphs.  This is the

 8     creation of conditions for the functioning of the public security

 9     station.  And I think it's the third sentence says:

10             "In view of the fact that the Chief of the police security

11     station in Prijedor and the Commander of the Police Station for the

12     control and the safety of traffic were both SDA people, these activities

13     had to be covert and involve a ...  limited number of personnel."

14             And he's talking about trying to establish the functioning of a

15     police station under the Serbian Ministry of Internal Affairs.  So the

16     chief and the commander he's referring to there, that would have been

17     Hasan Talundzic and Fikret Kadiric; right?

18        A.   Yes.

19        Q.   And he says this covert work -- he said:

20             "The work was carried out outside the Station premises, often

21     using the premises of the cultural centre in Cirkin Polje.  The focus of

22     the work was on the covert organisation and the formation of 'shadow'

23     police stations and the arming and equipping of personnel.  In this

24     manner, 13 police stations were established with a total staff of about

25     1.500."

Page 25056

 1             Now, I take it from everything you've told us so far, you didn't

 2     know anything about this; right?

 3        A.   Well, when you put it all together it all fits with what I said

 4     about, for instance, those crates that I saw, then it goes to show that

 5     this is probably true, that this was the way things were done.  But since

 6     I was clueless when I saw those crates, it means that I was clueless

 7     about this as well.  It does seem realistic to me, though.

 8        Q.   In the next paragraph he mentions that activities were launched

 9     to prepare for a take-over by force.

10             "These activities gained momentum in April and the actual date of

11     the take-over was forced upon us by the Presidency of the then

12     Socialist Republic of BH, when they issued the order to attack military

13     installations and convoys."

14             That's clearly a reference to that 29 April dispatch that you

15     told us about taking to the meeting and --

16        A.   Probably.

17        Q.   All right.

18             "As a result, in the night between 29 and 30 April, following

19     very detailed preparations and pursuant to the relevant decision of the

20     Executive Committee of the Serbian Municipality of Prijedor, an organised

21     take-over of power was embarked upon.  About 400 policemen assembled in

22     the cultural centre ... and at 0400 hours, took control of important

23     sites in the town ..."

24             That part, is that consistent with what you saw on the night of

25     the 29th and the morning of the 30th of April?  I think you gave us a

Page 25057

 1     lower number of policemen that you saw.  I think you said 150 to 200.

 2     But otherwise, is it consistent with what you saw?

 3        A.   This isn't impossible.  First of all, I came in as the night was

 4     falling and I suppose there were others coming after me.  I wasn't going

 5     out, but what was happening outside of the building?  There were -- there

 6     was the army and the youths and let me call them those people.  When did

 7     they come?  They didn't go into the building.  I didn't go out.  And I

 8     said that my assessment of the numbers was between 100 and 200.  Of

 9     course there could have been more.  There was room enough, that's for

10     sure.  But I didn't go out until the morning hours.

11        Q.   Okay.  Thank you.  If we could go to the next page in e-court in

12     both B/C/S and English.

13             And, Mr. Jankovic, it's the next page on your right-hand side.

14     At the top, it says:

15             "After the take-over, all personnel of Croatian and Muslim

16     ethnicity were summoned to interviews by the chief," that would have been

17     Drljaca then, I guess, "... and the option of signing declarations of

18     allegiance to the Republika Srpska was explained to them.  They were ...

19     given a reasonable time-limit ...  which was extended twice."

20             And then it says:

21             "Additionally, interviews were also conducted with a number of

22     Serbian members of the staff who had not been explicit enough in defining

23     their future work engagement."

24             Do you know what that refers to?  Do you know any Serbian members

25     who were interviewed by the chief about, you know, signing the

Page 25058

 1     declaration and continuing to work for the new Serbian SJB in Prijedor?

 2     Do you know anything about that?

 3        A.   Not from that period, I don't know anything.  What I know now is

 4     as they are pensioners and having arguments about the years of service

 5     that each of them have, then I know that they can't come to an agreement

 6     about which day which one of them came to work or whatever.  So I wasn't

 7     there and I don't know anything from that time.

 8        Q.   Okay.  I understand.  The next I want to ask you about --

 9             MR. HANNIS:  We need to go to page 14 in the English in e-court

10     and page 12 in the B/C/S in e-court.

11        Q.   And for you, Mr. Jankovic, if you could go to the next page where

12     there is a little blue sticky-tab at the top.  Keep going it's the last

13     one -- yeah.  Uh-huh.  Yes.  Okay.

14             You see this is a section dealing with communications and coded

15     communication.

16        A.   Yes.

17        Q.   I think at the bottom of your page it talks about open -- about

18     telegrams received in dispatch, both open and coded.  But you'll read

19     part 1, this is from the beginning of the year until April 30th.  So this

20     appears to be only the numbers for the first four months of the year,

21     would you agree?

22        A.   Give me a moment to have a look.

23        Q.   Yes.

24        A.   Because of the specificity of war activities, this report is made

25     up on three parts, namely, the part until the 30th of April; the second

Page 25059

 1     in the period thereafter; and the third relates to the participation in

 2     war activities.  Fine.  There's a great deal of it.  What is it

 3     specifically you are asking me about?

 4        Q.   I just want to confirm.  It seems to me these numbers are

 5     referring only to the first four months, from 1 January to 30 April.  So

 6     when it says coded telegrams dispatched, it was 36 during the first four

 7     months of the year?

 8        A.   I'm getting confused now.  Let me tell you the gist of it.  I

 9     would have to be analysing this document now.  This is the gist:  All of

10     the dispatches that were written had to have been entered into that book,

11     and when you're writing reports like these, you are consulting these

12     books only.  And nobody dared to lie or misrepresent anything because you

13     would have inspection coming to check.  And of course mistakes can

14     happen, like the bit where I wrote 1991 instead of 1992.  As for the

15     rest, I would have to look into the maths of it, what was meant by each

16     of the figures presented here, and I'm afraid it would take up too much

17     of your time --

18        Q.   Yes --

19        A.   -- this must have been taken out of one book or other.

20        Q.   No, I'm not trying to trick you here, and I don't really want to

21     haul out the log-books again because I don't think any of us do --

22        A.   I have no doubt about that --

23        Q.   But we looked at the one book of coded telegrams early on when I

24     started cross-examining you.  And you remember I think the number was

25     about 100 coded telegrams for the entire year of 1992?

Page 25060

 1        A.   Yes.

 2        Q.   And in your report, which we just looked at before looking at

 3     this document, you had 98 coded telegrams for the entire year.  And --

 4        A.   I don't remember, but I believe you.

 5        Q.   Take my word for it.  And here we see 36 -- we see 36 for the --

 6        A.   But evidently this isn't the period.

 7        Q.   Correct.  This is for the first four months from 1 January to 30

 8     April --

 9        A.   So that's probably how it was.

10        Q.   Yes.  And if you look at the code book I think you -- if you look

11     at the comms log for coded telegrams, you'll see that that works out,

12     meaning that there were approximately 62 sent from the day of the

13     take-over until the end of the year.  But I want to go to the next page

14     if we could, page 13, next page in B/C/S, still the same page in English

15     on the lower half.  I want to read from this paragraph, please bear with

16     me while I read a long passage and then I'll have a question.

17             "Although the imminent threat of war was very acutely felt in the

18     previous period, the work still had to be done ..." it was talking about

19     up until -- from the 1st of the year until April 30th, "... but it was

20     adversely affected as illustrated by the following:  The then-chief of

21     the Public Security Station, appointed by the SDA, was working full steam

22     to further the interest of his party," and that's Mr. Talundzic; right?

23     He's the SDA-appointed chief?

24        A.   Yes, he was the chief.

25        Q.   "...  requesting photocopies of the Communications duty roster so

Page 25061

 1     that the only Muslim still employed in the Communications,

 2     Mirsad Sahuric," who you've told us about before, "could keep him

 3     informed of anything of interest in Communications."

 4             Right so far?

 5        A.   Yes.

 6        Q.   And then it says:

 7             "During this time, the Serbs on the communications staff were

 8     covertly --"

 9             MR. KRGOVIC:  I apologise, is that a question or confirmation of

10     what was said here?

11             MR. HANNIS:  Please don't interrupt me when I'm getting to my

12     most important point.

13             MR. KRGOVIC:  Because you didn't pose the question.  You just

14     asked him to read, and he said yes.

15             MR. HANNIS:  I said, "Right so far?"  And he said, "Yes."

16             MR. KRGOVIC:  But you didn't pose the question.  You just read

17     him.

18             MR. HANNIS:  I'm asking if he agreed what I just read.

19             MR. KRGOVIC:  [Microphone not activated]

20             MR. HANNIS:  Let me read the next point.

21        Q.    "During this time the Serbs on the Communications staff were

22     covertly organising themselves, carefully monitoring the flow of

23     information through the Communications Centre and reporting about the

24     execution or non-execution of received instructions either to the

25     Executive Committee or to the Banja Luka Centre of Security Services,

Page 25062

 1     depending on their assessment."

 2             Mr. Jankovic, did you know about this?  Did you personally know

 3     about that?

 4        A.   Which bit?

 5        Q.   About the Serbs covertly organising themselves, the Serbs on the

 6     communications staff covertly organising themselves and reporting to the

 7     Executive Committee or Banja Luka centre about the reporting -- about the

 8     execution or non-execution of received instructions?  Did you know

 9     anything about that?  I'm talking about from the beginning of the year

10     until the 30th of April.

11        A.   Well, let me tell you, as I'm reading it, I have images of

12     pre-war Partisans films in my mind, where everybody from old women and

13     children were participants in the battle.  And even the communications

14     service now seems to be involved in this.  I had no connections with

15     Talundzic.  I spoke very little.  He didn't ask me much.  And of course I

16     had my specialist line that led to Banja Luka, but there wasn't much that

17     I had to deal with them.  The transmission of dispatches, right.  And I

18     could have relied on technical assistance from Banja Luka, but their

19     level of equipment was so poor by that time that I couldn't even depend

20     on them for that.  So when we're talking about this sort of underground

21     work or covert work, it's like we're talking Partisans all over again,

22     covering and reporting.  Come on.  Who would I have been doing that with?

23     I didn't know anybody there.  I told you that I saw him for the first

24     time during the take-over.

25        Q.   That last sentence you were referring to Simo Drljaca; right?

Page 25063

 1     When you said you saw him for the first time during the take-over?

 2        A.   Yes, yes.

 3        Q.   Okay.  No but --

 4        A.   And there was nobody else who came from the SDS.  Perhaps there

 5     was someone whom I didn't know and at any rate since I didn't know the

 6     person I wasn't able to be in touch with them.

 7        Q.   The next sentence, the last on the English page and going on to

 8     the next page in English:

 9             "All this was done clandestinely and for obvious reasons there

10     are no records."

11             Mr. Jankovic, I accept that you may have not known anything about

12     this and may not have participated in it, but do you disagree that other

13     Serbs working in the communications centre may have been doing this

14     without you knowing about it, some of your co-workers?

15        A.   Well, I'm convinced they have not.  This is why:  Those who type

16     in the dispatches, none of them, as I said, including Sarac who was too

17     lazy to send the dispatch in question in three different ways, they

18     simply didn't get involved.  Their only job was to type things in.  There

19     was this Mladen Raus who was a technician.  Before him was the Ukrainian

20     guy and later it was Sasa Djukic, I mentioned him here, he was a young

21     guy.  This Raus could fix a device or two, but to issue one without me

22     knowing, it was impossible.  I knew every device by heart.  If there were

23     three radio stations missing, I would notice, let alone a thousand-plus

24     stations.  Raus could not have issued anything of that sort.  I would

25     have known.  As for someone else doing things on the side without telling

Page 25064

 1     me, well, they weren't expert enough to fix devices.

 2             As for the signalsmen, I didn't even think they'd be able to do

 3     something to someone.  They simply forwarded their dispatches.  I also

 4     didn't know that the Sahuric person worked against the Serbs and later on

 5     he joined them after the take-over.  I think it was his job to do that

 6     without any opportunity being given to him to -- whatever he did had to

 7     have been noted down.

 8        Q.   Okay.  Let me stop you there.  You're saying you didn't know

 9     anything about this and you didn't do anything like that.  And you're

10     also saying as far as you're concerned you don't believe any of your

11     fellow Serb communication workers at that time could have or would have

12     done something like that.  Is that a fair summary?

13        A.   Yes.  I know positively for myself.  I'm convinced for the

14     others, although there is a possibility.  My belief is that they didn't

15     do anything of the sort.

16        Q.   I understand.  Reading on:

17             "Furthermore, during this time Serbian reserve police stations

18     were being covertly formed and preparations made for the take-over and

19     the Communications personnel took upon themselves to establish

20     communications for this operation.  This entailed a lot of work, from

21     attending meetings and assessing requirements, through the drafting of

22     directories of names and code-books to ensuring the necessary

23     equipment ..."

24             So again, if that happened, you're telling us that you didn't

25     know anything about it; right?

Page 25065

 1        A.   First of all, let me say this:  These spare or reserve illegal

 2     stations he mentioned, was anything done with them?  Is there any proof

 3     that any of that was included in any particular operation?  They may have

 4     figured in plans of organisation, but nothing was done with them for me

 5     to be able to notice that they were in existence.  I wasn't asked to

 6     provide any pieces of equipment.  Now, whether after the take-over some

 7     things were done, well probably.  On that day a number of radio stations

 8     were used as part of regular police work and used for that purpose.  But

 9     during the take-over operation, I don't seem to remember any dense radio

10     communication traffic that could not be covered by the pieces we had in

11     regular work.  I have always said this.  Only in larger-scale operations

12     where additional communication means are required, that was something I

13     must have known.  As for anything else, things could have done -- people

14     could have done things that I would not have been aware of.

15        Q.   You remember --

16             MR. KRGOVIC:  I apologise there is another correction to the

17     transcript.  I turn in Serbian.  [Interpretation] Page 48, when the

18     witness discussed of the larger-scale operations and then he reverted to

19     smaller-scale or less-important operations.  We don't find that in the

20     transcript.

21             MR. HANNIS:

22        Q.   Did you hear that, Mr. Jankovic?  Is that correct?  Did you

23     intend to include smaller-scale operation as well in that part of your

24     answer?

25        A.   Let me be clear.  I'm saying this:  There could have been

Page 25066

 1     smaller-scale operations which did not require any auxiliary

 2     communication means, and in that case no one would ask anything of me.

 3     Under such circumstances, I would have been ignorant of it.  However, in

 4     this specific case I have never heard of any illegal radio station being

 5     used in any operation.  I'm positive I have never heard of that.  No one

 6     ever asked any communication equipment piece of me.

 7        Q.   Okay.  Just a couple more questions and I'll be done,

 8     Mr. Jankovic.  You remember telling us about -- after the meeting with

 9     Mr. Zupljanin on the 9th of April when there was a discussion about the

10     new insignia, at page 24767 on Monday you told us that Chief Zupljanin

11     told you that you guys, meaning you people in the Prijedor police

12     station, must agree among yourselves about how to resolve this.  You

13     can't wait for someone from the outside doing that for you.  And you said

14     then Fikret Kadiric, the commander, said, "Sir we cannot do that because

15     some people are spying upon other people.  That's the word he used and he

16     pointed the finger at me."

17             Do you remember telling us about that, that Mr. Kadiric accused

18     you of spying?

19        A.   Yes.  He used a grammatically incorrect term, but that's the

20     meaning.

21        Q.   Is it possible that he suspected you because of some things he'd

22     seen happening in the communications department, do you know?

23        A.   I'll tell you another thing and then you can compare --

24        Q.   Well, you can tell me in a minute, but can you answer my question

25     first?

Page 25067

 1        A.   He said things that had nothing to do with the truth, that were

 2     groundless.  Only a couple of days later I was summoned by Chief Hasan

 3     Talundzic to his office, so I did.  Next to him was Fikret Kadiric and a

 4     female employee Fikreta Asusic [phoen].  Hasan told me this:

 5     "Sefita [phoen] complained that you passed by her on the staircase and

 6     that you hit her with your hand."  I was completely shocked.  I knew it

 7     had nothing to do with anything.  When I came to after the shock I asked

 8     her:  "When did that happen?"  She said:  "The day before yesterday,

 9     Monday."  And then I recalled.  Without a word I went to my office and

10     brought my travel order.  On that day I was in Sarajevo and returned late

11     in the evening.  I showed it to him and they fell silent.  No one ever

12     raised the issue again.

13        Q.   Okay --

14        A.   I think it was completely untrue.  Such things occurred on

15     numerous occasions.

16        Q.   All right.  Let me stop you there.  But you've seen what

17     Mr. Drljaca put in his report in some detail about the actions taken, he

18     says, by people in the communications department, about the setting up of

19     the reserve police stations.  His reports earlier in the year about 300

20     policemen guarding in Keraterm, Omarska, and Trnopolje.  I suggest to you

21     that what happened was you weren't trusted by Mr. Drljaca and the SDS

22     because you were not a political guy, and you've told us how you tried to

23     help your Muslim coworker Mr. Sahuric.  So you were out of the loop.  You

24     weren't told about these things because the radical Serbs, the extremist

25     Serbs, didn't trust you.  Isn't that the logical explanation for why you

Page 25068

 1     don't know about any of this, and why you didn't know about the combat

 2     activity that the Prijedor SJB police were involved in?  That makes

 3     sense, doesn't it?

 4        A.   Let me say this first.  We were a small operative unit.  In a

 5     cocoon so to speak.  We didn't have much contact with others.  Our office

 6     was locked and no one could enter except for us and the chief, who came

 7     rarely, once or twice a year.  We were a closed unit.  No one ever

 8     inquired about work.  Fikret could not have known anything because he

 9     didn't use to come in.  As for one of the signalsmen telling him

10     something, I don't think it was very likely, and this includes Sahuric.

11     As for the politicians, we were so remote to them that I wonder whether

12     they knew we existed.  They must have known that there were

13     communications departments in the MUP, but it ended with that.  If you

14     want to know anything more, you should ask them.

15        Q.   Thank you, Mr. Jankovic.  I don't have any more questions for

16     you.

17             JUDGE HALL:  Mr. Krgovic.

18                           Re-examination by Mr. Krgovic:

19        Q.   [Interpretation] I have a few questions for you.  They had to do

20     with the questions put to you by the Prosecutor.  I'll start with the

21     document in front of you, which is P00689.

22             MR. KRGOVIC: [Interpretation] Could we have page 13 in the

23     Serbian version.  The ERN number is 00633760.  It's the next page.  Yes.

24        Q.   Mr. Drljaca in the second paragraph reads --

25             THE INTERPRETER:  Interpreter's note:  Could we please wait for

Page 25069

 1     the English translation.  Thank you.

 2             MR. KRGOVIC: [Interpretation]

 3        Q.   He says that Mr. Fakovic used his independent channels to inform

 4     Chief Talundzic or to report to him.  Just one moment, please.  We don't

 5     have the English translation.  I think it is page 14 in the English.

 6             Mr. Drljaca asserts that Mr. Mirsad Sahuric independently report

 7     to Chief Talundzic.  The Prosecutor read out this part to you and you

 8     provided an answer about the document.  Is this part about Sahuric

 9     correct and what was your knowledge of his activities at the time?

10        A.   Sahuric, everything in this document is incomprehensible to me,

11     including the mention of Sahuric.  I am convinced that Sahuric was a good

12     worker and that he wasn't prone to do such things.  Even if I had known

13     that, how could I have -- well, I went to his house once or twice and I

14     even sent Raus and there was Sarac.  I told them to go and visit the

15     family.  We couldn't have been extremists, the both of us, to be on such

16     good terms.  I even sent Mladen Raus and Dusko Sarac also went to his

17     house.  I visited him twice before he left with the convoy.

18        Q.   Mr. Jankovic --

19        A.   I don't accept that he didn't do his job properly.

20        Q.   If I understand you correctly, is what Mr. Drljaca mentions

21     correct, in your view?

22        A.   No.  As I said, this only reminds me of the old Partisans movies

23     and heros of Mirko and Slavko.  They all joined hands in order to fight

24     the villain, including the children, and this document reminds me of

25     that.  The entire communications department was so small and there was so

Page 25070

 1     little leeway that things simply had to go through the books.  I couldn't

 2     issue a piece of equipment without people knowing.  We were always in a

 3     small enclosed space like this, and we knew nothing of the outside world.

 4        Q.   We don't have much time, could you please try and answer my

 5     questions briefly.

 6        A.   Yes, but I'm afraid it's impossible to answer this kind of

 7     question briefly.

 8        Q.   Mr. Jankovic, you were asked by the Prosecutor a moment ago about

 9     the participation of the police in combat.  When it comes to more

10     important operations involving the police, were there any changes made to

11     the communications network?  Was the communication department obliged to

12     do something?

13        A.   Certainly.  In the period before the take-over there were no such

14     operations.

15        Q.   I'm asking you about combat, if the police are engaged in combat,

16     is there anything for the communications department to do anything?  Do

17     you need to issue additional equipment, et cetera?

18        A.   Certainly.  With greater numbers of people, you need more

19     devices, and the person in charge of organising should plan for such a

20     contingency and then they would always ask for more equipment.

21        Q.   And if there were smaller things going on not requiring many

22     policemen, in other words, to carry out regular routine activities, did

23     they require any additional effort?

24        A.   No, because only the equipment that was in standard use was then

25     relied on.

Page 25071

 1        Q.   The Prosecutor cited some figures from Mr. Drljaca's reports.

 2     What is your knowledge concerning the document and the figures put forth

 3     by Mr. Drljaca and what is your impression?  Did he inflate the numbers

 4     or are the numbers too small, too low?

 5        A.   As for the figures that we saw in the two documents, they're not

 6     rounded off, but I don't think he changed anything.

 7        Q.   I was discussing the other figures, the number of policemen,

 8     radio stations.

 9        A.   No, it doesn't resemble anything.  It's unrealistic.  As for the

10     dispatches, I think it tallies with my figures more or less, according to

11     the books.  But as for his numbers of policemen, et cetera, no way.

12     Thirteen hundred policemen?  Where did he come up with that?  It's an

13     exaggeration.  Before the war the entire station had 230 employees,

14     including the crime department, communications department.  The crime

15     department had up to 30, the police over a hundred.  So the maximum could

16     have been 250.  From that you need to take off the number of Muslims who

17     left and some Serbs.  So how did he come up with the figure of 180

18     active-duty policemen?  It's ridiculously unreal.

19        Q.   The Prosecutor showed you another document before the one we just

20     discussed.  P2394, tab 138.  The last page, please.  At the bottom you

21     say that the overall telegram traffic was by 62 per cent lower than the

22     previous year?

23        A.   Yes.

24        Q.   Is -- does this relate to the whole year because this was your

25     report for 1992?

Page 25072

 1        A.   Well --

 2        Q.   Does this also include what you said before, which is that there

 3     was only one-third of the overall traffic compared to the previous years?

 4        A.   Well, one-third would be 33 per cent.  When I mentioned it to

 5     you, I wasn't familiar with these numbers.  Now when I look at them,

 6     that -- if we deduct 62 it would leave us with 38 per cent and one-third

 7     would be 33.  So it was my assessment, and I wasn't off much it seems.

 8     As for what period, I don't know.  As far as I'm familiar with it, you

 9     compare a quarter to a quarter or half a year to half a year.  So it has

10     to be an equivalent.  That's the principal used.

11        Q.   But report of yours covers a full year, if you look at the cover

12     page?

13        A.   This is the report about the coding, yes.  Those were annual

14     reports.

15        Q.   Mr. Jankovic, in the first three months or let's say until the

16     30th of April, 1992, were there any reductions?  What were the figures

17     before the 30th April compared to the previous year?  Was the network

18     down at any point in time before the take-over?

19        A.   Yes, there was.  Before the political problems occurred,

20     everything went down.  We no longer purchased new equipment.

21        Q.   I meant to ask you about the period when it was quiet before the

22     take-over, when you compare that period, the quiet period, with the

23     period in 1992, were there any discrepancies?

24             THE INTERPRETER:  Interpreter's correction:  1991.

25             MR. KRGOVIC: [Interpretation]

Page 25073

 1        Q.   Were there any significant differences?  I'm asking you about the

 2     quiet period.

 3        A.   There were changes in 1992 as well.  I'm not trying to avoid

 4     answering, but let's take 1985 or 1986, five years before this date, we

 5     always had about 100.000 dispatches a year.  In other words, 1991 was

 6     also a significant change and here we have another reduction by 62

 7     per cent compared to 1991, even though Prijedor was one of the smaller

 8     centres.  So it was a period of stagnation, although it's difficult to

 9     say anything more specific than that.

10        Q.   Mr. Jankovic, the Prosecutor asked -- showed you some documents

11     which did not originate from your -- in your communications centre and we

12     saw some entries.  Can you tell us what would be a relevant piece of

13     information about the number of sent and received dispatches and the rate

14     of success in terms of successful transmission.  Where could one find

15     such figures?

16        A.   Nowhere.  We only kept records in normal conditions.  If we go

17     back to the dispatch of a moment ago with my ellips is.  It went through

18     our regular communications channels but came back my Telefax.  We were

19     circumvented, in other words, and such entries were not made.  If

20     something didn't go through, it was also noted down.

21        Q.   But such an unsuccessful dispatch, would it have been assigned a

22     number?

23        A.   Those are the books that I am not familiar with.  Mira perhaps

24     kept such records.  I suppose she did, but I didn't worry about that.

25        Q.   From the figures shown to you by the Prosecutor, can you conclude

Page 25074

 1     whether there was a successful attempt to send a dispatch or not?

 2        A.   Well, I don't know.  What I could see in the books I was shown

 3     includes not only dispatches but documents of all sorts sent through

 4     different channels.

 5             THE INTERPRETER:  Interpreter's note:  Could the speakers not

 6     overlap and pause.

 7             Interpreter's note that a couple of questions and answers weren't

 8     interpreted.

 9             MR. KRGOVIC: [Interpretation] I apologise.

10        Q.   We do speak the same language so there was an overlap.  I asked

11     you if the books that the Prosecutor showed you made a clear indication

12     of whether a dispatch had been transmitted or not.

13        A.   Let me repeat what I said.  Normally something like that would

14     not have been an issue so that there wasn't a box made appositely for

15     that.  There was a column which stated remarks or notes, but there wasn't

16     anything entered there.

17        Q.   Mr. Jankovic, the Prosecutor further showed you a number of

18     documents which indicated an exchange between Mr. Zupljanin, that's to

19     say the CSB of Banja Luka, and the SJB of Prijedor.  I'll show you P00682

20     now.  It will appear on your screen shortly.  If I remember correctly we

21     don't have the right -- I don't have the right page of transcript.

22             You, it seems to me, commented on this dispatch of Simo Drljaca's

23     as being an impertinent one or brazen.  So would you say that this

24     dispatch reflects the sort of conduct or demeanour that a chief should

25     assume when addressing someone?

Page 25075

 1        A.   Well, look at this.  It says we are unable to conduct an inquiry

 2     into the stated death of a number of Muslim individuals in

 3     Koricanske Stijene because all the policemen who escorted the convoy for

 4     Travnik on that date were at the battle-field in Han Pijesak.  Well, this

 5     wasn't in Mars if it was in Han Pijesak.  I'm sure that this could have

 6     been dealt with, and it is really inappropriate of him to state such

 7     reasons to his immediate superior.  To me it is cheeky, it is brazen, and

 8     inappropriate.  And I can tell you that I saw similar writings of his

 9     before.  It is really irresponsible to say that you are unable to deal

10     with a matter that is as serious as this.

11        Q.   So quite apart from the fact that these policemen, as it says

12     here, were deployed on a mission, is -- or was there a record kept of

13     policemen in the Prijedor public security station and their data?

14        A.   Well, I don't know that and I don't know who was deployed to

15     Han Pijesak.

16        Q.   You misunderstand me.  My question was:  Were the particulars of

17     individual policemen kept on the record in Prijedor and should a superior

18     inquire of them?

19        A.   Well, yes.  I think that the commander would have a record or

20     perhaps the personnel service.  Somebody would at any rate.  Well, you

21     see, I had appropriate records for my communications officers that I used

22     when I was drawing up reports, and I'm sure they had for theirs.

23        Q.   The Prosecutor went on to ask you about the relationship between

24     Zupljanin and Simo Drljaca.  He asked you if you had an example to give

25     where Chief Zupljanin's instructions or orders were not complied with.

Page 25076

 1     Do you know of any fuel tanker trucks from or to Banja Luka passing

 2     through Prijedor?

 3        A.   Yes, I do think that I spoke about this, either to the Defence or

 4     the Prosecution.  I do recall this once when there was a shortage of

 5     fuel, which was a general occurrence at the time, and they got hold of a

 6     fuel tanker.  I think it was diesel fuel.  And Simo was told that this

 7     was intended for those in Banja Luka, but he said, "Oh, they'll get by.

 8     We'll keep this for our own purposes," although it was not initially

 9     intended for us, and I did find it inconceivable at the time.  I recall

10     that.

11        Q.   I'm sorry I didn't quite understand you now.  Can you explain

12     this to us.  Who took the fuel tanker and it belonged to whom?

13        A.   Well, I said we took it from the Banja Luka people -- well, I

14     can't speak of any persons because I don't know who it was.  I only know

15     that we had a shortage of fuel and all of a sudden we had a supply of

16     fuel.  And then when I asked about it, we -- it was said that we had

17     taken it over from the Banja Luka people.  Apparently my idea of it was

18     that this tanker was intended for the Banja Luka fellow policemen.  I

19     suppose it had to do with the centre.

20        Q.   And who was it who misappropriated it?  I don't mean physically,

21     but who ordered that this be taken?

22        A.   Again I repeat, I heard about it.  I didn't see it, but I would

23     say that nobody would dare do such a thing without the approval of one's

24     superior, and the superior must have been Simo.  I don't think any of the

25     commanders would have ordered it.  Perhaps I should be considering that

Page 25077

 1     possibility rather than blame it all on the late Simo.  But my idea would

 2     be that it was Simo who was behind it.

 3             MR. KRGOVIC: [Interpretation] We have some 20 minutes left, but I

 4     do believe it's time for our break now.

 5             JUDGE HALL:  Yes, so we would return for you to wrap up and then

 6     we have some housekeeping matters with which to deal before we adjourn

 7     for the day.

 8                           --- Recess taken at 12.03 p.m.

 9                           --- On resuming at 12.35 p.m.

10             MR. KRGOVIC: [Interpretation]

11        Q.   Mr. Jankovic, I have several short questions left for you.

12             MR. KRGOVIC: [Interpretation] Can the witness be shown P00377,

13     which is behind tab 52 of the Prosecution binder.  Please enlarge it.

14        Q.   Mr. Prosecutor read a portion of the document for you.  I will

15     read the part I'm interested in:

16             "This is to inform you that all the workers who have not signed

17     the solemn oath, or rather, who have not declared their intention to

18     continue working in public security stations as units of organisation,

19     the Banja Luka CSB of the Serbian Republic of Bosnia-Herzegovina MUP

20     have -- are to have that employment terminated as at 15 April 1992."

21             And then you did say it, but could you remind me whose signature

22     this was?

23        A.   I said and I'm convinced that it's Milutin Cadjo, the then

24     commander.

25        Q.   It goes on to read.  The chief has decided --

Page 25078

 1        A.   It says:  Has expressed his agreement with and then employment or

 2     what?

 3        Q.   Well, the interpretation says "emphasized."

 4        A.   From what I can read there he came to an agreement or agreed to

 5     something with someone.

 6        Q.   Do you know who was Cadjo's immediate superior?

 7        A.   Cadjo's?

 8        Q.   Yes, in the Prijedor public security station.

 9        A.   Well, I'm not sure.  There was jostling for position there.

10     There was Dujo Jankovic who was a commander and then -- well, I believe

11     that Jankovic was his senior, though I know that Cadjo was a commander

12     for a period as well in our building.

13        Q.   And who was their superior?

14        A.   Well, Simo, Simo was.  There was nobody in between them.  There

15     was them and then Simo.

16        Q.   Answering to the questions put by the Prosecutor in page 21 you

17     spoke of Simo Drljaca.  You described him.  You gave us an illustration,

18     and there's a part of what you said missing, so would you please now in

19     answering my question answer fully.  Whenever Simo wanted to shift

20     responsibility onto someone he would consult people, ask them, but

21     whenever he needed to have something done, that's where your sentence

22     doesn't end.  Whenever he was to gain or get something for himself, what

23     did you say then?

24        A.   Yes, yes, I remember I was saying that.  Yes, I knew what I

25     meant.  I just have to put it in words.  I did take the example of, I

Page 25079

 1     believe, parents and children.  Whenever he wanted the responsibility to

 2     lie with somebody else, he would be inquiring and in consulting people.

 3     But when he wanted something to be done and he didn't want many people to

 4     know about it, then he would set about it on his own.  You did mention

 5     fuel, that quantity of fuel, if what I heard was true.  Well, he didn't

 6     call the chief of the centre to ask him:  Chief, can we please steal your

 7     supply of fuel -- or whoever it was who did that.  I mean, I don't know

 8     if it was him.  That's what I wanted to say.

 9        Q.   Generally speaking, in respect of the regular period before these

10     events, whenever the chief of the station had to make important decisions

11     or have important decisions implemented, would he be briefing the

12     collegium about all this?  And I'm asking about the pre-Simo Drljaca

13     period.  Was this standard practice?

14        A.   Well, yes.  Whatever was of some significance was discussed and

15     agreed at the collegium meeting.  Only if it had to do with strictly

16     police business, then it would be the commanders and chiefs talking and I

17     wouldn't be joining their discussion because it wasn't my lot, but I

18     would be there.  Of course there were moments when I wasn't present at

19     these meetings, and then I wouldn't know anything.  So I wasn't a

20     participant, but I was present at the collegium meeting and would hear.

21     As for the latter period, that wasn't the case, no.

22        Q.   Did Mr. Drljaca say that you should adhere to the decisions taken

23     by Chief Zupljanin, and did he give you any sort of instruction on this

24     issue?

25        A.   Far from it.  Not at all.  Let me be more specific.  He didn't

Page 25080

 1     say either that we shouldn't be complying with what he said.  He just

 2     gave us our tasks and told us what we were to do.  And as for him

 3     addressing us on any issue, well, that individual didn't figure in that

 4     at all.

 5        Q.   Tell me, Mr. Jankovic, when it came to the workings of the public

 6     security station during Mr. Drljaca's time there, did they depart from

 7     standard practice?  You said at one point that there was this departure

 8     from standard procedure by 95 per cent you said in some context.  So

 9     would you say that this was true also for the running of the public

10     security station while Mr. Drljaca was there?

11        A.   [No interpretation]

12             THE INTERPRETER:  Can the witness please repeat his answer.

13             THE WITNESS: [Interpretation] It wasn't just him.  There were

14     other policemen who were police illiterates, the way I called them.  It

15     wasn't just him.

16             MR. KRGOVIC: [Interpretation]

17        Q.   I'm sorry, sir.  Mr. Jankovic, your answer wasn't recorded

18     properly.  I asked you what the difference was between the period before

19     Mr. Drljaca and after Mr. Drljaca took up his position in the station.

20     You said what you had to say but it wasn't interpreted.

21        A.   Well, let me just say briefly that in the normal period there

22     were meetings, including the collegium, and the superior officer was

23     complied with.  Whatever they were doing they had to comply with what he

24     said.  And every policeman or member of the station would be doing their

25     proper job and report back to the superior.  None of that existed when he

Page 25081

 1     took up his position.  I don't know if he had any consultations with some

 2     of his associates.  What I can tell you is that I and some other people

 3     were not part of his consultations, plans, and such-like.

 4        Q.   The Prosecutor also asked you if you knew when it was that

 5     Mr. Simo Drljaca was replaced.  I think you did say that you wouldn't be

 6     able to pin-point the date, and do you know who it was who removed

 7     Simo Drljaca?

 8        A.   I don't.  I only know that he went to Bijeljina, returned, and

 9     then left for good.

10        Q.   When discussing the Omarska and Keraterm centres, the Prosecutor

11     asked you about the growing numbers of these people.  You were talking

12     about the fact that both sides were preparing for clashes.  In that

13     period of time, early April [as interpreted], was it known the number of

14     Croats and Muslims who had taken part in these activities, i.e., attacks

15     on Prijedor?  And was there available information about how many of such

16     organised units there were?

17        A.   Well, I don't know the number --

18             MR. HANNIS:  I'm sorry, the question needs some clarification.

19     It says:

20             "In that period of time, early April, was it known the number of

21     Croats and Muslims who had taken part in these activities, i.e., attacks

22     on Prijedor?"

23             Now, I understand the attack on Prijedor was May the 30th, so

24     nobody could have known in April 1992 who was involved.

25             MR. KRGOVIC: [Interpretation] I don't think I mentioned April,

Page 25082

 1     but let me be more precise.

 2        Q.   Mr. Jankovic, at that point in time in Prijedor when the

 3     hostilities broke out and when these centres of Keraterm and Omarska were

 4     set up, what were the assessments of the numbers of Muslims and Croats

 5     who had been organised in these units?

 6        A.   How many individuals took part in the attack?

 7        Q.   No.  How many people were organised into formations as a result

 8     of responding to mobilisation call-ups.

 9        A.   In Prijedor, well I don't know the number.  I can give you some

10     guesses.  I do know that the lesser part of them did not participate.  I

11     know that there were 49.000 Muslims in the municipality.  There were

12     fewer Croats.  So let's say that there were 50.000 of them.  Let's say

13     that half of them were women, then you're left with 25.000.  And let's

14     say that 40 per cent of them would be able-bodied because you would have

15     the elderly and children.  And then if you take into account those who

16     deserted as well, there might have been those, you would end up with a

17     figure of 10.000.

18             Or let me give you this other view of mine.  The Kozarac police

19     substation which belonged to the Prijedor station covered 22.000

20     inhabitants before the war.  Of these 22.000, there were very few who

21     weren't Muslims.  There were Serbs, Ukrainians, Croats, but a handful in

22     all.  I don't think there were more than 2.000 of them.  So if we take

23     Kozarac alone to have had 20.000 Muslims and then half of them men and a

24     third of those were participants because of the rest being children and

25     elderly, again you would end up with some 3- to 4.000 persons as

Page 25083

 1     active-duty people.  But that would merely be my maths.  I didn't see any

 2     lists anywhere.

 3        Q.   A moment ago you said there was a small number of them who did

 4     not respond to the mobilisation, small number of Muslims.  What did you

 5     have in mind?  Did you have the JNA mobilisation?

 6        A.   No.  For example, I and my friend Djeric, who was an electrical

 7     engineer working in the mine, when the unrest period occurred before the

 8     take-over he took his wife and went to Germany.  He found work there.

 9     Not everyone was able to do that, but he avoided being drafted.  So he

10     was an able-bodied man who left and lived a good life elsewhere.  There

11     were many such people but not everyone could do that.

12        Q.   When you discussed mobilisation, did you have in mind the Muslim

13     TO mobilisation or some other?

14        A.   I said that I even saw on tape that everyone had their own

15     mobilisation.  All I could see on that tape was that there was a

16     mobilisation.  Whose it was and how many people there were I don't know.

17     I could see people there, but how many people they called, how many

18     people they gathered, that's something I don't know.

19        Q.   The Prosecutor showed you a number of documents discussing Serb

20     preparations for the beginning of activities.  I'll show you 2D00108.

21     You compared those preparations to the race to the moon between the US

22     and the USSR?

23        A.   Yes, just as an illustration.

24        Q.   We have a criminal report submitted by the Ministry of the

25     Interior.  Could we please go to page 3 in the Serbian version.  In the

Page 25084

 1     explanation of reasons it says that in late 1991 and early 1992 organised

 2     by the -- the organisation of Prijedor SDA is being approached by a

 3     number of people who wanted to have arms.  For that purpose they began

 4     collecting financial means to purchase weapons with the help of, among

 5     others, the so-called Prijedor Crisis Staff comprised exclusively of

 6     citizens of Muslim nationality.  Certain people left for Germany.

 7             My question is this:  Did you have any knowledge or information

 8     that at the same time the Serbs were forming their Crisis Staff, the

 9     Muslims had their own parallel organisation preparing for a take-over?

10        A.   I wasn't familiar with the whole situation.  I could just see

11     details here and there.  Suljo the colleague of mine, and who was a

12     neighbour, too, complained to me, and he was relatively wealthy just

13     before the war because he had poker machines in police facilities.  It

14     was -- he was -- he never wanted to give away much money and me

15     complained to me that they asked for a lot.  He basically told me that he

16     had to provide money, and he wasn't the only one that must have been

17     asked.

18             The -- when the shooting occurred during the attack on Prijedor,

19     for example, I could hear the fighting.  When you hear gun-shots you

20     could tell when a particular rifle was used called a Singapore rifle

21     which had a higher-frequency bullet sound like a wasp.  Our military and

22     the police did not have any other rifles save for the semi-automatic

23     produced by the Zastava factory and the so-called Kalashnikov, the

24     automatic rifle.  They sound the same.  When I heard what I did during

25     the first few days, I heard such sounds.  It must mean that those rifles

Page 25085

 1     were purchased from somewhere.  So there were weapons around.  It's not

 2     like they were without any weapons all of a sudden.  As far as I know,

 3     there were up to three companies involved, one across the bridge, one

 4     next to the Sedelos [phoen] facility, and another one.  And if a company

 5     has about a hundred people, I suppose they didn't send people into combat

 6     unarmed and it takes preparation.

 7        Q.   Mr. Jankovic, please focus on my questions.  I have very few

 8     left.  You have already provided me with an answer.  The Prosecutor

 9     showed you P2394 a moment ago and I want you to see it again.  It's tab

10     137.  Apologies.  It's P689 actually.  Next page, please.

11             This is Mr. Drljaca's document.  He mentioned 400 police members.

12     You've already told us what you think of his figures.  And that -- those

13     400 were supposed to be in Cirkin Polje.  You told us what your

14     assessment was of the number of people.  When you issued the IDs, were

15     you given 400 or 500 such forms approximately?

16        A.   Well, the cards were packed in small boxes resembling a cigarette

17     box.  It was about this size and when I finished it went down to that.

18        Q.   Could that have included 400 IDs?

19        A.   Impossible.  They didn't only ask for those on the first day.

20        Q.   [Microphone not activated]

21             THE INTERPRETER:  Microphone for Mr. Krgovic, please.

22             JUDGE DELVOIE:  [Microphone not activated]

23             MR. KRGOVIC: [Interpretation]

24        Q.   Yes, you already said that it was impossible that there were that

25     many?

Page 25086

 1        A.   That's correct.  Not everyone got it the first evening.

 2        Q.   Let me ask you this and please let me finish before answering.

 3     You described the people you saw in different uniforms and you said there

 4     were all kinds.  You said that some had police uniforms and then there

 5     were others.  In your assessment which group was bigger?

 6        A.   I said that there were all sorts of colours.  There were three or

 7     four different military uniforms, types of uniforms, the camouflage, the

 8     regular ones, the old for the reserve force, the olive-drab.  There were

 9     many without any uniform or in just a shirt.  Some were in jute clothes

10     resembling those that were issued to the reserve police force a while

11     ago, and I didn't see any of my colleagues there, people who worked with

12     me.  I knew all of them because I was there every day with them.

13        Q.   Compared to the overall number or -- what would be the

14     percentage, 15, 20 per cent of those you saw?

15        A.   Well, it's difficult to say.  It's half dark and I'm writing out

16     forms.  I told you there was a short meeting and then Simo gave me the

17     forms.  I didn't go out.  It was getting dark.  I would have to guess

18     whatever I said.  There may have been 20 per cent of our active

19     personnel, but it's best not to say anything because there could have

20     been two times as many or as few.

21        Q.   That's all right if you can't say.

22             MR. KRGOVIC: [Interpretation] Thank you, Your Honours, I have no

23     further questions.

24                           [Trial Chamber confers]

25                           Questioned by the Court:

Page 25087

 1             JUDGE HARHOFF:  Mr. Jankovic, I have just one small question for

 2     you.  You told us I think a couple of days back during your testimony

 3     here that at the meeting that was held on the evening of the 29th of

 4     April before the take-over of Prijedor, a great number of people were

 5     present that night.  You mentioned that a number of police officers were

 6     there.  I think you also mentioned that some paramilitary forces were

 7     there, and you also mentioned that there were two army officers.  Do you

 8     recall what you told us?

 9        A.   First of all, you said a meeting and then I thought you were

10     thinking of the 29th concerning the take-over.  And then from the latter

11     part of your question, I realised that you had a different thing in mind.

12     I thought you meant the meeting concerning the dispatch at 2.00 p.m., and

13     the other thing in the evening -- well, do you have in mind the other

14     part in Cirkin Polje and that you refer to it as a meeting?  In

15     Cirkin Polje?

16             JUDGE HARHOFF:  I do indeed, thanks.

17        A.   So I'm not discussing the part at 2.00 p.m., but the one

18     following 8.00 p.m.  I did use the term "a small meeting," but it wasn't

19     an official meeting.  I'll try to illustrate.  I got there, it was a

20     pre-fab building the size of this room surrounded by a courtyard three

21     times as big.  And there were many people there, maybe a hundred, 120 in

22     different groups discussing.  I got in as a junior manager.  I went in to

23     see where the others were and I found the commander there, the chief of

24     the crime service, and Hasan Talundzic, and Fikret.  Then Simo appeared,

25     I could see him.  I didn't talk to him because I didn't know him, but

Page 25088

 1     others did.  And since -- it became an office as a matter of fact -- I'll

 2     try to slow down.  It was the office of the local commune secretary who

 3     was in charge of issuing birth certificates, et cetera, there was a table

 4     there.  And people in charge sat down.  Simo said, "My name is

 5     Simo Drljaca.  I was sent by the SDS."  We introduced ourselves to them,

 6     and he seemed to know the people from the police, and I was always sort

 7     of on the side.  I was present but I didn't participate in the

 8     conversation because it came upon me all of a sudden.  I could observe

 9     what was going on there, and I can't tell you word for word what they

10     said.  But those four or five of them agreed that it should be sent to

11     town.

12             JUDGE HARHOFF:  Very well.  You see, my question goes to the

13     following aspects of those events; namely, who had organised all of this?

14     It must have taken some co-ordinated efforts to gather all these people

15     together with the purpose of taking over Prijedor during that night and

16     in the early morning hours of the following day.  Who in your

17     understanding was behind this?

18        A.   First of all, when you say that it was co-ordinated, it is my

19     opinion too.  It is impossible it was a mere coincidence.  That's the

20     first conclusion.  The second, if Simo arrived, some, including myself,

21     didn't know him because he was not a familiar person around town.  Maybe

22     half of the policemen did know him, the other half did not.  If he

23     arrived saying he was sent by the SDS, their involvement is obvious.  If

24     there was this major there whom I mentioned who asked for hand-held

25     devices, and there was another military person whose rank I no longer

Page 25089

 1     recall, and I could see them even though it was getting dark, there may

 2     have been more, it must mean that the army was involved too.  If someone

 3     called me through the communications centre, because we always had such

 4     situations in which we would be called to do something without any

 5     previous planning; for example, the chief can say, "Bring together the

 6     whole station."  And then the secretary does that.  They would do that

 7     through the communications centre to get to me.  Perhaps they would call

 8     ten people and those ten would call those under them.  It didn't strike

 9     me as unusual the way we were summoned, but I don't know who took part in

10     all that.  I never bothered to find out.

11             I did see all of those people there and it seemed to me they were

12     acting in concert.  No one seemed surprised.

13             JUDGE HARHOFF:  Thank you.  So your answer is that you are not

14     able to form an opinion about who had organised all of this.  You

15     mentioned that the army was there, that the SDS obviously played a role,

16     the police was involved as well, and possibly a number of others.  But

17     you do not have any opinion about who had organised the meeting in the

18     following events; is that correct?

19        A.   Yes.  I said that there were people from different organisational

20     parts.  I learned in the course of my work not to think about things I

21     shouldn't be.  It's not up to me to think about what the Prosecutor is

22     trying to do.  I know that if I'm summoned somewhere, I'm to sit there

23     and await for my tasks to be given to me.  I'm not the man in charge.

24             JUDGE HARHOFF:  Thank you, Mr. Jankovic.

25             MR. HANNIS:  Your Honours, I'm sorry to intervene, and I do it

Page 25090

 1     with great trepidation, but there was something in an earlier part of the

 2     answer that's extremely unclear to me and seems inconsistent and I would

 3     like to ask about.  It's at page 71 -- page 70, line 25.

 4                           Further Cross-examination by Mr. Hannis:

 5        Q.   Witness, Judge Harhoff asked you a question, and in your answer

 6     you said:

 7             "I got there, it was a pre-fab building the size of this room

 8     surrounded by a courtyard three times as big.  There were people there,

 9     maybe a hundred, 120 in different groups discussing.  I got in as a

10     junior manager.  I went in to see where the others were and I found the

11     commander there, the chief of the service, Hasan Talundzic, and Fikret."

12             Now, are you talking -- you're not talking about Cirkin Polje,

13     are you?  Because I had the understanding that there weren't any Muslims

14     at Cirkin Polje on the night of the 29th of April.

15        A.   Either you did not understand me or maybe I spoke too fast.  I

16     did say what you said, but what I meant to say that it was Fikret and

17     Hasan of course were not there.  That is probably what was missing.

18        Q.   Okay.  That's what I thought was the case.  I just wanted to be

19     sure.

20             JUDGE HARHOFF:  Thank you Mr. --

21             MR. HANNIS:  Thank you.

22             JUDGE HARHOFF:  Mr. Jankovic, I too actually wondered about it,

23     and it makes a huge difference of course.  So you confirm that there were

24     no Muslims present at the meeting that night or at the gathering?

25             THE WITNESS: [Interpretation] It's good that we cleared it up.

Page 25091

 1             JUDGE HARHOFF:  Thanks a lot.

 2             Thanks, Mr. Hannis.

 3             JUDGE HALL:  There was something arising, Mr. Krgovic?  You

 4     seemed to be about to rise?

 5             MR. HANNIS:  There was one thing I had requested, Your Honour,

 6     when the witness went home if he could look for his ID card that he had

 7     prepared that night.  He thought he might still have it, and I'd

 8     requested that the Trial Chamber direct Victim Witness to co-ordinate

 9     with him on that in the event that he might be able to find it and loan

10     it to us to make a copy and enter it into the record.

11             JUDGE HALL:  Yes, Mr. Jankovic, Mr. Hannis has just reminded you

12     of something that he requested yesterday.  So the -- such directions as

13     are necessary for the -- to facilitate the Chamber now makes.  So you can

14     expect to be contacted by, I suppose by VWS in terms of facilitating

15     this.

16             And your testimony is now at an end and you are released.  We

17     thank you for coming to assist the Tribunal and we wish you a safe

18     journey back home.  The Chamber has certain procedural matters with which

19     to deal so it isn't rising at the moment, and I would ask the usher to

20     please escort you from the courtroom.  Thank you, sir.

21             Did you wish to say something?

22             THE WITNESS: [Interpretation] Yes, I just wanted to ask you

23     something.  I already said that it's not a problem for me to provide a

24     copy.  There could be a technical matter, though, because I need to copy

25     it first.  In any case, if there is someone who could call me, you know

Page 25092

 1     my phone number, and then we could meet and hand-over the copy.

 2             There was another thing.  I was trying to remember things and the

 3     ID is like a booklet, you can open it.  On the right-hand side is the

 4     same text that used to be on the Yugoslav IDs, which is that the

 5     authorised official is entitled to verify one's identity, bring in

 6     persons, seize weapons, et cetera, in accordance with the law.  This is

 7     quite standard for any police force in the world.  It was on the

 8     right-hand side once you open the booklet.  It read:  Official ID.  And

 9     on the left-hand side there was first and last name and a few other

10     details.  That was it.  On the right-hand side was the text.  On the back

11     side there was nothing.  Perhaps someone should get in touch with me and

12     then we'll make a copy.  There's no reason for me not to.

13             JUDGE HALL:  Thank you, sir.

14                           [The witness withdrew]

15             JUDGE HALL:  Before we rise for the day, the Chamber wishes to

16     note that next week's schedule will be subject to some changes in order

17     to accommodate two Plenary sessions which have been -- Plenary session of

18     Judges which have been scheduled for Wednesday and Thursday.  So in order

19     to ensure that the witness next week completes his testimony before we

20     adjourn for two weeks, according to the last published schedule in

21     alternating trials, the Trial Chamber is making arrangements to sit an

22     extra session on the afternoon of both Monday and Tuesday.

23             Now, on Wednesday we are scheduled to sit in the afternoon and we

24     need to commence the hearing in the morning and then rise in the middle

25     of the day to reconvene in the afternoon after a break of approximately

Page 25093

 1     two and a half hours.  The details of this are still being worked out.

 2     And on Thursday, when we are also scheduled to sit in the afternoon, we

 3     will sit as normal, and we expect to sit regular hours on Friday morning.

 4     Parties should note that the precise details of this would be

 5     communicated the -- by the Legal Officers by way of e-mail.

 6             And if I may a moment, there's a note that I'm just seeing.

 7             The only thing I would add is that the concern of the Chamber

 8     remains that no court time is lost so that wherever gaps or otherwise

 9     occurs, the Chamber fully expects that the counsel would make every

10     effort to ensure that the time is fully spent.  Did counsel -- I

11     understand that the OTP has certain scheduling matters themselves to

12     raise.

13             MR. HANNIS:  Yes.  Your last comment sort of addressed what I

14     wanted to raise, Your Honour.  Given what had happened during the last

15     alternation between this trial and the Haradinaj trial, where there was a

16     gap, we did manage to get one witness in for one day.  But I guess just

17     in anticipating the possibility that something might happen again the

18     next time, we just wanted to alert everybody that if that happens, we

19     would ask the Defence to let us know if they will be able to bring in

20     somebody on short notice and who that might be so we can deal with that

21     in the event that we might be sitting sometime between the 24th of

22     October and the 4th of November in case Haradinaj is not sitting for any

23     reason whatever.  That was the first point.

24             And the second was, Your Honour, regarding the next witness from

25     the Defence, SZ-009.  I understand he's here already and has been here

Page 25094

 1     for a little while.  We would request if there's any proofing note we

 2     have it as soon as possible because his 65 ter is four brief paragraphs

 3     and rather vague.  One says:

 4             "The witness will speak about his visit to Prijedor during the

 5     summer of 1992.  Furthermore, he'll testify about his stay in Doboj in

 6     May 1992."

 7             That's not very informative and given that we don't have a

 8     statement from him and haven't had an interview with him, it would assist

 9     if we can have -- and he's not willing to speak to us, it would assist if

10     we could have some further details in our preparations for his

11     cross-examine.  Thank you.

12             MR. KRGOVIC: [Interpretation] Your Honour, as for the proofing

13     note, my colleague Mr. Aleksic is dealing with that and he will send it

14     in the course of the day.  What the Prosecutor said latterly is partly

15     untrue.  The witness [as interpreted] did speak to the witness back in

16     2004, and they do have a pretty detailed outline of his future testimony.

17     This would be the second time that they are seeing the witness and there

18     should be no doubt as to what this witness will speak to.

19             JUDGE HALL:  Thank you.

20             So with that we take the adjournment to reconvene -- I think we

21     sit in this courtroom next week at 9.00 Monday morning, and I trust

22     everyone has a safe weekend.

23                           --- Whereupon the hearing adjourned at 1.22 p.m.,

24                           to be reconvened on Monday, the 17th day of

25                           October, 2011, at 9.00 a.m.