111019IT

Page 25317

1 JUDGE HALL: Yes, Mr. Olmsted, you may continue.

2 MR. OLMSTED: Thank you, Your Honours.

3 Cross-examination by Mr. Olmsted: [Continued]

4 Q. Mr. Sajinovic, did you and the other -- or the former member of

5 the Milos group who is the -- responsible for communications, did the two

6 of you have a conversation with Vojin Bera in June or July of 2010 about

7 the flow of intelligence information from Mr. Radulovic up the internal

8 chain of command of the RS MUP in 1992?

9 A. Mr. Prosecutor, I cannot remember talking with him about the

10 information that you mentioned. I don't think I did.

11 Q. Let's start with, did you and the other member of the Milos group

12 that I mentioned, did you have a conversation with Mr. Bera in around

13 June/July of 2010?

14 A. I honestly don't remember when was the last time I saw Mr. Bera.

15 I'm not sure that I ever talked to him in the last year or two. I don't

16 know.

17 Now, as for the other member of the team, I see him on a daily

18 basis. He is a friend of mine, and he is my children's godfather.

19 Q. I'll try this one more time. You are, of course, aware that

20 Mr. Radulovic testified before this Tribunal last year. After his

21 testimony, did you have a conversation with Mr. Bera concerning that,

22 issues raised during that testimony?

23 A. Mr. Prosecutor, I'm going to repeat what I already said twice,

24 and I can tell you that I cannot remember. Frankly speaking, I don't

25 remember seeing Mr. Bera. It might have happened that I came across him

Page 25318

1 by accident, but what you are asking me specifically about, and the

2 conversation with him, this is something that I cannot remember.

3 Q. Then I'll have to move on.

4 Sir, you've testified that the Milos group was in Doboj in the

5 mid-May time-period. Does that mean that you arrived after the takeover

6 of Doboj town by the Serb forces?

7 A. That's right, Mr. Prosecutor.

8 Q. And for how long did you remain in Doboj?

9 A. I cannot remember exactly at this moment for how long we stayed

10 in Doboj. We were there, I don't know, a couple of days. Seven, ten,

11 days. I really cannot remember. It's been a long time ago. But I do

12 know that it was after the takeover that you referred to.

13 MR. OLMSTED: May we have on the screen 1D303, tab 10.

14 [Trial Chamber and Registrar confer]

15 MR. OLMSTED:

16 Q. All right. We have in front of us a 12 May 1992 Milos report,

17 numbered 125/92. And if we can read -- it begins about halfway through:

18 "There is panic in Doboj and the town can hardly be expected to

19 keep its current status because an attack on it is being prepared from

20 the direction of Gracanica, Maglaj, Bosanski Brod and Tesanj. Since we

21 are reporting from Doboj please forward this urgently to the chief of the

22 Banja Luka CSB and request suggestions regarding our further status in

23 this area."

24 Mr. Sajinovic, you will agree that this is an example of

25 Mr. Radulovic, again, using Belgrade to communicate with Mr. Zupljanin?

Page 25319

1 A. Well, I recognise the document that I can see on the monitor as

2 being one of the documents produced by the Milos group.

3 Now, one can discern from the text where we were and that

4 Mr. Radulovic was asking some suggestions from Belgrade, just as you read

5 it. Everything is correct.

6 Q. Well, he's asking, not suggesting. He is asking Belgrade to

7 forward urgently to Mr. Zupljanin this message and request suggestions

8 regarding further status. So he is asking Belgrade to do something on

9 his behalf; isn't that correct?

10 A. He is asking Belgrade to relay the message to Mr. Zupljanin, just

11 as it says in the document.

12 Q. Do you recall what was the issue regarding your status in Doboj,

13 that he was wanting clarification from Mr. Zupljanin?

14 A. I really cannot remember, Mr. Prosecutor. It was a long time

15 ago. And this note is not helpful. I don't know what they were

16 specifically referring to.

17 Q. Let's look at 65 ter 20004. It's tab 12.

18 What we have in front of us is a 13 May 1992 Milos report,

19 132/92. Can you confirm this is one of the -- your team's reports?

20 A. Yes, I can. Yes, it's one of our reports.

21 Q. Now, this report was sent the very next day from the previous

22 report we just looked at. And it states that according to the latest

23 reports, there is no imminent danger of a direct attack on Doboj by

24 Croatian armed forces and Muslim armed forces although the security

25 situation is still difficult.

Page 25320

1 So will you agree that as it turned out, there was no attack

2 planned on Doboj at that time after all? In other words, what was stated

3 in the prior report of an attack that was about to happen, in fact,

4 turned out to be incorrect.

5 A. Of course I cannot agree. You are putting me in a certain

6 context as if I were on the side of Croats or the Muslims and that I knew

7 what was their plan. I really didn't know what their plans were, and,

8 therefore, I cannot agree with you.

9 Q. That's not what I'm suggesting. Mr. Radulovic here in this

10 report is indicating that the intelligence, now, was that no attack was

11 imminent, as of the very next day, there was no attack that was imminent;

12 is that correct?

13 A. Mr. Prosecutor, the fighting around Doboj happened 2 or 3

14 kilometres from Doboj, if I remember correctly. That means that every

15 minute virtually there was a possibility for the Serbian defence line to

16 be broken through and to have enemy forces entering the town. If that's

17 what you're asking me about.

18 Now, as for the report that we saw on the screens a moment ago,

19 it says clear that according to the latest information, which means at

20 the moment when the report was being written, there was no imminent

21 danger of attack. They even say the exact hour when this report was

22 produced which was not the common practice with our reports. That means

23 that on the 12th of May -- on 13th of May at 1200 hours, there was no

24 danger. Maybe the situation changed at 1300 hours.

25 Q. All right. Let's take a look at 65 ter 20122. This is tab 11.

Page 25321

1 So this is a 12 May 1992 Milos report numbered 126/92. I'm not

2 showing you them in chronological order because this one is actually the

3 date of the first Doboj document I showed you, and it reports:

4 "... an artillery attack on the Muslim village of Grapska, Doboj

5 municipality, caused very many civilian casualties, including children."

6 How far is Grapska from Doboj?

7 A. Well, you haven't shown me the reports in the chronological

8 order, the one was from 13 and now one is from the 12th.

9 Now, as for the village of Grapska, I'm not sure. It's not far

10 from Doboj, but I can't tell you how many kilometres. I wouldn't like to

11 speculate. Anyway, it's not far away.

12 Q. And being in Doboj, do you recall how the Muslim citizens who

13 remained in Doboj town reacted to the news of this attack on a nearby

14 village? How did they react?

15 A. As much as I try, I really cannot remember. I don't think that

16 everybody had all the information at the time. You're asking me about

17 the Muslims' reaction. I was in contact with all the citizens of Doboj

18 on a daily basis, regardless of their ethnicity, so I don't know,

19 although I've read this note, I really don't remember this incident of

20 shelling. I'm not familiar with that.

21 So, at this point in time, I really cannot remember. Therefore,

22 it would be very difficult for me to describe to you how they felt. The

23 situation was bad. There was no electricity. I don't know how relevant

24 the information was that was produced in the media. I don't know.

25 Q. But can you confirm this one of the Milos team reports?

Page 25322

1 JUDGE HALL: Sorry, Mr. Aleksic is on his feet.

2 MR. ALEKSIC: [Interpretation] I apologise to my learned friend

3 Mr. Olmsted. Just for the clarity of the transcript, page 6, line 16, it

4 is written "I was in contact." Although I think that the witness said

5 otherwise.

6 MR. OLMSTED: I'll clarify that matter. Thank you.

7 Q. Can you clarify, does -- just to make sure the transcript is

8 correct. It's not because we're accusing of you anything.

9 But can you confirm for us that were not, in fact, in contact

10 with all the citizens in Doboj town at the time?

11 A. Yes, that's what I said. And that is the truth.

12 Q. And can you confirm this document we have in front of us, that

13 this is one of the Milos team's reports. It's the format and it has the

14 handwriting that we expect.

15 A. Yes. Concerning the format, the signature, and the handwriting,

16 I can recognise this document as the document of the Milos group.

17 Now, as far as the contents are concerned, I already said.

18 Q. May you please take off your headphones for a minute.

19 MR. OLMSTED: Your Honours, at this time, we would like to tender

20 these two exhibits into evidence as 65 ter 20004 and 20122.

21 MR. ALEKSIC: [Interpretation] No objection, Your Honour.

22 JUDGE HALL: Admitted and marked.

23 THE REGISTRAR: As Exhibits P2401 and 2402, Your Honours.

24 MR. OLMSTED:

25 Q. Sir, you mentioned during your examination-in-chief that there

Page 25323

1 were about five SDB Banja Luka officers present in Doboj during this

2 period of May investigating and taking statements from people "involved

3 in fighting against the Serbian people."

4 I take it by that you meant you were questioning -- or they were

5 questioning non-Serbs?

6 A. Mr. Prosecutor, it is not true that this is what I said.

7 I said that, at the time, there was a group made up of five or

8 six members of the State Security Service in Doboj, and if I remember

9 correctly, in a private session, I even gave you three names of members

10 of that group. Now you're talking about two members. That's as far as

11 this is concerned.

12 Now, concerning their role and their activities while they were

13 transferred from Banja Luka to Doboj, I know that they conducted

14 interviews with people who were of interest for the service. And I think

15 that this is what I said and I'm repeating it today.

16 I allow for the possibility, though, that quite a few people of

17 those were non-Serbs, but if there were any Serbs who were of interest

18 for the security service, they would have been interviewed as well.

19 Q. But just to make sure I'm absolutely clear on this: These state

20 security inspectors, they were Banja Luka -- Banja Luka state security

21 inspectors who were transferred temporarily to Doboj to assist with

22 interrogations.

23 A. Yes. It's been translated to me that they were from Banja Luka

24 and that they were transferred temporarily to Banja Luka.

25 Okay. Yes, that's correct, if that's what you said. They were

Page 25324

1 the SDB members of Banja Luka, and they were, I might say, seconded to do

2 their duties temporarily in Doboj.

3 Q. And for how long were they engaging in these activities in Doboj;

4 if you recall?

5 A. I cannot remember exactly the duration of the period, but I know

6 that they stayed behind in Doboj after we'd left. I know that one of

7 those inspectors remained permanently in Doboj; that is to say, he got a

8 permanent job there and continued living and working there.

9 Q. And who -- if you know, who temporarily reassigned them to Doboj?

10 A. Mr. Prosecutor, I don't know that. I can only assume how the

11 procedure should have been implemented.

12 Q. It would have required Mr. Kesic's authorisation at the very

13 least; isn't that correct?

14 A. That is correct. That's what I meant when I said that I suppose

15 how it should have been. And I wouldn't say at least. I think that

16 Mr. Kesic's approval or authorisations would suffice, and also

17 Mr. Zivkovic's request was required, who was, at the time, the chief of

18 the state security in Doboj.

19 Q. And can you tell us why it was necessary for the CSB Banja Luka

20 to assist Doboj in conducting these interrogations?

21 A. Just like in case of the previous question that you asked me in

22 view of my position within the hierarchy, I can tell you that I really

23 don't know. I really want to be 100 percent sincere. I can tell you

24 what my opinion is, if you are interested to hear it.

25 Q. That's not necessary.

Page 25325

1 Do you know -- do you know if there were a significant, a large

2 number of non-Serbs who had been arrested and detained during this

3 time-period? Were you aware of that? And, of course, I'm speaking of

4 Doboj.

5 A. I can't tell you that. Whatever I would say, it would amount to

6 speculation. During our stay there, I never saw any kind of facility or

7 collection centre where those people were detained. I really don't know.

8 Q. Well, you were aware there was a Doboj prison right behind the

9 police building, or right -- right near it?

10 A. Yes, of course. It was quite close to the police station, the

11 Doboj prison.

12 Q. And were you aware that non-Serbs were being detained there

13 during this time-period, awaiting their interrogations?

14 A. I wasn't aware of that, but it makes complete sense to me to

15 detain people there, whatever their nationality is, who are to be

16 interrogated and processed. That was the case before the war, and this

17 prison serves the same purpose even nowadays.

18 The only thing I know about the prison, now that you mention it,

19 is something that I heard from Radulovic; that is, that 80 to 90 per cent

20 of the prison employees were non-Serbs. I think that we wrote some kind

21 of report in that respect.

22 Q. That was a report that you saw during proofing last week.

23 A. I saw that report, I don't know if it was in Banja Luka or in

24 The Hague, but I remember it, and I remember the contents.

25 Q. These state security inspectors from Banja Luka, where did they

Page 25326

1 conduct their interrogations? Was it at the CSB building?

2 A. Yes. That was in the CSB building and at the police station in

3 Doboj; but that's the same building.

4 Q. And do you recall who brought these non-Serbs in for their

5 interrogation by -- by the state security? Were they escorted in by

6 police officers?

7 A. If I remember correctly, the policemen from that police station

8 in Doboj brought them in. But, as I've said already, I was perhaps only

9 once or twice outside that building and inside that building during all

10 the time we were in Doboj.

11 Q. Now while these state security Banja Luka officials were in

12 Doboj, to whom were they submitting the reports of their activities?

13 A. Again, I can't be sure because I was not there when they

14 submitted those reports, but it would seem logical that they submitted

15 them to the chief of the state security in Doboj, because they came from

16 that area where they worked.

17 Q. Yes. But their supervisors were in Banja Luka. So would they

18 have to report on their daily activities back to Banja Luka so that --

19 that the -- their superiors in Banja Luka were aware of the activities

20 they were engaged in?

21 A. If you know that for a fact, then you must be right. I don't

22 know.

23 It's not logical to me that they would report to their superiors

24 in Banja Luka while a war was going on because the practice was when

25 somebody is seconded to a different unit, the chief in that area becomes

Page 25327

1 in charge of them. The same worked in the army. When a member of a

2 military unit from Banja Luka was reassigned to a different unit in a

3 different area, the commander in that area became their superior. It's

4 possible, of course, these state security officers sometimes reported to

5 Banja Luka, back to Banja Luka, but I don't think that they would make

6 daily reports to them.

7 Q. What you just told us reassigning from one region to another --

8 oh, excuse me.

9 MR. ALEKSIC: [Interpretation] I really apologise to my learned

10 friend Mr. Olmsted, but it was not my intention to interrupt.

11 But page 11, last line, the witness said something quite

12 different from what was recorded. This thing about a military unit, I

13 don't think the witness said that.

14 Could Mr. Olmsted perhaps clarify with the witness what he

15 actually said.

16 MR. OLMSTED:

17 Q. Well, yes, I can do that.

18 I have been asked to clarify something you just said for the

19 record.

20 You were talking about reassignment from one area to another.

21 Can repeat what you told us about that?

22 A. If you put the question again specifically, maybe it would be

23 easier to answer. But if you meant the reporting by the group of

24 operatives who were in Doboj, who had been reassigned from Banja Luka to

25 Doboj, I said it would seem to me that they would be reporting to the

Page 25328

1 state security chief, that is, the -- the line of work to which they

2 belonged but in that area, not the area from which they were reassigned.

3 And I used one example; namely, my colleagues, policemen, when they were

4 assigned to the front line, would fall under the command of the military

5 commander in whose area of responsibility they were. So during their

6 stint on the front line, they were no longer answerable to the chief of

7 police station. They were answerable to the commander in that area where

8 they were seconded. In this case, that would be the chief of the centre

9 for national security or state security, as you wish, in Doboj. If

10 that's what you meant.

11 Q. So you're drawing a parallel between an instance of being

12 resubordinated from the police to the military, to being temporarily sent

13 to another region to assist with interrogations. Is that what you're

14 trying to do?

15 MR. KRGOVIC: [Interpretation] Your Honour, I apologise. It's not

16 an objection. But I have an observation.

17 The word used by the witness "otkomanda" was interpreted three

18 times in different ways. Once it was "transferred." The second time,

19 "reassigned." And the third time as "seconded." And I think that might

20 be a problem. I don't know definitively what the proper translation is

21 for the word he is using. And I think that it might be the problem in

22 the communication between the witness and Mr. Olmsted.

23 MR. OLMSTED: Well, let me put it this way.

24 Q. You don't know under what arrangements these state security

25 persons were sent from Banja Luka to Doboj, do you?

Page 25329

1 A. You already asked a similar question, and I told you my opinion,

2 and I told you what I know. I know they worked in Doboj at the

3 State Security Service, and they conducted interviews on the premises of

4 the State Security Service; that is to say, the state security sector in

5 Doboj.

6 Q. And you're not referring to any particular regulations as to what

7 happens when a police officer assists in another region with regard to

8 their chain of command. You can't direct us to any particular regulation

9 or law with regard to that?

10 A. The question is not crystal-clear to me, to be honest, but I was

11 trying to be frank and to explain. You -- you said a moment ago I was

12 trying to make some comparisons and parallels, which I'm not trying to

13 do. I'm just trying to explain how things worked at the time, in the

14 area where I worked, where I lived, where I spent time, because you said

15 it makes sense for colleagues who were in Doboj to report back to their

16 superiors in Banja Luka. The colleagues who were seconded from

17 Banja Luka to Doboj. I said it doesn't makes sense to me, and that's it.

18 Q. All right. I'm going move on.

19 You testified that members of the Banja Luka Special Police

20 Detachment provided security for these state security officers from

21 Banja Luka while they were in Doboj.

22 A. Yes, I did say something like that in response to a question

23 either from you or somebody from the Defence. At that time, there was

24 several members of the police unit -- the special police unit from

25 Banja Luka who were the security detail for the inspectors of the

Page 25330

1 State Security Service who were working in Doboj at the time.

2 Q. And, if you know, who within the CSB Banja Luka would have

3 assigned those special police officers that duty?

4 A. I didn't understand. Who from the CSB Banja Luka would be

5 assigned to that duty? The duty to provide security to these colleagues?

6 That would be the members of the special police unit. Perhaps this is a

7 confusion due to misinterpretation.

8 Q. Let me try the question one more time.

9 If you know, only if you know, can you tell us who within the CSB

10 Banja Luka leadership would have assigned those special police -- special

11 police officers to this duty to guard or protect the state security

12 officials in Doboj?

13 A. I understand the question now. The answer, however, is: I don't

14 know. Because you said in your question "only if you know." I don't

15 know. I can only tell you what I can guess.

16 Q. And -- yes, exactly.

17 And if I don't put that, "if you know" before every question just

18 assume it's there.

19 MR. OLMSTED: Can we have document ID FI 20-0185-ET on the

20 screen, please. This is tab 53. And, Your Honours, this is, in essence,

21 Exhibit 2D89, but it's the corrected translation that we are still

22 waiting for the final procedural resolution of it. But as we have to

23 show it to witnesses, I want to use it with this witness.

24 And there's also a B/C/S version link to it as well.

25 And I have been just told by my Case Manager that we need to ...

Page 25331

1 [Prosecution counsel confer]

2 [Trial Chamber and Registrar confer]

3 MR. OLMSTED: The B/C/S version is FI 20-0185-1.

4 Now that we have both on the screen can we zoom into the names on

5 the list, the 17 or 18 or 15 names there.

6 Q. Mr. Sajinovic, I know that this list is a bit hard to read. But

7 can you tell us if you recognise any of these individuals as the special

8 police detachment members who were assigned to protect the Banja Luka

9 state security officers while they were in Doboj? And I understand that

10 it was only a few that were assigned to that particular task, but maybe

11 you could find those three or four individuals among these 15.

12 A. Mr. Prosecutor, out of these 15 names, I -- I just don't see 15.

13 If maybe we zoom in a little more. This is better.

14 Well, out of these 15 persons listed here, if I can correctly

15 make out the names and surnames, I recognise two or three as members of

16 the special police unit, special detachment.

17 Q. Yes. But my question to you is: Do you recognise the names of

18 the individuals who were in Doboj providing protection to the state

19 security inspectors in May of 1992?

20 Do you see their names on this list?

21 A. Well, Mr. Prosecutor, of course I didn't know the names of all

22 those people, but I can -- I can say that I've seen two or three of these

23 in Doboj. At least out of those whose names I can make out. People whom

24 I know personally.

25 Q. Can you give us -- there's a number next to each name. Can you

Page 25332

1 give us the number, the entry number, of the people you recognise?

2 A. Well, for instance, number 1. Number 13.

3 Q. Any others?

4 A. I know that number 2 was a member of the special police

5 detachment, but I don't remember seeing him in Doboj. And as for the

6 rest, I can't make out three, four, five of these names. And as far as

7 the others are concerned, I can't recognise their names as those of

8 members of the special police unit from Banja Luka.

9 Q. That's fine. I understand it's difficult to read. But at least

10 number 1 and number 13, those Banja Luka special detachment -- special

11 police detachment members were in Doboj providing protection in May of

12 1993?

13 A. Correct.

14 Q. Now if we can just scroll up and over to the right hand corner I

15 want to zoom in on the handwriting on the upper right-hand corner. Zoom

16 in as much as you can, because it is also a little bit difficult to read.

17 Now we see in the upper right-hand corner, we see the name

18 Slavica Komljenovic, C-o-m-l-y-e-n-o-v-i-c [sic]. She's up -- her name

19 is handwritten up there at the top. Who was she in 1992?

20 A. Mr. Prosecutor, this also indicates her job title. And I do know

21 that the lady with this name was a technical secretary at the CSB

22 Banja Luka, and I remember her name, Slava, Slavica. And her job title

23 reminded me of her.

24 Q. Can you read out for us her job title? Because it is not

25 presented well in the English translation.

Page 25333

1 A. You want me to read the whole heading?

2 Q. That would be great. That would be terrific.

3 A. "In the presence of the tek. Secretary of the CSB Banja Luka,

4 Slavica," and I don't really see how the last name read but it begins

5 with a K an ends in ovic. "... received column and somebody's

6 signature."

7 Q. And you knew the technical secretary at the CSB was

8 Slavica Komljenovic?

9 A. I repeat: I know there was a Slavica at the CSB who was the

10 technical secretary and I'm not sure I ever knew her surname. But if

11 that's written here, I have no reason to doubt it.

12 Q. And do you recognise the signature underneath it, whose signature

13 that belongs to?

14 A. No. Not at all.

15 MR. OLMSTED: Your Honours, I don't know where we stand on

16 this -- on this translation, but I guess we just leave it be for now. We

17 have it in the record under its document ID number if we need to

18 cross-reference it.

19 JUDGE HALL: Yes, because I understand that the problems haven't

20 been fully resolved yet.

21 MR. OLMSTED: Thank you, Your Honours.

22 Q. Now you also testified there were other members of the Banja Luka

23 Special Police Detachment in the Doboj region, and you would see them as

24 you came and went from the town.

25 A. Precisely.

Page 25334

1 MR. OLMSTED: Let's have P1337, tab 13, on the screen.

2 And let's take a look at the second page briefly.

3 Q. Sir, you can see this is a 17 May 1992 Milos report, numbered

4 133/92. I think you were shown this during your 2004 interview with

5 Investigator Nicolas Sebire. And at the time, you told him that this --

6 you didn't write this one, in particular?

7 A. In response to your question, I can identify this as a

8 Milos group report under that date. But I really can't remember what

9 your colleague showed me in 2004. But it's not a problem. You can ask

10 me whatever you want.

11 Now, if the question was whether I wrote this report ...

12 Q. That was the question. If we can turn back to the first page.

13 And if you need to take a look at it to refresh your memory, just --

14 A. Yes, that would be good.

15 Do I need to read the whole report?

16 Q. No. Just enough to -- to tell us whether it's correct that you

17 did not type this one.

18 A. Right, I didn't.

19 Q. I do want to draw your attention to the final sentences of the

20 first paragraph which read:

21 "Apart from visible injuries suffered by the arrested persons

22 there was appropriation of private property by those who were carrying

23 out the searches. Such behaviour met with the indignation and

24 condemnation of all honest citizens, and especially the mobilised Serbian

25 Territorial Defence members, who threatened to use arms against the

Page 25335

1 special forces from" --

2 THE INTERPRETER: Could the counsel please be asked to tell the

3 interpreters the reference in the B/C/S text.

4 MR. OLMSTED: In the B/C/S text, it's the first paragraph and

5 it's -- I'm reading the last two sentences.

6 THE INTERPRETER: Thank you.

7 MR. OLMSTED:

8 Q. "Such behaviour met with the indignation and condemnation of all

9 honest citizens, and especially the mobilised Serbian Territorial Defence

10 members, who threatened to use arms against the special forces from

11 Banja Luka and the special forces organised by a man called Bozovic."

12 Mr. Sajinovic, do you recall during this time-period

13 Mr. Radulovic telling you about the criminal behaviour of members of the

14 special police forces from Banja Luka while they were in Doboj?

15 A. Mr. Prosecutor, from that period, I recall hearing, not only from

16 Radulovic but from many other persons as well, that some kind of illegal

17 activities, if I may put it that way, were being carried out by groups

18 and individuals in the area of Doboj whilst we were there.

19 Q. But I am referring particularly to the members or certain

20 members - not all members, but certain members - of the special police

21 detachment from Banja Luka.

22 A. Yes, I spoke about this topic specifically with Radulovic as

23 well. The information that we had at the time was that there were lots

24 of stories going around about the deeds committed by members of the

25 special unit from Banja Luka. According to what we knew, the majority of

Page 25336

1 these activities were, in fact, committed by local criminals organised in

2 groups, as well as some individuals from Doboj and its surroundings. I

3 spoke about that yesterday.

4 What is interesting to note here is concerning this report that

5 we're looking at and the sentence that you just read, it says that they

6 even threatened to put up armed resistance, in inverted commas, "to the

7 specials of Banja Luka."

8 When you put inverted commas in the Serbian language, that

9 indicates not exactly what is quoted. Therefore, this leads me to

10 believe that there were such rumours but that they were not founded.

11 This is the only thing that I can conclude from this document and from

12 the talks I had with Radulovic at the time regarding those illegal

13 activities.

14 Q. Yes. But you didn't -- you didn't gather this intelligence.

15 This was Mr. Radulovic. So he is the person who knew exactly what he was

16 reporting here, obviously.

17 A. Yes, that's correct. As far as this is concerned, it's correct,

18 and as far as I can recall the conversation that I had with Radulovic

19 about this topic, and I heard it from him personally that everything that

20 happened in the area of Doboj was attributed to outsiders. In this

21 instance, those outsiders were members of the special police detachment

22 from Banja Luka and members of special unit volunteers from Serbia led by

23 Radojica Bozovic.

24 If I remember correctly, I spoke about this extensively

25 yesterday. And just briefly, not only in the Doboj area, it was typical

Page 25337

1 that if anyone tried to commit a crime, and happens even today, they

2 leave some trail in order to point or set up somebody else as a

3 perpetrator. At the time, Bozovic's Red Berets were in Doboj, would wear

4 hats that were worn by Mr. Talic's specials or the hats by -- worn by

5 people from Banja Luka. So every person, every peasant in every village

6 was able to see that although they were virtually illiterate,

7 unfortunately.

8 JUDGE HALL: Before you move on, Mr. Olmsted, I would just wish

9 to point out to you that you have an hour remaining, a half of the first

10 session and then when we come back, you have a half-hour remaining.

11 MR. OLMSTED: Thank you, Your Honours.

12 Q. You testified that you saw CSB chief Andrija Bjelosevic in Doboj

13 one or twice. Can you tell us on what date, what occasions you saw him?

14 A. Mr. Prosecutor, I don't remember mentioning

15 Mr. Andrija Bjelosevic today. You say "you just said."

16 That's what I said maybe yesterday or the day before yesterday

17 but not today. I told you that I saw him once or twice. I cannot

18 remember. But that was during the period when we were in Doboj.

19 Q. And can you tell us on what occasions you saw him? Do you recall

20 the occasions? Did you see him at the CSB?

21 A. I think either outside or inside the building, and once I just

22 bumped into him in the street.

23 Q. You stated that Mr. Radulovic told you where Mr. Bjelosevic was

24 and that he was always at the Duge Njive area. Did Mr. Radulovic tell

25 you how he knew all this information?

Page 25338

1 A. Yes. You put it right. I remember that he was in the area of

2 Duge Njive. I remember asking this question because Bjelosevic was the

3 chief of the CSB Doboj at the time, and I asked Radulovic how come we

4 don't see him more often. And I'm trying to remember the exact name, but

5 I think it was a staff or -- or whatever of the Doboj operations group,

6 which was stationed in Duge Njive.

7 As I understood at the time, apparently his activity there was to

8 co-ordinate the defence of Doboj with the military commanders. I don't

9 know. This is just guess-work.

10 Anyway, that would be it, and I wouldn't like to speculate any

11 further.

12 Q. And while he was away, were the Doboj police reporting to his

13 deputy?

14 A. Mr. Prosecutor, I really didn't know, given my position, what the

15 hierarchy in Banja Luka was.

16 Now in you're asking me about the police, and I suppose you are

17 referring to the uniformed police, are you?

18 Q. I'm referring to the CSB police, yes.

19 A. Well, the Banja Luka CSB, and the organisation of any CSB was

20 similar, didn't have any police. Maybe they had some kind of dozen

21 police officers, but not exactly police officers. Those were inspectors.

22 So their duty was to carry out inspections of police stations.

23 Anyway, the police was in Banja Luka but I say the same

24 organisation was in place in Doboj, and people were organised within

25 various police stations.

Page 25339

1 Q. I want to move now to Prijedor. If we can have P --

2 MR. ALEKSIC: [Interpretation] I really apologise to my learned

3 friend. I don't intend to interrupt him.

4 23, 22, lines, the witness said, "I say the same organisation was

5 in place in Doboj." The witness said: In the public security station in

6 Doboj. And then he added that they were organised within various police

7 stations.

8 MR. OLMSTED:

9 Q. I guess we're going to have to ask you the question again just to

10 clarify the record because I didn't understand that interpretation.

11 Can you repeat --

12 A. Of course.

13 Q. Can you just repeat what you said with regard -- I assume what

14 you're saying is that CSB Doboj was organised the same way as CSB

15 Banja Luka, as far as the chain of command?

16 A. Yes, of course. That would be it.

17 Q. All right. Let's discuss Prijedor.

18 MR. OLMSTED: Let's have P1376 --

19 MR. ZECEVIC: I'm really sorry. If we are going to clarify this,

20 the answer of the witness, we must clarify it in its totality. And,

21 therefore, either -- either we clarify it or Mr. Olmsted should pose the

22 same question again, the question which he posed. Because right now in

23 the transcript, we are getting -- we have a recording of what -- of -- I

24 mean, adequate recording as to the answer of the witness.

25 Thank you. I'm sorry I interrupted.

Page 25340

1 MR. OLMSTED: All right. Let me see -- I guess we're going to

2 have to go back, and I'm going to have to go back to my prior question.

3 Q. My question -- my question that really originated this was while

4 Mr. Bjelosevic was away from the CSB, who was in charge -- who was this

5 charge of the CSB, and you were giving us a kind of explanation of how

6 essentially it was the same way.

7 Can you repeat your answer again in general? Because I think, at

8 this stage, I think we need to ask the question again.

9 A. My answer was that I didn't know who ran the CSB, although I

10 think that wasn't your question, but, never mind. I said that I didn't

11 know who was at the head of the CSB whilst Mr. Bjelosevic was away. If

12 I'm not wrong, you asked me to whom the police was reporting, and I asked

13 you, are you referring to the uniformed police, and you said, yes, that's

14 what you were referring to, and you were referring to the CSB police in

15 particular.

16 And then I said that, as far as I know, I drew a parallel between

17 the CSB Banja Luka and the CSB Doboj because they were organised in an

18 identical way and that applied to every CSB covered by the area of the

19 MUP of Republika Srpska. And I said that as far as I knew, the CSB did

20 not have police force. There were perhaps a dozen or so uniformed police

21 officers, but they were not actual police officers who were on the beat,

22 so to say, but, were, rather, sitting in offices and were doing the job

23 of police inspectors and each one of them had their own area of police

24 stations that they inspected. The police officers were within public

25 security stations and were organised within police stations in the area

Page 25341

1 covered by a specific CSB.

2 MR. OLMSTED: Is Defence counsel satisfied? Thank you. Let's

3 move on to Prijedor. May I have P1376, tab 15 on the screen.

4 Q. This is a 28 May 1992 Milos report numbered 162/92.

5 Now, according to this report, you were aware at the end of

6 May 1992 that, as it states here, a huge number of civilians from

7 Prijedor, men, women, children, and elderly, were arrested or

8 surrendered; is that correct?

9 A. This is one of the Milos reports, and it says what you just

10 quoted. Yes, that's one of the Milos reports; or, rather, one of

11 Mr. Radulovic's reports.

12 Q. Now, these civilians from Prijedor, they included the non-Serb

13 population from the villages in the Hambarine and Kozarac areas; is that

14 correct?

15 A. Well, I think one can say that that is correct.

16 Q. And where were these persons held? What were the primary

17 locations that they were held in?

18 A. As far as I know the situation in that period, nobody asked me

19 anything about this over the past two days. In addition to the reception

20 centres that I mentioned before, there was one also in the place which

21 is, I think, called Trnopolje. According to the information that I had

22 at the time, this is where the civilians were housed. They were put up

23 in this reception centre.

24 Q. Are you saying that none of them were housed at Omarska or

25 Keraterm?

Page 25342

1 A. Are you referring to the civilians, the women, the children, that

2 we were just talking about?

3 Q. Well, this talks about men, women, children, and elderly. Are

4 you saying all those persons were in Trnopolje or were they also at

5 Omarska and Keraterm?

6 A. You have allow for a fact, Mr. Prosecutor, that I couldn't have

7 known where everybody was put up. We had information that there was

8 civilians housed in Trnopolje. Able-bodied men, conscripts, people who

9 were captured during combat operations were accommodated in Keraterm and

10 Omarska, as you mentioned, and I spoke about this yesterday and before

11 yesterday; that is to say, that the information that we had at the time

12 was that at those reception centres interviews being conducted with those

13 people in order to carry out screening for those for whom it was

14 established that were not responsible for being involved in armed

15 rebellion were eventually released from Omarska and Keraterm.

16 Now as for women, children, and elderly, I really cannot tell you

17 that I saw them at any of those locations visited by Mr. Radulovic and

18 myself. If need be, I can repeat that we spent a short time at Keraterm.

19 The detainees there were in the lower part of the building, in a big

20 hall, and we were in the administration building above. We were not at

21 all allowed access.

22 Now, judging by the look on your face, you want me to stop,

23 right?

24 Q. Well, yes --

25 A. Mr. Prosecutor, it is difficult. I apologise. It is difficult

Page 25343

1 for me to talk about the year 1992 whilst are you smiling all the time.

2 This is really awkward for me.

3 Q. Please, don't read anything into my expressions. I do, however,

4 want you to try to keep to the question. You have given us a lot of

5 information that wasn't contained within my very simple question which is

6 that some of these civilians were actually held at Omarska and Keraterm,

7 and I can get from your answer that the answer is yes. And that's all

8 I'm trying to get at. But don't read anything into my expression beyond

9 that.

10 A. My answer is no. And please forgive me if I avert my eyes from

11 you. You are really breaking my concentration and I really don't like

12 the expression on your face.

13 Q. You testified that you had intelligence information that

14 non-Serbs in Kozarac were organising into military units and that they

15 had an intention to take over militarily in the area. That was on --

16 during your examination-in-chief; do you recall that?

17 A. Yes.

18 Q. Can you clarify for us, by area did you mean the Prijedor

19 municipality or were you only referring to the Kozarac area?

20 A. I was referring to the municipality of Prijedor.

21 Q. You would agree that if that was, indeed, the non-Serbs'

22 intention, they were extremely outnumbered by the Serb forces at the

23 time, including the VRS, the TO, the police, and the paramilitary units?

24 A. I wouldn't agree with that. That's not correct.

25 Q. Do you recall that the 43rd Motorised Brigade was in Prijedor

Page 25344

1 during this time-period?

2 A. I don't recall. I wasn't very familiar with the military

3 organisation. Since I am expected to give brief answers, I might just

4 not mention that there was no, the Army of Republika Srpska at the time.

5 According to the information that we had, these forces that we discussed

6 in Prijedor were much better organised. As for the so-called Serbian

7 forces and the Serbian population living in the area, laid all their

8 hopes in the JNA.

9 Q. Were you aware that the 5th Kozara Light Infantry Brigade was in

10 this -- if you know whether the 5th Kozara Light Infantry Brigade was in

11 Prijedor at this time?

12 A. I didn't know that.

13 Q. Were you aware that the 6th Sana Brigade from the Sanski Most

14 adjoining municipality was in the area, if you do know; yes or no?

15 JUDGE HARHOFF: I think the witness has expressed the view that

16 he was unfamiliar with the presence of the military formations. So

17 please move on.

18 MR. OLMSTED: Very well.

19 Q. Were you aware there was a Serb Territorial Defence organised in

20 Prijedor during this time headed by Slobodan Kuruzovic?

21 A. Mr. Prosecutor, believe me, that I didn't know. And I really

22 don't recognise the name that you have just given me.

23 MR. OLMSTED: Let's have P1388, tab 25, on the screen.

24 THE WITNESS: [Interpretation] Could you please enlarge it a bit.

25 MR. OLMSTED:

Page 25345

1 Q. This is a 11 July 1992 Milos report, numbered 271/92. The last

2 two sentences are what I'm interesting in. It says:

3 "The killing of civilians in Doboj, Teslic, and Kozarac are not

4 in favour of the Serbian dignity and the honour of the Serbian army.

5 Then it goes on to ask:

6 "Please explain to us what are the interests of the Serbs in

7 creating in a violent manner ethnically cleansed entities and how we

8 should position ourselves," et cetera, et cetera.

9 Sir, the report doesn't mention it, but we could include

10 civilians in Hambarine and Brezovo as well to this list.

11 A. I wouldn't take it upon myself to include anyone, Mr. Prosecutor.

12 This document speaks about the people who perished irrespective of their

13 ethnicity. This is a very emotion subject. I don't want to categorise

14 any people.

15 As for the killing of people in Teslic, that's the only incident

16 that I am aware of. We wrote about it. We arrested the group of the

17 Serbs who committed the crime. We processed them. And that was it.

18 JUDGE HALL: Mr. Olmsted, could you assist me by -- as to

19 identifying what the question was? Because you -- you read portions of

20 the report to the witness and then you declared the report doesn't

21 mention [indiscernible] so-and-so.

22 Where is the question?

23 MR. OLMSTED: That was the question. That -- it -- could it as

24 well include those two areas that aren't mentioned in this report, where

25 a large number of civilians were killed during this time-period.

Page 25346

1 JUDGE HALL: Mr. Zecevic, had you an objection.

2 MR. ZECEVIC: Yes, I'm sorry, Your Honours, I just noticed when

3 Mr. Olmsted was reading from the -- from the translation of the -- of

4 this document, that the translation is somewhat not correct.

5 It contains "ethnically cleansed entities" and that doesn't

6 appear in the original at all.

7 Therefore, we would request that this document be re-sent to --

8 CLSS so we can have the proper translation. It might turn to be an

9 important issue in this case, I guess.

10 [Trial Chamber confers]

11 JUDGE HALL: Mr. Sajinovic, you had your hand up. Yes, you

12 wanted to say something?

13 MR. ZECEVIC: I think the witness wants some water.

14 JUDGE HALL: Yes. We are about to take the break shortly, but

15 the --

16 THE WITNESS: [Interpretation] That's right.

17 JUDGE HALL: The Chamber would ask to you read out from the B/C/S

18 that you would have, the relevant portion.

19 And, Mr. Zecevic, if you would follow along, and we'd see what

20 the -- what the interpreters say.

21 MR. OLMSTED: And I think we're dealing with the last sentence in

22 the document.

23 JUDGE HALL: Did the usher ...

24 THE WITNESS: [Interpretation] I'm sorry, Your Honours, do I need

25 to read this?

Page 25347

1 As Mr. Prosecutor says, this is the last sentence then. The last

2 sentence reads in the Serbian version that I have:

3 "Please explain to us what the interests of the Serbs in creating

4 in a violent manner ethnically compact areas and how we should position

5 ourselves with regard to the manifestations and the perpetrators of such

6 activities."

7 JUDGE HALL: Mr. Zecevic, is your concern -- are your concerns

8 resolved? Or do we -- we now have on the record what the witness says

9 that the documents says in B/C/S. Should we nevertheless still send this

10 for -- to be retranslated?

11 MR. ZECEVIC: Well, Your Honours, it is -- this translation is

12 somewhat in between, I'm afraid, what the -- what the original says and

13 what is the previous translation.

14 Therefore, I would respectively ask that the document be sent to

15 CLSS just -- it's a one -- it's a one -- one sentence only. Thank you

16 very much.

17 JUDGE HALL: Yes.

18 And we'll take the adjournment and return for the -- so

19 Mr. Olmsted can complete his cross-examination. Thank you.

20 [The witness stands down]

21 --- Recess taken at 4.01 p.m.

22 --- On resuming at 4.33 p.m.

23 [The witness takes the stand]

24 MR. OLMSTED: Thank you, Your Honour.

25 May we have 65 ter 10191 on the screen, please. That's tab 30.

Page 25348

1 Q. Sir, this is a 7 September 1992 Milos report, numbered 372/92.

2 Can you confirm this is one of the team's reports?

3 A. Yes. The format is consistent with the reports of the

4 Milos group.

5 Q. Do you recall typing up this one, in particular?

6 A. I think I did this. In any case, I recognise the text.

7 Q. I'm just going to read the first two sentences.

8 It says:

9 "According to our source, VAL, and a large number of contacts

10 with citizens, we have the information that the security situation in the

11 Prijedor area is still [sic] quite difficult and rather chaotic. In this

12 area, buildings are still unnecessarily destroyed and citizens of Muslim

13 and Croatian nationality forcibly expelled, even killed."

14 After the events we were talking about before the break, in

15 Kozarac and Hambarine in May and early June 1992, the situation didn't

16 improve for the non-Serb population in Prijedor, did it? In fact, as

17 this report indicates, they were being -- continued to it be killed and

18 expelled, even into September 1992.

19 A. Well, as for the content of the report, it does say something

20 like that what you've just read. But whether that happened, as I said

21 when we discussed another report, it relates to that date and that

22 period. You say continued to be. I don't know whether it continued to

23 be. Whether it was continuous. But you can see the pseudonym on this

24 report. So it was a source of Mr. Radulovic's.

25 Q. Yes, I choice the word continued because I was reading the second

Page 25349

1 sentence I read, which was:

2 "In this area buildings are still unnecessarily destroyed and

3 citizens of Muslim and Croatian nationality forcibly expelled."

4 So I read the "still" in the report, as meaning it was a

5 continuing thing. Do you see that?

6 A. I do.

7 Q. Later on in the report it mentions information or stories about

8 mass graves.

9 Were you -- did you have any information about those mass graves,

10 or was this solely information that Mr. Radulovic had?

11 A. Excuse me. I did not have such information, and talking to

12 Mr. Radulovic, I never heard that he had such information either. It

13 says here that especially dangerous are stories about those locations of

14 mass graves. And I agree, that such stories are dangerous, so I cannot

15 confirm that it was correct and that some specific locations are meant.

16 I really can't answer this. Sorry.

17 MR. OLMSTED: Your Honour, may this be admitted into evidence.

18 MR. ALEKSIC: [Interpretation] No objection.

19 JUDGE HALL: Admitted and marked.

20 THE REGISTRAR: As Exhibit P2403, Your Honours.

21 MR. OLMSTED: May we have 65 ter 282 - this is tab 49 - on the

22 screen.

23 Q. I'm not a 100 per cent sure, but I think you had a look at this

24 document back in 2004. It's a sector -- line of work 01. So line 01,

25 state security sector, Banja Luka, survey of activities of the SNB sector

Page 25350

1 Banja Luka based on the line of work for 01 for the period April 1992 to

2 April 1993.

3 MR. OLMSTED: Could we turn to page 2 of, I think, both the

4 English and the B/C/S.

5 Q. And I want to look at the paragraph with the handwriting to the

6 left of it.

7 And in paragraph reads:

8 "In such a situation, the operative composition of this sector's

9 SNB is actively engaged in the investigations of ... detained persons,"

10 and then lists the municipalities: "... Prijedor, Bosanski Novi, Kljuc,

11 Sanski Most, Mrkonjic Grad, Doboj, Bihac, Petrovac, Glamoc, Gradiska,

12 Kotor Varos, and somewhat later, Jajce?"

13 If we could scroll to the left there's some handwriting. Do you

14 recognise that handwriting?

15 A. I do.

16 Q. Who does it belong to?

17 A. Mr. Vojin Bera.

18 Q. And since that handwriting does not appear in the English

19 version, can you just read what it says?

20 A. "Doboj and Banja Luka."

21 Before Doboj, I believe there is a letter, C, in Cyrillic, or

22 similar. But I'm not sure. But what I clearly see is "Doboj and

23 Banja Luka."

24 Q. And were you aware that Vojin Bera was co-ordinator of the state

25 security officers who were sent to the various detention facilities

Page 25351

1 around the region in 1992 to conduct interrogations?

2 A. No, I didn't know that.

3 Q. We've already talked about Doboj and a little bit about Prijedor.

4 Were you aware that there's state security officials who were engaged in

5 interrogations of non-Serb detains in Kljuc, Sanski Most, and

6 Kotor Varos?

7 A. As for other places, or, rather, the places you've just

8 mentioned, I knew that in those areas there was a presence of the

9 operatives of state security, operatives who were responsible for those

10 areas. And in peacetime, in the time of former Yugoslavia, the

11 State Security Service and all the other state institutions had

12 contingency plans for natural disasters, war, immediate threat of war

13 and, of course, the State Security Service had those plans as well.

14 Within the State Security Service, there were war time departments, and

15 that means, towns, or, rather, municipalities covered by a particular

16 centre of state security. There was one operative officer of

17 State Security Service in charge of each war time department; for

18 instance, the war time section of Kljuc, or Kotor Varos, or whatever.

19 Now, what they did and who they investigated, I don't know. They

20 were our colleagues working on an equal footing with us, and the object

21 of our interest were not colleagues from the same service. You know what

22 the object of our interest was.

23 Q. Can we please turn to page 5 in the English and the B/C/S.

24 And I'm interested in the bottom paragraph. It starts out --

25 well, before the numbered paragraphs it states:

Page 25352

1 "Bearing in mind only certain ... elements in the estimation and

2 in accordance with realistic possibilities, this department has focussed

3 on the following things ..."

4 And the first -- and I'm just going to summarise them. I'm not

5 going to read them all out.

6 But the first relates to discovering the pillars of intelligence,

7 propaganda and activities among foreign citizens.

8 The second, which is on page 2 of the English, is the gathering

9 of information about activities of the UNPROFOR members?

10 The third priority is organising of new immigration for the

11 purpose of monitoring terrorist activity towards the RS, Serbs, and

12 Serbian clubs abroad.

13 The fourth is gathering of information about forces, locations,

14 deployment, et cetera, of enemy formations.

15 And, finally, the fifth is discovering of criminal acts against

16 humanity committed against the Serb population in some regions.

17 Can you tell us, just within the structure of the state security,

18 who set these priorities?

19 A. You must believe me, Mr. Prosecutor, when I say that I could not

20 answer your question with any certainty. I could make conjectures again,

21 but you've made it quite clear you don't want me to.

22 Q. That's correct. And thank you for just keeping it at that.

23 With regard to this last objection -- objective, which is

24 discovering of criminal acts against humanity committed against the Serb

25 population in some regions, can you tell us, would this encompass crimes

Page 25353

1 committed against Serbs in the Autonomous Region of Krajina?

2 A. Have you to show me where that is. I can't see it. The last

3 thing I see is: "Gathering information ..."

4 Q. I apologise. Can we turn the page in the B/C/S version. I

5 apologise for that. Number 5 is on the second -- on the next page,

6 page 6. And if you look under number 5, it's what I just read and I just

7 want to confirm that that included state security inspectors looking into

8 such crimes committed in the ARK, the Autonomous Region of Krajina, as

9 well as perhaps Doboj region and elsewhere.

10 A. Since this is a report by the Banja Luka sector of the state

11 security, I conclude that this refers to the area covered by the state

12 security sector in Banja Luka.

13 Q. Thank you.

14 MR. OLMSTED: Your Honour, may this be admitted into evidence?

15 THE WITNESS: [Interpretation] Excuse me, Your Honour.

16 Mr. Prosecutor, looking at this document, I've been thinking, and

17 I remember I was shown this by your colleague in 2004, and that's fine.

18 But I would appreciate it if you could show me this document page by page

19 on the screen, or perhaps you have a hard copy. It is very important,

20 and you will hear the reasons, Your Honours, why.

21 I remember that I've said this to the investigator at the time,

22 certain observations of mine, and I think this is very important.

23 JUDGE HALL: Do you have a hard copy available that you may show

24 the witness?

25 MR. OLMSTED: Let me see if I have an unmarked copy.

Page 25354

1 THE WITNESS: [Interpretation] Hard copy would be even better.

2 Thank you, Your Honours.

3 MR. OLMSTED: He can use this one, I think. It's a little bit

4 marked up.

5 Q. But just ignore any blue pen mark on it.

6 A. It's not a problem. I just want to see the printed version.

7 Thank you again for enabling me to look at this document, and I'm

8 very happy, indeed, that I have recalled this document.

9 I'm not going to go into the contents at this time. The

10 Prosecutor has read out certain passages that he interested in, and

11 that's fine, I'm not going to comment on that. But one thing I noticed

12 in 2004 is this: The first page of the document, the second page, the

13 third page, the fourth page, the fifth page of the document, and the

14 sixth page of the document were typed on one and the same typewriter.

15 The font is the same, and even a layman can see it's one and the same

16 typewriter. What's interesting is, at the bottom of the sixth page, the

17 text does not end. Instead, there is a comma, and the text continued on

18 page 7 in a different typewriter, using a different font, different

19 letters, and the seventh, eighth, and ninth page were typed on a

20 different typewriter. I expressed my doubts about the authenticity of

21 this document in 2004, and I express them again for the reasons that I've

22 stated.

23 Since this is an overview or a survey of certain activities on

24 page 6, in paragraph 6, it says, "As a result, based on the gathered

25 information, in the form of notes," et cetera, "the service of national

Page 25355

1 security was sent," and then blanks, so many, it doesn't say how many,

2 Official Notes, so many communications, so many reports. So these are

3 blanks. I explained to the investigator at the time in detail - I don't

4 want to go into detail here now - but I believe that is somebody's

5 attempt to misrepresent things by leaving blank the place for the number.

6 I don't know what it is about, but I can't understand why at least two

7 different typewriters were used.

8 Thank you again. I hope I have been of assistance, and I

9 apologise for using a few extra minutes of the Prosecutor's time.

10 Q. No problem and thank you for your assistance. Can you remove

11 your headphones for a minute while we resolve this issue.

12 A. All right.

13 JUDGE HALL: Mr. Olmsted, Mr. Aleksic was about to say something

14 on your application. But before I hear from him, could I understand for

15 what purpose you seek to tender this document?

16 MR. OLMSTED: Well, the purpose is -- is obviously the content

17 and the -- particularly the areas I just covered that are in this report.

18 As -- are we concerned about the authenticity or the contents,

19 Your Honours? The relevance or the -- or the -- authenticity?

20 JUDGE HALL: Both now, having regard to the witness's

21 intervention.

22 MR. OLMSTED: Okay. The relevance is because it speaks about the

23 activities of line 01 at the state security sector in Banja Luka for the

24 period of -- from April 1992 through April 1993. So it does cover

25 entirely the indictment period.

Page 25356

1 And it discusses their activities, their priorities during that

2 time-period. And I haven't read all those parts of it, but it also talks

3 about the detention facilities in Prijedor, and et cetera.

4 As far as the authenticity is concerned, of course, this witness

5 is not an expert on -- on documents, he expresses opinion, of course, as

6 to what it is. It could very well be a draft of a report that is

7 eventually sent. He did authenticate the handwriting of Vojin Bera, who,

8 at the time, during this period, was the head of line 01. So whatever

9 stage in the drafting this was, at one point it was in the hands of

10 Mr. Bera, who would have been the one who would have authorised this

11 report.

12 And so we say that there's enough to authenticate it for purposes

13 of admission in this case.

14 [Trial Chamber confers]

15 JUDGE HALL: Mr. Aleksic, do you have something to contribute to

16 this discussion?

17 MR. ALEKSIC: [Interpretation] Yes, Your Honour. Thank you.

18 In addition to what the witness has said and what Mr. Olmsted

19 said the witness identified, this document has nine pages, and the

20 witness recognised two words in it that he says were written by Mr. Bera.

21 The document does not bear a number, does not bear the name of the

22 author.

23 What I see this as is a draft version. You can see in item 5

24 that lines are left blank for some things to be written in. Also,

25 Mr. Olmsted asked the witness if he knows that Mr. Bera was the

Page 25357

1 co-ordinator. The witness answered in the negative. Then the Prosecutor

2 asked if he was aware if operatives from the state security from

3 Banja Luka went to work in other centres. The witness says: I don't

4 know.

5 So in addition to all the formal deficiencies of this document,

6 the witness confirmed none of the major elements of this document,

7 nothing important.

8 That's what I wanted to say, Your Honours.

9 [Trial Chamber confers]

10 JUDGE HALL: Mr. Olmsted, what the Chamber doesn't understand is

11 what exactly this is and what -- what its origin is. And to whom was it

12 directed. None of that is apparent from the document itself, and the

13 witness is unable to assist.

14 MR. OLMSTED: Well, Your Honours, the title page tells you what

15 it is. It's a survey of activities of the SNB sector Banja Luka based on

16 the line of work 01, for the period April 1992 to April 1993. And it

17 has, at the top, it says it comes from the CSB Banja Luka, state security

18 sector and it even has a date, 12 April 1993. And -- up to the right it

19 says line of work, 01.

20 And we've heard evidence that line 01 within the state security

21 sector in Banja Luka was under Vojin Bera during this time-period. And

22 this is a report on their activities. And we've heard that among their

23 activities were sending state security inspectors to detention facilities

24 to interrogate detainees, and that's included in this report. This gives

25 us information as to what their priorities were during this time-period,

Page 25358

1 what kind of work they were doing. This is part of the CSB Banja Luka.

2 Now whether it is a draft or not, this witness obviously can't

3 provide any information on that. But drafts can be admitted into

4 evidence. We're not saying that this made it to the hands of anyone up

5 the chain of command. It is dated 1993. So that is not necessary

6 relevant for us, but what was relevant for us is the information that's

7 contained within it. And we submit that the handwriting of Vojin Bera,

8 the head of this section, on the page, and his handwritten notes on the

9 page shows that he was reviewing this. So this must have been something

10 he was considering and reviewing as to his line of work.

11 JUDGE DELVOIE: Mr. Witness, could you, anyhow -- oh, yeah,

12 sorry.

13 Mr. Witness, could you in any way support Mr. Aleksic's

14 allegation that this could be a draft?

15 THE WITNESS: [Interpretation] Your Honour, my answer would be

16 yes, I can fully confirm that this was a draft, at best. When I say "at

17 best," I was referring to what I spoke about earlier. And the indication

18 of that are the lines on page 6 in the Serbian, item 5. So all the

19 numbers are lacking, the number of reports, et cetera.

20 [Trial Chamber confers]

21 JUDGE HALL: The document is admitted and marked.

22 THE REGISTRAR: Exhibit P2404, Your Honours.

23 MR. OLMSTED:

24 Q. Mr. Sajinovic, you'll be happy to hear I'm very near to the end.

25 I just want to clarify just a couple of things that came up during your

Page 25359

1 examination that I don't think are going to be controversial.

2 If we can have P1369, tab 3, on the screen, please.

3 And had you a chance to look at this, I believe, when Mr. Aleksic

4 was asking you questions.

5 I'm not going to ask you any questions about the content. What

6 I'm interested in is if you look at the bottom, the reference number is

7 49/92. Do you see that?

8 A. Yes, I do, Mr. Prosecutor.

9 Q. And you see that the date of this Milos report is 2 April 1992.

10 A. That's right.

11 Q. Okay. Remember that, and let's take a look at 1D293.

12 JUDGE DELVOIE: Tab number, please.

13 MR. KRGOVIC: Tab number.

14 MR. OLMSTED: It was a Defence -- it was your tab, so if you

15 could help us out, that would be great. I didn't write down the tab.

16 It's a Defence document.

17 Q. But for purposes of this, you won't need to see the hard copy. I

18 just want you to look at the reference number on this one. Now, this one

19 is reference number 53/92. Do you see that?

20 A. Yes, I do. Of course.

21 Q. Now this one doesn't have a date on it. But can we draw the

22 conclusion that since its reference number is subsequent to the reference

23 number of the previous document, that this one was written after that.

24 In other words, the reference numbers are sequential: The first number

25 being the number of the report, and the second number being the year.

Page 25360

1 A. Yes, you are right. What you said last that first comes the

2 number of the report and then the year.

3 Now when you asked me whether I would be able to draw a

4 conclusion, if I understood you correctly, whether this document preceded

5 the previous one, according to the number, that could be the case. But I

6 have equally seen quite a few documents of ours without any number or

7 date on them. And when I was giving my answers the day before yesterday,

8 I said that one of my colleagues whose handwriting I identified here used

9 to establish this register in 1994. So I cannot say with any degree of

10 certainty whether this document was produced earlier.

11 Just let me tell you that I didn't read the contents. I was just

12 focussing on the form and the format.

13 Q. And that's exactly what I want you to focus on. But just to

14 clarify: The one we looked at before had the reference number 49/92

15 while this one has the reference number 53/92. So I was asking you

16 whether this meant that the one in front of us came after the previous

17 one, because it's later -- it's a higher reference number, indicating

18 that it was further along in the reporting cycle.

19 A. I gave you an answer. According to the number that you quoted,

20 it would only make sense that it came later. However, I cannot confirm

21 that for the reasons that I gave you. There is no date, and, as I said,

22 I've seen many reports of ours missing numbers and dates, et cetera.

23 So, whatever you say makes sense; but also whatever I say makes

24 sense. I am under oath, and, therefore, I cannot claim with any

25 certainty that this document was produced after the first one. But the

Page 25361

1 format is consistent.

2 Q. Thank you. And I think you've already testified that the person

3 who maintained these files was the third member of the Milos team, who

4 was responsible for communications.

5 A. Precisely so. What I told you is the truth.

6 Q. Final clarification. If we can have 2D84 on the screen.

7 MR. ALEKSIC: [Interpretation] It's our tab 10.

8 MR. OLMSTED: Thank you. Thank you for your assistance.

9 Q. And had you a chance to look at this during your examination.

10 And I just want to draw your attention to the end of the document, the

11 last two sentences. It says:

12 "Please keep Becirevic in custody until our arrival so that we

13 can conduct a detailed interview concerning these and other

14 circumstances."

15 Can you confirm with us, is that Dzemo Becirevic? Is that the

16 person you are referring to there?

17 A. Yes, that's the man.

18 Q. And can you tell us, you -- this is requesting that he be held in

19 custody until you arrive. Where was he being held?

20 A. You should first ask the question: Who held him; and then the

21 location.

22 I can only deduce something about who held him in custody, but I

23 don't know anything about the location.

24 Q. Okay. Could you answer who was holding him?

25 A. Judging by the language of the document, I would say that this

Page 25362

1 gentleman was in custody in Serbia, which means that, according to this

2 document, he was kept in custody by the RDB members in Serbia.

3 Q. And by RDB, you mean the Serbian MUP. That -- the security

4 services within the Serbian MUP.

5 A. When I say RDB, stands for State Security Department.

6 Q. And it says hold him until we conduct a detailed interview.

7 Do I take it that you did not go out to Serbia to conduct this

8 interview if it, in fact, occurred?

9 A. I don't know. I myself didn't go, and I don't remember whether

10 Mr. Radulovic went. I'm not aware of that.

11 When we discussed a similar note -- I'm sorry, no. I misspoke.

12 So, I don't remember, and I don't know if Mr. Radulovic went.

13 Q. All right. And maybe the note you're thinking about, let's turn

14 to 2D86.

15 MR. OLMSTED: And perhaps my learned friend can help me with the

16 tab number on that one.

17 MR. ALEKSIC: [Interpretation] Tab 12.

18 THE WITNESS: [Interpretation] I didn't understand which

19 particular note you were referring to.

20 MR. OLMSTED:

21 Q. Well, just take a look at this one. You were shown this one as

22 well during your examination. I'm not sure if it was by Mr. Aleksic or

23 by Mr. Cvijetic. But do you recall taking a look at this document during

24 your testimony here?

25 A. Yes, I do.

Page 25363

1 Q. I'm interested in the first paragraph at the very end. It says

2 that a statement was taken from Dzemo Becirevic at -- in September 1992

3 at the premises of the VIZ in Banja Luka. I understand by VIZ that's a

4 military prison.

5 Can you tell me, is that Mali Logor or is that some other

6 facility in Banja Luka?

7 A. Mr. Prosecutor, you are right. Is this abbreviation stands for

8 the military remand prison.

9 As far as I know, such prison existed within the compound of the

10 Mali Logor barracks in Banja Luka, but I really don't know whether the

11 military had such prisons elsewhere.

12 Q. And can you tell us how Mr. Becirevic was transferred from Serbia

13 back to Banja Luka; if you know?

14 A. I really don't know. I really cannot comment on this. Whether

15 he was transferred or not, and, if so, how, I don't know.

16 Q. Did you take part in this interview of him at the Mali Logor

17 prison? I take it by your answer you probably didn't because you're not

18 quite sure of the name.

19 A. On behalf of what? I'm not sure. But you are right. I didn't

20 take part in this interview. All I know is that this gentleman was

21 interviewed on several occasions, and I think that I did take part in one

22 or two, but not at this location that is mentioned here.

23 Q. At which location did you interview him at?

24 A. On the premises of the National Security Centre in Banja Luka.

25 Q. So at the CSB building.