Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13128

1 Monday, 20 January 2003

2 [Open session]

3 --- Upon commencing at 2.21 p.m.

4 [The accused entered court]

5 JUDGE AGIUS: Yes, Madam Registrar, call the case, please.

6 THE REGISTRAR: Yes, Your Honour. This is case number IT-99-36-T,

7 the Prosecutor versus Radoslav Brdjanin.

8 JUDGE AGIUS: Mr. Brdjanin, good afternoon to you. Can you hear

9 me in a language that you can understand.

10 THE ACCUSED: [Interpretation] Yes, Your Honour, I can hear you and

11 understand you.

12 JUDGE AGIUS: Thank you. Appearances for the Prosecution.

13 MS. KORNER: Good afternoon, Your Honours. Joanna Korner with

14 Denise Gustin case manager.

15 JUDGE AGIUS: Thank you good afternoon. Appearances for the

16 Defence.

17 MR. ACKERMAN: Good afternoon, Your Honours. I'm John Ackerman

18 with Milan Trbojevic and Marela Jevtovic.

19 JUDGE AGIUS: Thank you and good afternoon to you too. Before we

20 start, I have on my desk some what appear to be -- these are your

21 documents, do I take it? They are the Defence documents, no, that they

22 are going to use? All right.

23 So, yes, Ms. Korner?

24 MS. KORNER: Your Honour, two matters. I'm afraid that I've

25 managed to exhibit last Friday documents which had already got exhibit

Page 13129

1 numbers and the confusion is bad enough without adding to it. So could I,

2 Your Honour, P1581 --

3 JUDGE AGIUS: One moment.

4 MS. KORNER: -- has already been exhibited as P138. So can we

5 just make sure that doesn't appear?

6 P1585 has already been exhibited as P908.

7 P1587 is P1416.

8 And P1588 is already exhibited as P655. So we just make sure that

9 we don't have the same two documents or the same document with two

10 different numbers.


12 MS. KORNER: We've already got the Defence re-exhibiting some of

13 our documents with their numbers, and I'm grateful, may I say, to

14 Ms. Jevtovic for pointing that out, that we had already exhibited them.

15 JUDGE AGIUS: Thank you. Madam Registrar, if you could print out

16 this page and hand it over to my secretary so that she will make the

17 necessary adjustments after the sitting? Okay. Thank you.

18 MS. KORNER: Your Honours, for the second matter, may I ask to go

19 into private session very quickly?

20 JUDGE AGIUS: Yes, let's go into private session.

21 [Private session]

22 [redacted]

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21 [Open session]

22 JUDGE AGIUS: So we are now going to continue with the

23 examination-in-chief of the witness we have been hearing the last three

24 days.

25 [The witness entered court]

Page 13133

1 JUDGE AGIUS: Good afternoon, to you, Mr. Selak, Colonel Selak.

2 THE WITNESS: [Interpretation] Good afternoon.

3 JUDGE AGIUS: Welcome back. I hope you had a good weekend. We

4 will be proceeding with your testimony. We won't finish today but

5 probably we will finish tomorrow. And before we continue, please can I

6 ask you to repeat your solemn undertaking to tell us the truth, the whole

7 truth, and nothing but the truth? Thank you.

8 THE WITNESS: [Interpretation] I solemnly declare that I will speak

9 the truth, the whole truth, and nothing but the truth.


11 [Witness answered through interpreter]

12 JUDGE AGIUS: Thank you. Colonel. You may sit down. Ms. Korner

13 will be proceeding with her in chief.

14 Examination by Ms. Korner: [Continued].

15 Q. Colonel Selak, good afternoon. Could you have back, please, the

16 newspaper article that you were looking at on Friday? I'm not sure we

17 gave it an exhibit number. Yes, we did. 1593.

18 When we concluded on Friday, I was asking you about General Talic

19 having told the reporter about the transformation of the army. Now, if we

20 look at the next question by the reporter, he referred to groups of armed

21 people wearing other uniforms and an increase in shooting, planting

22 explosive devices, and robberies. Went on to say, "Some people seemed to

23 believe, mistakenly one would say, that this is something to do with the

24 army, but the fact is the army seems to have nothing to say about this."

25 And Talic said, "There must not be any armed or trained units outside the

Page 13134

1 corps and the Territorial Defence except for the legal security forces,

2 i.e., the police. That means no Serbian Defence Forces, or similar

3 organisations outside the JNA. I have warned that such forces must not

4 control the city." And then he talked about the military police or the

5 police force cooperating with the military police. Then the explosions.

6 And said, "In my opinion, what we have here are show-downs between groups

7 and individuals and the forces of the security services centre should deal

8 with it. If they need help from the military police, they only have to

9 ask."

10 Now, Colonel Selak, I think you dealt with this earlier but as far

11 as you could see, did either the security services, the members of the SUP

12 or the military police, do anything to control the SOS?

13 A. General Talic did say that the civilian police needed to do

14 whatever was necessary to protect the town, but he did nothing concretely,

15 that is his corps did nothing to prevent paramilitary formations from

16 wandering about town, roaming about town, or men who had been armed about

17 by the corps itself.

18 Q. Then he went on to deal with the strength of the Banja Luka

19 Corps. He explained that most of the people were deserters, that is the

20 SOS, "These are men whom we have already disarmed and arrested as

21 paramilitary formations." Then, I think you've already dealt with whether

22 that was correct. Then he was asked about the estimate of the critical

23 point in the corps's zone and replied, "The Banja Luka Corps has such a

24 large force and such an organisation that there is no risk of the corps or

25 the people of Krajina being endangered." And again I think you dealt with

Page 13135

1 that when we were dealing with your resistance group.

2 Now, can we go, please, to the part that -- it's headed, "Europe

3 does not want to see." And actually just before that, though, he was

4 dealing, the paragraph begins, "The crimes committed by the Croatian Army

5 in Kupres," and then goes on to say, "It makes me wonder all the more of

6 the policy of the Muslim leadership in Bosnia for I believe that

7 unfortunately, the greatest losers in this war could turn out to be the

8 Muslims, who in fact are not interested in any division of territory and

9 can live together with Serbs without any tension or conflict."

10 Then, "Wherever the Serbs are the majority population, there is

11 peace. This is an indisputable fact. Therefore, if Muslims in the

12 Autonomous Region of Krajina turn out to be too closely linked with the

13 headquarters of the SDA, which is not exactly inclined to peace, then

14 there could be conflicts which would lead no where."

15 He in fact summarising is saying that it is the Muslims who are to

16 blame for the situation. Was this something that he expressed privately

17 as well as publicly?

18 A. Yes.

19 Q. And then he went on to deal with the withdrawal of the ECMM

20 monitors. He was asked whether he had discussions with the

21 representatives of the local Muslims, and he said that he had spoken with

22 the Banja Luka mufti and a group of prominent Muslims from Banja Luka.

23 And then he dealt with the Territorial Defence being divided on --

24 along ethnic lines.

25 A. That's right.

Page 13136

1 Q. Thank you. That's all I want to ask but that article. But I want

2 you now, please, before we look at the first video clip that I want to ask

3 you about, is -- could you have back the 1st Krajina Corps war diary,

4 please? Have we still got the original here? I think it would be better

5 if the officer had -- Colonel Selak had the original.

6 MS. KORNER: Your Honour, we had a message from Mr. Ackerman that

7 he's going to be asking about quite a lot of the war diary, so we will

8 arrange for copies for Your Honours. It just takes a long time to print

9 out.

10 He doesn't need that, no, no, no. Thanks. I'll put up -- but I

11 will ask to put up on the ELMO, please, the English translation at page

12 104.

13 Q. Could you find, please, Colonel, the entry -- all right. It's not

14 right. Page -- I'm sorry, it's page 14, not 104. And could you find,

15 please, Colonel, the entry for the 24th of June, 1992?

16 MS. KORNER: Mr. Usher, can you give it to me, please? It's not

17 the right page.

18 THE WITNESS: [Interpretation] Yes?


20 Q. Now, this is a very long entry, I think, this one, and it records

21 the events effectively at the beginning of what was called operation

22 corridor. And I think on -- do we see -- can you find a part which says

23 that "General Talic was of the view that establishing a corridor was far

24 more important than the fall of Derventa?" I think it's right at the end

25 of that entry.

Page 13137

1 A. At the very end, yes.

2 Q. All right. And at 0502 hours, Major Veljko Latka [phoen] brought

3 in helicopter, Colonel Bosko Kelecevic, Chief of Staff, and Milan Martic,

4 a Minister of the RSK, from Knin. Do you see that?

5 A. Just a moment.

6 Q. I think you'll find it's the very last lines on the entry for the

7 24th of June.

8 A. Yes. Here he mentions General Talic. I'm sorry, I can't find

9 it. Kelecevic? Yes, he's mentioned here. Yes. Yes. I've found it.

10 Q. And you already told us who Milan Martic was. Now, can I ask,

11 please, that we play the video with the number V0002297?

12 MS. KORNER: I'm sorry, could we pause? Your Honours, there is a

13 transcript for this, which has got the number 11.6 on it. No. Has it?

14 Right. And it begins, the translation pages begin 03003505. It's headed,

15 "RTB Belgrade Radio and Television." Yes. If we can play the video?

16 Thank you.

17 [Videotape played]

18 THE INTERPRETER: [Voiceover] "More precisely at the location of

19 the 1st Krajina Corps command where Milan Martic has just arrived, will be

20 present at this meeting at what is being called a historic act where the

21 decision will be taken to mount a counteroffensive to go for all or

22 nothing. It is certain that whatever happens will be dependent on this

23 decision. Our forces have been tasked with -- or the aim of the operation

24 could be described as the liberation of Serbian areas, the Serbian people

25 who live in those areas, their territory, and to do this in two stages.

Page 13138

1 First by severing communications south of Derventa."

2 MS. KORNER: Could we pause the video, please and could you just

3 roll back so that we can see the man with the pointer?

4 [Videotape played]


6 Q. Colonel, I know it's a very bad video, but are you able to say who

7 that is?

8 A. It looks like Kelecevic, but it's not him, Bosko Kelecevic. I'm

9 afraid it's dark. It's not Talic, no. Kelecevic, no.

10 Q. Don't worry.

11 A. I'm not sure, I'm not sure.

12 Q. We are going to in a few moments, I think see a shot of a whole

13 lot of officers sitting around a table. If you recognise any of them,

14 could you just say stop so that the video stops and then identify them.

15 MS. KORNER: Yes, we can roll on.

16 [Videotape played]

17 THE INTERPRETER: [Voiceover] "Severing communications south of

18 Derventa along the River Bosna, Modrica, Bosanski Samac, and then in the

19 second part of the operation, to reach the river Sava and establish the

20 natural borders of the Serbian Republic of Bosnia and Herzegovina.

21 "The situation is a lot more than just alarming. We do not have

22 basic foodstuffs or medicines for the elderly, sick, or infirm."

23 MS. KORNER: Stop.

24 Q. Sorry, what did you say, Colonel? Can you see Talic to the right,

25 yes --

Page 13139

1 A. Talic, and to his left is Milan Martic, I think.

2 Q. Is that what it says on the screen?

3 A. I think it's him, I'm not sure. Yes. It says so on the screen

4 but the picture is very dark. I can just see his hair and his uniform.

5 And not his face really.

6 Q. We heard --

7 A. I'm not sure.

8 JUDGE AGIUS: Ms. Korner --

9 THE WITNESS: [Interpretation] I could see Martic.

10 JUDGE AGIUS: If we have the lights dimmed, it would help because

11 there is too much light for all of us actually. Could the technicians --

12 yes. Perfect. And perhaps we could rewind a little bit to where we

13 started from, and go -- proceed forward bit by bit.

14 THE WITNESS: [Interpretation] Yes, Talic. To his left or rather

15 on the screen it's on his right --


17 Q. All right.

18 A. I cannot recognise them. I'm not certain.

19 Q. It is a very bad quality video. All right. Let's go on.

20 A. I'm not sure.

21 Q. All right. Let's go.

22 MS. KORNER: Yes, you can go on playing the video, thank you very

23 much.

24 [Videotape played]

25 THE INTERPRETER: [Voiceover] "We do not have basic foodstuffs or

Page 13140

1 medicines for the elderly, sick, or infirm. They are dying every day.

2 Children are dying, and we could not watch this misery any longer. We

3 brought our forces here and have subordinated ourselves to General Talic.

4 Together with the army of Serbian Bosnia, we will attempt to open a

5 corridor and to prove to the whole world that no one can keep the Serbs in

6 isolation, closed in."

7 THE WITNESS: [Interpretation] These are personnel carriers, tanks.


9 Q. Colonel Selak, I'm sorry, you can't talk at the same time that the

10 video is playing. If you want to say something, then you have to say,

11 "Stop." It's not your fault. I should have explained that. Is there

12 something you want to say?

13 A. I just wanted to say that we see a column of combat vehicles,

14 anti-aircraft weapons, a tank unit in motion.

15 Q. If we just let the rest of the video play or the part I want, and

16 then I'll ask you some questions at the end. Thanks.

17 MS. KORNER: Yes, continue playing.

18 [Videotape played]

19 THE INTERPRETER: [Voiceover] "Reporter: The penetration of the

20 corridor began at dawn on the 12th of June this year. The clash of large

21 military formations occurred less than five minutes after the final

22 decision to break the Croatian Posavina storm. The liberators were met by

23 aggressors from the 103rd and 108th Croatian Brigades and hundreds of

24 Alija's mujahedin. In one night, Jokovac and Kotorsko fell while fighting

25 continued at Jakes and Dobor Kula, the Ustasha stronghold near Odzak. The

Page 13141

1 liberation of this area was commanded by Colonel Milan Novakovic and the

2 legendary Milan Martic with the collaboration of the "Vukovi sa Vucjaka,"

3 the wolves from Vucjak, under the command of Lieutenant Milankovic.

4 Colonel Novica Simic commanded a brigade of the 1st Krajina Corps at

5 Jokovac."

6 [Microphone not activated]

7 [Text added later] "This operation is being undertaken to widen

8 the corridor which we need and to establish the northern border of the

9 Serbian Republic of Bosnia and Herzegovina on the right bank of the River

10 Sava. The operation itself...part of the operation, this attack on Odzak,

11 is unfolding in stages, as we have been informed that there are about four

12 and a half thousand Serbian captives in the town itself. We therefore

13 have to take that into account. We have undertaken every measure to

14 ensure that their lives are not endangered, and we will attempt to free

15 them as soon as possible.

16 "Three Croatian brigades literally fled from Odzak as their

17 stronghold of Dobor Kula fell. On the same day, the soldiers from Modrica

18 also escaped, burning all before them and taking Serbian captives -

19 including women and children - across the Sava. The Croatian soldiers

20 then succeeded in setting light to part of the refinery in Modrica with

21 rocket launchers from the Croatian side. [end of added text]

22 The fighting for Derventa lasted for three days, Colonels Baltic

23 and Lisica commanded the liberators' army.

24 "The second purpose of this operation is to open a corridor

25 towards Serbia. In this way, we shall secure the area of the Krajinas.

Page 13142

1 It is easier for me to say Krajinas than the Knin Krajina and Bosanska

2 Krajina. Thus, we shall secure the necessary raw materials for industry

3 to work, and above all, to procure medicines and other essentials for our

4 children and the infirm. The third aim of the operation is for us to link

5 up with the East Bosnian Corps and to collaborate with them to penetrate

6 to the borders of the Serbian Republic of Bosnia and Herzegovina and join

7 them to the Federal Republic of Yugoslavia."

8 MS. KORNER: Thank you.

9 Q. Colonel, on the transcript it said that Talic was talking over

10 that last part, but was that in fact Talic's voice or was it whoever was

11 at the board indicating the map?

12 A. No. It is Talic's voice. Before him, there was Simic speaking.

13 Q. Right.

14 A. And after that, Talic's voice. I recognised the voice very well.

15 And Lieutenant Colonel was pointing from the corps command, the zones of

16 responsibility, and the axis along which it would act to gain control of

17 the corridor.

18 Q. All right. Now, we heard the reporter explaining that the

19 so-called liberation of this area was commanded by Colonel Milankovic, the

20 legendary Milan Martic, and the collaboration of the wolves from Vucjak

21 under the command of Lieutenant Milankovic. Now, Martic, apart from being

22 the -- one of the ministers from the Croatian Krajina, did he also have a

23 group of fighters, paramilitaries?

24 A. Yes. A large number of fighters, not a group. A group implies a

25 small number. A large number of fighters came from the Republic of

Page 13143

1 Serbian Krajina, and the aim was to gain control of the corridor, Banja

2 Luka, Doboj, towards Yugoslavia, which was of vital significance for the

3 Banja Luka Corps, as it was the only link between the Republic of Serbian

4 Krajina, the Bosnian Krajina, where the first corps was, and Yugoslavia.

5 Precisely because of logistic and all other support, and the linkage of

6 Yugoslavia with the Serbian Republic of Bosnia-Herzegovina and the

7 Croatian Krajina.

8 Q. But what I'm interested in is this apparently shows that

9 paramilitary formations were fighting with the 1st Krajina Corps on this

10 occasion. Was that something that you expected to see?

11 A. Yes. That's why they were armed, in fact, in order to join in

12 battle the forces of the Banja Luka Corps, because the Banja Luka Corps

13 didn't have a hundred thousand soldiers by establishment, and the

14 paramilitary units were joined who joined the corps for logistic support,

15 and these columns went to Belgrade to provide logistic support for these

16 units. I would give units, corps units, instructions. Now who they

17 passed on the logistics support to, I don't know, but they were fully

18 provided.

19 Q. And General Talic, we heard describing at the beginning of this

20 video clip, describing this operation, as the liberation of Serbian areas,

21 the Serbian people, who live in this area. As far as you know, did he

22 consider that wherever Serbs were, that was a Serbian area?

23 A. Yes. Literally so.

24 Q. Yes. Thank you. Now, I'd like you to look next at another --

25 some parts of a very, very lengthy video, which is 3881.

Page 13144

1 MS. KORNER: Your Honours, the video has got a transcript but it

2 doesn't need it because it's actually subtitled.

3 JUDGE AGIUS: Yes. In the meantime, Ms. Korner -- yes,

4 Mr. Ackerman?

5 MR. ACKERMAN: Your Honour, I was wondering if the transcript of

6 that last video is going to be made an exhibit?

7 JUDGE AGIUS: That was going to be my question.

8 MR. ACKERMAN: Because if not, we have a problem because a lot of

9 it wasn't translated.

10 JUDGE AGIUS: That was going to be my question. Was 11.6 -- did

11 you intend this to be an exhibit?

12 MS. KORNER: I did, Your Honour. I'm sorry, I moved on. I intend

13 for the video to be made P1581A with the transcript 1581B. I don't know

14 why the translation stopped in the middle but it -- why is that no good?

15 MR. ACKERMAN: [Microphone not activated]

16 MS. KORNER: No, it doesn't. How can it be B/C/S?

17 MR. ACKERMAN: [Microphone not activated]

18 MS. KORNER: I know that but so what, all right. .1, then.

19 1581-1. I think it's better that the transcript and the video stay

20 together. So if I can't have B because Mr. Ackerman says it means a B/C/S

21 transcript, then can I have point 1 or point 2, the video 1581.1, the

22 transcript 1582.2?

23 JUDGE AGIUS: 1581. We had already.

24 MS. KORNER: I know we did, Your Honour, but I just -- I would

25 like it attached to the video.

Page 13145

1 JUDGE AGIUS: What was -- 1518 would according to the statement

2 that Ms. Korner made earlier on at the beginning of the sitting revert to

3 its original exhibit number, which was 183 or something, I can't remember

4 now. So at the moment, at the moment, when I asked you to print out, the

5 documents that were marked last week, 1581, 158 -- whatever, that have

6 been highlighted, do not -- do not exist any longer, so we have blanks

7 there which are going to be filled in now as I take it from what

8 Ms. Korner has just stated?

9 Yes, Mr. Ackerman? Does that confuse you?

10 MR. ACKERMAN: Judge, it's an enormous problem. I'm always

11 thinking about somebody dealing with this transcript down the road who is

12 not sitting here. If they are looking at the transcript and they come

13 across Exhibit 1581, which we now have decided is 138. But if they come

14 across the transcript of Friday and see 1581 and they go look for it, they

15 are going to get a videotape which has nothing to do with it. I don't

16 think we should be changing the numbers after the fact because it is

17 misleading to anybody that is trying to follow the transcript. I think we

18 have to leave them alone, even if they are duplicates.

19 MS. KORNER: I never heard such complete -- anybody who wants to

20 read this transcript after will see it refers to a document. If they read

21 it properly, they will see the exhibit number changed, but I really do not

22 want to waste any more time on this utterly footling point. So can we

23 make it the next exhibit number up? If we followed that and we will sort

24 out the later -- those missing exhibit numbers later, so it will be P1594

25 as the point 1, for the video and P1594.1A for the transcript and B for

Page 13146

1 the B/C/S?

2 JUDGE AGIUS: Thank you, Ms. Korner.

3 MR. ACKERMAN: Your Honour, I just would like to say that these

4 are not futile points. I've gone a great deal of appellate work and these

5 things drive you crazy.

6 MS. KORNER: The expression was footling, which is not quite the

7 same thing --

8 JUDGE AGIUS: Let's move ahead. The transcript for the next video

9 is 7. --

10 MS. KORNER: You don't need it, Your Honour. That's what I was

11 about to explain. It's subtitled. Your Honour, there may be a slight

12 hiccup because I've given the booth the various times from my television,

13 and I hope it will work but it may not entirely. So this is the first

14 part of the video, Your Honour, which should start from 29 minutes in.

15 It's video 3881.

16 JUDGE AGIUS: Yes, again, could we have the lights dimmed a little

17 bit, please?

18 [Videotape played]

19 MS. KORNER: Can we pause for a moment?

20 Q. Can you tell us, do you know who that is?

21 A. Novica Simic. He was my neighbour. We lived in the same

22 building. He was a brigade commander, later a corps commander, and later

23 minister and member of the general staff of the Army of Republika Srpska.

24 Q. Thank you.

25 MS. KORNER: We'd like to continue playing the video.

Page 13147

1 [Videotape played]

2 MS. KORNER: Can we stop there, please?

3 Q. Do you know who that is, Colonel Selak?

4 A. I'm not sure. The face seems familiar, but it's been a long time,

5 and I'm not quite sure. He is a colonel but -- the face is familiar but

6 I'm not sure.

7 Q. I'm going to ask for the assistance of the AV because I gave them

8 a list of the timings on it. Was that up to 34.28 minutes? If so, I

9 don't want to play any more. And I can't remember. I suppose they have

10 no way of telling me that.

11 All right. Can we run it forward a bit more, please, and then

12 I'll just see.

13 [Videotape played]

14 MS. KORNER: All right. I think we can stop the video there.

15 Yes.

16 Q. Now, that part, because then could I ask the booth to move to the

17 next part that I've set out in the timings. But before we do that,

18 Colonel, two things about that part of the video. We heard Talic on a

19 number of occasions talking about the union of all Serbs, the mother

20 country, Serbia, joining up with the mother country, Serbia, and the

21 like. As far as you are aware, was this not just a political goal but one

22 that he personally shared as well?

23 A. That was the ultimate objective of the Army of Republika Srpska,

24 the Serb Krajina, to join up with Yugoslavia and create a joint state.

25 I'd like to ask you for a minute to say that what General Talic just said

Page 13148

1 that 11 babies died because of the shortage of oxygen was not true.

2 Personally, I provided seven oxygen bottles for the hospital and the Banja

3 Luka television also reported, that is informed the public. So this was

4 misinformation intended to add up to -- to add oil to the fire, to add

5 firewood to the fire, to stir up trouble and raise tension among the Serb

6 people.

7 Q. That was in fact the next question I was going to ask you, because

8 it's been raised a number of times already in this trial. As far as you

9 know, is there any truth in this story that was spread that these Banja

10 Luka babies died for lack of oxygen which was caused by the blockage of

11 the corridor?

12 A. That information was taken over and carried by all the media of

13 the Republika Srpska, in order to emphasise the importance of the corridor

14 towards Yugoslavia and the logistic supply of the -- of all the units. In

15 my transport columns for Belgrade, there were also civilian vehicles which

16 were taking food and medicines, and other supplies needed for the

17 population in Banja Luka and Bosanska Krajina. I repeat that the oxygen

18 for the hospital I supplied, so this is merely pointing out that 11 babies

19 died. Yes, they were tense, but it is not true that 11 babies died.

20 Q. All right could we move to the next part, if it's set up, which

21 should start at around 44 minutes? Yes. Thank you.

22 [Videotape played]

23 MS. KORNER: Can we pause there for a moment?

24 Q. Colonel Selak, do you know what we are looking at? We can see the

25 burned out villages and houses.

Page 13149

1 A. To the right on the screen are the units, that is UNPROFOR men,

2 UNPROFOR officers. On the left-hand side, I believe is Colonel -- the

3 name escapes me but I know him personally.

4 Q. Could we take the video back? I'm still worried about the -- just

5 to the shot before that.

6 [Videotape played]

7 MS. KORNER: Pause, yes, that one.

8 Q. Do you know what we are looking at? Is that Western Slavonia?

9 A. I believe it is. I believe it is Western Slavonia. I marked some

10 units or rather some areas in west Slavonia in Pakrac and Lipik, and I was

11 also in Glina and towards Karlovac. And with the commander of the 10th

12 Partisan Division, Colonel Jozsefic, I inspected, I toured this area. I

13 cannot really say which houses are these.

14 Q. Don't worry.

15 MS. KORNER: If we can carry on with the video.

16 [Videotape played]

17 MS. KORNER: I think we can pause it there, thank you. And then

18 if we could move it on to the next part while I ask a couple of questions?

19 Q. We saw also there, Colonel Selak, General Talic saying that --

20 words to the effect that there was a Muslim-Croat coalition to enslave the

21 Serbian people. From what you knew of him, did he genuinely believe that,

22 when he was saying this on television?

23 A. Yes. He did believe that sincerely because he sincerely wanted

24 for the Serb Republic of Bosnia-Herzegovina to come into being, and he did

25 all within his power to attain that objective. He believed that all the

Page 13150

1 means were good to achieve that objective. So they had excellent

2 cooperation with all political structures and with the SDS in particular.

3 And nobody opposed it because they were pursuing the same common goal, and

4 that was the establishment of the Serb Republic of Bosnia and

5 Herzegovina. He believed that firmly and to the very end.

6 Q. All right.

7 MS. KORNER: Could we have the final clip on this video, which is

8 about some 30 seconds or so? One -- it should start at 1 hour 32.

9 [Videotape played]

10 MS. KORNER: Can we go back slightly? I'm sorry, a bit further

11 back than that. We just need to see the question, I think. Yes. All

12 right. From there, yeah.

13 [Videotape played]

14 MS. KORNER: All right. We can stop it there, thank you. Yes,

15 that's all I require on that video.

16 Now, Your Honour, I should add that this is a series of clips at

17 various times assembled on one tape, and one could see clearly General

18 Talic saying or somebody saying the third year of the war, and that was

19 again a much later part of the show so that wasn't filmed at the time.

20 Q. But two things. General Talic in that clip that we looked at

21 referred to the Turkish converts and the Ustasha knife. Is that the sort

22 of language you would expect from a general in the army?

23 A. No. It is -- it was a very offensive statement, a very offensive

24 expression, and how shall I put it, an intellectual, an accomplished man,

25 should never allow himself to say that because he insulted the Bosniak

Page 13151

1 people, the Croatian people, and did so knowingly, and he was doing it in

2 order to mobilise the Serb people in their pursuit of their common

3 objective.

4 Q. He also mentioned that documents apparently found in Kozarac show

5 that there was a plan to -- not specified -- but liquidate people,

6 presumably the Serbs, going from house to house. Were you aware of any

7 such plan by the Bosniaks in Kozarac or anywhere in that area, to go from

8 house to house liquidating people?

9 A. This is a total fabrication. As a professional soldier, I'm

10 asking you: Who is going to leave what lists of houses, especially in

11 Kozarac, to carry lists around houses and keep them there? One can only

12 laugh at that, because it is quite clear who this is addressed to and

13 why. It is addressed to the people, to people who believe whatever he

14 says, because he's their commander. So they keep up the tension.

15 And what happened in Kozarac was the murder of over 2.500 people

16 in three days alone, not to mention the ethnic cleansing which followed

17 and which also meant the end of a -- much more larger number of people.

18 And it was statements like this of generals, corps commanders, politicians

19 of the SDS and other parties, Serb officials, they mounted the -- they led

20 to mounting of the tension, and unfortunately prompted the Serb people to

21 commit the crime which was committed in Kozarac and other areas. I'm not

22 going to did go into that now. Unfortunately, such intellectuals as Talic

23 are responsible for the genocide which took place.

24 Q. Now, Colonel, I want - before we look at the next video clip which

25 is very short - to ask you to look at a new document.

Page 13152

1 MS. KORNER: Your Honour, that video now become 1595? That's the

2 one with the number V0003881.

3 Q. Now, could you be shown, please, a document that has not been

4 numbered P380? Which I don't think I put in yet. No. P380, please I'm

5 sorry, did I say not been numbered? It has been numbered?

6 JUDGE AGIUS: I have a P380 which has nothing to do with that. I

7 have a P380 which is a Sanski Most document.

8 MS. KORNER: It should be a 1st Krajina Corps.


10 MS. KORNER: It should be 308 maybe. I'm sorry.

11 JUDGE AGIUS: I have a P380 which is a 1st Krajina Corps document.

12 MS. KORNER: Dated the 1st of June?


14 MS. KORNER: That's the one with a disclosure 4.627?

15 JUDGE AGIUS: Yes, correct.


17 Q. This is a 1st Krajina Corps operational report dated the 1st of

18 June. And if you look at the third paragraph --

19 MS. KORNER: We can put it on the ELMO, Your Honour, the English,

20 if there is a problem. It's one of those, is it? Oh, okay. I didn't

21 realise we had copied --

22 Q. In the second paragraph, it talks about "Groups being disarmed

23 every day, particularly within the city itself, people who failed to

24 respond to mobilisation or day work lose their jobs and criminal

25 Prosecution is instigated against them. A portion of the Muslim and

Page 13153

1 Croatian population is moving out and the region of Bosnian Krajina has

2 issued a decision to facilitate such departures providing that the Serbs

3 from Central Bosnia and places with predominantly Muslim and Croatian

4 populations were also allowed to move out. Those departing will not be

5 allowed to return."

6 Now, then in the next paragraph, it deals with operations in

7 Kljuc, and the energetic action by the 30th Partisan division resulted in

8 the defeat and break-up of these forces in the town of Kljuc and the

9 villages of Pudin Han, Velegic, and Donji Ramici. And then it talks about

10 280 enemy soldiers being captured in Kljuc and a number of them killed.

11 Then it talks about Kamicak and Vrhpolje. And then this at the bottom:

12 "The heaviest fighting has taken place in the area of Hambarine,

13 Prijedor, and Kozarac. Troops under the command of the Prijedor area

14 cleared Hambarine and Kozarac and completely destroyed one ZNG unit, black

15 shirts, foreign mercenaries, and legionnaires. The troops have arrested

16 more than 2.000 Green Berets, who are now in Omarska; 135 of them in Stara

17 Gradiska; and 5.000 in the village of Trnopolje. Among the arrested is a

18 large number of officers and organisers of paramilitary formations."

19 And then it says at the end of this paragraph: "The troops and

20 officers received written commendation from the corps commander for the

21 determination, skill, and courage they had demonstrated. They are an

22 example of how one should act while defending the Serbian Republic of

23 Bosnia-Herzegovina. Unfortunately, eight VRS army members have laid down

24 their lives in the fighting and 23 were wounded."

25 Now, Colonel, you've already explained to us what happened there

Page 13154

1 and about the meeting with General Talic, but I want you now, please, to

2 look at the video.

3 MS. KORNER: Could this document be made -- it's already --

4 Q. Now, can you look, please, at a short video, which bears the

5 number V0002590? For which there is a transcript, Your Honours, marked

6 11.7. It's a one-page. If we could play the video?

7 JUDGE AGIUS: Do we have a technical problem or what? Madam

8 Registrar, could you -- I can't see --

9 MS. KORNER: Here it is. It's on, Your Honour.

10 JUDGE AGIUS: All right.

11 [Videotape played]

12 THE INTERPRETER: [Voiceover] "They indulged in some birthday

13 celebrations. First greeting his soldiers and officers, and then the

14 numerous guests and invitees, the Commander of the 5th Kozara Brigade,

15 Colonel Pero Colic, stated how happy he was to be with such fighters today

16 in these difficult times of war and how together they were defending the

17 heart of Republika Srpska.

18 "Tomorrow, if need be, Posavina will be at Kozara, Kozara in

19 Herzegovina, Herzegovina at Srbobran, Srbobran in Serbian Krajina and all

20 of us together in Serbia and Montenegro as our brothers from these Serbian

21 lands have been with us from the beginning, fighting against the Ustashas

22 and Islam. Without this knowledge, we would not have been successful in

23 this struggle against the entire world, where even the few friends we have

24 are not allowed to be our friends. It is difficult to list all the places

25 and front lines where the heroic 5th Kozara Brigade carried its flag high

Page 13155

1 with honour and dignity. It should be enough to mention that it was on

2 all the Western Slavonian front lines where we not only defended and

3 succeeded in defending the Serbian people and the Serbian land, but

4 contributed greatly to the organisation of the Serbian army and its bodies

5 after...after Slavonia. The 5th Kozara Brigade, which earlier prepared

6 and armed the Serbian people, played a great role and succeeded in

7 defending Prijedor and the surrounding area after which we went to

8 Gradacac and then to the Brcko front. Here we feel at home, thanks

9 primarily to the fighters and the command of the 1st Posavina and the 3rd

10 Semberija Brigades. Our fighters accepted...became a part of this people

11 and that is what is most important for the defence of this Serbian land.

12 "To the bravest and most distinguished fighters."

13 MS. KORNER: All right. Thank you.

14 Q. Now, we heard Colonel Colic saying at this ceremony that the 5th

15 Kozara Brigade earlier prepared and armed the Serbian people. Were you

16 aware that the 5th Kozara Brigade had been arming the Serbs?

17 A. Yes. The 5th Kozara Brigade, that is General Uzelac, asked in

18 May, 1991, that weapons be issued to this brigade, the Territorial

19 Defence, but the conditions were not met for its mobilisation. I refused

20 to issue those weapons, Pero Colic -- Colonel Pero Colic, Colonel Vaso

21 Tepsic came to me - he was the assistant corps commander for the rear - to

22 ask for the weapons. And I did not give them to them but I called

23 General Crmaric in Belgrade.

24 Q. Can I stop you for a moment, Colonel Selak, because I think you

25 told us about this yesterday, this incident. But what appears to be said

Page 13156

1 here is that the 5th Kozara Brigade prepared and armed the Serbian

2 people. In other words handed over weapons to non-members of this unit.

3 Were you aware of that?

4 A. I was.

5 Q. And it says that it played a great role and succeeded in defending

6 Prijedor and the surrounding area. Did this unit play a part in the

7 attack on Kozarac?

8 A. It did. A direct part.

9 Q. Now, just one further thing: Could you have back that earlier

10 document, P380? Because there was one thing I forgot to ask you. You

11 still have it.

12 It's signed, we see, by Colonel Vukelic?

13 A. That's right.

14 Q. And it says at the -- in the last paragraph, "This report should

15 be thrashed out with all the soldiers specifying that the facts it

16 presents are more credible than those in the mass media." So it lacks

17 certain details regarding some specific communities.

18 Was this a regular thing, that a report on the current political

19 and security situation would be discussed with the soldiers?

20 A. Yes, this information went from the corps command and the

21 assistant for morale, assistant corps commander for morale, down to

22 brigade and other units, commanders, out side the brigades and the

23 commanders of these units were to inform all their troops, all their

24 officers, and all their men about this.

25 Q. All right.

Page 13157

1 MS. KORNER: Your Honour, could that last video, please, be made

2 Exhibit 1596 and the transcript will be 1A and 1B -- 1/A and 1/B. Your

3 Honour, it may well be that this is the appropriate time for a break

4 because I'm moving to a couple more documents and one last video.

5 JUDGE AGIUS: Which was 1595, then?

6 MS. KORNER: 1595 was the video before, 3881. The subtitled one.

7 JUDGE AGIUS: That was -- I see. All right. Okay.

8 MS. KORNER: Yeah.

9 JUDGE AGIUS: We don't have a transcript for this because we had

10 the subtitles, correct.

11 MS. KORNER: There is actually a transcript, but the subtitles are

12 there. And it is a very, very lengthy video, Your Honour so perhaps it's

13 just as well --

14 JUDGE AGIUS: Shall we break now, Ms. Korner?

15 MS. KORNER: Yes. I was going to say -- I did say.

16 JUDGE AGIUS: 15 minutes? 15 minutes break?

17 MS. KORNER: Yes.

18 JUDGE AGIUS: Mr. Ackerman? Okay?

19 --- Recess taken at 3.45 p.m.

20 --- On resuming at 4.08 p.m.


22 Q. Colonel Selak, could you be given now, please Exhibit number P608,

23 disclosure number 4.840? I want to return to the topic of cooperation,

24 before we look at the last video. Colonel Selak, again it's a 1st Krajina

25 Corps -- in fact an order dated the 1st of April, 1992, and it is, I

Page 13158

1 think, signed -- let me just check -- is that -- actually, I think that's

2 actually signed by General Talic himself, is it not, if you look at the

3 last page? Or is that a "za" -- maybe it's a "za"?

4 A. This is for General Talic.

5 Q. All right. And it starts with describing the complexity of the

6 political and security situation, particularly in Sanski Most, Prijedor,

7 Kljuc, Mrkonjic Grad, and Sipovo, and then it's an order in respect of the

8 10th Partisan Brigade. And the order is to send it towards Sanski Most,

9 deploy the union -- the union -- the unit in the Sanski Most, Kamengrad

10 village area and gives it the various tasks, the military tasks, and then

11 says, "Establish full cooperation with the organs of government in Sanski

12 Most municipality and collaboration with the Territorial Defence and

13 police units."

14 Would you expect an order redeploying a particular unit to include

15 establishing full cooperation with the political bodies?

16 A. This is not customary. However, it's illogical because the

17 brigade has to cooperate both with political and police authorities of the

18 respective municipality.

19 Q. Yes. All right. Thank you. That's already been exhibited. So

20 could you look, please, at one more document with the disclosure number

21 4.619, dated the 21st of May. Again, I think if you look at the last page

22 of this rather lengthy document, it's been signed on behalf of General

23 Talic?

24 A. Yes.

25 Q. And it talks about the general mobilisation of the Serbian army

Page 13159

1 within Bosnia-Herzegovina, and if we look under the words, "I hereby

2 order: 1. Immediately establish direct contact with municipal and

3 military and territorial organs on the ground, offering expert and

4 material support for the mobilisation process." Now, in -- I think you

5 may have already told us that -- this, but where a mobilisation was

6 ordered, was it important that there was direct contact with the

7 municipal, military, territorial organs on the ground?

8 A. Yes. It is essential, because those organs had accurate records

9 of all able-bodied men on their territory, with the exact addresses of

10 where they were residing.

11 Q. Then could you go, please, to paragraph numbered number 8? We see

12 that the tasks -- until the units received concrete combat tasks, engage

13 them in the following task, and item 4: "Establish the closest possible

14 cooperation with the people and legal authorities within their zones of

15 responsibility."

16 And then finally, item number -- paragraph number 11: "Do not

17 allow the presence of any paramilitary formations or other special

18 organisations within the zones of responsibility. Disperse individual

19 members amongst various units as volunteers, but if they refuse that,

20 break them up and, if necessary, destroy them."

21 We saw not so long ago the video showing Martic's men, I think

22 they were called Martici, and the Wolves of Vucjak fighting with the 5th

23 corps or the 1st corps by then. Was that -- this order to effectively

24 disperse paramilitary units among regular units something that you would

25 expect?

Page 13160

1 A. No. In this paragraph, it is indicated such groups should be

2 placed under the control of the corps units. Either as volunteers or as

3 groups. I had not heard that any such group had been disarmed, and the

4 unit commander should have made sure that those paramilitary units had to

5 carry out their orders.

6 Q. So -- I'm sorry, Colonel, does that mean that this order should

7 have meant that instead of the groups fighting as a group, like the Wolves

8 of Vucjak, they should have been split up and dispersed into actual units?

9 A. Paragraph 11 clearly says that they should be divided up and

10 attached individually to other units or brigades of the corps, and if they

11 don't obey, they should be disarmed. However, this was not implemented,

12 at least I do not know of a single unit of paramilitary formations having

13 been disarmed.

14 Q. Thank you. Now, I'd now like to you watch part of the video --

15 I'm sorry, Your Honour.

16 MS. KORNER: May that be made Exhibit P1597?

17 JUDGE AGIUS: Thank you.

18 MS. KORNER: I'd now like to you watch the last set of video

19 clips. One it's V0001853. Your Honour, there is a transcript which has

20 got the number 5.21 on it. Your Honour, part of what we are going to see

21 on this video has been seen on another video. Clearly the same clips were

22 recorded by different people. But parts we haven't seen before.

23 [Videotape played]

24 THE INTERPRETER: [Voiceover] "That is what they do to their own,

25 and as to what they are capable of devising for others, it is evidenced.

Page 13161

1 "...The Muslim and Croat extremists have under their control just

2 two more villages in Kotor Varos municipality - Vecici and Ravne. The

3 chief organisers of the resistance in these villages are well-known

4 criminals Muhamed Berbic and Mehmed Sadikovic. They have many wounded

5 among them, while their food supply is almost exhausted. Vrbanjci, until

6 recently an Ustasha stronghold, is now firmly held by the troops of the

7 Serbian Republic of Bosnia and Herzegovina.

8 "I would like to say that we encountered an excellent spirit of

9 cooperation among those people. Unfortunately, we had a situation where

10 in two villages, despite an agreement that had been reached, they started

11 shooting at units of the Ministry of the Interior of the Serbian Republic

12 of Krajina, as well as members of my unit. Therefore, we had to respond

13 accordingly.

14 "Mr. Brdjanin, could you please tell us what the reasons are for

15 your visit and what your view is on the latest developments in the

16 territory of Kotor Varos municipality?

17 "Let me tell you that being the president of the Autonomous Region

18 Crisis Staff, it is my responsibility to tour all the front lines. I have

19 admit that I have most frequently toured the Corridor, the passage to

20 Serbia, but simply today's visit...the reason for this visit is that every

21 Monday I must inform presidents of all crisis staffers about the political

22 situation in this region. We have to clear our area, which definitely

23 encompasses Kotor Varos and Jajce, and the most important battle being

24 waged is the one I toured yesterday, the breakthrough to Serbia. We can

25 see for ourselves that there is simply no point in further negotiating

Page 13162

1 with those who are at war with us; those who took up arms must be

2 defeated, must surrender their weapons, and total Serbian rule established

3 here."

4 MS. KORNER: Could we pause the video before we move on?

5 Q. What would be the importance of this speech being made by

6 Mr. Brdjanin to Banja Luka television, Colonel Selak?

7 A. The Kotor Varos municipality was on the border towards central

8 Bosnia, and the Banja Luka Corps had one of its main goals to take control

9 of Kotor Varos, so as to link up the line towards Teslic and Doboj.

10 Brdjanin's words were addressed not just to the combatants but

11 also to the population, and the aim they had set themselves, they wanted

12 to achieve, but on that day, more than 400 men were killed in Kotor

13 Varos. That was the price. In the report of this brigade, it was stated

14 that soldiers were killed but that is not true. The truth is that in

15 addition to soldiers, a large number of inhabitants were liquidated too,

16 and there are documents to corroborate this, and eyewitness testimony too.

17 Q. All right. He says that it's his responsibility to tour all the

18 front lines. Why? Why was that his responsibility? What was the

19 importance of him touring the front lines?

20 JUDGE AGIUS: Yes, Mr. Ackerman?

21 MR. ACKERMAN: Your Honour, I object to that. How could he

22 possibly know?

23 JUDGE AGIUS: Of course, of course, if it wasn't this witness, it

24 was another -- the one before him who did hint about the importance of

25 such visits, actually. So the -- your objection is not sustained. It's

Page 13163

1 rejected.


3 Q. From -- I'll rephrase the question because -- Colonel Selak, as a

4 soldier, what would -- or as a commander or whatever, what would have been

5 the importance of the leader, the President of the Autonomous Region

6 Crisis Staff touring the front lines?

7 JUDGE AGIUS: It was actually this same witness. You had asked

8 him very similar, almost identical question.

9 MS. KORNER: Yes, I had, in relation to an entry there but not

10 quite in the same way.

11 JUDGE AGIUS: That's why I'm allowing it.

12 MS. KORNER: Thank you.

13 THE WITNESS: [Interpretation] The visit of an official, of

14 political officials, such as the President of the Crisis Staff, for me as

15 a unit commander, would mean a recognition and paying tribute to me for

16 carrying out my tasks, that my unit and my soldiers had carried out the

17 tasks assigned to, and that the people stand behind that unit. Because he

18 represented the civilian authorities. And that is why it was very

19 important to make visits by political bodies to all front lines. And

20 these visits were regularly held throughout the war.


22 Q. Thank you. Could we continue playing the video

23 [Videotape played]

24 THE INTERPRETER: [Voiceover] -- "We also asked political

25 authorities to undertake all measures in order to avoid potentially

Page 13164












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 13165

1 inflammatory situations which could result in devastation of buildings,

2 loss of human life, and so on. However, I have to say that the other side

3 has, at least partially, come to terms with such activity on our part, but

4 certain number of extremists has gone into hiding and they do not wish to

5 be put under our control, nor do they wish to surrender their weapons.

6 "This surprise visit to Serbian soldiers by the Krajina leadership

7 demonstrates that there is a synchronised cooperation. In addition to

8 activities involving liberation of Serbian territories, officers, and

9 soldiers, members of Serbian armed units are also directly involved in

10 establishing the Corridor towards Serbia, which is one of the greatest

11 operations in the history of the Serbian people.

12 "...Serbian defenders, whereas more than 65 were wounded. Just

13 last week in this area, mostly in the villages of Vecici, Vranici,

14 Sokoline, and Rujevica, 17 soldiers and members of the special police unit

15 were killed. Last night's list of fatalities included Colonel Milan

16 Stevilovic, head of the Department for Intelligence and Security Affairs

17 of the 1st Krajina Corps; Stevan Markovic, head of the Police Department

18 in the Banja Luka Public Security Station; Obrad Bubic, a craftsman from

19 Kotor Varos; while Novo Petrusic, a driver, was captured and taken away.

20 In addition, yesterday in the afternoon, Djuro Eskic, an employee of

21 Proleter, was killed in Kotor Varos by a sniper shooting from Kotor on the

22 left bank of the Vrbanja river. Last year during a clearing of terrain in

23 villages inhabited by Muslims and Croats in Kotor Varos municipality, the

24 fiercest battles were waged in the very same village of Vecici. Yesterday

25 and today, aviation of the Serbian Republic of Bosnia-Herzegovina took

Page 13166

1 part in the final operations conducted jointly by the troops of the

2 Serbian Republic of Bosnia-Herzegovina and special police units, firing at

3 selected enemy targets."

4 MS. KORNER: Thank you.

5 Q. We can see planes bombing Kotor Varos there, Colonel. Do you know

6 what type of bombs they were using?

7 A. Yes.

8 Q. Or what type of weaponry?

9 A. For ground forces, tanks and APCs were used. Chemical weapons

10 were not used, only incendiary devices. Explosives, powerful bombs, and

11 incendiary cluster bombs. This was ordered by General Ninkovic.

12 MS. KORNER: All right. Thank you. Can you move on with the

13 video?

14 [Videotape played]

15 THE INTERPRETER: [Voiceover] "The number of fatalities among the

16 Muslim-Croat paramilitary has exceeded 300, with a significantly greater

17 number of wounded, about 200. In yesterday's and today's combat alone,

18 Muslim and Croat extremists had over 100 wounded and killed and about 200

19 wounded. Their own civilians, Muslim women, children, and the elderly are

20 held hostage by the extremists, who tortured and kill them. Yesterday,

21 between 16 and 1700 hours in the vicinity of Rujevica village, on the road

22 between Maslovare and Kotor Varos extreme cruelty, enemy villains ambushed

23 and tormented to death Stevan Markovic and Obrad Bubic, also killing Milan

24 Stevilovic and capturing Nova Petrusic. A commemoration ceremony was held

25 today in honour of Milan Stevilovic at the Banja Luka JNA hall.

Page 13167

1 "He spent many years of his young life serving in the military

2 police and security agencies. He selflessly took the time away from his

3 family and generously invested his efforts towards strengthening the units

4 and defenders of this beautiful homeland of ours. At the time of his

5 death, he was serving as the head of the Department for Intelligence and

6 Security Affairs in the 1st Krajina Corps, a formation he so

7 enthusiastically supported and towards whose success he worked

8 tirelessly. And those efforts of his were not fruitless, for he leaves

9 behind him a corps that has no equal in Europe or the world. He lived his

10 life and built his career in an honourable, decent, and dignified manner,

11 while his selfless work frequently served as an example to others. He

12 received several decorations and awards and was promoted to the rank of

13 colonel in an extraordinary procedure.

14 "Stevilovic was born in 1946 in the village of Motike by Drvar and

15 through his perseverance and tireless work has grown into --

16 "...a courageous and valiant son of Krajina and a hero of Drvar.

17 "Predrag Radic, president of the Banja Luka municipality, spoke of

18 the life and achievements of Colonel Stevilovic. Colonel Stevilovic's

19 funeral will take place tomorrow in his native village of Motike by Drvar,

20 while a commemorative service will be held in Stevan Markovic's honour

21 tomorrow morning in Banja Luka.

22 "...and our crew.

23 "The local commune of Kotor, another firm stronghold of the

24 Ustasha on the Kotor Varos municipality, has finally been captured.

25 Deputy commander of the special units of the Banja Luka Security Services

Page 13168

1 Centre, Ljuban Ecim, will tell us how this operation was conducted.

2 "This was definitely one of the most synchronised and most

3 organised operations conducted on the territory of Kotor Varos

4 municipality. Excellent results were achieved in some six hours of action

5 under the guidance of the special unit and splendid, let me underline

6 this, excellent assistance provided by the reserve and active forces of

7 the Security Services Centre, many of whose members took part in combat

8 for the first time today, but truly lived up with to the name of

9 Krajisnik, men from Krajina, in battle. We were also assisted by a

10 certain segment of units of Serbian forces...Serbian troops of the

11 Republic of Bosnia-Herzegovina. With only one victim and three wounded on

12 our side, we managed to destroy the core of the HVO and kill the

13 self-proclaimed HVO commander, Stipo Maric, also known as Sprzo, who has

14 up until now inflicted heavy losses on us through many treacherous

15 ambushes. His victims included Colonel Milan Stevilovic and head of our

16 police department, Stevan Markovic. However, justice came to collect its

17 dues, and today we destroyed the entire group and liberated a larger

18 portion of the town. So that now it can be said that the entire city of

19 Kotor Varos is finally free.

20 "Based on your assessment, what are the enemy's losses?

21 "Well, at least 50 or so, but we won't know the real figure for a

22 few days, because the terrain is fairly difficult to access and there are

23 many mountain peaks. The greatest obstacle is that part of the combat was

24 conducted in Kula and Stari Grad, where Sprzo was killed.

25 "What would you like to tell our viewers regarding Vecici?

Page 13169

1 "Well, Vecici partially got what it deserved and the rest will

2 follow. We are going one by one, and we will get to that village.

3 "With respect to the proposal on constituting an association of

4 assemblies of Republika Srpska and Republic of Serbian Krajina and also

5 the United Nations Security Council Resolution 820."

6 MS. KORNER: Stop. It's my fault. I had the microphone -- I had

7 the microphone off. Could we run the video back, please, to the beginning

8 of this segment and then start again? Right.

9 Q. Before we move on to this, Colonel Selak, we saw Ljuban Ecim being

10 interviewed. Did you know him?

11 A. I was with him twice, in the SUP building. We met there.

12 Precisely, we talked about certain weapons, but that was at the beginning

13 of the war in Croatia. Later on, we didn't meet again.

14 Q. This special unit of the CSB that he commanded, did you know

15 anything about that unit?

16 A. Yes. I received an order from the command of the 2nd Military

17 District of Sarajevo to issue weapons and other materiel, equipment, for

18 this unit.

19 Q. Yes. I think we looked at that document or you dealt with it in

20 your diary -- your workbook, earlier. The sort of people who were in that

21 unit --

22 A. Yes.

23 Q. -- Were they regular policemen? If you don't know, say so.

24 A. No. They were not regular policemen. Because the police also had

25 a reserve force, which was trained in peace time for the mobilisation when

Page 13170

1 it should occur, that is to increase the number of active police forces of

2 the town of Banja Luka.

3 Q. From your own knowledge, what sort of people joined this so-called

4 special unit? If you know.

5 A. They were mostly soldiers who had done their military service in

6 the military police. Those men received special training in peace time,

7 too.

8 Q. All right. Can we just look, then, at this last bit of the video

9 clip, please?

10 [Videotape played]

11 THE INTERPRETER: [Voiceover] "Dr. Nikola Koljevic, vice-president

12 of the Republika Srpska, in his opening speech stated that the final goal

13 was the creation of a union of Serbian states, but that at this stage we

14 needed to take one step at a time and create joint institutions which

15 were, at this moment, embodied in an association of assemblies, council of

16 ministers, and a joint coordination body. During the debate, assemblymen

17 also proposed a speedier course - unification of two Serbian states.

18 Radoslav Brdjanin, Nedeljko Rasula, and Mitar Miljanovic asked that a

19 decision on unification be adopted, so that voters could either confirm or

20 reject it at the referendum. Dr. Radovan Karadzic stated that, despite

21 the existing desire, this reality did not permit us to go forward

22 immediately with unification. As Dr. Karadzic put it: 'It does not dawn

23 before daybreak.' Assemblymen approved this explanation by a majority of

24 votes and constituted a four-member commission comprising: Rajko Kasagic,

25 Milovan Milanovic, Vojo Maksimovic, and Milan Trbojevic to prepare, in

Page 13171

1 collaboration with the commission of the Republic of Serbian Krajina,

2 documents needed for constituting the association of assemblies. The

3 debate on resolution 820 was also quite heated, although practically no

4 dissonant voices were heard. Dr. Radovan Karadzic stated that this

5 resolution was unjust toward the Serbian people. 'It could even be said

6 it was genocidal,' said Dr. Karadzic. Biljana Plavsic proposed that

7 Dr. Radovan Karadzic give a report to the assemblymen on the political

8 situation. General Ratko Mladic on the military one and Dr. Vladimir

9 Lukic on the economic situation. She also proposed the assembly adopt in

10 closed session two to three courses for further action in Republika

11 Srpska. Aleksa Buha, Minister of Foreign Affairs of Republika Srpska,

12 made a proposal, which was subsequently adopted, for the assembly to send

13 a memorandum to the members of the European Union, Security Council, and

14 the United Nations itemising all mistakes committed by European and

15 international policy makers in resolving the crisis on the territory of

16 the former and never-to-be-whole-again Bosnia and Herzegovina.

17 Momcilo Krajisnik, president of the national assembly of Republika Srpska,

18 gave us an assessment of the work conducted so far.

19 "In addition to the resolution we discussed certain segments..."

20 MS. KORNER: Stop. Thank you. I do not need any more of the

21 video. I don't think we need to see Mr. Krajisnik being interviewed.

22 That's all I want to play on that video. Your Honour, we should say, as

23 far as we can work out, because of the mention of the UN resolution 820,

24 this was an assembly -- we can't date it exactly but in early 1993.

25 Q. But what I want to ask you about this, Colonel, and this leads me

Page 13172

1 on to the final topic I want to ask you about and that's Brdjanin

2 himself. We heard Brdjanin and others, Rasula from Sanski Most, that a

3 decision on the unification of the two, as it were, Serbian states, the

4 two Krajinas, was decided upon.

5 Had you heard Brdjanin express views saying that the two, as it

6 were, the Krajinas should be joined together in one Serbian state?

7 A. Mr. Brdjanin's statement was carried by the media, both the Glas

8 from Banja Luka, Banja Luka Television. I didn't listen to the radio, but

9 I read it in the Banja Luka Glas.

10 Q. Had you heard -- this is we think, 1993. Had you heard him

11 express views earlier, either in 1991 or 1992?

12 A. No. Not in 1991, but yes in 1992.

13 Q. All right. Yes. Thank you.

14 MS. KORNER: May that then be made Exhibit P1598 with the

15 transcript as 1598-1, A and B?

16 Q. All right. Then I'd like to you look, please at one last document

17 and that's a newspaper article in connection with Mr. Brdjanin. Could you

18 be handed, please, the edition, it's 2.111 disclosure number, it's Glas,

19 19th of May and the headline is: "Fear of Imaginary Date." And under that

20 it says, "Subject, the Autonomous Region of Krajina's war staff claims

21 that there is no foundation for rumours about the war spreading around to

22 Banja Luka." And it quotes Radoslav Brdjanin giving an explanation for

23 the reasons surrounding various things that had been decided in respect of

24 the 20th of May.

25 And then he talks about the military recruits, "There was a heated

Page 13173

1 debate at today's session concerning disarmament. The long debate

2 following today's session of the Autonomous Region of Krajina's war staff

3 clarified all the uncertainties about who would be responsible for how the

4 confiscation of illegally-obtained weapons would be carried out. It was

5 concluded that this difficult and extremely responsible task for the

6 preservation of peace in these territories will be performed by members of

7 the military and civilian police forces."

8 And then it dealt with the political situation, and Mr. Bulic

9 addressed them. And then "Predrag Radic, mayor of Banja Luka, and general

10 Momir Talic commander of the Banja Luka Corps of the armed forces of the

11 Serb Republic of Bosnia-Herzegovina told reporters about the latest

12 conclusion from today's session of the Crisis Staff."

13 And then I think there is a box where we see that this -- Talic

14 speaking again. "The Serb Republic of Bosnia-Herzegovina proclaimed its

15 army. All other armies that are not under its command or part of the

16 police force we consider paramilitary and they must disarm. Because there

17 cannot be two armies in the area where the Banja Luka or Krajina armies

18 live and operate, said General Momir Talic, commander of the Banja Luka

19 Corps."

20 Now, this refers back to the meeting, again, of the 20th -- of the

21 18th of May that you recorded Talic telling his officers about in your

22 workbook. I want now to deal with, as it were, the connections between

23 Brdjanin and Talic. To your knowledge, how often would those two men

24 meet? I don't mean the exact figure but on average.

25 A. I wouldn't know the exact number of their meetings, but they met

Page 13174

1 regularly, to exchange information, both political and military. And the

2 number of meetings was indicative of their close -- of the close ties

3 between the politics and the army. Without their communication, there

4 would be problems for the population and for the troops, and to my mind,

5 it is -- it was natural for them to meet quite often.

6 Q. How often did you yourself, during the period of 1992, attend

7 meetings at which Brdjanin was present? You've already described, I

8 think, one or -- no, two meetings. One with the UNPROFOR agenda, as to

9 whether they were going to pay millions of dollars, and I think you

10 described one other. I'm not sure. But anyhow, can I ask you, how often

11 did you attend meetings at which he was present?

12 A. Only twice.

13 Q. Other than those meetings, did you see him in the media, either on

14 television or read about him in the newspapers?

15 A. Very often, almost daily.

16 Q. Is that -- let's split that. On television, are you talking

17 about, or the radio, or in the newspapers?

18 A. Banja Luka Glas, because it came out regularly, and in Banja Luka,

19 there were frequent power cuts, especially in 1991 [as interpreted], we

20 had serious problems with electricity so that I did not watch television

21 all that often but whenever we had electricity, and he -- whenever I saw

22 him, he was always explicitly requested the realisation of the ultimate

23 objectives of the SDS and the Crisis Staff of Bosanska Krajina.

24 JUDGE AGIUS: Mr. Ackerman?

25 MR. ACKERMAN: Your Honour, there is a transcript problems that

Page 13175

1 needs correcting. Page 44 line 7 the witness said 1992, not 1991.

2 MS. KORNER: We've had that one before, yeah.

3 JUDGE AGIUS: Colonel, did you say with reference to frequent

4 power cuts, were you referring to 1991 or 1992?

5 THE WITNESS: [Interpretation] 1992.

6 JUDGE AGIUS: Thank you, Mr. Ackerman. That corrects the mistake

7 in the transcript. Ms. Korner?


9 Q. You said that he -- whenever you saw him, in the media, he always

10 explicitly requested the realisation of the ultimate objectives of the SDS

11 and the Crisis Staff of Bosanska Krajina. What sort of influence did his

12 speeches and his -- well, first of all, what sort of influence did his

13 speeches have? How much influence did they carry?

14 JUDGE AGIUS: Mr. Ackerman.

15 MR. ACKERMAN: Your Honour, again how would he know?

16 JUDGE AGIUS: Maybe he does.

17 MR. ACKERMAN: He should be asked first whether he knows, and if

18 so, how he knows, then he can say it.

19 JUDGE AGIUS: That's fair. So you just rephrase your question as

20 to whether he is in a position to enlighten us on the information that you

21 are seeking.


23 Q. Colonel Selak, are you able to tell us, from your own knowledge,

24 what kind of influence his speeches and the like carried?

25 A. All Mr. Brdjanin's statements worried a great deal and frightened

Page 13176

1 me, my friends, all Muslims and all Croats, because they all concluded

2 from the statements that for them, there was -- it was impossible to go on

3 living in Bosanska Krajina. He's a man who is president of the Crisis

4 Staff, who has the authority on behalf of the SDS and on behalf of the

5 Crisis Staff, and we used to comment it, in all our contacts with the

6 citizens in Banja Luka, I mean Croats and Bosniaks. My colleagues,

7 officers, I mean Serbs, clearly commented on Mr. Brdjanin's words and

8 statements only in the affirmative.

9 Q. Now, we know that there were running in tandem the Regional Crisis

10 Staff headed by Mr. Brdjanin, as the President, and the Banja Luka

11 Municipal Crisis Staff headed by Mr. Radic, who was president of the

12 Municipal Assembly. Of the two of them, which was the more important, as

13 far as you and the army were concerned, first of all?

14 A. As for the army, Mr. Brdjanin was more important. However, for

15 the town of Banja Luka, Predrag Radic, the mayor of the municipality, was

16 more important.

17 Q. And what was the difference? Why was Mr. Brdjanin more important

18 for the army and Mr. Radic more important for the town of Banja Luka?

19 A. The Crisis Staff covered Bosanska Krajina as such, its whole

20 territory. And the army used all the human resources and all the material

21 resources, and -- but the army always had to go through the Crisis Staff,

22 through the Regional Crisis Staff. And Mr. Predrag Radic was responsible

23 only for the town of Banja Luka.

24 Q. Yes.

25 MS. KORNER: Colonel Selak, thank you very much indeed. That's

Page 13177

1 all I ask you.

2 JUDGE AGIUS: This will be P1599, this document?

3 MS. KORNER: The Article, Your Honour, yes.

4 JUDGE AGIUS: Thank you.

5 MS. KORNER: Thank you.

6 JUDGE AGIUS: So, Colonel, you are now going to be cross-examined

7 by Mr. Ackerman, who is the lead counsel in defence of the accused

8 Mr. Brdjanin.

9 It's almost unnecessary for me, but I will just remind you that

10 you have absolutely no right to distinguish between the Defence and the

11 Prosecution when it comes to questions and answers. Your duty is to

12 answer all the questions that Mr. Ackerman will be putting to you, as

13 truthfully and as fully as you can. That is in accordance with the solemn

14 undertaking that you made in the beginning of your testimony and which you

15 repeated every day. That's of course unless we tell you not to answer any

16 particular question that is put to you or we stop Mr. Ackerman from

17 proceeding with certain questions. But short of that, your duty is to

18 answer all the questions, because Mr. Ackerman here is doing his duty.

19 Mr. Ackerman.

20 MR. ACKERMAN: Thank you very much, Your Honour.

21 Cross-examined by Mr. Ackerman:

22 Q. Good afternoon, Colonel, almost good evening, I guess I could say.

23 A. Good afternoon.

24 Q. I have a lot of material to cover with you, and it would be

25 helpful, in terms of time, if you could listen very carefully to the

Page 13178

1 questions that I ask you and try your best to answer them. Some of them

2 you can answer easily with a yes or no. If they require any kind of

3 explanation, try to make it as brief and to the point as possible. And

4 that way, we'll finish maybe sometime tomorrow. Okay?

5 A. Okay.

6 Q. I just have some kind of general questions on a number of subjects

7 I want to start with. And I want to begin kind of where Ms. Korner began

8 with you, and that is the significance of the date 18 May, 1992. After

9 that date, which was the date that the JNA became the VRS, wasn't it?

10 A. That's right.

11 Q. After that date, you stayed in the service?

12 A. I did.

13 Q. And actually became an officer of the VRS?

14 A. That's right, but I applied for retirement on the 19th of May.

15 Q. And you wore on your uniform the insignia of the VRS?

16 A. No.

17 Q. How did you get by without being in proper uniform?

18 A. I had taken my oath in the Yugoslav People's Army, and I wore

19 those insignia until the end of my active duty, until my retirement.

20 Q. Other Muslim officers also remained when the VRS was created, did

21 they not?

22 A. A certain number, yes.

23 Q. Do you know how many?

24 A. I don't. In my unit, perhaps eight or nine people stayed on, I

25 mean officers, who were Croats or Bosniaks. I could perhaps list the

Page 13179

1 names, but as early as June, they quit the service following the order

2 issued by General Mladic, and left to Belgrade, to Yugoslavia.

3 Q. And non-commissioned officers who were non-Serb also remained in

4 the VRS, did they not, after the 18th of May?

5 A. All I know is that one of them stayed but he changed his name. He

6 was Muhamed Talic. He changed his name into Marko and stayed with the

7 army. He was my subordinate. He was an optician in a tank workshop.

8 Q. Are you familiar with a pilot by the name, I think, Crnalic was

9 his name, a Bosniak who remained in the VRS and actually flew some of

10 those aircraft we were seeing there on the television just a moment ago,

11 and bombed various villages? Are you familiar with him?

12 A. I didn't know a single pilot, because the air force had come from

13 Zagreb to Mahovljani near Banja Luka, and did I not communicate with them

14 except with the commander of the air base in Mahovljani but I did not

15 communicate with other officers.

16 Q. There were also many conscripts who were non-Serb, who remained

17 within the VRS after the changeover, weren't there?

18 A. I wouldn't know the number. True, some stayed but I wouldn't know

19 the number. But I disagree with your qualification, a large number,

20 because that was not the case.

21 Q. Well, if you consider that a very large percentage of the JNA on

22 18th May was Serb anyhow, I'll agree with you, it couldn't have been a

23 very large number. Correct?

24 A. According to the ethnic structure, and I'm referring to Banja

25 Luka, there should have been a larger number of the reserve force in the

Page 13180

1 corps units. And it was precisely the corps units which were reluctant to

2 take up such people, such individuals, because they miss trusted them.

3 They were reluctant to issue them with weapons fearing that they might

4 misuse them, and at the same time, those men were also afraid of joining

5 the units, because they feared for their own lives.

6 Q. Looking, then, on the other side of that coin, there were a number

7 of JNA officers who left the JNA and went off and joined the Army of

8 Bosnia-Herzegovina, didn't they?

9 A. A certain number, yes. Definitely. But I was not with the BH

10 Army. I know that there were men who joined, especially in Tuzla, in

11 Sarajevo, Mostar, and so and so forth, but from Banja Luka, nine -- we

12 were nine of us, Bosniak officers, and none of us joined the BH Army.

13 Q. You're familiar with Halilovic, Alagic, and Efendic, aren't you?

14 A. Yes. But I met them after the war. I did not know them during

15 the war. They were younger than I was and we were not in the same units.

16 Q. My point is, they were former JNA officers, though, weren't they?

17 A. Yes.

18 Q. Have you read their books?

19 A. No.

20 Q. Do you know Jovan Diviljak?

21 A. I do.

22 Q. Jovan Diviljak happened to be a Serb member of the JNA who joined

23 the Bosnian army, didn't he?

24 A. That's right. A decent, honourable man, a true officer, and a

25 good Serb.

Page 13181

1 Q. So after 18 May, when you continued to serve in the VRS, you

2 followed the orders that were given to you, did you not, like a good

3 soldier?

4 A. Yes, yes.

5 Q. And of course after 18 May, this army that you were in was no

6 longer a Yugoslav army but the army of the Serbian Republic of

7 Bosnia-Herzegovina, wasn't it?

8 A. Yes.

9 Q. And in that connection, being a Serb army, it would not be unusual

10 or improper or out of line for there to be legitimate concern about the

11 loyalty of non-Serb officers, would it?

12 A. I agree.

13 Q. You, sir, apparently were quite a remarkable officer. You always

14 got excellent efficiency reports and had a good reputation to the point

15 where even in 1992, when things had started happening in the country, you

16 were appointed as the liaison with United Nations forces who were being

17 assigned to that area, weren't you?

18 A. Yes.

19 Q. And who appointed you to that position?

20 A. The general staff of the Yugoslav People's Army.

21 Q. Can you give me a name of the actual person who appointed you?

22 A. General Blagoje Adzic.

23 Q. That would have been at that point in Belgrade, right?

24 A. Yes. I have the order. I gave it to the Prosecution.

25 Q. And then you served in that position for a period of time, until

Page 13182

1 things got difficult for you in that regard, didn't you?

2 A. I don't know what you mean "difficult" for me. At the beginning

3 of April, I was replaced and appointed commander of the logistics base in

4 Banja Luka.

5 Q. You had been appointed on this liaison job when?

6 A. I think it was the 5th or 7th of February. I have a copy of the

7 order, perhaps in my brief case, but the OTP have a copy too. We can find

8 it. Please don't hold me to my word regarding the exact date, but any

9 way, the beginning of February. So I held the position for about a month

10 and a half, no longer than that.

11 Q. And you told us in your testimony that you got into some

12 disagreement with Mayor Radic over the billeting of the UN officers.

13 Correct?

14 A. Yes.

15 Q. As a sort of general proposition, through this period of time, and

16 I'm focusing especially on 1992 here, you really had no serious problems

17 serving as a Muslim officer in the VRS, did you?

18 A. I didn't have any problems.

19 Q. I'm going to be referring, Colonel, as we go along, to your

20 various statements to the Prosecution, and you are entitled to have those

21 statements in front of you to refer to them, if you'd like to, and I can

22 ask the Prosecution to give them to you. It might be fair to you so that

23 you can follow what we are talking about, and we don't get into disputes

24 as to what we are talking about. I think that I'll ask that be done?

25 MS. KORNER: The Tadic transcripts as well or just the

Page 13183

1 statements?

2 MR. ACKERMAN: Just the statements, I think.

3 Q. I'm starting with the 1995 statement that you gave, and I'll work

4 chronologically from there. So if you can be given the 1995 one now, then

5 we can forge on.

6 The statement I'm going to refer to for the next several moments

7 and maybe the rest of today is the one that you made in 1995. And the

8 first reference I will make is page 11 of the English version. You are

9 speaking at that location about General Uzelac, and how, in 1991, he was

10 always out and around at meetings with SDS leaders, and that there were

11 dinner parties almost every night, and that's where all the decisions were

12 made.

13 Do you recall saying that?

14 A. Yes.

15 Q. The paragraph I'm actually referring to begins with, "Uzelac

16 turned over his duties to General Vukovic." I don't know if you can find

17 that or not, but you might want to look at it. And this group that was

18 out at dinner parties almost every night where all the decisions were made

19 actually wanted you to join them, didn't they, to become part of that

20 group?

21 A. That is my understanding, yes.

22 Q. It's what you said in your statement, isn't it?

23 A. I haven't read it, but yes, that's how it was. I haven't found

24 the exact place in the statement but I agree with what you just said.

25 Q. And so they were asking you to become a part of these dinner

Page 13184

1 parties where decisions were made, you, a non-Serb officer. And what you

2 did was refuse to do that. Correct?

3 A. Yes. I refused, but for the following reason: I was an officer,

4 true I had taken my oath to the Yugoslav People's Army, my oath of

5 allegiance, and at these meetings something else was discussed and being

6 done. I didn't want to be seen in the company of those people in Banja

7 Luka.

8 Q. But the points I'm trying to make, sir, is that they weren't

9 trying to shut you out, were they? But trying to bring you in.

10 A. Yes. I was for Yugoslavia but not for the kind of Yugoslavia that

11 was being tailored there and elsewhere in Serbia and other places. And

12 they knew that I was of pro-Yugoslav orientation and I was of such an

13 orientation, and that is why they wanted me to join them, to keep company

14 with them and to be with them, alongside them.

15 Q. I need you to find this next part, just so you can satisfy

16 yourself that I'm quoting correctly. It's about probably three pages back

17 from the one I just did. It's page 7 in the English version. It has to

18 do with the literacy of the Serb population.

19 A. Yes, please.

20 Q. Okay, did you find it?

21 A. I have the text on page 7 here, in my language, in which it says,

22 "Contrary to that, reserve officers," and above that, "all military

23 conscripts from Serbia, Montenegro," et cetera. I don't know which

24 paragraph you're referring to. Please help me.

25 Q. I'm going to do that right now. The paragraph begins with "the

Page 13185

1 top three reasons for the war in Bosnia-Herzegovina." That's how it

2 begins.

3 A. Yes, yes, I've found the place.

4 Q. And about halfway through that paragraph, you say this: "There

5 was a recent study reported on Belgrade TV that showed that 85 per cent of

6 the Serb population was illiterate or barely literate, elementary school

7 education. The study shows that these type of people can be greatly

8 influenced by the church and the mass media." That's what you said,

9 right?

10 A. Yes. I did say that. On the 18th of May, 1992 -- I'm sorry,

11 1995, I left Banja Luka and went to Belgrade, and I stayed there for 13

12 days. And in a weekly called Vreme, a professor at the faculty of

13 philosophy in Belgrade wrote, among other things, that 85 per cent of the

14 Serb people have less than a secondary education, and this is a

15 misquotation of what I said.

16 She said 85 per cent of the population have less than a secondary

17 education. And I stand behind that, that copy of the magazine can be

18 found. It was in the issue at the end of May, 1995. And that is what she

19 said. She was a person who had accurate data and who should be trusted.

20 Unfortunately, the same can be said of Bosnia, at least that is my

21 opinion. This applies to other ethnicities as well, and they were easy

22 prey for manipulation.

23 Q. I think, Colonel, what you have just told me is that the statement

24 that's contained within the statement you have in front of you is not

25 correct. It's not what you said. You didn't say that 85 per cent were

Page 13186

1 illiterate? Or if you were misquoted, you were mistranslated or

2 something. Is that your position?

3 A. I said that 85 per cent of the Serb population had an education

4 below the level of a secondary education. And that is what I read in the

5 article at the end of May, 1995, and I quoted from that article.

6 Q. Okay. And that would have, of course, referred to all of

7 Yugoslavia, and you've just told us that it probably also fairly reflected

8 the educational level of all the other inhabitants of the country?

9 A. Perhaps Slovenia should be excluded in the part of Croatia. As

10 for the rest, unfortunately, I'm afraid that is so.

11 Q. Now, the other thing that you say there, the last sentence of your

12 statement, says this: "The study shows that these type of people can be

13 greatly influenced by the church and mass media." Now, was that part of

14 the report that you saw or is that some conclusion you have made as a

15 result of the report?

16 A. That is my conclusion. Because that is exactly what happened.

17 That people believed their religious officers, in whose interest it was to

18 create the state of a Greater Serbia, which the Academy of Sciences in

19 Belgrade also discussed and there is such information available.

20 Q. Of course, if that kind of influence happened among the Serb

21 population, I think you'd concede that it also happened among non-Serb

22 population?

23 A. Yes.

24 JUDGE AGIUS: Shall we stop here for the break, Mr. Ackerman? Is

25 it convenient for you?

Page 13187

1 So we'll have a 15-minute break. Thank you.

2 --- Recess taken at 5.17 p.m.

3 --- On resuming at 5.40 p.m.

4 JUDGE AGIUS: Yes, Mr. Ackerman.

5 MR. ACKERMAN: Thank you, Your Honour.

6 Q. Colonel, you gave several statements to the Office of the

7 Prosecutor. One statement between 23 September, 1995 and 31 January,

8 1996. Correct?

9 A. Yes.

10 Q. And another between 10 January and 13 July of the year 2000?

11 A. Yes.

12 Q. And then another on 10 March, 2001?

13 A. I think that's right.

14 Q. And yet another one on 22 August, 2001?

15 A. Yes.

16 Q. And you gave testimony in the Tadic case, didn't you?

17 A. Yes, I did.

18 Q. And it's true, isn't it, that never in any of those statements, or

19 in any of that testimony, did you ever mention Radoslav Brdjanin?

20 Correct?

21 A. Yes. I think it's correct. I don't have all the statements here,

22 but I think I didn't mention him.

23 Q. Certainly, in statements that you gave to investigators of the

24 Prosecution, after Mr. Brdjanin's arrest in 1998, they asked you about

25 Brdjanin, didn't they?

Page 13188

1 MS. KORNER: Your Honour, I think Mr. Brdjanin was arrested in

2 1999, not 1998.

3 JUDGE AGIUS: Thank you, Ms. Korner.

4 MS. KORNER: And he's nodding behind you, Mr. Ackerman.

5 JUDGE AGIUS: Ms. Korner is right, Mr. Ackerman.

6 MR. ACKERMAN: Maybe I'm a year younger than I thought I was.

7 JUDGE AGIUS: Yes. Go ahead.

8 THE WITNESS: [Interpretation] Could you please repeat your

9 question?


11 Q. You gave one, two, three statements to the OTP after

12 Mr. Brdjanin's arrest in 1999, and in none of those statements did you

13 mention Mr. Brdjanin. And my question was: Surely, the investigators

14 must have asked you about him when they took those statements? I mean,

15 it's why they were talking to you.

16 A. If they had asked me about Mr. Brdjanin, I would have certainly

17 answered them. So if it's not contained in my statements, they didn't ask

18 me. And the answer is no.

19 Q. Doesn't it seem a bit bizarre to you that investigators

20 investigating the Brdjanin case would not ask you on three opportunities

21 if you knew anything about Brdjanin? Isn't that bizarre?

22 A. That is up to the Prosecution, as to what they are going to ask

23 me. It's not up to me, and I don't wish to enter into such details.

24 Q. Well, I suggest, sir, that they in fact asked you every time, and

25 every time you said you knew nothing about him. That's the case, isn't

Page 13189

1 it?

2 MS. KORNER: I'm sorry, can I ask on what possible grounds that's

3 based?

4 MR. ACKERMAN: Just logic.

5 MS. KORNER: Well --

6 JUDGE AGIUS: Whose logic, Mr. Ackerman?

7 MR. ACKERMAN: Mine, Your Honour, and perhaps several other

8 people's too. Otherwise it just baffles the mind.

9 JUDGE AGIUS: Go ahead. Not necessarily.

10 THE WITNESS: [Interpretation] I answered questions put to me by

11 the Prosecution, and I stand by what I said. There may be errors in the

12 interpretation. Such as the question of the 85 per cent of the Serbian

13 people being illiterate. That was misinterpreted. And I may allow for

14 the possibility that they -- there may be other minor details that were

15 misrepresented through translation. But basically, I stand by what I said

16 in those statements.


18 Q. The first time, then -- what you're telling us is, the first time

19 that you ever mentioned to anyone from the Prosecution anything about

20 Mr. Brdjanin was last week in your conversations with Ms. Korner?

21 Suddenly last week, you know about him and not just a little bit, but a

22 lot. Correct?

23 A. I know of Mr. Brdjanin since the elections in 1990 because I lived

24 in Banja Luka. Throughout my working life time. And after that,

25 Mr. Brdjanin held political positions. Therefore, it would be illogical

Page 13190

1 for me not to know Mr. Brdjanin.

2 Q. You didn't answer my question so I'll ask it again. The first

3 time --

4 A. Yes, please do.

5 Q. That you ever mentioned to anyone from the Prosecution anything

6 about Mr. Brdjanin was last week in your conversations with Ms. Korner?

7 That's true, isn't it?

8 A. I cannot remember each and every sentence of my statement. I

9 mentioned quite a number of people, personalities. My statements are here

10 before the Tribunal. So that is what you're claiming, it's easy to check

11 that, looking through the statements. I really cannot remember whether I

12 mentioned him somewhere or not in these statements earlier on.

13 Q. Well, let me ask you this --

14 A. And please don't --

15 Q. [Previous translation continues] ... Read them and it's not there

16 or would you like to have them supplied to you. So you can read them all

17 this evening and confirm to yourself that Mr. Brdjanin is not mentioned

18 there? It's up to you, and I don't care which choice you make.

19 MS. KORNER: Well, Your Honour, I can just check that and I'll

20 confirm on behalf of the Prosecution, rather than asking the witness to

21 read through the statements. I mean, when I've checked it myself.

22 Because I haven't.

23 JUDGE AGIUS: We take it that he's never mentioned -- Mr. Brdjanin

24 is not mentioned in any of those statements. That's a correct

25 affirmation, Mr. Ackerman.

Page 13191


2 Q. You told the Prosecutor last week that the last time you saw

3 Mr. Brdjanin was in 1994, when he spoke to you in the street and asked if

4 there was anything he could do to help. Do you recall telling the

5 Prosecutor that?

6 A. Yes. I do recall. Brdjanin was wearing -- Mr. Brdjanin was

7 wearing a camouflage uniform, at the marketplace in Banja Luka. I was on

8 the other side of the road. He came up to me and asked me, "Selak, are

9 you having any problems of any kind?" I said I was not and I went along

10 my way. I didn't stand around any longer with Mr. Brdjanin, talking to

11 him.

12 Q. You told the Prosecutor that he asked you if there was anything he

13 could do to help. Why would he have asked you if there was anything he

14 could do to help you?

15 A. Mr. Brdjanin probably knew quite a bit about me, just as I knew

16 about him, and it was quite fair on his part to ask me that. However, I

17 didn't want any help, because knowing what he was doing, and being aware

18 of his abilities, or rather his positions, I didn't want his help.

19 Q. Did you not at the time have a family member who was quite ill?

20 A. Yes, I did. My wife was seriously ill.

21 Q. And don't you think that that's what he was talking about,

22 wondering if he could help you in any regard with regard to that?

23 A. I never thought about it. I didn't have time either. I thanked

24 him and went along my way, and I struggled alone regarding my sick wife,

25 with the assistance of other people.

Page 13192

1 Q. Are you aware, or were you aware when he spoke to you that day,

2 that during the war he helped a number of Muslim people who were having

3 problems? Were you aware of that?

4 A. No. I'd like that to be true but I don't know anything about it.

5 Q. Do you know that he helped a great deal -- great number of Muslim

6 people to keep the apartments they had in Banja Luka?

7 A. No.

8 Q. Do you know that he was in trouble with members of the SDA and

9 acquired the reputation of being the Schindler of Banja Luka?



12 Q. SDS. He was called that in a publication or two? Did you know

13 that?

14 A. Could you please repeat it? Because the question really is not

15 clear to me. Did you mean the SDS or the SDA?

16 Q. The SDS. Do you know that he got in trouble with the SDS because

17 he was helping Muslim people, and in fact a couple of publications

18 referred to him as the Schindler of Banja Luka? Are you aware of that?

19 Did you see those reports?

20 A. I know nothing about those derogatory names, but I do know that

21 the end of 1994, he corrected some of his positions, in my view, and there

22 were comments about that in the press or rather among the citizens in

23 town. I do not recollect the details. After all, it was a long time ago,

24 but I did have information that he had corrected his views in relation to

25 the official policies of the SDS.

Page 13193

1 Q. When you responded to me, "I know nothing about those derogatory

2 names," what were you referring to?

3 A. What you said that he was referred to as, I don't know whom, what

4 name he was given. I hear that word for the first time. But I'm sorry, I

5 do know for sure that in the course of 1992 and 1993, that the citizens of

6 Banja Luka that I had contact with expressed very negative views about

7 Mr. Brdjanin, but I don't know anything about actual derogatory names he

8 was given.

9 Q. Well, I wouldn't consider it derogatory. Do you know who Oskar

10 Schindler was in World War II?

11 A. No. I heard something else. I thought I heard another word, not

12 this name that you have just used. I'm sorry.

13 JUDGE AGIUS: Next question, Mr. Ackerman.


15 Q. Oskar Schindler was a German who saved a number of Jewish people,

16 and that was the reference to Mr. Brdjanin being the Banja Luka

17 Schindler.

18 A. Jews, I see.

19 Q. I'm sorry, what did you say?

20 JUDGE AGIUS: Next question, Mr. Ackerman.


22 Q. Oh, I see. I see your answer. Thank you. All right. I'm going

23 to go to your second statement. It's made in the year 2000, and it's page

24 10 of the English version, January and July of 2000. And if you can find

25 a page, sir, where you begin talking about documents that were shown to

Page 13194

1 you, there is a sentence that begins, "I have been shown some other

2 documents, mainly regular combat reports, and I want to make the following

3 comments." It's on page 10 of the English version.

4 A. Yes. Document number 1 is -- is that the one? Or rather, when I

5 list them, starting with number 1?

6 Q. We'll get back to that in a moment. I now want you to at the same

7 time look at the Exhibit DB120.

8 Now, you have before you, sir, a document dated 11 April, 1992,

9 and -- a document authored and signed by Mesud Hasotic; is that correct?

10 A. Hasotic, Colonel Mesud Hasotic.

11 Q. And this document was written in his capacity as the assistant

12 commander for moral guidance and legal affairs of --

13 A. Yes.

14 Q. -- the 5th Corps?

15 A. Yes.

16 Q. And as we discussed yesterday, Colonel Hasotic was a Bosniak,

17 correct?

18 A. Yes.

19 Q. I want to just take you through parts of what he wrote here. At

20 the time this was written, the -- you were still the JNA. You had not

21 converted to the VRS yet, had you?

22 A. No, we hadn't.

23 Q. It's correct, isn't it, that the official policy of the JNA was to

24 keep Yugoslavia together and oppose the ethnic break-up of Yugoslavia?

25 A. Yes.

Page 13195

1 Q. And you described this document in your statement, the statement

2 that you have in front of you, from 2000, and it's now paragraph 2 of that

3 page that I referred you to. You described this document --

4 A. Yes.

5 Q. You described this document there as a document which -- "The

6 attitude reflected in this document" -- no. "This document conveys the

7 official position of the corps command to all its members," correct?

8 A. Yes, it is.

9 Q. You also described it as -- said this: "The content of this

10 document clearly reflects the attitudes and the position of the military

11 leadership," correct?

12 A. But of the corps command, sir; not of the JNA but the corps

13 command.

14 Q. Well, the words you used were "military leadership," wasn't it?

15 A. Yes, but he's speaking on behalf of the 5th Corps command. I did

16 not see eye to eye with Colonel Hasotic, and this was one of the reasons

17 for that, and I said so in my statement.

18 Q. Let's look at the exhibit now, his actual -- what he actually

19 wrote. Beginning at the beginning: "In several crisis areas in BH, there

20 is an escalation of open conflicts of ever-increasing intensity, with

21 tragic consequences in terms of human life and property. The situation is

22 most critical in Kupres, Bijeljina, Bosanski Brod, Sarajevo and Foca.

23 According to some of the evidence received up to 9 April, several hundred

24 people have been killed there, mostly women and children. The most

25 serious suffering is being experienced by the people of Kupres, where

Page 13196

1 heavy fighting is taking place between the armed formations of Croatia and

2 the Serbian people from these parts. The objective of the Croatian

3 state's diabolical plans is to take Kupres, regardless of casualties, and

4 to join up the BH HDZ paramilitaries along the Bugonja-Doboj-Bosanski

5 Brod axis. This would effectively sever the Serbian Krajinas from the

6 remainder of Yugoslavia."

7 Now, that is exactly what happened, isn't it? That area was

8 captured by the Croatian forces and it severed the Krajina from the

9 remainder of Yugoslavia. That's the corridor we are talking about, right?

10 A. The fighting around Kupres started in late 1994, and it is true

11 that the Croatian forces wanted to take Kupres and that area and to join

12 it to the Republic of Croatia. That was their objective, and we knew

13 about that.

14 Q. This is a report of April of 1992, and I'm talking about -- and

15 let me read the last sentence to you again.

16 A. Yes.

17 Q. "The objective of the Croatian state's diabolical plans is to take

18 Kupres, regardless of casualties, and it's the second part of this that

19 I'm interested in, "To join up the BH, HDZ paramilitaries, along the

20 Bugojno, Doboj, Bosanski Brod axis. This would effectively sever the

21 Serbian Krajinas from the remainder of Yugoslavia." And that is what

22 happened, isn't it? That area was captured by Croatian forces and the

23 Krajinas were separated from Yugoslavia, and that's why there was a later

24 war to open up the corridor. That's all true, isn't it?

25 A. This was the diabolical Milosevic-Tudjman plan, how to break up

Page 13197

1 Bosnia-Herzegovina, and so within that context, yes, it fully tallies with

2 that plan, they would have been separated. They would be separated, but

3 that was the breaking up of Bosnia-Herzegovina by other states, by the

4 Republic of Croatia and the Federal Republic of Yugoslavia.

5 Q. I take it your answer is that that's true, that that is exactly

6 what happened? What Colonel Hasotic predicted was going to happen

7 happened?

8 A. Yes, but that objective was not achieved because the Croatian

9 forces never entered Bugojno, Doboj, or Bosanski Brod. That did not

10 happen.

11 Q. How about this? Second paragraph: "Crime, looting and

12 inter-ethnic reprisals have spread over a large part of BH territory.

13 Complete anarchy reigns throughout the republic, and in some communities

14 there is total chaos. The division of the BH MUP into the MUP of the

15 Serbian people's republic and Republic of BH MUP has further threatened

16 the safety of people in multi-ethnic communities." That's true, isn't it?

17 A. It is.

18 Q. I want to ask you about a sentence down, the very end of that

19 paragraph. It says, "For a long time, RTSA, Sarajevo Radio and TV, showed

20 exhaustive footage of the withdrawal of the army from Macedonia, the

21 intentions behind this are quite clear, namely prepare the people to give

22 the JNA the same type of farewell, read as a fair one, from the republic

23 on that fine day when the Bosnia's turn comes."

24 Now, what he's speaking of there is when the JNA was withdrawn

25 from Macedonia and the pictures of that withdrawal, correct?

Page 13198

1 A. I do not remember that footage about the withdrawal of the JNA

2 from Macedonia. What I do know, however, is that the Republic of

3 Macedonia wanted and succeeded in keeping all the materiel of the former

4 JNA, and we, from Banja Luka, from the logistics base there, sent columns

5 of vehicles to Macedonia to pull out the materiel that was necessary for

6 the Banja Luka Corps.

7 Q. And he's predicting a time, is he not, when the JNA would be

8 withdrawing from Bosnia?

9 A. The JNA never pulled out from Bosnia, and the units which had

10 arrived from Croatia, even stayed in Bosnia and even at the Uzice corps,

11 the Novi Sad corps came from Serbia to Bosnia in pursuits of their

12 objectives, that is the official policy of the Federal Republic of

13 Yugoslavia.

14 Q. There actually were units of the JNA that left Bosnia, weren't

15 there? Not easily but they did.

16 A. No. The units did not pull out, did not leave. It was soldiers

17 who were serving their military duty in the units of the JNA in

18 Bosnia-Herzegovina, until the 18th of May, 1992, left the territory of

19 Bosnia and Herzegovina but the officers who were Serbs originally from

20 Serbia and Montenegro did not leave the JNA units. They kept their duties

21 and were on the payroll in the Federal Republic of Yugoslavia, like all

22 the rest of us.

23 Q. But wasn't there a unit around mid-May of 1992, that was stationed

24 in Sarajevo, maybe at a military academy there, that attempted to leave

25 Sarajevo and return to Belgrade in accordance with the order that the JNA

Page 13199

1 should return to Serbia? Don't you recall that incident, when that unit

2 tried to leave Sarajevo?

3 A. In the high military academy centre in the Marsal Tito barracks in

4 Sarajevo, there were some small units providing security, be it physical

5 or logistical, and a goodish number of people in those units wanted to

6 leave, and, yes, that was a problem. But I'm not aware -- I was not

7 familiar with the details of that whole matter.

8 Q. [Previous translation continues] ... Did it not, where those

9 soldiers, those JNA soldiers were actually attacked by Muslim forces or

10 paramilitaries in Sarajevo? That happened, didn't it?

11 A. I was not living in Sarajevo at the time, and I'd rather not say

12 something wrongly. I really do not have the accurate information, and I'd

13 rather not speak about it. I simply do not know. Yes, there was an

14 incident but I'm not aware of any of its details.

15 JUDGE AGIUS: What's the relevance of this present series of

16 questions, Mr. Ackerman?

17 MR. ACKERMAN: Your Honour, it has to do with the changing of the

18 guard, so to speak, between the JNA and the VRS and all the difficulties

19 that surrounded that and the essential truth of this document by

20 Colonel Hasotic, which I will finally get around to asking the last

21 question about. It all is building up to that.

22 Q. Finally, the last sentence of this document, signed by

23 Colonel Hasotic, "Our commands and units will continue in full combat

24 readiness to patiently monitor developments and take all measures so that

25 armed conflict does not occur. In this respect, all actions shall be

Page 13200

1 taken in strict compliance with the orders of the superior command."

2 That's what it says, right?

3 A. Yes. Colonel Mesud Hasotic originally from Sandzak in Serbia

4 wrote at that time, his son was living in Novi Pasar in Serbia, and such a

5 text, he wrote this text to protect his child, among many others, from

6 the -- from the effects of another statement. He also said that he would

7 strictly observe the order of his superior command, which was the command

8 of the 2nd Military District in Sarajevo, or rather as of the 20th, the

9 command of the Army of Republika Srpska in Pale.

10 Q. What you told the Prosecutor about this document, written by your

11 fellow Bosniak, Colonel Hasotic, is this: "The attitude reflected in this

12 document is why I resigned from the army."

13 A. Yes, precisely because of that state of affairs. I anticipated

14 even bigger problems, and with Colonel Hasotic, I disagreed on many

15 points, and we were never friends. We were simply colleagues.

16 Q. Well, what attitude do you see this document reflecting? It talks

17 about things being in bad shape, crime, looting, inter-ethnic reprisals

18 all over the place, predicting difficult times ahead, hoping that conflict

19 can be avoided. I mean, what attitude is that that bothered you? Were

20 you -- how did you object to this attitude? What was your objection?

21 A. It is true that there were serious problems regarding the personal

22 safety, the safety of the citizens of Bosnia-Herzegovina. The war in

23 Croatia, which was transferred to the territory of Bosnia-Herzegovina, the

24 proclamation of the Serb Republic of Bosnia-Herzegovina, told me clearly

25 that the army that I had sworn my allegiance did not exist any more and

Page 13201












12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.













Page 13202

1 that I therefore could not continue being its member.

2 Q. Finally, you said this document not being classified, was

3 available to all members of the 5th Corps. Do you know if it was actually

4 distributed to all members of the 5th Corps?

5 A. I don't, no, but I assume, in view of the military chain of

6 command, it must have come down to the level of brigade commands. Whether

7 the brigade commanders then forwarded it to their subordinates, that is

8 something that I do not know. I did not see this document whilst I was an

9 active-duty officer of that army in Banja Luka.

10 Q. All right. I'm going to go to another subject now.

11 It's correct, isn't it, that prior to 1991, according to your

12 estimate, about 90 per cent of the officers in the JNA were Serb?

13 Immediately prior to 1991.

14 A. No. I think that 90 per cent were of the Serb and Montenegrin

15 ethnicity, and there is also official information to that effect.

16 Q. In the -- I know this is easily explainable, but I'm going to have

17 to ask you anyhow, in the Tadic case, your testimony at page 1.211, you

18 were asked this question: "Prior to 1991, to your knowledge, what was the

19 ethnic composition of the officer corps of the JNA?" Your answer, sir,

20 was this: "The data was never officially published but I can say for my

21 unit, and make a rough estimate regarding the situation in the Banja Luka

22 Corps in which I served. In my base, about 90 per cent of the officers

23 were of Serb nationality. The situation was similar at the level of the

24 Banja Luka Corps." That was true, wasn't it?

25 A. Yes, but what I meant when I said Serb ethnicity, that it was both

Page 13203

1 Serb and Montenegrin, but if that is how it was recorded, that is what I

2 said, but what I meant were Serbs and Montenegrins.

3 Q. That's why I said it was easily explainable because I knew you

4 would say that. What I really want to get to is the next one. You then

5 said, "By the end of 1991, that percentage had increased to 99 per cent

6 Serbs." Right?

7 A. Yes, yes.

8 Q. And that was because of the war in Croatia and the departure of

9 non-Serb officers from the JNA, wasn't it?

10 A. Yes.

11 Q. I guess it was Wednesday of last week when you started testifying,

12 it's the transcript of the 15 January session, page 12.197, and I don't

13 know if you can remember this particular bit of testimony or not. If not,

14 we'll come back to tomorrow. But you were being asked about the

15 relationship between civilian and military authorities, in 1992, in the

16 area where you were serving, and in answer to one of the questions, you

17 referred to a problem in Teslic between civilian and military

18 authorities. Do you know the problem that I'm talking about?

19 A. Yes. I remember that in Teslic, the mayor of the municipality and

20 his associates were -- did not agree, or rather that there was certain

21 friction between the 5th Corps unit there and the chief of the

22 municipality. And I commented on this because there is also a document

23 about this. There were certain problems because -- and General Talic

24 intervened and said that this problem had to be resolved urgently.

25 MR. ACKERMAN: Your Honour, I'm getting ready to go to a fairly

Page 13204

1 large segment. I think I've got maybe a couple of small issues that I can

2 discuss real quickly from today's testimony and then we can stop for the

3 day.

4 JUDGE AGIUS: Okay. Go ahead, Mr. Ackerman.


6 Q. One of the things I wanted to discuss with you about your

7 testimony today, sir, was you talked about a statement that we heard of

8 General Talic where he used some terms, Turk and Ustasha, which you said

9 were unbecoming an officer and/or anyone who is educated and so forth.

10 Correct?

11 A. Yes.

12 Q. And I take it you would agree that the same is true of people who

13 would use the term "Chetnik"?

14 A. Yes. Except when it comes to paramilitary formations, but I

15 disagree with the term when applied to regular units.

16 Q. Yes.

17 A. And allow me to say that in my military career, I was called a

18 Turk three times. One of those who did that was General Uzelac,

19 General Adzic, and I had serious problems and there was verbal

20 altercation. I am not a Turk, I'm a Bosniak. Turks live in Turkey, not

21 in Bosnia.

22 Q. I agree with you about that. We saw a segment on the video where

23 Mr. Brdjanin was visiting the front lines, and you were asked what your

24 view was of the reason for his visit to the front lines, and you gave some

25 answer about, well, it was important to -- for recognition of the people

Page 13205

1 that were there fighting and things of that nature. Did you hear what

2 Mr. Brdjanin said about his reason for visiting the front lines?

3 A. That was something I heard, and I understand.

4 Q. Did you hear --

5 A. I mean what he said.

6 Q. Did you hear -- he was asked what his reason was for visiting

7 there and he answered that. Did you hear his answer?

8 A. I cannot repeat it, but he said he had come to visit units. In a

9 sense, I can't really remember those details.

10 Q. Well, he said that he did that because, I think he said, on

11 Mondays, he was required to report to the presidents of the various crisis

12 staffs in the Autonomous Region of Krajina?

13 A. Yes, you're right. Yes, yes.

14 Q. Now, that makes a great deal of sense, doesn't it? That would

15 have been part of his duties as president of the Crisis Staff of the

16 autonomous region, wouldn't it, to report to the presidents of the crisis

17 staffs of the various municipalities?

18 A. Because perhaps the term is a misnomer. He informs and briefs

19 municipal crisis staffs. You report to your superiors, and municipal

20 crisis staffs were at a lower rung but they had to be briefed about what

21 went on in other areas, because municipal crisis staffs did not have the

22 information about what went on, specifically in Kotor Varos, Doboj, or

23 wherever. And that was why the President of the Crisis Staff I toured

24 them and naturally, then, briefed all other municipal crisis staffs, be it

25 in writing or in some other way.

Page 13206

1 Q. So between the two reasons for him going there, his statement as

2 to why he went there and your guess as to why he went there, his statement

3 is probably more accurate, isn't it?

4 MS. KORNER: Your Honour, I haven't got the LiveNote in front of

5 me of today's thing but I rather thought my question was not what was the

6 reason for him going there but what was the importance, which is a

7 different question.

8 JUDGE AGIUS: And I'm pretty sure although I don't have the

9 LiveNote record that you are right. No, no, you're right.

10 MR. ACKERMAN: I'm pretty sure the word is "reason," and I bet

11 it's there.

12 JUDGE AGIUS: You're both right, then. We can stop here and take

13 this up tomorrow, Mr. Ackerman.

14 Colonel, we are going to stop here and we can continue tomorrow.

15 Do you think you'll be able to finish tomorrow, Mr. Ackerman?

16 MR. ACKERMAN: Very unlikely, Your Honour, very unlikely. And

17 I've already told Ms. Korner about that, she knows.

18 JUDGE AGIUS: All right. Thank you.

19 --- Whereupon the hearing adjourned at

20 6.29 p.m., to be reconvened on Tuesday,

21 the 21st day of January, 2003, at 2.15 p.m.