Tribunal Criminal Tribunal for the Former Yugoslavia

Page 21838

1 Friday, 31 October 2003

2 [Open session]

3 [The witness entered court]

4 --- Upon commencing at 9.05 a.m.

5 [The accused entered court]

6 JUDGE AGIUS: Yes, good morning. Madam Registrar, could you call

7 the case, please.

8 THE REGISTRAR: Yes, Your Honour. Good morning, Your Honours.

9 This is the case Number IT-99-36-T, the Prosecutor versus Radoslav

10 Brdjanin.

11 JUDGE AGIUS: Thank you, Madam.

12 Mr. Brdjanin, good morning to you. Can you follow the proceedings

13 in a language you can understand?

14 THE ACCUSED: [Interpretation] Good morning, Your Honour. Yes, I

15 can.

16 JUDGE AGIUS: I thank you. Please take a seat. Appearances for

17 the Prosecution.

18 MS. KORNER: Joanna Korner, Julian Nicholls, assisted by Denise

19 Gustin, case manager. Good morning, Your Honours.

20 JUDGE AGIUS: Appearances for Mr. Brdjanin.

21 MR. CUNNINGHAM: David Cunningham and Aleksandar Vujic, Your

22 Honours.

23 JUDGE AGIUS: Any preliminaries?

24 MS. KORNER: Just to flag up. It can really be dealt with at the

25 end of the day. I'm anxious to know firstly confirmation that the witness

Page 21839

1 listed for next week is actually coming, and then to know who's coming

2 after that. I know there has been some problems, and we're told that the

3 list of witnesses probably won't be coming, or at least one of them.

4 JUDGE AGIUS: One moment. Let me --

5 MS. KORNER: Can I say, Your Honour, I've mentioned it to

6 Mr. Cunningham, and he's going to make inquiries at the break with

7 Mr. Ackerman, but I think the Court and ourselves --

8 JUDGE AGIUS: But I think my first concern first and foremost and

9 another priority, is whether the next witness for whom we dedicated an

10 entire week --

11 MS. KORNER: That's the other matter I want to mention. I've

12 already mentioned that to Mr. Cunningham. It may be that he doesn't take

13 a whole week, so if Mr. Ackerman and Mr. Cunningham are anxious to keep

14 momentum going, they may want to have somebody else here for Friday. It's

15 possible that the witness may not take as long as we think.

16 JUDGE AGIUS: It's up to you. I mean, I'm not going to interfere

17 with that.

18 MR. CUNNINGHAM: May I address the Court, sir. The primary

19 witness for next week, he has been verified. He is supposed to come in on

20 Sunday for proofing and be ready to go on Monday. That is my

21 understanding.


23 MR. CUNNINGHAM: And Ms. Korner has talked to us about several

24 matters including, Glamoc and Laktasi municipalities, I'm going to talk

25 about that with Mr. Ackerman, try to have an answer for her in the Court

Page 21840

1 today. And I'll try to resolve what's going on with witnesses. If we're

2 not going to use the entire week, I can assure you it's our desire to go

3 forward and not waste a day. So I'll update the Court and counsel at the

4 first possible moment.

5 JUDGE AGIUS: One thing I wanted to tell you is on Tuesday -- all

6 of next week I will be busy all mornings in sentencing hearing in Dragan

7 Nikolic, every day.

8 MS. KORNER: Your Honour, I didn't realise we were afternoons next

9 week.

10 JUDGE AGIUS: Yes, we are afternoons next week. And on Tuesday, I

11 have to finish at 5.00 because at 5.30 I have a medical appointment that

12 if I don't attend to now, it will be here in the Netherlands if you

13 cancel -- have one appointment cancelled, it's another two months. This

14 is already overdue. So I will have to leave here at 5.00 unless I manage

15 to postpone it. But so far, I haven't succeeded because it's in a

16 hospital. So they stick to a schedule normally.

17 That's about it. Otherwise I am at your convenience. Important

18 thing is to know that this witness is coming because if he doesn't turn

19 up, then we have problems.

20 MR. CUNNINGHAM: And I'll verify that during the break as well,

21 Your Honours.

22 JUDGE AGIUS: All right. Thanks.

23 MS. KORNER: Your Honour, can we ask whether the Court schedule

24 could be updated because according to the schedule we've got, it says

25 afternoon on Monday, and then mornings for Tuesday to Friday.

Page 21841

1 I wonder if we could have a schedule for the rest of November,

2 whether we're mornings and afternoons.

3 THE REGISTRAR: Normally it's posted on Tribunet, but this

4 afternoon we will send out the updated court calendar.

5 JUDGE AGIUS: Okay. All I know is that when we fixed the Nikolic

6 sentencing hearing, we checked at the time, Judge Schomburg and myself, to

7 ensure that both cases could proceed without any hitches. And it was in

8 the afternoon.

9 THE REGISTRAR: The reason we moved to the morning, because CMSS

10 thought Judge Agius would always like to sit in the morning. So once we

11 identify the chance, we put it --

12 JUDGE AGIUS: All right. But the Nikolic has already been fixed

13 for all mornings, and we will take the entire week for sure because we've

14 got several witnesses. So --

15 MS. KORNER: I don't think all the responsibility, if I can put it

16 that way, should be on you. I think we would all prefer to sit in the

17 mornings rather than the afternoons.

18 JUDGE AGIUS: Yes. And I do try to make sure that when that is

19 possible, we sit in the morning.

20 MS. KORNER: Yes, absolutely.

21 JUDGE AGIUS: But sometimes it's just not possible.

22 MS. KORNER: Your Honour, perhaps there will an updated schedule

23 later today so we can see where we are.

24 JUDGE AGIUS: Yes, Ms. Korner. Please, Madam Chuqing.

25 Good morning to you, sir. Welcome back. This should be your last

Page 21842

1 day in this Tribunal. And I remind you once more that you are testifying

2 under oath on the basis of the solemn declaration that you entered earlier

3 on in the week. Madam Korner will be proceeding with her

4 cross-examination, and then we'll see whether there is a re-examination,

5 and then we can call it a day.

6 Ms. Korner.

7 MS. KORNER: We have a blank screen at the moment, Your Honour.

8 JUDGE AGIUS: Yes, you're not the only one.

9 MS. KORNER: Perhaps while it's coming back on, I hope. Your

10 Honour, what I want to get back over is, we checked the audio tape. I

11 simply want to go back over that slightly disputed passage. So-- because

12 there's obviously-- it was concerning to us that there might be further

13 errors.

14 JUDGE AGIUS: Whether he spoke with Predrag Radic or whether--

15 MS. KORNER: Exactly, and I think we've solved how this happened

16 but the answer would be if Mr. Blagojevic would be good enough to read out

17 that one answer that he gave which begins in English "I found out about it

18 at the end of August" and then I'd like a translation, please, by the

19 interpreters of what he says.

20 MR. CUNNINGHAM: And could I have a page number that he's

21 reading --

22 MS. KORNER: It's the top of page 5 English. It's that one

23 answer.

24 If you could read it out, please, Mr. Blagojevic.


Page 21843












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Page 21844

1 [Witness answered through interpreter]

2 Cross-examined by Ms. Korner: [Continued]

3 A. It says here, I learned this at the end of August. I bumped into

4 the then chef du cabinet of the president of the municipality, Mr. Radic.

5 Mr. Jazic was the chef du cabinet of the president of the municipality,

6 Mr. Radic..

7 Q. That's your added explanation. Can you just literally and slowly,

8 please, Mr. Blagojevic, read just what your answer was that was recorded,

9 very slowly.

10 A. Shall I read it again?

11 Q. Yes, slowly, please. The exact words that are down there.

12 A. "I learned this at the end of August when I happened to meet at

13 the entrance into the municipal building of Banja Luka the then chef du

14 cabinet, I believe, of the president of the municipality, President Radic.

15 That means the chef du cabinet of the president of the municipality.

16 Q. Yes.

17 MS. KORNER: Your Honour, it's the word -- I think what caused the

18 confusion --

19 JUDGE AGIUS: It's all right, Ms. Korner.

20 MS. KORNER: Your Honour, I appreciate that, but obviously I don't

21 want Your Honours or the Defence to be concerned that we made an error.

22 It's the word "I believe" or "I mean." And it starts when he used the

23 word "I believe," which can also I think "I mean," it was translated as he

24 meant -- he meant Radic, and that's where the problem arose.

25 JUDGE AGIUS: All right.

Page 21845

1 MS. KORNER: I checked with the interpreters.

2 Q. Thank you very much, Mr. Blagojevic. All right.

3 Now, Mr. Blagojevic, I want to ask you a little bit about

4 correspondence. As secretary to the assembly of the autonomous region,

5 would you receive official correspondence that came to the assembly?

6 A. Yes.

7 Q. And would you deal with that correspondence?

8 A. If something was topical, yes.

9 Q. And if it was something that was important, would you consult with

10 Mr. Kupresanin about whether a reply should be sent or whether it should

11 be raised in a meeting?

12 A. Yes.

13 Q. And was it the same when you were secretary to the crisis staff of

14 the region? Would you deal with correspondence that came in to the crisis

15 staff?

16 A. No. It did not arrive at the crisis staff.

17 Q. I'm sorry. You mean there was never -- there was never a letter

18 addressed to the crisis staff?

19 A. I can't remember. Really, I can't.

20 Q. It's not a difficult question, Mr. Blagojevic. Are you saying

21 that in -- between May and the beginning of August, not one letter came in

22 to the crisis staff?

23 A. I can't remember. It is possible, but I really can't remember.

24 It was 12 and a half years ago. I'm not saying that it didn't arrive.

25 Q. I'm sorry. Are you telling this Court that you can remember

Page 21846

1 clearly dealing with correspondence that came in to the assembly which was

2 prior to the crisis staff, but you can't remember about the crisis staff?

3 A. The assembly was organised in an entirely different manner. The

4 work of the crisis staff was an improvisation.

5 Q. It may have been an improvisation, but I'm asking you whether or

6 not if correspondence came into the crisis staff, you dealt with it?

7 A. No, even if things did arrive, I would forward them immediately to

8 the president.

9 Q. To Mr. Brdjanin?

10 A. Yes, or when there was a meeting, I would present that at the

11 meeting. I would take it to the meetings, and that is the only thing I

12 can remember.

13 Q. All right. So -- all right. So you would open official mail. If

14 it was important, you would take it to a meeting, or else you would give

15 it to Mr. Brdjanin?

16 A. Probably.

17 Q. All right. Now, I want to deal a little bit more, please, with

18 the powers of the assembly.

19 MS. KORNER: Could you be shown now Exhibit P116, the authority.

20 Q. Now, this is a document from the Executive Board of the SDS dated

21 the 24th of February. And it's a decision appointing Mr. Vukic, the

22 in-charge coordinator for the Serbian autonomous district Krajina. It

23 sets out his duties, to coordinate and take responsibility for the

24 activities of the municipal boards of the SDS in cooperation with the

25 presidents of the assembly and the SAO Krajina government to ensure the

Page 21847

1 implementation of decisions, conclusions, and attitudes of the assembly of

2 the Serbian People of BH, and to take part in the work of the SAO Krajina

3 Crisis Staff.

4 And it says: "The decision shall enter into force on the day of

5 its adoption." It's signed by Mr. Djukic, and it's copied to the

6 municipal boards of the SDS of the SJ SAO Krajina, the president of the

7 assembly of the Serbian People of BH and the SAO Krajina government. As

8 secretary to the Krajina government or the assembly, did you see this

9 document?

10 A. I can't remember. But it is possible. I really can't remember

11 whether I saw this.

12 Q. I mean, it's an official document, isn't it? Stamped?

13 A. Yes, yes.

14 Q. All the rest of it.

15 Well, the first question is: Do you accept that this effectively

16 makes Dr. Vukic the -- it's described as coordinator, but the head of a

17 regional SDS board?

18 A. Yes.

19 Q. You see, you told us in interview, Mr. Blagojevic, page - I think

20 we've got it up on the screen - page 15, and you'll see in front of you on

21 a screen, Mr. Blagojevic, I hope -- you have to press the button.

22 Do you see an answer? You were being asked questions about people

23 who attended the regional crisis staff. And you were asked about Erceg.

24 Can you see that? I know it's not very easy to read, at line 9. And then

25 you said you didn't know how many times, maybe a few times, Predrag Radic

Page 21848

1 attended maybe once or twice, because he didn't recognise this, and so on

2 and so forth. And then you deal with Vukic.

3 "He was president of the party, and he was dealing with that. If

4 there were other meetings, those were party meetings. He was saying

5 sometimes that he was the president of the municipal board, and then the

6 regional board, which regional board was never established. It never

7 existed."

8 A. I didn't understand. Which regional board?

9 Q. The SDS regional board. That's what you were talking about,

10 wasn't it?

11 A. Yes. People disputed his appointment as the president of the

12 regional board. They were saying that he was never elected at any of the

13 sessions to become the president of the regional board. And people were

14 saying that he was a self-appointed president of the regional board.

15 Q. Yes, but you knew better, didn't you, because you'd seen this

16 decision appointing him?

17 A. Here it says he is charged as a coordinator. He was a member of

18 the regional board of the SDS, and it says here he is here put in the

19 position to be in charge of coordinating the work of the SAO Krajina.

20 Q. All right. So you agree that there was a regional board of the

21 SDS?

22 A. Yes, probably. Probably.

23 Q. I'm sorry, Mr. Blagojevic. You were in Banja Luka. Not

24 "probably." Was there or wasn't there to your knowledge a regional board

25 of the SDS?

Page 21849












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Page 21850

1 A. I did not attend those sessions. I don't know how it functioned.

2 I don't know how it operated.

3 Q. You may not have attended the sessions. Were you aware of press

4 conferences being given on a regular basis by Dr. Vukic as the president

5 of the SDS regional board?

6 A. Yes, yes, yes.

7 JUDGE AGIUS: So you knew that the regional board existed. So why

8 all this going around in circles and circles? Sometimes I start thinking

9 this man in front of me, his memory is not his strong point. But I don't

10 think that is the problem. I think your memory is all right.

11 Yes, Ms. Korner.


13 Q. Now, going back to that decision, what it says in the clearest

14 possible terms is that he is to take part in the work of what is described

15 as the SAO Krajina Crisis Staff. So in February of 1992, Mr. Blagojevic,

16 you were aware, were you not, that it was intended that there should be a

17 regional crisis staff?

18 A. In February, no.

19 Q. When this document is dated.

20 A. Yes, but I didn't know then about it's existence. There were no

21 previous arrangements, nothing pointed to the fact that this might exist.

22 Q. Well, the reason I'm pointing this out to you, Mr. Blagojevic, is

23 because the tenor of your evidence has been throughout that the regional

24 crisis staff was an illegal body. That's what you're trying to tell this

25 Court, isn't it?

Page 21851

1 A. I'm saying that it was not founded on any of the decisions of the

2 government.

3 Q. Well, the SDS, to all intents and purposes, was the government of

4 the Republika Srpska, wasn't it?

5 A. There was an institution called government headed by the prime

6 minister and other ministers.

7 Q. Was Mr. Dzeric a member of the SDS?

8 A. I don't know. I really don't know.

9 Q. Was Mr. Karadzic a member of the SDS?

10 A. Yes, yes.

11 Q. Was Mr. Krajisnik a member of the SDS?

12 A. Yes.

13 Q. Was Mrs. Plavsic at that time a member of the SDS?

14 A. Yes. Yes.

15 Q. All right. Let's move on, then, please. Could you now have a

16 look at P120, which is the next meeting of the assembly after the one we

17 looked at yesterday of the 29th of February. And could you look, please,

18 at the last page, just so we can see it. Again, this is one of the

19 documents, Mr. Blagojevic, you gave to Mr. MacIntosh. Do you remember

20 that?

21 A. Yes.

22 Q. And again, it's -- were these minutes drafted by you?

23 A. Yes.

24 Q. And we can see that in effect, it's a meeting that brought into

25 being the decision that had been made on the 29th of February to become

Page 21852

1 part of the Serbian Republic in Bosnia. And we see there that the

2 assembly is passing various decisions, putting the constitution and laws

3 into effect, and then the election of the president of the executive

4 council of the autonomous region.

5 Now, the candidates were Erceg, Mr. Beslac, and Brdjanin.

6 A. Yes.

7 Q. And is this right that the previous president had been

8 Mr. Grahovac?

9 A. That's correct.

10 Q. Who had been dismissed?

11 A. Yes.

12 Q. Mr. Brdjanin stood for election as president of the executive

13 council although he was already vice-president of the assembly. Do you

14 know --

15 A. Yes.

16 Q. Do you know why he did that?

17 A. Well, he was put forward by the representatives of the

18 Municipality of Celinac.

19 Q. You remember that?

20 A. Yes.

21 Q. And as it turned out, it was decided to exclude him for the very

22 reason that he was already the first vice-president of the assembly. And

23 then various decisions were taken. And would you agree, these were all

24 important decisions?

25 A. Well, yes.

Page 21853

1 Q. The decision to form a Security Services Centre, that's the CSB.

2 The decision to form -- I'm sorry, which affected the security. It had to

3 do with the security of the region. Is that right?

4 A. Yes.

5 Q. The decision to form the petrol, Krajina-petrol. That effected

6 the economy, of course. Is that right?

7 A. That was just a renaming of one company. It got a new name

8 actually. This name, Krajina-petrol. It used to be called by a different

9 name. So when I spoke about the decision with respect to the process

10 ongoing in the company, then the proposal made was that it should be

11 called Krajina-petrol.

12 Q. Did you say you spoke about it?

13 A. About what?

14 Q. I'm sorry. Are you saying you spoke in the assembly, or that's

15 what you told us before?

16 A. No, before. Yesterday, I think I said that.

17 Q. Okay. All right. And then a decision to appoint Mr. Kondic, the

18 director general of the payment transactions and financial supervision

19 service of the Autonomous Region of Krajina. So that was to do with the

20 financing, wasn't it, of the autonomous region?

21 A. Yes.

22 Q. And I missed, but there was a discussion of the election and

23 appointment of a secretary. And it was pointed out -- to the CSB, and it

24 was pointed out that that proposal would be made by Mr. Mandic. All

25 right.

Page 21854

1 Now, finally on this topic, could you look, please, at P153.

2 This is a document dated the 16th of April 1992. And it's got a

3 stamp, is that right, on the top showing that it was received -- of the

4 assembly of the autonomous region.

5 A. Yes. And it says it was received by Mr. Vojislav Kupresanin.

6 Q. Would that be a document that you, as secretary, would have opened

7 and given to Mr. Kupresanin?

8 A. No. We can see that this was addressed to him because it says

9 "Vojo Kupresanin" at the top there.

10 Q. Forgive me. I'm not sure -- where do you see that?

11 A. Up here.

12 Q. But that's a statement. The document's not actually addressed to

13 him, is it? It's addressed to the governments of the AR, Autonomous

14 Region of Krajina, and the Serbian Republic of Bosnia and Herzegovina, to

15 all Serbian municipalities. It's not actually personally addressed to

16 him, is it?

17 A. Yes, but I can see his signature here. He was the one who

18 actually received the document and signed for it. I can see the signature

19 up here.

20 Q. All right. Would you have seen it?

21 A. Yes.

22 Q. In fact, if you look at the -- there's a stamp at the end of the

23 document. Doesn't that show it was received by somebody called

24 Mr. Batinar [phoen]?

25 A. Yes, for Banja Luka, for Banja Luka. The man didn't work in the

Page 21855












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Page 21856

1 region. So probably this was an employee of the municipal assembly.

2 Q. All right. Anyhow, it's a document relating to the Territorial

3 Defence, or a decision of the Serbian Republic being established, and it

4 also says: "A state of an imminent threat of war is hereby declared.

5 There is to be general public mobilisation..." And so on. And then

6 there's an explanation which says, under one: The established TO staffs

7 of newly established municipalities set up district staffs in districts.

8 This matter is hereby placed under the jurisdiction of the government of

9 the SAOs." And so on and so forth.

10 So in other words, an important matter relating to defence was

11 being placed under the jurisdiction of the governments, including the

12 Autonomous Region of the Krajina. Is that correct?

13 A. That's how it should be, yes.

14 Q. Can I get back to where we started yesterday. There is no

15 question, is there, Mr. Blagojevic, but that these regional governments

16 were important, functioning parts of the Serbian authorities?

17 A. Yes. In view of their authorisations at all events, yes.

18 Q. But as a matter of practical reality, these governments, these

19 regional governments, whatever happened later, were important for the

20 functioning of the Serbian Republic.

21 A. Well, probably. Yes, probably.

22 JUDGE AGIUS: Ms. Korner, this document is dated 16th of April.

23 Could you rephrase the question putting it in that time frame. Because

24 16th of April of 1992 is quite significant. I mean, what was the

25 situation in Bosnia at the time?

Page 21857

1 MS. KORNER: Your Honour, that's the point I'm now making.

2 JUDGE AGIUS: I would imagine so. I mean, that's why I'm asking

3 you to go straight to it.

4 MS. KORNER: Yes.

5 Q. It was at this stage, wasn't it, that preparations were being

6 made - and I don't want to go into who started it or who did what - but

7 preparations were being made for what was clearly an armed conflict or

8 going to be an armed conflict?

9 A. Well, probably.

10 Q. Mr. Blagojevic, let's not have probably. There you are sitting as

11 the secretary of the Krajina assembly on the 16th of April. To your

12 knowledge, was there about to be a conflict?

13 A. Well, I really don't know if there was about to be a conflict.

14 JUDGE AGIUS: When did the war start? When did the war start?

15 Not the Croatian one.

16 THE WITNESS: [Interpretation] You mean when it started exactly,

17 Your Honour?

18 JUDGE AGIUS: When did it start exactly?

19 THE WITNESS: [Interpretation] Mr. President, exactly. Well, I

20 think already in the month of April some conflict started. I think in the

21 Brod Municipality, in actual fact, towards the end of March and the

22 beginning of April.

23 JUDGE AGIUS: You are right. So when on the 16th of April of 1992

24 the Serbian government decides to entrust the regional SAOs with matters

25 of defence, how do you understand that? That the central government

Page 21858

1 itself was transferring to a large extent matters of defence to the

2 regions? Is that how you would read it?

3 THE WITNESS: [Interpretation] Mr. President, at the time, the war

4 on defence was in force giving certain authorisations to the secretariats.

5 And probably, the minister referred to that because I can see that he

6 refers to it on the basis of Article 68 and Article 81 of the constitution

7 of Serbia.


9 Q. Mr. Blagojevic, really, I would like to move along. So if you

10 could just try and concentrate on the question and answer.

11 On the 6th of April, you do remember that the independence of

12 Bosnia had been recognised apparently by the European Community?

13 A. Yes.

14 Q. And it was absolutely clear to you, wasn't it, Mr. Blagojevic,

15 that no way was the Serbian government, so-called, going to accept this?

16 A. Yes.

17 Q. And so for the first time, the Serbian government was using these

18 regional authorities which had been established by them. Is that right?

19 A. Yes.

20 Q. All right. And they were saying here a state -- or Mr. Subotic,

21 the defence minister for the Serbian government was saying a state of

22 threat of imminent war is hereby declared. Is that right?

23 A. Yes.

24 Q. And that was the reason for the formal declaration, wasn't it, of

25 crisis staffs?

Page 21859

1 A. Well, here they -- actually, he just refers to the secretariats

2 which had their support in the constitution and the law on national

3 defence.

4 Q. No, in general terms, and we're going to move on to Mr. Dzeric's

5 instructions in a moment that you looked at. But in general terms, the

6 reason for crisis staffs under the old Bosnian law was if the assembly was

7 unable to meet owing to an emergency or an actual war or a threat of war.

8 That's right, isn't it?

9 A. Yes, pursuant to the constitution, that is right.

10 Q. That is why the crisis staffs in the municipality came into

11 existence, and that is why the regional assembly formed a crisis staff.

12 Isn't that right, Mr. Blagojevic?

13 A. May I just say with respect to your latter question, if the

14 assembly cannot meet, then what were these organs supposed to be called?

15 I just can't remember. I don't think they were called crisis staffs. I

16 think this organ had a different name for a state of imminent war or

17 threat of war. I think it was called differently, if they were unable to

18 meet and convene a session.

19 Q. Well, I'm going to suggest to you they were actually called war

20 presidencies or something like that, but the effect was the same, isn't

21 it? It was a body derived from the assemblies together with the leaders

22 of the police and so on and so forth.

23 A. Yes, that's how it should have been, yes.

24 Q. All right. Now, can we look, please, again at the document that

25 you looked at with Mr. Cunningham which is P157. Mr. Dzeric's document;

Page 21860

1 excerpts, rather.

2 And what you had to say about this when you were shown it, and

3 this is the LiveNote for the 29th. The question was put to you by

4 Mr. Cunningham, and it's page 54 of that LiveNote: "Does this document

5 ever mention to the best of your knowledge regional crisis staffs?" And

6 you said: "As far as I can see in this document, no." Question: "When

7 you were working for the ARK, when you found out about this document, when

8 you read it, what effect, if any, did it have on you?" "None whatsoever."

9 Can we take it from that that you saw this document when it was

10 issued on the 26th of April, or shortly after?

11 A. After that. After that.

12 Q. Yeah. And how did you see it? Who gave it to you?

13 A. I saw it when it was published in the Official Gazette of the

14 Serbian Republic because it was published in the Official Gazette fairly

15 speedily.

16 Q. All right. And that's the direction to the municipalities as to

17 how they should work. Is that right?

18 A. Yes.

19 Q. But one of the things it had to do, if you look at item number 14:

20 "The Crisis Staff shall convene and make decisions in the presence of all

21 its members, take official minutes, issue written decisions, and submit

22 weekly reports to the regional and State organisations..."

23 Now, what was the regional organisation in the Krajina?

24 A. The regional institutions, you mean, at the time. Well, all the

25 institutions were established at the 4th of March assembly in 1992, those.

Page 21861












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Page 21862

1 Q. What was the regional institution to which weekly reports would

2 have to be submitted, the regional institution which was part of the

3 government structure?

4 A. Well, it says here that the crisis staffs of the municipal bodies

5 should send to the regional bodies their reports, or rather their minutes.

6 Q. I'm going to ask you one last time, Mr. Blagojevic: What was the

7 regional organisation that formed part of the government of the Serbian

8 Republic?

9 A. The executive council, the executive council of the region.

10 Q. Of -- the executive council of what body?

11 A. Well, probably the regional secretariat for national defence.

12 Q. This is not talking about national defence --

13 A. And --

14 Q. -- Is it? It is talking about all the duties that the crisis

15 staff has to carry out.

16 A. This set of instructions, you mean? Yes, yes.

17 Q. Mr. Blagojevic, are you deliberately trying to avoid giving the

18 answer that you know to be the truth?

19 MR. CUNNINGHAM: I'm going to object to the form of the question

20 as being argumentative, Your Honour.

21 JUDGE AGIUS: Rephrase the question, Ms. Korner.

22 MS. KORNER: With respect, I don't think that is a proper

23 objection. I'm asking him whether he is intentionally trying to avoid it.

24 It's not a comment.

25 JUDGE AGIUS: Yes, restrict it to that, please.

Page 21863


2 Q. Are you intentionally trying to avoid saying that it was the

3 assembly of the autonomous region or whatever body represented it?

4 A. No. I really don't know whom they sent this off to. I know that

5 the assembly of the region, but I don't remember that a single crisis

6 staff ever submitted a report.

7 Q. That was the reason, wasn't it, why the presidents of the crisis

8 staffs of the municipality were attending the meetings of the regional

9 crisis staff, to give a report on what was happening on their area?

10 A. Well, I said yesterday what that grew into. First of all, what

11 happened was that the composition of the body was highly diverse. And we

12 saw the composition and the members that made it up pursuant to the

13 decision, and then the deputies, presidents of municipal boards,

14 municipalities came in, that kind of thing.

15 Q. The question I asked, Mr. Blagojevic, was: Isn't that why the

16 presidents of the municipalities were attending on a weekly basis when

17 possible meetings of the Crisis Staff of the region?

18 A. Well, they would come and present the problems of their

19 municipalities.

20 Q. I'm asking you this question: Is it not because of this

21 instruction from Mr. Dzeric that the municipalities were coming to

22 submit -- well, actually, I'll take that back. I don't think --

23 JUDGE AGIUS: I think you can stop here, and the Trial Chamber

24 will draw its own conclusions, Ms. Korner.

25 MS. KORNER: And in any event, Your Honour, I don't think the

Page 21864

1 question I was about to ask is one he can properly answer. All right.

2 Q. Now, I want to deal with a different topic, and that is the topic

3 of the arrival of the SOS in Banja Luka.

4 JUDGE AGIUS: Let's see if he remembers about them, first.


6 Q. Do you remember the arrival of the SOS in Banja Luka?

7 JUDGE AGIUS: Probably he's not.

8 Do you remember the SOS?

9 THE WITNESS: [Interpretation] Why not, Mr. President? I said that

10 one morning when I was on my way to work, at a certain point a group of

11 people stood in front of me and didn't allow me to pass by and sent me

12 back. And I didn't know who these people were or what they represented.

13 So I wasn't allowed to go to work. They sent me back.


15 THE WITNESS: [Interpretation] And that's all I know about them.

16 At the time, that's all I knew about them.


18 Q. Do you remember barricades being set up by these men?

19 A. Yes, yes. And on my way to work, I came upon one of these

20 barricades. That was precisely it.

21 Q. And you were on your way to work to the municipal building?

22 A. Yes, that's right.

23 Q. And these people had surrounded the municipal building, hadn't

24 they?

25 A. Yes.

Page 21865

1 Q. And they were armed?

2 A. Well, some of them did have arms. Others didn't. The composition

3 was different. But you could put it that way. They did have weapons,

4 yes. I saw some people wearing camouflage uniforms without weapons

5 whereas others did have weapons.

6 So Mr. President, may we go into private session, please, for this

7 part.

8 Q. Well, it's a matter for Your Honours. I'm not sure what the

9 problem is.

10 JUDGE AGIUS: Let's go for a while into private session first.

11 And you tell me why.

12 [Private session]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

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21 [redacted]

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24 [redacted]

25 [redacted]

Page 21866












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Page 21876

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8 [redacted]

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10 [redacted]

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12 [redacted]

13 [redacted]

14 [redacted]

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

16 --- On resuming at 10.58 a.m.

17 [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [Open session]

23 JUDGE AGIUS: The moment you want to go to private session, you

24 just ask me. And we will accede to your request if it's the case. I see

25 you perplexed. Maybe it's a question of interpretation. I say any

Page 21877

1 time -- we are back in open session now. And any time you want us to go

2 back to private session, let me know. All right?

3 Yes, Ms. Korner.

4 MS. KORNER: Thank you, Your Honour.

5 Q. Mr. Blagojevic, I want to now talk -- ask you some questions about

6 the crisis staff. Could you have back, please, Exhibit P168. You were

7 asked about that yesterday, and it was put to you that all these people

8 came from Banja Luka. I want to explore that a little further, please.

9 Brdjanin, the president of the crisis staff, was the

10 representative from Celinac to the Assembly of the Serbian People. Is

11 that right?

12 A. Yes.

13 Q. The vice-president of the Assembly of the Autonomous Region.

14 A. He was from Srbac. He lived in Banja Luka.

15 Q. I'm sorry. Because I don't want to keep you here too long. I'm

16 not interested in where they lived. I'm trying to establish what the

17 positions of these people were. Do you understand? All right. Mr.

18 Brdjanin was also the -- for some period of time the president of the

19 executive council in Celinac.

20 A. Yes.

21 Q. He was a member of the Crisis Staff of Celinac?

22 A. Well, probably, by virtue of office.

23 Q. Lieutenant-Colonel Sajic, he was the person in charge of the

24 National Defence Council, is that right, in the autonomous region?

25 A. Yes, he was the secretary for National Defence, I believe, for the

Page 21878

1 Banja Luka Municipality.

2 Q. Kupresanin, I'll come back to him. He was also a deputy to the

3 Assembly of the Serbian People, wasn't he?

4 A. Yes, yes.

5 Q. And he was, as we know, president of the assembly?

6 A. Yes.

7 Q. Mr. Erceg was the president of the executive council to the

8 assembly?

9 A. Yes, the executive council, yes.

10 Q. Mr. Radic was the president of the municipal assembly?

11 A. Yes.

12 Q. Dr. Vukic, as we've seen, was the head of the regional board or

13 the coordinator of the SDS?

14 A. Yes.

15 Q. Dr. Milanovic, who was he? I think you did tell us in interview,

16 but I now can't remember.

17 A. He was a national deputy, and he became vice-president of the

18 National Assembly of Republika Srpska later on.

19 Q. General Momir Talic was the head of the 5th Krajina Corps based in

20 Banja Luka?

21 A. Yes.

22 Q. Do you agree that it was the biggest corps in the whole of

23 originally the JNA and then later the VRS?

24 A. Yes.

25 Q. Major Jokic, was he the air force?

Page 21879

1 A. I really don't know what his role, or rather function was. What

2 position he occupied. I don't know what his profession was either.

3 Q. Stojan Zupljanin, chief of the CSB?

4 A. Yes, he was chief of the CSB.

5 Q. And clearly, that was a vital position in Banja Luka, wasn't it,

6 the head of the regional police force?

7 A. Yes.

8 Q. Dr. Kuzmanovic who was later replaced. He was the director of the

9 university?

10 A. Yes.

11 Q. Mr. Puvacic was the public prosecutor?

12 A. Yes.

13 Q. Jovo Rosic was the judge in charge of the Banja Luka court?

14 A. Yes.

15 Q. And then we come to Dubocanin and Stevandic. Who was

16 Mr. Dubocanin?

17 A. In view of the functions we mentioned earlier on, I'm really not

18 clear of their position here.

19 MS. KORNER: Can we go into private session, Your Honour.

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

21 [Private session]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 21880

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2 [redacted]

3 [redacted]

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15 [redacted]

16 [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [Open session]


23 Q. So, Mr. Blagojevic, it's right, isn't it, that the regional crisis

24 staff was supposed of the most powerful men in the region in each of their

25 respective spheres?

Page 21881

1 MR. CUNNINGHAM: I'm going to object to that question because how

2 can he differentiate between the 17 members in saying whether A is the

3 top. I just think it calls for him to make a conclusion across the board

4 as to whether they're at the top of the region in their respective sphere.

5 JUDGE AGIUS: I don't agree with you, Mr. Cunningham. I mean, the

6 question is a very clear-cut and important one, too, whether this regional

7 crisis staff actually was composed as to the first 15 members of the most

8 important people in the region. So the witness should look at those 15

9 names. And if he disagrees, for example, if he thinks that Dr. Kuzmanovic

10 was not a powerful personality or person in the region, even though he was

11 replaced, he can say so. But then I would expect him to answer with

12 regard to the rest. So proceed.

13 I think, please --

14 MS. KORNER: I'll split this. I'll split this, Your Honour.

15 Q. General Talic was the head of the army for the whole region?

16 A. Yes.

17 Q. Mr. Zupljanin was head of the police for the whole region?

18 A. Yes.

19 Q. The two leading politicians in the assembly were members of this

20 crisis staff?

21 A. Yes.

22 Q. This crisis staff, therefore, had real authority, didn't it,

23 Mr. Blagojevic?

24 A. Well, by virtue of the office these people held, that would be the

25 conclusion.

Page 21882

1 Q. All right. Thank you.

2 Now, I want to go back over this question of why Brdjanin and not

3 Kupresanin became the head of this crisis staff. You've told us that --

4 you told us on Wednesday -- on the 29th that it was a matter of discussion

5 at one of the sessions of the crisis staff when the deputies asked why

6 Mr. Kupresanin as president of the assembly was not the ex officio

7 president of the crisis staff. At what session of the crisis staff did

8 this come up?

9 A. At one of the meetings when the presidents of the municipalities

10 and boards and the deputies came to attend. So they raised that question,

11 the reason why Mr. Brdjanin was the presiding person and not

12 Mr. Kupresanin.

13 Q. And you then said that Mr. Kupresanin gave an explanation to this

14 effect, and you remember this clearly apparently, and this is at page 65

15 of the LiveNote: "Why should I assume responsibility, he said, for one

16 body if the government left it to municipalities to appoint and replace

17 directors of enterprises and all the other positions." Now, did he say

18 that to you in private or to the crisis staff?

19 A. Yes, he said it at the crisis staff meeting as well.

20 Q. And can you explain to us what you meant. Can you explain what he

21 meant by that?

22 A. Well, he told me -- he told me that in view of the fact of what

23 happened on the 29th of February, that is to say, the rift between the

24 region and the central headquarters, that this would give rise to even

25 greater problems, make them even more profound between the region and the

Page 21883

1 government on one side as it would between the municipalities and the

2 region on the other. So at the assembly of the autonomous region held on

3 the 29th of February, as I say, the delegates, or rather most of the

4 delegates, the presidents of the municipalities, gave absolute support to

5 the central powers.

6 Q. Precisely, except that we've just looked at a whole series of

7 documents which show, and which I thought you'd agree with,

8 Mr. Blagojevic, that the regional government was an essential part of the

9 operating of the whole of the Serbian government.

10 A. Well, yes, but there was a decision that was made, and he referred

11 to the decision about the organisation of companies. And pursuant to that

12 decision, the government nominated all the directors. And generally, all

13 the appointments at a political level, and nominations, and the Executive

14 Boards of the municipalities would appoint directors at a municipal level.

15 And one article of that decision stipulated that the appointed individuals

16 would be responsible to the organs appointing them. So he kept

17 underlining this fact and said "why should I be there when I have no

18 authorisations?" And also, one of the reasons that he quoted was his

19 health. He said his health was not good, and that he was getting ready to

20 undergo heart surgery, and I think that's what happened soon afterwards.

21 He was operated on, and I think he said that he no longer wanted to be

22 involved in the conflict between the representatives of the municipality

23 and himself because he was having a great deal of problems, as I said, for

24 his clearly-worded speeches and statements at the assembly meetings. He

25 was very sharp and came into conflict with both the army and the police.

Page 21884

1 Q. Can we take this, please, in stages. The appointment, or more

2 pertinently, the dismissal of persons from companies and the like was only

3 one part, was it not, of the function of the assemblies and then the

4 crisis staffs?

5 A. Well, the decision to form the war presidencies later on and the

6 organs in the municipalities, they were given full competencies.

7 Q. Yes, I'm sorry. That's not the question. The question was:

8 Appointment or dismissal of people from companies was only one part of the

9 functions of assemblies and crisis staff, wasn't it?

10 A. Among other things, yes. That, too.

11 Q. Now, was this the situation, that Mr. Brdjanin was a much stronger

12 personality than Mr. Kupresanin?

13 A. I don't think so, no. Mr. Kupresanin enjoyed far more respect.

14 Q. Well, that's a different matter. I'm talking about the

15 personality of the two men. Was Mr. Brdjanin a more forceful personality

16 than Mr. Kupresanin?

17 A. Well, I really couldn't say myself. It's difficult to assess

18 that.

19 Q. We've looked at some of the assembly minutes, and it's clear

20 that -- would you agree -- I'm sorry. Would you agree that Mr. Brdjanin

21 spoke apparently more often than Mr. Kupresanin?

22 A. Which assembly meeting?

23 Q. In the assembly of the autonomous region.

24 A. Well, Mr. Kupresanin was the presiding officer. And when he was

25 presiding over the meeting, he would conduct the meeting, in fact. So

Page 21885

1 there would be very little reason for him to actually take the floor. It

2 would be the delegates who would take the floor. That's the way the

3 assembly operated.

4 Q. I see. So it's because Mr. Kupresanin was in charge that he

5 didn't speak very often?

6 A. Yes.

7 Q. And you don't agree that Mr. Brdjanin had the more forceful

8 personality?

9 A. Well, I think that a true picture and appraisal was given by the

10 assembly meeting that we discussed yesterday, the one that was held -- or

11 rather, I think we mentioned it this morning where the executive council

12 of the region was elected, where Mr. Brdjanin was put forward for

13 president. And I don't think he received more than seven votes for being

14 a candidate at all.

15 Q. Did you ask Mr. Kupresanin at any stage why he didn't -- why he

16 wasn't on the crisis staff that was formed as a result of the SOS's

17 demands?

18 A. Well, he said that nobody called him to do that, or informed him

19 about anything. And yet, he was president of the assembly of the region.

20 Q. Now, can we move to the question of the recording of these crisis

21 staff meetings. You looked at the instructions that were handed out by

22 Mr. Dzeric a moment ago. And one of these -- those instructions was to

23 this effect, that official minutes of crisis staff meetings had to be

24 taken. Do you remember that?

25 A. Yes. But this related to the crisis staff of the municipalities,

Page 21886

1 and they did keep minutes.

2 Q. Whether or not it related to the crisis staff of the

3 municipalities, a crisis staff of the region was formed. Do you agree?

4 A. Yes.

5 Q. You had taken minutes of the meetings of the assembly?

6 A. Yes.

7 Q. The crisis staff was replacing the assembly of the region. Do you

8 agree with that?

9 A. Well, you could put it that way. In view of the later presence of

10 the deputies, the presidents of the municipalities, of the executive

11 boards and so on and so forth.

12 Q. We could put it any way we like, Mr. Blagojevic. How do you put

13 it? It replaced the assembly, didn't it?

14 A. One could say that.

15 Q. And you've told us that in your opinion, as a result of the

16 decisions taken by the government, the assembly of the autonomous region

17 was a lawful assembly. That's right?

18 A. The assembly of the autonomous region, you mean. Yes, that's

19 right. It was based on the constitution of the Serbian Republic of

20 Bosnia-Herzegovina.

21 Q. And it was absolutely clear to you, I suggest, from the documents

22 which we've looked at and which you saw that the crisis staff of the

23 region was equally, as far as the Serbian Republic was concerned, a lawful

24 organisation?

25 A. Well, nevertheless he had to derive his authorisations from

Page 21887

1 government decisions. And all the affairs that the government was engaged

2 in, it had to convey these competencies and authorities to the crisis

3 staff of the region which is something it did not do. So that none of the

4 members of the government ever asked reports from the crisis staff, nor

5 did they attend crisis staff meetings.

6 Q. Can we leave that aside for the moment. I want to concentrate on

7 the minutes, please. Can you explain to this Court why you did not take

8 any minutes as you say you did not?

9 A. Well, it was impossible, Madam Chairman, to keep the minutes.

10 Because the meetings were held every day, one day after another, for three

11 days continuously, for example. And now in the municipality of the

12 region, the assembly of the region, there was just one employee, myself.

13 I had one office, 3 metres by 2 metres. And the investigators saw the

14 size of that office when they were there. I had no administrative

15 apparatus. Whereas the Banja Luka Municipality had a staff of 600 working

16 in the administration, and the entire assembly of the region just had me,

17 one employee. And when a meeting of that type was held, you would have 30

18 to 35 participants taking place, you would have to organise everything

19 which means that I would need the technical equipment for recording the

20 meeting, I would need a shorthand typist, and I would need other

21 technicians and the necessary facilities.

22 That's one point. And secondly, the meetings would go on for four

23 or five hours, that means that we would need to type it out, prepare all

24 the documents, and I didn't have the service to back me up to do that. So

25 it was decided that as people took the floor, and there were no clear-cut

Page 21888

1 rules on procedure for the work, as you usually have in assembly work,

2 that presentations by members taking part in the discussion would be

3 limited to 5, 10, or 15 minutes, there were no rules governing the work of

4 these meetings. So I think somebody from the Serbian Municipality of

5 Drvar, for example, a very rich area, rich in forests, he would make a

6 40-minute speech about the war profiteering and how the forest was being

7 cut down.

8 And then he would end by saying that the municipality lacked

9 sugar, oil derivatives, flour, and things of that kind. There was a

10 shortage of medicines and nothing was actually functioning. So there were

11 no strict, clear-cut rules. So the agreement was reached that when

12 somebody would take the floor, their time wouldn't be limited. And at the

13 end of his discussion, he would propose conclusions. What he wanted to do

14 and what he thought should be done. And he would set this out in writing,

15 and that is what I would note down. I would note down the person's

16 conclusions. We would then hand that on to Mr. Brdjanin. And at the end,

17 Mr. Brdjanin would read through these proposals. So that's what it was

18 like.

19 Because it was absolutely impossible, not feasible, to have a

20 meeting lasting four, five or more hours and a session going on the next

21 day, to prepare all the minutes. You can't have good quality minutes

22 without stenographic notes. And people would complain if you did so and

23 say that's not what they said. So those were my problems. And as I had a

24 lot of experience in the field, we had to improvise to a great extent.

25 Q. All right.

Page 21889

1 A. So those -- and the investigators were able to make their own

2 minds up as to that because my office was the smallest office in the

3 Banja Luka Municipality building. It was a room 3 by 2 metres.

4 Q. What was the problem about setting up a recording device?

5 A. Well, we didn't have one. Quite simply, we didn't have one.

6 Q. In the whole of the Banja Luka Municipality, you had no recording

7 device?

8 A. We didn't -- we were just borrowing their premises, if I can put

9 it that way. They gave us two rooms to use. The president of the

10 executive board, for example, had absolute power over all the resources.

11 He wasn't a member of that particular body. He ignored the body and never

12 attended any meetings. Although he was president of the board, he never

13 attended any meetings of that particular body. So, of course, we weren't

14 lent support.

15 Q. I'm sorry. Who did you say never attended meetings of the body?

16 A. Mr. Kasagic. Mr. Kasagic. Their administrative department would

17 receive salaries, they had the necessary resources which were lacking in

18 this other places. So we didn't have the necessary facilities. I had

19 trouble coming by the paper we needed.

20 Q. Who told you that you need not take minutes?

21 A. Well, quite simply, it was impossible to take minutes.

22 Q. But it was your job to take minutes. Who told you need not take

23 minutes?

24 A. They all agreed that when somebody asked to take the floor, that

25 person would make a note of his conclusions and proposals because we

Page 21890

1 didn't have the necessary facilities to do things in the proper way and

2 record things in the proper way.

3 Q. When you say -- pause, Mr. Blagojevic.

4 Mr. Blagojevic, you say "they all agreed..." Who agreed?

5 A. All those who were present.

6 Q. But did you at some point, Mr. Blagojevic, as you must have, say

7 to Mr. Brdjanin, as president of the crisis staff, "Look, it is impossible

8 for me to take minutes"?

9 A. Well, not to him. I told everyone, all those present.

10 Q. But it was your responsibility to the president of the crisis

11 staff to take minutes, wasn't it?

12 A. He agreed with that method of work, the one we applied, because he

13 was fully conscious of the fact that we didn't have the necessary

14 facilities and conditions to work as we had been doing when the other

15 organs had the complete administrative in their hands.

16 Q. The discussions and the decisions being taken were important ones,

17 weren't they, Mr. Blagojevic?

18 A. Well, yes, they were. They were important. If you look at it

19 that way. However, now the final implementation of those decisions is

20 what we should take a look at.

21 Q. That's exactly what we are going to take a look at,

22 Mr. Blagojevic.

23 Didn't you think or anybody think that it would be important to

24 keep a record of these decisions being taken in a time of conflict?

25 A. Of course, of course. That was absolutely necessary, yes. But

Page 21891

1 quite simply, what I'm saying is this: There were no technical

2 possibilities of doing that. And as I said, the meetings were held one

3 after another for three days. And the discussions went on for four, five,

4 six or more hours in a single day. So this would take a stenographer two

5 or three days to get all that down in record form. And if he were to draw

6 up the minutes, you would have to do so over a period of several days.

7 Q. All right. And this is how you described in your interview the

8 method you say happened, that the decisions when they were made - this is

9 at page 21 for Mr. Cunningham - someone had to type them up, someone had

10 to approve them, someone signed them, and they were published.

11 I'm sorry, that was the question. "Explain the process of how it

12 went from the decision being made at a meeting to being in the Official

13 Gazette and published in Banja Luka." And you said: "Well, they would

14 dictate this to me. I would write it down. Then I would type it. If I

15 couldn't type it, then I would ask a woman who worked in a typist office

16 to help me, and then I would prepare it for publishing." Is that what you

17 say happened still?

18 A. Yes, yes. There was a decision, a decision which was taken on the

19 6th. Pursuant to this decision, the secretary of the Autonomous Region of

20 Krajina was authorised to prepare the Official Gazette for the publication

21 of the decisions of the assembly, the crisis staff, and the executive

22 council. I remembered only yesterday afternoon that item 2 gave the

23 authorisation to the person under item 1 to be allowed in case of the

24 absence of the members of the crisis staff to sign this decision. And

25 then I also remembered that when I was looking at the signatures

Page 21892

1 yesterday, I remember that I also had an authorisation pursuant to that,

2 and I also remember that what I saw yesterday was not a forgery, that

3 where it said "Boro Blagojevic," that indeed was my signature. For a

4 moment, I was afraid it was a forged signature.

5 Q. I'm going to come on to the question of signatures a little later.

6 I want to, please, just stick to the notes.

7 A. Very well, then.

8 Q. You went on to say this, that you drafted resumes - I'm now

9 looking at page 22 of the interview, Mr. Cunningham - and you were asked:

10 "Did you circulate them to the members who had taken part in the

11 discussions?" That's your resume of what had been said. And you said:

12 "No." And you were asked: Who were the persons who saw these resumes?"

13 And you said Brdjanin. And you said: "Brdjanin would read them to see if

14 he would agree with them."

15 A. Well, when a member put forward a conclusion, he was then asked to

16 put it in writing. This would then be submitted to Mr. Brdjanin for his

17 perusal. And then when Mr. Brdjanin read it and when this person

18 formulated this conclusion, I was also given the task to read it. In some

19 of the decisions, I saw quite a number of technical mistakes being made.

20 Q. And you also told us, and is this right, that Mr. Brdjanin would

21 make his own notes?

22 A. Yes, I believe that he made his own notes in order to be able to

23 draft his own conclusions. Because very often, it was him who proposed

24 conclusions.

25 Q. And there's no doubt about it. As you told us in interview,

Page 21893

1 Mr. Brdjanin was in control, in command of those meetings. Page 19.

2 That's right, isn't it?

3 A. Yes, it is.

4 Q. I want to ask you one last time, Mr. Blagojevic. Are you really

5 telling us that no minutes were recorded or kept by you of these important

6 meetings?

7 MR. CUNNINGHAM: I object, Your Honour. It has been asked and

8 answered. It has been discussed in detail.

9 MS. KORNER: I know, I'm giving him one last opportunity.

10 JUDGE AGIUS: Yes, answer the question.


12 Q. Are you really telling us that, Mr. Blagojevic, that the crisis

13 staff of the region was the only authority I suggest in the whole of

14 Bosnia that did not keep minutes of official meetings?

15 A. I'm sure of that. It was impossible for the various reasons that

16 I've mentioned. There was no technical possibility to do that.

17 Q. All right. And you didn't think it was advisable to keep your own

18 notes or resumes for the future?

19 A. No. I just simply didn't have the conditions in place. I did not

20 have anybody to whom I could delegate tasks. I had to perform all the

21 duties. I had to be a stenographer and everything else. So if you look

22 at the decisions in the Official Gazette, you will see a lot of technical

23 mistakes that were supposed to be corrected later on. But we didn't

24 because we just didn't have anybody to take care of that.

25 Q. Now, I want to move to the Official Gazettes. All decisions

Page 21894

1 passed by authorities, municipal or regional, had to be published in the

2 Gazette. Is that right?

3 A. No, no. Only the decisions passed by the regional crisis staff

4 and the regional executive council, or if a decision was taken by the

5 assembly of the region. Those were published.

6 Q. All right. And the reason for publication in the Gazettes is

7 what?

8 A. The reason would be the consequence of the session on the 29th of

9 February 1992.

10 Q. I'm sorry. Don't bother about that. Can you tell me just

11 generally --

12 A. Very well, then.

13 Q. -- why are regulations, decisions, and authorities published in

14 the Gazette -- a gazette?

15 A. The reason was the following: People said that this would prove

16 to the central government that we were not doing anything behind their

17 back.

18 Q. Stop, Mr. Blagojevic.

19 A. This is important.

20 Q. I'm asking generally why do the decisions made by the Serbian

21 Republic or by municipalities, why are they published in a gazette? I'm

22 asking for the general reason.

23 JUDGE AGIUS: As a lawyer, you should know as well.

24 THE WITNESS: [Interpretation] It is a well-known fact, to make the

25 general public aware of the decisions that were taken and how they are to

Page 21895

1 be applied.


3 Q. Right. Now, can you have a look, please, again at Exhibit P227.

4 You were the person, I think, Mr. Blagojevic, who gave these

5 Gazettes to the representatives of the Office of the Prosecutor. Do you

6 remember that in April, or possibly in August 1996?

7 A. Yes.

8 Q. What happened to issue 1?

9 This is the issue 2, the Official Gazette of the Autonomous Region

10 of Krajina. What happened to issue 1?

11 A. Lots of people have asked me that same question. I was going to

12 publish the statute of the region and all the other general enactments and

13 the decisions taken at the last session when the executive council and the

14 secretariat, secretariats were established. That was what I was going to

15 publish in issue number 1.

16 Q. Yeah, but do you mean it wasn't published?

17 A. No, it was not published.

18 Q. All right. I don't think I'll go down that road.

19 Anyhow, it's right that you're shown, Mr. Blagojevic, as the

20 editor of the Gazettes, if we look at the last page?

21 A. Yes. The assembly authorised me to prepare and to edit the

22 Official Gazette which would carry the decisions taken by the assembly, by

23 the executive council, and the crisis staff.

24 Q. Right. So it was your job to ensure that when they went into the

25 Gazette, they were accurate?

Page 21896

1 A. Yes. This should have been the case.

2 Q. All right. Can I just ask you, if we can just look, please, at -

3 and we'll need to have, I'm afraid, on the ELMO the actual B/C/S version -

4 the first decision dated the 4th of May.

5 After the words -- after the typed signature of

6 Lieutenant-Colonel Sajic, do some letters appear? It's a terribly bad --

7 A. It says the secretariat, the secretary of the Secretariat for

8 National Defence, the Autonomous Region of Krajina.

9 Q. No.

10 MS. KORNER: Usher, can you take that, and I want that last line.

11 It doesn't appear on that copy very clearly.

12 Q. Right. Do we see there the secretary of the Council for National

13 Defence, and then the name Lieutenant-Colonel Sajic?

14 A. Yes.

15 Q. What do the letters after his name stand for? Do you see those

16 two letters?

17 A. SR. That is, in his own hand, his own handwriting. But let me

18 tell you about this. This merits some attention. There were quite a

19 number of technical mistakes. For example, it says: "The responsible

20 people are presidents of the crisis staff of the municipalities." This is

21 a mistake. Above that, in the original document, it says that the

22 responsible persons are presidents of Council for National Defence. And

23 in the original document, you can see that. And I was the one who was

24 supposed to correct this mistake, but I didn't do it, if you look at the

25 original document by Mr. Sajic.

Page 21897

1 Q. Believe me, Mr. Blagojevic, I'm not interested in the moment in

2 technical mistakes in the rest of document. That means -- those initials

3 means that you confirmed that was signed by Lieutenant-Colonel Sajic in

4 his own hand?

5 A. Yes.

6 Q. Well, now, you see, let's look at one of, or some of the

7 signatures of Mr. Brdjanin, or some of the decisions signed by Mr.

8 Brdjanin. If we go, please, to the 6th of May decision, which was number

9 3, does that show Radoslav Brdjanin as the signatory with the same

10 letters, SR, confirming that he signed it in his own hand?

11 A. Yes, yes.

12 Q. Or obviously somebody on his behalf who had put "za" on the

13 original document?

14 A. Yes.

15 Q. And all the decisions that apparently were signed by Mr. Brdjanin,

16 when they go into the Gazette --

17 MR. CUNNINGHAM: I'm going to object, Your Honour, because based

18 on the testimony yesterday I believe there's two, maybe three documents

19 that he identified as being signed by Mr. Brdjanin. And I don't know of

20 anywhere in the record where there has been any proof that he signed the

21 other documents. Of course, I wasn't here for that part of the trial, and

22 I will certainly trust your memory over my recollection of the record.

23 JUDGE AGIUS: Mr. Cunningham, the position is this: I think you

24 ought to distinguish between what the witness recognised as certainly

25 being Mr. Brdjanin's signature and the rest. But he did not exclude any

Page 21898

1 of them.

2 MS. KORNER: I think the point is being missed slightly by

3 Mr. Cunningham. That's not the exercise I'm undertaking now. I know what

4 was said.

5 MR. CUNNINGHAM: I understand the exercise you're taking with

6 these two notations, the two letters after the signature. I understand

7 that completely. I just wanted to lodge an objection -- and I think the

8 Court recognises what I'm trying to do, and I understand Court's position

9 as well. I just didn't want -- and I apologise for interrupting. I did

10 not want it to be taken as some sort of concession that we're agreeing

11 that he signed these other documents.

12 JUDGE AGIUS: From that point of view, yes, point taken and

13 conceded. But it doesn't mean to not amount to an obstacle to Ms. Korner,

14 for Ms. Korner to proceed with her questions.

15 MR. CUNNINGHAM: I understand.

16 JUDGE AGIUS: Okay, let's go ahead, then.


18 Q. Each and every one of the documents that bear Mr. Brdjanin's

19 signature that we have copies of are in these Gazette with those letters

20 after that, aren't they, Mr. Blagojevic?

21 A. Yes, yes.

22 Q. Would you have put those into the Gazette if you hadn't been

23 satisfied that Mr. Brdjanin had signed those decisions?

24 A. There were some decisions which were not signed by him. Still,

25 they were published. If I was about to publish my issue of the Gazette

Page 21899

1 and if the minutes were not ready yet, I would still put those decisions

2 in the Gazette even if they were not typed because there was no time

3 between the session and the dates of the publication.

4 JUDGE AGIUS: I don't think -- you either did not understand the

5 question or you avoided, tried to do your best to avoid answering it.

6 That's not the answer that's expected of you.

7 I'll read the question that Ms. Korner put to you again. First it

8 was put to you that throughout this Gazette, each and every one of the

9 documents that bear Mr. Brdjanin's signature, they also show -- carry also

10 the two letters. And you are being asked: Would you have put those into

11 the Gazette - that is, the CP, the confirmation that this is signed by Mr.

12 Brdjanin with his own hands - would you have put in that declaration if

13 you were not satisfied that those documents had indeed been signed by Mr.

14 Brdjanin?

15 THE WITNESS: [Interpretation] This was something that was passed

16 at a session of the crisis staff.

17 JUDGE AGIUS: What was passed at a session of the crisis staff?

18 Were you authorised to make a false declaration, for example, say, signed

19 by Mr. Brdjanin with his own hand when it wasn't? Would you have made

20 that statement?

21 THE WITNESS: [Interpretation] No, no.

22 JUDGE AGIUS: So am I to conclude that when you put down Radoslav

23 Brdjanin, S.R., that was because you were satisfied that indeed

24 Mr. Brdjanin had affixed his signature to that document with his own

25 hands?

Page 21900

1 If it had been signed by someone else for Mr. Brdjanin, for

2 example, what would you put down here? Would you put down "Radoslav

3 Brdjanin, S.R."?

4 THE WITNESS: [Interpretation] Yes. Because he was president of

5 the crisis staff.

6 JUDGE AGIUS: But if he didn't sign it himself and someone else

7 signed it, would you declare to the public that it had been signed by

8 Radoslav Brdjanin when it wasn't?

9 THE WITNESS: [Interpretation] Yes, because whatever was adopted at

10 sessions, we would publish it regardless of the fact whether it was signed

11 or not.


13 Q. You told us a moment ago, Mr. Blagojevic, that sometimes you

14 published these minutes before they were signed. Is that what you're

15 telling us?

16 A. I did not quite understand. Publish what?

17 Q. That you put the minutes or the -- I'm sorry, the decisions, I

18 should say, or the conclusions into the Gazette before they had been

19 signed? Is that what you're saying?

20 A. Yes, precisely. Yes.

21 Q. But supposing you'd got it wrong and that wasn't the decision that

22 had been arrived at? Wasn't it a bit dangerous to do that? And you

23 didn't have any minutes or notes that you could look at.

24 A. No, I didn't have any minutes or notes. But what was concluded,

25 we would go. We would type it. But sometimes because of a lot of duties

Page 21901

1 that I had --

2 Q. All right. Go on.

3 A. -- They didn't have the time to wait, to sign. In the meantime,

4 we had to prepare the Gazette for publication, and that's what we did.

5 Q. Well, let's take --

6 A. It was enough for us to hear something being adopted at a session.

7 Q. But if you had got it wrong, without minutes or recordings, you

8 had no way of showing that this unsigned decision had been accurately

9 recorded by you. That's right, isn't it?

10 A. Well, on the following day, we would submit those to all the

11 members, to their desks. And nobody objected to anything that was done by

12 us.

13 Q. I'm sorry, Mr. Blagojevic. These Gazettes came out long after the

14 decisions that had been taken. This one, issue 2, was published on the

15 5th of June, and the last decision recorded in it was that of the -- well,

16 actually, it's not quite right. I take that back, because it was the 3rd

17 of June. I'm sorry, ignore that for the moment.

18 Mr. Blagojevic, what I want to understand is this: When you put

19 those letters, SR, after each of the decisions supposedly signed by Mr.

20 Brdjanin, you're telling this Court that sometimes they had not been

21 signed by Mr. Brdjanin, and sometimes they had never been signed at all.

22 Is that right?

23 A. It is absolutely right.

24 Q. But it was important, was it, for the people who were going to

25 read the Gazettes to know that Mr. Brdjanin's signature, whether it was or

Page 21902

1 wasn't on it in real life, was on those decisions, and that's why you put

2 the initials SR? Is that right?

3 A. Yes, you're right. But again, this conversation shows you that

4 this was just an improvisation, that there were no conditions in place to

5 do it properly. For example, today there will be a session. There will

6 be another session on the following day. We would prepare everything. On

7 the following day, we would put the papers on their desks. There would be

8 no objections. And things were just done in that improvised way. It was

9 nothing but an improvisation.

10 Q. All right. Now, let's just deal with the signatures, please.

11 The one and only signature of Mr. -- well, let's deal with your

12 own, first of all. Can you have a look, please, at P273 again. That's a

13 conclusion of the 2nd of July dealing with a, as it were, coordinating

14 body, which included Mr. Brdjanin and others. Is that your signature?

15 A. My signature would be only where it says "Boro." Because Brdjanin

16 could also be signed by other members of the crisis staff.

17 Q. I'm sorry. On the document, is that your signature?

18 A. No. This is not my signature.

19 Q. It's not your signature?

20 A. I can't say for a fact. I don't know.

21 Q. Mr. Blagojevic, please. Do you recognise your own signature?

22 Did you hear the question, Mr. Blagojevic? Would you look,

23 please, at that signature and tell us whether or not you signed that.

24 A. I'm not sure. But it's possible. I'm not sure, however.

25 JUDGE AGIUS: Ms. Korner, earlier on today during the first

Page 21903

1 session, he referred to a document which supposedly, as I understood, and

2 I may be the stupid one here, but I remember him saying, referring to a

3 document which supposedly bore his signature.

4 MS. KORNER: I thought it was this one, Your Honour.

5 JUDGE AGIUS: I don't know. Because I heard you now say this is

6 the only document you have which bears his signature.

7 MS. KORNER: From the crisis staff, yes.

8 JUDGE AGIUS: Earlier on today, you said -- you referred to a

9 document which you saw yesterday, I suppose, which had your signature on

10 it. And yesterday, you weren't quite sure. In fact, for a moment, you

11 even said -- you even thought it was a forgery. And then you thought, and

12 it came to your mind that that was no forgery and that was indeed your

13 signature. Were you referring to this document? Were you shown any other

14 document yesterday which had your signature?

15 THE WITNESS: [Interpretation] Where it says "Boro," I'm sure

16 there. I'm sure about that where it says "Boro" because I remember the

17 decision that was made authorising me to be -- me to sign in the absence

18 of.

19 JUDGE AGIUS: But which document? Which document were you

20 referring to? Is it this one?

21 THE WITNESS: [Interpretation] Several other documents.

22 JUDGE AGIUS: But the one you mentioned earlier on today, you told

23 us earlier on today, perhaps someone can refer me to the LiveNote page and

24 line, that there was a document which had your signature on it, and that

25 yesterday you weren't quite sure that it was your signature. In fact, you

Page 21904

1 were even suspecting that it was a forgery. But then you had afterwards

2 and that you came to the conclusion that that was indeed your signature.

3 Which document were you referring to?

4 THE WITNESS: [Interpretation] There were several documents where

5 it clearly said "Boro." Those ones.

6 JUDGE AGIUS: Did you see them yesterday?

7 THE WITNESS: [Interpretation] Yes, that's right. Yes, yes.

8 JUDGE AGIUS: And was that during the examination-in-chief by

9 Mr. Cunningham or when you were being questioned by Ms. Korner?

10 THE WITNESS: [Interpretation] I think it was Mr. Cunningham

11 because I always have a -- I'm always suspicious when it comes to copies.

12 Had it been an original document I could say straight away because the

13 regular practice is for copies to be certified as corresponding to the

14 original, they must be certified saying they are a true reflection of the

15 original, and that must be done by the organ charged to do that.

16 JUDGE AGIUS: Okay, yes, Ms. Korner.

17 MS. KORNER: Your Honour, I'm just a bit concerned about the time.

18 JUDGE AGIUS: I'm sorry, I'm just trying to --


20 Q. Are you saying that one of the documents that Mr. Cunningham

21 showed you yesterday which were all concerned with whether or not

22 Brdjanin's signature was on them, you actually saw your signature. Is

23 that what you're saying?

24 A. Yes, yes. Where it clearly says "Boro".

25 Q. You mean you signed on behalf of Mr. Brdjanin?

Page 21905

1 A. Yes. What you said signed for, that was it. Pursuant to point

2 2.

3 Q. During the next break, you can have all those documents back that

4 Mr. Cunningham showed you, and you can tell us which ones you signed. But

5 I want to move on.

6 JUDGE JANU: Can you have it in original?

7 MS. KORNER: They got the original, well, that photocopy

8 originals. I don't think we have got originals of any of these, that I

9 recall. We'll do a check, Your Honour.

10 JUDGE AGIUS: Thank you. Perhaps he can tell us whether this

11 signature resembles your signature, at least.

12 THE WITNESS: [Interpretation] Well, it does. That first letter

13 does resemble mine. As to the rest, I can't be sure. As I say, I'm not

14 sure.

15 JUDGE AGIUS: All right.

16 THE WITNESS: [Interpretation] All I'm saying is that I'm not sure.

17 JUDGE AGIUS: Go ahead, Ms. Korner, please.

18 MS. KORNER: Thank you.

19 Q. Can we look at the only document you positively identified

20 Mr. Brdjanin's signature on. And that is in my version P -- there is a

21 number of different versions. P688. I can't remember the exhibit number

22 that he was given yesterday, but it's the same document.

23 MR. CUNNINGHAM: I think it's 254.

24 JUDGE AGIUS: 254. It's more probably 255. It's more probable

25 255.

Page 21906

1 MS. KORNER: Yes, both of those, Your Honour -- yeah.

2 MR. CUNNINGHAM: As usual, Your Honour, your recollection is right

3 on.

4 JUDGE AGIUS: Thank you, Mr. Cunningham.


6 Q. Well, can you have 688 and 255. That is the document on which you

7 positively identified Mr. Brdjanin's signature. Is that right?

8 JUDGE AGIUS: What do we have on the ELMO, just for the record?

9 MS. KORNER: That's 688.

10 JUDGE AGIUS: This is 688.


12 Q. Is that right, Mr. Blagojevic? You positively identify his

13 signature?

14 A. On which document?

15 Q. The one you can see on the ELMO.

16 A. Yes, yes.

17 Q. And 255, which we'll give you back again, is a copy of that

18 decision which was sent for immediate delivery to the president of the

19 municipal crisis staff. If you look at the top of it, bring it down so

20 that Mr. ...

21 A. Also Brdjanin's signature.

22 Q. I'm sorry. It's headed there "for immediate delivery - in

23 handwriting - to the president of the municipal crisis staff." Yes?

24 A. Yes.

25 Q. Is that your handwriting?

Page 21907

1 A. No, that's not me.

2 Q. Whose handwriting is that?

3 A. It's the handwriting of Mr. Kupresanin's secretary.

4 Q. Right. So this was an important decision that had to be sent to

5 the crisis staff presidents, the municipal crisis staff presidents. Is

6 that right?

7 A. Yes.

8 Q. And no doubt, you remember this decision clearly because it was

9 the one that said non-Serbs could not hold effectively any jobs. That's

10 right, isn't it?

11 A. Yes, yes.

12 Q. And so important, was it, that it was actually published in the

13 newspaper, if you look, please, at Exhibit 254.

14 Do you remember seeing a copy of this decision being published in

15 Glas?

16 A. Yes.

17 Q. Now, I'd like you to have the Gazettes for the relevant period.

18 Could you have, please, Exhibit P295. There's the Official Gazette

19 published by you as editor. And it lists the decisions taken from the 9th

20 of June onwards. Is that right?

21 A. Yes.

22 Q. And if we look, please, just very quickly, we see the 9th of June,

23 and then the next decision, the 23rd of June. Correct?

24 A. Yes, yes.

25 Q. And from there, the next decision published is the 29th of June,

Page 21908

1 to do with motor vehicles and the like. Right?

2 A. Yes.

3 Q. Why didn't this decision, this vitally important decision, appear

4 in the Gazette?

5 A. Well, quite simply I decided, in agreement with Mr. Kupresanin,

6 that that decision for us didn't merit being published in the Official

7 Gazette.

8 Q. I'm sorry. Didn't merit?

9 A. Yes. Precisely because of the text of it.

10 Q. Do you mean because it was a completely, utterly, illegal

11 decision?

12 A. That, too, absolutely. That its contents really didn't merit

13 being published, and that was highlighted by a meeting held after that

14 where none of the presidents who were there, who attended, had any report

15 to table in that regard pertaining to it. And so after that, I and

16 Mr. Kupresanin, because of the contents of the decision, thought that its

17 place, proper place, was not publication in the Official Gazette.

18 Q. Yet, Mr. Kupresanin's secretary sent it to the presidents of the

19 municipality. Is that right?

20 A. Yes, she did send it to the presidents of municipality to act upon

21 it. And later on, at a crisis staff meeting, nobody tabled any reports

22 pertaining to it.

23 Q. That's simply -- Mr. Blagojevic, that's not true, is it?

24 A. As far as I know, that was it.

25 Q. You thought it was illegal; Mr. Kupresanin thought it was illegal.

Page 21909

1 You didn't put it into the Gazettes because of that. Did anybody take

2 that up with Mr. Brdjanin?

3 A. No.

4 Q. And why was that?

5 A. Well, quite simply what it said there was the responsible person

6 was the secretary, responsible for placing the documents there.

7 Q. As a result of that decision, countless non-Serbs that hadn't

8 already been dismissed were dismissed, weren't they, Mr. Blagojevic?

9 A. I really don't know. I really can't remember. Because it was in

10 1992, you know.

11 Q. Mr. Blagojevic, did you have non-Serb friends in Banja Luka?

12 A. Of course, of course. A very large number, in fact.

13 Q. How many of them kept their jobs?

14 A. Well, my friends, the ones I knew, kept their jobs.

15 Practically -- or rather, a large number of them did because every

16 morning, Mr. Emir Busatlic, a well-known Banja Luka physician, or rather a

17 dentist, came to me every morning. And there was this other gentleman,

18 the vice-president of the Banja Luka municipality, Mr. Tonko Ruzic, they

19 came in every morning and they remained in their posts until the end of

20 their term of office, both of them.

21 Q. Do you remember Mr. Brdjanin giving an interview in Glas and

22 naming people, non-Serbs, who had to be sacked?

23 A. I can't remember, but quite possibly that did happen, although I

24 can't remember.

25 Q. Mr. Osmancevic, Dzevad Osmancevic, the head of Metal?

Page 21910

1 A. Possibly. Dzevad Osmancevic was a well-known director of Metal

2 from Banja Luka.

3 Q. Was he dismissed?

4 A. I don't remember. I really don't remember.

5 Q. All right. I was going to do this later, but --

6 A. I don't remember whether he was then or not.

7 Q. You told us that nobody carried out that instruction in the

8 municipalities, to your knowledge. Can you have a look, please, at P1879.

9 That's a letter addressed to the Crisis Staff of the region from

10 the president of the Crisis Staff of Petrovac signed by Mr. Novakovic.

11 You knew Mr. Novakovic presumably?

12 A. Yes.

13 Q. And you've told us that you would have dealt with correspondence

14 that came to the crisis staff. What is the letter headed? Would you like

15 to read it out, please, Mr. Blagojevic.

16 A. It says: "Implementation of steps and decisions set in the Crisis

17 Staff session of 22nd of June 1992."

18 Q. And the next line, please. Read the next line aloud, please.

19 A. "Pursuant to item II of the Krajina AR Crisis Staff decision

20 dated the 22nd of June 1992, we hereby inform you that the following steps

21 from item I of the decision has been implemented in the territory of our

22 municipality."

23 Q. And that does go on to explain how they've dismissed the people in

24 accordance with that decision?

25 A. Yes.

Page 21911

1 Q. So are you telling us, Mr. Blagojevic, as you did a little time

2 ago, that no municipality reported on what steps they had taken?

3 A. I really didn't remember. I couldn't remember, really.

4 JUDGE AGIUS: I think we need to clear this up, because yesterday,

5 if you remember, Ms. Korner, I did put to the witness two questions. One

6 relating to the Municipal Assemblies, and the other relating to the

7 municipal crisis staffs. And if I remember well, what he conceded was

8 that practically in all the municipalities, the municipal assemblies had

9 gone into hibernation. They had been replaced by the municipal crisis

10 staffs. And then when he had stated earlier on that no implementation of

11 the regional crisis staff had taken place, he meant the municipal

12 assemblies and not the municipal crisis staffs. And he did concede

13 yesterday that implementation did take place by the municipal crisis

14 staffs. That's what I understood yesterday. The decisions of the ARK

15 Crisis Staff were not implemented by the municipal assemblies, but were

16 implemented by the municipal crisis staffs.

17 MS. KORNER: Your Honour may be right. We had better understand

18 from Mr. Blagojevic.

19 JUDGE AGIUS: Do you agree with what I have just stated, basing

20 myself on what you had --

21 THE WITNESS: [Interpretation] Yes, precisely, Mr. President.

22 That's what I was thinking. That the municipal assemblies at their

23 meetings didn't put that forward, and the crisis staff of the

24 municipalities, except for this -- actually, I don't know whether any

25 other reports came in with respect to this.

Page 21912

1 I really don't remember.


3 Q. Mr. Blagojevic, we can deal with quite a large topic that I have

4 lined up for you in one simple question. Is it your evidence that to your

5 knowledge, the municipal crisis staffs implemented the decisions made by

6 the regional crisis staff?

7 A. Well, I really don't remember whether they fully implemented those

8 decisions. I just don't remember. I haven't any knowledge or awareness

9 of it. I have no knowledge about that.

10 Q. Well --

11 JUDGE AGIUS: Who implemented the decisions of the regional crisis

12 staff?

13 THE WITNESS: [Interpretation] Well, Mr. President, I didn't get

14 any feed -- there was no feedback information. Except for what it says

15 here, I really can't remember whether there was any feedback information

16 coming in to the effect that they were informing the crisis staff and that

17 we did such and such in conformity with your decision. I really can't

18 remember whether there was -- whether the municipalities did give out

19 information about that.

20 JUDGE AGIUS: Ms. Korner, please.


22 Q. Mr. Blagojevic, the reason that the meetings were being held which

23 were attended by the presidents of the municipalities is so that they

24 could inform the crisis staff of what was happening in their region and

25 what they were doing about the directions given by the crisis staff.

Page 21913

1 Isn't that right?

2 A. Usually at those meetings, they would indicate the state of

3 affairs in their municipality and any problems they were encountering.

4 And there were also cases where it said "pursuant to the crisis staff

5 decision, let us see how the municipality was being supplied with food,

6 oil derivatives, medicines and so on." The army with cigarettes, that

7 kind of thing.

8 And then I told you how the discussions would evolve. They would

9 say "we don't have this or we're lacking in that or we don't have the

10 facilities for the other."

11 Q. Yes, but in these lengthy discussions, these meetings that went on

12 for days and days and days, was one of the subjects touched upon what the

13 municipal crisis staffs were doing to carry out the instructions of the

14 regional crisis staff?

15 A. Probably. When, for example, they discussed the problem of --

16 Q. No, no, Mr. Blagojevic. Let's not have probably. You are able to

17 remember things like what Kupresanin said. You were present at those

18 meetings. Is that what was happening, amongst other things, that reports

19 were being given?

20 A. That reports -- that the municipalities tabled reports? Is that

21 what you mean?

22 Q. That the municipalities reported to the regional crisis staff, to

23 Mr. Brdjanin, about what was being done in their area to carry out the

24 instructions like this one?

25 A. Well, at these meetings, there was most probably talk of that,

Page 21914

1 too.

2 Q. All right. I'm not going to pursue this any further.

3 JUDGE AGIUS: I feel like being in a dental clinic rather than in

4 a courtroom, Ms. Korner.


6 Q. Right. Can we move on, because I need to finish today,

7 Mr. Blagojevic, with you.

8 The funds, let's deal with that now, you asserted -- the only

9 thing you're very sure of is that nobody took any notice of the order that

10 funds should be given to the autonomous region. Is that still your

11 evidence?

12 A. When the executive council was set up, it informed all the

13 secretariats, and laws were applied at that time passed by the National

14 Assembly, that is to say laws on taxation, various transactions, commerce

15 and so on. So the resources that were supposed to be paid into the

16 republican budget would remain in the area of the Autonomous Region of

17 Krajina and placed in the service of.

18 Q. Mr. Blagojevic, you were taken through a number of decisions by

19 Mr. Cunningham that were orders to the municipalities to supply funds to

20 the Autonomous Region of Krajina Crisis Staff or whatever. And you said,

21 you were positive about that, and I can read back your words, no funds

22 were paid. Is that still your evidence?

23 A. Yes, absolutely so. That is the decision by which the

24 municipalities were supposed to have 30 dinars per inhabitant paid in.

25 There were no technical reasons or any rules and regulations according to

Page 21915

1 which they could put that into practice because they paid in regular taxes

2 and contributions on the basis of the law governing income taxes and

3 turnover taxes, taxes on goods and services. And so those taxes, those

4 funds, went to the social accounting service in Banja Luka, and those

5 funds were supposed to go to the budget of the Federation. However, the

6 executive council didn't send those funds to the Republic budget, but kept

7 them back in Banja Luka.

8 Q. All right. Could you have a look, please, at Exhibit P2107. Just

9 have a look at it, and then I'll ask you the question. Perhaps it better

10 be moved up the ELMO so that...

11 Yes, can we go to the next.

12 All right, Mr. Blagojevic. Does that show that the Municipality

13 of Bosanska Krupa on the 10th of July complied with the decision of the

14 crisis staff on the 13th of May to pay 3 dinars per citizen a month?

15 A. In the conclusions of the crisis staff, it was stated that 30

16 dinars per month per citizen should be paid in. 30 dinars per capita.

17 Whereas here I see it says 3 dinars. So 10 times less than the 30.

18 Q. All right. You said no funds -- whether it may be a typing error

19 or not is neither here nor there. You said no funds were ever paid in as

20 a result of this decision. But do you agree that you were wrong about

21 that?

22 A. I really didn't remember this. I didn't even know about this.

23 Because here, I can see 3, whereas 30 was what was prescribed. And I

24 believe that this municipality did not even have any money. I don't know

25 whether they had any money at their disposal at all, any funds. Because

Page 21916

1 there were just a few municipalities that funded the entire region, Banja

2 Luka, Gradiska, Laktasi, Srbac, Prnjavor, Mrkonjic Grad, Bosanska Dubica.

3 These were the only places where something was going on. Prijedor. Novi.

4 This particular municipality, the Serbian Municipality of Krupa, I don't

5 know where they are today. The entire territory of that municipality is

6 just one village. There are no economic entities there. The total number

7 of voters there is not more than a hundred. So I suppose --

8 Q. All right, Mr. Blagojevic. That will do.

9 JUDGE AGIUS: Let's take advantage of the fact that his memory

10 seems to be coming back, Ms. Korner. We'll have a 25-minute break. In

11 the meantime, if you have any other documents in line on this matter, you

12 can prepare them.

13 MS. KORNER: Yes. Your Honour, but I think he was going to be

14 given -- he wants to identify his signature in the same bunch of

15 documents.

16 JUDGE AGIUS: Yes, thank you.

17 Usher, could you escort the witness out of the courtroom, please.

18 Yes, Mr. Cunningham.

19 MR. CUNNINGHAM: Judge, I will have redirect. I just wanted to

20 let the Court know.

21 JUDGE AGIUS: I would imagine so. Thank you. 25 minutes from

22 now.

23 --- Recess taken at 12.34 p.m.

24 --- On resuming at 1.01 p.m.

25 MR. CUNNINGHAM: Your Honour, may I --

Page 21917

1 JUDGE AGIUS: Yes, I recognise Mr. Cunningham.

2 MR. CUNNINGHAM: Thank you, Your Honour. On LiveNote, page 68,

3 line 22, that's when the Court starts --

4 JUDGE AGIUS: One moment. 68. Yes.

5 MR. CUNNINGHAM: That's when Your Honour made some statements with

6 respect to your recollection of testimony from yesterday.

7 JUDGE AGIUS: Mm-hmm.

8 MR. CUNNINGHAM: And while I typically rely on the Court's

9 recollection, I think -- I just wanted -- my perception, my recollection

10 of the testimony yesterday is different from that that you expressed, and

11 I just wanted to note that for the record.


13 MR. CUNNINGHAM: And it's okay with the Court, Witness Number 17

14 will follow the witness next week.

15 JUDGE AGIUS: All right.

16 MS. KORNER: Well, Your Honour, can we come back to witnesses at

17 the end of the session. I mean, I'm delighted to hear that Witness Number

18 17, if it's the man I think it is, is coming, but I'd like to know about

19 the following week, but I'll leave it till the end of the session.

20 JUDGE AGIUS: Yesterday, just to clear this up, Mr. Cunningham, I

21 had asked the witness "Were the Municipal Assemblies meeting at the time

22 or were they in hibernation because of the existence of crisis staffs in

23 all the municipalities?" The witness said: "Probably they had to freeze

24 their activities, so there were no sessions due to the government's

25 decision on the establishment of crisis staffs." And then I said: "So

Page 21918

1 wouldn't it have been logical and reasonable in a time of great crisis

2 that the crisis staffs of the Autonomous Region of Krajina to make sure

3 that the decisions and conclusions are adopted, are implemented, that the

4 statute of the Autonomous Region of Krajina be amended?" Since the

5 Municipal Assemblies were not meeting, and therefore, could not adopt or

6 approve the decisions taken by the ARK Crisis Staff, was that the

7 situation to be accepted, to be kept, to be tolerated in a time of crisis,

8 or a situation which needed a remedy, the remedy being the amendment to

9 the statute that was adopted on decision number 42.

10 The witness said: "Since the assemblies could not hold the

11 meetings then the crisis staff of each municipality was supposed to ratify

12 this." And then I said: "So I would take it if I were to show you

13 documents of conclusions or decisions taken by the municipal crisis staffs

14 adopting, endorsing the decisions taken by the ARK Crisis Staff, would

15 that mean that the municipal crisis staff were implementing the decisions

16 of the ARK crisis staff or not to you?" And the witness said: "If they

17 ratified them at the sessions, I suppose they were in a position to

18 implement them." This is what was said yesterday.

19 Ms. Korner.

20 MS. KORNER: Thank you. Your Honour, can I come back to witnesses

21 at the end of the session? I regret that -- I didn't think the witness is

22 going to finish today, unless Your Honours will order me. But I've got a

23 number of more topics.

24 JUDGE AGIUS: If I were you, Ms. Korner, I would bring it to a

25 quick end, as quickly as possible, my suggestion is. And I think the

Page 21919

1 situation being what it is, I would rather prefer to have -- to hear what

2 the re-examination is about.

3 MS. KORNER: All right. Well, Your Honour, there are a number of

4 topics that I really --

5 JUDGE AGIUS: Go ahead. I'm not going to foreclose on you, but I

6 have told you what my preference is.

7 MS. KORNER: All right. Can we deal with the meetings themselves.

8 Q. A few topics, please, Mr. Blagojevic. General Talic didn't attend

9 very often, but sent Colonel Vojinovic to represent him at the meetings.

10 Is that right?

11 A. Yes.

12 Q. And you told us in interview at page 35, Mr. Cunningham, that at

13 the one meeting you remember Talic attending, apart from the problem of

14 conscripts and the problems between the military authorities and the

15 deputies, it was put to you that at the same meeting, Talic made many

16 requests to the crisis staff regarding food and housing for the soldiers.

17 And your reply was: "Yes, he said that he was having huge problems." Do

18 you remember that?

19 A. Yes.

20 Q. As far as the paramilitaries were concerned, and this was a topic

21 that went on for some time in the meetings, didn't it?

22 A. Yes.

23 Q. It wasn't, was it, the Serbian paramilitaries, Arkan's forces, the

24 White Eagles, the Wolves of Prnjavor that were being discussed, but what

25 were called the Muslim paramilitaries, the Green Berets?

Page 21920

1 A. Can this be in private session, please.

2 JUDGE AGIUS: Yes, certainly.

3 MS. KORNER: Yes.

4 JUDGE AGIUS: Let's go into -- let's go into private session.

5 [Private session]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [redacted]

12 [redacted]

13 [redacted]

14 [redacted]

15 [redacted]

16 [redacted]

17 [redacted]

18 [redacted]

19 [redacted]

20 [redacted]

21 [redacted]

22 [redacted]

23 [redacted]

24 [redacted]

25 [redacted]

Page 21921













13 Page 21921 redacted private session













Page 21922

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 [redacted]

7 [redacted]

8 [redacted]

9 [redacted]

10 [redacted]

11 [Open session]


13 Q. The camps.

14 JUDGE AGIUS: We are in open session, Ms. Korner.


16 Q. The camps, Mr. Blagojevic, you've told us there was never any

17 discussion about the camps at any of the meetings you attended. Do you

18 still want to adhere to that answer?

19 A. I really can't remember that these matters were ever discussed.

20 Q. Mr. Brdjanin, as the president of the crisis staff, made a visit,

21 didn't he, to, among other places, Omarska?

22 A. I really don't know.

23 Q. I'm sorry. Did you not read not anything in the newspapers or on

24 television about Mr. Brdjanin and other politicians visiting Omarska?

25 A. I don't remember. I don't remember.

Page 21923

1 Q. Mr. Radic?

2 A. I don't remember.

3 Q. You do, however, remember Mr. Kupresanin, your direct boss of the

4 assembly, visiting camps, don't you?

5 A. Correct.

6 Q. Mr. Kupresanin went to Omarska. Correct?

7 A. He did.

8 Q. Took out of Omarska a deputy -- a Bosniak deputy called

9 Mevludin Sejmenovic. Is that right? Is that right?

10 A. Yes, yes.

11 Q. And he went to Manjaca as well, didn't he?

12 A. I don't know. I really don't. I am aware of the visit to Omarska

13 because I witnessed him bringing Mr. Sejmenovic back.

14 Q. Did you go to Omarska as well?

15 A. No, no, no.

16 Q. How did you witness him bringing Mr. Sejmenovic back, then?

17 A. He brought Mr. Sejmenovic to his office.

18 Q. So Mr. Kupresanin, Mr. Radic, and Mr. Brdjanin, who had all been

19 to these camps, according to you - is that what you're saying - never

20 raised in any meeting the fact that Prijedor was running a camp that

21 clearly, as you now know, if not before, was a disgrace?

22 MR. CUNNINGHAM: Judge, if I might just -- I have an objection

23 because the question states that Mr. Brdjanin has been to all of these

24 camps, and that's not true. I understand what she is trying to do, but I

25 just wanted to register an objection to that part of the question.

Page 21924

1 JUDGE AGIUS: I think I have to sustain the objection, Ms. Korner.

2 Yes.


4 Q. Mr. Brdjanin, who had been to Omarska, never raised in a meeting

5 the fact that this was a disgraceful camp?

6 A. No.

7 Q. Mr. Kupresanin, who I suggest to you went to Omarska and to

8 Manjaca, never raised the fact that two camps were being run where

9 prisoners were in a disgraceful condition?

10 A. Yes, he did, when he brought Mr. Sejmenovic back. He talked about

11 that.

12 Q. In a meeting of the crisis staff?

13 A. No. N

14 Q. So when did he talk about that?

15 A. When he brought Mr. Sejmenovic back to his office.

16 Q. So he, then, told you what the conditions in Omarska were like?

17 A. Yes, he did.

18 Q. Did you ask him whether he was going to raise that in a crisis

19 staff meeting at which the leaders of the Prijedor Municipality would be

20 attending?

21 A. No. I didn't. This was simply not within my purview. I was not

22 a political figure to raise any such issue or suggest anything to him.

23 Q. Because the authorities, representatives of the authorities in

24 Prijedor, did attend the crisis staff meetings, didn't they?

25 A. Yes.

Page 21925

1 Q. And to your knowledge, was there anything to prevent

2 Mr. Kupresanin or Mr. Brdjanin saying to these people "these camps are a

3 disgrace; you must close them down or clean them up"?

4 A. I don't know. There was a certain competition between the people

5 from Prijedor and those from the Banja Luka region. There was a sort of

6 animosity.

7 Q. I understand that. I understand that's what you're saying anyhow.

8 What was to prevent them, Mr. Kupresanin, from saying to Mr. Stakic or

9 Simo Drljaca or Srdjo Srdic or any of those -- Kovacevic, that camp is a

10 positive disgrace?

11 A. I really don't know.

12 Q. All right. I want you to look, please, briefly at Document Number

13 P229.

14 This was sent -- this document was sent to the Crisis Staff of the

15 Autonomous Region of Banja Luka. Do you remember this document?

16 A. Yes, I do.

17 Q. And it was clear, wasn't it, that the municipalities were urging

18 the Autonomous Region of Krajina Crisis Staff to become even more extreme

19 in its attitudes?

20 A. Judging by this, yes.

21 Q. And this document was discussed, wasn't it, at a meeting of the

22 crisis staff on either the following day or the day after. That's the

23 8th, 9th of June. Is that right?

24 A. I can't remember whether this was...

25 Q. And Mr. Blagojevic, isn't it one of the reasons why Colonel

Page 21926

1 Vojinovic was told that the Muslims in the military in the VRS had to be

2 dismissed?

3 A. I'm not aware of that.

4 Q. Do you not remember Colonel Vojinovic attending a meeting of the

5 crisis staff not long after this where it was made plain that the crisis

6 staffs wanted non-Serbs in the military to be dismissed?

7 A. I'm really not aware of that. I know that there were a lot of

8 Bosniak and Croat officers in the army, and this is what was said to

9 Mr. Vojinovic. I really don't remember.

10 Q. Did you know the names of Colonel Selak and Colonel Hasotic?

11 A. No.

12 Q. Now, at the end of this period, on the 17th of July, all the

13 decisions taken by the crisis staff were put to the assembly for

14 verification, weren't they?

15 A. I don't remember.

16 Q. All right. Well, have a look, please, at Exhibit 285.

17 A. Yes, I remember now.

18 Q. Yeah. It's one of the documents you provided to the Office of the

19 Prosecutor, isn't it?

20 And we can see that, if you put it that way, the great and the

21 good attended this meeting: Talic, Hadzic from the Croatian Krajina,

22 Martic from the Croatian Krajina, Subotic, Mr. Ostojic, Mr. Kalinic, and

23 General Ninkovic. And if we look, please, at item number 4, verification

24 of the decisions and conclusions adopted by the Crisis Staff and war

25 presidency of the Autonomous Region of Krajina, there was a debate and --

Page 21927

1 sorry. Following a debate in which several assembly members took part all

2 decisions and conclusions adopted by the crisis staff and the war

3 presidency of the Autonomous Region of Krajina were verified.

4 There was one brave man who stood out against them. So that gave,

5 Mr. Blagojevic, according to you, did it not, full authority and legality

6 to the decisions taken by the crisis staff?

7 A. Yes.

8 Q. Including the decision signed by Mr. Brdjanin personally which you

9 didn't put into the Gazette?

10 JUDGE AGIUS: The one of the 22nd June.

11 MS. KORNER: That's right.

12 Q. And including the alteration to the statute of the Autonomous

13 Region of Krajina which said that the municipalities that you were shown

14 yesterday, the municipalities had to obey - and I'm paraphrasing now - the

15 instructions of the region. That's right, isn't it, Mr. Blagojevic?

16 A. Yes.

17 MS. KORNER: Thank you.

18 JUDGE AGIUS: Yes. Will you finish in 20 minutes, Mr. Cunningham?

19 MR. CUNNINGHAM: I'll try, because I know the witness wants to get

20 home. So I'll do my best.

21 JUDGE AGIUS: All right.

22 [Trial Chamber confers]

23 Re-examined by Mr. Cunningham:

24 Q. The first area I want to go over with you is in response to the

25 Prosecutor's question with respect to correspondence that the ARK Crisis

Page 21928

1 Staff may or may not have ever received. Did you ever receive any

2 correspondence -- when I say you, I'm referring to the ARK Crisis Staff,

3 receive any correspondence from the RS saying -- ordering them to disband

4 the ARK Crisis Staff?

5 A. I don't remember.

6 Q. You remember giving your statement to the OTP in Banja Luka in

7 July of 2001. Correct?

8 A. What I meant was that they never delivered it, if you know what I

9 mean. They never sent any letters to the Crisis Staff, that is,

10 representatives of the government or the presidency. That's the way I

11 understood your question, sir.

12 Q. Okay. So no correspondence from the republic -- from the RS.

13 Correct?

14 A. Correct.

15 Q. Okay. Ms. Korner showed you a document that I believe is

16 Prosecutor Exhibit 2107. That is the exhibit, I believe, from the

17 Petrovac Crisis Staff dated 10 July 1992 dealing with their allocation of

18 3 dinars per person for funds. Do you remember that exhibit? And the

19 usher's going to -- it's actually --

20 A. Yes, I saw it only a little while ago. However, given their

21 economic strength, I doubt whether they ever paid a single dinar into any

22 funds.

23 Q. I want to remind you, I'm assuming that you would like to be at

24 home with your family for the weekend. So if you listen to my questions,

25 there's a good chance you could be out of here to be with your family. So

Page 21929

1 just listen.

2 So your testimony today is this letter -- this document which came

3 from Krupa, I stand corrected on that, this is the first time you had ever

4 seen the document? Or you just didn't remember seeing it before.

5 A. I couldn't remember it.

6 Q. All right.

7 A. It was a long time ago, as you know.

8 Q. Okay. Listen to the question. Was there any other correspondence

9 on this topic, that is, satisfying the conclusion of the ARK on 13 May

10 1992, was there any other correspondence, any or report from any other

11 municipality? Do you ever remember getting anything else?

12 A. I don't remember. I really don't.

13 Q. Page 9 of the LiveNote today, Ms. Korner was asking you about the

14 attendance of certain members of the Crisis Staff covering a topic that I

15 had covered with you yesterday. And in your testimony yesterday, you

16 couldn't recall how many times such people as Stojan Zupljanin,

17 Mr. Mirjanic, Mr. Puvacic, Mr. Dubocanin, Stevandic, and Djuro Bulic

18 attended. When I asked you about your statement in Banja Luka that we

19 have been referring to, did you ever get a complete copy of this

20 statement?

21 A. [No Interpretation]

22 Q. Never had a chance to read the entire thing to refresh your

23 recollection, did you?

24 A. Are you referring to the one of the 19th?

25 Q. Right. The one that we've seen bits and pieces of on the screen

Page 21930

1 in front of you. You didn't have a chance to look at it and refresh your

2 recollection. And the reason that I'm asking that, in your testimony -

3 excuse me, in your statement to the OTP from July of 2001 - you could

4 recall there how many times certain people attended the meetings. Am I

5 correct?

6 A. I said it yesterday. These people attended, as far as I can

7 remember, only a couple of times. Later on, it turned out -- into

8 meetings attended by the deputies, the presidents of the municipalities --

9 Q. I really want to get you home. I know you miss your family, so

10 bear with me.

11 MR. CUNNINGHAM: I'd like to show him his statement in B/C/S to

12 refresh his recollection because I want to ask him questions about --

13 because he answers in the statement specifically how much certain

14 witnesses attended. Excuse me, certain members attended.

15 Q. I'm on page 16 of the English version. And on the middle of page

16 16, on line 14 - and I'm sorry, Mr. Usher, I can't give you the exact page

17 of the Serbian version, but I think it is going to be about one page

18 ahead.

19 MS. KORNER: Would it be quicker if he just puts to him how many

20 times he says each person attended.

21 MR. CUNNINGHAM: That's fine with me.

22 Q. In your statement, sir, and I want to see if this refreshes your

23 recollection, you were asked specifically how often did Stojan Zupljanin

24 attend. And I want to see if this refreshes your recollection. You said

25 that I think that Stojan Zupljanin attended one session, one meeting. I

Page 21931

1 can't recall properly, but I think it was one.

2 Does that refresh your recollection?

3 A. Yes, yes. And I adhere to that.

4 Q. Okay. With respect to Dr. Mirjanic, you said that he attended

5 around ten times. Is that correct?

6 A. Which doctor?

7 Q. Dr. Mirjanic.

8 A. That's possible. Because I can remember things much better then

9 than I can now.

10 Q. And understandable. With respect to Milan Puvacic, you said that

11 he "attended only a few times." Does that refresh your recollection?

12 A. That's correct.

13 Q. And with respect to Jovo Rosic, you said at line 21 "the same

14 thing, maybe a few times". Does that refresh your recollection there?

15 A. That's correct.

16 Q. And with respect to Dubocanin, you said that "maybe he attended

17 six or seven, eight meetings." Does that sound -- refresh your

18 recollection?

19 A. That's correct.

20 Q. And you gave the same answer when the name of Mr. Stevandic was

21 brought up, the same several times was your answer. Is that correct?

22 A. Correct. It was a long time ago. 12 and a half years. And it's

23 very hard for me to be precise on some facts.

24 Q. That's fair. On page 15 and 16 of the LiveNote today, Ms. Korner

25 discussed with you in the case of Milorad Sajic, the regional secretariat

Page 21932

1 for National Defence, do you recall if that body, those regional

2 secretariat for defence, whether they were abolished in May?

3 A. I'm not quite sure. But I seem to feel that the amendments to the

4 law on national defence, that Articles 37 to 53 were deleted.

5 Q. Okay. You were asked several times about reports from

6 municipalities. And towards the end of Ms. Korner's cross-examination,

7 she specifically asked you about the attendance of representatives from

8 Prijedor. Do you recall how often -- or how would you characterise the

9 attendance by the Prijedor representatives? Were they there at every

10 meeting? What do you recall?

11 A. Well, quite certainly, they didn't attend every meeting.

12 Q. Okay. And do you remember in your statement to the OTP at page 20

13 being asked what would happen if Mr. Rasula or Srdjo Srdic showed up at

14 crisis staff meetings? Do you remember what you told the OTP? Because if

15 you don't, I'll put the question to you directly to see if it refreshes

16 your recollection.

17 A. Mr. Srdjo was there several times.

18 Q. Do you remember making this statement to the OTP, page 20, when

19 asked about Mr. Rasula and Srdjo Srdic attending crisis staff meetings?

20 And I'm going to pick it up at line 20, and I'm quoting you.

21 "Because" -- well, I'll read the entire answer. "Well, if they were in

22 Banja Luka and there was a meeting or a session of the crisis staff in

23 Banja Luka at that time, then they would drop by. Because deputies would

24 usually come to have a cup of coffee with Mr. Kupresanin, and then when

25 they visited him and if the crisis staff organised a meeting, then

Page 21933

1 Mr. Kupresanin would say to them, `well, we have a meeting with the crisis

2 staff, and there is a session today, and you could attend it and you can

3 also express your own problems'. They would come to see Vojo and

4 criticise government. They would tell him about troubles how the

5 government forgot about them, how the government isn't helping them, and

6 basically how they criticised the government."

7 Does that refresh your recollection of what you told the OTP in

8 Banja Luka in July of 2001?

9 A. Yes, that's correct. What you just read out. Correct.

10 Q. Okay. Do you ever remember at any of these meetings Mr. Srdjo,

11 any representative from Prijedor or any municipality that had the camps,

12 ever bringing anything up about the camps?

13 A. I really don't remember.

14 Q. When you found out about Omarska, because Mr. Kupresanin had

15 brought the gentleman back from Omarska, do you happen to recall whether

16 or not the crisis staff even was in existence when you found out about

17 Omarska?

18 A. I can't remember.

19 Q. Fair enough.

20 Ms. Korner asked you questions with respect to the crisis staff

21 decisions and the signatures thereon. Were other members -- was it agreed

22 by members of the crisis staff that someone other than Mr. Brdjanin could

23 sign crisis staff decision?

24 A. Yes, a decision was made authorising the secretary to prepare the

25 Official Gazette. And in the absence of someone, one of the members, that

Page 21934

1 someone else could sign. I happened to remember that actually yesterday

2 afternoon.

3 Q. I want to go back now to Prosecutor's Exhibit 2107 and just have

4 that available to you because that is the decision from the Bosanska Krupa

5 Crisis Staff in response to the request for payment of a per capita

6 payment of dinars. First of all, do you know whether or not the crisis

7 staff ever opened any sort of banking account, had made any sort of

8 banking arrangements for the receipt of any money related to this per

9 capita request?

10 A. No, no. There was just the giro account of the assembly itself.

11 Q. Okay. Was there -- although this crisis staff decision says that

12 Krupa has allocated 3 dinars per person, do you know whether that money

13 was ever forwarded to the crisis staff?

14 A. I really don't remember whether any of this was ever implemented.

15 Q. Okay. You also told us that the amount offered was 10 times less

16 than that requested. Do you know whether the crisis staff ever sanctioned

17 the Municipality of Krupa or its crisis staff for their response?

18 A. No. I've just remembered that probably that money was never paid

19 in because on the account of the assembly, there were no funds, and we

20 sought funds from the federal executive council of the region, or rather,

21 the government of the autonomous region.

22 Q. There is some confusion in my mind, so help me out here. Did any

23 other municipality even respond to this request for a per capita, 30 dinar

24 payment?

25 A. No, no. I've just remembered. After the 4th of March 1992, all

Page 21935

1 the funds could be paid in only on the giro accounts of the executive

2 council of the region, because in actual fact that was the government of

3 the autonomous region.

4 Q. Okay. Two or three more brief topics. Ms. Korner talked to you

5 about Serbian paramilitaries and other paramilitaries in the context of

6 crisis staff orders. I would like the usher to show you P227, which is the

7 ARK Gazette. Go to entry number 15 - excuse me - it's entry for 15 May

8 1992, and I'll find the page. The English translation, the page is 20.

9 Conclusion number 3, I'll read it to you very slowly, it says:

10 "Especially strict measures shall be implemented against any person

11 misusing uniform and insignia of police, TO, or army, and without

12 authorisation stopping, checking people's identities or vehicles,

13 searching dwellings or other premises."

14 By the way that that conclusion is phrased, would that be directed

15 to Serbian paramilitaries or to non-Serbian paramilitaries?

16 A. This is the conclusion which refers to the Serbian paramilitaries.

17 Q. The final area that I want to talk to you has to deal with --

18 Prosecutor showed you Exhibit P229. And to refresh your recollection,

19 Prosecutor's P229 is a conclusion dated 17 June 1992 from the Sanska --

20 7 June, I apologise, from what has been known as the Sanska Una subregion.

21 And this was showed to you. And it was put to you in something along

22 these lines. Isn't this a request for the crisis staff to become even

23 more extreme? Do you remember that being asked of you just -- no more

24 than 20 minutes ago?

25 A. Correct.

Page 21936

1 Q. Do you happen to know what -- whether there was a subsequent

2 document, specifically Prosecutor's 247, that was also issued by the same

3 region? If we can have you look at that very briefly, then, Judge, that

4 will be my very, very last area. If we can just finish this, then I'll be

5 done.

6 Have you ever seen this document? Were you aware of it, sir?

7 A. No.

8 MR. CUNNINGHAM: Your Honour, that's all I have.

9 MS. KORNER: Your Honour, we've actually got the original of the

10 document --

11 JUDGE AGIUS: The signature.

12 MS. KORNER: It's another photocopy, but still.

13 JUDGE AGIUS: Yes, I would suggest it's shown to the witness, and

14 that will be your final statement for today.

15 Give it to him straight away.

16 You are being shown, Mr. Blagojevic, the best that the Prosecution

17 can show you. Do you recognise your signature on that document?

18 THE WITNESS: [Interpretation] Well, it's possible. I'm not sure.

19 I'm really not sure, but it is possible.

20 JUDGE AGIUS: All right, all right.

21 THE WITNESS: [Interpretation] Because it's not the original. This

22 is a copy, after all.

23 JUDGE AGIUS: Yes, all right. Okay. So you can take the document

24 back, please.

25 Mr. Blagojevic, both Judge Janu, Judge Taya, and myself had

Page 21937

1 several questions to put to you. But we've heard from Mr. Cunningham that

2 you would like to be back with your family as soon as possible. And we

3 will accommodate you. We will not be asking you any questions. You're

4 free to go. But before the usher accompanies you out of this courtroom,

5 on behalf of the Tribunal, I would like to thank you for having come over

6 to give your testimony. You will be escorted by the usher, and you will

7 receive all the attention and assistance you require in order to enable

8 you to return back to Banja Luka at the earliest possible opportunity.

9 THE WITNESS: [Interpretation] Mr. President, may I be allowed to

10 thank you.

11 JUDGE AGIUS: Thank you.

12 THE WITNESS: [Interpretation] I would like to say that I thank

13 this distinguished Tribunal for giving me the honour of testifying here

14 for three days, and to try, because after all, it has been 12 and a half

15 years since the events, to testify to the best of my recollections, and to

16 have us clarify certain facts for the Tribunal really to gain an insight

17 into the legal and relevant state of affairs. And I really do extend my

18 gratitude to the distinguished President and his colleagues, to the

19 Prosecution, and also to the Defence counsel and all the other people who

20 have helped me here in these past few days at the Tribunal because I do

21 feel proud of having come here and being given the opportunity of saying

22 something after 12 and a half years and presenting some facts here.

23 JUDGE AGIUS: Thank you. We also wish you a safe journey back

24 home.

25 Yes.

Page 21938

1 MS. KORNER: Your Honour, I know it's running over slightly, but

2 I'll ask for Your Honours' and the interpreters' indulgence over this

3 question of witnesses, as I understand it, the witness who is scheduled to

4 come next week and will be followed by Witness Number 17. I wanted to

5 know who is coming after that.

6 MR. CUNNINGHAM: I was about to tell you. 29. 32.

7 MS. KORNER: Your Honour, finally, then, Glamoc, Srbac, Laktasi,

8 are we going to hear from them.

9 MR. CUNNINGHAM: I talked to Mr. Ackerman about that, the final

10 agreement had not been reached. I think our agreement was that we will

11 let them know by Monday, and we will let you know by Monday.

12 JUDGE AGIUS: All right. I thank you, Mr. Cunningham, Ms. Korner,

13 for all the cooperation that you have shown in order to enable this

14 witness to return home before the weekend.

15 It is my duty, however, to thank the interpreters, the rest of

16 technical staff, all the rest of the staff, particularly, I repeat, the

17 usher, without all your cooperation we wouldn't have finished. So I thank

18 you all. We meet Monday in the afternoon. Thank you. I don't know which

19 courtroom. I still have to check.

20 --- Whereupon the hearing adjourned at 1.52 p.m.

21 To be reconvened on Monday, the 3rd day of

22 November, 2003, at 2.15 p.m.