Tribunal Criminal Tribunal for the Former Yugoslavia

Page 5729

1 Tuesday, 29 May 2007

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.01 a.m.

6 JUDGE ROBINSON: Mr. Tapuskovic, you are to continue your

7 examination in chief.


9 [Witness answered through interpreter]

10 MR. TAPUSKOVIC: [Interpretation] Good morning, Your Honours.

11 Thank you.

12 Examination by Mr. Tapuskovic: [Continued]

13 Q. [Interpretation] I understand that the witness will be able to

14 come closer to the map and sit at the same time, because as I understand,

15 there's an extension cable provided for him to be able to speak in the

16 microphone while he is showing things on the map.

17 JUDGE ROBINSON: Is that so? May I be informed.

18 [Trial Chamber confers with usher]

19 JUDGE ROBINSON: I understand that the extension is for the

20 headphone, not for the microphone.

21 MR. TAPUSKOVIC: [Interpretation] Then we're going to face

22 difficulties. But, anyway, let us start working and then we'll see

23 whether it is going to proceed normally.

24 Q. Mr. Veljovic, good morning. You know that last time we started

25 this examination-in-chief on behalf of the Defence. In order not to go

Page 5730

1 back to what I had started, I'd like to ask you this: Before you became a

2 member of the Sarajevo-Romanija Corps, which unit of the JNA you had been

3 a member of?

4 A. It was the 216th Mountain Brigade of the JNA.

5 Q. Do you know how this change occurred?

6 A. Since the Yugoslav army withdraw from the territory of the

7 Republic of Bosnia and Herzegovina on the 19th of May, 2002, and pursuant

8 to the decision of the assembly of the Republika Srpska on the 12th of

9 May, the army of Republika Srpska was established.

10 Q. How did it come about that this name was given to it? Do you know

11 anything about it in particular or did you not attach any special

12 importance to that under the circumstances when the hostilities broke out?

13 A. Through the media, we learned that the assembly of Republika

14 Srpska had reached a decision to form a new army to be named the army of

15 Republika Srpska and that the chief -- the General Staff was established,

16 headed by General Ratko Mladic.

17 Q. Thank you. I'm not going to go back to what you spoke about last

18 week; however, you do remember that on the day when we started, we left

19 off with your answer in which you said that there were no changes in

20 positions of the two parties, i.e., the Sarajevo-Romanija Corps and the BH

21 army from 1992 until the end of the war; is that correct?

22 A. No, it isn't. I said that since 19th December, 1994, when I

23 assumed my duties, there were no changes after that date until the 15th of

24 June, 1995 offensive.

25 Q. Very well. Can you describe for us the positions in April 1992?

Page 5731

1 For example, on the hills of Zuc, Hum, Grdonj, et cetera, what were the

2 positions like at the time? But please careful to speak in the microphone

3 when you give your answers.

4 A. In 1992, the VRS positions and the positions of the ABiH, or

5 rather, the 1st Corps, looked differently than shown in this map, because

6 Vogosca, Rajlovac route, where Zuc was a dominant feature, were held by

7 the Serbia forces all the way up to the tobacco factory, Potoka Kuca,

8 Pofalici, Naselje, all the way to Hum and the Zuc hill.

9 Q. Thank you.

10 A. As far as Grdonj is concerned, it's here, and these positions

11 remained unchanged.

12 Q. In what way?

13 A. That's how the forces were deployed.

14 Q. The area that you have just mentioned and explained was populated

15 by whom in April 1992?

16 A. Pofalici and Zuc were predominantly inhabited by Serbs. They

17 constituted a much bigger majority than the Muslims.

18 Q. So what happened in that area after the hostilities began?

19 A. After the hostilities began, on the 16th of May, from the

20 direction of Hum the town, and the Kuco Potok, the population came under

21 attack. They tried to defend themselves in Pofalici, and this area of

22 Pofalici here was lost. The Serb civilians had to leave the area, and the

23 defending soldiers sustained enormous casualties. When on the 16th of May

24 this area was seized, forces were regrouped. I'm talking about the BH

25 army forces, or rather, the Patriotic League, the Green Berets, and the

Page 5732

1 Territorial Defence.

2 Q. Can you please slow down?

3 A. And after that they continued with combat operations from the

4 direction of Pofalici, Kuce Potok with a view of capturing, Zuc; and,

5 finally, on the 8th of June, they managed to seize this dominating feature

6 stretching from Vogosca, or rather, Hum, which overlooks Polinje to

7 Rajlovac.

8 Q. In other words --

9 JUDGE ROBINSON: Sorry. What was the precise date of those

10 hostilities which led to the loss of that territory by the Serb forces?

11 THE WITNESS: [Interpretation] This took place on the 16th of May,

12 1992, when Pofalici and the whole neighbourhood of Zuc fell. Since this

13 hilly area was populated, it fell on the 8th of June; and, finally, the

14 Muslim forces took full control of the Zuc feature on the 8th of June,

15 1992.

16 MR. TAPUSKOVIC: [Interpretation]

17 Q. So that was the date?

18 A. Yes.

19 Q. Yes. Was that the date when this separation line was set up?

20 A. Yes.

21 Q. Please, what happened with the population in the area, the

22 majority Serb population? Were there any casualties there is?

23 A. There were many casualties in the area of Pofalic. According to

24 the census and according to the findings of certain commissions, the

25 number of casualties was almost 300.

Page 5733

1 On the 8th of June, when Zuc was finally seized, the majority of

2 casualties were among soldiers and to a lesser degree among civilians, but

3 their entire property was destroyed.

4 Q. And in May, who were the casualties?

5 A. Serbs in Pofalici and, as I said, almost 300 people were

6 casualties in May. Some people say there were even children among them,

7 but I don't know about that.

8 Q. So that was the situation to the north. What was happening and

9 who in April 1992 was in the area of the Mojmilo hill?

10 A. In May 1992, the Green Berets were in the area of Mojmilo,

11 including the Territorial Defence and the Patriotic League. I'm talking

12 about 1992.

13 Q. I'm asking you about April, before the hostilities broke out.

14 A. People were living in Mojmilo. There were a few Serbs, but it was

15 predominantly populated by Muslims.

16 Q. But --

17 A. On Mojmilo, there were some facilities like water-tanks. There

18 was a small JNA unit guarding these facilities.

19 Q. That is exactly why I'm putting this question to you. How did it

20 happen that this JNA unit that was there in April in Mojmilo was not there

21 any longer? That's what I'm asking you.

22 A. It was a small guard unit, and the Patriotic League, the

23 Territorial Defence, and the Green Berets forced them out by using weapons

24 and other means used in a war.

25 Q. Can you tell us when did this exactly happen?

Page 5734

1 A. I don't know exactly. But I do know for sure that between the 3rd

2 and the 10th of May, the armies of the VRS or the JNA were not there.

3 Q. When did the situation on Debelo Brdo and Colina Kapa became the

4 one as you described earlier?

5 A. Debelo Brdo and Colina Kapa had positions that remained unchanged

6 between 1992 and the end of the war.

7 Q. Very well. Under the circumstances, can you explain what was the

8 position of Grbavica, Nedzarici, Dobrinja, and Hrasno? Can you explain

9 their position and where the separation line was?

10 A. In 1992, or rather, in April of that year, and early May, JNA

11 units and later on, on 19th of May, the VRS units held the airport. We

12 had an axis from Lukavica towards Ilidza.

13 Q. I don't know what you mean by that.

14 A. That means that we held both the airport parts of Lukavica, one

15 part of Dobrinja, and Grbavica within the boundaries almost as the ones

16 shown here, although there was some shifting in 1992 towards Grbavica,

17 too. So the positions on Grbavica remained more or less unchanged. There

18 were just some minor shifts here in 1992 in this area.

19 Q. And where were you at that time?

20 A. As far as we're concerned, we moved from the area of Han Pijesak

21 to assist in the evacuation of the army, the 2nd Army that was stationed

22 at Bistrik. We headed out on the 2nd of May; and by the 3rd of May we

23 arrived at Lukavica in the Lukavica sector.

24 Q. Could you please tell me, a lot of mention has been made about

25 protected areas. Can you please us, what was the position of those parts

Page 5735

1 of the town that I just asked you about, in relation to the existence of

2 the protected areas?

3 A. You mean Grbavica?

4 Q. I mean Grbavica, Nedzarici, Dobrinja.

5 A. Well, in early May, no protected areas had been declared yet.

6 Q. Yes. But when this idea was mooted, what can you say in this

7 regard? In view of the position of Grbavica Hrasno, Nedzarici, Dobrinja,

8 was this part of this zone?

9 A. Well, we didn't hold Hrasno at all, but we did hold Nedzarici and

10 Grbavica. And as far as I know, there were no protected areas at that

11 time.

12 Q. And where were the demilitarised zones?

13 A. I heard that Srebrenica was a demilitarised zone, and Zepa, too.

14 I didn't hear about any other zones.

15 Q. Igman?

16 A. Well, Igman was declared a demilitarised zone in 1993.

17 Q. Well, was it demilitarised?

18 A. Well, only for a very brief period of time and then it was

19 demilitarised no longer because the Muslims --

20 THE INTERPRETER: Interpreters note: It is impossible to work

21 because we can hear a lot of background noise.

22 JUDGE ROBINSON: Just a minute, please. The interpreter says that

23 it is impossible to work because she's hearing a lot of background noise,

24 and may I ask that this be checked by the technical personnel.

25 THE INTERPRETER: Interpreter's note: Your Honours, this is

Page 5736

1 because of the microphone that was switched on at the Defence bench.

2 JUDGE ROBINSON: Do you understand that? She says that this is

3 because of the microphone that was switched on at the Defence bench, so

4 that microphone is to be turned off.

5 So let us proceed.

6 MR. TAPUSKOVIC: [Interpretation]

7 Q. I have to ask you, Witness, to speak slowly. You did so last

8 time, but could you please continue doing so because then we could put

9 everything into the transcript.

10 So could you please tell us what happened with Igman, in light of

11 the fact that it had been declared a demilitarised zone?

12 A. Well, the Operation Lukovac 1993 was launched in early July 1993.

13 The units of the Sarajevo-Romanija Corps reinforced with some other

14 elements from other corps, and from the Main Staff got from their lines at

15 Jahorina to the area of Bjelasnica and the village of Lukavica; and then

16 they established this line towards Grdonj and managed to reach this whole

17 area here at Bjelasnica; and then the United Nations reached a decision

18 whereby the units of the Republika Srpska army and the Sarajevo-Romanija

19 Corps should withdraw from the area of Bjelasnica and the large portions

20 of the Igman mountain, and the lines that it could still retain were

21 defined.

22 Q. And was this complied with?

23 A. Well, the Republika Srpska army did withdraw to the lines as

24 defined by the UN, because there were threats that there would be

25 air-strikes if it failed to do so; and as far as I know, I was in one of

Page 5737

1 the brigades of the Sarajevo-Romanija Corps. And the Brigades that were

2 here on those positions really had to withdraw, and that's what at the

3 did. They withdrew all the way down to the lines as they were determined.

4 Q. Who posed a threat to this demilitarised zone after that period

5 and when?

6 A. Well, I was not at the corps command at the time, but we did

7 receive reports, we and the other brigades, that the force of the BH army,

8 the 1st Corps, exploited the fact of our withdrawal and infiltrated the

9 majority of its forces from some of its positions into the mountain of

10 Igman, thus violating the agreement.

11 Q. When did that happen? Can you tell us at least approximately?

12 A. Well, it was sometime in the fall of 1993.

13 Q. And from that time, until the end of the war, who actually held

14 the positions on Mount Igman?

15 A. Well, for the most part, Mount Igman, to be quite precise, 80 per

16 cent of Mount Igman was held by the BH army forces, the 1st Corps, and one

17 portion of Igman was held by the Sarajevo-Romanija Corps as stipulated in

18 the order and the agreement between the -- our forces and the United

19 Nations.

20 Q. And since the BH army held this part of Igman that you just

21 described to us, what areas did it control from those dominant positions

22 if we look at the demarcation line that you explained at length last time?

23 A. Well, in this western area, it controlled this area here. So it

24 didn't move its positions, and the positions were not moved here where

25 they faced the Serbian area of Veljkovici; and then here, the positions

Page 5738

1 were like this, and their forces held these positions and this is how our

2 lines went.

3 Q. I actually asked you something else. From its positions on Mount

4 Igman, the BH army was able to control what areas, when we talk about the

5 demarcation lines?

6 A. Well, those positions made it possible for them to control this

7 area Vojkovici. There are about one thousand houses here, all Serbian

8 households; and this line from the foothills of the Igman, all the way

9 down to these villages, they were able to control this area from their

10 dominant positions; in other words, the inhabits of these villages and the

11 Sarajevo-Romanija Corps units. And here to the west, they were able to

12 control the Ilidza area; and as for the rest, well, they controlled this

13 area, too, from their dominant positions, but this was just a wooded area

14 [Trial Chamber confers]

15 JUDGE ROBINSON: Yes. Thank you. Thank you very much,

16 Mr. Tapuskovic. We're just trying to understand the import of the

17 evidence, and we wondered whether the witness might be able to say whether

18 he has any information as to why Igman was demilitarised by the United

19 Nations.

20 THE WITNESS: [Interpretation] Mr. President, I was not at the

21 command at that time, but we, in the units, received information to that

22 effect from our brigade commanders. I became a member of the corps on the

23 19th of December, 1994; and from that time on, I am able to give you more

24 details about the positions of the corps, and I'm familiar with almost

25 everything that happened at the corps level.

Page 5739

1 JUDGE ROBINSON: Yes. So you don't have any information as to why

2 Igman was demilitarised. You may not have, of course.

3 THE WITNESS: [Interpretation] Well, in all probability, this was

4 because in 1993 there was Operation Lukovac, and the forces of the 1st

5 Corps of the Republika Srpska army managed to reach those units here --

6 those positions here at Malo Pojle and Velika Polje at Igman. And all

7 they had to do was to take this kilometre here to, again, establish the

8 encirclement around Sarajevo, and they were not allowed to do that. So

9 the supply lines for the city would have been broken had that been allowed

10 to happen.

11 JUDGE ROBINSON: Thank you very much.

12 JUDGE MINDUA: [Interpretation] Witness, just to continue with a

13 follow-up question following the President's question.

14 You arrived in the corps on the 19th of December, 1994, after a

15 decision had been made to demilitarise Igman.

16 When you arrived, who was effectively in command of the place, of

17 Mount Igman?

18 THE WITNESS: [Interpretation] When I joined the corps, as you

19 yourself said, the Muslim forces dominated Mount Igman; in other words,

20 the 1st Corps of the BH army.

21 JUDGE MINDUA: [Interpretation] Thank you.

22 THE WITNESS: [Interpretation] Thank you.

23 MR. TAPUSKOVIC: [Interpretation] May I continue?


25 MR. TAPUSKOVIC: [Interpretation]

Page 5740

1 Q. Mr. Veljovic, well, the first question: When did the Republika

2 Srpska army lose its control over the airport?

3 A. The Republika Srpska army, pursuant to a decision of the United

4 Nations and by virtue of signing agreement on the demilitarised zone of

5 the airport, which was to be placed under the control of UNPROFOR, and

6 this was concluded sometime in June, late June or early July 1992 as far

7 as I know, but I -- I'm not sure about the dates. But it was in June or

8 July, that was when the Republika Srpska army forces handed over the

9 airport.

10 Q. And how would you then define the positions of the two sides at

11 that moment after this decision was reached? What is your assessment of

12 the situation at that time?

13 A. Well, when we held the airport, which was until June or July 1992,

14 the BH army forces, by that I mean the 1st Corps, they were in the

15 encirclement within the city of Sarajevo.

16 When our forces pulled-out from the airport in June and July, the

17 forces and the population were no longer in the encirclement, and our

18 position became more difficult and we had to --

19 Q. Just a moment, just a moment. Could you please give shorter

20 answers; and if necessary, the Trial Chamber will seek additional

21 clarification.

22 How did the position of the Republika Srpska army deteriorate

23 after it had handed over the airport?

24 A. After the airport was handed over, the Republika Srpska army found

25 itself in a very difficult situation, in terms of command and control, and

Page 5741

1 in terms of its supply lines, transportation, the evacuation of the

2 wounded and the sick.

3 Q. What happened with the Lukavica-Ilidza route?

4 A. The Lukavica-Ilidza route was cut off at that time.

5 Q. Thank you. And the people from Ilidza, Ilijas, Vogosca, and those

6 areas that were still part of Sarajevo at the time, were they able to go

7 anywhere, to move at all?

8 A. The people from Ilidza, the broader area of Ilidza, and Ilijas

9 were able to move, but it was quite difficult.

10 Q. I would like to ask you to specify. Don't use pronouns. But have

11 you to name the locations, because we can't know what you mean.

12 A. Well, the people from Ilijas, since Ilijas is here to the north,

13 they were able to move towards Vogosca. That route was open, the route to

14 Vogosca. But as far as the Vogosca to Grdonj route, we actually had to

15 build a road here through very rugged train, here, all the way through

16 Hrese, and then onwards to Pale.

17 As for Ilidza, the broader area, there was a road to Lukavica,

18 through Vrace to Pale; and when the airport area was handed over, they too

19 had to move to Rajlovac, Vogosca, and then they had to take this very

20 difficult road that we had to build. It was an macadam road that we

21 built.

22 Q. Why do you say difficult road?

23 A. In view of the fact that this is a macadam road, that it was not a

24 proper road, that the terrain is hilly, and that transportation took a

25 long time, and it was very far away to go the other way around, 50 or 60

Page 5742

1 kilometres was the other road to Ilidza.

2 Q. What were the other difficulties involved? Were there dangers,

3 towards Spicasta Stijena, elsewhere?

4 A. There were dangers since the road went close to the separation

5 lines at the areas of Zuc and Hum and Grdonj, and the Kosova areas, too.

6 So the road could be hit by different weaponry, including mortars, all

7 weapons that had a range of over 500 metres.

8 Q. You say that the road could be hit, and what was it that actually

9 happened?

10 A. Well, what often happened on the road was that people got killed

11 on that road because of the gun-fire coming from the other side. It was

12 soldiers who were killed and civilians who moved air long that road,

13 because there was no other road.

14 Q. That road, say, from to Lukavica, how long was it in actual fact?

15 A. This is where Ilidza is, and then have you to go here, Vogosca,

16 Hrese through Pale, Pale is here, and then only from up here where

17 Trebevic is and then down to Lukavica. So it was 70 or 100 kilometres;

18 whereas, here the road to Lukavica was five to six kilometres. Well, via

19 Nedzarici, it wasn't even three kilometres, viewed from this part here.

20 Q. Thank you. What about people from Ilijas. Did they have any

21 alternative and how could they go? How else could they leave the area?

22 A. This is Ilijas. When they came, they took this other road,

23 Vogosca and here, and then via this road leading to Sokolac. It was a

24 dirt path more or less.

25 Q. When you say that there was practically no road, what were you

Page 5743

1 saying? Can you explain this to the Judges?

2 A. This is a enormous mountain, and there are woods and certain parts

3 from where timber is taken. These were macadam roads. They weren't

4 proper roads. They were only used for heavy trucks that would transport

5 the timber from there. Ozren is the name of that mountain.

6 Q. Please bear in mind that you should start answering questions when

7 the typing stops; and also when you give your answers when the typing

8 stops, that is when we will continue and would you please try to speak

9 slower.

10 A. It's a bit inconvenient for me sitting this way and trying to

11 explain things and point them out. It was much easier in the other

12 courtroom.

13 Q. Can you explain whether you know whether a tunnel existed under

14 the airport?

15 A. There was a tunnel under the airport.

16 Q. Thank you. At the time that is referred to the indictment against

17 General Milosevic, did it function; and if so, how?

18 A. As far as I know, this tunnel functioned from the autumn of 1993

19 onwards; that is to say, the months of November/December 1993, all of

20 1994, and 1995.

21 Q. Can you tell us what actually went through this tunnel; did you

22 know?

23 A. I personally did not see; but according to our intelligence, the

24 tunnel was used for manoeuver purposes of the 1st Corps of the army of

25 Republic of Bosnia-Herzegovina; that is to say, moving from town towards

Page 5744

1 Igman, and from these positions and to Igman, and then also towards Nisica

2 Vesarevn [phoen], the Niksic plateau, and this other area up here. This

3 tunnel was built over here in this area, and it went into Butmir,

4 Hrasnica, and the Hrasnica road further on. That's where the forces

5 moved.

6 Q. Can you tell me about the 1st Romanija Brigade. What positions

7 was it in 1992 and 1993?

8 A. The 1st Romanija Infantry Brigade in 1992 and 1993 was at these

9 positions: Grbavica, Zlatiste, Trebevic, and here, all the way to Grdonj

10 and Spicasta Stijena, and in part, through Jahorina in this area towards

11 Gorazde.

12 Q. Can you tell me where the fiercest fighting took place in relation

13 to the separation line?

14 A. The fiercest fighting took place in the area of Grbavica and here

15 in the area of Nedzarici in 1992, and in view of the fact that there was

16 always fighting in this area, but Nedzarici-Grbavica was where the

17 fiercest fighting took place.

18 Q. Under these circumstances, can you explain what the position was,

19 especially in relation to Grbavica?

20 A. Grbavica was in a fire pocket, as we say, facing Miljacka in the

21 urban area. From Mojmilo and from Debelo Brdo, it was exposed to

22 cross-fire. It was encircled by a firing system. Fire came from Mojmilo,

23 Debelo Brdo, and from in here. There was cross-fire, and in addition to

24 that, there was fire from all areas. So it was as if it were a sack that

25 was fired on. That's why we call it a fire sack, too. And fire came from

Page 5745

1 Nedzarici as well.

2 Q. Can you tell me about the area of Spicasta Stijena and Grdonj?

3 A. As for Spicasta Stijena and Grdonj, since the main feature of

4 Grdonj, which is when viewed from here, from Radava goes to Hrese or

5 Pasino Brdo. That is where the forces of the army of Bosnia and

6 Herzegovina held a dominant position and threatened the village of

7 Mrkovici, and that's where the supplies for the Ilidza and for the

8 north-east and part of the front came.

9 JUDGE ROBINSON: At what time period is this that we're talking

10 about? What year is this?

11 THE WITNESS: [Interpretation] It is 1992, all the way up to 1995,

12 the lines remained unchanged in this area.

13 JUDGE ROBINSON: Because I was going to ask you, Mr. Tapuskovic,

14 whether, having dealt with 1992, you're going to move on to the later

15 period, 1994/1995, which is actually the indictment period.

16 MR. TAPUSKOVIC: [Interpretation] Of course. But it was necessary

17 to explain all of this, in relation to these hills and all these problems,

18 because I think that without that I couldn't ask him anything that is

19 related to the relevant time. That is why I thought that, first of all,

20 the witness should tell me the following.

21 Q. You mentioned Lukavica 1993?

22 A. Lukovac 1993.

23 Q. Lukovac 1993, yes. Were there any similar actions later, with a

24 similar name, except for that particular one that happened then?

25 A. There was no similar action, and the forces of the

Page 5746

1 Sarajevo-Romanija Corps, in view of the personnel levels, could not have

2 carried out such an action.

3 Q. At the time when you were in these areas, what kind of orders did

4 you receive in terms of opening fire and in which situations could you

5 open fire, according to these instructions or these orders?

6 A. Just tell me what year.

7 Q. I'm asking about 1992, but I'm also asking you a general question.

8 A. In 1992, there were conflicts between the army of

9 Bosnia-Herzegovina and the army of Republika Srpska in the entire

10 territory here, in relation to the city and further on, the front line;

11 and from February 1994, when there was a demilitarisation of the

12 artillery, when all heavy weaponry had to be taken out, there weren't

13 supposed to be any clashes in the urban area.

14 Q. We'll get to that as well. I'm asking but when the hostilities

15 broke out. What kind of orders were issued in relation to when it was

16 possible to take military action.

17 A. Military action could be taken only if the positions of the army

18 of Republika Srpska were threatened.

19 MR. TAPUSKOVIC: [Interpretation] Your Honours, I think that I will

20 be allowed to show a document, to show the witness a document that was not

21 on my 65 ter list, but it is on the Prosecutor's list for

22 cross-examination. I think that I can avail myself of such a right.

23 JUDGE ROBINSON: I don't see why not.

24 MR. TAPUSKOVIC: [Interpretation]

25 Q. Mr. Veljovic, I would like to show you a document.

Page 5747

1 MR. TAPUSKOVIC: [Interpretation] The 65 ter number is 03140. It's

2 a Prosecution document that I got after the witness took his solemn oath.

3 Could that document please be shown to the witness.

4 THE WITNESS: [Interpretation] Could it please be enlarged a bit?

5 MR. TAPUSKOVIC: [Interpretation] I don't see the English version.

6 Oh, yes. Yes.

7 Q. Please have a look at this document. Please look at its date.

8 Can you tell us what the date is of this document?

9 A. The 13th of September, 1992. The command of the 1st Romanija

10 Infantry Brigade Command.

11 Q. Slower, slower, please. What is this?

12 A. This is a regular combat report.

13 Q. Thank you. Who signed it?

14 A. I can't see. Oh, it's me. It says KIK, Captain First Class,

15 Stevan Veljovic.

16 Q. Tell us what paragraph 1 says. If you can, read it out and tell

17 us whether that is the way things actually were, but read it out loud.

18 A. "During the night, the enemy was sporadically opening sniper and

19 infantry arms fire on all defence positions of the brigade." I cannot

20 read a certain part of it. "From 1600 hours, an 82 millimetre mortar was

21 operating on Soping, which resulted in the killing of one civilian;

22 whereas, another civilian was severely wounded in various intervals. An

23 "osa" was operating."

24 Q. Thank you. Was that the way it was?

25 A. Yes, that was the way it was.

Page 5748

1 Q. Wait and give us your answer slowly.

2 Can you read out paragraph 2?

3 A. Paragraph 2: "Units of the brigade respond only in exceptional

4 circumstances with gun-fire when enemy fire reaches such intensity that it

5 endangers the lives of our soldiers."

6 Q. Just a moment. Thank you.

7 JUDGE ROBINSON: Why don't have you him tell us -- have him tell

8 us or explain to us the references to Soping and osa in paragraph 1.

9 MR. TAPUSKOVIC: [Interpretation] That's precisely what I wanted to

10 ask him after this.

11 Q. On whose territory Soping was?

12 A. Soping was in the territory of the army of Republika Srpska.

13 Q. Thank you. What does osa signify?

14 A. It was a firing at the Jewish cemetery held by the Romanija

15 forces. Osa was an anti-rocket launcher intended to destroy bunkers and

16 other armoured vehicles.

17 Q. Here you described under which circumstances it was allowed to

18 open fire. Was that the essence of the orders that you were receiving

19 throughout the whole war? Did you receive any different orders in any

20 sense?

21 A. In 99 per cent of cases, the commanders issued orders only to open

22 fire if we came under attack, not to fire on the enemy and not to provoke

23 any armed conflict. This is the kind of order that we were receiving.

24 Q. Thank you. Item 4, can you please look at it and tell us if what

25 you wrote in this document is true.

Page 5749

1 A. I can't see exactly the time, but it says here that in a passage

2 beneath Soping, one killed civilian was found. The case was reported to

3 the military police which has been investigating it.

4 Q. Thank you. Was that correct?

5 A. Yes. It is correct, because this is what I wrote in my report,

6 obviously, but it's been a long time ago and it's difficult for me to

7 remember.

8 Q. Thank you.

9 MR. TAPUSKOVIC: [Interpretation] I would like now to show you

10 another document, which is on my list, 65 ter list, but it was also on the

11 Prosecution list, and it's still on the Prosecution list of documents that

12 the Prosecution intends to use with this witness. The number of this 65

13 ter document is 0169 -- 01969. It's a bit longer document.

14 JUDGE ROBINSON: Mr. Waespi.

15 MR. WAESPI: Good morning, Mr. President.

16 While we're waiting, what is the fate of this document the Defence

17 has shown to the witness?

18 JUDGE ROBINSON: Are you prompting him to tender it?

19 MR. TAPUSKOVIC: [Interpretation] Yes, Your Honours, I'm tendering

20 it as a Defence exhibit to be admitted.

21 JUDGE ROBINSON: Mm-hm. Yes, we admit it.

22 THE REGISTRAR: 65 ter 03140 becomes D185, Your Honours.

23 MR. TAPUSKOVIC: [Interpretation] So this is another document. I'm

24 not sure if we have an English version thereof.

25 Can we just move to the end of this document first; that is, page

Page 5750

1 2.

2 Q. Do you see who signed this document?

3 A. Commander Major-General Dragomir Milosevic.

4 Q. A while ago you were talking about your combat report. Can you

5 please look at the penultimate passage of your 1992 combat report. Was

6 this combat report in line with what is written here?

7 A. You mean item 8?

8 Q. I'm referring to the last passage of item 8. Can you please read

9 it?

10 Please, sorry. Can you please read the last passage of item 8?

11 A. "Envisage and make concrete tasks as to who is to neutralise and

12 destroy fire points, machine-gun, and sniper nests which prevent movement

13 around Grbavica, Ilidza, Vogosca, Kasindol," et cetera.

14 Q. Thank you.

15 MR. TAPUSKOVIC: [Interpretation] Please, my screen is

16 malfunctioning and I'm not able to follow the cursor.

17 Q. This order, is it in the spirit what you wrote in your combat

18 report?

19 A. Yes, it is.

20 MR. TAPUSKOVIC: [Interpretation] Can we go back now to page 1.

21 Q. Can you please first look at the date? What is the date of this

22 document?

23 A. The 12th of August, 1994.

24 Q. Can you now look at the end of this first page, specifically item

25 6, or rather, 7, and its last sentence.

Page 5751

1 A. Can you please enlarge this a bit?

2 Q. Look at it.

3 A. Very well.

4 Q. No. Item 4, it begins with, "four" under item 7. It is the last

5 sentence, the very last sentence.

6 A. I see 7. It's not item 4; it's the 4th Mixed Artillery Regiment.

7 Q. Can you please read it out?

8 A. The 4th Mixed Artillery Regiment is to draw up a fire plan in the

9 region of" --

10 THE INTERPRETER: Interpreter's correction: Mixed Artillery

11 Division of the 1st Sarajevo Motorised Brigade is to prepare fire

12 according to the brigade commander's decision. The 4th Mixed Artillery

13 Regiment is to draw up a fire plan in the region of Bascarsija and

14 Vrbanja. Fire is to be open in compliance with the order of the SRK

15 commander."

16 MR. TAPUSKOVIC: [Interpretation]

17 Q. Can you now explain to me what was the position of the

18 Sarajevo-Romanija Corps throughout the war vis-a-vis Bascarsija?

19 A. This is Bascarsija, this area here, and it's the most important

20 part of the town in the cultural and historical sense. This particular

21 neighbourhood, it was built in the Turkish architectural style with very

22 meager and fragile material. It comprised small houses and buildings.

23 There were only a few artillery shots that would require to destroy this

24 whole area. That is -- that is why these buildings were protected

25 strictly and they remained unchanged and intact to this date, and anyone

Page 5752

1 with verify and check that.

2 Q. Was that the reason why such a decision had to be made only with

3 the approval or on orders of the commander of the SRK?

4 A. Yes. And this was particularly stressed and reports were being

5 sent to units, saying that such buildings the civilian population and

6 roads and movements of people shall not be targeted at any cost, except on

7 his specific orders, and he was the one not to ever issue such an order.

8 Q. Were there any fire from that part of the town targeting the VRS?

9 A. In view of the deployment of the BH army and its corps, or support

10 equipment, including mortars of all calibres, were deep into the defence

11 area of the corps. If the line was here on Colina Kapa, Rastovac and

12 other features, then the mortars positioned not far away from Bascarsija

13 were firing at our positions, and we were not allowed to respond because

14 we would have destroyed this cultural and historical area and bring about

15 condemnation by the international community and the United Nations. They

16 used this in a very ingenious way in order to try and place blame on us.

17 MR. TAPUSKOVIC: [Interpretation] I kindly ask for this document to

18 be admitted as a Defence exhibit.

19 JUDGE ROBINSON: We admit it.

20 THE REGISTRAR: As D186, Your Honours.

21 JUDGE HARHOFF: Counsel, reading the order from General Milosevic,

22 it still seems to me that the order requires that a fire plan be drawn up

23 in the region of Bascarsija and Vrbanja, and I'd like to -- to be sure

24 that it is understood to mean that the SRK should prepare a fire plan and

25 determine certain targets within Bascarsija. Is that correctly

Page 5753

1 understood, that the idea of this order was to actually to target houses

2 in Bascarsija?

3 Witness, can you answer that question directly?

4 THE WITNESS: [Interpretation] Yes. It was not to identify the

5 targets. He strictly demanded, in view of the fact that it was a cultural

6 monument, to make it clear to subordinate units, that targets in

7 Bascarsija can be engaged only and solely on his order. There's this

8 Vrbanja mosque crossing the Miljacka river and Bascarsija were not under

9 any circumstances to be targeted; and if that were to happen, that could

10 only happen on his orders.

11 JUDGE HARHOFF: And do you know then if such orders were ever

12 given?

13 THE WITNESS: [Interpretation] These orders were never given. Had

14 they been given, this kind of neighbourhood built of very weak material

15 would have been completely destroyed, and that would have been a reason

16 for another very strong condemnation with regard to what was happening in

17 Sarajevo.

18 JUDGE HARHOFF: Thank you.

19 THE WITNESS: [Interpretation] Thank you, too.

20 MR. TAPUSKOVIC: [Interpretation]

21 Q. Witness, tell me, you, nevertheless, knew where these firing

22 positions were on the Vrbanja bridge, and the SRK also knew where these

23 positions were, particularly since you were there since the beginning of

24 the war. You knew where these firing positions were, didn't you?

25 A. Yes. By observing from a certain part, we acquired information

Page 5754

1 about the location of enemy firing positions for support. I'm referring

2 to 82 metre, 120-millimetre, and 60-millimetre mortars. Most of them were

3 deployed in the inner-city.

4 Q. Thank you. We will come to that later.

5 A. Cengic Vila, Bascarsija.

6 Q. We'll come to that later. What I wanted to ask you to tell the

7 Judges: Even if you knew where these firing positions relating to

8 Bascarsija were, was there ever any order issued to fire upon Bascarsija?

9 A. There was never any order issued to fire any heavy weaponry on

10 Bascarsija, Cengic Vila, or any part of the town, except on the separation

11 line and military positions. Mortars were used to target military

12 position, but there was a strict ban referring to all other parts, not

13 only Bascarsija, but Bascarsija was particularly stressed because of its

14 cultural and historical importance. It was so important that there was no

15 target.

16 JUDGE ROBINSON: Just one moment, please.

17 [Trial Chamber confers]

18 JUDGE ROBINSON: Mr. Tapuskovic, I'm going to ask the witness

19 whether this was an offensive plan or a defensive one.

20 THE WITNESS: [Interpretation] Well, from 1992 the Republika Srpska

21 army, or, to be more specific, the Sarajevo-Romanija Corps, carried out

22 only one defensive operation and that was Lukovac 1993. All the other

23 offensive actions, we actually did not carry out any other offensives. We

24 only defended ourselves until the end of the war.

25 JUDGE ROBINSON: Let me see if I understand that because the

Page 5755

1 transcript says that, from 1992, the Republika Srpska army, or more

2 specifically the Sarajevo-Romanija Corps, carried out only one defensive

3 operation, and that was Lukovac 1993; and then your last sentence was:

4 "We only defends ourselves until the end of the war." So could you just

5 clarify the answer for me.

6 MR. TAPUSKOVIC: [Interpretation] Your Honour, the witness, as far

7 as I was able to understand him, because I speak the same language, he

8 said offensive and then he corrected himself, and then he said it was

9 defensive; and then he corrected himself and he said offensive, so, hence,

10 this misunderstanding. The only offensive operation was Lukavica 1993.

11 THE WITNESS: [Interpretation] Lukovac, 1993. The only time when

12 we launched an attack was in 1993 when we carried out Lukovac Operation.

13 For the rest of the time, the Sarajevo-Romanija Corps defended itself

14 against the 1st Corps of the BH army, which launched several offensive

15 operations: The Death and Life Operation, Koverat 1, Koverat 2, and then

16 the last one was T-95 Operation here in Sarajevo.

17 JUDGE ROBINSON: So your answer covers the period 1994 and 1995, as

18 well as 1993.

19 THE WITNESS: [Interpretation] [No interpretation]

20 MR. TAPUSKOVIC: [Interpretation]

21 Q. Now I would ask you to tell me when the 1st Romanija Brigade moved

22 to other positions from the positions that it manned until 1993?

23 A. The 1st Romanija Brigade, following Lukovac 1993 Operation, once

24 this position here was broken, moved from Jahorina. One of its battalions

25 moved up to Bjelasnica and to positions above Igman; and then in the

Page 5756

1 spring of 1994, it was tasked with taking up to the positions up here at

2 Niksic plateau, from the village of Ajdanovici to the village of

3 Kridinici. So these were just the two battalions in 1994 and in

4 November --

5 THE INTERPRETER: Microphone for the counsel, please.

6 MR. TAPUSKOVIC: [Interpretation]

7 Q. You have to answer your question for me to continue.

8 What happened at the Niksic plateau in 1994? Why did you have to

9 move two battalions to that location? So now I'm talking about 1994 and

10 1995.

11 A. Well, in February, a demilitarised zone was established, following

12 the signing of an agreement, and the heavy weapons had to be moved away

13 from the city of Sarajevo to a line 20 kilometres from the city centre,

14 and all the artillery had to move to those positions and placed under the

15 control, and that went both for the artillery of the Sarajevo-Romanija

16 Corps of the VRS and the 1st Corps of the BH army.

17 The corps forces -- well, in fact, it benefitted the 1st Corps

18 most, because they knew that the agreement had been signed, that there

19 would be no fighting --

20 JUDGE ROBINSON: Mr. Tapuskovic, how does what happened in the

21 Niksic plateau in 1994 impinge on the location identified in the

22 indictment, which is Sarajevo? This raises a question of relevance, and

23 that's why I'm asking you.

24 MR. TAPUSKOVIC: [Interpretation] Well, the area of responsibility

25 of the Sarajevo-Romanija Corps --

Page 5757

1 Q. Well, in fact, was the Niksic plateau within this area of

2 responsibility?

3 A. Yes.

4 Q. And what happened after the heavy weapons had been moved out or

5 placed in storage? What happened then?

6 A. In 1994, in February, agreement was signed stipulating that all

7 heavy weapons had to be moved out of a zone, defined in the agreement to

8 an area 20 kilometres away from the city centre. That went for both

9 party, both warring factions, and these weapons had to be placed under the

10 control of UNPROFOR. So the heavy weapons could not be used.

11 There was a prohibition on the use of happy weapons, and all

12 fighting was prohibited in a 20-kilometre zone. The forces of the 1st

13 Corps of the BH army utilized their human resources potential, moving

14 those forces out of the city through the airport tunnel deploying them on

15 various areas.

16 JUDGE ROBINSON: This may be a procedural misunderstanding. I

17 asked you, Mr. Tapuskovic, to explain the relevance of evidence relating

18 to the Niksic plateau, the relevance to the indictment which is concerned

19 principally with Sarajevo, but you don't answer my question by asking the

20 witness further questions.

21 MR. TAPUSKOVIC: [Interpretation] Well, Your Honours, let me

22 explain to you. You know that a witness, who was not a protected witness,

23 came here to give evidence. It was a high-ranking officer from the BH

24 army, the only such personage to give evidence here, and he testified that

25 after the zone of exclusion of heavy weapons was established that the 1st

Page 5758

1 Corps of the BH army employed the following tactics: They would move

2 their fresh troops through the tunnel and attack Ilidza, Ilijas, Vogosca,

3 the Niksic plateau in particular, the northern part; and to the south,

4 they would attack Trnovo, and they would provoke the other side at the

5 lines where the heavy weapons had been moved to.

6 This was the tactics employed by the BH army throughout the fall

7 of 1994 from the time when Dragomir Milosevic took over the command, and

8 it actually began in the spring of 1994, as soon as the total exclusion

9 zone was established, and this lasted until the offensive launched in May

10 1995. And Witness, this witness here before us, knows a lot about those

11 events.

12 [Trial Chamber confers]

13 JUDGE ROBINSON: Mr. Waespi, on the question of relevance of

14 evidence relating to the Niksic plateau.

15 MR. WAESPI: Mr. President, we also don't think it is relevant,

16 but we have a certain understanding that the Defence, with its first

17 witness, wants to lay out the land, so that is the reason why we didn't

18 object that far.

19 JUDGE ROBINSON: Thank you.

20 We'll take the break now.

21 --- Recess taken at 10.33 a.m.

22 --- On resuming at 10.52 a.m.

23 [Trial Chamber confers]

24 JUDGE ROBINSON: Please continue, Mr. Tapuskovic.

25 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honour.

Page 5759

1 Q. Mr. Veljovic, I would like to ask you to answer as briefly as

2 possible and as slowly as possible. I will now take you through another

3 of documents, but we have to make sure that we don't overlap and that we

4 use the time allotted to us as efficiently as possible.

5 Now I have to move on to the time-period in which General

6 Milosevic was the commander of the Sarajevo-Romanija Corps. You said that

7 you knew, approximately, when he was pointed the commander of the

8 Sarajevo-Romanija Corps?

9 A. Yes.

10 Q. When was that?

11 A. Well, as far as I know, in August 1994.

12 Q. And could you please tell me, first of all, what happened in this

13 period in August 1994? What characterised this period in as simple terms

14 as possible?

15 A. Well, since the total exclusion zone was established while General

16 Galic was the commander, prohibiting the use of happy weaponry and the

17 fighting in the city, the Muslim forces, the 1st Corps of the BH army, was

18 in a favourable position because they knew that there would be no fighting

19 in the city area, and it concentrated its forces on the Trnovo axis and

20 the Niksic plateau in order to cut shorter this front here and to

21 re-establish the front here at Jahorina and to connect its lines here at

22 Pale, to put us in an untenable situation, to put in those pockets of

23 fire. That's what they wanted to do, to make our situation even more

24 difficult than it used to be.

25 Q. Thank you. And where were the casualties, both civilian and

Page 5760

1 military, in this period?

2 A. The lives of soldiers and civilians in this period were lost in

3 the Trnovo theatre of war and in the Niksic plateau and a small part of

4 the Ilijas theatre. All the other areas, the Serbian Ilidza, Grbavica,

5 Nedzarici, and in particular this densely populated area, they were

6 protected. This is where the 1st Corps was positioned, and this is where

7 most of the people were concentrated, the highest density of population.

8 Q. Now I would like to show you a document.

9 MR. TAPUSKOVIC: [Interpretation] That's DD00-264 -- 2462.

10 Q. And could you please explain to the Judges very slowly where does

11 this document originate from, what is the date, what are its contents? So

12 could you please answer these questions. Three questions, but you can

13 answer them once you've had a look at the document.

14 A. This document is from the Republic of Bosnia and Herzegovina,

15 staff of the Supreme Command of the Armed Forces. The date is the 1st of

16 November, 1994. It's a report on great combat achievements of the 1st

17 Corps units.

18 Q. Who signed this document?

19 A. Well, I can't see it now. This document was signed by the

20 commander of the Main Staff, of the General Staff; in other words, that

21 was General Rasim Delic.

22 Q. All those things that you described to us regarding the fighting,

23 does this correspond what it is says here in the first paragraph of this

24 document. Could you please read it?

25 A. Yes, I can. "In the last few days, the units of the -- units and

Page 5761

1 commands of the 1st Corps continued combat operations in the areas of

2 Bjelasnica and Treskavica towards Trnovo and Roboj and made great

3 achievements in liberating the territory and seizing war booty, which

4 consisted of combat equipment unprecedented in quantity and usefulness."

5 Q. Thank you. And do you know what units they used to achieve those

6 results?

7 A. Well, as can you see from this text, those units were the units of

8 the 1st Corps of the BH army in the areas that I just specified.

9 Q. Can you please look at the fourth paragraph, and in fact if can

10 you read it.

11 A. Yes, I can. "The 1st Corps units have been reinforced by war

12 booty as follows: 70, 55 tanks; 122-millimetre self-propelled Howitzer;

13 five armoured transporters; five different types of cannon; two

14 anti-aircraft guns; five anti-aircraft machine-guns; 12 different calibres

15 mortars; six anti-aircraft rockets."

16 Q. Thank you.

17 A. "Seven trucks, a water tank truck, a bus, a large number of luxury

18 cars, and large amount of different calibre infantry and artillery

19 ammunition."

20 Q. Do you know that this was in fact what happened?

21 A. Yes.

22 Q. And now let us move on to the penultimate paragraph, if you can

23 just read it. Can you see it, and does this correspond to the events on

24 the ground?

25 A. Is this the one starting with "I congratulate"?

Page 5762

1 Q. Yes.

2 A. "I congratulate the brave fighters an officers" --

3 Q. Go slowly.

4 A. "I congratulate the brave soldiers and officers, all units and

5 commands of the 1st Corps for taking a direct part in the planning,

6 preparation, and carrying out of combat operations that produced such

7 results."

8 Q. Was this something that, in fact, was the dominating feature of

9 the fall of 1994?

10 A. Yes, that is so, in light of the fact that the demilitarised zone

11 was used to attack the flanks in order to achieve those results, because

12 they knew that the 1st Corps of the Republika Srpska army would not be

13 able to respond and to try and link up the front line here in the city

14 area. And, in fact, they used their superiority in personnel to achieve

15 those results.

16 Q. Was there any combat at the other separation lines after all, the

17 one us that referred to just now?

18 A. Yes, but only from time to time, and individually. We soldiers

19 called this sporadic gun-fire. It came from town, so that they would in

20 this way engage part of our forces; and since we did not have a great deal

21 of manoeuvring force, we did not manage to appose them at the flanks, in

22 view of the high personnel levels of the 1st Corps of the army of

23 Bosnia-Herzegovina.

24 Q. Thank you. Now, when that period elapsed, what happened then?

25 A. When that period elapsed - again, I'm referring to the period of

Page 5763

1 1994 that elapsed - we were in an unfavorable position on our flanks.

2 Also, at the Niksic plateau, there was some movement and all conditions

3 were created for fully destroying the Sarajevo-Romanija Corps and the

4 population that lived in the area.

5 In 1994, on the 23rd of December, a new agreement was signed about

6 total cessation of hostilities; and for the duration of four months, from

7 the 1st of January, 1995, up to the month of April, or rather, the 1st of

8 May, 1994, this was a cease-fire on all fronts in the former

9 Bosnia-Herzegovina. Politicians signed this, and the commander of the

10 Main Staff, Rasim Delic, most probably with the commander of the Main

11 Staff or his envoy, on the 31st of December, 1994, signed that.

12 Q. Thank you. I don't really need all those details.

13 Tell me now, what was this four-month period like? Up to the

14 month of May, what happened during that period?

15 A. As for the front of the Sarajevo-Romanija Corps and the 1st Corps,

16 up until the end of April, it was calm most of the time, expect for

17 sporadic fighting, and the preparations of both armed formations to train

18 further; whereas, in other areas, especially the Vlasic area towards

19 Banja Luka.

20 Q. We're not interested in that here?

21 A. Let me just explain.

22 Q. Please don't. We don't have time for that.

23 Now tell me briefly, when was it that you arrived at the Main

24 Staff of the Sarajevo-Romanija Corps?

25 A. The command of the Sarajevo-Romanija Corps, not the Main Staff?

Page 5764

1 Q. Yes.

2 A. As for the command of the Sarajevo-Romanija Corps, I arrived there

3 on the 19th of December, 1994?

4 Q. Thank you. Can you briefly describe what the chain of command

5 looked like in that situation when you arrived there? I mean, you were

6 there at headquarters, right?

7 A. Yes.

8 Q. And what did things look like?

9 A. The headquarters, the staff, was staffed only by one-fifth; that

10 is to say, only 20 per cent of the necessary personnel, and that is the

11 way things remained all the way up to the end of the war. At the head of

12 the corps was General Milosevic. We issued orders to tour units in order

13 to have the cease-fire observed.

14 Q. Who issued these orders?

15 A. The Main Staff issued these orders, and the orders were carried

16 out by the commander towards his subordinate units.

17 Q. In these conditions of war, what was the authority vested in

18 individual commanders at levels below the level of the command of the

19 Sarajevo-Romanija Corps?

20 A. The authority of the commanders of the lower ranking units, after

21 the cease-fire agreement was signed, were non-existent in their combat

22 zones respectively until they would receive orders from the corps

23 commander.

24 Q. Do you know anything about the role of the liaison officer?

25 A. The role of the liaison officer, what I know about that is that

Page 5765

1 liaison officers were in the same building where we were. And from time

2 to time when Brigade commanders reported at the staff, they would also

3 come from time to time to report; and most probably, they directly

4 reported the corps commander, but I did not know about everything that

5 went on.

6 MR. TAPUSKOVIC: [Interpretation] Your Honours, lest I forgot. The

7 document DD00-2462, I would like to have it admitted into evidence as a

8 Defence exhibit.


10 THE REGISTRAR: As D187, Your Honours.

11 MR. TAPUSKOVIC: [Interpretation] .

12 Q. Can you tell the Judges whether you remember when you attended

13 these talks between Milosevic and the liaison officers? Can you remember

14 any of this? What was discussed primarily?

15 A. Well, what was discussed primarily were certain meetings that were

16 being scheduled, and then also helicopter flights by UN officers so that

17 fire would not be open, then also to allow free passage to humanitarian

18 convoys through our attempts, also not to have roundabout roads taken,

19 then also have to wounded persons from the protected areas like Grdonj to

20 be transported into Sarajevo for treatment. That's about it. I didn't

21 know about anything else.

22 Q. What was your duty? What was it that you did?

23 A. I was operations officer in the corps. In the Corps Staff, I was

24 subordinated to the Chief of Staff of the corps to the deputy commander of

25 the commander; that is to say, General Milosevic, and that was Commander

Page 5766

1 Cedomir Sladoje.

2 Q. What was it that you did specifically? Did you have any

3 particular task?

4 A. The operations department where we conducted teaching and training

5 for improving the units and collecting combat documentation; and then

6 after that, according to this combat documentation, we planned our

7 Defence, and the commander and others would make certain corrections in

8 those plans.

9 Q. Thank you. Did you use this cease-fire for some kind of

10 preparations and for training your men?

11 A. Yes.

12 Q. Please, I'm going to show you a Prosecution Exhibit, P680, which

13 is on the 65 ter list of the Defence, so P680 is the number.

14 Can you take a look at this? Can you tell us whose document this

15 is, what the date is, and what this pertains to?

16 A. This is a document of the Sarajevo-Romanija Corps. The 5th of

17 January, 1995 is the date. Drafting of the order for training in 1995,

18 order.

19 Q. Thank you. Thank you. Do you see this note up here?

20 A. Yes.

21 Q. Can you tell us -- well, actually don't give any answers before I

22 finish my question.

23 Can you see this note? What does this note state?

24 A. Yes. This note is addressed to the operations officer, to me, to

25 Major Veljovic.

Page 5767

1 Q. According to these instructions, what were you supposed to be do?

2 A. Let me just read the first paragraph, and then it is going to be a

3 bit clearer.

4 You moved this a bit, so it's not very good. This is what it

5 says: "Pursuant to the instructions for training in 1995, and -- or

6 rather, the Main Staff of the army of Republika Srpska, strictly

7 confidential, number 03/4-2571/94. And in order to thoroughly and

8 realistically plan the substance and forms of training in 1995, as well as

9 to meet the deadlines set in the Main Staff instruction, I hereby" -- I

10 can explain this.

11 Q. Well, please explain what it was that you were supposed to do, but

12 as briefly as possible.

13 A. My operations organ was supposed to carry out the teaching, and

14 this had to do with everything in relation to our life, work, and teaching

15 there. And at every moment the army had to carry out training every year.

16 The Main Staff of the army of Republika Srpska is the creator of this

17 training; and on the basis of its order, on the basis of the order of the

18 Main Staff of the army of Republika Srpska, all subordinate units --

19 Q. Thank you.

20 A. -- have to carry out training.

21 Q. Does this particularly pertain to all units in the actual sense of

22 the word or to the weapons used by the units?

23 A. Yes, in all corps.

24 Q. Wait for my question. Wait until you see it there, and then give

25 me your answer. Can you answer this question for me?

Page 5768

1 A. Yes. In terms of all the corpses of the army of Republika Srpska,

2 training was carried in accordance with the order issued by the Main

3 Staff.

4 Q. For what particular weaponry, if you can tell me?

5 A. In terms of planning, training, we would reduce some of the

6 training into brigade level, battalion level, company level, and certain

7 types of training are carried out by the command itself, the command of

8 the Sarajevo-Romanija Corps.

9 MR. TAPUSKOVIC: [Interpretation] Can this document be admitted

10 into evidence as a Defence exhibit as well? Oh, I'm sorry. I'm sorry.

11 It's already a Prosecution Exhibit. Thank you. Well, it's already a

12 Prosecution Exhibit.

13 Now I would like to put yet another Prosecution Exhibit to the

14 witness, P683 -- or rather, P684.

15 Q. Can you have a look at this document quickly, briefly, tell us

16 what this is, whose document, what's the date, and what is its essence? I

17 don't want to dwell on it very long.

18 A. I signed this and this other person typed it out, if you see this

19 SV and the other initials. So I worked on drafting on this document. It

20 was signed by General Milosevic.

21 Q. Just a moment. Just a moment, please. Since we're talking about

22 documents anyway, a proper document, what does a proper document contain?

23 A. A proper document contains the information on who it was that

24 dictated the document, who typed it out on a typewriter, and who signed

25 the document.

Page 5769

1 Q. Who drafted this document, and what does this pertain to?

2 A. That's me, SV, Stevan Veljovic, and the typist, and the document

3 was signed by Dragomir Milosevic, commander.

4 Q. Can you tell us what it contains?

5 A. Could it please just be moved down a bit, so that I see the

6 document?

7 "The commander of the Sarajevo-Romanija Corps, strictly

8 confidential, number 20/04-20, the 19th of January, 1995."

9 Q. Please, please. Try just to read it, and tell what you say this

10 is.

11 A. This is an order on assigning and dispatching sniper instructors

12 for training at the Jahorina barracks. It's an order.

13 Q. There. Now who organised it?

14 A. This corps was organised -- this course was organised by the

15 corps.

16 Q. What was the purpose?

17 A. Training snipers, sniper instructors, for carrying out their

18 combat tasks at the separation lines, since they were highly untrained and

19 they did not know how to use -- well, I mean, the teaching organ of the

20 Main Staff attempted to carry out this training of sniping instructions,

21 because it was only soon after the conflict broke out that snipers were

22 introduced and many people did not each know what a sniper was.

23 Q. What kind of tasks for what kind of tasks?

24 A. Well, strictly military tasks, and one knows what it is that

25 soldiers who are snipers are supposed to, to destroy military objectives.

Page 5770

1 MR. TAPUSKOVIC: [Interpretation] This is a document that was

2 already admitted -- that has already been admitted.

3 Q. Now, tell me, while you were in this position that you were in,

4 what can you tell me about General Dragomir Milosevic? Where was he most

5 of the time, and what was it that he did?

6 A. General Dragomir Milosevic was commander of the corps and he was

7 in charge of the units of the command, and he was made in charge by the

8 Main Staff. He was at the command post in Lukavica, and then he was at

9 forward composts in Trnovo and at the Niksic plateau. And everywhere he

10 was he was, as a rule, at the command post.

11 Q. Can you tell us where he spent most of his time? Please look at

12 the typing.

13 A. He spent most of his time touring units and positions, and he

14 would invariably return to the command post in Lukavica or the two forward

15 command posts towards the Niksic plateau or Trnovo.

16 Q. Did you ever hear any of his orders, and what did his orders

17 pertain to?

18 A. Since the corps was in a very difficult position, it had suffered

19 enormous losses in the preceding period of the war, his position was that

20 the corps should take defensive positions and that it should be properly

21 fortified because we were expecting that the forces of the army of

22 Bosnia-Herzegovina would attack us any minute. And wherever he went, he

23 spoke to soldiers and officers at these positions and said that fire

24 should only be opened at enemy soldiers and no one else, and that they had

25 to pay particular attention to fire coming from heavy weapons, and this

Page 5771

1 pertained to the weapons of the other side.

2 And the Geneva Convention had to be observed at all costs because

3 he said that there is responsibility after every war and probably this

4 one, too, and that is what he would say to his soldiers. And at a front

5 line this big, perhaps there were some omissions that he could not have

6 prevented because people in these units had different kinds of problems

7 and --

8 Q. Thank you. Thank you.

9 Could you now please explain to the Trial Chamber, especially this

10 period from January up to May. Did you have information about this, what

11 the army of Bosnia-Herzegovina would do?

12 A. Yes.

13 Q. What kind of information?

14 A. The BH army had violated the truce. In February 1995, they

15 carried out the Vlasic Operation. It was a broad operation aimed at the

16 1st Corps of the VRS towards Banja Luka, and they achieved significant

17 result by capturing Mount Vlasic.

18 Q. Thank you. Thank you.

19 A. And we had information that there was a impending attack on us

20 because the BH army was preparing such an attack.

21 Q. Describe for us this period between January and May at the command

22 post and at these specific positions?

23 A. As far as the truce around Sarajevo is concerned, it was more or

24 less observed by both parties until May, except for some sporadic

25 incidents that were not of any major significant. But the units on both

Page 5772

1 side, that is our corps and their side as well, were conducting training.

2 They are training for offensive operations, and we were training for

3 defensive operations.

4 Q. Can you tell me what started happening in early May?

5 A. In early May, units of the army of Bosnia and Herzegovina resumed

6 intensive fighting in the area Treskavica and Trnovo front from the town

7 towards Debelo Brdo.

8 Q. I'm going to show you now document DD00-195 [as interpreted]. And

9 if you please can just take a look at it and tell me briefly whether this

10 corresponds to what you just said. Please look at it carefully.

11 MR. TAPUSKOVIC: [Interpretation] The number is DD00-1925.

12 Q. Here there's mention of certain places. Do you remember this?

13 And, in particular, what do these figures tell you, especially the

14 sentence preceding the list of these numbers?

15 A. "The army of the Bosnia-Herzegovina 1st Corps command, strictly

16 confidential." This is submitted to the army of Bosnia-Herzegovina and

17 General Staff Karkin. It's an entering combat report 8-0, 330 hours [as

18 interpreted].

19 On the morning of the 5th of May, 1995, we received an entering

20 combat report from the forward command post of the 14th Division,

21 Bijela Lijeska, which we are transmitting in its entirety. From 0930

22 hours, the Chetniks directed heavy artillery and mortar fire on the

23 Djokin Toranj, trig point 2086, firing around 1.000 shells. At around

24 1930, the Chetniks seized Djokin Toranj. During the night work was being

25 done to establish a new line of defence which we held before Djokin Toranj

Page 5773

1 was seized. Since we have used up around 1.000 shells and grenades over

2 the past four days, we need the following replenishment: 60-millimetre

3 shell --

4 Q. Very well. We see the list. What can you tell us? What actually

5 happened here with this Djokin Toranj?

6 A. Djokin Toranj is at the linkup point here between the Herzegovina

7 Corps and the corps in the area of responsibility of the Herzegovina

8 Corps. This is the linkup point between the two corps of ours.

9 Q. Who took this location first?

10 A. The 1st and the 4th Corps of BH seized these positions in a

11 concerted action.

12 Q. What was the conflict about?

13 A. The conflict was about who was going to take full control of this

14 small feature. That's a hill on Treskavica called Djokin Toranj.

15 MR. TAPUSKOVIC: [Interpretation] Can we also please have this

16 document admit as a Defence exhibit, because it shows the commencement of

17 the may conflicts.


19 THE REGISTRAR: As D188, Your Honours.

20 MR. TAPUSKOVIC: [Interpretation]

21 Q. Can you please now look a document DD00-1747.

22 A. Can I please have it enlarge it a bit.

23 MR. TAPUSKOVIC: [Interpretation] Your Honours, here, I have only a

24 portion of this document translated, and I would like to put it to

25 witness. If he can first look on page 1, whose document this is, and then

Page 5774

1 I'm going to ask him about the portion that was translated because I had

2 to arrange for a translation myself. Oh, yes, yes. We did receive the

3 whole translation. Now we have it on the screens.

4 Q. So who issued this document, sir?

5 A. The 1st Corps command of the BH army issued this document on the

6 16th of May, 1995. That's mid-May.

7 Q. Can this preamble indicate where these conflicts took place?

8 Please slow down. Wait for me to finish my question before you give me an

9 answer.

10 Look at it, and then tell me where these clashes broke out.

11 A. These clashes broke out in the Zlatiste, Debelo Brdo, Trebevic,

12 and Spicasta Stijena sectors.

13 Q. Thank you.

14 A. This is this area here: Debolo Brdo, Zlatiste, Trebevic, and

15 Spicasta Stijena.

16 Q. Can we now move to page one, which speaks about the daily use or

17 expenditure of ammunition on the 16th of May, 1995.

18 MR. TAPUSKOVIC: [Interpretation] This is, Your Honour, when the

19 indictment incidents took place, among other things.

20 If we can please look at page 2; chapter entitled "Consumption of

21 Ammunition." Do you see this? Does this show the amount of the

22 ammunition spent by the 12th Division.

23 A. Yes, since this was the area of responsibility of the 12th

24 Division, and that comprised the town area.

25 Q. Can you give us a few figures?

Page 5775

1 A. Yes, I can. Large calibre: 120-millimetre mortar, 76 shells;

2 82-millimetre mortar, 466 pieces; 60-millimetre mortar, 379 shell; B1 gun

3 shells, 10; and now come to infantry ammunition.

4 Q. What's the number of rounds?

5 A. 16.300, et cetera.

6 MR. TAPUSKOVIC: [Interpretation] Your Honour, can we have this

7 document please admitted into evidence as a Defence exhibit.

8 JUDGE ROBINSON: Yes. But what are we to make of the evidence

9 about the ammunition? Are you saying this is at a very high level or

10 exactly what do you want us to draw from this evidence?

11 MR. TAPUSKOVIC: [Interpretation] I would like to draw your

12 attention to the fact --

13 JUDGE ROBINSON: Are you --

14 MR. TAPUSKOVIC: [Interpretation] -- that in May only 16.000 rounds

15 of bullets were fired, and that was at the time, when, according to the

16 indictment, a large number of incidents took place, and this is also a

17 time when an ongoing conflict began, which went all through June and July

18 in particular. Through some other documents, you will be able to see that

19 on a daily basis thousands and thousands of rounds of bullets and shells

20 were fired from the 12th Division positions. This is the period May,

21 June, July, all the way through the period when into NATO bombing started.

22 This kind of fire came on a daily basis from the area of

23 responsibility of the 12th Division. This document demonstrates that on

24 the 15th of May, or rather, 16th of May, so many shells were fired, 76 of

25 120 millimetre, and so on and so forth, and also 16.000 rounds of

Page 5776

1 ammunition. I think this is particularly relevant for this period because

2 this shows that an activity, combat activity was being launched that went

3 on permanently and that it was particularly pursued by the BH army.

4 Because if the Defence is not availed of an opportunity to show

5 what the situation was in the course of this clash in the aftermath of the

6 truth, then I think that the Defence will be really put in a position not

7 to address this whole issue in a just and fair way, the issue that relates

8 and pertains to the indictment.

9 The Defence believes that we have to demonstrate what kind of

10 armed conflict took place in the period -- in this period. Of course, it

11 does not justify any retaliatory actions, but we have to establish what

12 kind of operations were ongoing. Even this rifle fire could have caused

13 these incidents in a certain way. We already spoke about this.

14 JUDGE ROBINSON: Thank you. But bear in mind that the

15 Prosecution's case, as I understand it, is not that combat activities were

16 not engaged in or perhaps even initiated by the BH army. Their case is

17 that there was activity on the part of the Serb forces, and that activity

18 was carried out under the command of the accused and gave rise to the

19 charges in the indictment of terror, war crimes, and crimes against

20 humanity.

21 They're not saying, as I understand it, that the BH army was

22 inactive; in fact, I believe they concede that there was an armed

23 conflict. That's the basis. That's one of the requirements for an

24 indictment of this kind.

25 MR. TAPUSKOVIC: [Interpretation] Your Honours, nowhere in the

Page 5777

1 indictment did they establish the existence of an armed conflict. This

2 was a free interpretation, but you will find nowhere in the indictment

3 that there was an armed conflict involving two armies and, in particular,

4 an armed conflict in the aftermath of the truce. When every day and I

5 have numerous numbers of these reports because the Defence had an

6 opportunity to see the files of BH army which was not the case notice

7 Galic case, but I brought only the most illustrative ones because I'm sure

8 that you wouldn't allow me more. I have, therefore, seven or eight

9 reports of this kind that show what kind of conflict was going on in May,

10 June, and July, and then until the end of the war, not to mention the NATO

11 bombing.

12 Under such circumstances, I believe that this whole matter has to

13 be taken into consideration. There was truce, first, then what followed

14 was the phase that we described; and now, since there is mention about the

15 campaign, not only whether a certain number of incidents took place, which

16 we're going to examine whether they were proved or not, in which the

17 accused is charged with direct involvement. However, here we have a phase

18 in this armed conflict which was dominated by fire from all kinds of

19 weapons predominantly from the positions of BH army and the area of

20 responsibility of their 1st Corps.

21 Therefore, I believe that the Defence indeed should be allowed to

22 demonstrate this in evidence, not only through telling stories, but also

23 to prove this by presenting documents retrieved and acquired from the BH

24 archives. All this was happening concurrently with the incidents that the

25 accused Milosevic is charged with in May and June, and I think this is

Page 5778

1 relevant and the Defence should be allowed to take this course.

2 JUDGE ROBINSON: Just a minute.

3 [Trial Chamber confers]

4 JUDGE ROBINSON: Mr. Tapuskovic, I'm not clear what your case is

5 in relation to the existence or non-existence of an armed conflict. Would

6 you clarify that for me? What are you saying?

7 MR. TAPUSKOVIC: [Interpretation] Well, I spoke at length and I

8 thought that I would not have to go into explaining this again, when we

9 discussed the campaign to instill terror, for instance.

10 I simply fail to understand why I have to explain those arguments

11 yet again, because if we're talking about fear, terror, and a campaign to

12 instill it --

13 JUDGE ROBINSON: You have to explain because the Chamber needs the

14 clarification. It's the duty of the Trial Chamber to keep abreast of the

15 arguments presented by counsel in this case and to ensure that it

16 understands the arguments that are being presented, and that's why you are

17 asked to explain it.

18 So, once again --

19 MR. TAPUSKOVIC: [Interpretation] Please, please do not deduce on

20 basis on of my silence that I do not know the answer. But if the Defence

21 has not managed to show what we intend to prove in our case, and if such

22 documents and the evidence of this sort cannot be used to clarify the

23 issues regarding, in particular, this period that the dominant period that

24 is in fact half of the period relevant for the indictment against General

25 Milosevic in which the most blatant incidents occurred, the bombs, the

Page 5779

1 shells --

2 JUDGE ROBINSON: Did you not hear the question I asked you? It's

3 quite simple. I'm asking to you explain to me what is your position; that

4 is, the position of the Defence in relation to the issue of an armed

5 conflict? And I ask it specifically because in the last intervention from

6 you, which was very long, you started out by saying that the Prosecution

7 either did not allege the existence of an armed conflict or did not

8 sufficiently prove it, yet at the end of your intervention you referred to

9 an armed conflict. So I'm confused as to what your position is, and

10 that's what I'm asking to you do, to explain to me what the position of

11 the Defence is with regard to this issue. Concentrate on that.

12 MR. TAPUSKOVIC: [Interpretation] The Defence contends that there

13 was not a conflict, in the broader significance of the word, in the entire

14 former Yugoslavia, but that there was an armed conflict on very specific

15 demarcation lines, and this is not stated in the indictment at all. The

16 BH army is not mentioned at all. It is as if it had not existed. And if

17 we are not allow to prove in what ways the BH army actually operated in

18 this area, what the front line looked like, what was happening at the

19 demarcation lines at the time when the incidents took place in the times

20 relevant in the indictment, then I simply I cannot see why I have to

21 explain this at any greater length or in any greater detail.

22 I'm trying to prove that on any given day, thousands and

23 thousands, hundreds of hundreds of shells were fired from the 1st Corps

24 positions, the BH army 1st Corps positions, and that the primary goal was

25 simply something that had to do with the protection of living on one side.

Page 5780

1 No reprisals, no retaliation, but just response to operations launched by

2 the other side in June, July, August, September, October, November when

3 the incidents listed in the indictment actually took place.

4 JUDGE ROBINSON: Thank you very much for that intervention.

5 First, paragraph 26 of the indictment reads: "At all material

6 times relevant to this indictment, an armed conflict existed in

7 Bosnia-Herzegovina in the territory of the former Yugoslavia."

8 In the light of that, I don't understand your contention that the

9 Prosecution does not allege an armed conflict or that no evidence has been

10 brought in relation to that issue.

11 Now, secondly, you say what you are trying to prove that "on any

12 given day, thousands and thousands, and I'm reading from the transcript,

13 hundreds of hundreds of shells were fired from the 1st Corps positions,

14 the BH army 1st Corps positions, and that the primary goal was simply

15 something that had to do with the protection of living on one side. No

16 reprisals,, no retaliation just response to operations launched by the

17 other side in June, July, August, September, October, November when the

18 incidents listed in the indictment actually took place."

19 You're going to bring evidence that will show, as I understand it,

20 then, that in relation to the allegations in the indictment in those

21 months, the BH army was simply responding to attacks launched -- sorry,

22 that the Serb army was simply responding to attacks launched by the BH

23 army. Because if you're going to do that, then, of course, that would be

24 very, very relevant.

25 MR. TAPUSKOVIC: [Interpretation] Well, is it possible, Your

Page 5781

1 Honour, I explained all this in my opening statement. Everything that was

2 done in this time-period in light of the specific situation was done in

3 extreme necessity, in extreme military necessity in this type period. On

4 other occasions, again, we had a necessity; but in this period, everything

5 was done in extreme military necessity in order to prevent the other side

6 from achieving military goals.

7 I explained this in my opening statement, Your Honour.

8 [Trial Chamber confers]

9 JUDGE ROBINSON: Well, Mr. Tapuskovic, I hear what you have said,

10 and I am very have interested in it.

11 Now, when you bring that evidence later on, when you call your

12 witnesses, my advise to is that you must as far as possible relate that

13 evidence to the allegations in the indictment. Don't allow the evidence

14 to be at large. Let it be related as specifically as possible to the

15 allegations in the indictment, and that way you will show or attempt to

16 show that the Serb forces were, as you have just told me, simply

17 responding to attacks to protect themselves.

18 JUDGE HARHOFF: And may I add, Mr. Tapuskovic, that the difficulty

19 we have is to conclude from the evidence that you have shown to us in

20 these orders to conclude that the fire exchanged between the two parties

21 was just from the Serb side being responsive to attacks from the ABiH

22 side. And the difficulty we have, to be specific, is that we cannot

23 conclude that from this evidence, because this evidence shows nothing more

24 than the fact that there was fire. It doesn't show anything about who

25 initiated the fire.

Page 5782

1 So in continuation of the President's advice to you, I also

2 strongly invite you to be more specific when you put the evidence to us.

3 Thank you.

4 THE INTERPRETER: Microphone, please.

5 MR. TAPUSKOVIC: [Interpretation] Well, perhaps it is important to

6 stress this suggestion that I received, and that is that the Defence

7 intends to prove, if it can, that a civilian person, and a civilian

8 facility in particular in this period, that such persons and such

9 facilities were never targeted by Republika Srpska army troops and that

10 everything that happened, in particular in this time-period from October,

11 or rather, August, 1994 until early May, that there were no such elements

12 that pertain to what we were talking about as regards the campaign. But

13 in this time-period, when the majority of the incidents occurred, that is

14 in May and June, it is out of the question to claim that the Republika

15 Srpska army targeted civilian persons or facilities at all.

16 Your Honour, I cannot bring here witnesses to speak about the

17 incidents because we cannot find such witnesses, and I cannot ask

18 Witness Veljovic specifically about some incidents that took place in May,

19 but I can adduce evidence to show what the situation looked like at the

20 time. Based on some judgements that I read, it is not important who

21 started the conflict at all. But in this time-period, the Defence

22 contends and believes that it has irrefutable evidence that what happened

23 in May, June, and July, and onwards, it is quite clear and it is well

24 known who prepared the offensive an and who carried it out in this

25 manner.

Page 5783

1 And this is important for new your deliberations on who is

2 responsible for the specific incidents, and we have yet to determine which

3 of these incidents are the result of direct targeting and which incidents

4 are a mere consequence of combat activities of fighting. Because it is

5 quite natural that if you have fighting of this nature, you will have

6 civilian casualties on both sides. And if I were to be allowed to try and

7 prove, and this is out of the question, to prove that as many people were

8 killed on the other side, 2.500 soldiers were killed on the other side.

9 How were they killed? And hundreds of civilians were killed. How?

10 Well, they were not targeted directly. I cannot credit that contention.

11 But the armed conflict in Sarajevo is not -- I'm interested in the

12 armed conflict in Sarajevo which was at the very heart, at the very core

13 of the conflict in the broader region in the whole of our unfortunate

14 country of the former Yugoslavia, and it affected all the peoples that

15 took part in this conflict there.

16 JUDGE ROBINSON: Mr. Tapuskovic, thank you. Please continue now

17 with the evidence.

18 THE REGISTRAR: Your Honours, document DD00-1747 will be admitted

19 as D189.

20 JUDGE ROBINSON: Did I say so? I did? Well, if I did, that's all

21 right. It is to be admitted.

22 MR. TAPUSKOVIC: [Interpretation] Well, perhaps I will brother you

23 with all of these documents through some other witness. But at least for

24 one point in time when the majority of the incidents occurred, according

25 to the indictment, I would like to ask this witness what he can confirm.

Page 5784

1 Q. What did you know? What did you learn about the participation of

2 various divisions in the military operation that was being prepared, and

3 when did this operation actually begin?

4 A. On the 18th of May, 1995, and this can be seen from some

5 documents, because I was able to obtain certain documents where I read

6 some reports that were also published in the book by lye Rasim Delic. On

7 the 18th of May, Army General Rasim Delic received an order from President

8 Alija Izetbegovic.

9 Q. No, no, no. Please, don't tell us about what you learned from the

10 book. The Court is not interested in that. What I want to know is what

11 reports did you receive about this offensive that was in the making at the

12 time, and were you informed about what was about to happen?

13 A. We were notified by our security and intelligence organ that is

14 charged with the collecting of this kind of data, that on the 15th of

15 June, at the latest, an offensive would be launched. The code-name was

16 Operation T-95.

17 Q. Thank you. And did this operation in fact begin?

18 A. It began at 3 hours, ten minutes on the 15th of June, 1995.

19 Q. Did you know who took part in this offensive?

20 A. Yes.

21 Q. Could you please tell us?

22 A. The offensive was carried out at the level of the BH army. The

23 main agent was the 1st Corps. They were entrusted with carrying out

24 combat activities. The attacks of the BH army, from the 18th of May until

25 the 15th of June, used up all personnel, all the equipment, all the

Page 5785

1 materiel, with the exception of the 5th Corps which was stationed in Bihac

2 and the 81st division which was stationed in the Gorazde area, because

3 they were in the UN-protected areas.

4 Q. Thank you. Does this knowledge of yours correspond to this

5 document, DD00-1769?

6 JUDGE ROBINSON: I think the witness is waiting to answer.

7 Are you in a position to answer?

8 THE WITNESS: [Interpretation] Yes.

9 "The army of the Republic of Bosnia-Herzegovina, the command of

10 the 1st Corps, strictly confidential, 01/3-120. The date is the 6th --

11 the 8th of June, 1995. Order of the commander of the 1st Corps for

12 attack."

13 MR. TAPUSKOVIC: [Interpretation]

14 Q. Thank you.

15 MR. TAPUSKOVIC: [Interpretation] Can we now look at page 4,

16 please. The English version is also page 4, and also in B/C/S page 4.

17 Q. Can you see what it says here under number 4? Now what is written

18 here, does that correspond fully to what it was that was happening at the

19 separation line?

20 A. May I read it.

21 Q. Well, yes, but pay attention to paragraph 2.

22 A. "The commander of the corps decided in coordinated action with the

23 forces of the 4th Corps, 3rd Corps, and 7th corps unit the of the Republic

24 of BH, MUP, and with own support carry out a combined assault operation of

25 the joint units of the 1st Corps with a simultaneous attack by the forces

Page 5786

1 from the front of the zone of the 14th and 16th Divisions. 14th Division,

2 14th Division, the 16th Division, the forces of the 12th Division from

3 Sarajevo the city area, and forces tactically infiltrated deep mind enemy

4 lines," that is to say, in our territory.

5 "Group the main forces in the zone of responsibility of the 14th

6 Division along the Vijenac, trig point 1360; Crni Vrh, trig point 1788

7 axis; and the auxiliary forces in the zone of responsibility of the 16th

8 Division and the 12th Division. Objective of operation: Break up the

9 enemy forces." We are the enemy.

10 "Along the axis of attack and take control of the

11 Trnovo-Kijevo-Krupac road and the Semizovac-Srednje-Nisici road. With a

12 part of the forces of the 12th Division, push the enemy between the Bosna

13 river and Vogosca, and then link up with the forces of the 7th Corps in

14 the Dvor village and Doboj village sector. Keep the thrust of artillery

15 support, POB and PVO, on the axis of the attack of the main forces in the

16 12th Division."

17 Q. Thank you. Was that the way it was then? Was that it was at all

18 the separation lines --

19 A. Yes.

20 Q. -- that were shown on the maps?

21 A. Yes.

22 Q. So what did this look like in relation to what was going on?

23 A. In view of the fact that we were following the activities of the

24 1st Corps and the operations, there was a change of -- in the main attack

25 of the forces where the 7th Corps of General Mehmed Alagic is earmarked to

Page 5787

1 be involved in the main attack and to look at the area of Bosna and

2 Ilijas. Already on the 3rd of May, three brigades were brought into the

3 area of Viseko, or rather, the village of Mostra and deployed to the

4 village of Mostra --

5 Q. Thank you. Thank you. And what happened at the separation lines,

6 for example, towards Grbavica, Nedzarici?

7 A. At ten past 3.00, at the same time, we were attacked

8 simultaneously along the front line. The fiercest attacks were from

9 Viseko and Kaluk towards Vogosca, and then from the area of Zuc here

10 towards Semizovac; whereas, part of the 3rd Corps in the Nisica river

11 valley was attacking, and their main objective was to cut off and encircle

12 the population and the units here in this part of the front; and then from

13 town towards this southern part from the direction of Debelo Brdo, they

14 cut off our lifeline. Here, in the area of Zlatiste, they took up the

15 roads; and then here in the area of Hrese, they broke through the

16 positions; and then from the area of Mojmilo, they want towards the

17 barracks in the area in Lukavica with a view to having the forces of the

18 corps and the population thrown back to the plateau in Jahorina.

19 Q. Thank you. In that first clash, were there any casualties?

20 A. The forces involved in the operation, and the operation was called

21 Operation T-95, 61.5 per cent of the total potential of the army of

22 Bosnia-Herzegovina was involved in this operation, vis-a-vis the corps.

23 And in terms of numbers, this is between 130 to 135.000 men, and all of

24 this against a corps that had 18.000 members. At first, we did not have

25 any reinforcements; but later on, we got about 1.500 men to support us.

Page 5788

1 Terrible losses were sustained, especially at the northern front. In five

2 days, we had about 140 soldiers dead and tens of civilians killed and

3 about 700 wounded, some of them seriously, some of them with light wounds.

4 JUDGE ROBINSON: What period was this?

5 THE WITNESS: [Interpretation] This was notice period between the

6 15th of June, up until the 21st of June; that is to say, four, five, six

7 days, we had these intensive attacks at the northern part of the front.

8 Also in the southern part of the front, there were major losses as well.

9 JUDGE ROBINSON: Okay, yes.

10 THE WITNESS: [Interpretation] Very well.

11 JUDGE ROBINSON: I'm going to take this as an example that you

12 just told us of a particular combat operation in which the Serb forces

13 were outnumbered by the ABiH forces and suffered significant losses.

14 So, Mr. Tapuskovic, how does that impact on any of the counts in

15 the indictment? How are we to use that evidence? And I stress again that

16 it is my duty, it is the duty of the Trial Chamber, to understand the case

17 being presented by both sides. How are we to use that evidence in

18 relation to, say, Count 1, which charges terror; or Counts 2 to 4 that

19 charge sniping, murder, inhuman attacks, unlawful attacks on civilians;

20 Counts 5 to 7, shelling, murder, inhuman attacks, unlawful attacks on

21 civilians?

22 You have evidence there now. We have evidence from this witness

23 of this combat operation that took place as he said between - when is it,

24 June? - the 15th and the 21st of June, in which the Serb force, were

25 outnumbered and suffered significant losses. How are we to relate that to

Page 5789

1 the charges in the indictment? What are you asking us to draw from that

2 evidence?

3 MR. TAPUSKOVIC: [Interpretation] Your Honour, he did not say that

4 this offensive lasted between the 15th and the 26th. He said that during

5 these five or six days, there were losses, and he said how big the losses

6 were. They are part of the front.

7 JUDGE ROBINSON: Never mind, that's not the important point. The

8 point is that you have evidence. You're presenting evidence of a combat

9 operation in which the Serb forces were outnumbered, probably even

10 attacked by the ABiH, and suffered significant losses. And I'm asking

11 what are you asking the Trial Chamber to draw from that in relation to the

12 charges in the indictment? And could you point me specifically to any of

13 the charges in which you would be asking us to say, for example, this

14 evidence contradicts the allegation in the indictment or the evidence

15 presented by the Prosecution in its case.

16 MR. TAPUSKOVIC: [Interpretation] Your Honour, if you look at

17 shelling, please look at the 16th of June. As for the 16th of June, there

18 are a large number of incidents: Those that remained in the indictment

19 and those that were in the original indictment; that is to say, that a

20 large number of incompetences occurred on the 16th. I asked him about

21 this offensive. And as for all the documents that I had -- from all the

22 documents I had, I just singled out for the 16th, for that offensive, four

23 or five documents that I have here; and that show from all brigades of the

24 12th Division, there was an abundance of shells of all kinds coming from

25 there, and also there was rifle gun-fire as well.

Page 5790

1 I wanted to show on the basis of a few document.

2 A. I wanted to show -- on the basis of a few documents, I wanted to

3 show the Trial Chamber how big this activity was on the 16th.

4 JUDGE ROBINSON: Please, I didn't see Mr. Waespi on his feet.

5 MR. WAESPI: Yes, I have been silent for a while. Just a couple

6 of points, if I may on this issue.

7 Because as you rightly observed, Your Honours, responding by the

8 SRK to ABiH attacks or defensive actions, whatever you want to

9 characterise, doesn't entitle the SRK to target civilians. Even if it was

10 out of necessity, even that would not be a defence. And also not using

11 air bombs. Three's three incidents mentioned on the 16th of June,

12 incident 11, 12, and 13, as we know, there's been testimony, lots of

13 testimony about the indiscriminate nature of these air bombs. It doesn't

14 allow them to indiscriminately to shell the city in response where

15 civilians are located, and we have seen casualties, where UNPROFOR members

16 testified.

17 Or the second argument I wanted to make, Mr. President, two days

18 later, 18th June 1995, and this is our shelling incident number 14, the

19 attack on the school of Dobrinja. We heard testimony saying that it was

20 quiet on that day, so there was not even a response to anything. But even

21 if it were the SRK, the accused is not allowed to target civilians, not

22 even in response.

23 JUDGE ROBINSON: Thank you, Mr. Waespi.

24 Of course, it's not my wish to anticipate the closing arguments in

25 the case. I simply want and I think I'm obliged to try to understand the

Page 5791

1 case that is being presented, and that's why I asked you to relate it to

2 the indictment. You have referred us to the 16th of June in relation to

3 which there are three incidents, and perhaps you might in the break look

4 at the incidents referred to for the 16th of June. There are three.

5 Mr. Waespi just referred to one on the 18th as well.

6 But I'm grateful for the answer that you're giving me, and I

7 believe that my understanding is developing as the case progresses. And I

8 stress that I understand that that is part of my function.

9 Let us take the break now for 20 minutes.

10 --- Recess taken at 12.23 p.m.

11 --- On resuming at 12.48 p.m.

12 JUDGE ROBINSON: Yes, Mr. Tapuskovic, please continue.

13 MR. TAPUSKOVIC: [Interpretation] Your Honours, I would first like

14 to tender the document DD00-1769 to be admitted as a Defence exhibit.

15 JUDGE ROBINSON: Yes, it will be admitted.

16 THE REGISTRAR: As D190, Your Honours.

17 MR. TAPUSKOVIC: [Interpretation] Your Honours, this again has to

18 do with the discussion that we had before the break. I did my best to

19 choose among the abundance of documents that I had in my hands those

20 pertaining to what we discussed, i.e., the 16th of June. I refrain from

21 obtaining any documents or showing them to the witness that pertain to any

22 other date. I just wanted to show the situation prevailing on the 16th of

23 June.

24 I would first like to ask the witness about the actions that took

25 place on the 16th of June, because Mr. Waespi mentioned another date; that

Page 5792

1 is, the 18th of June and the school in Dobrinja, as well as some other

2 things. These are the issues that we still have to discuss here in front

3 of you, under which circumstances these incidents happened and who was

4 responsible for the 18th of June, let alone the issue of air bombs.

5 But I am kindly asking you to allow me to ask the witness, given

6 what was happening on the 16th of June, as an example, if he can tell us

7 some of the documents, and I will not deal with many other documents.

8 However, I would like to single out the 16th of June.

9 Will you allow me that?

10 JUDGE ROBINSON: Yes, please proceed.

11 MR. TAPUSKOVIC: [Interpretation]

12 Q. Mr. Veljovic, you said that when the conflict began, the one that

13 took place on the 16th of June. How many actions or operations were on

14 that date? Was there any significant for you to remember that date in

15 terms of the number of operations under taken?

16 A. The operation started on the 15th, and as the day progressed they

17 became more intense. One of the worst days was the 16th.

18 Q. Thank you.

19 MR. TAPUSKOVIC: [Interpretation] Now, Your Honours, in relation to

20 this specific date, I would like to show the witness four documents

21 showing the consumption of ammunition by the BH army and ask him to

22 confirm whether this corresponded to what happened on that day. I would

23 not tackle any other documents that I probably can tender in a different

24 way.

25 Can he tell me anything about the actions taken by the brigades of

Page 5793

1 the 12th Division and whether that corresponds to the events of the 16th.

2 For example, if we can look at the first document bearing this date, and

3 there's a total of four of them, and with this we shall finish.

4 Q. Can you please look at this document and tell me something about

5 document DD00-3583.

6 JUDGE ROBINSON: Mr. Tapuskovic, that's not the best way to lead

7 evidence. There's a document in front of the witness. Ask the witness a

8 specific question about it. Don't ask him to give evidence at large, to

9 tell you something about it.

10 What is that you wish to hear? Elicit the evidence.

11 MR. TAPUSKOVIC: [Interpretation] I would like to hear from you

12 Witness, Mr. Veljovic, about this date and the activities that took

13 place. What weaponry was used, to what extent, and what kind of weapons?

14 A. The 12th Division launched a fierce attack on the 16th, since due

15 to some justifiable reasons it was unable to join other divisions on the

16 15th. It operated from the town concentrating --

17 THE INTERPRETER: Could the witness please repeat the names of the

18 locations. He was turned away from the microphone.

19 JUDGE ROBINSON: Witness, would you please repeat the names of the

20 locations, as the interpreter didn't hear.

21 THE WITNESS: [Interpretation] The 12th Division launched a fierce

22 operation on the 16th from the inner town because that was its area of

23 responsibility. The main axis of attack were from Zuc towards Vogosca,

24 from Debelo Brdo to Zlatiste where they broke through the line. On both

25 Zuc and Zlatiste, they cut off the communication and thereby encircled

Page 5794

1 Grbavica all together.

2 Then in the area of Falitici [phoen], they also broke through the

3 defence lines, and this is where fierce fighting took place. The

4 consumption of ammunition was at a very high level from all available

5 weaponry such as mortars, guns, tanks, et cetera. They used it in order

6 to cut off from Mojmilo towards the barrack, this area, and to encircle

7 through Zlatiste and Mojmilo, and to link up in the area of Vogosca down

8 the river of Misoca.

9 Q. My question in relation to everything you mentioned and the

10 operation in which all kinds of weaponry was used, and if I am allowed to

11 show these four document, does the quantity of the materiel used and the

12 weapons and the number of shells fired correspond to what happened on that

13 day? That is why I'm showing you this document first, and just to look at

14 the consumption on that day and which brigade it was.

15 A. That was 111th Brigade, and it shows high level of consumption of

16 ammunition, and a division is made up of several brigades.

17 Q. Can you please look specifically at the quantities of the materiel

18 used on page 2 of the B/C/S version, because we have a translation of only

19 this part.

20 A. Here it says that high-calibre rounds: Shells 60, 200; shell 82,

21 175; shell 120, 82; and 20.000 rounds of 762 bullets; 2.000, 7.2 depending

22 on the calibre.

23 Q. Did this correspond form what was coming from that direction?

24 A. Yes.

25 MR. TAPUSKOVIC: [Interpretation] Your Honours, can this document

Page 5795

1 please be admitted as a Defence exhibit. I would like to show the witness

2 only three other documents and then I leave it, and all of this refers to

3 the 16th of June. This particular document refers to the 111th Brigade.

4 JUDGE ROBINSON: Yes, it will be admitted.

5 THE REGISTRAR: Your Honours, this becomes D191.

6 MR. TAPUSKOVIC: [Interpretation] Yes. The same thing, only now

7 it's document DD00-3588, bearing the same date.

8 Q. Can you please look which brigade we are talking about now?

9 A. 115th.

10 Q. What date?

11 A. 16th of June, 1995.

12 Q. Does this correspond to the quantity of ammunition shown on second

13 page in the B/C/S version.

14 Just a moment, please. Please look close to the bottom of the

15 page.

16 A. Yes.

17 Q. Does this quantity correspond?

18 A. Approximately. I didn't count each one. For example, 246,

19 60-millimetre shells; 41, 120-millimetre; 20-millimetre grenades, 120; et

20 cetera.

21 Q. Thank you.

22 MR. TAPUSKOVIC: [Interpretation] Your Honours, can this document

23 be admitted as a Defence exhibit?

24 JUDGE HARHOFF: Before we do so, maybe, Mr. Tapuskovic, you would

25 like to explain to the Chamber what sort of ammunition is it that we see

Page 5796

1 here on this and the preceding exhibit. I see, for instance, that 44

2 mines for RPG SADP were used. Could you clarify that a bit, what that is?

3 I guess RPG stands for rocket propelled grenades. Do you use mines for

4 this kind of weapon?

5 THE WITNESS: [Interpretation] It's a hand-held anti-armour

6 launcher used for destroying bunkers and armoured vehicles, but it can

7 also destroy personnel inside; whereas, other munitions target only

8 personnel.

9 JUDGE HARHOFF: Thank you very much for this clarification.

10 What is the Zolja of which four have been used?

11 THE WITNESS: [Interpretation] Zolja is also an anti-armour weapon.

12 It's calibre is 60 millimetres, and it is used also for destroying

13 fortified munitions. There are others called Osa. It has a larger

14 calibre and more power.

15 MR. TAPUSKOVIC: [Interpretation] I also tender this document to be

16 admitted into evidence as a Defence exhibit.


18 THE REGISTRAR: As D192, Your Honours.

19 MR. TAPUSKOVIC: [Interpretation]

20 Q. In order to shorten my examination, let us look at another

21 document, which is DD00-35800.

22 Which brigade is this and what is the date?

23 A. Can we just scroll it down a bit? I don't see.

24 It's the 112th Brigade of the 12th Division.

25 Q. And the same applies, approximately, to what you said about the

Page 5797

1 previous document?

2 A. Can I just have a clearer picture? I don't see very well.

3 Can you improve the image?

4 Q. Concerning this document, can you tell us what is 7.9 calibre?

5 A. 7.9 millimetre refers to a rifle bullet, just as 7.62 is for an

6 automatic rifle. Those were the rifles manufactured in Zastava, and they

7 were a bit old-fashioned.

8 MR. TAPUSKOVIC: [Interpretation] Can we also have this document

9 admitted as a Defence exhibit, please.


11 THE REGISTRAR: As D193, Your Honours.

12 MR. TAPUSKOVIC: [Interpretation] Your Honours, I don't know for

13 how long you're going to tolerate me. It seems to me that the eight hours

14 that I had asked for, I would like to know how long I have left. It seems

15 to me that I have spent about four hours, and I think that I should be

16 careful about this. You haven't made a decision, so I don't know exactly

17 whether I can --

18 JUDGE ROBINSON: You don't wish to follow the practices of the

19 Prosecutor then, because they simply went on.

20 MR. WAESPI: Mr. President, not all the time. I think we got into

21 a habit of asking leave to ask a few questions. I don't have any

22 objection for the Defence to use more time. It's the Defence's first

23 witness, and that's our position.

24 JUDGE ROBINSON: So how much more time would you need?

25 MR. TAPUSKOVIC: [Interpretation] To tell you the truth, it's

Page 5798

1 difficult for me to say, but I will take into consideration whatever the

2 Chamber advises me to do. I will do my best to finish this by the end of

3 business today or maybe earlier.

4 [Trial Chamber confers]

5 JUDGE ROBINSON: Very well, Mr. Tapuskovic. We'll work on that

6 basis.

7 MR. TAPUSKOVIC: [Interpretation] I'm very grateful to you, Your

8 Honours. I will relax a bit now.

9 I would like the witness to be shown document P665, please. 665,

10 please.

11 Q. Mr. Veljovic, please, with regard to this document, I have a few

12 things that I would kindly ask you to read carefully before you give me

13 answers.

14 First, can you tell me who produced this document?

15 A. This is a document from the Sarajevo-Romanija Corps from the

16 forward command post at the Niksic plateau.

17 Q. Did you say what was the date?

18 A. The date is the 10th of August, 1994.

19 Q. Could you please tell us, you have already spoke about this, but

20 can you please explain to the Judges once again. I think this will not be

21 repetitive. Could you read the first paragraph, and tell us where those

22 positions were?

23 A. Well, since at this time I was in the 1st Romanija Brigade, which

24 half of it was deployed in the Niksic plateau sector, I'm quite familiar

25 with this. We're talking about October 1994 when the BH army units, from

Page 5799

1 the Supreme Command staff of the BH army, when the Supreme Command staff

2 of the BH army made the decision to launch a decisive attack to take the

3 route Semizovac-Srednje-Nisici, and to cut off the supply lines for our

4 equipment, materiel food for the forces deployed at the Niksic plateau,

5 and we would effectively be cut off had they succeeded in doing that.

6 Q. You have spoke been that, so this is quite enough.

7 Can you now please look at item 2 in this order; in fact, that

8 would be item 1, paragraph 2.

9 A. Item 1, paragraph 2. "The Ilijas Infantry Brigade, the task is to

10 first mount a persistent defence of current positions. Part of forces is

11 to is extricate and attack along the route Tarcin-Dol-Krst, topographic

12 point 1147, the village of Nasici, with a task of taking control of the

13 Misoca river crossing and cutting off part of the enemy forces in this

14 area supported by Corps Artillery Group 1."

15 Q. Could you please show us on this map where those positions are,

16 and can you just describe it very briefly.

17 A. Well, these are the positions right here.

18 Q. Could you please tell us what is this then?

19 A. Well, they're attacking from this axis, the route, the

20 communication route, and the forces that are in contact here have to mount

21 a persistent defence. So their commander tasked with them with mounting a

22 persistent defence and to extricate a part of the forces to attack and in

23 order to prevent the enemy from cutting off that route.

24 Q. So who is in an encirclement here, and who has an advantage here.

25 A. Well, in -- with regard to the strength and with regard to the

Page 5800

1 fact that they have the dominating position, this area was not really all

2 that densely inhabited.

3 Q. Could you please look at item 5 on the next page in the B/C/S

4 version. This is the 10th of August, 1994, and could you please look at

5 item 5. That's page 2.

6 A. Item 5.

7 Q. Yes, item 5. Do you see it, and could you please read what it

8 says in paragraph 2.

9 A. "Colonel Cvetkovic is to group" --

10 Q. No, no, no. Paragraph 2.

11 A. Well, it says: "A launcher is to be prepared for operation in

12 Mosevicko Brdo. AB," that probably means aerial bomb launcher, "is to be

13 prepared for action, and another launcher is to be prepared to target

14 Gradina, Konjsko Brdo, and Velika Bukovo.

15 Q. Could you please tell me, in your brigade, did you ever have the

16 equipment that is listed here?

17 A. Well, I was in the 1st Romanija Brigade at the time, and 1st

18 Romanija Brigade did not have any aerial bomb -- air bomb launchers as

19 indicated here.

20 Q. If you look at the information listed here, you read out Gradina,

21 Konjsko - please wait until I finish - Konjsko Brdo, Velika Bukovo. You

22 said that this is a rugged terrain, no roads leading in or out. What does

23 it mean?

24 A. Well, this is a wooded area, rugged terrain, impassable, and there

25 are -- there is no population there.

Page 5801

1 Q. And you, yourself, did you hear any reports from other fighters

2 from other brigades about those air bombs?

3 A. Yes, I did. I heard that some soldiers and some craftsmen were

4 working on some makeshift launchers, and this actually had not been done

5 properly at all. You need to have a plane in order to drop an air bomb.

6 And if you don't comply with the instructions for use for -- with the

7 manual, then you're not doing it properly, and you're incurring risk. I

8 know that in one incident, six of our soldiers were killed in this sector.

9 This was imprecise -- an imprecise weapon, and technically it was not

10 perfected at all.

11 Q. Thank you. Thank you. Does that mean -- well, I shouldn't really

12 be leading you on this. If six soldiers were killed, as you say, whose

13 soldiers?

14 A. Well, our soldiers.

15 Q. Well, did you perhaps hear what was the reason or in fact what was

16 done about it?

17 A. Well, I often heard the commanders say that this weapon should not

18 be used because of our safety, because it was not technically perfected.

19 Q. Well, on the basis of this document, what can we conclude, when

20 was this?

21 A. Well, it was in 1994, in August.

22 Q. Thank you.

23 MR. TAPUSKOVIC: [Interpretation] Well, this is a Prosecution

24 Exhibit. It is already in evidence.

25 Well, I would like to -- I would like us to look at Prosecution

Page 5802

1 Exhibit 194. I hope that we will have time to deal with it.

2 But while --

3 JUDGE MINDUA: [Interpretation] Excuse me. There's something that

4 I don't really understand regarding the exhibit that we have just seen.

5 The witness is saying that what is written in this document is

6 exact or not? This is what I'd like to know. This brigade of the

7 Romanija Corps, it did have air bombs and launchers, yes or no? That's

8 what I like to understand. Did the brigade have those launchers and air

9 bombs or not.

10 We could ask the witness, maybe.

11 MR. TAPUSKOVIC: [Interpretation] Your Honour, well, the witness

12 replied that his brigade did not have any but that he heard, as he

13 recounted to us. That's why I ask him again.

14 Q. Your brigade, the brigade where you were serving,, did it at any

15 point use such bombs.

16 A. While Milosevic was the commander and followed by Colonel Lizdek,

17 we never had any such launchers. I heard that a 3rd Brigade had such

18 launcher, and that the Ilijas Brigade and the Igman Brigade that they

19 had. In fact, the troops, some craftsmen, did all kinds of makeshift

20 weapons, including those launchers. This was very, very dangerous because

21 it had not perfected before it was put to use. It was very imprecise.

22 Nobody dared to even get close to those launchers; and once it was fired,

23 it could easily fall on our own positions or villages.

24 I think that there was a court case Because of the use of this

25 weapon, and that was -- proceedings were launched by the prosecution

Page 5803

1 office of the army of Republika Srpska.

2 Q. When was that?

3 A. Where --

4 Q. Where was that?

5 A. Well, it was there in Vogosca. They were testing this equipment.

6 Q. So this weapon was the way you just described it.

7 A. Yes.

8 JUDGE MINDUA: [Interpretation] Yes, but this Prosecution document,

9 it's true in the description of these launchers, you're not contesting the

10 fact that these launchers did exist?

11 MR. TAPUSKOVIC: [Interpretation] Well, as you can see, the

12 document that this witness spoke about clearly states that such a thing

13 did exist and that it worked just as he described it in August 1994. So I

14 wouldn't embark on making any further comments regarding the allegations

15 in the indictment that all of a sudden this weapon was created and started

16 being used in 1995, and it was designed to put an end to the conflict.

17 We will in fact continue discussing this issue of air bombs as our

18 case develops, but this is the document that I now showed to the witness

19 and the witness knows what is the situation was at this time. He knows

20 that it was used on the basis of what he heard. He knew that it was ready

21 to be used in the rugged terrain uninhabited area, impassable terrain.

22 That's what he explained.

23 That's what I asked him and he gave me his answer. He told me

24 that -- that because of all this hulabaloo, our people got killed. In one

25 incident six people were killed. He heard about that, when one of those

Page 5804

1 bombs was actually launched.

2 JUDGE MINDUA: [Interpretation] Thank you.

3 MR. TAPUSKOVIC: [Interpretation]

4 Q. But now, since we have this map here in front of us, could you

5 please now explain. Perhaps we could zoom in by zone and you know how to

6 read a map, of course. Could you please tell us what does this map show

7 in the area of responsibility of 101st Brigade, and we just heard that on

8 one day, it fired the number -- certain number of shells as indicated in

9 the document. So what do we see here? What do we see here? What does it

10 have in terms of weapons?

11 A. Well, we see here --

12 MR. TAPUSKOVIC: [Interpretation] Could we please zoom in a little

13 bit.

14 A. Well, I can't see it here, but let's talk about 102nd Brigade.

15 Q. That's fine.

16 A. Well the 102nd Brigade has a mortar platoon. It has launchers, as

17 indicated by those arrows symbols. It has 60-millimetre mortars deployed

18 here in behind the Mojmilo hill and on the Mojmilo hill sector.

19 Q. And if we are look at 101st, if we go right on this map, what do

20 those arrows signify?

21 A. These are anti-armour and anti-fortification launchers. This is

22 where you actually launch those anti-armour rockets that you use to fight

23 armour and to destroy fortified facilities such as other bunkers or other

24 buildings. And here behind the hill, in the inhabited area where you have

25 the little dot with the half circle --

Page 5805

1 Q. Mr. Veljovic, could you please take it slowly so that we are able

2 to explain this.

3 If you look at 115 Brigade, could you please describe those

4 positions? What do those symbols and marks signify?

5 A. Well, here, where it says "155," that's the command: The

6 battalion commanders, the 2nd Battalion, 3rd Battalion. That's the

7 disposition of the forces here in this area, facing Nedzarici, and here at

8 the airport and Dobrinja.

9 Q. What kind of weapons do we see here?

10 A. Well, you can see here that they have a 120-millimetre mortars,

11 82-millimetres, 62-millimetre. And a semi-circle behind this dot means

12 that this is a platoon that has four weapons. And you can see here in the

13 depth towards 101st Brigade in the city itself in the inhabited area,

14 there were the barracks were, they are deep in the territory Nedzarici,

15 Pale, Stup. They had their mortars deployed as well.

16 Q. Thank you.

17 A. Which means --

18 Q. Just a moment. Let us now move north. 112th Brigade.

19 A. Could you please scroll down a little bit?

20 Q. Could you please explain those positions and the weapons?

21 A. Well, here, again, we have mortars, and you have recoilless guns,

22 anti-armour weapons, mortars. So we have several mortar positions here,

23 here, here, and here. And here you have the anti-armour weapons, and

24 recoilless guns that are used to fight armour.

25 Just one suggestion. This means that this brigade was deployed

Page 5806

1 around the city, and all the support artillery has to be in the depth. It

2 cannot be at the front end of the defence because a mortar needs as

3 four-man crew, and the crew would be engaged with infantry fire and it

4 would be destroyed. The depth, that's the city, that's the depth where

5 the depth of their defence was, and we could not target them there because

6 we would hit the city centre.

7 If you have combat, our artillery has to engage their firing

8 positions to destroy their fire-power, and we didn't want to do that

9 because we would have will to target the entire city.

10 Q. And was this the situation throughout?

11 A. Well, yes, the way that you see it here in this area and this is

12 not our map. This is what they plotted. That's, I think, a map that was

13 produced by the BH army.

14 MR. TAPUSKOVIC: [Interpretation] Could we move north a little bit.

15 If at least you can indicate to us what are those?

16 A. Well, can you see here anti-aircraft, machine-gun, the command

17 posts, this is a large calibre cannon here, mortars, mortars. So this all

18 deployed in inhabited areas, and this is pretty far away from the front

19 line, the front end. You can see it's maybe two or three kilometres in

20 the depth of the defended territory in the inhabited areas.

21 Q. Can we now move east, and can you tell us what are those brigades

22 and what kind of weapons are deployed there?

23 A. That would be 152nd, 105th Brigade. You see they have mortars.

24 They have their command posts in the very city centre. All those flags

25 that you see here, these are command posts in the most densely inhabited

Page 5807

1 area. This is where 115th Brigade has its positions. This is -- this is

2 where they deployed two mortar platoons in the most densely inhabited area

3 of the city centre, and they put their firing points so deep inside their

4 defended territory.

5 And in order to target them, if we were to target them, we would

6 have caused immense civilian casualties. That would have been a tragedy,

7 and that's why we never did it. They exploited this fact to achieve their

8 own successes. And they also used mobile mortar, mortars mounted on

9 vehicles, and here at Cengic Vila you see that have both their command

10 posts and mortar emplacements.

11 Q. Well, I almost failed to ask you that. When did they use those

12 vehicle-mounted mortars, mobile mortars?

13 A. Well, in 1992 and then on to 1995, at the beginning, they had few

14 of such units, but then they intensified the manufacturing of those

15 weapons at Zenica, at Vitez; and then they managed to bring it into the

16 city, in particular mortars because they are easily transported through

17 the tunnel. Of course, it is very difficult to bring in Howitzers or

18 other weapons because they had to be dismantled first.

19 Q. And what -- how -- where did they deploy those mobile mortars that

20 they mounted on trucks?

21 A. Well, they would -- you put some soil on the truck bed, you put

22 the mortar up there, fire a few shells, and then you just move it. They

23 would often provoke fire. They would provoke our response, and they

24 wanted us to respond to return fire and then we would hit the area around

25 the hospital where they would have put such mortars, but we did take great

Page 5808

1 care.

2 Q. Now I would like to show you a document. There's just this one

3 document left and then I would like to finish.

4 MR. TAPUSKOVIC: [Interpretation] DD00-3561. I don't know why it

5 is so dark.

6 Q. But could you please tell us what the date on this document is,

7 whose document it is, and does it actually explain what it was that you

8 talked about, how the in-depth positions were located along the front line

9 that you spoke of until now?

10 A. The date of this document of the BH army is the 16th of March,

11 1995, Command of the battalion of the Viteska Brigades.

12 Q. And what is the order?

13 A. The order says: "I order, I hereby order."

14 Q. No, no, no, no. Please. What does it say underneath the

15 letterhead? What is this order for?

16 A. Well, there's this lot here: "Defence systems and engineering

17 order."

18 Q. Wait a minute. What kind of system?

19 A. Well, --

20 Q. Well, it says so. It's written there, please.

21 A. Well, I can't read it. Probably engineering support, combat

22 system. Probably it says engineering support, combat system. I know

23 about these things and that means --

24 Q. Thank you. Thank you. That will do.

25 Would you look at the very end?

Page 5809

1 MR. TAPUSKOVIC: [Interpretation] Your Honours, I don't know, my

2 document is clear, and why there are three's these black marks here. The

3 English version is fine, but can it please be placed on the ELMO so that

4 he have a proper look at it, so he can read the one but last paragraph,

5 and so that he can read what is says on top of the document, because what

6 it says there is ...

7 A. That's right. I can see it this way, too.

8 What paragraph do you want me to look at?

9 Q. Well, remember what you couldn't read a few moments ago, at the

10 very top, the letterhead.

11 A. "The order on organising the firing system and the engineering

12 support."

13 Q. The one-but-last paragraph.

14 A. "In all areas of defence, if you look at the PAMs and PATs, and

15 you will" -- well, that means in the buildings and houses, that they

16 should be built in depth, and that over their own heads they fire at our

17 positions.

18 Q. Thank you.

19 MR. TAPUSKOVIC: [Interpretation] Can this document please be

20 tendered, or rather, admitted into evidence as a Defence exhibit.


22 THE REGISTRAR: As D194, Your Honours.

23 MR. TAPUSKOVIC: [Interpretation]

24 Q. In addition to what you saw in the map I showed you a few moments

25 ago, where were all of their weapons?

Page 5810

1 A. Well, you can see that they were all in the urban areas. It was

2 all depicted in the map. We all saw that on the map what was marked in

3 blue. You saw where machine-gun was, where a mortar was. You could see

4 that it is throughout town, that these weapons are throughout town.

5 Q. Thank you. We have to hurry.

6 These are not all the weapons, the ones that are inscribed here?

7 A. Well, if all the weapons were to be inscribed, it is just a small

8 map, so it would just look like a big inkblot. You couldn't really see

9 anything.

10 Q. Yes.

11 A. One to 50.000 is the scale, so what is that if you look at such --

12 Q. Thank you. Thank you. Can we just look at this other document

13 now.

14 MR. TAPUSKOVIC: [Interpretation] And that would be my last

15 question in relation to that document. The document is DD00-3318.

16 Q. Look at this document, please. Could you look at the date, and

17 could you tell me what it shows in relation to the firing positions that

18 existed in depth as you told us? Can you just explain that, too?

19 A. Can we just see this a bit better. We cannot see the numbers

20 properly.

21 Q. You can see the date, can't you?

22 A. I see the date: The 13th of June, 1995. "Order". I cannot read

23 this here. "Order to battalions: First of all" -- oh. This is -- well,

24 "the first combat firing group consisting of" -- I cannot read this.

25 Q. All right. Look at the firing positions down there.

Page 5811

1 A. Yes, yes, down there. "One in the region of Mojmilo, two in the

2 region of the annex," that is near the Zeljeznicar football stadium, "with

3 three plus one NB 82-millimetre mortar. Cengic Vila then," which is in

4 the centre of town, "two mortars of 120-millimetre calibre," that is the

5 biggest calibre. There is no bigger mortar calibre. "Then firing

6 position five in the region of -- of the heating room of Cengic Vila, and

7 then these 107-millimetre launchers in the area the hill of Mojmilo."

8 Those are the ones that we did indicate that were involved in the

9 preparation of the corps command.

10 Q. Let's not look at the entire document. It's three pages long.

11 What does this mean when you look at this? Now, look, Cengic Vila

12 and then it says the Bristol Hotel. So where were the firing positions

13 within -- within the city zone itself?

14 A. Mr. Tapuskovic, what it says here in the document was copied out

15 on the map, because what is written in the document is copied out 90

16 per cent of it on the map, and we saw clearly what the map shows.

17 MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. I would

18 like to thank you for the time that you have given me to question the

19 witness. I did have other matters to deal with, but this will be quite

20 sufficient for you to learn some more about what it was that was happening

21 at the time.

22 Your Honours, sorry, this document, this document, could it please

23 be admitted into evidence.


25 THE REGISTRAR: As D195, Your Honours.

Page 5812

1 JUDGE ROBINSON: Well, Mr. Waespi, you have the night -- you have

2 the night from which you can benefit and begin your cross-examination

3 tomorrow.

4 --- Whereupon the hearing adjourned at 1.42 p.m.,

5 to be reconvened on Wednesday, the 30th day of May,

6 2007, at 9.00 a.m.