Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4104

 1                           Wednesday, 23 June 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.03 a.m.

 5             JUDGE KWON:  Good morning, everybody.

 6             I note Mr. Robinson is absent today.

 7             I was advised that there's something for you, Mr. Tieger, to

 8     raise.

 9             MR. TIEGER:  Yes, Mr. President.  Thank you very much.

10             If we could move into private session.

11             JUDGE KWON:  Very well.  We'll go into private session briefly.

12                           [Private session]

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22                           [Open session]

23             JUDGE KWON:  Yes, I think we are now in open session.

24             Unless there are other matters to raise, let's bring in the

25     witness.

Page 4106

 1                           [The witness entered court]

 2                           WITNESS:  JOHN WILSON [Resumed]

 3             JUDGE KWON:  Good morning, General.

 4             THE WITNESS:  Good morning, sir.

 5             JUDGE KWON:  I hope we can conclude your evidence today.

 6             Mr. Karadzic, let us continue.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             Good morning to everybody, and good morning, General.

 9             THE WITNESS:  Good morning, Mr. Karadzic.

10                           Cross-examination by Mr. Karadzic: [Continued]

11        Q.   [Interpretation] Let me remind you -- or, rather, ask you:  For

12     10 months in 1992, you were with UNPROFOR in Bosnia-Herzegovina, is that

13     right, and Yugoslavia?

14        A.   Yugoslavia is more accurate, the former Yugoslavia.

15        Q.   Thank you.  Did you then, on the 13th of December, 1992, become

16     an adviser to the conference or in the Conference on the former

17     Yugoslavia?

18        A.   Yes, I did, although the date is questionable.  But approximately

19     then, yes.

20        Q.   And did you remain in that post until the 12th of March, 1993?

21     Rather, the 12th of December, 1993, I meant to say.

22        A.   Yes, I did.

23        Q.   Am I right in saying that that was a very important advisory role

24     in the team of Secretary Vance and Mr. Stoltenberg?

25        A.   They were rather more important people, I'd say.  But, yes, it

Page 4107

 1     was a significant role.

 2        Q.   Was there anybody more important -- a more important adviser on

 3     military issues than you?

 4        A.   Well, the force commander, and there were three of them in the

 5     time that I was there.  They were formally the military adviser to

 6     Mr. Vance and Mr. Stoltenberg, but on a daily basis, certainly, I

 7     provided that intimate support.  But the important issues, the force

 8     commander was always consulted.

 9        Q.   Thank you.  Now, a little patience, please, because I'd like to

10     ask you whether the following posts were ones that you occupied, and I'll

11     read it in English:

12             [In English] "A.  Three times daily situation reports on UNPROFOR

13     operational activities."

14             [Interpretation] Is that right?

15        A.   On many occasions.  Sometimes it was only once a day.  It

16     depended upon the level of operational activity in the former Yugoslavia.

17        Q.   Thank you:

18             [In English] "B. Provide regular, usually biweekly intelligence

19     assessments on future developments.

20             "C.  Obtain urgent information on specific operational activities

21     as they affected ongoing negotiations."

22             [Interpretation] Are B and C correct?

23        A.   They are.

24        Q.   [In English]  "D.  Draft the military aspects of negotiating

25     documents"?

Page 4108

 1        A.   Correct.

 2        Q.   [Interpretation] Thank you:

 3             "E.  Refer to the force commander major issues requiring his

 4     personal attention and agreement."

 5        A.   Correct.

 6        Q.   "F.  Pass information between the co-chairman and the force

 7     commander on an as-required basis."

 8        A.   Correct.

 9        Q.   "Pass information on ICFY activities to UNPROFOR, usually to the

10     head of Civil Affairs"?

11        A.   Correct.

12        Q.   Finally:

13             "Attend negotiating sessions, accompany the co-chairman during

14     his travels, and provide advice on the military practicality of various

15     initiatives."

16             [Interpretation] Is that right?

17        A.   That's right.

18        Q.   [No interpretation]:

19             [In English]  "Brigadier Wilson was intimated involved in the

20     drafting and negotiation of the BH military agreement.  It was the one

21     document of the various peace packages formally accepted and signed by

22     all the parties.  He was also less successfully engaged in detailing

23     negotiations over the conflict in Croatia for many months."

24             [Interpretation] Is that paragraph correct as well?

25        A.   Yes, it is.

Page 4109

 1        Q.   Thank you, General, sir.  Well then I'm not quite clear why in a

 2     paragraph of your statement you say you were a minor player.  Is this

 3     not, after all, an important function?

 4        A.   If you say so, Mr. Karadzic.  I simply say there were more senior

 5     and more significant people there.  The ICTY had many people of

 6     ambassadorial rank assigned there, and there were significant other

 7     advisers who had the ear of the co-chairman.

 8             JUDGE KWON:  General, did you say ICTY or --

 9             THE WITNESS:  An error once again, Your Honour.  ICFY, I-C-F-Y.

10             MR. KARADZIC: [Interpretation] Thank you.

11        Q.   There were several witnesses in court here who said that they

12     were minor players.  Now, do you have an explanation as to why the

13     Prosecution is calling people who consider themselves to be minor players

14     and not calling your bosses to come in and testify?

15             JUDGE KWON:  Mr. Karadzic, it's not for the witness to answer

16     those questions.

17             THE ACCUSED: [Interpretation] Well, then the Trial Chamber will

18     probably find an answer to that question.

19             MR. KARADZIC: [Interpretation]

20        Q.   But, General, perhaps from the decision-making standpoint, there

21     were people higher placed than you, but it seems to me that from the

22     level of information, there was nobody that was above you; right?

23     Information on military matters, I mean.

24        A.   On military matters, that's correct.

25        Q.   Thank you.  Now I'm a little concerned, General, and here's why:

Page 4110

 1     During this testimony of yours, for example, on the 21st of June, on the

 2     transcript on page 3945, you were in a quandary as to whether Nedzarici

 3     was a Serbian settlement, and then on 3944, page 3944, you weren't sure

 4     whether you -- or you said, rather, that you didn't know General Siber?

 5     Is that all correct?

 6        A.   That's correct.

 7        Q.   Thank you.  And then once again on page 3945, you did not know

 8     whether Nedzarici was under the control of the Serbs; right?

 9        A.   I stated that it was a disputed area, that the confrontation line

10     changed over time there.

11             JUDGE KWON:  Yes, Ms. Sutherland.

12             MS. SUTHERLAND:  Sorry, Your Honour.

13             I would ask Mr. Karadzic to quote the exact line back to the

14     witness when he's taking him to transcript.  When asked about

15     General Siber, the witness answered:

16             "I have a vague recollection of Mr. Siber, perhaps a member of

17     the Presidency forces."

18             So it wasn't that he didn't know him.

19             JUDGE KWON:  Thank you.  I can't check it myself because LiveNote

20     is not working.  In the meantime, can we know when it will be fixed?

21                           [Trial Chamber and Registrar confer]

22             JUDGE KWON:  Let's continue, Mr. Karadzic.

23             MR. KARADZIC: [Interpretation] Thank you.

24        Q.   Well, I'm not quoting verbatim.  I'm just asking in general

25     terms, and that's why I'm quoting the page number.  You said, on

Page 4111

 1     page 3948, for example, that you weren't sure whether you knew the

 2     contents of the letter from General Morillon to Izetbegovic; right?

 3        A.   I don't know which letter we're talking about.

 4        Q.   Thank you.  Now, can you tell me, General, at what distance you

 5     can see -- you can hear the outgoing fire of, let's say, a mortar?

 6        A.   It depends on how much other noise is in the area at the time.

 7     But if it is quiet, you would hear it at more than a kilometre.  If there

 8     is other firing going on close by, you might hear it at 200 metres.  It

 9     depends, Mr. Karadzic.

10        Q.   Thank you.  And on page 3951, for example, you weren't sure how

11     far the PTT building was from the center of town.  How far was the PTT

12     from the positions from which the Muslims could have shot?

13        A.   The Muslims could have shot from right outside my window.  That's

14     a very vague question.  You need to be more specific.

15        Q.   Well, how far is the PTT from Marin Dvor, Bascarsija, not to

16     mention the surrounding hills, which were also locations where the

17     Muslims were located?  So how far is the PTT building from Marin Dvor,

18     let's say?

19        A.   I don't know this level of geography that you're asking,

20     Mr. Karadzic.  I don't have a detailed knowledge.  These places are

21     meaningless to me.

22        Q.   But certainly more than one kilometre; right?

23        A.   I restate, I don't know the geography.

24        Q.   Thank you.  Now, on page 3952, you said that you didn't know the

25     deployment of Muslim forces.  Is that still your answer?

Page 4112

 1        A.   Yes, it is.

 2        Q.   Thank you.  On page 3953, you weren't able to confirm any

 3     knowledge of the fact that we, in 1993, stopped a counter-offensive at

 4     Srebrenica and that we didn't enter Srebrenica at all.  Is that still the

 5     position you maintain?

 6        A.   I cannot recall such a counter-offensive, Mr. Karadzic.

 7        Q.   It was a large counter-offensive one year after the beginning of

 8     the war in Eastern Bosnia.  And General, sir, we allowed armed formations

 9     in those villages to stay there.  We didn't touch them for one and a half

10     years or one year.  And when we couldn't take it any more, we launched a

11     counter-offensive.

12             Now, do you know that there was a very large Muslim armed

13     formation there at the time?

14        A.   Mr. Karadzic, now that you've provided a little bit more

15     information about that counter-offensive, as you describe it, I do recall

16     that military action.  I believe as a result, the enclaves in the

17     Drina Valley were created; is that correct?

18        Q.   That is correct, thank you.  Now, on page 3959, you said that you

19     didn't know that the Serbs were expelled from the Neretva River Valley.

20     Is that still your position?

21        A.   That's still my position, yes.

22        Q.   Thank you.  And is it still your position that you do not know

23     that in the Neretva River Valley, there were 44.000 Serbs living there

24     and that the vast majority fled, most of them before the war, from the

25     Neretva River Valley?

Page 4113

 1        A.   Yes.

 2        Q.   Thank you.  Now, on that same page, 3959, do you still say you

 3     don't know where the Serbian refugees came from in Nevesinje and other

 4     parts of the so-called High Herzegovina area?

 5        A.   Yes.

 6        Q.   Thank you.  On that same page, you said that you did not know

 7     that even before the war the Serbs fled from Livno.  Is that still your

 8     position?

 9        A.   Yes.

10        Q.   Thank you.  On page 3960, you said that you did not know which

11     armed incidents took place before the war broke out in

12     Bosnia-Herzegovina.  Do you maintain that position?

13        A.   The context of this is lost on me at the moment.  I don't know in

14     which context you're asking this, which incidents.

15        Q.   Well, do you know how many places were bombed in

16     Bosnia-Herzegovina, today's Republika Srpska, how many places were bombed

17     from Croatia before the war broke out in Bosnia?

18        A.   I don't know when the war broke out formally, Mr. Karadzic, and

19     I'm not sure what the term "bombed" means.  "Bombed" to me normally means

20     delivered by a military aircraft.

21        Q.   Well, shelled, let's say shelled, using artillery.  But let me

22     give you an overall statement and summarise, General.

23             Do you know that there were many shells from Croatia falling on

24     Bosanski Brod, Samac, Dubica, falling on Novi Grad, and that this

25     happened before the outbreak of the war, if we take it that the war broke

Page 4114

 1     out in Bosnia on the 6th of April, together with its recognition?  So do

 2     you know how many from Croatia, and you were in charge of Croatia as

 3     well, how many combat operations there were against the Serbs in Bosnia?

 4        A.   Mr. Karadzic, in the period mid-January, when our military

 5     liaison officers first deployed into -- along the line of confrontation

 6     in Croatia, and mid-March or the end of March, when I moved down to

 7     Sarajevo, we were reporting the violations of the cease-fire agreement,

 8     which included firing from Croatia into Bosnia and Croatia into the

 9     Krajina, which was still part of Croatia anyway, and we were reporting

10     incidents reported by both parties.  And it was happening, often, 2- or

11     300 violations a day, and I'm sure some of those would have been fire

12     from Croatia into Bosnia, and equally a lot of them were from Bosnia into

13     Croatia.  So I am aware that there was military action before the 6th of

14     April along that northern border of Bosnia, but it was from both sides.

15        Q.   Who could have shot at Croatia from Bosnia, General?  Why are you

16     constantly trying to strike a balance when the Serbs are victims?

17        A.   You asked me to be impartial, Mr. Karadzic, and that's what I

18     tried to be for my two years that I was associated with the conflict in

19     the former Yugoslavia.  There was a conflict with two sides

20     participating.  Both sides were firing weapons.  I'm simply reporting the

21     facts.

22        Q.   But, General, impartial does not mean to falsify the truth and

23     falsify the events.  The Serbs from Bosnia never fired on Croatia, nor

24     did they have anything to fire at them with, whereas Croatia did many

25     months before the outbreak of the war.  So how can you say that it

Page 4115

 1     involved both sides?  But never mind, let's move on.

 2             Now, did you know when the refugees -- the Serb refugees started

 3     fleeing from Croatia and coming to Bosnia?  Do you agree that that was

 4     already the case in June and July of 1991?

 5        A.   Well, I wasn't there in that time-frame, but I am aware that

 6     there were many refugees -- Serb refugees who had to flee Croatia, and

 7     some of them ended up in Bosnia and some went to other places.

 8        Q.   On page 3961, you said that you did not know what happened when

 9     the Croats stormed Bosanski Brod on the 3rd of March, you don't know what

10     happened.  The Croatian Army crossed over into Bosanski Brod, and you

11     asked me what army I was referring to.  And I said that I believed they

12     were the Croatian National Guards Corps, the Zenga, and other irregulars.

13     What is your position now?  Do you maintain your position?

14        A.   Yes.

15        Q.   And on that same page, you said that you didn't know very much

16     about the Lisbon Agreement, you weren't well informed about that?

17        A.   That's correct.

18        Q.   Thank you.  On 3965, page 3965 of that same transcript on that

19     same day, you said that Minister Doko, in June 1991 -- or, rather, that

20     Bosnia had already had a defence minister, Jerko Doko, who became the

21     defence minister in January 1991.  Are you aware of that?

22        A.   I said yesterday I believe that it wasn't until late May that I

23     became aware that there was somebody who called themselves the minister

24     of defence, and I believe it was Mr. Doko.  When he was appointed, I

25     don't know, but I only became aware of him in late May.  As you recall,

Page 4116

 1     Mr. Karadzic, I was not involved with any of the political parties until

 2     UNPROFOR left on the 16th/17th of May.  My point of contact a couple of

 3     days after I left became the minister of defence, Mr. Doko, and he was

 4     the person I spoke to on the Presidency side until he was relieved by

 5     Mr. Halilovic.

 6        Q.   Thank you.  General, do you know that Halilovic was never defence

 7     minister, he was actually commander of the Muslim army?

 8        A.   I think you're perhaps more accurate than I was in my

 9     terminology.

10        Q.   Page 3965, you said that you did not know about the

11     Patriotic League and its establishment or that they wanted war with the

12     Serbs in the summer of 1991.  Is that still your position?

13        A.   I never heard of the Patriotic League until you mentioned it

14     here, Mr. Karadzic.

15        Q.   Thank you.  You did not know that up until January 1992, that is

16     to say, two or three months before the war, the Patriotic League had its

17     staffs and units in 103 municipalities?  Actually, you've already

18     answered this.

19             Now, did you know that the Muslim forces -- or, rather, the

20     Sarajevo forces had been established as the 1st Corps, consisting of the

21     12th, 14th, and 16th Division?  You didn't know about that either.  That

22     is on page 3966.

23        A.   No, I didn't.

24        Q.   Thank you.  Also, you did not know that in Sarajevo, there were

25     about 15 brigades with their headquarters, logistic bases, artillery,

Page 4117

 1     tank and mortar positions, which constituted over 300 legitimate targets.

 2     That's on the same page, 3966.

 3        A.   I didn't know that that was the organisation of the Muslim forces

 4     within the city.  I don't know that they can be described as legitimate

 5     targets unless you look at their specific deployment.

 6        Q.   Do you still maintain that the Muslim forces in Sarajevo

 7     consisted of 15.000 policemen?

 8        A.   It's my estimate that there were 1500 -- around 15.000 Presidency

 9     forces there.  I don't know that I've ever described them wholly as

10     policemen.  At some point in time, they became an army for the Presidency

11     of Bosnia-Herzegovina.  My estimate is about the size of the army.

12        Q.   Do you know that brigades existed in the town of Sarajevo, with

13     their respective numbers, the 101st and so on and so forth?

14        A.   No, I didn't.

15        Q.   And do you know that you reported about the 10th Mountain Brigade

16     and that you called them extremists?  I guess they were criminals.  That

17     was what one of your reports says.  Do you remember that?

18        A.   No, I don't.

19        Q.   Thank you.  Page 3968, you were not very clear on whether ECMM

20     had their own people in Bijeljina and Northern Bosnia; is that right?

21        A.   That's correct.

22        Q.   Thank you.  General, did you manage to locate the tunnel that you

23     talked about?  You said that to the south of Sarajevo, there was a

24     tunnel, and Mrs. Plavsic also told you that the Muslims held that.  Do

25     you know of the existence of that tunnel?

Page 4118

 1        A.   I became aware of the existence of the tunnel.  Exactly when, I

 2     can't recall.  But, yes, I was aware of the existence of the tunnel.  I

 3     can't recall any conversation with Mrs. Plavsic saying that.  She may

 4     well have.  I can't recall it.

 5        Q.   Thank you.  On 3976, you also said that you were not aware of the

 6     ethnic picture of Sarajevo.  On the same page, you also said that you did

 7     not know which areas were predominantly populated by Serbs and that were

 8     under our control.  Does that -- is that still your position?

 9        A.   Yes, with some qualification, in that I was broadly aware that

10     some suburbs were Serb.  For example, I understand Ilidza was Serb, so

11     that would be one exception to your statement.

12        Q.   Thank you.  On page 3980, you said that you did not know that the

13     Muslims held Hum and that on the slopes of Hum the Muslim artillery had

14     their positions; is that right?

15        A.   That's correct.

16             THE ACCUSED: [Interpretation] Thank you.

17             JUDGE KWON:  Just a second, Mr. Karadzic.

18             General, you just -- a minute ago, you said you don't remember

19     having a conversation with Mrs. Plavsic about the tunnel?

20             THE WITNESS:  That's correct, sir.

21             JUDGE KWON:  If I can remind you what you said yesterday.  I

22     don't have the updated page number.  It's page 25, in line 15/16.  You

23     said:

24             "I received an allegation from the Presidency representatives

25     that there was a tunnel somewhere to the south of Sarajevo which was

Page 4119

 1     being used to hold a large number of non-Serb people."

 2             And then --

 3             THE WITNESS:  Your Honour, if I may, we're talking about two

 4     different tunnels.  One is a tunnel considerably to the south of

 5     Sarajevo, where it was alleged that prisoners were held.  I think the

 6     tunnel that Mr. Karadzic is referring to is the tunnel which went under

 7     the airport and was used by Presidency forces to move personnel and

 8     supplies and equipment into the city.

 9             JUDGE KWON:  Thank you.  Then the tunnel which was located at the

10     southern part, you had a conversation with Mrs. Plavsic?

11             THE WITNESS:  About the one that's alleged with the prisoners of

12     war or detainees, yes, but not about the one under the airport.

13             JUDGE KWON:  Thank you.

14             Mr. Karadzic, please continue.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can we have 1D1855 in e-court.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is your statement, General, dated the 24th of November,

19     1993.  It's towards the end of your term as military adviser.  Do you

20     recognise the statement?

21        A.   Yes, I do.

22             THE ACCUSED: [Interpretation] Thank you.  Could I please have

23     paragraph 3.  It's at the bottom of the first page.

24             MR. KARADZIC: [Interpretation]

25        Q.   Could I please ask you to read that?

Page 4120

 1        A.   "Nevertheless, I raised the issue of detention camps with both

 2     parties on a number of occasions.  Each party responded that they would

 3     permit our visiting the alleged sites (whose existence they each denied),

 4     providing we first visited the other parties' camps.  In one case, it was

 5     agreed that we could visit a Serb --"

 6             THE ACCUSED: [Interpretation] Can we please have page 2?

 7             THE WITNESS:  "-- camp alleged to exist at Pale, and a Muslim

 8     centre located in a road tunnel to the south of Sarajevo.  We had to

 9     abandon the proposal when the Presidency said we could visit their

10     location but they could not guarantee our safety.  Soon after this

11     incident, other more pressing operational tasks emerged and precluded any

12     possibility of further investigation."

13             MR. KARADZIC: [Interpretation] Thank you.

14        Q.   General, do you see now that it was the Muslims that held the

15     Serbs in a tunnel to the south of Sarajevo, not the other way around?

16        A.   Yes, I do.  I believe this document rather than my recollection

17     at this time.

18        Q.   Thank you.  May I remind you, General, to the south of Sarajevo,

19     towards Mostar, in the tunnel of Osenik, the Muslims held several hundred

20     Serbs in that tunnel.  And in town itself, near Ciglane, one side faces

21     Velesici and the faces Ciglane, they held their tanks and they also held

22     Serbs that were detained there.  Do you know about that other tunnel of

23     Sarajevo?

24        A.   No, you've confused me with that question.

25        Q.   This is what I'm putting to you:  There were two tunnels.  They

Page 4121

 1     were both in Muslim hands, and Serbs were held in both tunnels.  One

 2     tunnel is in the centre of town.  It's below Kosevsko Brdo, the hill of

 3     Kosevo from Velesici to Ciglane, and the other one is in the area towards

 4     Mostar, to the south of Sarajevo.  And you are referring to it here.  And

 5     that's when you were told that Muslims held Serbs in that tunnel.  Did

 6     you know about this other tunnel in the centre of town?  It wasn't hard

 7     to visit that one.

 8        A.   No.

 9        Q.   Thank you.  Could you please just read the first sentence of

10     paragraph 4?

11        A.   "I cannot specifically recall if detention campsites near Vogosca

12     were included in the extensive lists provided to me."

13        Q.   Thank you.  Paragraph 5:

14             "Given the state of fighting around the city ..."

15             Could you have a look at that sentence?  It's toward the bottom

16     of paragraph 5.  Have you found it?

17        A.   No.

18        Q.   The second part of paragraph 5.

19        A.   "Given the state of fighting around the city and the absence of

20     UNPROFOR operational presence around Vogosca, I believe it would have

21     been extremely unlikely that an UNMO could have visited that area until

22     about September, when additional weapon concentration sites were

23     negotiated and established in areas to the north of the city."

24             JUDGE KWON:  I should note, General, for the record, it should

25     read "UNMO operational presence."

Page 4122

 1             THE WITNESS:  UNMO, yeah.

 2             THE ACCUSED: [Interpretation] Could we have 7, please.

 3             JUDGE KWON:  We can read.  What is your question, Mr. Karadzic?

 4             MR. KARADZIC: [Interpretation]

 5        Q.   It would be a good thing if the general were to be reminded that

 6     "Newsday" reporters were aggressively asking him to confirm what it was

 7     that they had wanted.  The general showed his integrity here, and he

 8     noted that as an improper thing that happened to others as well.

 9             General, is that the way it was, as I have put it, that you were

10     asked to confirm things that were physically impossible, in terms of

11     investigations and so on?

12             [In English] "The UN action was outside my mandate.  I further

13     advised him that UN presence in the area was extremely unlikely during

14     the period I was in Sarajevo."

15             [Interpretation] What do you say to that?  Do you recall this

16     telephone call from "Newsday"?

17        A.   Yes, I had a number of conversations with this particular

18     reporter.  He had a story that he insisted upon, and a version of it that

19     I don't believe was supported by the facts, and I simply tried to tell

20     him the story that I knew.  And he would not accept it.  He was very

21     aggressive.

22             THE ACCUSED: [Interpretation] Could we please have the next page,

23     page 3:

24             [In English] "He changed the timing of the alleged incidents from

25     May/June to summer and late summer."

Page 4123

 1             [Interpretation] And then paragraph 8, to your credit, could you

 2     please read that.

 3        A.   "I am firmly of the belief that, while one cannot entirely

 4     discount a possible UN presence in the area, this article is a deliberate

 5     disinformation.  This would not be the first time, nor the last occasion

 6     that the parties have attempted to discredit UNPROFOR."

 7             THE ACCUSED: [Interpretation] Thank you.  Can this document be

 8     admitted?

 9             JUDGE KWON:  Yes.

10             THE REGISTRAR:  Your Honours, that will be Exhibit D334.

11             MR. KARADZIC: [Interpretation] Thank you.

12        Q.   General, let us have a look at 3982.  You could not say when the

13     Army of Republika Srpska came into being; right?

14        A.   Correct.  I gave an estimate of some time around about late May,

15     when General Mladic arrived in Sarajevo.

16        Q.   Thank you.  General, why did you say that the Serbs, the Bosnian

17     Serbs, wore five-pointed stars on their cap?  Is that not one of the

18     stereotypes, that Serbs were inclined towards Communism?

19        A.   I can't recall ever making a comment on five-pointed stars,

20     Mr. Karadzic, ever.

21        Q.   You did say, though, that a group that was involved in an attack

22     or, rather, committed an offence wore JNA uniforms and that on their

23     helmets and caps they had five-pointed stars.  Do you know that the

24     Bosnian Serbs did away with all ideological insignia on their caps?

25        A.   I did not make, to the best of my recollection in my evidence

Page 4124

 1     here, any reference to badges on uniforms.  When I did refer to the dress

 2     of the --

 3        Q.   Red stars, that's what you said, red stars.  I think that's in

 4     your statement.  But, all right, let's move on.

 5             You did not know that the conflict in Bijeljina lasted for two

 6     days, on the 1st and 2nd of April.  That is on 3983.  Right?

 7        A.   That's correct.

 8        Q.   And you did not know that this conflict was initiated by the

 9     Muslim extremists; right?

10        A.   There's a tense here.  You're saying I did not know.  I'm saying

11     I do not know, Mr. Karadzic.

12        Q.   Thank you.  You don't know that the Serbs were also victims in

13     Bijeljina, that there had been some Serbs that had been killed too;

14     right?

15        A.   No, I didn't know that either.

16        Q.   Thank you.  You said that the conflict -- or, rather, the essence

17     of your understanding of the conflict was the fact that Serbs would not

18     accept the independence of Bosnia.  On page 3986, you say that the Serbs

19     accepted the independence of Bosnia on condition that the

20     Lisbon Agreement be honoured; right?

21        A.   I don't recall saying that.

22             JUDGE KWON:  Just a second.

23             Yes, Ms. Sutherland.  Microphone, please.

24             MS. SUTHERLAND:  The witness didn't say that.  He said, in fact,

25     when he was asked the question:

Page 4125

 1             "Did you know that we made a concession and that we recognised

 2     that there was -- that Bosnia was an independent state, and that that --

 3     that was, in fact, the very essence of the Lisbon Agreement?"

 4             The witness answered:

 5             "No, I didn't know that."

 6             JUDGE KWON:  Thank you.  Be precise in citing his evidence,

 7     Mr. Karadzic, please.

 8             THE ACCUSED: [Interpretation] Well, my question was not

 9     interpreted properly.  The interpretation was not proper.  Now we see

10     that.  That will be corrected in the final transcript.

11             MR. KARADZIC: [Interpretation] All right.

12        Q.   Now, on page 3986, you did not know where the position of

13     Mount Zuc was, and there was fighting around that mountain, and the

14     Muslims took that mountain and they were in a position to fire at all of

15     Sarajevo and Vogosca as well; right?

16        A.   I don't know where Mount Zuc is, Mr. Karadzic, so I guess my

17     answer would have been no.

18        Q.   Thank you.  You did not know that parts of Vogosca that were

19     populated by Muslims --

20             JUDGE KWON:  Yes, Ms. Sutherland again.

21             MS. SUTHERLAND:  Excuse me, Your Honour.

22             Mr. Karadzic took the witness to the page 3986 and then said, You

23     didn't say something, and then proceeded to misinterpret what was

24     actually said, but then doesn't follow up with a question.  And all these

25     questions have been asked and answered already by the witness.  We've

Page 4126

 1     been going on at this for quite some time.

 2             JUDGE KWON:  I took it that he was about to conclude his

 3     cross-examination.  But you are just wrapping up his answers.  What's the

 4     point?  Let's proceed.

 5             THE ACCUSED: [Interpretation] The point is to see whether

 6     something changed, as far as the memory of the general is concerned.  He

 7     didn't know a great many things that he had to know, in view of the

 8     position he had held, or, rather, he misrepresented things.  He ascribed

 9     certain things to the Serbs that had been done by the Muslims.  I think

10     that's important, and I hope that I will be able to wrap up within the

11     time that you gave me.

12             MR. KARADZIC: [Interpretation]

13        Q.   So, General, on 3988, you did not know that the Serbs controlled

14     Muslim parts of Vogosca; right?

15        A.   Correct.

16        Q.   Thank you.  Let me ask you now whether you knew that at Ilidza or

17     in Hadzici, the Serbs did not control Muslim parts.  In Pale, they did

18     not control Muslim areas.  You haven't stated that yet.  I'm asking you

19     now:  Do you know that the Serbs did not control --

20             MS. SUTHERLAND:  Your Honour.

21             JUDGE KWON:  Yes.

22             MS. SUTHERLAND:  Mr. Karadzic put to the general, right, on

23     page 3988:

24             "You did not know that the Serbs controlled Muslim parts of

25     Vogosca; right?"

Page 4127

 1             That wasn't what was put.  The question was:

 2             "Did you know that a part of Vogosca is inhabited by Muslims, and

 3     that that's a part that Serbs never controlled and that included

 4     Kobilja Glava, the area from which they attacked Vogosca?"

 5             And the answer was:  "No."

 6             JUDGE KWON:  He paraphrased in a certain way and the general was

 7     able to answer.  Let's move on.

 8             But I raised it, Mr. Karadzic.  I don't see the point of you

 9     repeating or wrapping up the previous answers given by the general.

10             THE ACCUSED: [Interpretation] Very well, Excellency.

11             Now I'm going to ask my associate to count how many important

12     facts there were that a military adviser has to know, and the general

13     would have to know that.  If he did not know that, he could not be a good

14     adviser or a good associate to the mediators in our peace conference.

15             JUDGE MORRISON:  That's a statement and an assertion.  It's not

16     evidence and it's not a question.

17             JUDGE KWON:  That would be a good subject for your submission

18     later on, not subject for the cross-examination of witnesses.

19             THE ACCUSED: [Interpretation] Can we have in e-court -- actually,

20     I give up.  I'm giving up on almost -- well, actually, it's almost 100

21     key facts that the general does not know and he had to know about that in

22     view of his important position.

23             Could we have 65 --

24             JUDGE KWON:  No statement.

25             General Wilson, do you have any comment on this statement?

Page 4128

 1             THE WITNESS:  I would say, Your Honour, that a military adviser

 2     doesn't have to know all the facts, but he has to know where to go and

 3     find them.  And if there was a requirement for specific information or a

 4     report, then it was my job to consult with UNPROFOR, for them to look at

 5     the records, provide me with advice, and then to pass it to the

 6     co-chairman, and I did this on a regular basis.  I did not have a

 7     detailed knowledge of every event on every day of the conflict in the two

 8     years I was there, and I'll openly admit that, Mr. Karadzic, but I knew

 9     where to find out if the UN, in fact, knew.  And there was a great

10     deal -- there were many unknowns and many grey issues, if you wish,

11     during the conflict.  It was impossible to attribute.

12             JUDGE KWON:  Thank you, General.

13             Have your concerns been resolved, Ms. Sutherland?

14             MS. SUTHERLAND:  Yes, Your Honour.

15             JUDGE KWON:  Yes, Mr. Karadzic, let's conclude your

16     cross-examination.

17             THE ACCUSED: [Interpretation] 10603, that's the 65 ter number I'd

18     like to have now.

19             MR. KARADZIC: [Interpretation]

20        Q.   While we're waiting for that, General:  Did you regularly send

21     reports to Canberra every week?

22        A.   That was a requirement from my national authorities, so, yes, in

23     broad terms during 1992, but not during 1993.

24        Q.   Thank you.  And what about the others; did they also send reports

25     to their own governments?

Page 4129

 1        A.   What others are we talking about?

 2        Q.   Well, the other UN representatives from different nationalities.

 3     It was a multinational group, so did your colleagues send reports to

 4     their governments?

 5        A.   I don't know.  I didn't ask them.  It was none of my business.  I

 6     was required to report on a weekly basis on, essentially, concerning my

 7     personal security.  Australia had very limited strategic interest in this

 8     conflict, and I was only reluctantly released to the United Nations for

 9     it.  The minister of defence would have been quite happy for me to return

10     to my former duties rather than continue to participate in the event, so

11     my weekly reports were to allow them to assess the security situation and

12     my personal safety.  If it was unacceptable, I would have been withdrawn.

13     That was the purpose of them, not to report the operational activities of

14     the parties.

15        Q.   Thank you.  Well, this one looks pretty operative to me.

16             Let us look at paragraph 1, for instance.  This is what you say:

17             "The past week has been marked by heavy fighting in Sarajevo."

18             And then you say:

19             "Serb forces have continued to shell the city ..."

20             And then further down, you say -- further down.  Could we please

21     see the lower part of this page.  You say that weapons will be --

22     actually, you say that observers will focus, and so on and so forth.

23     This is a rather operative report:

24             [In English] "A number of death threats issued against him the

25     last seven to ten days for alleged bias towards the Serbs.  It is an

Page 4130

 1     interesting city."

 2             [Interpretation] That's what you say.

 3             So you are aware of these Muslim threats to the UNPROFOR

 4     commander, death threats, because he is allegedly biased towards the

 5     Serbs.  So, General, this is your report, isn't it?

 6        A.   It is my report.  Much of it was actually in the international

 7     media at the time.  When I'm talking about the detailed deployment of

 8     what's happening of UN forces in UNPROFOR, it is because the three majors

 9     mentioned, Majors Day, McManus and Tully, are three Australians who are

10     there on temporary deployment from UNSO, the Middle East, so my

11     government is very interested to know how these three Australians are

12     going to be employed in Sarajevo, for the same reason I gave in regard to

13     my own personal security.  That's way I have attempted to describe their

14     likely employment.  And, yes, there were death threats issued against

15     various UN personnel, including General MacKenzie and myself.

16             THE ACCUSED: [Interpretation] Thank you.

17             I'd like to tender this document, if it's not an exhibit already.

18             THE REGISTRAR:  This has been admitted as Exhibit P1034,

19     Your Honours.

20             JUDGE KWON:  Thank you.

21             THE ACCUSED: [Interpretation] May we now have a 65 ter document.

22     11286 is the number.

23             MR. KARADZIC: [Interpretation]

24        Q.   You see, General, that the corps commander -- the then corps

25     commander of the Sarajevo Romanija Corps forbid the use of artillery

Page 4131

 1     pieces in the area under the corps and that it could only be used --

 2     exclusively be used if he granted permission?

 3        A.   I would say he gave permission very often, then, Mr. Karadzic,

 4     because the period 14 May to 24 June was a period of intense operational

 5     activity, with daily heavy artillery fire into the city of Sarajevo, with

 6     very, very few pauses.  It was a very liberal interpretation of this

 7     directive, I would say.

 8        Q.   But, General, wouldn't it be necessary to determine who was doing

 9     the shooting and then go on from there and say the Serbs were shooting

10     'round town?

11        A.   Mr. Karadzic, I haven't disputed the fact that both sides fired.

12     It's the nature of the fire that's of concern.  That the Serbs were

13     disproportionate, inappropriate, widespread in their response, that's the

14     issue.

15        Q.   Well, if you look at this document, it was issued on the same day

16     as your report.

17             Now, General, if you do not know where the Serb forces were and

18     where the Muslim forces were, and where the Serb settlements were and the

19     Muslim settlements were, how can you report to your government, telling

20     them that it was the Serbs firing?  What about if the Muslims fired from

21     Sirokaca, Hum, Zuc, Debelo Brdo and so on, who was the culprit then, who

22     was to blame then?  Do you agree that you should have known all this,

23     that you should have known who did the firing?

24             The interpretation is not correct again.

25        A.   Mr. Karadzic, I answered yesterday that it was my assessment that

Page 4132

 1     because of the weight of fire that was coming in, that it was attributed

 2     to the Serbs; that the Presidency forces did not have the quantity of

 3     weapons to produce the amount of fire that was coming -- or that was

 4     occurring within the city.  That's why it's attributed to the Serbs, in

 5     my estimate.

 6             JUDGE KWON:  General, you said several times that the Serbs were

 7     disproportionate, inappropriate, and widespread in their responses.

 8             THE WITNESS:  Yes, Your Honour.

 9             JUDGE KWON:  Just for clarity, what do you mean by being

10     widespread in their response?

11             THE WITNESS:  Your Honour, technically when artillery fires, it

12     fires in a unit called a battery of six artillery pieces, and it has an

13     area on the ground where it lands, if it's employed correctly, of about

14     250 by about 250 metres.  Usually, it's fired at six rounds at a time so

15     they all land at approximately the same time for maximum effect.  That's

16     how good artillery unit fires.  Typically, the Serb fire would be spread

17     over -- it might be over a kilometre.  The rounds were coming in.  There

18     was a mixture of calibres, heavy and light.  It didn't appear to be

19     related to any particular target.  There was no concentration of fire

20     around -- you know, they didn't appear to have a specific target in mind.

21     It was just the general area that was being fired upon.  The example of

22     the mobile mortar, for example.  The mobile mortar fired, and I observed

23     it, two rounds or three rounds of fire, and approximately 200 rounds was

24     fired in response.  It was an urban area, full of tall apartment

25     buildings.  Many of them were hit and set on fire.  The distribution of

Page 4133

 1     the fire was, as I say, over quite a large area, entirely

 2     disproportionate for two rounds to be responded by 100 or more -- perhaps

 3     200 rounds, and such heavy weight of fire that can cause so much damage

 4     and so much collateral damage.  That's an example, but it's typical of

 5     what happened at that time.

 6             JUDGE KWON:  Thank you, General.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   General, you have no proof of that.  Now, do you know that the

 9     Serbs --

10             JUDGE KWON:  Do not make speeches, Mr. Karadzic.  You just --

11     [Overlapping speakers]

12             MR. KARADZIC: [Interpretation]

13        Q.   Is it correct when I say that you don't have proof of that?  Or

14     if you do, show it.  Let's see the proof and evidence of that?

15        A.   I said, Mr. Karadzic, I saw this with my own eyes.  I'm saying it

16     under oath.  I can't be more specific than that.  I haven't got a film of

17     it.  Otherwise, I can't be more specific.

18        Q.   Do you know, General, that the Serbs took back positions from

19     which they were pushed away from with artillery fire, they took back

20     those positions with artillery fire?

21        A.   That has been related to me, but I have no specific example of

22     that.

23        Q.   We have evidence of that here.  The Muslim side reported that, We

24     were pushed back, and then with long artillery fire the Serbs pushed us

25     back and returned to the trenches.  Is that legitimate, General?

Page 4134

 1        A.   Once again, it depends very much upon where this happened,

 2     Mr. Karadzic, whether this happened on the top of an isolated hill or in

 3     the middle of an urban area.

 4        Q.   Along the lines, the lines from which we were pushed back.  And

 5     if they passed by, the Serb settlements were destroyed, just like

 6     Pofalici.  And since the Serbs did not have enough infantry, they used

 7     the artillery to push out the Muslim army from their trenches and then

 8     they went back to the trenches.  Is that legitimate?

 9        A.   I return to my earlier point.  It depends where in the

10     circumstances.

11             THE ACCUSED: [Interpretation] Thank you.

12             I'd like to tender that document, 1126.

13             JUDGE KWON:  I wonder whether you asked any question about this

14     or not.

15             THE ACCUSED: [Interpretation] Well, I did ask a question.  I

16     asked whether the general knew that the corps commander had prohibited

17     this and that he was the only person who could issue permission, and the

18     general's answer was that, as far as he was concerned, the general

19     issued -- the commander issued permission too frequently.  And in the

20     previous document that was admitted, the general said that the Serb

21     forces continued to shell the city, whereas it is my case and I claim

22     that that was just said lightly and that all shells falling from the

23     hills down onto the town was said to be Serb.  And the general agreed

24     with that.

25             JUDGE KWON:  Ms. Sutherland.

Page 4135

 1             MS. SUTHERLAND:  No objection, Your Honour.

 2             JUDGE KWON:  Yes.  We'll admit it.

 3             THE REGISTRAR:  As Exhibit D335, Your Honours.

 4             THE ACCUSED: [Interpretation] May we have 1D1160 displayed next,

 5     please.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   This is one of your documents, General.  1D1860 is the correct

 8     number.  And if you look at it, you can see how you understood at the

 9     time who wanted to achieve what in Sarajevo.  And if we look at

10     paragraph 3, one sentence there, and then we'll go on to the next page,

11     it says:

12             [In English] "A BH Army offensive in Sarajevo would appear to

13     remain on hold."

14             [Interpretation] And we're talking about the 22nd of January,

15     1993.  And you know that an offensive was underway launched by the Muslim

16     forces in Sarajevo; is that right?

17        A.   That's what's written there, yes.

18        Q.   But do you accept that?  Did you write that?

19        A.   I did.  I co-authored this with Brigadier Messervy Whiting.

20        Q.   Thank you.  May we turn to page 2, please, and I'd ask you to

21     read out paragraph 6.  It's a short one.

22        A.   "No major developments should be expected in the Sarajevo area.

23     Without unacceptable casualties, the capture of the city is an

24     unobtainable objective for the Serbs.  The BSA will remain in a defensive

25     posture and rely on superiority in indirect firing weapons to deflect any

Page 4136

 1     BH Army offensive."

 2        Q.   You see, General, that at the time you knew that the Serb

 3     artillery was used to stop a Muslim offensive; right?  You realised that?

 4        A.   Yes, and that's not in dispute, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you.  May we now pan down the

 6     page to paragraph 9.  I'll read out one sentence:

 7             [In English] "BH Army forces will, as a priority, continue to

 8     apply pressure to disrupt Bosnian Serb Army lines of communication and

 9     strengthen their links to the Srebrenica and Gorazde pockets in

10     eastern Bosnia..."

11             MR. KARADZIC: [Interpretation]

12        Q.   Can you read out, "They would also assist," that sentence,

13     please?

14        A.   "They would also assist in ensuring BSA compliance with

15     territorial agreements and place BiH Army forces in an advantageous

16     position for a resumption of hostilities which they probably regard as

17     inevitable."

18             THE ACCUSED: [Interpretation] Thank you.  May we now turn to

19     page 3.

20             JUDGE KWON:  Yes, Ms. Sutherland.

21             MS. SUTHERLAND:  If Mr. Karadzic can put a question to the

22     witness, Your Honour.

23             JUDGE KWON:  Probably he may put a question after taking on one

24     more paragraph.  Let's wait.

25             MR. KARADZIC: [Interpretation]

Page 4137

 1        Q.   Do you see there paragraph 11 and the second sentence:

 2             [In English] "BiH Army forces may ..."

 3             [Interpretation] Can you read it out, please, the sentence

 4     beginning:  "BiH Army forces may ..."

 5        A.   "BiH Army forces may be prepared to launch an offensive using

 6     their troops, without Croat support, if they believe their position in

 7     peace negotiations is so weak they must provoke foreign intervention."

 8        Q.   Thank you.  And now paragraph 13:

 9             "In summary, BiH Army forces military objectives are assessed

10     as:"

11             Can you read out points D and E, please, General?

12        A.   "Launch an offensive in the Sarajevo area if they consider their

13     bargaining position in negotiations untenable and intervention is the

14     only recourse.

15             "E.  Continue to re-arm and build up forces and resources for a

16     resumption of the war when they are in a more advantageous position."

17        Q.   General, you wrote this.  Does this show that you knew the

18     situation and that you knew the Muslim army would launch offensives and

19     that it would persevere in those offensives?

20        A.   This document is my assessment of the operational situation in

21     January of 1993 and my personal assessment of how I saw this developing.

22     This was my job, to advise the co-chairman of this, and I did this on a

23     regular basis.

24             THE ACCUSED: [Interpretation] This is a very correct assessment.

25     I have no quibbles about that.

Page 4138

 1             And I'd like to tender the document.

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  Exhibit D336, Your Honours.

 4             JUDGE KWON:  Mr. Karadzic, you have about 15 minutes.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   General, I noticed that you make a lot of psychological

 7     characterisations of the actors concerned, and you've said probably for

 8     the needs of the Krajisnik trial, the case against Krajisnik, that I

 9     said --

10             THE INTERPRETER:  Could Karadzic repeat that word?  I didn't --

11     could Mr. Karadzic repeat what he just said, please?

12             JUDGE KWON:  Sorry.  The interpreters are asking you to repeat

13     what you said.  They couldn't follow.  Take a look at the -- could you

14     repeat your question?

15             MR. KARADZIC: [Interpretation]

16        Q.   You made quite a lot of psychological and moral characteristics

17     of the actors involved, especially the Serbs.  And for the requirements

18     of the Krajisnik trial -- against Krajisnik, that is, you said that I

19     consulted him and that he might have even been more important.  Now, do

20     you know that every decision by the president, every decision of mine,

21     must have been taken to the Assembly for the Assembly to vote on it and

22     accept it or not?  Were you aware of that?

23        A.   I do recall you saying in Geneva, Mr. Karadzic, that you had to

24     take at least important decisions to the Assembly.  I find it very hard

25     to believe that every decision of yours would have to be taken to some

Page 4139

 1     sort of political assembly.

 2        Q.   But in one of your reports -- in several of your reports, in

 3     fact, you are reporting and saying that I'm fighting at the Assembly in

 4     Pale to have the constitutional principles adopted from the

 5     Vance-Owen Plan.  So your report that Karadzic is having problems and

 6     that he's fighting in the Assembly to have such major issues presented at

 7     the Assembly, that was your report, that I had difficulties in the

 8     Assembly; right?  That's what you said?

 9        A.   I don't know what report we're talking about, Mr. Karadzic.

10     That's of a political nature.  My interest and my responsibilities were

11     on military matters.  I find it hard to believe that I'd be talking about

12     your political responsibilities.  But if you remind me of the report, I'd

13     be happy to look at it.

14        Q.   Well, I just have 15 minutes left, but on some other occasion we

15     shall be offering that up for admission.

16             Anyway, this is a report dated the 28th of August, 1993, as

17     requested by Brigadier Wilson:

18             [In English] "The following is an update of the B and H

19     Assembly ..."

20             [Interpretation] And then you go on to speak about the Bosnian

21     and the Serb Assembly met in Pale:

22             [In English] "The Serb Assembly met in Pale yesterday for the

23     first of two day-long session.  Karadzic is pushing hard to have the

24     Geneva package accepted by the delegates.  Many of those delegates,

25     however, are arguing strongly against making the territorial concessions

Page 4140

 1     called for."

 2             [No interpretation]:

 3             [In English] "Karadzic is reported to have lost patience with the

 4     hard-line delegates, calling some of them paranoid.  He is arguing that

 5     gains in international legitimacy present the Serbs control approximately

 6     70 per cent of the B and H area.  Under the Geneva Agreement, they would

 7     end up with 52."

 8             JUDGE KWON:  Mr. Karadzic, do you have any 65 ter number or the

 9     like?

10             THE ACCUSED: [Interpretation] I have 1D1857.  Can we see that on

11     e-court?  And give me a minute or two more.

12             JUDGE KWON:  Let us see the document.

13             THE ACCUSED: [Interpretation] 1D1857 is the document number.

14             JUDGE KWON:  I was told that it hasn't been released yet.  Shall

15     we put it on the ELMO, then?

16             THE ACCUSED: [Interpretation] Yes, please, because my time is

17     limited and this is, after all, an important document.  It's being

18     up-loaded.  It's already been up-loaded, so it's already on e-court, but

19     the announcement has not reached us.

20             JUDGE KWON:  No, I don't see it in the e-court.

21             THE ACCUSED: [Interpretation] This is at our request.  It was

22     updated.  A meeting of the two assemblies, the Muslim, Croatian, and

23     Serbian Assembly; right?

24             JUDGE KWON:  Can you show the bottom part?  Can you move it?

25             THE ACCUSED: [Interpretation] It's on e-court now.

Page 4141

 1             JUDGE KWON:  Yes.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Can you see, General, that you did have the information?

 4        A.   This is an example of knowing where to ask information, as a

 5     military adviser, Mr. Karadzic.  I've gone down to Bosnia-Herzegovina

 6     Command and asked them to provide information which I would have passed

 7     to the co-chairman.  There are many hundreds, if not thousands, of these

 8     documents which passed my desk in my 12 months in Geneva.  I don't recall

 9     this particular one.

10        Q.   But you see, General, here, that I am fighting to reduce the

11     70 per cent to 52 per cent of the territory of Bosnia-Herzegovina?

12        A.   That's what the report says, Mr. Karadzic.

13        Q.   And you see that I'm not finding it easy to get this through the

14     Assembly.  I'm struggling against the hard-liners and people who are

15     losing territory; right?

16        A.   That's the job of a good leader, Mr. Karadzic, to get people to

17     do things that they don't necessarily want to do.  It's the

18     responsibility of good leadership.

19        Q.   Do you remember that Lord Owen said that it was unprecedented

20     that an army that was not defeated is asked to leave behind such a large

21     portion of territory under its control?

22        A.   No, I don't recall that.

23             THE ACCUSED: [Interpretation] Very well.  We have that piece of

24     evidence here, and we will be showing it in due course.

25             But I'd like to tender this document into evidence now, please.

Page 4142

 1             JUDGE KWON:  Yes, this will be admitted.

 2             THE REGISTRAR:  As Exhibit D337, Your Honours.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   In paragraph 107 of your report, you said:

 5             [In English] "It was normal in dealing with military commanders

 6     at a certain level.  They were interested in fighting a war and gaining

 7     military advantage, not in withdrawing."

 8             [Interpretation] Therefore, you can say that you agree that I

 9     asked that from 70 per cent of the territory that we controlled, that we

10     could go back to 52 per cent and conclude a peace agreement, and that the

11     deputies were dissatisfied with that, as were the military structures?

12        A.   No.

13        Q.   Well, you wrote this.  You said that the military factor did not

14     like withdrawing, and here it would have to withdraw from 70 per cent of

15     the territory to 52 per cent of the territory, which means that they

16     would have to give up control of 30 per cent of what they were holding;

17     right?

18        A.   I don't believe that paragraph mentions percentages at all,

19     Mr. Karadzic.  I haven't got it in front of me, but --

20        Q.   But if you look at paragraph 106, this is what it says --

21             JUDGE KWON:  Shall we show it through e-court or the general can

22     be provided with the statement.  Do you have your statement before you?

23             THE WITNESS:  No, I don't, Your Honour.

24             JUDGE KWON:  Yes.

25             THE ACCUSED: [Interpretation] I'd like to draw the participants'

Page 4143

 1     attention to paragraph 106, which starts:

 2             [In English] "As a result of the London Conference in 1992,

 3     Karadzic agreed that Serbs' heavy weapons in certain locations in Bosnia

 4     would be concentrated."

 5             [No interpretation]:

 6             [In English] "The Bosnian Serb military were unwilling to effect

 7     the political agreement that had been reached by their political leaders

 8     in London."

 9             [Interpretation] And then 107:

10             [In English] "This was normal when dealing with military

11     commanders at a certain level.  They were interested in fighting a war

12     and gaining military advantage, not in withdrawing."

13             [Interpretation] And this, then, is the basis for the assertion

14     made by Lord Owen that it was unprecedented in history to see an

15     undefeated army leaving behind a third of the territory that it was

16     otherwise in control of.  And that's your statement, isn't it?

17             JUDGE KWON:  So what is your question, Mr. Karadzic, to the

18     witness?

19             THE ACCUSED: [Interpretation] Well, my question was:  Does the

20     general agree that he did have this knowledge to the effect that we were

21     ready to withdraw from 70 per cent of the territory to 52 per cent of the

22     territory, and that I had to struggle, in a democratic assembly, against

23     the deputies, and that the military structures were against this option

24     too?  It's logical, and he says it's logical, himself, it was logical for

25     them to oppose that.

Page 4144

 1             THE WITNESS:  No.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   You didn't know that; is that what you're saying?

 4        A.   Not the detail of that, Mr. Karadzic.

 5        Q.   However, this statement and your report testifies to the fact

 6     that you did.  Thank you.

 7             Now, General, you mentioned that we accepted --

 8             JUDGE KWON:  You made another statement.

 9             Would you like to comment on that statement, General Wilson?

10             You have a separate observation, Ms. Sutherland?

11             MS. SUTHERLAND:  Yes.

12             In addition, Your Honour, I just want the record to be clear.

13     Back on page 25, lines 25, Mr. Karadzic put:

14             "But in one of you're reports -- in several of your reports, in

15     fact, you're reporting and saying that I'm fighting at the Assembly."

16             When you look at -- it's clear, Your Honours, to see the document

17     that he then showed General Wilson, which has now been marked as D337, is

18     not authored by the witness.  It's, in fact, authored -- drafted by

19     David Harland and says "as requested by Brigadier Wilson," but this is

20     David Harland's comments, not the general's comments.

21             JUDGE KWON:  Thank you.

22             THE WITNESS:  Your Honour, Mr. Karadzic put such complex

23     questions to me.  Sometimes I can find five or six elements.  If some of

24     them are inaccurate, then I can only answer no.

25             JUDGE KWON:  Whether you would like to comment upon his statement

Page 4145

 1     that --

 2             THE WITNESS:  For example, I'm totally unaware of what percentage

 3     of territory was involved, and it changed weekly, daily, during

 4     negotiations in Sarajevo, and people went into great detail, sometimes

 5     moving a line on a map a kilometre or two.  So it depends on what time

 6     Mr. Karadzic is talking about.

 7             I am aware that Mr. Karadzic did from time to time try and sell a

 8     particular agreement to the Serb political assembly in Banja Luka.

 9     Whether he was successful or not, I don't know the reason for that

10     because I was not present.

11             JUDGE KWON:  And, of course, you would stand by what you stated

12     in your statement?

13             THE WITNESS:  I did -- I do, Your Honour.

14             JUDGE KWON:  Mr. Karadzic.

15             MR. KARADZIC: [Interpretation] Thank you.

16        Q.   But on page 30 of this report of yours -- or, rather, on page 4

17     of the transcript, you confirmed the need to obtain urgent information on

18     specific operational activities as they affected ongoing negotiations.

19     That's right, isn't it?

20        A.   I don't know which -- what document we're talking about here.

21        Q.   I'm talking about that list of the roles of a military adviser.

22     Point C was this, to do what I've just read out, and you confirmed that

23     earlier on?

24        A.   It was one of my jobs to obtain information for the co-chairman

25     about ongoing operational matters, yes, and military matters.

Page 4146

 1        Q.   And then you asked Harland to inform you about what was going on

 2     in the Serb Assembly, and Harland informed you that Karadzic was facing

 3     problems to get approval for the Serb side to reduce its territory from

 4     70 per cent to 52 per cent; isn't that right?

 5        A.   You'd have to show me the document again.

 6        Q.   The document that was in e-court a few minutes ago.

 7        A.   Yes, I understand that, but I can't recall seeing in that

 8     document the two percentages.  I didn't take it -- [Overlapping

 9     speakers].

10             THE ACCUSED: [Interpretation] Do we have it in e-court?  Yes.

11             MR. KARADZIC: [Interpretation]

12        Q.   Look at this:  "Karadzic is pushing ..."  You don't have to read

13     it out loud.  Just look at the last sentence.

14        A.   I see that now, thank you.

15        Q.   So in accordance with paragraph C, were you not informed?  And

16     when you were not informed, you asked Harland to inform you about what

17     the Serb position essentially was in relation to the territory that was

18     under its control; right?

19        A.   Correct.

20             THE ACCUSED: [Interpretation] Could I have another 15 minutes or

21     so, Excellency?  It would be better if I could have an entire session.

22     There are many documents that are important, like this one, and that we

23     will not have time to deal with otherwise.

24             JUDGE KWON:  You wasted so long a time putting unnecessary

25     questions this morning.  I'll consult with my colleagues.

Page 4147

 1                           [Trial Chamber confers]

 2             JUDGE KWON:  How much do you have, Ms. Sutherland, for your

 3     re-examination?

 4             MS. SUTHERLAND:  At this stage, Your Honour, I think 10 minutes,

 5     but I want to consult with Mr. Tieger.

 6             JUDGE KWON:  Yes.

 7                           [Trial Chamber confers]

 8             JUDGE KWON:  We'll have a break for half an hour, and you will

 9     have 15 minutes, Mr. Karadzic.

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

11                           --- On resuming at 11.05 a.m.

12             JUDGE KWON:  Yes, Mr. Karadzic.

13             MR. KARADZIC: [Interpretation] Thank you.

14        Q.   General, remember that yesterday we looked at some documents

15     where I referred to the reasons why the Serbs cannot be left without any

16     artillery around Sarajevo, and that my position was that if the artillery

17     were to withdraw, the Muslim army would try to break through and kill all

18     our civilians.  Remember, we showed that yesterday?

19             1D1870.  In the meantime, could I have that on the screen,

20     please?

21        A.   I'm familiar with your position on this matter, Mr. Karadzic.

22        Q.   Thank you.  Now we're going to see what the Command of the

23     1st Corps is ordering towards the end of your stay there, on the 8th of

24     December, 1993.  We also have a translation of this document.  I would

25     like to draw your attention to number -- actually, before number 2, this

Page 4148

 1     section:

 2             "The battalion that mostly consists of local people and refugees

 3     from the Zenica region, and it does not have full establishment

 4     composition, has suffered considerable difficulties -- significance

 5     losses in the fighting to date."

 6             So see this -- we are the enemy, they are writing this about us,

 7     and they are saying that we are under-manned.

 8             I would like to draw your attention to number 2 as well.  You see

 9     what the objective is of the 1st Corps against the

10     Sarajevo Romanija Corps.  The Sarajevo Romanija Corps is going to defend

11     itself from attacks in the area of responsibility of the

12     5th Motorised Brigade and the 102nd Motorised Brigade.  Their objective

13     is to take the Nedzarici area and create favourable conditions for moving

14     further towards Ilidza.  So they want to take all these Serb areas; isn't

15     that right, General?

16        A.   That's what's written in this document, Mr. Karadzic.

17        Q.   That was at the time while you were there.  Were you aware of

18     that?  That was at the time when you were involved with the conference?

19        A.   Right at the very end of my time then, Mr. Karadzic.  I think I

20     actually, on the 8th of December, handed over my duties to

21     General Pellnas.

22        Q.   It seems to me that it was on the 13th or 12th of December, but

23     all right.  Let us see, please, what the commander of the 1st Corps of

24     the Army of Bosnia and Herzegovina decided.  As we know, the corps was

25     deployed in Sarajevo.  I would like to draw your attention to what he

Page 4149

 1     decided, especially the sentence that reads:

 2             "Creating panic among Chetniks and civilians, launch an attack

 3     along certain lines."

 4             Do you see that part?

 5        A.   Yes, I do.

 6             THE ACCUSED: [Interpretation] Thank you.  Can we move on to the

 7     next page?  I think that's the way it is in English too.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   See, they even turned schools into military facilities.  Did you

10     know that, General, that schools and kindergartens in Sarajevo had been

11     transformed into military facilities?

12        A.   Mr. Karadzic, I don't think those schools had had children in

13     them for almost two years by that stage.  They were formerly a school,

14     would perhaps be more accurate.  There were no longer children going to

15     school in Sarajevo in late 1993.

16        Q.   I agree, all of those schools had no children there.  But when

17     they say that Serbs responded with fire at the school, then nobody says

18     that these are schools where there are no children and that were actually

19     turned into military facilities; right?

20        A.   I don't know that to be true.

21        Q.   Thank you.  I would like to draw your attention and the

22     attention -- actually, I'd like to draw the attention of all the

23     participants to the entire document.  But could you please look at

24     paragraph 6 now, "Firing Support."  We can also have the Serbian version

25     for the benefit of the interpreters.  That would be the next page.

Page 4150

 1             Just look at what the 1st Corps has at its disposal, the fire

 2     support that the units will have, those that intend to break into Serb

 3     neighbourhoods.  Do you see that, General?  There's a reference to the

 4     brigades, the 5th and 102nd Motorised Brigades, and so on, the 101st and

 5     so on.  Do you see that?

 6        A.   It talks about units, but it doesn't describe their size.  I

 7     mean, you can have a battalion which might be fully equipped and manned,

 8     and it could be quite strong or it could be quite hollow with very few

 9     forces.  It's a name, Mr. Karadzic.

10        Q.   As adviser to the mediators, did you know what the actual force

11     of the 1st Corps was?  You say 15.000.  I say 80.000.  Did you know that

12     their three divisions had between 60.000 and 80.000 men?  That's the

13     1st Corps of the Muslim army.

14        A.   It depends, Mr. Karadzic.  When we're talking about -- I gave an

15     estimate of 15.000 at the beginning of the conflict in April/May.  I

16     assume you're now talking about the end of 1993.  It's quite conceivable

17     that that 15.000 had grown significantly through the opportunity to train

18     and, no doubt, the acquisition of additional weapons.  It could well be

19     in that order, but I can't confirm your number.  I do not know the

20     number.

21             THE ACCUSED: [Interpretation] Thank you.  Could we have the next

22     page in English.

23             MR. KARADZIC: [Interpretation]

24        Q.   Quite simply, the participants should see what they have here.

25     See, General, from Mount Igman -- you see that from the previous

Page 4151

 1     paragraph and this paragraph.  From Mount Igman, artillery will fire at

 2     Sarajevo; right?  It was the previous paragraph, but it's also in the

 3     next paragraph too, number 15, "Command and Communications."  The

 4     Communications Centre from Mount Igman and so on and so forth, 15.3.  Do

 5     you see that, sir?  The police is also involved in the operations carried

 6     out by the 1st Corps; right?

 7        A.   I can see what's written in the document, Mr. Karadzic.

 8        Q.   All right.  During the negotiations, you had some information,

 9     and on the basis of that information you advised the co-chairman as to

10     what the objectives should be and what the balance of forces was; right?

11        A.   I gave them my assessment of what it was, and I was able to

12     repeat information provided to me by UNPROFOR.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this document be admitted?

15             Can we have 1D1866?

16             JUDGE KWON:  Ms. Sutherland.

17             MS. SUTHERLAND:  Following your guide-lines, Your Honour, I don't

18     think that this document should be admitted.

19                           [Trial Chamber confers]

20             JUDGE KWON:  Mr. Karadzic, we are concerned about your use of

21     time.  The general did not know anything about this document, except for

22     some schools which he knew incidentally, so we will not admit this

23     document.

24             MR. KARADZIC: [Interpretation]

25        Q.   General, do you see this document?  The Command of the Sarajevo

Page 4152

 1     Romanija Corps, on the 7th of December, is probably responding to a

 2     request, but is providing information to Mr. Krajisnik, the speaker of

 3     the Assembly, about cease-fire violations carried out by the Muslims.

 4     It's the 31st of August and up until the 1st -- the 5th of November.  So

 5     could you please note:

 6             "The structure of these violations and the number of projectiles

 7     involved, artillery projectiles that fell on Serb territory"?

 8             Do you see that, General?

 9        A.   I do see that, Mr. Karadzic.  There was a war going on.  Both

10     sides were firing.  I think that's acknowledged by everybody.

11        Q.   Thank you.  But these are Serb areas of town, and in these

12     partial reports in the media, and some official reports too, it says that

13     there was fire at the city, and it goes without saying that it was the

14     Serbs that were doing the firing.  And look at the results.  Twenty-four

15     dead, 37 severely wounded, 25 with light wounds.  Do you see that?

16        A.   I see that, but I have no idea what report you're talking about,

17     nor media coverage.

18        Q.   Well, General, the speaker of the Assembly is taking part in

19     negotiations, and at his request the commander is informing him about

20     cease-fire violations so that he could put this to you at the conference,

21     all the things that the Muslims are doing, that is, and the structure is

22     here, the structure of the violations -- of the cease-fire violations

23     that were carried out by the Muslims.

24             Do you see in the last paragraph, that in the area of the Jewish

25     cemetery, a mass grave for Serbs was found?

Page 4153

 1        A.   That's the first time I've seen a report of that, Mr. Karadzic.

 2        Q.   But, General, we discussed that.  Krajisnik did not ask for this

 3     for his private collection, as it were.  Mr. Krajisnik is asking for this

 4     information so that we could present it at the conference.  We are

 5     presenting it at the conference.  You were a participant in this

 6     conference.  You have to know about this.  You have to evaluate this, you

 7     have to take it into consideration; right?

 8        A.   Are we talking about the mass grave or about the firing of

 9     artillery shells?

10             JUDGE KWON:  Yes -- just a second.

11             THE ACCUSED: [Interpretation] Primarily violations.

12             JUDGE KWON:  Yes, Ms. Sutherland.

13             MS. SUTHERLAND:  Your Honour, the witness has already said on a

14     number of occasions that it was around this date or the following day

15     that he left his position as military adviser to the conference.

16             JUDGE KWON:  Yes.

17             Mr. Karadzic, you have two minutes.

18             THE ACCUSED: [Interpretation] This is a four-month period from

19     the end of August until the 5th of November, and the general at the time

20     was part of the conference.  This was his very own activity.  He was

21     supposed to have information, and we saw what his duties were.

22             JUDGE KWON:  What is your question to the witness?

23             MR. KARADZIC: [Interpretation]

24        Q.   General, if you didn't know about this, didn't you have to know

25     about it?  Was it not your duty to know this?

Page 4154

 1        A.   Mr. Karadzic, I've already said that I acknowledged that there

 2     was a war going on and they were -- people were firing from both sides,

 3     and I don't think anybody would dispute that.  But if we're talking about

 4     the total number of rounds, just quickly adding up, there's something in

 5     the order of a thousand rounds over a five-month period, it does not seem

 6     to me to be an intensive level of activity.  Your troops on some days

 7     would do that before morning tea, firing into Sarajevo.

 8        Q.   Well, that's not right.  And it's not five months, it's two

 9     months, September and October, so it's two months.  And if it were all to

10     be added up, it would be a lot more.

11             Can this document be admitted?  The general said that all sides

12     were firing, so let's see what it was that the Muslim side was firing.

13             JUDGE KWON:  His evidence is there, and the general did not know

14     anything about this document.  We'll not admit this document.

15             Your last question, Mr. Karadzic.

16             THE ACCUSED: [Interpretation] Can we have 1D01285.  P860, that's

17     the number, and it's already been admitted, therefore.

18             MR. KARADZIC: [Interpretation]

19        Q.   General, in your paragraph 106, you refer to the

20     London Conference and to my agreement that Serbs concentrate heavy

21     weapons, et cetera, et cetera.  Are you aware of my letter -- or, rather,

22     my position presented in my letter sent to the editor of "The Guardian,"

23     I think it is?

24        A.   I can't recall such a letter, Mr. Karadzic.

25        Q.   It's not the document.  P860 or 1D01285.  The Serb position is

Page 4155

 1     presented on the 18th of August, I think.  1D01285, please.  It's a

 2     Defence exhibit, 1D01285.

 3             JUDGE KWON:  I don't think it has been --

 4             MS. SUTHERLAND:  I've got it noted as Prosecution exhibit P00860.

 5             JUDGE KWON:  86?

 6             MS. SUTHERLAND:  86.

 7             JUDGE KWON:  Thank you.

 8             THE ACCUSED: [Interpretation] Yes, that's it, that's it.  Can it

 9     be rotated, please?

10             I'm not sure this has been admitted.  I have the wrong number

11     here, as if it were admitted as a P document.

12             MR. KARADZIC: [Interpretation]

13        Q.   General, since at that point in time you were working for the

14     conference, were you not interested at all in the position of the Serb

15     side that is coming there to negotiate and that is presenting its

16     position here in this letter?  And were you aware of that position?

17        A.   I was aware of the Serb position, which changed over time while I

18     was in Geneva.  I was broadly aware of what the position was, but I'm

19     unaware of this letter to the editor.

20             JUDGE KWON:  Just for the record, could you give the number

21     again, Ms. Sutherland, P number?

22             MS. SUTHERLAND:  P00860.

23             JUDGE KWON:  860.  Then he was correct.  No, it's a different

24     one, so I'm not sure whether this has been previously admitted.

25             We'll admit it in case -- no, we'll deal with it separately.

Page 4156

 1             Let's hear your last question.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Do you know, General, that the Party of Democratic Action had

 4     asked citizens from certain areas, say specifically from Trebinje, to

 5     leave Trebinje so that in three or four months' time they could ask to

 6     get Trebinje on the basis of ethnic cleansing?

 7        A.   No, I didn't, Mr. Karadzic.

 8        Q.   We have that document.  If we have time, 1D0151.  And we also

 9     have evidence of that in Professor Koljevic's diary.  The Muslims first

10     asked me to approve that, and I refused, and then they gave secret

11     instructions for people to move out of Trebinje so that they could accuse

12     us.  The number is D1851.

13             JUDGE KWON:  There's no --

14             THE ACCUSED: [Interpretation] It's not the document, no.

15             JUDGE KWON:  I don't think there's any point --

16             THE ACCUSED: [Interpretation] All right.  If he didn't know about

17     it, all right.

18             MR. KARADZIC: [Interpretation]

19        Q.   The last question, General:  Is it not 3:1 in favour of the

20     Serbs?

21        A.   I don't understand the question.

22        Q.   I'm not asking about here.  Here, it's 5 love in favour of the

23     Serbs, but tonight in South Africa, against Australia, is it not going to

24     be 3 nil against the Serbs?

25        A.   I must say, Mr. Karadzic, that it will probably be in favour of

Page 4157

 1     the Serbs.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             JUDGE KWON:  Ms. Sutherland.

 4             MS. SUTHERLAND:  Your Honour, I have no re-examination of the

 5     witness.

 6             I want to just add that there was five documents over the course

 7     of the two days that the Prosecution wasn't advised of that the Defence

 8     were going to use, and we would appreciate, in future, if we could be

 9     advised of all documents that they intend using during cross-examination.

10             JUDGE KWON:  Thank you for that reminder.

11             Mr. Karadzic, would you like to tender that, the last item, which

12     was a newspaper article as to your position?

13             THE ACCUSED: [Interpretation] Yes, certainly.  I thought that the

14     Prosecution had tendered it.  But if they haven't done that, then I would

15     like to tender it as a Defence exhibit.

16             JUDGE KWON:  Do we know whether or not it has been admitted?

17             MS. SUTHERLAND:  Your Honour, Mr. Reid advises me that the

18     information that we got from the Defence said that it had been admitted

19     as a Prosecution witness -- a Prosecution exhibit, but that was

20     incorrect.  So I defer to Mr. Registrar.

21             THE REGISTRAR:  No, Your Honours, I don't have it on my record as

22     an exhibit either for the Prosecution or the Defence.

23             JUDGE KWON:  What would be your position, Ms. Sutherland, as to

24     its admission?

25             MS. SUTHERLAND:  Just one moment, Your Honour.  I want to read

Page 4158

 1     the transcript.

 2             JUDGE KWON:  The witness didn't have an idea about its content.

 3             MS. SUTHERLAND:  In that case, Your Honour, following your

 4     guide-lines, no.

 5             JUDGE KWON:  Yes, we'll not admit it.  The accused will have

 6     another opportunity to tender it.

 7             General, that concludes your evidence.  Thank you very much for

 8     your coming a long way to the Tribunal to give it.  Now you're free to

 9     go.  Thank you again.

10             THE WITNESS:  Thank you, Your Honour.

11                           [The witness withdrew]

12             THE ACCUSED: [Interpretation] If I may respond to the

13     distinguished Ms. Sutherland.

14             Today, we sent another note saying that we have not received a

15     very important exculpatory document in relation to Ambassador Okun.

16     There are two sources why documents are not appearing, documents that we

17     are going to deal with; one, late disclosure on the part of the OTP, and

18     the second reason is that witnesses give very lengthy answers.  I put one

19     question, and they give answers to three questions, and then I have to

20     get a document out that I had not intended to tender along with that

21     particular witness.  So those are the reasons why there are some

22     documents that we had not sent notification for earlier on.  And, of

23     course, there's the pressure of time that the Defence is under.  We don't

24     have enough time to prepare or to present what we have to present.

25             JUDGE KWON:  In any event, I would expect in the future -- expect

Page 4159

 1     you to do your utmost to comply with that disclosure.

 2             Due to the scheduling issue, in terms of witnesses, we don't have

 3     any witnesses for this week, and I will let you know, as soon as

 4     possible, as to the date for Mr. Mandic's testimony.

 5             That said, unless there's any matter, we'll rise.

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  We'll sit on Monday, 2.15, to hear evidence of

 8     KDZ-185.

 9                           --- Whereupon the hearing adjourned at 11.31 a.m.,

10                           to be reconvened on Monday, the 28th day of June,

11                           2010, at 2.15 p.m.