Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11939

 1                           Wednesday, 16 February 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.02 a.m.

 6             JUDGE KWON:  Yes, good morning, everyone.  Good morning,

 7     Mr. Glavas.

 8             THE WITNESS: [Interpretation] Good morning.

 9             JUDGE KWON:  Mr. Karadzic, please continue.

10             THE ACCUSED: [Interpretation] Thank you, I wish a good morning to

11     everyone in the courtroom.

12                           WITNESS:  TIHOMIR GLAVAS [Resumed]

13                           [Witness answered through interpreter]

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

15        Q.   [Interpretation] And good morning, Mr. Glavas.

16        A.   Good morning.

17        Q.   Yesterday, at page 92, lines 10 through 12, speaking about the

18     departure of the civilian Muslim population before the conflict broke

19     out, you mentioned that this happened at the orders of the Crisis Staff.

20     Did you mean the Muslim Crisis Staff?

21        A.   That's correct.  I meant the Bosniak Crisis Staff in Hadzici

22     municipality.

23        Q.   Thank you.  Did anyone ask you, either here or at the

24     Bosnia-Herzegovina court, ask you about the structure and existence of

25     the Muslim Crisis Staff?

Page 11940

 1        A.   No.

 2        Q.   Thank you.  Am I correct if I say that Muslim Crisis Staffs were

 3     established and became operational as early as mid or the latest

 4     September 1991?

 5        A.   Absolutely.

 6        Q.   Thank you.  Do you remember that the Serbian Crisis Staff was

 7     established sometime in late March 1992, after the Muslims reneged on the

 8     agreement and --

 9        A.   That's correct.  I think it may have even been later.  I think it

10     may have been formed after the all-Serb Assembly.

11        Q.   Are you referring to your own municipality?

12        A.   Yes.

13             THE ACCUSED: [Interpretation] Can we now have P2297, please, in

14     e-court?  This is a document dated 11 April 1992.

15             MR. KARADZIC: [Interpretation]

16        Q.   Mr. Glavas, yesterday or the first day of your testimony, this

17     was admitted into evidence as a document on the establishment of an

18     advisory organ of Hadzici Serb Municipal Assembly, dated 11th April 1992.

19     You mentioned that the civilian population there was unprepared and that

20     they considered that they were actually left to their own means by the

21     leadership; is that correct?

22        A.   Yes.

23        Q.   Is it correct that in Sarajevo, outside Hadzici municipality, for

24     six days already, war had broken out, six days earlier?

25        A.   That's correct.  In my earlier testimony, I've already said that

Page 11941

 1     we were rather late in all -- to follow up on all these events, the

 2     establishment of or the division of the police, breakout of the conflict

 3     and so on.

 4        Q.   In your testimony and statements you mentioned the murder of a

 5     Serb policeman on the 4th of April.  May I just remind you that this

 6     man's name was Petrovic, he was a police officer, and he was killed while

 7     he was on duty at the police station in the Novo Sarajevo Public Security

 8     Station?

 9        A.   Yes, I am well aware of that case.

10             JUDGE KWON:  Ms. Edgerton?

11             MS. EDGERTON:  Your Honour, I don't recall seeing reference in

12     any testimony or statement of Mr. Glavas to this effect and I just wonder

13     if I could have a source for that, please.

14             JUDGE KWON:  Yes.  Can we have the reference, Mr. Karadzic?

15             THE ACCUSED: [Interpretation] The witness did confirm this, and

16     it would take up a lot of my time but I'm pretty certain that during the

17     examination-in-chief he did mention the killing of this police officer.

18     However, since that was not explored, I wanted to ask him whether that

19     policeman was a Serb and whether this happened after mobilisation was

20     declared.

21             JUDGE KWON:  Shall we proceed in the meantime?  Yes.

22             MR. KARADZIC: [Interpretation]

23        Q.   Am I correct in saying that Mr. Izetbegovic on the 4th of April

24     declared general mobilisation?

25        A.   I believe so.

Page 11942

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we now see page 2 of this document, please, in English?  We

 3     can leave the Serb as it is.  Here we see that it says that on the

 4     11th of April, it was decided that a body, a commission, should be

 5     established.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Could you tell us what that commission's task would be?  What the

 8     purpose of its establishment was?

 9        A.   I'm not sure what commission you're referring to.

10        Q.   Very well.  Let me remind you, was the basic topic here the

11     political and security situation in Hadzici municipality in this

12     document, and then the second item on the agenda was miscellaneous

13     issues?

14        A.   Yes.

15        Q.   Thank you.  Here it says that Ratko Radic from the

16     Serbian Territorial Defence and an army unit -- I can't find that in

17     Serbian -- [In English] "Serbian Territorial Defence and an army unit

18     needs to act together.  The Serbian population needs to be protected from

19     all possible attacks."  [No interpretation].  [In English] "It is

20     necessary to get organised as soon as possible to protect the

21     population."

22             [Interpretation] Was it only then that the people of Hadzici

23     began considering this issue of protection and defence in the event of

24     war?

25        A.   Yes.  That was the topic we discussed, how to organise ourselves

Page 11943

 1     in Hadzici.

 2        Q.   Thank you.  Then if we keep ongoing, we see that

 3     Nevenko Samoukovic says that the municipal assembly and authorities are

 4     not functioning and he mentions that -- can we have the next page in

 5     Serbian, please.  It is not legible enough, but basically what it says

 6     there is that the authorities and organisations are not functional; is

 7     that correct?

 8        A.   Well, yes.  That's how it was in 1991, practically the assemblies

 9     were held without Serbian representatives.

10        Q.   Thank you.

11             THE ACCUSED: [Interpretation] Can we now have 1D3247, please?

12     1D3247.  We are not sure whether we have a translation.  Yes, we do.

13             MR. KARADZIC: [Interpretation]

14        Q.   Under item 1 here, does it say that at this session of

15     11th April, organs and bodies of the Assembly of the Serbian People of

16     Hadzici were -- have been constituted and then it goes on to mention what

17     the organs are.  Is that correct?

18        A.   Well, yes, that's correct.  And I believe I've already discussed

19     this and answered questions about this document.

20        Q.   Thank you.  Would you please now take a look, after bullets A and

21     B, where it says:

22             "All the activities above, and taken by the Assembly of the

23     Serbian People of Hadzici, in order to protect the Serbian people and

24     preserve peace in the territory of Hadzici municipality."

25             And then -- is that what it says there?

Page 11944

 1        A.   Yes.

 2        Q.   And then in the last paragraph it says:

 3             "The Assembly of the Serbian People of Hadzici wishes to take

 4     this opportunity to call on all the inhabitants of Hadzici municipality

 5     to preserve peace and refrain from doing anything that might harm

 6     somebody else, and it also stresses that all the three people -- that the

 7     assembly wishes to emphasise that it will strictly abide by all the

 8     republican decisions by the three peoples aimed at solving the current

 9     crisis."

10             Is that what is stated there?

11        A.   Yes, that's correct.

12             THE ACCUSED: [Interpretation] Thank you.  Can we have this

13     document admitted, please?

14             JUDGE KWON:  Yes.

15             THE REGISTRAR:  As Exhibit D1066, Your Honours.

16             THE ACCUSED: [Interpretation] Can we now have 1D3248, please?

17             MR. KARADZIC: [Interpretation]

18        Q.   This is from the news agency "SRNA" and this is a public

19     proclamation.  The police of the Serbian Municipality of Hadzici, near

20     Sarajevo, has incessantly been capturing Muslim terrorists.  In addition

21     to the three men of two days ago, of which we've informed you, last night

22     14 others were captured at Veljko Polje on Mount Igman, and again, a

23     vehicle was captured, a refrigerated truck, and then it says what the

24     registration plates are, and then it says where a quantity of ammunition

25     and weapons was found.

Page 11945

 1             Then it goes on to say, "Za dom spremni."  What does that mean?

 2        A.   Well, that is a greeting used by Croats.

 3        Q.   From what period, Croats?

 4        A.   Well, from the time of the Second World War.

 5        Q.   Is that an Ustasha greeting?

 6        A.   Yes, that's correct.

 7        Q.   Thank you.  So registration of the vehicle was -- it was a

 8     Mercedes vehicle and then one could also read, on the equipment found in

 9     the vehicle, and the weapons, the name Mustafa Haris Plicanic.  And then

10     it goes on to say that the Serb MUP has decided that the -- has

11     discovered that the functionaries of the Muslim and Croatian MUP are

12     organising and preparing terrorist organisations against prominent Serbs,

13     intellectuals and activists, and that they have already organised.  Is

14     that something that was established by the police?

15        A.   Yes, but I would like to add something.

16        Q.   Please, go on.

17        A.   The case mentioned here, this incident, is something that I'm

18     very familiar with because -- both the first case where the

19     three terrorists were captured, and this other second case, and it was

20     really something that was done by my police, but I don't know how this

21     found its way into the news media because we didn't provide any

22     information.  But I recall this very well because we had just begun our

23     work and reorganised the police and we weren't very familiar with the

24     ground, and I know that the situation was under much better control at

25     Ilidza than it was in Hadzici, where I wasn't able to work as

Page 11946

 1     effectively.  I remember this but I cannot really comment on how this

 2     found its way into the media.

 3        Q.   Well, can we scroll up the document a bit and see the name of the

 4     journalists, Nedeljko Zugic.  He probably received this from a ministry.

 5     Yes, we can see that this was received from the Ministry of Information.

 6     Does that explain things a bit?

 7        A.   Well, yes, this is possible because the way we worked at the time

 8     was to provide written information to our superiors and the centre,

 9     central authorities, but I never did so myself.

10        Q.   Thank you.

11             THE ACCUSED: [Interpretation] Could we please have this admitted

12     into evidence?

13             JUDGE KWON:  We will mark it for identification pending

14     translation.

15             THE REGISTRAR:  As Exhibit D1067, marked for identification,

16     Your Honours.

17             MR. KARADZIC: [Interpretation]

18        Q.   Can it be concluded, then, that up until this time, there are no

19     overt clashes and conflicts up until the 19th of May -- or rather, the

20     17th of April, I apologise.

21        A.   Well, yes.  Up until the 17th of April, there was no fighting, no

22     overt clashes.

23        Q.   Thank you.  Do you recall that the leadership left for Pale as

24     early as the 5th of April, as soon as the conflict in the city itself

25     broke out?

Page 11947

 1        A.   I cannot recall the exact date, but I do remember that that was

 2     in early April, when you left for Pale.

 3        Q.   Thank you.  Do you remember that -- whether Hasan Efendic -- or,

 4     rather, that he had issued two directives on the 12th and 14th of April,

 5     about an all-out attack against the JNA, the Serb side, and the

 6     Serbian Democratic Party, and that following that, there was a small

 7     attack or minor attack on Ilidza and then on the 22nd of April, ensued a

 8     major attack on Ilidza?

 9        A.   Well, I am not really -- I don't know anything about that

10     personally.  I just heard of that, but I was not at Ilidza or in Ilidza

11     at the time.

12        Q.   Thank you.  But on the 22nd of April, did you provide assistance

13     to Ilidza because it had come under attack?

14        A.   Yes.  That's correct.

15        Q.   Is it correct, and were you informed, that Ilidza had been

16     attacked, the Serb part of Ilidza, from outside but also from within

17     Ilidza by the Muslims who lived on the Serb territory?

18        A.   Not only was I familiar with this but Mr. Tomislav Kovacevic was

19     in charge of the police and the situation at Ilidza was really alarming,

20     and I remember that at one point, he sent a panicky request for

21     assistance because he said, you know, You come and help us because

22     tomorrow it will be too late.

23             But let me also add that Ilidza and Hadzici are contiguous

24     territories and we always supported each other.  I always received

25     support from the police, but also from Mr. Tomislav Kovac or, rather,

Page 11948

 1     especially from him, so that we had already had different types of

 2     cooperation and that is why we also had received their assistance and

 3     they sent some units to help us.

 4        Q.   How did this affect the general atmosphere and the general state

 5     of mind of the Serb population, this attack on Ilidza by the Muslims?  In

 6     other words, am I correct in saying that the civilian population was

 7     terrified but also furious primarily with us because we did not prepare

 8     them sufficiently for -- to defend themselves?

 9        A.   Yes, that's correct.

10             THE ACCUSED: [Interpretation] Thank you.  I would like to tender

11     this document, please.

12             JUDGE KWON:  What document, Mr. Karadzic, are you referring to?

13             THE ACCUSED: [Interpretation] What we have in e-court, it is a

14     statement about these incidents, the discovery of weapons and so on.

15             JUDGE KWON:  Have we not marked it for identification already?

16             THE ACCUSED: [Interpretation] I apologise.  Very well.

17             MR. KARADZIC: [Interpretation]

18        Q.   When the conflict erupted, what was the situation with your chain

19     of command?  Is it correct that the communications were down, the

20     telephones, that they were compromised and damaged?

21        A.   Well, yes.  That was especially the case with the public security

22     station in Hadzici, and I've already said in one of my statements that we

23     had to move to an improvised building so that we had no means of

24     communication other than phones.  We didn't have the teleprinter, radio

25     communications, no communications whatsoever.  All we had was couriers,

Page 11949

 1     you know, you write a document down, you write something down, and then

 2     you give it to the courier to take it to an address.

 3        Q.   Thank you.  In paragraph 80 of your amalgamated statement, on

 4     page 32 and 33, you say that, for example, the political leadership

 5     including Karadzic issued instructions for convoys with students leaving

 6     Sarajevo, the -- can the participants find this or do I have to call it

 7     up in e-court?  The convoy has to be allowed to get to Ilidza -- through

 8     Ilidza to central Bosnia.

 9             [In English] "We had a lot of problems implementing this on the

10     ground.  Dr. Karadzic and his associates had a plan that he wanted to

11     effect, but on a later period, there was a different development on the

12     field.  I especially mean in the area of Ilidza and Hadzici.  I had a

13     feeling that the people in these areas were left to care for themselves.

14     For example, Dr. Karadzic or his political associates never came to

15     Hadzici."

16             [Interpretation] What is described and suggested in this

17     paragraph, that the local authorities during the first months of the

18     conflict were primarily left to their own devices and that there was no

19     communication between local and central authorities?

20        A.   Yes.  And just a small addition.  When I commented upon that,

21     when speaking to the Prosecution, I wanted to say that it was easy for

22     you and your leadership because you made declarations about certain

23     matters, but that we had terrible problems to implement certain things.

24     So it's along those lines, that it really has to do with what I said

25     already.  What you read out now is something that I firmly stand by, that

Page 11950

 1     we were left at everyone's mercy down there.  That's what I meant.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] Can we now have 65 ter 90221.  This

 4     is a record from the cantonal court in Sarajevo.  Could we have page 27?

 5             MR. KARADZIC: [Interpretation]

 6        Q.   So this is your testimony in the Jovicic case, right?  Do you

 7     remember that you testified there?

 8        A.   Yes.

 9        Q.   I would like to draw your attention to the second answer that you

10     gave.  Viewed from the top:

11             "Witness, so from the very beginning, how did people transfer

12     from the reserve police to the military police?"

13             And then the witness, you, say:

14             "Well, you know, how can I say, in the territory of the

15     municipality, I mean --"

16             The president of the Chamber says:

17             "Was that according to one's wishes and affinities?"

18             And the witness says:

19             "In the territory of the municipality where I worked, in the area

20     of which I was chief of police, this is how things worked, because we had

21     very poor communications with -- I mean our higher organs, so I mean in

22     that sense, the centre of public security and the ministry itself did

23     certain work at local level, but along with the decisions of the Crisis

24     Staff?"

25             Is that what you confirmed during that testimony as well, namely

Page 11951

 1     this absence of communication with higher organs?

 2        A.   Yes.  That's right.  It is obvious.

 3             THE ACCUSED: [Interpretation] Thank you.  Can this page be

 4     admitted?

 5             Or, if it's sufficient to have it in the transcript as I have

 6     read it out, we can deal with it that way.

 7             JUDGE KWON:  Let's do that in that way.

 8             THE ACCUSED: [Interpretation] Thank you.  Can we now place on the

 9     ELMO the proofing notes that we received from you through the OTP.

10             MR. KARADZIC: [Interpretation]

11        Q.   This was a few days ago, on the 13th of February, 2011.  You

12     spoke to Barry Hogan.  Could you please look at the first paragraph?  I'm

13     going to read it out in English:

14             [In English] "KDZ589 stated that while the SDS had good

15     organisation before the war, from the republic level to the municipal

16     level, when the war broke out things became chaotic."

17             [Interpretation] Is that the way it was?

18        A.   Yes.

19        Q.   Let us have a look at the next highlighted paragraph.

20             [In English] "KDZ589 feels that if the SDS had such great

21     organisation, then it would have -- not have been possible that so many

22     Serb people were caught by surprise and detained as they were."

23             [Interpretation] So that was your feeling?  Actually, the Serb

24     people were caught by surprise and totally unprepared, right?  The

25     pre-war system of communications and the structure was falling apart, and

Page 11952

 1     there were no proper solutions that were required by the new

 2     developments?

 3        A.   Well, that's how it was, but I don't see why you're taking this

 4     out of context.  Everything I said is contained in this document.

 5        Q.   Well, I can read all of it out but we don't have enough time.

 6        A.   All right, all right.  I apologise.

 7        Q.   Why don't you provide the context, then?  You lived in the Muslim

 8     area, there is a reference to Mr. Bratic here and so on.  You can tell us

 9     quite fairly how all of this happened.

10        A.   Well, let me tell you something.  I don't know how this appeared

11     in writing.  I spoke to Madam Prosecutor, and I thought that it was a

12     more or less informal conversation, and I wanted to provide my own views

13     regarding this organisation that permeated all of the questions that were

14     put to me from the lowest level to the highest level, organisation in its

15     entirety.  I was just trying to explain that things were not functioning,

16     and I tried to demonstrate this by providing a few examples from the

17     municipality of Hadzici.

18             To this day, that is what I claim.  I simply cannot accept that

19     someone thinks that there is some kind of proper organisation in place,

20     when there are drastic examples that can tellingly demonstrate that no

21     such concept ever existed, that there was this marvellous communication

22     between the top leadership and us.

23             I see that there is a reference here in English, there is a

24     reference to Bratic, Mile Bratic.  At this meeting that was discussed a

25     few moments ago, he was practically elected commander of the Serb

Page 11953

 1     Territorial Defence.  He lived in an area that was under the command of

 2     the Bosniak forces, so practically he was taken prisoner there like all

 3     other Serbs.  I was trying to explain that, what kind of organisation

 4     there was and how all of that functioned.  When a commander of the

 5     Territorial Defence who had just been elected is staying in an area under

 6     Bosniak control and is detained immediately, he was a prisoner at the

 7     silo straight away, and unfortunately, I have to say the man is

 8     five years younger than I am and he died years ago.  How do I explain

 9     this entire situation, when it is true that over 500 Serbs in the area of

10     Pazarici, Tarcin and wherever else were taken prisoner.  That is what

11     I tried to explain.  So you cannot really put it that way.

12             I don't want to take up too much time because I've already said

13     this, I mean how the first and second attack in Hadzici was repelled.

14     This was not organised by the SDS.  It is citizens who organised this, a

15     few of them prominent citizens, along with the assistance of the

16     technical institute.  The only fortunate thing for the Serb people in

17     Hadzici was that the technical institute was there on that territory and

18     it gave a major contribution to the defence of the area.

19        Q.   Thank you.  Can I understand it this way, then?  Although before

20     the war, the SDS was organised politically, but this political

21     organisation was not accompanied with appropriate preparations for

22     defence and that kind of organisation?

23        A.   Well, that's what I forgot to mention when I spoke to Ms. Carolyn

24     about this.  I see that there are two basic distinctions there.  What you

25     said just now, I'm not challenging that.  The Serb Democratic Party that

Page 11954

 1     had an excellent organisation before the war and it had a very good

 2     infrastructure from the highest to the lowest level, everything

 3     functioned like clockwork, the organisation of the Serb people and so on

 4     and so forth, and that went on, including distribution of weapons.

 5     However, at the very moment when war operations broke out, and I can say

 6     that with certainty, and I imagine that's the way it was everywhere, the

 7     organisation was shattered.  Local organisations were left to their own

 8     devices.  People on the ground were left to their own devices.  That's

 9     the way it was.

10        Q.   Thank you.  THE ACCUSED: [Interpretation] Is this sufficient, the

11     fact that we have this in the transcript?  Or should we adopt this

12     document as well?

13             JUDGE KWON:  I'm not sure whether we need to admit this.  It

14     won't be necessary.  They are already in the transcript.  If I can add,

15     to this, if the witness is to be agreeing with whatever you're going to

16     put, you don't have to put documents before him, necessarily, but it's up

17     to you, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] Thank you.  Let us go on and then

19     we are going to see whether we need the document as well.

20             MR. KARADZIC: [Interpretation]

21        Q.   At the very outset, there was no system in place and then a new

22     system had to be created, and this meeting on the 11th of April of the

23     Serb representatives in the municipality of Hadzici was in that context,

24     right?

25        A.   Yes.

Page 11955

 1        Q.   Thank you.  In the later period, as state authority was slowly

 2     being established and laws being passed, were more and more instructions

 3     coming in from the central level to your level, the local level?

 4        A.   I don't know what period you're referring to.

 5        Q.   Let us look at paragraph 74 of your amalgamated statement, on

 6     page 31.  I'm going to read it out in English so that you can receive

 7     interpretation.

 8             [In English] "Directives from military, political and police

 9     ministry ordered that these paramilitary forces be subordinated to the

10     military commands and ought to be disbanded and even liquidated if they

11     refused."

12             [Interpretation] Is it correct -- is it correct that such

13     instructions could come only in the later period, from May onwards, May,

14     June, et cetera, because of the disintegration of the system?

15        A.   Yes, yes.  I don't know.  My comment had to do with the presence

16     of paramilitaries so that's why I didn't understand.  At any rate, yes.

17        Q.   After May, after May, so it's not from the beginning of May but

18     from May onwards.  From that point of view, were there any instructions

19     that pertained to the protection of civilians of other ethnic

20     backgrounds, then also the honouring of international humanitarian law,

21     et cetera?

22        A.   Yes.

23        Q.   Am I right if I say that the second half of 1992 was spent

24     establishing law and order as such?

25        A.   Yes.  That is quite correct.  All public security stations,

Page 11956

 1     including my own, the one that I headed, were busy at first with

 2     permanent war operations.  Later on, we moved on to something that I

 3     cannot exactly call peacetime structure, but at any rate, we did go back

 4     to our regular work as well.

 5        Q.   Thank you.  We are going to go back to that, the capacity of the

 6     police and the number of active duty policemen.  I'd like to draw your

 7     attention to paragraph 62 of your amalgamated statement, page 26.  Sorry,

 8     actually, do you have your statement in Serbian?

 9        A.   No, I don't.

10        Q.   I'm going to read it out in Serbian, then:

11             [In English] "So you were informed by the commander of this

12     action."

13             [Interpretation] It has to do with the action in Musici, the

14     police action.

15             [In English] The answer is:  "Yes."

16             "Q.  He told you that three persons got killed?"

17             Answer is:

18             "Yes, I found out that the action was taken in Musici hamlet,

19     that's where -- that there was an armed resistance and that these people

20     unfortunately got killed."

21             "Q.  Did the crime police officer conduct an investigation as to

22     the deaths of the three civilians or residents and one of the Serbs, as

23     you said?

24             "A.  If you are referring to the classic standard crime scene

25     inspection, I don't think that there were conditions in place to carry

Page 11957

 1     out a crime scene inspection.  But some operative actions and activities

 2     were taken and I'm sure that this was -- that the full information was

 3     delivered in writing and then forwarded to the centre and to the higher

 4     chain of command in the Ministry of Interior."

 5             [Interpretation] Are you suggesting by way of this paragraph that

 6     the state organs -- actually, can we conclude that state organs were

 7     concealing this or other crimes, or did they document them?  Actually,

 8     were there attempts to hush things up, and after providing documentation,

 9     can one speak of hushing up generally?

10        A.   That's out of the question.  The main purpose was exactly to

11     present this kind of situations until such time comes that we can

12     undertake certain measures.  But as I said, we were not able to carry out

13     standard crime scene investigations due to the prevailing situation.

14     This was only written in documents and then forwarded to the competent

15     institutions such as the centre and the ministry.

16        Q.   If I tell you that even nowadays, both in the federation and

17     Republika Srpska, there are trials based on criminal reports and other

18     documents provided during the war, do you find that convincing?

19             JUDGE KWON: [Microphone not activated] Mr. Karadzic, move on to

20     your next topic.  I said, how relevant is that?

21             MR. KARADZIC: [Interpretation]

22        Q.   Well, I wanted to find out whether the police documented certain

23     things and whether that would be forwarded to the courts was up to the

24     circumstances.  I all -- wanted to know whether, as a rule, police filed

25     all the crime-related documents.

Page 11958

 1        A.   Yes.  And I can tell you with full certainty, not only about this

 2     case but about hundreds of other cases, and everything is recorded,

 3     everything that happened in Hadzici and Ilidza, that was of security

 4     interest.  We only had certain gaps and shortcomings in the initial

 5     period.  However, in the latter part of 1992, until the end of the war,

 6     I say categorically that everything was recorded.  You, yourself, would

 7     be surprised if you saw how many documents exist that are going to be

 8     used at the trials in Bosnia-Herzegovina and Republika Srpska.

 9        Q.   I'm waiting for the interpretation.  Did it ever happen that

10     somebody intervened from a higher level for certain incidents to be

11     covered up?

12        A.   I don't have such experience, and I don't think that anyone else

13     does, but I particularly didn't have such experience.

14             THE ACCUSED: [Interpretation] Now, can we have 3244 -- 1D3244 in

15     e-court, please?

16             MR. KARADZIC: [Interpretation]

17        Q.   This is a document that you produced for the month of April 1992.

18     We don't have a translation but we can see what it means.  Does this

19     document prove who was on the --

20             JUDGE KWON:  Just a second.

21             Yes, Ms. Edgerton?

22             MS. EDGERTON:  We will give you the translation within a couple

23     of seconds.

24             JUDGE KWON:  Thank you.

25             THE ACCUSED: [Interpretation] The Defence would be extremely

Page 11959

 1     grateful if we could receive a translation along with the original, but

 2     that's going to be rectified at any rate.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Now, Mr. Glavas, does this document show that on your payroll you

 5     had 30 police officers, including the chiefs, commanders, deputy

 6     commanders, and you only had 25 regular police officers; is that correct?

 7        A.   Yes, it is.

 8        Q.   So we are talking about April 1992, is it correct, as you said a

 9     minute ago, that out of this number, a considerable number of people

10     mentioned here were involved in defence operations rather than in police

11     work?

12        A.   Well, they nearly didn't do any police work at all.  They were

13     very much occupied and busy in war operations.

14             THE ACCUSED: [Interpretation] Can we have this document admitted

15     into evidence, since we have the translation so it doesn't have to be

16     marked for identification first?

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  As Exhibit D1068, Your Honours.

19             MS. EDGERTON:  And we've e-mailed the translation across the

20     room.

21             JUDGE KWON:  Thank you very much.

22             THE ACCUSED: [Interpretation] Thank you.  Can we have 1D3245,

23     which refers to the following months?  And let's look at the situation

24     then.  1D3245.

25             MR. KARADZIC: [Interpretation]

Page 11960

 1        Q.   Is this the list of employees serving at your station in May of

 2     1992?

 3        A.   Yes.  But I can't see the whole list.

 4        Q.   Can we please scroll up and after that I'd like to see page 2.

 5     Can we move now to page 2, please?

 6        A.   It's all right.

 7        Q.   It seems that you have been -- had been reinforced during that

 8     month by two additional policemen, because we see there are 32 of them

 9     now on the list; is that correct?

10        A.   Yes.

11             THE ACCUSED: [Interpretation] Can this be admitted into evidence?

12     I believe there is a translation of this document as well in the hands of

13     the OTP.

14             JUDGE KWON:  Do we?

15             MS. EDGERTON:  It's also just been e-mailed.

16             JUDGE KWON:  Thank you.  That will be Exhibit D1069.

17             THE ACCUSED: [Interpretation] And can we now have 1D3246?

18             MR. KARADZIC: [Interpretation]

19        Q.   Tell me, were policemen being killed during that period,

20     Mr. Glavas?

21        A.   Yes.

22        Q.   This is the last month of your tenure in Hadzici, i.e.,

23     July 1992.  Now we see that you had lost seven men in one way or another,

24     and that along with the executive personnel, you have a total of

25     25 staff; is that correct?

Page 11961

 1        A.   Yes.

 2             THE ACCUSED: [Interpretation] Can we have this admitted into

 3     evidence?

 4             JUDGE KWON:  As well, we have English translation?

 5             MS. EDGERTON:  No.

 6             JUDGE KWON:  No.  We will mark it for identification.  Or do we

 7     need an English translation?  Let's do that.  Yes.  We mark it for

 8     identification pending translation.

 9             THE REGISTRAR:  As Exhibit D1070, marked for identification,

10     Your Honours.

11             MR. KARADZIC: [Interpretation]

12        Q.   But in addition to these police officers, every police station

13     had some administrative staff, so you are not counting them as members of

14     the police staff; is that correct?

15        A.   I don't think that we had these services set up at the time.

16             THE ACCUSED: [Interpretation] Can we now have 1D3239, please?

17             MR. KARADZIC: [Interpretation]

18        Q.   This is your response to the request from the ministry for

19     information about the structure and the situation in your station.  A

20     total number of active duty police officers required for the police

21     station to successfully carry out its duties is 44; is that correct?

22        A.   Yes, because we had some serious thought at that point that the

23     police station should start doing its duties and jobs.

24        Q.   But previously it says that you had 26; is that correct?

25        A.   Yes.

Page 11962

 1        Q.   And then there is a note which says that we have exhausted all

 2     the possibilities of recruiting a larger number of reserve police

 3     officers because they were engaged in other units as military conscripts.

 4             Can we scroll up so that you can see this part of the document?

 5             We note that we have exhausted the possibility of engaging a

 6     larger number of reserve police officers because supposedly these reserve

 7     police officers are military conscripts and are engaged in other units.

 8             Is that the point?

 9        A.   Yes, because at that point, since we had so few people, I think

10     that the priority was given to army units.

11        Q.   So you were proposing to increase up to 200?

12        A.   That's correct.

13             THE ACCUSED: [Interpretation] Can we have this admitted into

14     evidence?

15             JUDGE KWON:  I note again there are so many documents

16     untranslated.  Having said that, we will mark it for identification

17     pending translation.

18             THE REGISTRAR:  As Exhibit D1071, marked for identification,

19     Your Honours.

20             THE ACCUSED: [Interpretation] I believe that last week we

21     presented around 100 documents and that I think that fewer than five have

22     been translated, but I do accept your criticism and we will do our best

23     to remedy this.

24             MR. KARADZIC: [Interpretation]

25        Q.   You had information about large-scale arrests of Serbs who

Page 11963

 1     remained in the areas where Muslims were a majority; is that correct?

 2        A.   Yes, it is.

 3        Q.   I would like now to remind you of a sequence of certain events,

 4     so feel free to tell me, "yes" or "no," or that you don't know.  So it's

 5     totally up to you.  I'm not expecting you to know everything, but as a

 6     member of the police force, I suppose you knew a lot.  In October of

 7     1991, the SDA's deputies -- SDA deputies acted arrogantly and that

 8     prompted the SDS deputies to walk out of the parliament sessions.  Are

 9     you aware of that?

10        A.   Yes, I am.

11        Q.   Now, in 1991 and 1992, the Serbian population in Hadzici were

12     restless and anxious, and due to that, they posted guards in the Serbian

13     villages, in fear of being attacked by somebody; is that correct?

14        A.   Yes, it is.

15        Q.   Can we say that as far as back in March of 1992, reasonable Serbs

16     and Muslims set up joint patrols in order to provide the protection for

17     their villages and create the sense of security?

18        A.   Yes, that's absolutely true.  In the majority of mixed

19     settlements, we had situations of that sort.

20        Q.   Thank you.  Is it correct that on the 8th of May, the Muslims

21     blocked the entrance to the repair and maintenance centre and that

22     negotiations were initiated, but that during the night, they withdrew

23     after fire was exchanged between Muslim and Serbian villages?

24        A.   I can't remember that information.

25        Q.   I have information here that on the 9th and 10th of May, 1992,

Page 11964

 1     the Muslims, at their own initiative, left the centre of the town of

 2     Hadzici towards Pazaric and Tarcin.  Is that what you refer to as a

 3     departure that was carried out according to the Crisis Staff order?

 4        A.   Yes, that's it, but I don't think I mentioned that particular

 5     date.

 6        Q.   Is it correct that about one or two days later, there was a clash

 7     between the Muslims and the Serbs because the Serbs -- the Muslims

 8     attacked Hadzici from Tinovo and Igman in the early morning hours?

 9        A.   Which date did you mention?

10        Q.   11th of May.

11        A.   Yes.

12        Q.   Thank you.  Is it true that from the 11th of May onwards, there

13     was daily fire opened at Hadzici from artillery weapons and from sniper

14     rifles and that the whole area was encircled by the Muslims except the

15     route that led to Ilidza?

16        A.   That's correct, but later on, it turned out to be sporadic fire

17     that was an attempt to tie up our forces.  Actually, the idea behind that

18     was to attack the barracks.

19        Q.   So on the 12th of May, they captured the Krupska Rijeka barracks

20     and killed a number of JNA soldiers in the process and captured a number

21     of them.  Until 1993, that was Muslim-run prison for the Serbs; is that

22     correct?

23        A.   Yes.

24        Q.   Is it true that in late May 1992, there was a conflict between

25     members of the JNA and the Muslim forces?  Thank you.  Let us look at a

Page 11965

 1     specific example --

 2             JUDGE KWON:  Did we hear the answer to the last question?  Did

 3     you say yes, Mr. Glavas?  Because your answer was not translated.

 4             THE WITNESS: [Interpretation] Yes.  I said that about the attack

 5     on the Krupska Rijeka barracks.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Now, let's go into some detail regarding the Musici incident.  Is

 8     it true that the JNA was legally in Bosnia-Herzegovina until 20th of May?

 9        A.   Yes.

10        Q.   Did the Musici incident take place on the 20th of May?

11        A.   Correct.

12        Q.   Therefore, the Musici incident was preceded by a successful

13     action in Krupska Rijeka and the capture of the barracks there; is that

14     correct?

15        A.   Yes, it is.

16        Q.   Can we now shed some light on the situation although you came

17     only after the Musici event.  Is it true that people were killed on both

18     sides in Musici?

19        A.   Yes.  That's correct.  The first one to be killed was a Serb,

20     I think his name was Zoran Pusara, and after that, three Bosniaks were

21     killed.

22        Q.   Was there fire opened on a daily basis from Musici on the road

23     leading to Donji Hadzici and was a decision taken to search for weapons

24     in Musici actually prompted by these constant fire?

25        A.   Precisely so.

Page 11966

 1        Q.   In Musici itself, had Muslims already been organised in military

 2     units and had their squads, platoons and so on, in other words military

 3     organisation?

 4        A.   Yes.  And I believe I've already mentioned that in the BH court.

 5        Q.   I beg your indulgence.

 6             THE ACCUSED: [Interpretation] Could we now please have

 7     65 ter 90221?  This is your testimony in Sarajevo, before the Sarajevo

 8     court, in the Jovicic case.  Page 21, please.  We have page 21.  Could we

 9     please see 24?  Here we see the first answer that you gave there.  The

10     question was whether the police had noticed before those conflicts that

11     the civilian population was leaving Hadzici, and then your answer:

12             "Well, yes, you see, it was a very special situation down there

13     in Hadzici.  At the moment when the police was divided, what followed

14     practically was the division of all the other institutions, government

15     institutions, in the municipality.  And what we observed, and that was

16     very indicative and would later have ramifications, was that at this time

17     we observed mass movements of the civilian population out of the

18     municipality.  In other words, a large majority of the population was

19     moving from Grivici, for instance, towards Ormanje, from Dupovci towards

20     Pazarici, from Zunovnica towards Igman.  There was a mass pullout of the

21     population and we knew that an all-out attack would follow, which, in

22     fact, materialised and happened on the 20th of May, I believe."

23             Is that correct?

24        A.   Yes.  That's correct.  This is what I said in court.

25        Q.   In other words, no one forced them to leave but, rather, as you

Page 11967

 1     said, on orders from their Crisis Staff, they moved out, which led you to

 2     conclude that there would be an attack, which is, in fact, how it

 3     happened.

 4        A.   Well, we did not interpret anything.  We knew for a fact that

 5     there would be an attack.

 6        Q.   Thank you.  As you were not present during the attack in Musici

 7     itself, I would move on to another incident.

 8             THE ACCUSED: [Interpretation] Can we now please have 65 ter 1549?

 9     Your Honour, if you feel that this is sufficient, we need not tender this

10     document into evidence, perhaps.

11             JUDGE KWON:  It's up to you, but speaking for myself, I don't

12     think we need to admit this, given that everything he confirmed is in the

13     transcript.

14             THE ACCUSED: [Interpretation] Thank you.  Can we now have

15     65 ter 1549, please?

16             MR. KARADZIC: [Interpretation]

17        Q.   This is a report, it was admitted as D317.  It's an exhibit

18     already.  And it says, a report of the 28th, I believe, of May 1992.  No,

19     29th of May, 1992.  If we look at the last paragraph, it says:

20             "Following the situation, the enemy assess that they could, if

21     they prepare a terrain attack with arms against Zunovnica storage with a

22     force of an infantry battalion.  The attack took place on the

23     25th of May, 1992, in early morning hours, and from two directions.  One

24     company along the axis of Crne Stijene-Zunovnica station -- could we move

25     on to the next page in Serbian, please?  Thank you.  And the 2nd Company

Page 11968

 1     should move along the axis Lokve-Kasetici-Zunovnica storage with the

 2     purpose of taking over the depot premises.  They were largely successful

 3     and took control of three-fourths of the storage premises and the

 4     buildings there."

 5             Is this consistent with what happened?

 6        A.   Yes, it is.

 7        Q.   Thank you.  We can skip the next paragraph, and then, we can

 8     read:

 9             "After taking in consideration the entire situation, the

10     commander of the Serb Republic of Bosnia-Herzegovina Main Staff decided

11     to deploy a strengthened combat group under the command of the chief of

12     the Serb artillery, Colonel Zivanovic."  I hope everyone can see this.

13     "And that on the 26th of May, 1992, at 1900 hours, they accomplished that

14     mission and recaptured part of the depot.  In the first combat phase,

15     that is, until the combat group arrived, we had the following losses:

16     Dead, 15 soldiers; wounded, 25; and missing, 9; and one defender of

17     Kasetici village was killed; slaughter of members of the Serb population

18     of Kasetici village, six."

19             Were these civilians who were slaughtered?

20        A.   Yes.  There were criminal complaints and the perpetrators of this

21     crime are -- were discovered.

22        Q.   Very well.  And then it goes on to say, in the second phase, when

23     the combat group arrived, there were no casualties.  And then there

24     follows a report on what had been looted from the depot.

25             Now, could you tell us please what these Zunovnica barracks, what

Page 11969

 1     was that, whose was it, who it did it belong to?

 2        A.   The Zunovnica depot was --

 3             THE INTERPRETER:  Interpreter's note:  Could the witness please

 4     repeat his answer from the beginning?

 5             JUDGE KWON:  Mr. Glavas, could you repeat your answer?  The

 6     interpreters couldn't hear you.

 7             THE WITNESS: [Interpretation] This was a barracks, or rather, a

 8     depot of the former JNA, which housed a number -- a large quantity of

 9     ammunition and shells.

10             MR. KARADZIC: [Interpretation]

11        Q.   According to the number of buildings mentioned here, was -- would

12     you say that this is a large number of facilities?

13        A.   Well, in fact, there were few -- there were many more than here,

14     than mentioned here.

15        Q.   This village of Kasetici, where the six civilians were

16     slaughtered, was that a Serbian village in Hadzici municipality?

17        A.   Yes.  But I wouldn't say it was Serb.  It was a mixed village.

18     There were both Bosniaks and Muslims, in one part there were Bosniaks,

19     and in another Serbs, and unfortunately the Serbs who were there, they

20     were slaughtered by their neighbours, their Muslim neighbours.

21        Q.   Thank you.  Could we now have the next page in Serbian and the

22     English is fine.  That's exactly the part we need.

23             "After stabilising our own lines, we -- it is our assessment that

24     we inflicted large losses on the enemy in personnel.  According to our

25     information so far, the losses that the enemy suffered were around

Page 11970

 1     130 personnel.  Following stabilisation of our own ranks, we approached

 2     to the realisation of two main tasks as follows:  First, mobilisation of

 3     men and establishing of the Hadzici Battalion infantry -- Infantry

 4     Battalion.  We have difficulties with this task because armed men are

 5     self-organised and they have very skewed convictions concerning their

 6     defences and the defences of their own homes."

 7             Is this consistent with what you could observe at this time at

 8     the end of May?

 9        A.   Well, yes.  This was a daily occurrence, and I have to say that

10     we had great difficulty to actually defend our own doorsteps, and chasing

11     people away from there.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] Could we now have the next page,

14     could we scroll up the English version or, rather, could we have the next

15     page in both versions?  In English it's the previous page.

16             MR. KARADZIC: [Interpretation]

17        Q.   I would like to ask you something about the work obligation.  Is

18     that something that was regulated by law in the former Yugoslavia in

19     wartime conditions?  In other words, that all civilians were to be

20     mobilised either in military units or to be engaged in work units?

21        A.   Well, that's correct.  That was regulated by the Law on

22     All People's Defence.

23        Q.   Here we see that it is proposed that all able-bodied men in the

24     repair and maintenance centre should cease to be paid employees that

25     apply in peacetime, but, rather, be assigned to work details that would

Page 11971

 1     apply in wartime conditions; is that correct?

 2        A.   Yes.

 3        Q.   Thank you.  Did this work obligation, is that something that

 4     applied to all citizens regardless of their faith or ethnicity?

 5        A.   Yes.  That's correct.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can we now, please, have 65 ter

 8     1648?  65 ter 1648.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Are you aware that at one point in time, in the Serbian

11     Municipality of Hadzici, at the municipality of Hadzic, a forward unit of

12     the Ministry of Defence was established, which was the case per

13     establishment in each municipality?

14        A.   Yes, I'm aware of that.

15        Q.   Did this Ministry of Defence section deal with mobilisation and

16     civilian affairs in the service of the army?

17        A.   Precisely.

18        Q.   Thank you.  Here we see a report on their work between August 1st

19     and December 20th, 1992.

20             Can we now have the next page, please?  Can we have page 3,

21     please?

22             Here we see mention is made of the establishment of this unit

23     pursuant to the Law on the Army and it also cites the law on which -- on

24     the basis of which it was established.  And then it says that it shall be

25     responsible for organising and the carrying out mobilisation in work

Page 11972

 1     organisations and so on and so forth.  Now, let's see item 2 here on this

 2     page, the establishment of defence organs, and then it says:

 3             "At the request of the Ministry of Defence, on the

 4     16th of July, 1992, a section of the Ministry of Defence of Hadzici was

 5     established and Stojic Milovan was appointed as its chief."

 6             This was, in other words, at the proposal of the

 7     Executive Council that had been established on the 18th of April; is that

 8     correct?

 9        A.   I'm not sure what Executive Council or board you're referring to.

10        Q.   Well, in any case, at the proposal of some Executive Council,

11     this person, Milovan Stojic was appointed chief of the office and this

12     occurred on 16th of July, 1992?

13        A.   Well, yes.  I am aware of that, and this person, I'm familiar

14     with his name, too.

15        Q.   And then it goes on to say that the situation is as follows:  All

16     previous records have been destroyed, part of them were taken to the

17     command of the city of Sarajevo, part were taken -- a part of them were

18     taken by the SDA.  And then can we have the next page in Serbian?  The

19     reporting centre was practically disestablished, plundered and

20     demolished, all communications equipment stolen.  And then it says it was

21     necessary to start from scratch.  The circumstances surrounding the

22     establishment of this organ were as follows:  All military records have

23     been destroyed, the territory of the former municipality was cut in half.

24     New refugees have already arrived.

25             Is it correct that Hadzici was on the front line, as it were,

Page 11973

 1     towards Herzegovina and the areas under the control of the Muslim army,

 2     and that a large number of refugees actually came into Hadzici from those

 3     areas?

 4        A.   Yes, that's absolutely correct.

 5        Q.   Did refugees begin coming already at the time while you were

 6     still in Hadzici?

 7        A.   Yes.

 8        Q.   Is it correct that the municipality had the obligation to

 9     accommodate these people and to provide food for them?

10        A.   Well, yes.  That was our responsibility, of the authorities.

11        Q.   Is it correct that these people were unhappy and very angry and

12     that it was necessary to take extraordinary effort in order to stop them

13     from taking action to avenge whatever had happened to them?

14        A.   Yes.

15        Q.   Now, let's take a look at what it says later on.  In this

16     context, this organ was an active participant in taking -- in the context

17     of these activities, this organ participated in the reception of

18     three large convoys of refugees from Zenica, Kakanj, Vitez, and Busovaca.

19     It was necessary to -- can we have the next page, please?  The next page

20     in Serbian.  It was necessary to receive, accommodate, register, and

21     place these people in different homes.  And in addition to these three

22     convoys, there were also numerous smaller groups of refugees arriving.

23             So is this what happened?  Did the municipality take action to

24     receive these refugees and did this actually drain the municipal funds?

25        A.   Well, I believe that the greatest problem was, in fact, with

Page 11974

 1     these mass exodus from central Bosnia of refugees who then came into

 2     Hadzici, and I believe that those refugees were the ones who created the

 3     most problems.

 4        Q.   Thank you.  Can we have the next page in Serbian?  I believe that

 5     we had it in English, that particular section.  I would like to draw your

 6     attention to this:

 7             "Various orders and letters were used in order to establish

 8     communication with the General Staff of the army and the Presidency, but

 9     we didn't manage to do that it.  In mid-September, we managed to break

10     down this barrier and establish operation, that is at enviable level

11     today."

12             Does this confirm the information that you gave, namely that

13     central organs could not be reached easily before mid-September?

14        A.   Yes.  I think that that confirms precisely what I said a few

15     moments ago.

16        Q.   Can we have the next page in Serbian?  I believe it's the

17     last page in English as well.  Now, this is what it says down here, that

18     various certificates and permits within its jurisdiction shall be issued.

19     Is it correct that whoever would want to move about freely would have to

20     seek a certificate stating that he was already engaged in work obligation

21     or in the military?

22        A.   Yes.

23        Q.   Was that useful for that particular person, in order to ensure

24     freedom of movement?

25        A.   Yes.  With appropriate papers one could move about, as it were.

Page 11975

 1        Q.   Thank you.  Let us see what it says what the problems here are.

 2     Inadequate premises, lack of basic equipment, insufficient cooperation

 3     with responsible institutions, strong pressure for engagement on the

 4     basis of work obligation.

 5             Is it correct that most people wanted to have work obligation,

 6     that they preferred it to wartime obligation and that this brought the

 7     possibility of getting a bit of a salary and some extra food and so on?

 8        A.   Well, yes.  People avoided wartime obligation.

 9        Q.   So people, the population, were seeking work obligation.  I'm

10     asking you this because sometimes work obligation is termed as negative

11     discrimination.  Does this seem to show that that is positive

12     discrimination, when you get work obligation?

13        A.   Well, it was positive discrimination.

14        Q.   Thank you.

15             THE ACCUSED: [Interpretation] Excellencies, is it time for the

16     break?  Can this document be admitted?

17             JUDGE KWON:  Yes, this will be Exhibit D1072.

18             MR. ROBINSON:  Excuse me, Mr. President.  I was informed that the

19     Prosecution has provided us a translation of D1071 and we'd appreciate if

20     that could be admitted as an exhibit rather than MFI.

21             JUDGE KWON:  Can you confirm that, Ms. Edgerton?

22             MS. EDGERTON:  Yes.

23             JUDGE KWON:  That will be done.

24             We will have a break for half an hour and resume at 11.00.

25                           --- Recess taken at 10.30 a.m.

Page 11976

 1                           --- On resuming at 11.02 a.m.

 2             JUDGE KWON:  Yes, Mr. Karadzic.  Please continue.

 3             THE ACCUSED:  Thank you.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   We saw what you knew and what your position was, namely that

 6     there weren't enough contacts between the local level and the central

 7     level, and as a matter of fact, people out there felt betrayed.  And

 8     I would like to show you paragraph 24 of your consolidated statement, on

 9     page 9.  I'm going to read it out:

10             [In English] "Politicians at this time did not really count on

11     controlling Hadzici because of the Bosniak majority.  A lot of success

12     was attributed to Radic and that's another reason he remained there, but

13     this was really an illusion.  Radic spent most of his time with Karadzic

14     in Pale during this critical period."

15             [Interpretation] Can you tell us specifically which critical

16     period you meant?  Before the war broke out or afterwards?

17        A.   I think it refers to the period before the war broke out.  May

18     I just add something?

19        Q.   Please go ahead.

20        A.   It could not have pertained to the period when the war broke out

21     because I remember that in one passage of the statement I gave in

22     Sarajevo, I said that Mr. Ratko Radic for a while - actually, I think

23     I actually referred to the date too - was absent from the area.

24        Q.   Thank you.  Do you remember that -- sorry, are you referring to

25     the outbreak of war in Sarajevo on 6 April or are you referring to the

Page 11977

 1     outbreak of war in Hadzici a bit later?

 2        A.   Whatever I said, I was referring to the areas I know very well,

 3     Hadzici and Ilidza.

 4        Q.   Thank you.  Did you know that before the war broke out, on the

 5     6th of April, I was in Sarajevo throughout and that until the

 6     1st of March, until the barricades were put up, I did my regular work,

 7     I went to the clinic to work?

 8        A.   I know that, yes.

 9        Q.   Thank you.  First of all, let us see what the people thought

10     there, that the Serbs were not counting on the municipality of Hadzici

11     because there was not a Serb majority there.  Do you remember, I think we

12     mentioned that, that in case the peace were to be maintained, that

13     municipalities would be organised, namely, wherever possible,

14     two municipalities should be established, and in that sense, the Serb

15     municipality had counted on having two municipalities set up in the

16     municipality of Hadzici?

17        A.   Yes.

18        Q.   The talks that you referred to in this paragraph have to do with

19     this time before the war, and it's on the assumption that there will be

20     no war, right?

21        A.   Precisely.

22        Q.   Thank you.  In the next paragraph of your statement,

23     paragraph 25, you say:

24             [In English] "Ratko Radic's relationship, as Crisis Staff

25     president and SDS president, with Radovan Karadzic and the

Page 11978

 1     Serbian Republic leadership was very good.  I think that he had very good

 2     communication with Dr. Karadzic and connections.  I base this on his

 3     trips to Pale.  He would often say that he came from Pale and got

 4     instructions from Dr. Karadzic.  You could tell from his behaviour that

 5     he was close to Dr. Karadzic.  I can't give you any concrete examples

 6     when he came back with orders, but I can just tell you that he regularly

 7     went to Pale to visit Karadzic.  He often went to Pale with Vido Banduka,

 8     president of the Executive Board of the Serbian Municipality of Hadzici.

 9     Also Nevenko Samoukovic and Radislav Pejetic [phoen] would travel to Pale

10     with Radic to meet with Dr. Karadzic.  They were all presidents of the

11     municipality Executive Board at different times.  Ratko Radic always

12     remained in his position of a president of the municipality until the end

13     of conflict."

14             [Interpretation] Do you remember that a moment ago we saw a

15     document stating that it was only in mid-September that this barrier

16     could be broken through, namely that the state leadership could be

17     reached?

18        A.   Yes, you mean the Ministry of Defence.

19        Q.   Thank you, yes.  Am I right when I say that that was the

20     impression that had been created, that Radic had created, however, you

21     never saw the instructions that Radic received from the state leadership,

22     right?

23        A.   Yes.  That is exactly what it's all about.  It has to do with

24     impressions.  Very often he told us that he was with you up there in Pale

25     and he did this very unpleasant thing.  Whenever he wanted to have any

Page 11979

 1     idea carried through in that area, he always referred to you.

 2        Q.   Thank you.  I would like to ask you briefly whether you remember

 3     that the very existence of the Crisis Staff was a regular thing, when

 4     there would be power cuts, when, for example, these days there was no gas

 5     coming in from Russia, when there would be an earthquake and things like

 6     that, that a Crisis Staff would be established?

 7        A.   Yes, practically every time something like that happened, a

 8     Crisis Staff would be established, before the war as well.

 9        Q.   Thank you.  Do you agree that Crisis Staffs, or, rather,

10     War Presidencies, or, rather, these smaller organs of government were

11     actually supposed to stand in for larger organs like parliament when

12     parliament could not meet, like in war?

13        A.   Yes.

14        Q.   Do you remember that all decisions of the state leadership and of

15     the municipal leaderships were supposed to be confirmed at the sessions

16     of parliament that would be held as soon as possible, both at state level

17     and at municipal level?

18        A.   Yes.

19        Q.   Thank you.

20             THE ACCUSED: [Interpretation] Can we now have a look at

21     65 ter 1523?  Can we go back to the critical events that were taking

22     place in the municipality itself?  Of course, we are going to deal with

23     this through documents.

24             MR. KARADZIC: [Interpretation]

25        Q.   We have to go back to the 12th of May.  Please focus on all of

Page 11980

 1     it.  But we have this second paragraph here, sorry, can we agree that

 2     this was on the 12th of May, 1992, and that is the Ministry of the

 3     Interior?  This is a bulletin of daily events, right?

 4        A.   Yes.  I see that that's it.

 5        Q.   This is what the police is reporting about what happened on the

 6     12th of May, the second paragraph:

 7             "Heavy exchange of fire between Serb defence forces and members

 8     of the TAR," I guess that's Tarcin Territorial Defence -- oh, TZV, that

 9     is so-called, the so-called TO of the former BiH has been going on for

10     more than two days in the Hadzici area.

11             "Despite the unequal balance of forces with Serbs being fewer in

12     numbers, attacks of Muslim paramilitary formations have been resisted

13     successfully.  The situation in Hadzici is still very difficult, at the

14     moment, the area of Krupacka Rijeka, Tinovo Brdo and JNA facilities in

15     Zunovnica are besieged.  However, Serb forces control this area and have

16     the situation under control for the time being."

17             Does this have something to do with that attack of the

18     Green Berets that is referred to in that previous sentence up there?

19        A.   Well, what was meant here was the attack that took place against

20     the barracks in Krupa.  Now, the sporadic gunfire around Hadzici, as

21     I said a few moments ago, this was manoeuvring on their part to draw our

22     forces away so that they could carry out an attack, as they did at the

23     barracks in Krupa.

24        Q.   Thank you.  Now I would like to ask you to shed more light on the

25     question of paramilitaries and their relations with the local

Page 11981

 1     authorities.

 2             THE ACCUSED: [Interpretation] Can this previous document be

 3     admitted, this daily bulletin?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  As Exhibit D1073, Your Honours.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   So we have 1D3240, which is identical to 65 ter 23088, and

 8     I think it would be more advisable if we call up 23088.  On the

 9     6th of August, you left Hadzici.  Do you remember leaving behind of

10     certain aggregate report concerning the events that happened up until

11     that time?  So that was sent, or, rather, dated 9th of, August, 1992, it

12     was sent to the Sarajevo CSB, do you recall that?

13        A.   All I remember is based on the comments given by the OTP.  I am

14     more or less familiar with the content, and as far as I can recall, I can

15     see that my name is there and my signature is there, but it was not me

16     who signed it.  Although there is mention of certain things that

17     pertained to my period, by that time I was already in Ilidza.  It is

18     dated the 9th, and I was at Ilidza already at the 6th.  Practically, I

19     hadn't been relieved of my duty of the police chief in Hadzici, so

20     apparently somebody signed this on my behalf.  However, if you want to

21     ask me about the contents of this document, I don't see any problem

22     because I am more or less familiar with those things.

23        Q.   Thank you.  There is a case relating to a 1993 document which is

24     close to the period while you were between two positions, but am I to

25     understand that the contents of this document is consistent with the

Page 11982

 1     knowledge that you have, because three days prior to this date, you were

 2     in charge of that centre?

 3        A.   Yes.  I am familiar with all the events described in this

 4     document.

 5        Q.   Can I now direct your attention to item A?  I'm not going to read

 6     it all.  And here you explain that after the setting up of the Serbian

 7     police station Hadzici, or in the process of its forming, and in the

 8     following 14 days, we noticed the activities of certain small groups of

 9     so-called 'free agents,' but there were no significant or proper

10     paramilitary units in that period; is that correct?

11        A.   Yes, it is.  And you have here "free agents" in inverted commas.

12     That's how we called those young guys who had weapons and who thought

13     that they had free hand.  They didn't want to put themselves under

14     anyone's control or to become part of any formation, and that is why we

15     called them as we did.

16        Q.   Thank you.  Then you said that immediately thereafter, you

17     proceeded with providing the protection -- I'm a little bit in a hurry.

18     It was not recorded that you said that you had problems with them because

19     they had weapons and they didn't want to place themselves under the

20     control of either military or the police.  Is that correct?

21        A.   Yes, it is.  We had a lot of problems.

22        Q.   Thank you.  Then you go on to say in this same paragraph that:

23             "In the period while the police station was being formed and in

24     the initial period, we started most seriously dealing with carrying out

25     primarily providing the protection of citizens and their safety and

Page 11983

 1     property, in securing public law and order, and detecting criminal

 2     offences and perpetrators thereof."

 3             When you say "citizens," did you refer to any citizen regardless

 4     of their ethnicity or faith?

 5        A.   Yes, absolutely.

 6        Q.   In your own family, do you have people who are of different

 7     ethnic or religious affiliation?

 8        A.   Yes.  My wife is a Croat.

 9        Q.   Thank you.  Can we now look at the next page?  I believe we have

10     to move to the next page in English as well.  Now, you say that until

11     that moment there had been no paramilitary formations.  However, there is

12     indications of insertion of small groups [indiscernible] sabotage and

13     terrorist groups.  And then you go on to say, as mentioned above, small

14     groups and individuals, so-called free agents, committed crimes of theft

15     from other persons, mainly of movable property and assets, thus gaining

16     unlawful material gain for themselves or others.

17             A certain small number of military conscripts and members of the

18     police station did not stay immune to such activities.  One has to

19     underline here that an organisation, the greater part of illegally

20     acquired property, mainly vehicles, was seized from police officers and

21     placed at certain locations and that measures are being taken to seize

22     vehicles and other illegally acquired property from other citizens.  And

23     then it says in the period from April to July, police officers of this

24     police station were engaged in all combat activities which was necessary

25     at the time, and since 1st of August, 1992, a large number of police

Page 11984

 1     officers returned from the front lines and were placed back on regular

 2     MUP activities, as can be seen in the following table per month.

 3             So during this period, while they were on the front line, they

 4     were unable to carry out their regular police work, nor was anyone able

 5     to do that instead of them; is that correct?

 6        A.   Yes.

 7        Q.   You also highlighted here the need to purge the police force

 8     because it had been noted that some of the police officers were involved

 9     in committing crimes; is that correct?

10        A.   Yes.  Precisely so.  I believe that I made a comment to the OTP

11     also to the effect that during this period of war operations at the

12     beginning of war, we were considerably weakened because we applied very

13     bad criteria when recruiting members of the police, which opened up the

14     door for people prone to crime to enter our ranks.  Therefore, we had to

15     purge our own force because we knew, unless we do that, we would never be

16     able to carry out the work that we were expected to do.

17        Q.   Thank you.  Now we see that in April, there were 105 combat

18     activities in which police took part, which meant more than three a day

19     on the average.  In May there was 130, more than four a day, and these

20     figures dropped slightly in June and July, and we have regular activities

21     in three and five cases, respectively; is that correct?

22        A.   Yes.  I think this is consistent with what I said yesterday in

23     examination-in-chief, which is to say that in addition to combat

24     activities, starting from June, more or less, we started carrying out

25     security service work as well.

Page 11985

 1        Q.   Can we now move to the next page, please?  I'm not going to read

 2     everything.  I would just like all the participants to look at

 3     sub-item C, we have it in the Serbian as well, and it describes what was

 4     being done.  The detection of perpetrators, an increase the number of

 5     criminal offences, theft, aggravated theft, theft of motor vehicles,

 6     unauthorised entry into apartments and other rooms, an increasing number

 7     of perpetrators of criminal offences -- of perpetrators of criminal

 8     offences in addition to the known or unknown perpetrators from the area

 9     of Hadzici municipality, including a large number of perpetrators from

10     the areas of other municipalities, as well as perpetrators of criminal

11     offences who are in the municipality as refugees from the area of Zenica

12     and other places; is that correct?

13        A.   Yes, that's correct.

14        Q.   So the emergence of these identified perpetrators and the large

15     number of refugees meant deterioration of the conditions of your work; is

16     that correct?

17        A.   Yes.

18        Q.   Later detection of crimes and perpetrators was something that was

19     done by a small number of members of the police stations.  Can we now

20     move to the next page in both versions, please?  The station is lacking

21     in most basic equipment and forensic equipment, such as sufficient number

22     of communications systems, et cetera, et cetera.

23             And it also says that they are involved in large number of combat

24     operations.

25             Can we move to the next page now, please, because we are going to

Page 11986

 1     tender this document.  I'm not going to read all of it.

 2             Now I need page 5.  It says here:

 3             "As regards providing and exchanging information --" can you

 4     confirm or deny in your mind, is there a difference between a prisoner or

 5     a detainee -- a prisoner of war and/or a detainee?

 6        A.   Yes, there is.

 7        Q.   Thank you.  So when you talk about prisoners, that implies an

 8     armed conflict; is that right?

 9        A.   That would be the case, but I'm not sure.

10        Q.   But when we say "detainees," we are talking about perpetrators of

11     crimes; is that correct?

12        A.   Yes.  I'm afraid that when we talk about prisoners, this refers

13     to the Muslims that were held in detention.

14        Q.   Now you say that some of them were moved to the state prison in

15     Kula or released.  A smaller number of them are in Hadzici and they are

16     being treated in a fair manner and according to the law.

17             Now, did this state prison in Kula constitute actually a remand

18     prison that existed a long time before the war?

19        A.   Yes.

20        Q.   In examination-in-chief, Ms. Edgerton showed us the photographs

21     of the municipal building and the garages.  Her question contained a

22     statement to the effect that those were the places where the detained

23     Muslims were held.

24             Was the criteria for their detention, their religious

25     affiliation, or was it based on a possible act that they had committed?

Page 11987

 1        A.   Those were mainly Bosniaks, as I said, from Binjezevo, Zunovci

 2     [phoen] and Kucice, and most of them were in possession of long-barrelled

 3     weapons.  They were brought in and interviewed.

 4        Q.   Some of them were transferred to the state prison in Kula but

 5     some were released; is that correct?  This is what it says under

 6     paragraph D.

 7        A.   Yes.  I have no reason to doubt the veracity of this text.

 8        Q.   It says here, under E, that there are no military judiciary

 9     organised in the area of the municipality.

10        A.   Yes, that's correct, there were no such organs.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can we have this document admitted

13     into evidence?

14             JUDGE KWON:  Yes.

15             THE REGISTRAR:  As Exhibit D1074, Your Honours.

16             MR. KARADZIC: [Interpretation]

17        Q.   Since we have tackled the issue of taking prisoners and

18     capturing, can we now look at 65 ter 10730?  And we'll revert to the

19     issue of paramilitary in order to clarify it further.  This is a report

20     on the work of the Municipal Committee for the Exchange of Prisoners

21     during the period from, I think the 1st of October until the

22     21st December, 1992, and certain individuals are mentioned here from both

23     sides who were exchanged.

24             Now, can you please focus on what it says here?  And I quote:

25             "Since it was obvious --" it is possible that we are going to be

Page 11988

 1     faced again with a bad translation.  I'm going to read this and I want

 2     the interpreters to interpret this:

 3             "Since it was obvious that the previous records were disorderly

 4     and unclear, a census of the entire Serbian population in the areas of

 5     Tarcin and Pazarici was carried out, as well as of the Muslim population

 6     in the Hadzici area under control of the Serbian authorities ..."

 7             What it means is that the areas of Tarcin and Pazarici, as it

 8     says here, were under Serb control.  The translation is not good.  So let

 9     me continue:

10             "... the Muslim population in the Hadzici area under the control

11     of the Serbian authority, and more precise and clear records of prisoners

12     including the civilians who are free to move around have been

13     established."

14             So in the area of Hadzici municipality, which was under the

15     control of the Serbian forces, there were Muslim civilians who were

16     completely free to move around, on the one hand, and there were Muslims

17     imprisoned on whatever basis; is that correct?

18             THE INTERPRETER:  Could Mr. Karadzic please repeat what he says?

19             JUDGE KWON:  Could you repeat, Mr. Karadzic?

20             MR. KARADZIC: [Interpretation]

21        Q.   Records were made of the Serbs who remained in the

22     Muslim-controlled territory; whereas in the territory under Serb control,

23     we have records of the civilians who are free to move around and records

24     of the Muslims who were imprisoned on whatever basis.  Is that correct?

25        A.   Yes, and I think that this primarily refers to the men who were

Page 11989

 1     brought to the sports centre, and this term "free citizens" referred to

 2     women and children who remained either in Hadzici or in Binjezevo or

 3     other places.

 4        Q.   And they were Muslim.  Now, were there any Muslims of military

 5     age who refused and did not actually heed the call-up that was sent out

 6     to them, the call-up papers?

 7        A.   There were no such instances but there were some who did report

 8     for work duty.

 9        Q.   They reported for work duty or obligation to the Serbian

10     authorities, correct?

11        A.   Yes, that's what I meant.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] We would now like to tender this

14     document but we would also like it to be translated properly, because the

15     translation actually affects or alters the understanding of the text and

16     the meaning.

17             MR. KARADZIC: [Interpretation]

18        Q.   Mr. Glavas, the Muslims who did report for their work detail,

19     were they treated and did they have the same benefits that the Serbs who

20     were under work obligation enjoyed?

21        A.   Yes.  In my view, that's how it was.

22        Q.   You also mentioned that some actions were taken pursuant to

23     orders from the Crisis Staff.  Did it ever occur that the Crisis Staff or

24     any other organ of authority, either police or military, issued orders or

25     allowed or tolerated illegal treatment of detainees?

Page 11990

 1        A.   Well, in principle, there were no such instances.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] We would like to tender this

 4     document.  However, we would like to have the translation revised.

 5             JUDGE KWON:  We have heard the explanation of the witness, but

 6     we'll see how it can be done.  We will admit it as Exhibit D1075.

 7             THE ACCUSED: [Interpretation] Can we now have 65 ter 11574,

 8     please?

 9             MR. KARADZIC: [Interpretation]

10        Q.   We will now return to the issue of paramilitary units.  Before

11     that, Mr. Glavas, let me ask you this:  The document we saw a little

12     earlier, the previous document, which gave a very clear picture of all

13     the abuses, even the abuses that were committed by police officers, so it

14     was very candid -- let me ask you this:  Were you as a police officer,

15     the chief, ever asked to actually engage in cover-up?

16        A.   No, never.  Nor would that have been permitted.

17        Q.   Thank you.  All right.  Now we have this document before us.  We

18     see that it comes from the Ministry of the Interior, the

19     administration -- the police administration, the Sarajevo police

20     administration.  It is sent to the Ministry of the Interior, and it is a

21     report on the realisation of orders, strictly confidential number 10, so

22     on and so forth, of the 27th of July, 1992.  And it says:

23             "Pursuant to your order and in accordance with a working

24     agreement with the Romanija Birac CSB chief, I visited most public

25     security stations in that area," and then it goes on to describe where

Page 11991

 1     all he had gone.

 2             Now can we have the next page?

 3             And we see from the top -- and could we have the English page

 4     too, the next page.  I would especially like to point out that the

 5     regrouping and returning or reverting of the tasks from the domain of the

 6     organs of Interior are to the public security station, does that mean

 7     that they were returning from the front line, that the police officers

 8     were returning from the front line?  We were waiting for the translation

 9     but your answer was yes, obviously.  Correct?

10        A.   Yes, that's how it was.

11        Q.   And then it goes on to say, that in most public security

12     stations, the work was analysed and a certain number of staff members

13     whose professional knowledge and moral code is not compatible with the

14     work in the service or who manifested a tendency towards committing

15     crimes during the war, were eliminated from the service.  And this task

16     will remain as a permanent one for the next period, and its realisation

17     will be continually monitored.

18             So is it correct that as soon as they again began doing their

19     basic work, the police work, they began a purge in their ranks; is that

20     correct?

21        A.   Yes.

22        Q.   Now there is -- we next see that they speak of paramilitary

23     units.  A special problem in certain areas are paramilitary formations,

24     groups and individuals who waged their own personal wars.  True, as I was

25     informed, they respond to and provide support units of the Serbian army

Page 11992

 1     and police but obviously they have some special motives for war and so on

 2     and so forth.

 3             Do you agree that there is a significant -- a major difference

 4     between volunteers and paramilitary units?  Now, to refresh your memory,

 5     do you remember that before the war broke out in Yugoslavia, the

 6     Presidency issued a decision regulating the question of volunteers who

 7     had to be put under military control?

 8        A.   Yes, true volunteers, actually, who did arrive, they placed

 9     themselves under military command, but as for paramilitary units, they

10     were -- they presented a major problem and they were paramilitary units.

11        Q.   Thank you.  A little further down it says in some areas such as

12     in Ilidza and Pale, for instance, they stay in special buildings and are

13     often on the move in different areas.  And then on the route

14     Sarajevo-Zvornik, in the course of leaving the field, they leave in

15     groups and create problems for the local public security station,

16     ignoring them or even threatening to attack police officers at the

17     check-point.

18             So would you agree with me that they were a major threat to the

19     police and state organs?

20        A.   Well, yes.  I think that this document does not stress

21     sufficiently how dangerous they were.  It says that they were

22     threatening, but they actually used their weapons and were armed.

23        Q.   Did you, yourself, have a clash with one such group while you

24     were in Hadzici?

25        A.   Yes, I believe so, and I believe I said so in my statement to the

Page 11993

 1     Prosecution.  I don't know if there is a need for me to repeat it now.

 2        Q.   Can you tell us just briefly what kind of incident this was and

 3     whether you were there, whether you were involved in that as a

 4     representative of the government?

 5        A.   Yes.  I believe this happened in May.  I was on my way to -- or

 6     actually, I attended one of the meetings that we had Ilidza organised by

 7     Mr. Kovac, and when I returned to our headquarters, where the police

 8     station was housed at the time, and I believe I showed that on the photo,

 9     the garages and the ground floor, we had some individuals of Bosnian

10     nationality who were held there.  When I arrived at the station, I was

11     told that paramilitary units, and my police officers told me that they

12     were White Eagles or something like that, that they were unfortunately

13     already on the premises of the sports centre and that they mistreated and

14     abused the prisoners in all sorts of ways, and I've also testified about

15     this at the BH court.

16             And when I arrived from Ilidza, they were already in the garages,

17     and because there were other five -- there were some five other police

18     officers, who were reliable police officers, we went there together and

19     asked them, What are you doing here?  And they said, Well, we wanted to

20     take these prisoners out and mistreat them.  And I said, No, you won't do

21     that.  I won't allow it.  And then it escalated, our verbal conflict

22     escalated, and then I drew out my weapon, they drew out their weapons,

23     and then my police officers, when they saw me pulling out my weapon, they

24     also pulled out their weapons, and there it kind of ended, and these

25     paramilitary members left.

Page 11994

 1        Q.   But they outnumbered you, right?  There were only five of you,

 2     correct?

 3        A.   Well, yes.  At that point in time I was pretty certain that if we

 4     really had an armed conflict, that there were other police officers at

 5     the police station who would support us.

 6        Q.   Thank you.  Does it say here in this document that their presence

 7     in MUP ranks is unacceptable for several reasons?  And then it goes on to

 8     speak about their duty to be resubordinated either to the police or to

 9     the military, but here in this document it says that the police did not

10     want them and that they were unacceptable for various reasons?

11        A.   Well, absolutely.  There was never a single member of any

12     paramilitary unit within any of the units that I was a commander of.

13        Q.   Thank you.  Now, then, we have a description here of some

14     Chetniks from the detachment Dusan Silni, who were staying in the orchard

15     of Rakovica.  They were pretty well organised and independent in their

16     work.  Well, this is a reference to Ilidza, in fact.  But on the

17     next page we see a reference made to Hadzici.  That's on page 3.  I don't

18     want to ask you about the period prior to August in Ilidza.

19             Can we have the next page in both versions, please?  Can we have

20     the next page in Serbian, page 3?  And in English as well.

21             Here we see, in the area of the Serbian Municipality of Hadzici,

22     there are some 10.000 inhabitants, there are 26 active and 30 reserve

23     police officers, there are no organised paramilitary formations -- units

24     there, and the situation in the police force is good.  These 26 regular

25     police officers, active duty police officers, was that an insufficient

Page 11995

 1     number of police officers to deal with these paramilitary units?

 2        A.   Well, obviously, it was, because there were not many members of

 3     paramilitary units there.  That's what it says there.  There are no

 4     organised paramilitary formations.

 5             THE ACCUSED: [Interpretation] I would like to tender this

 6     document and then we'll move on to some other municipalities, but I only

 7     wanted to ask you about this relating to Hadzici municipality up until

 8     the 3rd of August.

 9             JUDGE KWON:  Exhibit D1076.

10             THE ACCUSED: [Interpretation] Thank you.  Can we now have

11     65 ter 1606, please?

12             MR. KARADZIC: [Interpretation]

13        Q.   This is a similar type of inspection in the field of the

14     10th of August, and then there is a report.  This is an inspection of the

15     Romanija Birac CSB Security Services Centre, do you agree that that's

16     what it says here in the subtitle?

17        A.   I do.

18        Q.   And then it says relating to -- in relation with the realisation

19     of your order of the 27th of July, 1992.  Now let's take a look at the

20     third paragraph, that, together with the chief of the CSB police duties

21     and tasks department, Drago Borovcanin, I perform an inspection of the

22     region of the Ilidza SJB, Vogosca SJB, Centar SJB, and then the public

23     security stations from Pale to Zvornik.  But you were in Ilidza at the

24     time already; correct?

25        A.   Yes, but I was the deputy chief of the public security station,

Page 11996

 1     not the chief.

 2        Q.   Thank you.  In the last paragraph it says, it was concluded that

 3     some substantive changes occurred, when compared to the previous period,

 4     because the paramilitary formations were made to leave this area, however

 5     not entirely, because some of them still remained in the Vocnjak

 6     building, but according to the police station commander and the commander

 7     of the Ilidza brigade, this job can be considered to have been completed.

 8             Can we now have the next page, please?

 9             In Serbian as well, please.

10             This work can be considered done.  And then below it says:

11             "I stress that the level of cooperation with the army in the

12     Serbian-held areas is improving and that this area is under constant

13     enemy attacks, and that in terms of material and technical supplies and

14     assets available to the station, this is something that should be

15     especially in focus."

16             And then it goes on to say, while inspecting the region of

17     Vogosca Public Security Station at the work meeting with the chief of the

18     SJB, it says that there was an increase in all types and forms of crime,

19     poor organisation and technical equipment, uncontrolled deployment in the

20     region of a group and so on.

21             So a week later, the same commission revisited the area in order

22     to see what had been implemented.  Now, Mr. Glavas, in view of the fact

23     that it was wartime, can it be considered that the commission coming back

24     a week later could actually establish that most of the tasks had been

25     accomplished, correct?

Page 11997

 1        A.   Yes.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] I would like to tender this

 4     document into evidence.

 5             JUDGE KWON:  Yes.  Exhibit D1077.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             JUDGE KWON:  I was told that it has been admitted already.  Can

 8     we have the exhibit number, then?

 9             THE REGISTRAR:  Exhibit P1107, Your Honours.

10             JUDGE KWON:  Thank you.

11             THE ACCUSED: [Interpretation] Yes, yes.  Well, we are still on

12     this page.

13             MR. KARADZIC: [Interpretation]

14        Q.   Could you please have a look at this other part?  It says a group

15     of Chetniks that was in this area after Radic's death.  This has to do

16     with Boro Radic not Ratko Radic, right?

17        A.   Yes, yes, that's it.

18        Q.   After Radic's death they left the area, right?  And then it is

19     obvious that in this municipality, 1 per cent of the population are

20     Muslims and Croats.  Does that mean a certain percentage not 1 percentage

21     point?  Would that be in the spirit of our language?

22        A.   A certain percentage, there are some, yes.

23        Q.   Thank you.  So crimes are primarily directed against their

24     property.  In talks with the SJB chief and the police station commander,

25     we came upon a conclusion -- we came to the conclusion that there is no

Page 11998

 1     inclination and, according to their evaluation, no conditions to prevent

 2     the mentioned group in an organised manner, because that would worsen the

 3     relations between the Serb population and invoke hostility of the

 4     population towards the police because the persons in question are local

 5     persons that are known from before as having been prone to crime.

 6             Is this something that happened often?  Did the police have

 7     problems with the population that was exerting pressure to the effect

 8     that people who could possibly take part in combat should not be touched?

 9        A.   Yes.  We had problems like that.  What you read out now in

10     relation to Vogosca is something that I know personally because at that

11     time I was already in Ilidza, and at Ilidza we had a highly organised and

12     capable so-called special unit.  I remember that at that time I sent this

13     special unit there precisely because of these problems.  I think I sent

14     them there for some 10 or 15 days precisely to deal with the situation

15     there in Vogosca.

16        Q.   Does that mean that it was easier for you to resolve this with

17     policemen who were not from Vogosca rather than those who were and who

18     were therefore under pressure of the local population?

19        A.   Yes.  That primarily meant these young men from the special unit.

20     If necessary, if they were supposed to resort to weapons.  They were

21     capable of doing that, too.  That's why we sent them inter alia.

22             THE ACCUSED: [Interpretation] Can we now have 18354?  That would

23     be the 65 ter number.  I can just hope that the audio material will be

24     used for this transcript to be made complete because you and I are not

25     actually making any pauses.

Page 11999

 1             This is already the month of September.

 2             The Ministry of the Interior, the CSB of Romanija and Birac, to

 3     the Public Security Stations Ilidza, Hadzici, Vogosca, all of those that

 4     are mentioned here, right?  And it says, reference, your documents of the

 5     27th and 28th of July, 1992.  It says here that through these documents

 6     of ours, you've been made aware of the order of the Minister of the

 7     Interior that pertains to activities and measures of urgently dismissing

 8     from the Ministry of the Interior employees who -- against whom criminal

 9     proceedings have been instituted ex officio, except for political and

10     verbal offences, as well as employees who committed crimes during the war

11     and, for well-known reasons, criminal proceedings were not instituted

12     against them.

13             This is a 65 ter document.  Do we have a translation by any

14     chance?  It would be easier for the interpreters, too, because I'm

15     reading so fast.  Could the Trial Chamber ask Madam?  No?

16             MS. EDGERTON:  No.  And maybe Dr. Karadzic could assist us by

17     slowing down his pace a little bit.

18             JUDGE KWON:  I was mistaken.  That comment was made by the

19     interpreters.  Slow down, Mr. Karadzic.

20             THE ACCUSED: [Interpretation] I have to slow down.

21             MR. KARADZIC: [Interpretation]

22        Q.   Does this paragraph refer to orders of the ministry to cleanse

23     the police of those who were held criminally liable and those who were

24     not actually charged for well-known reasons because they were still at

25     the front line?

Page 12000

 1        A.   Yes, that's right.

 2        Q.   Thank you.  Then further on, it says -- we are going to skip

 3     one paragraph, it says:

 4             "In spite of the mentioned obligations, a number of SJBs did not

 5     take this subject matter seriously enough.  It is the heads of these SJBs

 6     that are responsible for that, who are in charge of the SJBs concerned,

 7     and who are authorised to do so by way of certain regulations.  In order

 8     to objectively view this subject matter and inform the Ministry of the

 9     Interior about that, and that is what the Ministry is asking us to do, it

10     is necessary for the SJBs that have not done so yet carry out an analysis

11     of possible involvement of employees in the commission of crimes and

12     other violations of work duties as stipulated in the Law on the

13     Interior."

14             This is already the first half of September.  Are these measures

15     aimed at introducing rule of law and respect for laws and are we starting

16     with the police?

17        A.   Yes.  Inter alia, legal regulations are referred to here.  So you

18     see, at the time when the war started, it seemed to be different measures

19     were taken by the ministry all the time, actually, because disciplinary

20     proceedings were undertaken within the ranks of the members of the

21     ministry.

22        Q.   Thank you.  The last two paragraphs:

23             "Public security stations who do not have such cases are

24     duty-bound to confirm that in writing.  Likewise, this centre of security

25     services should be notified of such issues including measures taken in

Page 12001

 1     the period from the 1st of April, 1992, until the present day.  Head of

 2     the CSB, Zoran Cvijetic."

 3             Were you aware of this action taken by him and it goes all the

 4     way down to the chiefs of the public security stations?

 5        A.   Yes, I was aware of it and you saw what it said.  It was sent to

 6     all the stations, and I remember that it was somewhat different then.

 7     I remember that this area went all the way to Zvornik, the organisation

 8     was somewhat different at that time.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] Can this be admitted -- or, rather,

11     marked for identification until it's translated?

12             JUDGE KWON:  Yes, we will do that.

13             THE REGISTRAR:  As Exhibit D1077, marked for identification,

14     Your Honours.

15             THE ACCUSED: [Interpretation] Can we now have in e-court

16     65 ter 18499?

17             It seems that we have a translation, too.  That's going to be

18     fine, then.

19             MR. KARADZIC: [Interpretation]

20        Q.   This is the 23rd of November, 1992.  It's the same chief of the

21     CSB, Zoran Cvijetic, and Simo Tusevljak is signing on his behalf.  It's

22     being sent to the commander of the Sarajevo Romanija Corps, and it has to

23     do with problems concerning members of the Ilidza Serbian Public Security

24     Station, right?

25        A.   Yes.  Just one small correction, it says here that

Page 12002

 1     Mr. Zoran Cvijetic, chief of the CSB, received this document from the

 2     centre and he practically forwarded it in its entirety to the command of

 3     the Sarajevo Romanija Corps.

 4        Q.   Yes, yes.  He just forwarded it.  I see.  Right.  Already then --

 5     actually, was it in 1993 when you assumed different duties or were you in

 6     a different position already then?

 7        A.   Yes, yes, by then I had already become centre -- become head of

 8     the station in Ilidza.

 9        Q.   Thank you.  Now, this is what this document says.  On the

10     14th of November, 1992, at the Kobiljaca check-point, a convoy was

11     stopped and checked by policemen and operatives of the crime prevention

12     service, and then this was interrupted by Brne's Chetniks and the

13     Serbian Guard who entered the buses without asking, and mistreated not

14     only the passengers but also the policemen, belittling their work and

15     drawing firearms at them.

16             Did that happen as described here?

17        A.   Yes.  That is certainly what happened.  We had lots of situations

18     like that.

19        Q.   Further on it says, despite being warned about their actions by

20     the chief of the public security station -- that's you, isn't it?

21        A.   Yes, yes.

22        Q.   These formations again acted in the same way on the

23     15th of November in 1992, during a check at the Blazuj intersection,

24     during a check of a convoy with Jewish citizens, where those people tried

25     to enter the buses in an even rougher manner and seized passenger

Page 12003

 1     vehicles from the convoy.  Energetic action by the policemen prevented

 2     these formations from achieving these aims.  On the 16th of November, so

 3     that's three days in a row, right?

 4        A.   That's right.

 5        Q.   On the 16th of November, 1992, a preannounced convoy of Croats

 6     and Muslims was stopped in Ilidza with a view to checking them.

 7     Policemen and members of the special units secured the convoy and

 8     prevented the Chetniks and Serbian Guard who had gathered around the

 9     convoy, in spite of warnings not to interfere in the work of the police,

10     from achieving the above-mentioned aims.  Please take action in line with

11     the above document and place the said formations under control so that

12     similar situations do not arise in the future and inform us about what

13     has been done citing the above number.

14             So this is the police asking the military to do something about

15     this, to prevent these patriots, who are introducing themselves as

16     members of the armed force but, in actual fact, they are renegades and

17     they are out of control, right?

18        A.   That's right.  However, the main reason why we sent this kind of

19     a document to the corps was that there is a reference to the

20     Serbian Guard here.  You see that?  This is a regular part of the Ilidza

21     brigade who sort of got out of control.  They were involved in various

22     things that they were not supposed to be involved in, and that is why

23     this kind of document was sent to the Sarajevo Romanija Corps command.

24        Q.   Thank you.  I'd like to ask you something now that I'm sure that

25     you know.  Am I right if I say that when the system changed, certain

Page 12004

 1     elements or renegades who were out of control represented themselves as

 2     anti-communists, and in that way, they were against regular policemen,

 3     regular officers, and this was just intended to mask their irregular

 4     behaviour, right?

 5        A.   Absolutely.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can this document be admitted?

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  Exhibit D1078, Your Honours.

10             THE ACCUSED: [Interpretation] Thank you.  Can we look at P2304

11     for a moment?  P2304.  Yes, it's a Prosecution exhibit so there is a

12     translation too.  This is already the 9th of January, 1993.

13             MR. KARADZIC: [Interpretation]

14        Q.   And it's sent to the undersecretary of the National Security

15     Service, Dragan Kijac, and it is the Ministry of the Interior, the

16     Sarajevo CSB that is writing to him, the National Security Service

17     sector.  Do you see this document?

18        A.   Yes, I see it.  And I know of this document because it was

19     presented to me by the Prosecution.

20        Q.   I see.  You see here what it says, that parts of this group

21     appeared there as part of a wedding procession and they were clashing

22     with the military police, and military policemen even had a concussion,

23     pistols were taken away and so on.

24             So, does this mean that there are still clashes going on of this

25     nature even in January 1993?

Page 12005

 1        A.   Unfortunately, yes.

 2        Q.   Thank you.  I would like to indicate another thing here, namely

 3     the difference between volunteers and paramilitaries.  Vasilije Vidovic,

 4     Vaske, is mentioned every now and then.  This paragraph says that he took

 5     part in resolving the matter, that he was under the command of the Army

 6     of Republika Srpska although he dressed in a rather unconventional way,

 7     like American Scouts.  Is it true that he belongs to that category of

 8     volunteers who accept discipline and obey orders, whereas these who

 9     appear as a wedding party are actually paramilitaries?

10        A.   Yes, precisely.  I know that Chetnik Vaske personally.  And I

11     know that he had exceptionally good relations with the then commander of

12     the Ilijas Brigade, and I know that he placed himself under the command

13     of the Ilijas Brigade absolutely and voluntarily and he did not avoid

14     cooperation with the military as opposed to others, including those

15     mentioned here.

16        Q.   Thank you.  This has already been admitted.  Now I'd like to ask

17     you whether you remember that you came to Ilidza's aid when it was

18     attacked on the 22nd of April, 1992, and when they were requesting

19     assistance?  Hadzici.  The Hadzici police came to their aid.

20        A.   Yes.  But I think that I've already spoken about that.

21        Q.   Yes, yes.  Thank you.  But I wanted to ask you whether you

22     remember how many fatalities there were on the Serb side during that

23     attack of the Muslim Green Berets.

24        A.   Your question is not clear.

25        Q.   Do we agree that Serb Ilidza, the Serb part of Ilidza, was

Page 12006

 1     attacked from Sokolovic, Kolonija, Otes, and Hrasnica by the Muslim

 2     Green Berets as well as by local Muslims who lived together with Serbs

 3     and who shot them in the back?

 4        A.   Yes, that's right.  Should I provide a more extensive

 5     explanation?

 6        Q.   I just wanted to ask you whether you know how many people got

 7     killed then on the Serb side, approximately.

 8        A.   I don't know exactly.  I think it was 15 or 20 victims.  I don't

 9     know exactly, believe me.

10        Q.   Thank you.  Was this a dramatic turning point in people's minds

11     and was it on that account that Mr. Kezunovic, president of the

12     municipality, resigned?

13        A.   I think that that was one of the reasons.  After that attack at

14     Ilidza, especially after realising how people had lost their lives,

15     I mean the situation in Ilidza was truly chaotic.  There was fighting in

16     the area that you referred to, and as fighters tried to avoid getting

17     wounded from the other side, they were shot in the back.  Later on, it

18     turned out that, regrettably, citizens of Bosniak ethnicity entered the

19     rehabilitation institute and, regrettably, they were wearing medical

20     uniforms.  They prepared weapons and when the attack took place, the

21     locals of Ilidza sustained more casualties at the hands of the locals

22     than those who were attacking from the outside.

23             JUDGE KWON:  Mr. Glavas, can you tell us when it happened?

24             THE WITNESS: [Interpretation] That happened on the 22nd of April,

25     1992.

Page 12007

 1             JUDGE KWON:  Thank you.

 2             THE WITNESS: [Interpretation] You're welcome.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   So did this crisis give rise to mutual blaming and the search for

 5     those who were responsible for such a situation in Ilidza?

 6        A.   I think that that was the main reason for such chaos in Ilidza.

 7     I know that my colleague, Kovac, had tremendous problems as a result of

 8     this situation.  He was even branded as a traitor.

 9        Q.   Can you refresh our memory briefly about who Predrag Ceranic was?

10        A.   Predrag Ceranic was an ex-operative of the State Security Service

11     of Ilidza.  I think that in mid-1992, he took the position of the chief

12     of the public security station in Ilidza.

13        Q.   Can we please now have 1D3243?  Let us look now how the

14     National Security Service is reporting about all these accusations,

15     rumours and other allegations.  1D3243.  What we see here, is that a

16     National Security Service report from Ilidza dated 25th of June, 1992?

17     Can we please look at the bottom of the page and then -- so it's the

18     25th of June; is that correct?

19        A.   Yes, it is.

20        Q.   Next page, please.  This won't take too much time because we

21     don't have a translation.  And there is your name mentioned, among others

22     who are accusing each other, and it says, the National Security Service

23     has certain indication which are being checked relating to activities and

24     behaviour of security interests in the area of the Serbian Municipality

25     of Hadzici.  In other words, there is almost total mistrust in this

Page 12008

 1     territory, the citizens are expressing their mistrust more and more

 2     towards certain important institutions such as the public security

 3     station, the army and certain individuals.

 4             So at a time of crisis, when solutions are not being found, the

 5     people exert pressure on their own institutions.  Is this what this is

 6     about?

 7        A.   Well, yes.  That's it.  I don't find this unusual at all.  I had

 8     seen much worse situations.

 9        Q.   Thank you.  Now there is allegations at your expense and it says

10     that the chief of the SJB of Hadzici, Glavas Tihi, and police station

11     commander Branislav Mijatovic are thought to be very unreliable and there

12     are reports of their cooperating with the opposing side.

13             Now, among the people who are living in fear, was it a practice

14     that any contact with another side was declared treason?

15        A.   Yes.  That was the case, and that was in the period while I was

16     there, although I think that was due to the fact that I try in every

17     possible way to save my father and my two brothers.  But I wouldn't want

18     to comment on this any further.

19        Q.   Let us now move to the next page, but please bear in mind that

20     I'm not taking what is written here at face value.  I just want to

21     illustrate the situation.  Now, the paragraph 4, it says there is

22     mistrust in the highest government organs in the municipality.  So that

23     as soon as there is gunfire, the people from the government flee to Pale,

24     allegedly under the excuse that they were going to talks with the

25     government of the Republic of Srpska.  He's talking about rumours and

Page 12009

 1     there were such rumours?

 2        A.   Yes, there were.

 3        Q.   Can we move to the next page, please?  And he is making his

 4     assessments here at the end, by saying although we would not like to make

 5     any suggestions, we would like to underline the certain unit commanders

 6     of the Serbian army in Hadzici estimate that for -- to ensure a full and

 7     successful defence of the Serbian positions, another 100 combatants

 8     approximately need to be recruited, and it's signed by Predrag Ceranic;

 9     is that correct?

10        A.   Yes, it is.

11             THE ACCUSED: [Interpretation] Can we have this admitted into

12     evidence?

13             JUDGE KWON:  We will mark it for identification, pending English

14     translation.

15             THE REGISTRAR:  As Exhibit D1079, marked for identification,

16     Your Honours.

17             THE ACCUSED: [Interpretation] Thank you.  Can we now have

18     65 ter 1556?

19             MR. KARADZIC: [Interpretation]

20        Q.   While we are waiting for it, do you agree, nevertheless, that the

21     state leadership thought that these rumours cannot be taken seriously

22     into account and that you did not lose any of your credibility in the

23     eyes of the minister and other state organs?

24        A.   That is precisely right.  To be honest with you, I didn't know

25     about this report at the time.

Page 12010

 1        Q.   Well, what kind of secret service would that have been, had you

 2     known about it?  Would that be right?

 3        A.   Yes, that's right.  I have my own opinion about them but this is

 4     not the time nor the place to express it.

 5        Q.   Now, this is Ilidza, the 4th of June, now, let's see how the

 6     foundation was created for these rumours to be spread, but let us also

 7     look at the reality of the clashes with the paramilitary formations.  Can

 8     we have the next page in both versions, please?  This is the same author,

 9     only now his assessment is that he says that individuals are presenting

10     numerous disinformation about Serbian public security station in Ilidza

11     and about the Ilidza Brigade, with the aim of dividing and sowing

12     mistrust among combatants and citizens in these institutions.

13             This information is entitled "A Rift," so let's look at that.  It

14     says here that, according to the information that we have, that when you

15     arrived at Ilidza, you established contact with President Prstojevic

16     which was followed by good cooperation and that you heard that the

17     municipal authorities were blamed for the difficult situation in Ilidza;

18     is that correct?

19             It's not in this document.  I'm just giving you a kind of

20     introduction before we get to this document.  Do you remember that when

21     you came there, you were introduced to him and you had good cooperation

22     and you didn't have any problems with the municipal authorities in Ilidza

23     despite all these rumours; is that correct?

24        A.   Yes.  It is correct.  But I don't see any connection with this

25     document.

Page 12011

 1        Q.   We'll come to that because the author is the same.  Some of your

 2     colleagues suspected that the municipal authorities were tolerating the

 3     presence of renegade groups, but did you, yourself, see that they were

 4     more afraid, I mean the authorities, of them rather than tolerating them?

 5        A.   Yes, there were situations of that kind in which representatives

 6     of the military made such comments to the effect that almost the

 7     political authorities were behind such formations, and I can confirm for

 8     both municipalities that that was not the case.  I know that,

 9     particularly in Ilidza, I had an extremely good cooperation and I know

10     what Mr. Prstojevic was doing at the time.

11        Q.   Now, can you look at the last two paragraphs on this page, which

12     says that, certain individuals are trying to portray the robberies

13     committed by crimes and certain members of the Serbian TO and some other

14     according to the Crisis Staff order and also the --

15             THE INTERPRETER:  Could Mr. Karadzic please slow down and tell us

16     which particular paragraph he is reading.  Thank you.

17             JUDGE KWON:  The interpreters were not able to follow.

18             THE ACCUSED: [Interpretation] Very well.  I'm going to repeat it.

19             MR. KARADZIC: [Interpretation]

20        Q.   So those who were blamed for the death of members of the

21     Serbian armed forces on the 21st of April, during the first attack on the

22     territory of Serbian Municipality of Ilidza, they accuse the head of the

23     Serbian Public Security Station Ilidza, Tomislav Kovac, despite the fact

24     that the cause of the death can -- can we move now to the next page in

25     Serbian, the English is all right.  The cause of their death was a

Page 12012

 1     cunning attack by the enemy and poor organisation of the Serbian TO at

 2     the time.

 3             Do you recall that this is consistent with the process of looking

 4     for the -- those who are to be blamed for the loss of these two men in

 5     Ilidza?

 6        A.   Well, yes.  That's it, but I really find it ridiculous to accuse

 7     Mr. Tomislav Kovac who, at the time, was by far the most competent man.

 8     So it is really pointless to comment on that any further.

 9        Q.   Thank you.  I would gladly show you some of the intercepts

10     between Tomislav Kovac and Nedjeljko Prstojevic relating to these events,

11     but I'm afraid that you don't know anything about these intercepts and

12     that you wouldn't be in a position to comment on them; is that correct?

13        A.   I would prefer not to comment on that.

14        Q.   Thank you.  Can we now skip one paragraph and then it reads as

15     follows:  In addition, citizens complained to the Serbian public security

16     station of Ilidza, reporting thefts and forceful expelling of Muslim

17     citizens from Ilidza, committed by "Seselj's men," in inverted commas,

18     However, when the Serbian Public Security Station Ilidza decided that in

19     such cases interventions were necessary, the president of the former

20     Crisis Staff of Ilidza, Nedeljko Prstojevic and his deputy,

21     Radislav Unkovic opposed this decision, stressing out that with

22     Seselj's men there should be no messing around; in other words, that they

23     were doing it on their behalf, since Prstojevic and Unkovic tasked them

24     with it.  Is this true or is this just part of this exchange of

25     allegations and accusations?

Page 12013

 1        A.   Well, let me tell you this:  I'm not familiar with any of this,

 2     and I would not like to comment on it.

 3        Q.   Do you know if Prstojevic and Unkovic were the ones who ordered

 4     this or do you think this is just allegations without any foundation?

 5        A.   Well, if you want my honest opinion, I think that this whole

 6     information is suspicious.

 7        Q.   Now I'd like to ask you something about the term "Seselj's men,"

 8     in inverted commas.  In your view, were White Eagles -- Dusan Silni, were

 9     they Seselj's men, were they considered to be Seselj's men?

10        A.   Well, I didn't consider them as Seselj's men.  However, they were

11     members of the Serbian Radical Party.

12        Q.   I'm asking you this because both these formations belonged to

13     other parties but it was commonplace to say that everyone who was not

14     part of the military was a Seselj's man.

15             Now, can we look at the last page, please?  I believe that we

16     need the last page in English as well, the last two paragraphs.  Before

17     the break let me just finish this.  And it says here that Sinisa Milic

18     persuaded Seselj's men to attack and take over the SSJB Ilidza and he

19     succeeded, but they gave up their plan soon realising that energetic

20     retaliation would follow.  In regard to this, "Seselj's men," again in

21     inverted commas, behaved in a strange way.  Tonight, on the 4th of June,

22     they arrived at the building of the public security station of Ilidza

23     with the intention to take one of the prisoners out, without having

24     obtained the approval of the officer in charge.  Once they were not

25     allowed to do that, they, headed by Sinisa Milica, aka Mongo, threatened

Page 12014

 1     with weapons until they got the two prisoners from the health centre

 2     given to them.  On that occasion, Mongo threatened to blast the health

 3     centre if their request was not met.  The "Seselj's men," in inverted

 4     commas, gathered in front of the station under arms and they went away

 5     only after they had been warned by the commander of the station and

 6     employees of the police.

 7             Were you aware of such so-called internal danger that lured from

 8     these renegades and could these renegades be considered to be locals?

 9        A.   Yes.  There is mention here of Sinisa Milic, Mongo.  I knew that

10     man from Ilidza.

11        Q.   Were these young men prone to committing crimes before?

12        A.   Yes, they were.

13             THE ACCUSED: [Interpretation] Thank you.  Can we admit this into

14     evidence?

15             JUDGE KWON:  Yes.

16             THE REGISTRAR:  As Exhibit D1080, Your Honours.

17             JUDGE KWON:  We will have a break, Mr. Karadzic, after which you

18     will have 40 minutes to conclude your cross-examination.  We will resume

19     at five past 1.00.

20             THE ACCUSED: [Interpretation] If necessary, I would need a few

21     minutes more.  I am counting on your standard practice because we are not

22     wasting time really.

23             JUDGE KWON:  Please try to conclude in that period of time.

24     We'll see.

25                           --- Recess taken at 12.35 p.m.

Page 12015

 1                           --- On resuming at 1.08 p.m.

 2             JUDGE KWON:  Yes, Mr. Karadzic.

 3             THE ACCUSED: [Interpretation] Thank you.  Could we now have 1658

 4     from the 65 ter list, please?

 5             MR. KARADZIC: [Interpretation]

 6        Q.   We are still on the topic of paramilitary units.  I'm not going

 7     to read out the whole thing but I would like to refer you to the first

 8     part, where it says that paramilitary units knew the exact date when the

 9     new commander of the Igman Brigade would arrive and they even prepared to

10     assassinate him.  And then it says, when the new commander arrived,

11     Colonel Spasoje Cajic, Brne's formation felt that it would not have the

12     privileges that it had had until that time and that it would have to

13     place itself under the brigade command as an integral part of the

14     Republika Srpska army.  Upon the arrival of the new commander, Brne came

15     in person to him and told him that he knew everything about him,

16     including the exact time he was to take over the brigade, and one of the

17     Chetniks had told him that he had been in charge of his assassination.

18             Does this reflect the relationship or the attitude of these

19     renegades and what their attitude was to the institutions, official

20     institutions?

21        A.   Yes, that's true, but I see also that mention is made here of

22     Velimir Dunjic, he's the previous commander, and also here there should

23     be a correction, this is Spasoje Cojic, not Cajic, there should be an O.

24     And I have to say that he was a little bit prepared to give them freer

25     hand and that he, himself, was in some kind of collusion with these

Page 12016

 1     paramilitary formations.

 2        Q.   Thank you.  Further on it says further, bearing in mind that the

 3     leadership of Republika Srpska had declared that all paramilitary units

 4     had to be placed under the joint command of the VRS, we can conclude that

 5     it would not be easy or painless to deal with Brne's men.  In relation to

 6     that, we have to stress that this group of men denigrates and

 7     underestimates the Chief of Staff of the VRS, as well as corps commanders

 8     and other officers.  For them, they claim that they are traitors and

 9     Tito's generals, that they are incompetent, while at the same time giving

10     preference to some of their men and units.  Thus, for instance, according

11     to Brne, the former JNA officers are a group of incompetents, and Arkan,

12     Captain Dragan and he, himself, were the real fighting force.

13             Is this, in fact, a smokescreen which people like to use,

14     claiming that someone was Tito's general because they were communists?

15        A.   Yes, this is typical of their conduct.

16        Q.   I see that interpreters are having a difficult time.  There

17     should be Tito's generals and communists there.

18             Further on it says, so we have -- it has to be emphasised that

19     they are also bothered by civilian authorities as well as MUP workers,

20     about whom they tell falsehoods and slander them, saying they are

21     thieves, criminals and so on and so forth.

22             Based on this official note from the state security, can we

23     conclude that the civilian authorities were also targeted by these men

24     and that, in fact, they did not enjoy their support and that they were

25     trying to discredit the legal authorities, government bodies?

Page 12017

 1        A.   Well, yes.  That's correct.  It is absolutely out of the question

 2     that the government authorities supported them.  Perhaps they feared

 3     them, but that they supported them, that's out of the question.

 4        Q.   Thank you.  This is an exhibit already.  It was signed by

 5     Srdjan Sehovac.  You do know this officer of state security, don't you?

 6        A.   Yes.  He used to work there and we worked together.  We were

 7     co-workers at Ilidza Public Security Station.

 8             JUDGE KWON:  It was one of the Prosecution exhibits that we

 9     admitted, P2305.

10             THE ACCUSED: [Interpretation] Can we now have 1D3241, please?

11     Can we pull it up in e-court?

12             MR. KARADZIC: [Interpretation]

13        Q.   You said that the government authorities actually feared these

14     groups and they tried to avoid getting into conflict with them.  Does

15     that mean that the authorities did not have at their disposal a

16     sufficient or strong enough police force in order to be able to deal with

17     them?

18        A.   Well, I don't think that was the only problem.  We had a large

19     police force in Ilidza and we could oppose them.  However, there were

20     some personal links there, personal collections, and these men would

21     sometimes break into the police station itself and issue threats to the

22     people there.

23        Q.   Thank you.  Do you know that Budo Obradovic, the president of the

24     Executive Council, was killed in that way?  Somebody burst into his

25     office and shot him dead.

Page 12018

 1        A.   Yes, I know of that.

 2             THE ACCUSED: [Interpretation] Thank you.  Did I quote the correct

 3     number, 1D3241?

 4             JUDGE KWON:  I think it's coming.  This is 2341.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Mr. Glavas, somebody signed on your behalf, but you were put

 7     there as the chief of the public security station.  We don't have a

 8     translation so I will have to read this:

 9             On the 20th of November, 1992, at around 2030 hours, at the

10     check -- traffic check-point Butila, Rajlovac municipality,

11     Pero Hrkalovic [phoen] from Rajlovac, under the influence, and with his

12     rifle cocked, approached a group of police officers of this station, or

13     rather, approached Zarko Vidic and Goran Stanisic, asking them why they

14     were checking traffic, telling them that they were thieves and so on and

15     so forth, on which occasion the military police disarmed them.  In other

16     words, they called the military police to assist them.

17             On this occasion they were disarmed by the military police, but

18     some 20 or so citizens had gathered and they protested and tried to

19     protect Pero so that members of the police and the military assessed that

20     it was time to withdraw from the check-point to avoid a physical

21     conflict, which they did because the citizens gathered there were armed.

22     The command of the Ilidza Brigade was informed of the incident and this

23     station, in coordination with the military police and the public security

24     station in Rajlovac, took measures in order to establish all the facts

25     relating to this incident.

Page 12019

 1             The first question:  Is this one of those cases where the state

 2     authorities clashed with irregular groups and their erratic behaviour?

 3        A.   That's exactly what this illustrates.  I can only say that there

 4     were a number of such incidents.  Unfortunately, in some of them,

 5     firearms were used.

 6        Q.   Thank you.  My next question:  This report says that these

 7     citizens that had gathered there, some 20 of them, were armed.  Now, let

 8     me ask you, Mr. Glavas, do you recall Tito's doctrine of an armed people

 9     and the purpose of that was for them to be able to defend themselves in

10     case of an aggression?  This was primarily in reference of the

11     Warsaw Pact, correct?

12        A.   Yes.

13        Q.   Mr. Glavas, could you tell us -- I mean, can it be said -- or,

14     rather, who is the state representative, a government representative, in

15     this particular instance in this incident?  Is it the member -- the

16     police and the army, or the citizens and the people who were opposing

17     them?

18        A.   Well, it should be the police officers and the army who tried to

19     prevent these incidents.

20        Q.   Thank you.  Did you feel that it was your responsibility to

21     oppose -- or do you feel responsible for these -- the conduct and the

22     behaviour of these individuals?

23        A.   No, I can't really say that I feel responsible for that, but this

24     is just a good illustration of how difficult it was to carry out our

25     duties and how dangerous it was to carry out our duties as police

Page 12020

 1     officers, of maintaining law and order.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] I would like to tender this

 4     document.

 5             JUDGE KWON:  We will mark it for identification pending

 6     translation.

 7             THE REGISTRAR:  As Exhibit D1081, marked for identification,

 8     Your Honours.

 9             THE ACCUSED: [Interpretation] Can we now have 1562 from the

10     65 ter list?

11             MR. KARADZIC: [Interpretation]

12        Q.   While we are waiting for that, Mr. Glavas, in addition to

13     threatening the safety and security of citizens, you also had problems

14     with major incidents involving theft and burglaries and looting.  So can

15     we agree that this was a time, the wartime, conducive to all types of

16     criminal offences?

17        A.   Yes.

18        Q.   Well, I can't really ask you about what the percentage of

19     psychopaths would be in any society at any given time, especially under

20     these conditions, but we'll leave that to experts.  But can I ask you,

21     under these circumstances, was it the case that the individuals who were

22     already prone to crime from before now had an opportunity to reactivate

23     themselves?

24        A.   Yes, that's exactly how it was.

25        Q.   Now, let's see what the position of the authorities was on the

Page 12021

 1     matter of private property.  This is a document from the municipal

 2     government of Hadzici, dated the 10th of June, 1992.  Can you see it?

 3        A.   Yes.

 4        Q.   Here we see that this is a request to take measures to hand over

 5     individuals who failed to report after they received a mobilisation call,

 6     in the territory of Hadzici municipality.  And then it says that a large

 7     number of conscripts failed to report after they were mobilised, and who

 8     are now in the territories of Pale, Sokolac and Han Pijesak

 9     municipalities but who hail from the Hadzici municipality, and the

10     Hadzici municipality actually wanted those other municipalities to send

11     those people back?

12        A.   Well, yes, that's -- we can see here that there were mass

13     attempts to desert, where people left their areas, their municipalities,

14     for other areas, where the fighting was far less fierce.

15        Q.   Thank you.  And we see in the second paragraph that the Serb

16     Municipality of Hadzici wants them to be sent back and put them in use

17     for defence because we are continuously targeted by Muslim Ustasha

18     forces, otherwise we shall label all of those who had left the

19     Serb Municipality of Hadzici as deserters, confiscate their property and

20     forbid their return to the territory of the Serb Municipality of Hadzici.

21             From what you know, was this a reference to the Serb conscripts

22     who actually tried to avoid and who left the municipality in order to

23     avoid being mobilised?

24        A.   Well, that's exactly who it refers to, to Serb conscripts.

25        Q.   Aside from this threat that their property would be confiscated,

Page 12022

 1     because that is within the jurisdiction of courts, but this is a call, a

 2     desperate call, for them to come back and help defend their fatherland;

 3     correct?

 4        A.   Yes.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] I'd like to tender this document

 7     now.

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  As Exhibit D1082, Your Honours.

10             MR. KARADZIC: [Interpretation]

11        Q.   Thank you.  I would now like to see 65 ter 1621, please.

12             The 15th of September, so as that document from the military

13     department of Hadzici says, it was only from the 15th of September

14     onwards that communication could be established with the central organs.

15     Let's see what it says here:

16             "Decision has been made by the municipal authorities to rescind

17     rights obtained on the basis of tenancy rights or employment.

18             "Article 1, all persons who were formerly resident on the

19     territory of the Serb Municipality of Hadzici who have not returned to

20     the municipality and have not provided an explanation for their inability

21     to return to the competent municipal authorities for military affairs,"

22     and so on and so forth, "shall have the status of displaced persons and

23     shall not have the right to citizenship of Republika Srpska."

24             Does this pertain to persons who fled from Republika Srpska?  Or

25     those who were in Pale or some other municipality?

Page 12023

 1        A.   This is a reference to persons who left the territory of the

 2     municipality of Hadzici.

 3        Q.   I see.

 4             "Article 2, persons referred to in Article 1 herein have a

 5     statutory right to a socially owned flat in the Serbian Municipality of

 6     Hadzici shall no longer be entitled to any rights obtained on the basis

 7     of tenancy rights."

 8             And Article 4:

 9             "The property of persons referred to in Article 1 herein shall be

10     provisionally used for the needs of the defence of the Serbian

11     Municipality of Hadzici.  The competent municipal organs shall oversee

12     the care and manner of use of this property."

13             First, let us make a distinction here.  The municipality believes

14     that they are not entitled to socially owned apartments that were made

15     available to them and that they do not actually own?

16        A.   Yes.

17        Q.   Property that is not in dispute will be used for defence and it

18     is the competent organs that are going to provide for that, right?

19        A.   That's the way it should be.

20        Q.   Does this pertain to Serbs who don't want to go back to defend

21     the municipality?

22        A.   Yes, that's right.  However, I think that the basic reason for

23     making this kind of decision was the fact that in the area of Hadzici,

24     due to reasons well known from before, and due to the situation as such,

25     there were quite a few available apartments and at that time there was an

Page 12024

 1     onslaught of refugees.  And I think that that is how the municipal

 2     authorities were trying to deal with that, how to have those apartments

 3     allocated.  That's how I interpret this decision.

 4        Q.   Thank you.  I don't know whether you know this but it did appear

 5     in the Official Gazette.  On the 19th of August, I annulled every

 6     possibility to infringe upon property rights.  However, the government

 7     did prescribe a way in which property would be made temporarily available

 8     not to the local population but people who came from elsewhere.

 9             That's what you meant when you were speaking of refugees, right?

10        A.   Yes, that's right.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can this be admitted?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  As Exhibit D1083, Your Honours.

15             THE ACCUSED: [Interpretation] Thank you.  Can we have 1543?  And

16     that's the 65 ter number.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is a very early decision of the Crisis Staff of the

19     26th of May, 1992.  It's a decision on the establishment of a commission

20     set up to make a list of all abandoned flats and property on the

21     territory of the Hadzici Serb municipality, number 1.  On the basis of

22     this decision a commission for making a list of all abandoned flats and

23     property on the territory of the Serb Municipality of Hadzici is being

24     established, and then its members are listed there, and the appointed

25     commission, it says further on, is obliged to make a list of all

Page 12025

 1     abandoned flats and property on the territory of the Serb municipality of

 2     Hadzici and also to seal them so that they could all be registered and

 3     placed at the disposal of the Serb Municipality of Hadzici.  See, so a

 4     list is being made, they are being sealed.  You were there, do you

 5     remember that this was done by the municipal authorities?

 6        A.   Yes.  I remember that very well, the time when these apartments

 7     were sealed.

 8        Q.   Thank you.  Was there any looting going on at the time?  Was this

 9     measure indispensable, as it were?

10        A.   Yes, inter alia was a measure of caution.

11        Q.   Thank you.  Can this be admitted?

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  As Exhibit D1084, Your Honours.

14             THE ACCUSED: [Interpretation] Thank you.  Can we now have

15     65 ter number 1645?

16             MR. KARADZIC: [Interpretation]

17        Q.   This is from December.  This reflects the position of the

18     municipal authorities with regard to property and property-related

19     rights.  When you see the essence, we will ask you whether you are in

20     agreement.  Can we have page 3?  5, point 5.  Item 5, yes, we have it in

21     English now.  Yes.

22             The third subparagraph underneath the name of Vitomir Banduka, it

23     says:

24             "The question of whether the commission for allocating flats

25     should allocate private houses was also raised.  Ratko Gengo explained

Page 12026

 1     that this commission did not allocate flats and houses but provided

 2     accommodation for refugees."

 3             Then further on, item 6 says:

 4             "It is believed that this decision raised a dilemma as to what

 5     should be done with the -- with," and we cannot read what it says -- "who

 6     had taken shelter outside our municipality because of war operations.

 7     Branislav Jovanovic --" it's the next page in English.

 8             "Branislav Jovanovic asked for an explanation about what about

 9     those who left after the 13th of August, 1992?  The answer he received

10     was that they were considered to be refugees from this municipality, to

11     have fled from this municipality."

12             Does this correspond to your knowledge about the ways and means

13     resorted to by the municipality to resolve the problem of accommodating

14     those who arrived in Hadzici?

15        A.   Yes.  I'm aware of that, but, Mr. Karadzic, I have a small remark

16     to make.  I don't mind commenting on this record or these minutes of the

17     Municipal Assembly of Hadzici, that speaks about how certain vital

18     problems were being resolved in the area.  I'm accepting this.  I accept

19     that I can comment upon what happened there because I believe you won't

20     have any other witnesses from that area.  However, I already said that

21     I'm not a person who was ever involved in politics, so I don't think that

22     I'll be able to give you any kind of useful comment.

23        Q.   All right.  I accept that.  Can we have page 7?  It's probably

24     page 8 in the document.  6442, that's the ERN number.  Yes, that's right.

25     That's it in the Serbian language.  Just let us have a look at this.

Page 12027

 1             As far as looting is concerned, it is believed that there is

 2     considerably less of it and that omissions that happened in the initial

 3     period are due to the fact that the station was involved in defence.  So

 4     the members of the station were taking part in fighting, right?

 5        A.   Yes.  I think that that has already been established on several

 6     occasions.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] Can this document be admitted?

 9             JUDGE KWON:  Yes.

10             THE REGISTRAR:  As Exhibit D1085, Your Honours.

11             THE ACCUSED: [Interpretation] Thank you.  Can we now have 1D3084?

12             MR. KARADZIC: [Interpretation]

13        Q.   This is a letter of yours, information that you are sending in

14     your capacity of chief of the security station in the Serb Municipality

15     of Ilidza.  Can you read this?  Please find attached a report concerning

16     the discovery of shell fuses and gunpowder in gas cylinders; right?

17        A.   Yes, I'm aware of this case.  It's my name and surname there but

18     it was signed by Mr. Nikolic who was my assistant at the time.

19        Q.   Thank you.  Can we have the second page now?  Since there is a

20     translation, I don't have to read all of it out.  Could you please have a

21     look and can you tell us whether this is what happened?  Was Dr. Pejic

22     the director of the municipal -- of the military hospital in Blazuj, that

23     took care of our own wounded and those of the other side?

24        A.   Yes, that's right.

25        Q.   Can you tell us about this case, why did he go to the police?

Page 12028

 1        A.   It's hard for me to read this.  It's barely legible.

 2        Q.   This is what he says, that he received two cylinders from the

 3     UNHCR and they did not contain gas but were filled with a suspicious

 4     substance.  A commission of the Ilidza Public Security Station,

 5     representatives of the military and civilian police attached to UNPROFOR,

 6     and one UNHCR representative went to the spot and established the

 7     two metal cylinders were involved, one of a net weight of 28.3 kilograms

 8     with a certain number and the other one with a net weight of

 9     43.8 kilograms with a number that follows.  The gas cylinders were opened

10     by authorised officials and gun powder was found in the first one, but in

11     the other one, 200 fuses were found, most probably for 82-millimetre

12     calibre shells.

13             Have I jogged your memory?

14        A.   Yes, now I remember the case.  I know what this is all about.  I

15     know that this was a serious omission, and I think that Dr. Pejic or

16     somebody from the military gave a public interview and we were supposed

17     to deal with this on a confidential basis.  We were -- we were almost in

18     a position to find a lot more of such material.

19        Q.   Thank you.

20             THE ACCUSED: [Interpretation] Can this be admitted?

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit D1086, Your Honours.

23             THE ACCUSED: [Interpretation] Thank you, 1671.  That's the 65 ter

24     number.  Could we have that, please?

25             MR. KARADZIC: [Interpretation]

Page 12029

 1        Q.   Do you remember who Dusan Kalajdzic is, commander of the Blazuj

 2     reserve police station?

 3        A.   Yes, I know the man.  I know him in person -- I know him

 4     personally.

 5        Q.   He is reporting, on the 19th of September, 1993, and explaining

 6     what was going on.  He is speaking about the history of the reserve

 7     police station, the public security station in Blazuj.

 8             Can we have the next page, please?

 9             Mr. Kalajdzic is presenting the history of the division of the

10     MUP.  And let us have a look at this other paragraph, the

11     second paragraph.  And in English it's the last paragraph on this page,

12     where it says, once Tomo Kovac assumed the duty of commander and so on,

13     from 1991, the SDA leadership of Rakovica, through the municipality and

14     its head, Edin, twice requested in writing, through the municipality

15     chief Edin, that Blazuj station be divided.  This was seen for what it

16     was, and pursuant to Tomo's instructions, this was not allowed.  Although

17     Edin had asked for that at meetings of commanders, an effort was being

18     made to reinforce the Muslim station in Rakovica.

19             Could I please have the next page in English?

20             Do you remember this was immediately after the multi-party

21     elections?  The elections took place in November, and the government was

22     established in mid-January 1991; right?

23        A.   Yes.

24        Q.   Thank you.  Can we now have the next page?

25             Now, does this document demonstrate -- this about the barricades

Page 12030

 1     is not very important at the moment.  Let's move to the paragraph which

 2     begins on the 4th of April, 1992.  It says that the following actions

 3     were taken in -- of intercepting and checking suspicious Muslim vehicles

 4     following reports received with weapons at Kobiljaca.

 5             Is this proof that immediately after the elections in early 1991,

 6     manipulations of the police began with the intention of splitting the MUP

 7     and to reinforcing the Muslim police forces?

 8        A.   Yes, Mr. Karadzic.  But I don't think that it's appropriate for

 9     me to comment on this.  I said something to that effect to the OTP.  This

10     is a chronology of events that took place when I was not there and I was

11     in Ilidza.

12             THE ACCUSED: [Interpretation] Therefore, your Excellency, I'm not

13     going to tender this at this point.  We shall have to wait for another

14     witness to tender it through.

15             THE WITNESS: [Interpretation] I'm sure that you will find

16     appropriate people from Ilidza who can be better placed to confirm this

17     than I am.

18             MR. KARADZIC: [Interpretation]

19        Q.   Thank you.  Now, let me ask you briefly about some striking and

20     drastic events that as a policeman you should have been aware of, which

21     took place in your municipality.  Can you just confirm whether you know

22     about them, you don't know about them, or maybe you don't know anything

23     about them?

24        A.   All right.

25        Q.   Is it true that in March of 1992, the Serbs from Gornja and

Page 12031

 1     Donja Rastelica noticed in the melting snow the Muslims digging trenches

 2     in the area?

 3        A.   That's correct, and that was nothing unusual for that particular

 4     area.

 5        Q.   Thank you.  Is it true that armed Muslim groups that numbered a

 6     total of 300 to 400 men, according to some opinions, there were more of

 7     them, led by Mirsad Sabic --

 8             THE INTERPRETER:  Could Mr. Karadzic please repeat the names

 9     again?

10             THE ACCUSED: [No interpretation]

11             JUDGE KWON:  Mr. Karadzic, you need to repeat your question,

12     starting from the name.

13             MR. KARADZIC: [Interpretation]

14        Q.   It says here that there were armed groups numbering a total of

15     300 to 400 men, led by Mirsad Sabic, Mujo Lihovac [phoen] and his son,

16     Nijaz Lihovac, aka Gera, in accordance with a so-called directive of the

17     TO staff of Efendic, on the 11th of May, encircled the JNA barracks, the

18     Zupa [as interpreted] near Gornji Zovik?

19        A.   Yes.

20             MS. EDGERTON:  Could we find out what Dr. Karadzic is reading

21     from?

22             THE ACCUSED: [Interpretation] These are the questions that I'm

23     putting to the witness, either asking him to confirm or to deny, but I

24     can recommend to Ms. Edgerton this book called "The Black Book" by

25     Mr. Toholj, from the information centre, and the book is based on witness

Page 12032

 1     statements.  And the majority of these witnesses will appear as Defence

 2     witnesses.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Now, here we have a policeman who didn't have any political party

 5     affiliations and who may have known these things.

 6             Mr. Glavas, are you aware of these things?

 7        A.   Absolutely, I am.  Whatever you said is consistent with what

 8     I said earlier.  We are talking here about members of the reserve police

 9     force in this place, Mr. Sabic is well known, but I think that the date

10     is not correct.  I think that the Krupa barracks was attacked on the

11     12th of May.

12        Q.   Thank you.  It says that it started on the evening, probably

13     continued on the 12th.  It says that Zarko Milic and another two soldiers

14     were killed, and also a certain Nijaz Mehic on the side of the attackers.

15     One of the killed JNA soldiers was wounded in the leg and died of

16     haemorrhage on the way to hospital.  The others were captured, taken to

17     the forestry building in Tarcin --

18             THE INTERPRETER:  Interpreter's note:  The interpreters cannot

19     repeat such a long list of names spoken so quickly.  Thank you so much.

20             JUDGE KWON:  The interpreters can't follow with that speed, in

21     particular you're enumerating those names.

22             THE ACCUSED: [Interpretation] I apologise to the interpreters.

23     So Vlado Bozic, Dragan Mutavdzija, reservists Dragan Jaksic,

24     Dragan Lojanica, Vojno Milanovic, and Slavomir Vidojevic were first

25     detained at the fire-fighting centre in Tarcin, and then two days later

Page 12033

 1     in a silo, which, in that manner, became a mass camp.  Is that correct?

 2        A.   Yes.  I am quite familiar with this case.  Later, it would turn

 3     out that practically these were the only individuals that could enjoy the

 4     proper status of prisoners of war.  The rest were all civilians.  So we

 5     are talking here about the people that were only capable of being treated

 6     as prisoners of war.  The other people were civilians.

 7        Q.   Is it true that on the 17th of May, a raid was carried out in

 8     Tarcin and that the remaining Serbs were arrested, and that this action

 9     was led -- Slobodan Kukricar was killed, and Nedeljko Vukovic [phoen] and

10     Gane Bozic [phoen] were captured.  The attackers were led by

11     Mirsad Bratic; Cedomir Domuz [phoen]; Zijad Imamovic; Mirsad Selimovic,

12     aka Srce; a certain Pisca [phoen], last name Mrdzanic [phoen]; and

13     another Mrdzanic.

14             Do you remember that?

15        A.   Yes.  I do.  But I'm not sure that you put your question

16     correctly.  I think that we mentioned this in the context on the attack

17     on Zunovac [phoen].

18        Q.   Yes.  You are correct.  The first attack on the Zunovnica

19     barracks was carried out on the afternoon of --

20             JUDGE KWON:  Your time is up.  Conclude by 2.00.

21             THE ACCUSED: [Interpretation] Thank you.  I apologise to the

22     interpreters.  We have a wonderful opportunity to ask this of the man

23     who, by virtue of his position, could have known all this.

24             MR. KARADZIC: [Interpretation]

25        Q.   Is it correct that the village of Kasetici was attacked from the

Page 12034

 1     direction of Crepljani five days before the action in Tarcin of 25th of

 2     May, that there were five fatalities, and that one day before that, the

 3     whole Serbian family consisting of Aso Milosevic, Dejan Milosevic,

 4     Jovanka Milosevic --

 5             MS. EDGERTON:  It's just all going too fast, Your Honour, to

 6     allow any of us to properly catch up.

 7             JUDGE KWON:  I'm only amazed by the interpreters, the quality of

 8     interpreters and the stenographers who are following.

 9             THE ACCUSED: [Interpretation] I agree, but I'm pressed for time.

10     That's my problem.

11             MR. KARADZIC: [Interpretation]

12        Q.   So is it true that the village of Kasetici was attacked from

13     Tarcin, Do, and Dejovici?

14        A.   Mr. Karadzic, I am familiar with this case but that was not the

15     sequence of events as you stated.  Now, this was an attack on the

16     barracks in Zunovac, and after we recaptured our positions and while the

17     Bosniak forces were retreating, this massacre in Kasetici happened.  This

18     was more or less what happened.

19        Q.   So the Muslim forces, while retreating, killed the Milosevic

20     family, and the burst of fire were fired by Adem Kalem,

21     Azemi Sakovic [phoen] and their leader was Ahmet Sakovic.

22             Do you know that?

23        A.   Yes.  I know that this incident is soon going to be tried in

24     Republika Srpska because we filed a criminal report because we know

25     exactly who the perpetrators were.

Page 12035

 1        Q.   And these victims were massacred?

 2        A.   Yes.  They were mostly elderly people who were massacred.

 3        Q.   Thank you.  Is it true that the Serbs of Rastelica were also the

 4     subject of a pogrom when Refik Tufa came with another two men, killed --

 5     arrested all the men and took them towards Tarcin?  Do you remember this,

 6     being a policeman?

 7        A.   Of course I remember.  You don't need to elaborate these issues.

 8     I know very well what this is about.  Rastelica was attacked on the 28th

 9     of May.

10        Q.   Yes, it was led by Refik Tufa.  Then it says on the 10th of May,

11     the policeman Mirsad Sabic came with another man in escort and ordered

12     the Serbs to hand over their weapons.  On the early morning of the 29th,

13     three days after the devastation of Bradina, three lines of Muslim or

14     three circles of Muslim soldiers encircled --

15             JUDGE KWON:  Mr. Karadzic.

16             THE ACCUSED: [Interpretation] -- the village and this Ferhatovic

17     was among them.

18             JUDGE KWON:  Given the time, I just let you go, continue, but how

19     relevant are these events at all?

20             THE ACCUSED: [Interpretation] The position of the Defence, Your

21     Excellency, is that the situation in Hadzici was not a regular one in

22     which the state is responsible for what is going on.  It was chaos.  To

23     begin with, the Muslim side separated themselves, they left the Serbian

24     part of Hadzici, organised themselves, dug trenches, and launched attacks

25     on the barracks and military installations; and on the other hand, the

Page 12036

 1     Serbian authorities were unskilled, they were recently formed, and this

 2     part of the municipality was flooded by refugees.  I want this witness

 3     just to confirm whether the state was capable of doing anything because

 4     in this particular case, the state was accused of being responsible for

 5     certain events.  I just want a picture to be portrayed for the benefit of

 6     the Chamber.

 7             JUDGE KWON:  My question is how the facts that the Muslims

 8     allegedly committed crime are relevant to your case?  Is that the reason

 9     why the Serbs committed crime?

10             THE ACCUSED: [Interpretation] My thesis is that the Serbs did not

11     commit crimes because the state and state organs prevented that, but what

12     the Muslims did created certain atmosphere of panic and vengeful

13     behaviour.  We have here a representative of the state who was combatting

14     crimes committed both by the Serbs and the Muslims.  So I wanted this

15     witness to make a picture for you.

16             JUDGE KWON:  The Chamber does not argue with you.  That being the

17     case, such facts are not necessary all the more.  Conclude your

18     cross-examination in three minutes.

19             MR. KARADZIC: [Interpretation]

20        Q.   Mr. Glavas, I would now like to show you a map of Hadzici, a

21     plane geographic map, 65 ter 19107, 65 ter 19107.

22             I believe it would be easier for you to mark on this map the

23     separation line and also the line between the two municipalities, the

24     Serb and the Muslim part of the municipality.  The page is 0701-0752

25     under the number that I gave you, the 65 ter number.  From the municipal

Page 12037

 1     binder.  I would like to ask my learned friend whether we have the right

 2     number for the municipal binder, municipality binder.

 3             JUDGE KWON:  It's page 31?

 4             MS. EDGERTON:  I'm sorry, Your Honour, I don't have that binder

 5     with me but I think Your Honours must be able to assist.  My apologies.

 6             JUDGE KWON:  In order to mark it.

 7             THE WITNESS: [Interpretation] May I say something?

 8             JUDGE KWON:  Yes, please, Mr. Glavas.

 9             THE WITNESS: [Interpretation] Mr. Karadzic, if you don't have the

10     map, perhaps I can make it easier for you, and I can provide the trig

11     points.  It's from the Stupnik-Obeljak elevation point, Brezovaca,

12     Kasatici, by way of Tinovo, Gunsar [phoen], Ostrik.  And then towards the

13     border with Croatia or with the Croatians, you have the elevations of

14     Bela and Kokoska.  So that was the line, the boundary.  I know them by

15     heart.

16             MR. KARADZIC: [Interpretation]

17        Q.   Thank you.  Did Croats arrest and detain Serbs, your Croats?

18        A.   No.  We had -- we didn't have any misunderstandings or any

19     conflicts with the Croats who were on the border with Hadzici

20     municipality.

21        Q.   Thank you.  What about the Serbs in Hadzici?  Did they arrest and

22     detain Croats?

23        A.   I believe if there were any cases, there were very few.

24        Q.   Did Musici inhabitants take part in the attack on Hadzici?  And

25     did they open fire in Hadzici in the attack on the barracks, and did they

Page 12038

 1     open fire within the town itself?

 2        A.   Well, I don't know if they opened fire on the barracks, but I

 3     believe that we had information that they had attacked the road -- a road

 4     there so that it was difficult to use that road at the time.  They opened

 5     fire on that road.  But I'm not sure about the barracks.

 6        Q.   Thank you.  Now the Court Usher will help you to activate the

 7     e-pen and then perhaps you can show us and mark the border between the

 8     Serb part of the municipality and the Bosnian part, the boundary of the

 9     municipality of Hadzici.

10        A.   [No interpretation]

11        Q.   Where it says "Municipal Assembly building" and we see these two

12     yellow triangles, is that the very centre?  Is that the town itself,

13     Hadzici town?

14        A.   Well, this part here that I'm indicating.  [Marks].  I'm not sure

15     whether this is the border, whether I'm absolutely accurate, but the

16     accurate delineation of the border were the elevations that I mentioned

17     earlier.  So we didn't even have 30 per cent of the municipality.

18        Q.   Thank you.  Were the Muslim forces right behind these hills

19     behind Hadzici and they could open fire on you at any time?

20        A.   Yes, their forces were on the other side of Ormanje.  We were on

21     this side and Ormanje was a sort of buffer zone.

22        Q.   No man's land?

23        A.   Well, something like that.

24        Q.   Are you referring to that peak of Ormanje, the mountain peak?

25        A.   Yes.

Page 12039

 1        Q.   Would you please mark the Serb part with an S and the Muslim part

 2     with an M?

 3        A.   [Marks]

 4        Q.   And would you now please date and sign this document?  I believe

 5     it's the 16th.

 6        A.   [Marks]

 7        Q.   And my final question, Witness:  We saw that there were Muslim

 8     civilians in the Serb part of the municipality who were on work -- under

 9     work obligation and who could freely move around.  Now, were there Serbs

10     on the Muslim part of the municipality who were free and remained free

11     until the end of the war?

12        A.   I don't think so.  I think that perhaps there may have been two

13     to three men, mostly older men.

14        Q.   Thank you.  You also told us that you -- there was a border with

15     Konjic municipality and was it --

16             THE INTERPRETER:  Could the accused please repeat his question?

17             JUDGE KWON:  Ms. Edgerton?

18             MS. EDGERTON:  Your Honour, it's with respect to the redirect.

19     Your Honours haven't inquired yet and, I'm sorry, I haven't offered an

20     estimate of what time I might take, but this is a pattern that repeats

21     itself and the Prosecution is continually constricted with Dr. Karadzic

22     pressing the line by asking one more question, one more question, which

23     usually amounts -- which usually has an effect on our effective redirect.

24             JUDGE KWON:  I didn't expect that your redirect would last more

25     than 20 minutes?  You have more than 20 minutes?

Page 12040

 1             MS. EDGERTON:  No, Your Honour, but I note it's now 10 after 2.00

 2     and we are sitting until 2.30 today.

 3             JUDGE KWON:  Yes.  So your last question, Mr. Karadzic.

 4             THE ACCUSED: [Interpretation] Well, I've concluded more or less.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Could you just tell us about Bradina, did Bradina in any way have

 7     any ties to your municipality or did it belong to your municipality, and

 8     can you tell us what kind of danger it posed to the Muslims and what

 9     happened to Bradina?

10        A.   Bradina was part of Konjic municipality, but it's a fact that it

11     was closer to the Hadzici municipality area.  It was a purely or

12     predominantly Serb-populated municipality, and in my view, in view of

13     the -- of the -- their position militarily they were absolutely unable to

14     pose any danger or threat to the Muslims because on -- they bordered on

15     the one side on the Muslims and then on the other side, they also had

16     borders with territory that was under the control of the Muslims, so they

17     were some sort of buffer zone.  And there was not a chance, not even a

18     theoretical chance, that they could actually oppose the Muslims, and

19     unfortunately, a lot of people were arrested there, some of them were

20     taken prisoner and so on.

21        Q.   Is it true that some 50 to 60 civilians were buried outside the

22     church grounds?

23             JUDGE KWON:  Mr. Karadzic, you said you have concluded your

24     cross-examination.

25             THE ACCUSED: [Interpretation] I have.  Thank you, Mr. Glavas.

Page 12041

 1     I would like to tender this map.

 2             JUDGE KWON:  This marked map will be admitted as Exhibit D1087.

 3             Yes, Ms. Edgerton?

 4             MS. EDGERTON:  Thank you, Your Honours.

 5                           Re-examination by Ms. Edgerton:

 6        Q.   Mr. Glavas, I'd like to deal again with some themes that have

 7     come up in your cross-examination.  The first being one that you spoke

 8     about to a great extent today, the presence of paramilitaries in Ilidza.

 9     Now, talking about the presence of paramilitaries in Ilidza, Dr. Karadzic

10     asked you at one point that the -- his question was the government

11     authorities actually feared these groups and they tried to avoid getting

12     into contact with them, and he asked you whether that meant that they

13     didn't have at their disposal a sufficient or strong enough police force

14     to deal with them.  And your response was, well, that wasn't the only

15     problem.  We had a large police force in Ilidza and we could oppose them.

16     However, there were some personal links, personal connections, and these

17     men would sometimes break into the police station itself and issue

18     threats.  Do you remember that?

19        A.   Yes.  But I'm not sure that I said "personal connections."  What

20     I meant was there were personal relations.  It doesn't mean that they

21     were close with the president of the municipalities.  However, there were

22     cases -- well, I, for instance, know of a specific case, that Brne would

23     burst into Mr. Prstojevic's office and pull out his gun, his pistol.

24        Q.   Mr. Glavas, I'm very curious about these personal connections

25     because you've said, when you were asked whether Prstojevic and Unkovic

Page 12042

 1     were the ones who ordered or controlled the paramilitaries, you said,

 2     well, that was suspicious information, and you also said that the police

 3     had -- and particularly cited Mr. Kovac and his argument with Legija, and

 4     that's in your written evidence, you said that the police absolutely did

 5     not have anything to do with the paramilitaries being in Ilidza.  And

 6     when you discussed, in your written evidence, the attempts to rid Ilidza

 7     of the paramilitaries, you talked about the cooperation of the Ilidza

 8     brigade commander.

 9             So who, if the political leaders, the police, and the

10     Ilidza Brigade had nothing to do with the presence of the paramilitaries

11     in Sarajevo, who were the personal connections that ensured their

12     presence?

13        A.   Well, I believe that I said this in the interview we had in

14     Sarajevo, how it was possible for paramilitary units to be there.  This

15     was true information.  So through friendly connections and ties, they

16     were able to come to a certain area.

17        Q.   You seem to be well informed.  Are you able to give us a name?

18     And perhaps it might be easier if I just confine my question to Ilidza

19     municipality.

20        A.   Very well.  Well, I will repeat what I've already said in

21     Sarajevo.  When I came to Ilidza, and when I was briefed on the presence

22     of these paramilitary units, I learned, among other things, that

23     Dragisa Ivelja was the one who actually brought in these paramilitary

24     units, and I had very specific information that he was the one who had

25     brought in the Arkan -- Arkan's men.

Page 12043

 1        Q.   And who ensured the presence of the Seseljevci?

 2        A.   I think because at the time they were members of the

 3     Serbian Radical Party for all practical purposes, and at this time it was

 4     being established in that area as well, I believe that it was members of

 5     the Serbian Radical Party who actually ensured or made it possible for

 6     them to be present there.

 7        Q.   Did the individual whose name you've just given us which reads

 8     Dragica Ivelja have any role in the government or the authorities of the

 9     Serb municipality of Ilidza?

10        A.   No.  I don't know whether he had any role in the government or

11     the authorities, but I do know that at the time he was involved in, well,

12     let's -- shall we call it rear activities?

13        Q.   What do you mean by "rear activities"?

14        A.   Well, I meant supplies, logistics, primarily supplies of food for

15     the needs of the citizens of Ilidza.  That's what I was referring to.

16        Q.   Thank you.  I'll move on to another area.  You talked with

17     Dr. Karadzic about communications in your cross-examination today.  And

18     at page 10 you were asked whether -- in regard to a particular document

19     you were asked whether the local authorities during the first months of

20     the conflict were primarily left to their own devices, and that there was

21     no communication between local and central authorities.  That's page 10,

22     line 16 to 20.  And you said yes, that's correct.  And then you commented

23     on another document, 65 ter 01648, pages 33, lines 24 to 34, there

24     Dr. Karadzic asked in regard to that document whether this confirmed that

25     the information you gave, namely that the central organs could not be

Page 12044

 1     reached easily before mid-September, and you said that that confirms that

 2     precisely.  Do you remember that evidence?

 3        A.   I do remember that evidence, but I was referring to the type of

 4     communications that we had in terms of communications equipment.  It was

 5     very poor, so we were only able to report on any incidents or any events

 6     of any significance by way of courier service.

 7        Q.   So when your answers referred generally to local authorities,

 8     were you, in fact, actually limiting your answer specifically to the

 9     situation as you recalled it in Hadzici municipality?

10        A.   That's right.  And generally, I spoke about matters that had to

11     do with the activities that I had as the chief of police down there.

12        Q.   In that case, I'd just like to go to one document which you've

13     already seen today, D1073.  You were shown that at page 39 of today's

14     transcript.  This is a report on the daily -- on daily events by the

15     Minister of the Interior of the Serbian Republic of Bosnia-Herzegovina.

16     Now, this is dated 12 May 1995, and if you go down to paragraph 2 of the

17     English on page 1 and just scroll down so you can see further down the

18     same page in Serbian -- pardon me, it's dated 1992, my mistake.  You see

19     that this document talks about the situation as it was for the past

20     two days in Hadzici, saying, among other things, despite unequal balance

21     of forces, with the Serbs being less in number, attacks of Muslim

22     paramilitary formations had been resisted successfully.  That was not

23     read out to you earlier.  And I just want to ask whether this type of

24     report reflects your regular communication through the hierarchy of your

25     organisation to the central authorities.

Page 12045

 1        A.   Yes.

 2        Q.   Thank you.  Can we just go over to another document, please,

 3     D00317, which you also saw today.  It's a report on the combat readiness

 4     of the Serbian Municipality of Hadzici, dated 29 May 1992.  And if we

 5     could go over to the Serbian page 2 and stay --

 6             MS. EDGERTON:  If we could scroll down a little bit, thank you,

 7     to the bottom of this page, this document says -- the Serbian page needs

 8     to go up a little bit, and he can't see the whole page on the left-hand

 9     side so I don't want it to be cut off.

10        Q.   This document says, among other things, that as a result of

11     combat activities, the Crisis Staff -- or we, asked for help from the

12     commander of the HQ of the Main Staff.  I see the English doesn't quite

13     match.  The English says -- pardon me, the English reads, "Commander of

14     the HQ of the Serbian Republic."  And the B/C/S version reads, "Commander

15     of the Main Staff of the Serbian Republic of Bosnia-Herzegovina himself,

16     who presently sent a fighting group under the command of

17     Lieutenant-Colonel Petrovic."

18             And I just want to ask you, to your mind, does this reflect an

19     ability of people at the local level in Hadzici to contact the central

20     authorities at a critical time?

21        A.   No.  And I'll tell you why.  I see here mention of this

22     Lieutenant-Colonel.  Now, I was in Hadzici at the time, and his mission,

23     his only mission, was to pull out the conscripts from Pazarici and -- or,

24     rather, the cadets and his primary purpose of his being in Hadzici was

25     that mission.  And they were --

Page 12046

 1             THE INTERPRETER:  Could the witness please repeat the second part

 2     of his answer?

 3             JUDGE KWON:  Mr. Glavas, could you repeat your second part of

 4     your answer?

 5             THE WITNESS: [Interpretation] I would not put the two together

 6     and I wouldn't bring that in relation with the local authorities for the

 7     simple reason that I know that the then-former Yugoslav People's Army had

 8     some loose ends that they had to capture.  Among other things, there was

 9     a group of cadets in Pazarici barracks, and they had come there in order

10     to pull them out of there.  In the meantime, the attack on Hadzici was

11     launched and they happened to be there, so they were able to help us in

12     recapturing Zunovnica and pulling out those cadets from Pazarici and pull

13     them out of that entire area.

14        Q.   Now, Mr. Glavas you've earlier looked at this document and said

15     it was quite accurate and that was the basis on which I put this document

16     to you.  Are you saying that the document is now no longer -- is not

17     accurate, in fact?

18        A.   No.  That's not what I meant.  Perhaps someone misinterpreted it.

19     I'm sorry.  All of a sudden this went away.  What you read out to me now

20     is something that I had not known before.  However, what I said now is

21     something that can be checked very, very easily.  I know the name and

22     surname of this Lieutenant-Colonel who came and I know what his mission

23     was, what the purpose of his coming to our area was.  First of all to get

24     the cadets out of the barracks in Pazarici, and that was under the

25     control of the Bosniak forces.

Page 12047

 1        Q.   Now you're repeating yourself a little bit.  What I read to you

 2     was the passage that said, "We asked for help from the commander of the

 3     headquarters of the Serbian Republic of --" pardon me.  "We asked for

 4     help from the commander of the Main Staff of the Serbian Republic of

 5     Bosnia-Herzegovina himself."

 6             Are you saying that that is not accurate?

 7        A.   I don't know who wrote this document.  I cannot say now whether

 8     it's accurate.  I told you, these active duty officers who were in the

 9     area at the time were only there for the reasons that I mentioned a few

10     moments ago.

11        Q.   Thank you.  We'll move on to one final area.  Dr. Karadzic, at

12     page 48, asked you whether it ever occurred that the Crisis Staff or any

13     other organ of authority, either police or military, issued orders or

14     allowed or tolerated illegal treatment of detainees.  And your answer

15     was, well, in principle, there were no such instances.  So I'd like to

16     know how to interpret this answer.  Are you saying it didn't happen?

17        A.   Yes.  That's what I wanted to say.

18        Q.   But you've already given evidence about civilians in Hadzici

19     being detained at the sports centre for the express purpose of exchange.

20     You've given evidence of women being among that number.  You've given

21     evidence of abuse going on, in fact, in your written evidence you said

22     sexual abuse, at the sports centre, and you've given evidence that the

23     sports centre was instituted and maintained under the control of the

24     Crisis Staff.  So how do you explain your answer?

25             JUDGE MORRISON:  Ms. Edgerton, are you seeking to impeach the

Page 12048

 1     witness, because this is a Prosecution witness?

 2                           [Trial Chamber confers]

 3             THE WITNESS: [Interpretation] I do apologise.  May I answer this

 4     question?

 5             JUDGE KWON:  Yes, by all means, we will allow you to put the

 6     question.  Yes, please proceed to answer, Mr. Glavas.

 7             THE WITNESS: [Interpretation] Ms. Carolyn, it seems that we

 8     haven't understood each other.  I'm not contesting what you said just

 9     now.  Those are facts.  That is what I said in my statement.  It never

10     crossed my mind to deny any of what I had stated to you.  I was just

11     trying to say that the municipal authorities and the police authorities

12     and the military authorities never gave any instructions to carry out any

13     kind of torture against persons who were detained on certain premises.  I

14     am not challenging the fact that persons were not being brought in and

15     detained in various areas, including where I was chief of police, but

16     that is what I meant.

17             MS. EDGERTON:  Thank you.  That's everything, Your Honours.

18             THE ACCUSED: [Interpretation] May I just ask for one particular

19     clarification?

20             JUDGE KWON:  No, this time, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] It will remain unclear, Excellency

22     who are the people who called themselves Seseljevci or Arkanovci,

23     Seselj's men or Arkan's men, and the impression will remain that it is

24     people from came from Serbia.  Already in April, these people who had

25     come from Serbia were denied any hospitality and -- well, you ask the

Page 12049

 1     witness.

 2             JUDGE KWON:  Please, I'll consult my colleagues.

 3                           [Trial Chamber confers]

 4             JUDGE KWON:  Very well.  Mr. Glavas, can you answer the question?

 5             THE WITNESS: [Interpretation] Oh, I can answer the question, but

 6     I think that Mr. Karadzic and I do not agree this time.  I had already

 7     given a statement to the OTP down there, when I spoke about paramilitary

 8     formations.  I said that there were these two basic groups, but they can

 9     also be mixed.  I spoke of para formations that come exclusively from our

10     area, Republika Srpska, and also there were those that came from

11     elsewhere.  When I said elsewhere, I meant that these were persons coming

12     from Serbia.  That is the statement I made to the Office of the

13     Prosecutor, and I cannot deny that.

14             JUDGE KWON:  Thank you, Mr. Glavas, that concludes your evidence.

15     On behalf of the Tribunal and the Chamber, I thank you very much for your

16     coming to The Hague to give it.  Now you're free to go.

17             THE WITNESS: [Interpretation] Thank you.

18                           [The witness withdrew]

19             JUDGE KWON:  Mr. Robinson?

20             MR. ROBINSON:  Yes, Mr. President, just for one moment.  If

21     I could ask that eight different passages from our transcript be made

22     public in connection with Mr. Zecevic's situation.  I've given the dates

23     to your staff and if we could also make that part of the public record

24     I would appreciate it.

25             JUDGE KWON:  There seems to be no reason not to grant your

Page 12050

 1     request, but just out of an abundance of caution, the Chamber will

 2     consider each transcript and will give its ruling in writing in due

 3     course.

 4             And tomorrow, we will be hearing Mr. Pseudonym?

 5             MR. GAYNOR:  Yes, the first witness is scheduled to testify by

 6     videolink and he's testifying under pseudonym.

 7             JUDGE KWON:  Yes.

 8             MR. GAYNOR:  And the other witness is available in The Hague

 9     too ---

10             JUDGE KWON:  Thank you.

11             MR. GAYNOR:  -- to commence as soon as the other one is finished.

12             JUDGE KWON:  Thank you.  I apologise for the delay but the

13     hearing is now adjourned for today.

14                           --- Whereupon the hearing adjourned at 2.33 p.m.,

15                           to be reconvened on Thursday, the 17th day of

16                           February 2011, at 9.00 a.m.