Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14210

 1                           Monday, 6 June 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

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

 6             JUDGE MORRISON:  Good morning, everybody.  Just a reminder that

 7     we are again sitting under the provisions of Rule 15 bis in the absence

 8     of Judge Kwon.

 9             Good morning, Mr. Neskovic.  Could you take the solemn

10     declaration, please.

11             THE WITNESS: [Interpretation] Good morning.  I solemnly declare

12     that I will speak the truth, the whole truth, and nothing but the truth.

13             JUDGE MORRISON:  Thank you.  If you would like to sit down and

14     make yourself comfortable, and then Mr. Tieger will commence the

15     proceedings.

16             MR. TIEGER:  Good morning, Mr. President, Your Honours, everyone

17     in and around the courtroom.

18                           WITNESS:  RADOMIR NESKOVIC

19                           [Witness answered through interpreter]

20                           Examination by Mr. Tieger:

21        Q.   And good morning, Mr. Neskovic.

22        A.   [No interpretation]

23        Q.   Mr. Neskovic, you testified in the case of Prosecutor versus

24     Krajisnik on the 18th, 19th, and 20th of July, 2005; is that correct?

25        A.   Yes.

Page 14211

 1        Q.   And is it also correct that you've had the opportunity to review

 2     the audio tapes of that testimony?

 3        A.   Yes.

 4        Q.   Can you confirm for the Trial Chamber, then, that your testimony

 5     accurately reflected your statements before the Court and that if

 6     examined on the same subjects in this court, that the information you

 7     would provide would be the same; in short, that you stand by that

 8     testimony?

 9        A.   Basically yes, although some words would be different.  I would

10     not be able to repeat everything in the same words every time again.

11        Q.   I don't think a verbatim memory quiz is what the rule had in

12     mind, Mr. Neskovic.  Thank you.

13             MR. TIEGER:  Your Honour, P22217, the entirety of the testimony

14     from the Krajisnik case from 18 July through 20 July 2005, is now

15     tendered.

16             JUDGE MORRISON:  Thank you.

17             Mr. Robinson.

18             MR. ROBINSON:  No objection, Mr. President.

19             JUDGE MORRISON:  That will be admitted.

20             THE REGISTRAR:  As Exhibit P2568, Your Honours.

21             JUDGE MORRISON:  Thank you.

22             MR. TIEGER:  Thank you, Mr. President.

23             And I will proceed to read the summary or address the associated

24     exhibits as the Court wishes.

25             JUDGE MORRISON:  Yes, Mr. Tieger, if you just read it out.

Page 14212

 1             MR. TIEGER:  Thank you, Mr. President.

 2             Mr. Radomir Neskovic, a public -- well, let me explain for --

 3        Q.   Mr. Neskovic, I'll be reading for the Court a short summary of

 4     your testimony.  It's not intended to capture all the details and is not

 5     intended to replace your evidence which is, in fact, in evidence.  It's

 6     just intended as a guide so that the evidence is briefly summarised.

 7             MR. TIEGER:  Mr. Radomir Neskovic, a public opinion researcher by

 8     profession, was asked by Mr. Karadzic in August 1990 to join the SDS, to

 9     do research and analysis of public opinion for the party and he attended

10     meetings of the Main Board.  On 12 July 1991, Mr. Neskovic was on a list

11     of names proposed by Dr. Karadzic for the Main Board and was elected to

12     be a member of the SDS Main Board.  He was elected deputy chairman of the

13     SDS Executive Board on or around 31 July 1991.  In 1992, the witness was

14     also President of the Crisis Staff in Novo Sarajevo.  In 1993, he

15     considered himself to be a de facto member of the Executive Board of the

16     SDS.

17             The SDS party was hierarchical and once a decision was taken, it

18     was necessary for this decision to be implemented by all the bodies - by

19     the local board, by the municipal boards.  Each member of the local

20     committee would be active on behalf of about 20 households.  Obedience

21     was required and municipal bodies could be dismissed if they failed to

22     implement the party's policies.  Mr. Karadzic was the undisputed

23     authority in the party and expected obedience.

24             After joining the SDS, Mr. Neskovic visited many municipalities

25     to resolve organisational and staff issues and conflicts.  He was tasked

Page 14213

 1     to do so by either the SDS Executive Board or Main Board or directly from

 2     Mr. Karadzic.  Upon return, he would submit a report to the

 3     Executive Board or to Mr. Karadzic personally, although he came to

 4     realise that Karadzic was already informed of what he had been involved

 5     in even before he had returned from the field.

 6             In addition to emissaries such as Mr. Neskovic, Dr. Karadzic

 7     communicated with the municipal leadership of the SDS in various ways,

 8     including direct contact with municipal leaders by phone and fax and

 9     letters.  In addition, leaders from municipalities very frequently came

10     to see Mr. Karadzic for various questions and issues.  Mr. Karadzic could

11     authorise these municipal officials to act and they would do so

12     accordingly.

13             As a member of the Main Board and Executive Board, Mr. Neskovic

14     was present at a meeting of a large number of SDS functionaries held in

15     the Holiday Inn around 19 December 1991.  Mr. Neskovic testified that at

16     this gathering Mr. Karadzic distributed numbered copies of the Variant A

17     and B document to municipal representatives.  Mr. Karadzic gave an

18     introductory speech that had to do with the threat that Serbs were under

19     and then municipal leaders were called up to take the document and told

20     to read it.  He understood that it was mandatory for those who received

21     the A and B document, that is, persons who held high-ranking positions

22     within the local authorities, to implement the document, although it was

23     up to them to decide how best to do so.

24             The witness also testified about the implementation of Variants A

25     and B instructions in the municipality of Novo Sarajevo, where he was a

Page 14214

 1     member of the Crisis Staff set up pursuant to those instructions.

 2             Mr. Karadzic devoted much attention to those holding formal

 3     positions on behalf of the SDS in the governmental authorities, such as

 4     members of the Presidency, Serb ministers, president of the Assembly, and

 5     MUP representatives and would "focus on his representatives within the

 6     organs of power."  Many persons appointed to high-level positions were

 7     personal picks of Mr. Karadzic, including the president of the Assembly,

 8     Mr. Karadzic's close associate Momcilo Krajisnik.  Mr. Karadzic and

 9     Mr. Krajisnik often visited party bodies when it came to personnel

10     policies and they would appoint individuals to posts in executive power

11     structures.  The personnel in the Ministry of Interior in the MUP were

12     also personally chosen by Mr. Karadzic.

13             The witness also testified that Muslims were expelled in droves

14     from Grbavica and also testified about a man named Batko who maltreated

15     and terrorised people and whose main targets were Muslims.

16        Q.   Mr. Neskovic, I have a few additional questions for you, but as I

17     advised the Trial Chamber, my examination-in-chief will be brief.

18             First of all, Mr. Neskovic, although it's alluded to in your

19     testimony, I don't think it's explicit, can you tell the Court for how

20     long you continued to be a member of SDS?

21        A.   I was a member of the SDS beginning with 12 July 1990 until

22     August 1997.

23        Q.   Thank you.  I wanted also to ask you about an issue that may be

24     related to two aspects of your testimony.  Your evidence was that the

25     SDS party was hierarchical, that it was necessary for decisions from the

Page 14215

 1     top to be implemented by the lower bodies, and that members could be

 2     dismissed if they failed to implement party policies.  And you also

 3     testified that at the meeting in December at the Holiday Inn at which the

 4     Variant A and B document was disseminated, that the atmosphere was

 5     emotionally charged and that it was not conducive to discussion about the

 6     substance of the document because one might have appeared to be a traitor

 7     if one appeared to be rejecting the document.

 8             Now, I wanted first to ask what was the significance during those

 9     times of being labelled or called a traitor?

10        A.   Well, I stated that, thinking that it might happen that way;

11     however, at that meeting it didn't happen and nobody even discussed the

12     document.  It was just an assumption on my part.  If somebody were to be

13     called a traitor, that person would lose their reputation among the

14     Serbs, among their acquaintances, among the party members.  That would

15     mean losing one's standing and one's influence in the Serbian community.

16        Q.   And did concerns about the consequences of being deemed a traitor

17     also play a role in general party discipline?

18        A.   I don't think so.  Party discipline applied to the implementation

19     of policy.  A person who would fail to implement the party policy or

20     would cause conflicts at the level of lower organs of the SDS would be

21     sanctioned for that failure.  If somebody were labelled a traitor in the

22     Serbian community would not necessarily entail disciplining on the part

23     of the SDS party.

24        Q.   Mr. Neskovic, you testified that members of the Main Board would

25     regularly attend meetings of municipal boards in the areas they were from

Page 14216

 1     and that this was one of the ways that SDS policies were communicated to

 2     and followed by those in the field.  Did the SDS deputies, first those in

 3     the joint Assembly and then later in the Bosnian Serb Assembly, play a

 4     role in conveying information to the field and relaying to the leadership

 5     what was happening in the field?

 6        A.   I'm not sure about deputies.  I don't have that information.  But

 7     it certainly applied to members of the Main Board.  Members of the

 8     Main Board regularly attended meetings of municipal boards in their

 9     native places, and the relationship between grass-roots organisations of

10     the SDS and the leadership of the party was very strong, very well

11     developed.  There were many contacts from the top down and vice versa.

12     Speaking of members of the Main Board, the answer is yes; but as far as

13     members of the parliament are concerned, I'm not sure to what extent they

14     were involved in municipal organisations.

15        Q.   Thank you.  You testified that part of the organisational

16     structure to facilitate communications was that each member of a local

17     board was to be active on behalf of 20 households.  And just to be clear,

18     were those local board members expected to report the information they

19     received directly to the SDS leadership at the central level or to the

20     municipal boards immediately above them?

21        A.   The basic organisation was the local board, that's the lowest

22     organisation of the SDS, and it would have up to 15 members.  Each of the

23     members was in charge of some 15 to 20 households where he represented

24     the SDS, and he would inform the local board, the local board would

25     inform the municipal board, and the municipal board would report to the

Page 14217

 1     president of the party or the Main Board.

 2        Q.   Thank you.  Mr. Neskovic, you explained to the Court in 2005 that

 3     when you returned from the field, you would report back to either the

 4     Main Board or the Executive Board or to Mr. Karadzic himself, and if you

 5     wanted to submit a report to Mr. Karadzic, you realised that he was

 6     already informed of what you had been involved in even before you

 7     returned.  I wanted to ask you how you came to this realisation, whether

 8     it was from discussions directly with Dr. Karadzic, from others in the

 9     SDS.  How did you come to realise that?

10        A.   I usually reported to Mr. Karadzic verbally concerning the work I

11     had done in a particular municipality, but he never insisted on an

12     exhaustive verbal report.  Our conversations would be very short, from

13     which I concluded that he had already received reports from the municipal

14     board or somebody else in the municipality.  So he was informed already,

15     and that's why he did not ask me for an exhaustive report.  That's how I

16     made that inference.

17        Q.   And when you went to the field, did local leaders speak to you

18     about or provide you with information about their contact with

19     Dr. Karadzic?

20        A.   No.

21        Q.   So you came to address the issues that you had to address and

22     focused on those issues with them?

23        A.   Yes.  I always asked that they specify what I'm supposed to do.

24     It was usually about conflicts between different factions within the

25     organisation and I played the role of mediator to defuse those tensions.

Page 14218

 1     That's what I usually dealt with, not other issues.

 2        Q.   And finally, Mr. Neskovic, you testified that Mr. Karadzic was

 3     the undisputed authority in the SDS party and that he, along with

 4     Mr. Krajisnik, was the supreme authority of the Serb movement, whose

 5     policies were implemented through deputies, ministers, MUP officials,

 6     through people in government, whether it was the joint government of BiH

 7     or later in Republika Srpska.  And although you seemed to put a start

 8     date on that situation by reference to the time when there was still a

 9     joint government, I wanted to ask you for how long this was the case,

10     that is, was that the case during the course of the war?

11        A.   Right.

12             MR. TIEGER:  Thank you, Your Honours.  That concludes the

13     examination-in-chief.  With respect to the associated exhibits, I advised

14     the Court yesterday about one issue.  I don't believe there's any -- and

15     that is the incorrect listing of 65 ter 01482 on the list of documents to

16     be used rather than the associated exhibits.  I also note that the

17     second-to-last reference in the listing of associated exhibits, that is

18     00332 should be 06079, those are two documents of the same date bearing

19     on the same issue, but it is 06079 that is referred to at transcript

20     page 16834.  I've spoken with Mr. Robinson about that and he has no

21     objection.

22             MR. ROBINSON:  Yes, Mr. President.  We don't object to any of the

23     associated exhibits.

24             JUDGE MORRISON:  Thank you, Mr. Robinson.  While you're on your

25     feet, Mr. Robinson, it's a collateral issue.  The Prosecution has put in

Page 14219

 1     a motion with respect to the recommencement of the evidence of

 2     Dr. Treanor.  Would you -- could you be in a position to respond to that

 3     orally at some point this morning?

 4             MR. ROBINSON:  Yes, Mr. President.  I can do that right now.  I

 5     don't think we would have any objection to that.  We have also today sent

 6     a letter to the Prosecution asking for disclosure of the other interviews

 7     at which Mr. Treanor was present, so that we can see whether there was

 8     any other material that hasn't been disclosed to us that could be

 9     relevant to his cross-examination.  But assuming there is none, I don't

10     see any reason why we couldn't go ahead with his testimony after this

11     witness concludes.

12             JUDGE MORRISON:  Thank you.

13             Is that sufficient for your purposes, Mr. Tieger?

14             MR. TIEGER:  I haven't had an opportunity to see the letter, but

15     it sounds like we'll be moving forward and that would be appropriate.

16             JUDGE MORRISON:  Dr. Karadzic, it's now your opportunity to

17     cross-examine.

18                           [Trial Chamber and Registrar confer]

19             MR. KARADZIC: [Interpretation] Good morning, Your Excellencies.

20     Good morning to everyone.

21                           Cross-examination by Mr. Karadzic:

22        Q.   [Interpretation] Good morning, Mr. Neskovic.

23             Has anyone heard me?

24             JUDGE MORRISON:  Yes, you're coming through my microphone --

25     earphones certainly.

Page 14220

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Good morning, Mr. Neskovic.  I don't know if you can hear me.

 3        A.   Good morning, Mr. Karadzic.  I heard.  I heard the second part.

 4     I can hear now.

 5        Q.   Thank you.  I wanted to ask you, you were kind enough to meet

 6     with my advisor on the 10th of October, 2009, and on that occasion a

 7     transcript was made of that interview; is that correct?

 8        A.   Yes.

 9        Q.   I must ask you that both of us make a pause between questions and

10     answers so we don't overlap and make things hard for the interpreters.

11     Has my advisor sent you a transcript of that interview for your

12     consideration?

13        A.   Yes.

14        Q.   Would you answer the same questions today in the same way?

15        A.   Basically yes.

16        Q.   Thank you.  Let us start from the beginning.  You described our

17     meeting and the moment you joined the Serbian Democratic Party.  Do we

18     agree that before the 12th of July, 1990, the two of us did not know each

19     other and we met the night before the day when the SDS was established?

20        A.   Yes.

21        Q.   Is it the case that you with your democratic party of freedom

22     that had already been established as well as other parties and movements

23     collectively joined the SDS at that session of the Assembly?

24        A.   Yes.

25        Q.   Thank you.  After that, knowing about your career record, did I

Page 14221

 1     ask you to take charge of analytical affairs in the party, especially

 2     analysing the public opinion?

 3        A.   Yes, that was in August 1990 in Pale.

 4        Q.   Thank you.  After that you became deputy, or rather,

 5     vice-president of the Executive Board or deputy president of the

 6     Executive Board, and at the next electoral assembly you became member of

 7     the Main Board too?

 8        A.   No.  I attended the Main Board meeting at Ilidza from

 9     August 1990, and I believe I was co-opted by you onto the Main Board.

10     However, I became member of the Executive Board at the elections on the

11     31st of July, 1991, after the electoral assembly held on the

12     12th of July, 1991.

13        Q.   Thank you.  I see that your memory is better than mine.

14             Now, do you remember that one of the main initiators in the

15     formation of the Serbian Democratic Party was Mr. Aleksandar Vukovic, a

16     political scientist, a specialist lawyer and so on and so forth.  Do you

17     remember that?

18        A.   If you mean Aca from Grbavica, the old Aca, then yes.

19        Q.   That's right.  That's the same person.  Now, I'd like to show you

20     a document which is connected with our cadres election.

21             THE ACCUSED: [Interpretation] And may we have 1D3558 on our

22     screens on e-court, please.

23             MR. KARADZIC:  [Interpretation]

24        Q.   We have here the two versions, both in Serbian and in English.

25     Let me remind you that on the 12th of January, 1991, which is to say

Page 14222

 1     right after the elections and immediately before the formation of the

 2     joint authority in Bosnia-Herzegovina, as you can see from this document,

 3     Mr. Vukovic is sending an amended proposal of candidates for leadership

 4     positions.  And here he goes on to enumerate the names of people,

 5     regardless of whether they were members of the party or not.  And I'm

 6     sure you will remember and you will agree that the person listed under

 7     number 1 was not a member of the party.

 8        A.   Can you tell me what your question is.  What are you asking me in

 9     fact?

10        Q.   Well, I wanted to enumerate the people.  Let's see, number 1, we

11     have that on the first page.  But may we turn to the second page.

12             THE ACCUSED: [Interpretation] May we have page 2 of the Serbian

13     and of the English as well, please, on our screens.

14             MR. KARADZIC: [Interpretation]

15        Q.   Now, just look at those names there.  Do you remember, for

16     example, that Mr. Kovas who was there on behalf of the Serbian Democratic

17     Party, the republican prosecutor was not a member of the party and

18     Simo Kuraica was not.  Skoko might have become a party member but was not

19     one at that particular point.

20             THE ACCUSED: [Interpretation] And may we have the last page

21     displayed, please.

22             And the last page in Serbian as well, please.

23             MR. KARADZIC: [Interpretation]

24        Q.   Do you agree that your name is listed is there under number 17

25     and it says that you were working at Sarajevo RTV, that you were a

Page 14223

 1     lawyer, and that you were proposed to be assigned to responsible duties

 2     in the Presidency.

 3             Now, my question is this:  Do you agree that many of the people

 4     from this list were people who were not, in fact, members of the

 5     Serbian Democratic Party?  For example, number 3, Ranko Nikolic, used to

 6     be a minister in the communist era and that the cadres commission led by

 7     Mr. Dukic adopted this and that these people were put forward as

 8     candidates to hold positions in the leadership?

 9        A.   I must say that this is the first time that I see this document.

10     I don't know on the basis of what authority Vukovic could have proposed

11     cadres in this fashion, and I never knew about this until today.  Most of

12     the personnel, the cadres, that exercised power and authority had nothing

13     to do with the SDS.  And I don't know today how those people were put

14     forward bypassing the SDS organs because they weren't members, in fact,

15     of the SDS.  Now, as far as I'm concerned, nobody proposed me to any

16     Presidency or anything like that, nobody put my name forward.  So my

17     answer would be yes, most of the Serbs in the BH government had nothing

18     to do with the SDS and were proposed to the positions they held bypassing

19     the SDS or, rather, not as members of the SDS.

20        Q.   Thank you.

21             THE ACCUSED: [Interpretation] I would like to tender this

22     document into evidence now, please.

23             MR. TIEGER:  No objection, Your Honour.

24             JUDGE MORRISON:  That will be admitted.

25             THE REGISTRAR:  As Exhibit D1273, Your Honours.

Page 14224

 1             MR. KARADZIC: [Interpretation]

 2        Q.   We'll come back to that topic, Mr. Neskovic, as to what guided us

 3     to have people who weren't members of the SDS proposed and entrusted with

 4     important state functions, but now may we look at 65 ter document 18531,

 5     please.  18531 next, please, and it is the minutes from the 1st Session

 6     of the newly elected Executive Board of the SDS of BH held on the

 7     31st of July, 1991.

 8             Can you see the document and that in paragraph 2 it says that

 9     Karadzic attended as well as Krunic, Neskovic, and others?  And now at

10     the bottom there, under number 1, it says in paragraph 1 that Karadzic

11     proposed the election of the president of the Executive Board and then

12     put forward the proposal of Mr. Rajko Dukic, put forward Mr. Rajko Dukic

13     for the post.  Dukic thanked him.

14             Now, do you remember that Dukic had his own party and that he

15     joined the Serbian Democratic Party when you did?

16        A.   Yes.

17             MR. TIEGER:  Sorry to interrupt, but if this draft translation is

18     a full translation of the document, then I would ask that the English

19     page be placed to correspond with the B/C/S.  But if it's not, I think we

20     need to know.

21                           [Defence counsel confer]

22             THE ACCUSED: [Interpretation] This is a Prosecution-approved

23     document.  It's -- we do have the translation, N0301736.  Or rather, we

24     can hand it over to the Prosecution or put it on the overhead projector

25     perhaps.  It wasn't up to us to have an approved translation or not --

Page 14225

 1     and to upload the translation.

 2             MR. TIEGER:  Well, I don't want to get into a procedural wrangle.

 3     I think if we're going to use the document and it's possible to get the

 4     translation on screen, we should do so.  That's all I'm asking at the

 5     moment.

 6             JUDGE MORRISON:  Well, Mr. Tieger, that must be right.

 7                           [Trial Chamber and Registrar confer]

 8             JUDGE MORRISON:  Well, I understand it can't come up on e-court,

 9     but it could come up on the ELMO.  Is that right?

10             THE ACCUSED: [Interpretation] Then we don't need the English

11     portion of the screen.

12             JUDGE MORRISON:  Yes, can you work that way, Dr. Karadzic?  Is it

13     coming up on the ELMO?

14             THE ACCUSED: [Interpretation] Yes, that's right.  We need to

15     manipulate it a bit, but I'm sure we'll make our way.  Can we look at the

16     bottom of the page where it says Dukic expressed his gratitude but asked

17     that somebody else be elected because he was already working.  He had an

18     enterprise in Vlasenica, so he was busy with other matters.  And then we

19     can turn to the second page both in English and in Serbian.

20             MR. KARADZIC: [Interpretation]

21        Q.   Now on page 2 can you see that for his deputy, deputy of the

22     president, Rajko Dukic put forward Mr. Radomir Neskovic, as it says

23     there.  And then in paragraph 2, or point 2, Dukic stressed that the

24     Executive Board would have six commissions, for social affairs, for

25     information, they're all listed there, for agriculture, forestry, and the

Page 14226

 1     water industry, and so on and so forth.  And now at the bottom you see it

 2     says:

 3             "The members of the commission put forward so far are prominent

 4     experts in their individual fields."

 5             Do you remember that?

 6        A.   Yes.

 7        Q.   Do you remember that from the very beginning our criteria was

 8     that they be professionals occupying these posts?

 9        A.   No.  I apologise, but I have to say that the professionals were

10     in the Serbian Democratic Party.  According to this, it would appear that

11     the party did not have any professionals and that they had to find

12     professionals from outside the party.

13        Q.   All right.  We'll come back to that.

14             THE ACCUSED:  [Interpretation] But may we now turn to page 3 in

15     the Serbian and the English can stay on the screen.  That page of the

16     English was fine on the screen.  May we have the English back.

17             MR. TIEGER:  I think the document's been uploaded to e-court.  It

18     may be easier to work that way.  The Registrar is aware of that.

19             JUDGE MORRISON:  Yes, it has been.  Thank you, Mr. Tieger.

20             MR. KARADZIC: [Interpretation]

21        Q.   Now, do you agree that stress here is laid on the fact that all

22     these people and all this work must be conducted at a high professional

23     level, and then Dukic went on to say that the party president from the

24     previous year to the present day had not been remunerated for his

25     expenses during the performs of his functions and so on and so forth.  Do

Page 14227

 1     you remember that portion?

 2        A.   Yes.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] I tender this into evidence.

 5             MR. TIEGER:  No objection.

 6             JUDGE MORRISON:  That will be admitted.

 7             THE REGISTRAR:  As Exhibit D1274, Your Honours.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             MR. KARADZIC: [Interpretation]

10        Q.   In your interview with the Defence you stressed, on page 12 of

11     the Serbian version and page 11 of the English, that a problem loomed in

12     the party, the people felt tricked.  They had given a great contribution

13     to the electoral victory and then suddenly other people appeared who had

14     been in the League of Communists previously and that that's how the

15     leading positions were filled.

16             THE ACCUSED: [Interpretation] May we have 1D3487 displayed,

17     please, on e-court next.  Page 12 of the Serbian and it's 11 of the

18     English.

19             MR. KARADZIC: [Interpretation]

20        Q.   Do you agree looking at this document here that -- well, the

21     first paragraph about the disagreements and after the People's

22     Assembly -- well, do you agree that the elections in 1990 brought not

23     only a change in the regime but a change in the system of socialist self

24     management, or rather, socialist self management became a multi-party

25     democratic system; do you agree with that?

Page 14228

 1        A.   Yes.

 2        Q.   Do you agree that I was anxious and worried that the cadres of

 3     the Serbian Democratic Party -- or rather, let me ask you this first.  Do

 4     you agree that the personnel and most of the cadres of the Serbian

 5     Democratic Party had been dissidents for many years beforehand, that is

 6     to say, they were far removed from the exercise of government?

 7        A.   No.  The SDS had thousands of cadres.  It did have a number of

 8     dissidents but it also had people who had nothing to do with power and

 9     authority.  But it also had members, many members who were professionals

10     and knew how to govern.  So it was a very well-educated and professional

11     party base.

12        Q.   Thank you.  Now, do you agree that there was the danger that

13     after 40 years of suffering, the Serbian Democratic Party, or rather, its

14     membership in one way or another might wish to take its revenge on the

15     people who had ruled them for 40 years and that there could have been a

16     new division among the Serb people except that now all the democrats

17     would be the ones who would laud it, if I can put it that way, over the

18     communists?

19        A.   Well, you have two questions there.  First of all, I don't accept

20     that there would have been revanchism of the SDS over members of the

21     party who had lost power.

22             Now, your second question.  That is true, you did strive and

23     advocate the fact that the Serb people should be one whole and not be

24     divided into Chetniks and partisans within that body of people.

25        Q.   Now, do you remember, and you have it towards the bottom of the

Page 14229

 1     page, that I made a proposal immediately after the elections that an

 2     expert government be established and not a party government in order to

 3     reduce tensions which were already burgeoning in Bosnia-Herzegovina and

 4     that the other two parties did not accept that?

 5        A.   Yes, but -- you proposed the formation of an expert government,

 6     but when it came to realisation, when ministers were appointed, we saw

 7     that it nothing to do with experts in the government.  They were

 8     ministers from the list of the BH League of Communists.

 9        Q.   Thank you.  Now, do you agree that as opposed to the SDS, the SDA

10     brought to the leadership functions party people exclusively?

11        A.   Yes, and so did the HDZ and that's why the elections were held,

12     so that the party people could take over power and authority on the basis

13     of the votes.  And if power and authority were to remain with the cadres

14     of the former party, then there would have been no need for elections,

15     they would have been senseless.  So yes, they did appoint their cadres to

16     positions of power and authority, whereas the SDS did not.

17        Q.   Thank you.

18             THE ACCUSED: [Interpretation] May we have the next page, please.

19     The Serbian is 13 straddling 14, and the English is 12 straddling 13.

20             MR. KARADZIC: [Interpretation]

21        Q.   You remember correctly that the only minister of the cabinet of

22     the joint Bosnia-Herzegovina from SDS was late Velibor Ostojic; right?

23        A.   Right.

24        Q.   Thank you.  Then you stressed that I had proposed that a new

25     basic organisation be introduced, local board instead of municipal board,

Page 14230

 1     and you spoke about that today.  And in the interview you confirmed that

 2     the main organisation of the SDS was a local one and that people were

 3     directly elected by the membership.  And then representatives were

 4     delegated upwards.  Do you agree that people were elected upwards and

 5     requests were made from lower levels to upper levels?

 6        A.   For 1991 and the party elections and the electoral Assembly,

 7     that's correct; but I'm not sure about 1996.

 8             THE ACCUSED: [Interpretation] Can we see the next page, 14 in

 9     Serbian and 13 in English.

10             MR. KARADZIC: [Interpretation]

11        Q.   When my advisor asked you to what extent the SDS was organised,

12     how well it was organised and how long it took to make it fully

13     operative, you answered it took about a year and it became well defined

14     and operative on the 12th July 1991.  And then you said that it was

15     defined vertically and horizontally on an absolutely democratic basis and

16     that one could not be part of the SDS organisation without having the

17     support of a local board, except in the case of certain experts.  And

18     then you said that in democratic terms the party was defined very

19     broadly, but in 1991 it had no power or authority in the republic, it had

20     no influence on the authorities.  And then you said, "We didn't have a

21     single man in the Presidency of Bosnia at lower levels."

22             And you describe a situation where the Serbs in power are one

23     team and Serbs in SDS a different team which lasted all the way up to

24     1996.

25             I'd like to ask you:  Do you remember that in 1990, I did not run

Page 14231

 1     for a single state position and I wanted in that way to set an example

 2     for other SDS members, that they should only serve their own people, not

 3     strive for power; is that correct, that I did not run for any positions?

 4        A.   That's correct.

 5        Q.   Earlier today Mr. Tieger asked you about traitors.  Do you agree

 6     that that referred to betraying decisions that had already been made

 7     because it was a multi-party system.  It was not allowed for anyone in

 8     the SDS to carry out policies of another party and it did not apply to

 9     decision-making but only the implementations of -- implementation of

10     decisions?

11        A.   The guiding principle in the SDS was democratic centralism.

12     There was democracy in decision-making and the charting of policies, but

13     in the implementation of those policies it was centralism.  What was

14     wrong with the SDS was factions inside organisations, that was not

15     tolerated.  Any influence by other parties on the SDS was not tolerated,

16     and the leadership was to be separated from basic organisations.  That's

17     the way centralism operated and people who would depart from this would

18     be criticised and sanctioned.

19        Q.   Do you agree that the only high-ranking person expelled from the

20     SDS was late Vladimir Srebrov who wanted to turn Young Bosna, the youth

21     organisation of the SDS, into an iron fist of the SDS and the board

22     expelled him after long debates without any proposal for my part.  Do you

23     remember that?

24        A.   I believe he even became Vice-President of the SDS in Skenderija

25     and he was expelled because of his positions about Young Bosna as some

Page 14232

 1     sort of party guard that was not very well liked as an idea.  So he was

 2     expelled and another person who was expelled was Milakovic from Prijedor.

 3        Q.   Do you agree that there were no other expulsions perhaps all the

 4     way until 1996, when some members established their own parties?

 5        A.   As far as I remember, there were no expulsions because the

 6     culpability of a particular member had to be proven by his local

 7     organisation.  Nobody could be expelled without eliciting the opinion of

 8     their local organisation.  So there were no expulsions, as far as I

 9     remember, while I was a member of the SDS.

10             THE ACCUSED: [Interpretation] Can we now see page 16 in Serbian,

11     later 17, and in English that would be 15 and 16 -- sorry, 14 and 15.

12             MR. KARADZIC: [Interpretation]

13        Q.   In Serbian, towards the bottom, you say:

14             "I don't remember.  I told you --"

15             It says:

16             "I don't remember we were removed by any decision of Karadzic's,

17     but as far as the government and Presidency and the MUP, many people

18     expected to get into power after the elections, but Radovan persistently

19     avoided implicating the SDS in state authorities and he kept old staff in

20     their positions."

21             You say Mandic had nothing to do with the SDS, Draskovic.

22             THE ACCUSED: [Interpretation] Can we see the next page in

23     Serbian.  It's not the right page in English.  It should be 14 and later

24     15.  15 towards the bottom in English.

25             MR. KARADZIC: [Interpretation]

Page 14233

 1        Q.   And you keep on enumerating.  Do you recall that not a single

 2     chief of a regional centre of the MUP was a member of the SDS?

 3        A.   If I remember well, no.  In fact, it was the rule.  Former

 4     members of the League of Communists were appointed to all positions, not

 5     members of the SDS, and that continued later on during the war in

 6     Republika Srpska, the same policy.

 7        Q.   And then you answer here:

 8             "I heard that discussion while testifying in the Krajisnik case,

 9     where you said that the leadership of the SDS was one thing and the

10     leadership of the Bosnian Serbs another thing."

11             And you said these were two separate things; right?

12        A.   Yes.

13        Q.   Then on page -- Serbian page -- Zepinic officials -- and then you

14     say when Bosnia-Herzegovina broke up, when Republika Srpska was created,

15     Karadzic did not allow the SDS to exert influence on the government or to

16     appoint ministers because they would have appointed themselves, which is

17     logical.  We would have sat down and divided positions among us and we

18     would nominate ourselves as parties tend to do; right?  And I was a

19     hindrance to the complete take-over of power by the SDS.

20        A.   Yes, you implemented systematically one certain policy.  At the

21     republican level in Bosnia and Herzegovina or Republika Srpska it was

22     your policy not to allow SDS members to take executive power, and through

23     your influence you placed former members of the League of Communists in

24     those positions.

25        Q.   But do you agree that I made sure that they had left the

Page 14234

 1     League of Communists and they were nonparty personalities?

 2        A.   I don't know what your hopes were.  All I know is that the SDS

 3     never came into executive power at the republic level.

 4             THE ACCUSED: [Interpretation] Next page in English.  In Serbian I

 5     would like to see page 19 now and page 17 in English.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   My advisor asked you:

 8             "What was the relationship between Dr. Karadzic and the leading

 9     politicians in the Krajinas?"

10             And you said:

11             "It didn't work so well.  People from the Krajinas were rather

12     independent.  They were not afraid, like Kupresanin, they did not fear

13     Karadzic, they opposed him, freely criticised him and put forward their

14     own positions.  There was no submission in it.  The Krajinas displayed a

15     great political independence."

16             Do you remember that even before the elections in 1990 there was

17     a kind of competition between Banja Luka and Sarajevo, and the entire

18     Krajina had a constant chip on the shoulder that everything is being

19     given or taken over by Sarajevo and they wanted some balance restored?

20        A.   The Banja Luka region always displayed resistance to Sarajevo, be

21     it Bosniak, Serb, or Croat sources.  It always aspired to greater

22     independence and they always put forward arguments that Banja Luka, a

23     very big city, ranked 18 in terms of development.  In any case, they did

24     not like it at all that Banja Luka, such a major centre, ranked 18 in

25     terms of development.

Page 14235

 1        Q.   And do you agree that it was mainly, first and foremost, an

 2     economic issue?

 3        A.   I don't know whether it was an economic issue.  They had a strong

 4     resistance to centralism then as they have now.

 5             THE ACCUSED: [Interpretation] Can we keep page 19 in Serbian and

 6     have page 18 in English.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   My advisor asks you:

 9             "Generally speaking, did Karadzic allow you to carry on with the

10     democratic process and debates?"

11             And you say:

12             "We have to be precise.  Throughout this period, as far as party

13     relations within the party are concerned, Karadzic was a great democrat.

14     Everyone was free to debate, express their opinions, there was no

15     dictatorship, no oppression.  Everything was very democratic and free in

16     communication within the party."

17        A.   Yes, there was great democracy in decision-making and the work of

18     the Executive Board, but centralism ruled in the implementation of

19     policies already charted.  There was democracy in decision-making, but

20     centralism and hierarchy in the implementation of these decisions.

21        Q.   We can keep these pages on the screen.  You say:

22             "Within the party and debates in the Main Board, the party was

23     democratic, there was no dictatorship.  The party did not suffer from

24     authority.  For instance, the authority of Krajisnik and Biljana Plavsic

25     and Koljevic was not felt in the Main Board.  Krajisnik did not even ask

Page 14236

 1     for the floor.  He couldn't say, You know, I'm the president of the

 2     Assembly, let me tell you this and I'll go.  We couldn't care less that

 3     you are the president of the Assembly.  You are a member just as we are.

 4     So Radovan was not really burdened with authority."

 5        A.   That's right.  Krajisnik, Plavsic, and Koljevic never even took

 6     the floor at the Main Board meetings.  They were just present there and

 7     they did not play a big role in the Main Board of the SDS.

 8             THE ACCUSED: [Interpretation] 65 ter 30225 is the next document I

 9     would like to see in e-court.

10        Q.   30225 is an intercept of a conversation between you, Miskovic,

11     Srdic, and myself.  This discussion took place on 10 September 1991.  You

12     were already in your position of vice-president of the Executive Board,

13     and you were at that time obviously in the field.

14             10 September 1991, that's it.  Karadzic, Neskovic, Miskovic, and

15     Srdic from Prijedor.  We can see, and you remember, that there was a big

16     problem with the local authorities in Prijedor.  Municipal deputies from

17     the SDS became renegades from the party because they refused to work

18     along with the leadership of the SDS.  There was a man Milakovic there

19     who ended up as a criminal.

20             Do you remember there was chaos in Prijedor?

21        A.   I remember about conflicts within the municipal board in Prijedor

22     and the various factions, but I don't know about the work of the

23     deputies.

24             THE ACCUSED: [Interpretation] May we turn to the second page now,

25     please, or rather, page 2 of the Serbian and 3 of the English.

Page 14237

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Do you agree that, right up until the end, we did not succeed in

 3     dealing with the situation of the party in Prijedor and that it was

 4     terra incognita, a completely unknown situation there?

 5        A.   Well, I don't know.  But there were always two factions fighting

 6     for supremacy within the municipal board and the situation was never

 7     completely resolved.

 8             THE ACCUSED: [Interpretation] May we have page 2 of the Serbian

 9     and 3 of the English.

10             MR. KARADZIC: [Interpretation]

11        Q.   This is my reply.  I say:

12             "Please tell us.  Those who don't wish to respect party policy

13     and wage party policy but are engaged in their own private policies."

14             And you say:

15             "Yes."

16             And then on page 4 of the Serbian and 6 of the English, Karadzic

17     says:

18             "But wait a moment.  Let me tell you.  Listen to me please.  Do

19     as Neskovic has proposed, but tell the deputies that they're on our list

20     and not us on their list and they have to behave properly towards the

21     party that brought them into power and you do as follows."

22             Do you remember all that?  Do you remember that that was the

23     position we took, that the deputies that once they were elected for a

24     particular party programme and for a particular party, then it was up to

25     them to promote that programme?

Page 14238

 1             Let's now look at page 6 of the Serbian and 8 of the English.

 2             Do you agree with what I've just said?

 3        A.   Yes, the deputies should promote party policy because it was the

 4     party that elected them.  But don't forget that I put forward my own

 5     proposals, although I can't remember the details of my proposals for a

 6     solution.

 7        Q.   But you can see that I supported those proposals; right?

 8        A.   Yes, that's right.  And you were very angry and you swore a lot.

 9     You were extremely angry at Srdja and Miskovic and the situation in

10     Prijedor in general.

11        Q.   Thank you.  Now, it says on page 6 of the Serbian and 8 of the

12     English:

13             "Yes, but last time there was Srdjan and Savanovic and they

14     didn't act as we had agreed.  They did not do as we agreed."

15             And then page 8 of the Serbian and 11 of the English, Srdjo is

16     speaking and he says:

17             "I won't allow anybody to disabuse you because somebody said who

18     is Karadzic?  What does he want?  Who listens to him?  We'll do what we

19     want to do.  He can't impose his will on us.  He can go and say things

20     like that in Sarajevo," and so on.

21             Now, do you agree that this confirms that the party gave great

22     leeway and freedom to activities and that to a large extent it had been

23     decentralised in that respect?

24        A.   Well, this conflict in Prijedor surpassed and went beyond the

25     usual measures of political pluralism and democracy.  This was a clash

Page 14239

 1     between two clans and probably in the background you had personal

 2     interests, large personal interests.  So the conflict was very serious

 3     and this surpassed democracy.  It was a clash between two factions in the

 4     municipal board in Prijedor.

 5        Q.   And when it says "Who cares about Karadzic?  Let him do what he

 6     wants in Sarajevo," is that resistance towards the centre which the whole

 7     of the Krajina displayed?

 8        A.   No, it's just Srdja Srdic and his thirst for power, and he didn't

 9     want to leave his post and did everything he could to remain performing

10     the duty he performed.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] I'd like to tender this document,

13     but just as an MFI, for identification.

14             MR. TIEGER:  Well, a couple of matters.  First of all, I don't

15     think that's necessary.  I believe that's on the associated exhibited

16     list.  Secondly, when -- again, I hate to raise it again, when

17     Dr. Karadzic says "this is me speaking," I don't think it's appropriate

18     for MFI.  I think it's been authenticated and he can't present it on the

19     one hand for such and then call for an MFI process.  Also it involves

20     this witness who has simultaneously authenticated the exhibits.  For any

21     number of reasons I can't imagine that marking it for identification is

22     appropriate rather than admitting it.

23             JUDGE MORRISON:  Well, Dr. Karadzic, this does appear to be one

24     of those intercepts whose -- the authenticity and accuracy of which you

25     appear to not only accept but to put forward; is that correct?

Page 14240

 1             MR. ROBINSON:  Excuse me, Mr. President, if I could answer that.

 2     You frequently remind Dr. Karadzic that he's not giving evidence during

 3     this portion of the case.  I think we have the right to put the

 4     Prosecution to its proof with respect to the reliability of intercepts

 5     and they've chosen to delay that until some time later in the trial when

 6     they call the appropriate witnesses.  So we're not in a position -- we

 7     should be in a position where we are able to challenge the reliability of

 8     intercepts and at the same time protect ourselves in the sense that if

 9     intercepts are found to be reliable and found to be admissible, we get

10     the benefit of those which are favourable to our case.  So, otherwise we

11     would have to sit there and wait and do nothing with intercepts and then

12     call all these people back to try to use the intercepts if you decided

13     that the Prosecution has established that they are reliable and

14     admissible.  So I don't think that's a good procedure.  In this way we

15     are able to challenge the intercepts and at the same time preserve our

16     ability to have the information before the Chamber in an efficient way.

17     Thank you.

18             JUDGE MORRISON:  Mr. Tieger.

19             MR. TIEGER:  The reality is that in the end I think it won't

20     matter that -- but this -- clearly the Defence's position, that is,

21     proffering a particular document as reliable to make the point it's

22     attempting to make in examination, is a factor to be considered in its

23     admissibility and has nothing to do with whether or not Dr. Karadzic is

24     testifying.  This is what the Defence is doing by way of that particular

25     document.  This is a Defence position on it.  In any event, it's going to

Page 14241

 1     be a factor to be considered one way or another, and I think that we

 2     continue to see that these intercepts are indeed reliable.

 3                           [Trial Chamber confers]

 4             JUDGE MORRISON:  Well, Mr. Robinson, it's not a question, of

 5     course, of Dr. Karadzic giving evidence; it's a question of whether or

 6     not he accepts the authenticity of a document, which is entirely another

 7     matter.  But although it's -- it seems to me to be Delphic as far as

 8     logic is concerned, we will MFI this simply for the point of consistency.

 9     As Mr. Tieger accurately observes, at the end of the day it probably

10     won't make any difference.

11             While I'm speaking, we're sitting until 1345 today.  What I

12     propose is that we take a break now for 20 minutes, we recommence at

13     10.40, and for planning ahead, the second break at 11.45 until 12.15.

14             So we'll rise now until 10.40.

15                           --- Recess taken at 10.19 a.m.

16                           --- On resuming at 10.41 a.m.

17             JUDGE MORRISON:  Yes, Dr. Karadzic.  Thank you.

18             THE ACCUSED: [Interpretation] Thank you.

19             What has happened with the intercept?  What's its number?  What's

20     the number?  May I be given some information about that.

21             THE REGISTRAR:  Your Honours, that's MFI P2571.

22             THE ACCUSED: [Interpretation] Thank you.

23        Q.   May I have 1D3487 again, please, ID 3487, which is the Defence

24     interview with you.  1D3478 is the number.  And may we turn to page 21 of

25     the Serbian and 19 of the English.

Page 14242

 1             You say here that at the Main Board, from 1991, there was a

 2     Deputies Club which adopted attitudes and didn't have to report back to

 3     the Main Board, and then you go on to say that the party couldn't adopt

 4     positions and issue instructions to the deputies as to how they were to

 5     vote.  And given the circumstances, it was the Deputies Club which

 6     assumed all the power and authority.

 7             Now, do you agree that this was a great problem for the SDS, in

 8     view of the fact that the other parties had full control of their

 9     membership and deputies?

10        A.   I don't know whether the other parties had control over their

11     deputies.  I really can't say.  I don't know.  But what I do know is that

12     the SDS Deputies Club was a constituent organ which passed all

13     constituent acts and documents which lay the grounds for Republika Srpska

14     and that it didn't have to receive orders from the Serbian Democratic

15     Party or answer to them.  They worked autonomously.  It was a centre of

16     power in its own right.

17        Q.   Thank you.  Now, if I put it to you that in the Western

18     democracies parties have a deputy or a whip, if I can put it that way,

19     following the work of the deputies to see whether they're acting in line

20     with party policies, did the SDS have this whip given to them by God, so

21     to speak, in the Assembly and otherwise in Republika Srpska?

22        A.   No.  But I have to say that the Deputies Club of the SDS was not

23     an ordinary Deputies Club.  It made up the Assembly of the Serbian people

24     in Bosnia-Herzegovina, it passed constituent documents.  So the party

25     didn't have this whip ordained by God or anything like that.

Page 14243

 1        Q.   Thank you.  Now, I'm sure you know the famous proverb about our

 2     lack of co-operation which says:  You have two Serbs and three parties.

 3     Do you agree that in Republika Srpska these deputies that came from the

 4     SDS, 72 from the SDS, and the rest from the reformist parties, the

 5     communists, and so on, that they behaved as if they represented

 6     83 parties and not one; that is to say that they were completely

 7     independent and autonomous in the decision-making process and very often

 8     stood up to -- very often the SDS deputies would oppose each other?

 9        A.   No, they did oppose certain opinions and say what they thought

10     with respect to policy, but it's a constitutional act to pass documents

11     and the SDS deputies were unanimous when documents and acts were passed.

12     They exercised consensus and they had another one from the -- 73 from the

13     SPO and the other deputies from the Assembly who came from other parties,

14     they had different -- took different positions and later on formed their

15     independent Deputies Club within the Serbian Assembly.

16        Q.   Thank you.  May we now turn to page 26 of the Serbian which is

17     24 of the English of this same document.

18             You say here that the SDS -- that the role of the SDS was

19     strengthened when it came to organising a plebiscite because the deputies

20     could not organise a plebiscite without the SDS, of course.  Have you

21     found that passage?  And the party played a major role in organising the

22     plebiscite and then its role after the plebiscite went downhill again,

23     whereas the SDS Deputies Club took on a central role once again, a

24     central role as a central political body or body for political decisions.

25             Do you agree that the party transferred all its power and

Page 14244

 1     authority to its representatives in the state organs?

 2        A.   The party didn't do this.  It was the state organs who

 3     transferred the power.  They did not -- they were not duty-bound to

 4     report back to the Serbian Democratic Party at all.  The Serbian

 5     Democratic Party would not have transferred this to the executive organs

 6     in the positions of power.

 7        Q.   So people from the party were angry at me because of that in a

 8     way, weren't they?

 9        A.   Yes.

10        Q.   Thank you.

11             THE ACCUSED: [Interpretation] May we now have 29 of the Serbian

12     and 27 of the English displayed, please.

13             MR. KARADZIC: [Interpretation]

14        Q.   You say here, and we'll find it, Karadzic said, I think, in one

15     of his speeches that decisions were being made at the Deputies Club.  He

16     appointed all sorts of experts there without any connections with the SDS

17     so the SDS began to fade away, stop all its activities.  And then came

18     the shocking decision of the government of the Serbian Bosnia-Herzegovina

19     led by Djeric -- it should be with an R, Djeric.  Do you agree,

20     Branko Djeric; right?

21        A.   Yes, the first prime minister.

22        Q.   Anyway, the SDS in July 1992, or rather, June 1992, in a special

23     way was banned.  The decision banned all political organisations and

24     their activities, but being the only one, the only party, the SDS was

25     banned.  And that's how it was banned and this caused a further rift in

Page 14245

 1     the SDS.

 2             Do you agree that the government of Republika Srpska under the

 3     leadership of Professor Djeric was completely independent and autonomous

 4     in its work and that this came at its proposal without having the party

 5     interfere in its work?

 6        A.   I don't think so.  The government exceeded its authority on this

 7     point.  It banned the political organisation from operating one which was

 8     in power and which had formed the government in question, and this was

 9     unheard of in politics, that the government which was formed on the basis

10     of a political party should ban that political party from operating.  And

11     I think that the government overstepped its authority on this point and

12     had no right to ban the political party that was in power from operating.

13        Q.   Do you agree that, at that point, in order to alleviate the

14     situation I issued an order that the operation of the SDS should not be

15     banned but rather put on ice?

16        A.   No.  They would never have agreed to something like that.  We

17     were banned from operating by the government in a perfidious way, and the

18     order applied to all political organisations and banning all political

19     organisations from operating but there was just us.  The government

20     overstepped its authority on this point.

21        Q.   Thank you.  Do you agree that until such time as the SDS was

22     reactivated in February 1994, a couple of parties were set up, such as

23     the socialist party, the radical party, et cetera?

24        A.   The Serbian radicals of Vojislav Seselj were set up.  The

25     socialist party, as a branch of Slobodan Milosevic's party, was set up as

Page 14246

 1     well.  We regarded as -- not as a contribution to the multi-party system,

 2     but rather as an attempt at reinforcing those parties which had their

 3     head offices in Belgrade while undermining the influence of the party in

 4     power.  That was my understanding of it.

 5             So yes, these two parties were formed during the war which makes

 6     the entire situation contradictory.  On the one hand, the government

 7     banned the ruling political party from operating whilst, on the other

 8     hand, allowing parties from Belgrade, such as the radicals and

 9     socialists, to set up their local branches over here.  So I understood it

10     as a policy directed against the SDS.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can we now have 22217, a 65 ter

13     document, which is the transcript from the Krajisnik case.  In e-court

14     it's page 166.  So page 166 in e-court of 65 ter 22217.  Can it be

15     enlarged?

16             MR. KARADZIC: [Interpretation]

17        Q.   I will read out your answer from, say, line 7:

18             [In English] "It depended on the people in leadership positions

19     in the municipalities; some had a tendency to act for independently.  In

20     the case of the Municipal Board of Banja Luka, that board did not really

21     feel it had to respect party discipline.  There were other such Municipal

22     Boards ... but the party structure prescribed in the statute was somewhat

23     disturbed by the unlimited possibility that representatives of

24     Municipal Boards had to go and see Mr. Karadzic, to speak to him in

25     person ... Karadzic might tacitly authorise them to act in a different

Page 14247

 1     way ..." and so on.

 2             [Interpretation] Do you agree -- do you recall the jokes Branko

 3     told me the other day without saying that it was Branko Mikulic, in fact.

 4     Do you agree there was a possibility for manipulations, that people would

 5     present themselves as having received the backing of a prominent

 6     personality without it, in fact, being so?

 7        A.   Well, I'm not aware of a specific case, but I do accept that

 8     there could have been instances where people tried to manipulate

 9     situations in this way.

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

11     65 ter 30481, 30481, page 2.

12             MR. KARADZIC: [Interpretation]

13        Q.   This is an intercept, page 2, is that right?  It's a conversation

14     between myself and Ante Jovanovic, who says:

15             "Believe me when I tell you that I wrote and we have made an

16     agreement with the personnel of ours from the MUP.  I'm short of

17     22 policemen of Serbian nationality and they need to be transferred to

18     me.  And now, for instance, I'm telling them that constantly, If you come

19     tomorrow I won't have a police force, I won't have a police force, and

20     they haven't helped me at all.  And I say, Well, don't mention that to me

21     anymore.  I don't know whether they will come or not ..." et cetera.

22             He goes on to say:

23             "Well, it's not about that.  I mentioned you because I wanted

24     them to provide me with a police force."

25             Will you agree with me that this is one of the instances where

Page 14248

 1     Mr. Jovanovic is trying to achieve something for his own purposes by

 2     referring to my name as an authority in the case?

 3        A.   Well, I don't know anything about this.  Let me tell you that the

 4     MUP itself was far removed from the party.  Except for Mico Stanisic who

 5     was a member of the party, there were mostly non-party individuals

 6     working there.

 7             THE ACCUSED: [Interpretation] Can we go back to 1D3487, 1D3487,

 8     page 50/51 in Serbian and 47 in English.

 9             MR. KARADZIC: [Interpretation]

10        Q.   My advisor asks you as follows:

11             "Since the Prosecution also seem to insist that the SDS is one

12     and the same thing with Republika Srpska, what is your comment on that?"

13             You say:

14             "It's not the same thing."

15             What do you have to say about this, that the SDS was removed from

16     the government?

17        A.   Well, let me tell you that at the level of the executive branch

18     on the local regional level, and even later on on the national level, the

19     SDS was not part of the government and SDS does not equal the executive

20     government.  As for the municipalities themselves, well, that's not the

21     same thing.  The SDS did participate in the power-sharing with the SDA

22     and HDZ after the elections.  So the situations on the local and regional

23     levels differed greatly.

24        Q.   Thank you.

25             THE ACCUSED: [Interpretation] Can we have the next page in both

Page 14249

 1     Serbian and English.  We can keep the English page.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   At the top of the page you say in this interview:

 4             "The situation with the government and the SDS that I still am at

 5     a loss to understand persists to this day.  Not a single government,

 6     Djeric's, Lukic's, Kozic's," I suppose you will agree with me that it's

 7     Kozic and not Kojic, "was ever proposed to the Main and the

 8     Executive Boards and personnel affairs, nor did anybody ever ask these

 9     organs about anything.  The SDS could not even be in the government in

10     Pale ..."

11             And that's what you said; is it right?

12        A.   Yes.

13        Q.   You were then asked:

14             "Was it not the case that the SDS operated through the Assembly

15     of Republika Srpska?  Who was in that Assembly?"

16             And you say:

17             "Well, the Assembly is just one body where indeed there were

18     SDS deputies."

19             Can we turn to the next page in English, please.

20             "However, the SDS did not issue any orders to them and they

21     constituted a centre of power in its own right which acted autonomously."

22             In your next answer you say that they were an autonomous centre

23     and 98 per cent of them were appointed by the SDS but they did not answer

24     to the SDS at all.  They were completely out of SDS's control.

25             Therefore, this confirms that the deputies operated autonomously.

Page 14250

 1     They were not controlled by the party and were able to act upon their own

 2     conscience.

 3        A.   Well, the way I see the Assembly is the -- the SDS is the

 4     constituent party representing the Serbian people who laid the grounds

 5     for Republika Srpska.  So they -- the deputies of the SDS were an

 6     authority in their own right, and when it came to passing these basic

 7     decisions, they acted unanimously.

 8        Q.   I have to correct, the transcript should read:  "Well, yes,"

 9     because you said, "Well, yes, the way I see ..." et cetera.  Do you agree

10     with me that you said "Well, yes"?

11        A.   Well, I said that the deputies were independent, they were an

12     autonomous constituent body of the Serbian movement and did not take

13     orders from the SDS.  They were unanimous to a high degree.  Yes, they

14     did not receive orders from the SDS.

15             THE ACCUSED: [Interpretation] Can we go back to the 65 ter 22217,

16     page 16 in e-court, the transcript we looked at before.

17             MR. KARADZIC: [Interpretation]

18        Q.   From line 2 your answer:

19             [In English] "At the top of the party, President Karadzic, who

20     pursued his policies, tried to ensure that legal principles were followed

21     in the broad party organs when he took decisions, so he tried to act at

22     the top, but a lot of initiatives were taken at the municipal level."

23             [Interpretation] And then line 8:

24             [In English] "There was a lot of democracy until a decision was

25     taken, and when a decision was taken, then the usual party hierarchy was

Page 14251

 1     implemented."

 2             [Interpretation] Line 13:

 3             [In English] "So I would call this a principle of democratic

 4     centralism."

 5             [Interpretation] This is what you stated in the trial against

 6     Mr. Krajisnik.  Was that your position and was that the case at the time?

 7        A.   Yes.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can we have page 151 of the same

10     document.

11             MR. TIEGER:  And, Your Honour, to the extent possible, may I

12     suggest for clarity of the record and ease of reference that 65 ter 22217

13     and other -- be referred to as P2568 which is the exhibit number it now

14     bears.  And to the extent we can do that for other exhibits that had been

15     admitted, I think that would be to everyone's benefit.

16             JUDGE MORRISON:  That seems to be logical.

17             THE ACCUSED: [Interpretation] Thank you.  We will proceed that

18     way.

19             MR. KARADZIC: [Interpretation]

20        Q.   In line 10 you say:

21             [In English] "Between March 1991 and the 31st of July, 1991, I

22     would have had to visit at least something in the range of between 25 or

23     30 municipalities."

24             [Interpretation] And then at page 152, page 152, line 20:

25             [In English] "No.  Up until the 31st of July, it had to do with

Page 14252

 1     the pre-electoral activities within municipal organisations, electoral

 2     matters.  After the 31st of July, we were talking about other activities,

 3     routine work of Municipal Boards and their functioning and overcoming

 4     problems and disagreements between fractions within those Municipal

 5     Boards."

 6             [Interpretation] And another passage on page 161, please, from

 7     line 13.

 8             [In English] "When you made your visits to the municipalities, as

 9     you've described, in 1991, you were not carrying to the municipality

10     instructions from the leadership of the SDS, were you?"

11             [Interpretation] Answer:

12             [In English] "I wasn't carrying any particular kind of

13     instructions.  The statute was quite sufficient for me, the statute that

14     was in force.  To be frank, I acted in a fairly independent manner.  It

15     was possible for me to decide on how to deal with certain problems; I

16     could do this in an independent manner.  But I had not been issued any

17     precise tasks."

18             [Interpretation] Do you agree that you stated this, namely, that

19     basically it worked that way, the statute was the fundamental document

20     that was acted upon, and you had great liberty in finding ways to apply

21     the statute?

22        A.   Yes, the statute was the fundamental document binding upon

23     everyone.  In view of the fact that the statute introduced a novelty,

24     that the local board was the basic organisation, diminishing the

25     influence of municipal authorities, the municipalities reacted by

Page 14253

 1     disapproval because they were no longer the basic organisation.  Yes, I

 2     did act in this way and my role was mainly the role of a mediator based

 3     on the current statute.

 4        Q.   Do you agree that there could have been no greater

 5     decentralisation of the party than by identifying the local board as the

 6     main organisation in the socio-political community?

 7        A.   No, I don't think this is about decentralisation.  This is an

 8     original concept of organising party politics, where the basic organ of

 9     the party is the one that is the closest to the grass roots, because the

10     Serbian Democratic Party was organised as a centralised party in terms of

11     organisation without the middle regional level.  There was no regional

12     level.  So all the party activity took place between the local board and

13     the highest level.  The activity developed up the chain, that's how it

14     was organised.

15        Q.   I would now like to move to another subject, the subject of

16     regionalisation, to the extent that you knew about it.

17             THE ACCUSED: [Interpretation] P2568 is the document I would like

18     to call up.  I'm sorry, that's the interview.  I'm calling 1D3487,

19     1D3487.

20             MR. KARADZIC: [Interpretation]

21        Q.   That's your interview with the Defence.  Here you answer, when

22     you say at the Main Board you have to say at which session, and so on and

23     so forth.  And then you say:

24             "The idea of regionalisation originated in Banja Luka.  The

25     people who advocated the Autonomous Region of Krajina were the ones who

Page 14254

 1     came up with the idea of regionalisation, and that's the only region

 2     which was in fact established.  All the other regions existed only on

 3     paper.  They just proclaimed their regions and nothing else.  That means

 4     you can't lump them all together."

 5             I'd like to ask you this about regionalisation.  Even before the

 6     elections and forever in Bosnia-Herzegovina, was the regional

 7     distribution often criticised but all the critique came mainly from the

 8     Krajina?

 9        A.   I'm afraid I didn't quite understand the question.  But as far as

10     Bosnia and Herzegovina as a federal unit was concerned, it had strong

11     institutions at the level of Bosnia and Herzegovina and it had a strong

12     position in municipalities so that municipalities had their own

13     Assemblies.  The house of municipalities and deputies were elected from

14     these Assemblies.  There was a strong position of municipalities but no

15     regions, no middle level.

16        Q.   That's the situation we found in place when we won the elections,

17     the council of municipalities and the citizens' council in the Assembly

18     of Bosnia and Herzegovina?

19        A.   Yes.

20        Q.   Do you agree that demands for regionalisation were very old, much

21     older than the SDS?

22        A.   I think it would be more correct to say that demands for

23     regionalisation were much older than the regionalisation itself.  The

24     regionalisation occurred later.  The first stage was decentralisation in

25     the authorities of Bosnia-Herzegovina.

Page 14255

 1             THE ACCUSED: [Interpretation] Can we now see page 15 in

 2     Serbian -- sorry, this was page 9 in Serbian and page 8 in English.  We

 3     did not show them.  They accompanied this first answer.

 4             Now I'd like page 15 in Serbian and page 14 in English.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You speak about the organisation, this is your first answer on

 7     this page.  You say:

 8             "Regionalisation was an official topic between Karadzic,

 9     Izetbegovic, and Kljuic, it was no secret, no taboo, it was much

10     discussed."

11             And a bit further down:

12             "Alija insisted on the independence of Bosnia and Herzegovina

13     while we were against.  And on the other hand, Serbs insisted the Bosnia

14     and Herzegovina be decentralised."

15             And yet further down:

16             There was the regionalisation that created municipalities in the

17     Bosnian Krajina.  The SDS created Bosnian Krajina.  The reason why the

18     first region came into being is that, in summer 1991 or earlier, the war

19     began in Croatia, so people were mobilised there and went to war in

20     Croatia, whereas the war was not felt in Sarajevo.  Here the war

21     atmosphere prevailed much earlier and representatives of the

22     municipalities, Serbs, created the Autonomous Region of Krajina without

23     asking for anyone's permission, Karadzic's or Kljuic's.  And then because

24     of the war in Croatia, this region already had its legislative

25     authorities, the budget, the army, the police, et cetera.  Following the

Page 14256

 1     example, other regions started proclaiming their own regions, north

 2     Bosnia, Majevica, et cetera, but they remained regions only on paper.

 3     They were never institutionalised; correct?

 4        A.   Yes.

 5             THE ACCUSED: [Interpretation] Can we now see 65 ter 18561 in

 6     e-court.

 7             The 2nd Session of the Executive Board of the Serbian Democratic

 8     Party which you attended.  It says Dukic was president of the

 9     Executive Board, Draskovic vice-president.  I attended, Buha, Dutina,

10     Ilic, et cetera.  It's English page 2, listing the people present.

11             Can we now go to Serbian page 4, English page 5.

12             MR. KARADZIC: [Interpretation]

13        Q.   Item 6, it was ascertained that the platform, meaning the

14     platform on independence; right?

15        A.   No.  I think it was the platform on the position of Bosnia and

16     Herzegovina in Yugoslavia dated -- no, sorry.  I don't know which

17     platform it was.  I thought it was the one of 14 October.

18        Q.   Yes, it was finalised on the 14th of October, but it was always

19     the case that platforms had to be ratified by the Assembly?

20        A.   I don't know really.  I never attended sessions of the Assembly.

21     This is probably about a platform that was being prepared for enactment,

22     but I'm not sure which specific platform is meant here.

23        Q.   I have to slow down for the interpreters.  Item 6:

24             "It was ascertained that the platform, constitution, and

25     referendum were unacceptable because they were, in fact, three very

Page 14257

 1     cunningly calculated blows to the Serbian people.  We are emphatically

 2     against any imposition of solutions because there are solutions

 3     acceptable to all peoples in Bosnia and Herzegovina."

 4             And then item 8, English page 6, it says:

 5             "It was pointed out that the inter-party agreement on the

 6     implementation of personnel policy was not being carried out, especially

 7     in the MUP but also in other organs of state administration."

 8             THE ACCUSED: [Interpretation] Can we see the next page in

 9     Serbian.

10             MR. KARADZIC: [Interpretation]

11        Q.   "Energetic work must be done in this area because the functioning

12     of certain state organs and services in Bosnia and Herzegovina has been

13     compromised."

14             Do you remember that the Serbian Democratic Party had to fight

15     for the positions that belonged to it according to the inter-party

16     agreement, but the implementation of that agreement was sabotaged and the

17     other two partners marginalised the SDS?

18        A.   As I've already said, the SDS was removed from personnel policy.

19     From the very beginning, it did not make any decisions about personnel.

20     Personnel policy was charted outside the Main Board.  I believe you did

21     the main work on that together with Rajko Dukic.  Now, what you agreed

22     with the SDA and the HDZ, which positions you had agreed upon, I don't

23     know.  In any case, personnel policy was not dealt with by the

24     Executive Board so I don't have any information about the agreements

25     between you, Kljujic, and Izetbegovic.

Page 14258

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] May this be received?

 3             MR. TIEGER:  No objection, Your Honour.

 4             JUDGE MORRISON:  Yes, that can be admitted.

 5             THE REGISTRAR:  As Exhibit D1275, Your Honours.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Can we now see 1D3487 again, the interview, page 18 Serbian,

 8     16 in English.  Let's just wait for the English.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Towards the top, my advisor asks you about the establishment of

11     the Autonomous Region of Krajina.

12             "At that time Karadzic was just president of the party, but how

13     did Karadzic and the leadership of the SDS view the establishment of the

14     Autonomous Region of Krajina?"

15             And you answer:

16             "There was no unanimous position ..." and a bit further down you

17     say:

18             "... but personally, I saw it as an exertion of influence on the

19     institutions of Bosnia and Herzegovina, pressure on Muslims and Croats to

20     accept the regionalisation as a precondition for the Serbs to accept some

21     sort of confederation."

22             Do you agree that in the end it all resulted in our acceptance

23     that Bosnia could be independent, on the condition that it be

24     restructured from inside?

25        A.   I'm not sure I understood, but I'll try to clarify this.

Page 14259

 1     Throughout 1991, the interest, the main interest of the Serbs was to

 2     remain within Yugoslavia.  The Serbs did not accept an independent Bosnia

 3     and Herzegovina.  As for this regionalisation, it took three different

 4     forms.  One was the regionalisation that you negotiated with Izetbegovic;

 5     the second, the regionalisation implemented by Krajina and other regions;

 6     and the third was the one done by the Assembly of the Serbian people in

 7     Bosnia and Herzegovina.  Thus, the Serbs, and you in the leadership,

 8     refused the option of an independent Bosnia and Herzegovina all the way

 9     up to that autumn.  But after the peace conference on Yugoslavia and the

10     Badinter Commission, when it became clear that Yugoslavia was breaking

11     up, you accepted that Bosnia become independent, on the condition that it

12     be transformed and decentralised in some form.  Now, which form, it was

13     not quite clear.

14             That's how I saw these events, and I have to stress also that

15     with Izetbegovic, sometime after October 1991, you had intensive

16     negotiations about resolving the political crisis.  But from October

17     onwards there was all-out conflict between the three parties and every

18     party went its own way.  So the conflict between the leaders of the

19     parties dates back to October.  We can say that the leadership of the

20     Serbs in Bosnia-Herzegovina sometime in end 1991/early 1992 was prepared

21     to accept the independence of Bosnia and Herzegovina, but only on the

22     condition that its internal structure be changed, decentralised,

23     federalised, or something to that effect.

24        Q.   Thank you.

25             THE ACCUSED: [Interpretation] Now, staying with that document,

Page 14260

 1     may we have page 27 of the Serbian and 25 of the English.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   In response to a question of whether you, as member of the

 4     Main Board or the Executive Board, ever learnt of some plan for part of

 5     Serb territory in Bosnia-Herzegovina to be separated, cut off, your

 6     answer was no.  Is that your answer today, secede a part of

 7     Bosnia-Herzegovina, your answer was no?

 8        A.   I can just give a yes or no answer.  But what -- or, rather, I

 9     cannot.  But the Serb position was that we are going to stay within the

10     remaining state, same state, which was Yugoslavia, and the territories

11     where we are in the majority we will keep within Yugoslavia.  Now those

12     who wish to secede from Yugoslavia, the Bosniaks and Croats, that is, can

13     secede but without taking away our territories.  And in that way, we

14     wanted to shift the responsibility for the crisis onto the Bosniaks and

15     Croats in this way, which is to say we support the existing state and

16     remain within that state.  Anybody wishing to secede from that state, let

17     them go, and this kind of policy was legitimate up until the Badinter

18     Commission, which interpreted the fact that Yugoslavia was in

19     dissolution, that it no longer existed and so on.  Otherwise, the Serb

20     question in Bosnia and Herzegovina was -- well, the Yugoslav question was

21     dominant rather than Serb question, less energy was invested to reach an

22     agreement with the other two nations about their own position within

23     Bosnia-Herzegovina.  And then we faced a wall at the beginning of 1992,

24     when Yugoslavia left us hanging and created the Federal Republic of

25     Yugoslavia, defined its western borders, and the Serbs from Croatia and

Page 14261

 1     Bosnia-Herzegovina were left outside that territory.  Unfortunately, we

 2     in Bosnia-Herzegovina were more Yugoslavs than the leadership of

 3     Yugoslavia.  We strove for Yugoslavia more than Yugoslavia's leadership

 4     did.

 5             So all I want to say is that there was this necessary change of

 6     circumstance.  One is the interpretation given by the Badinter

 7     Commission.  Reality was different after the interpretation provided by

 8     the Badinter Commission.

 9        Q.   Thank you.  Now, do you agree that with the existence of

10     Yugoslavia all the Serbs and Croats and Muslims lived in a single state?

11        A.   Yes.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] May we now have page 29 of the

14     Serbian and 27 of the English, staying with that same document.  Page 27,

15     please, and then we'll be moving on to page 28.

16             MR. KARADZIC: [Interpretation]

17        Q.   You were asked here about a meeting held on the 19th of December

18     at the Holiday Inn hotel, and you said that yes, you attended the

19     meeting.  And then what was the meeting about was the next question and

20     your answer was:

21             "I don't know ..." et cetera.  There were members of the

22     Main Board, the Executive Board, deputies, municipal leaders, various

23     others -- other people, chauffeurs, escorts, there were more than

24     200 people.  Let's say there were 45 people in the Main Board, 15 or

25     16 in the Executive Board, and so on.  So there was no particular agenda

Page 14262

 1     and what was to be discussed was the situation in general and the

 2     overall -- and overall Serbian documents, the plebiscite, Yugoslavia,

 3     Bosnia, and the Muslim documents, those of Krajina, and so on.  There was

 4     no agenda, no particular agenda.

 5             Now, do you remember that on the 19th of December, the government

 6     of Bosnia-Herzegovina unauthorised, without an Assembly decision and

 7     without convening the Assembly, asked the European community to recognise

 8     the independence of Bosnia-Herzegovina and that in those dramatic moments

 9     this meeting was convened.  That is the backdrop?

10        A.   I know that the BH government did make that request, but I don't

11     know that it was this particular date and I don't know that this meeting

12     was convened because of that.

13        Q.   Thank you.  Let's stay with page 28 of the English, and may I

14     have page 30 in the Serbian displayed, please.

15             You described at one point in the interview the way in which

16     decisions were taken and documents made of the Serbian document -- SDS,

17     that they were prepared by these experts, that there was an extensive

18     discussion, the decision would be adopted, it would receive a number, a

19     stamp, a signature, and would come out with -- as an official document

20     with a reference number and everything else.  Is that how the SDS passed

21     its documents?

22        A.   Yes.  It was very serious.  There was a separate legal

23     commission - I think I was a member of it - and all the documents were

24     written and passed in a very serious manner with all the attending

25     procedure.

Page 14263

 1        Q.   Thank you.  We're now talking about this Variant A and B, the

 2     document that was distributed at the meeting and you say:

 3             "However, what is debatable in the document is that it says

 4     'Crisis Staff of the SDS,' which is incorrect because the Crisis Staff of

 5     the SDS and Main Board never existed.  At least I never knew of it as a

 6     legal organ.  I attended I think 99 per cent of the Main and the

 7     Executive Board.  The Crisis Staff never existed."

 8             And then a little further down you go on to say:

 9             "The document never got into the SDS organs nor was it filed

10     anywhere.  It wasn't discussed neither as a draft or as a thesis,

11     nothing.  It just appeared just like that, out of the blue.  Radovan

12     brought it with him."

13             And then still further down you go on to say:

14             "He was sitting at the corner of the desk and handing it out to

15     people to read and return, but he didn't say, 'This is an order, you have

16     to do this.'  There were quite a few contradictions.  The document said

17     strictly confidential, or some sort of secret, and yet it was distributed

18     amongst 200 people.  It said that the SDS had prepared the document.  It

19     wasn't prepared, in fact, by the SDS.  It also said that the Crisis Staff

20     was established but the Crisis Staff or a Crisis Staff didn't exist."

21             Now let's look at how you describe the way in which -- the way in

22     which SDS documents were prepared, staying with that page -- or rather,

23     we've already established that.  You said that it was done in a very

24     serious, highly responsible way.  And it says here in the SDS -- so

25     anyway, do you agree with what you said about the structuring and

Page 14264

 1     formation of SDS documents, and that this document, A and B, was -- did

 2     in no way correspond to that serious procedure and was not engendered in

 3     the SDS?

 4        A.   The A and B document is a contradictory document in all its

 5     details and elements.  What I know about it is that it wasn't written in

 6     the SDS, in the legal commission or the Executive Board or Main Board.

 7     The Main Board and Executive Boards of the SDS did not pass it as one of

 8     their documents and the Crisis Staff of the SDS -- well, I don't know

 9     that it ever existed.  I don't think it did.  And it's not a document

10     which came into being along regular procedure practiced by the SDS party.

11     It came into being in a fashion in which I'm not aware of, and you

12     promoted it -- and elsewhere, and you promoted it in December or made it

13     public at that meeting.

14        Q.   Thank you.

15             THE ACCUSED: [Interpretation] May we now turn to page 31 in

16     Serbian and 29 in English, please.

17             MR. KARADZIC: [Interpretation]

18        Q.   And this is what it says:

19             "I later learnt a secret document -- but this B, I wasn't clear

20     on what that was.  The B -- that B wasn't clear to me.  It said that when

21     you were a minority, when you were threatened, when your physical

22     survival was threatened, you had the right to oppose and even use arms to

23     protect the lives of the group, and I didn't understand what the need was

24     for emergency acting in a situation where a majority in the

25     municipality -- when any decision could be adopted in a regular procedure

Page 14265

 1     or an emergency procedure."

 2             Now, does this indicate the fact that somebody proposed this to

 3     the Serbian Democratic Party, somebody who was not a member of the

 4     Serbian Democratic Party?

 5        A.   Well, I think that the document is quite incorrect.  Now, if

 6     somebody put forward a document, then they should have written "proposal"

 7     and signed the document proposed by whom, so that then the SDS could

 8     discuss the document.  We have here the erroneous writing of the

 9     Crisis Staff of the SDS and strictly confidential.  We have a series of

10     contradictory elements and details precisely stipulated, but we don't

11     have the writer of the document or the group of people who wrote the

12     document, which I consider to be completely erroneous procedure.  If

13     something is proposed, you have to write "proposal" and you have to say

14     who is tabling the proposal.

15        Q.   Thank you.  Do you remember that already in December -- or

16     rather, let me put it this way.  Do you remember that at the beginning

17     the JNA and the pensioned officers as old-time communist cadres, that

18     they were very wary of the SDS, the SDA, and HDZ as national parties,

19     they didn't approve of them?

20        A.   As far as I know, they viewed the HDZ as being enemies, hostile,

21     because there was the conflict with Croatia.  The SDA was viewed as an

22     enemy and they viewed the SDS as a necessary evil, a party that they were

23     opposed to, but since there was no other party then it was a necessary

24     evil, so to speak.  And as we can see from the document, we don't have

25     the interest of the Serbs in Bosnia-Herzegovina dominate here.  What

Page 14266

 1     dominated was Yugoslavia's -- the interests of Yugoslavia, and including

 2     the overall Serb component in preserving Yugoslavia as a state.  And in

 3     fact, Serb interests have been equated to the Yugoslav interest here

 4     quite erroneously.  So if the Yugoslav interest has been jeopardised,

 5     then automatically the Serb interest was jeopardised in BH, which was

 6     quite incorrect.

 7             So the writers of this document see the interests of the JNA and

 8     Yugoslavia as their focal point, and the Serbs -- they're just using the

 9     Serbs here as a means to realise that end.  I don't understand this

10     document as being in the Serb interest.  I understand it as being in the

11     Yugoslav interest and put forward in a very incorrect way, quite wrongly

12     so.

13        Q.   Thank you.  --

14             JUDGE MORRISON:  Dr. Karadzic, we're going to take the second

15     break now.  Thank you.  And we'll resume again at 12.15.

16             THE ACCUSED: [Interpretation] The witness said that it was

17     anonymously distributed, and therefore incorrect.

18             THE WITNESS: [Interpretation] I said anonymously written, quite,

19     yes.

20             JUDGE MORRISON:  Thank you.

21                           --- Recess taken at 11.45 a.m.

22                           --- On resuming at 12.16 p.m.

23             JUDGE MORRISON:  Yes, Dr. Karadzic.

24             THE ACCUSED:  Thank you.

25             MR. KARADZIC: [Interpretation]

Page 14267

 1        Q.   In this answer you indicated that this A/B variant is much

 2     clearer now because this was a minority that could be threatened and

 3     activities in circumstances of being under threat.

 4             THE ACCUSED: [Interpretation] I would now like to call up in

 5     e-court 65 ter 16731, 16731.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   This is an excerpt from minutes of a meeting of the local boards

 8     of the municipality of Novo Sarajevo.  This is your region; right?

 9             THE ACCUSED: [Interpretation] Can we look at page 2 now, please.

10             MR. KARADZIC: [Interpretation]

11        Q.   And we can look at the second paragraph which states:

12             "It is a fact that many members of the Municipal Board have

13     fallen into the embrace of the government and that they are serving the

14     government.  We know very well that the formation of the Crisis Staff in

15     these difficult times was done with the best of intentions and with the

16     aim of safe-guarding the interests of the Serbian people."

17             Do you agree that the Crisis Staffs on the Serb side were

18     established only in February or March or April 1992 while the Muslim side

19     had Crisis Staffs practically throughout the whole of 1991?

20        A.   I don't know.  I know of the Crisis Staff in Novo Sarajevo.  That

21     is what I am familiar with.  I don't know when the others formed their

22     Crisis Staffs.

23        Q.   Do you agree that the purpose of the Crisis Staff was exclusively

24     the protection of the people?

25        A.   Well, I don't think that we could take it like that because if

Page 14268

 1     protection of the people depended on some Crisis Staff or other, then

 2     that -- people would have a very difficult time of it.  I don't think so.

 3     I think that the position of the Serbian people in Bosnia-Herzegovina

 4     depended on the decisions of the Assembly, the Serbian Assembly of

 5     Bosnia-Herzegovina, and its actions, that these were the constituent

 6     acts, not those of the Crisis Staff.

 7        Q.   Thank you.  But it states here at this meeting of your local

 8     boards that the forming of the Crisis Staff was done with the best of

 9     intentions and with the aim of safe-guarding the interests of the Serbian

10     people -- well, perhaps this would be a better question.  Do you

11     differentiate between a party Crisis Staff and a municipal party --

12     Crisis Staff, a Crisis Staff of a party as an informative body which

13     reports back on political positions and the municipal Crisis Staff as an

14     institution of the local government?

15        A.   The party Crisis Staff of the -- of Novo Sarajevo is something

16     that I don't know much about.  I know about the municipal staff, but that

17     staff included cadres from the party.  This one specific here is the one

18     in Vrace and I think that the background for this meeting was quite

19     different, which was not actually stated in the minutes.

20        Q.   Thank you.  But do you agree that the first idea was for the

21     Crisis Staff to serve the people in organising their defence?

22        A.   I think that the participants at the meeting were not thinking

23     about the Crisis Staff.  There was a struggle for power between the two

24     factions in the Novo Sarajevo municipality.  And in the Crisis Staff one

25     side criticised the other, that it wasn't working enough on the formation

Page 14269

 1     of the Crisis Staff, it wasn't working enough on the protection of the

 2     Serbian people, it wasn't active enough in the plebiscite.  So these

 3     questions or issues served as a pretext for one faction to settle

 4     accounts with another in the Crisis Staff.  So I think this is the

 5     background for this meeting.  It is something that would continue and

 6     culminate in late February.

 7        Q.   Thank you.  And this was not a rare occurrence, it was not

 8     something that happened only in this municipality, it happened in other

 9     places as well, didn't it?

10        A.   Well, I can only speak of the municipalities where I did go.

11     There were instances of a struggle for power, especially in rich

12     populated municipalities where power was important.  So within the boards

13     there was a struggle for power.  Here, as far as I know, there was a

14     struggle for power exclusively between Serbs who were in power and those

15     who were not in elected bodies in the municipality of Novo Sarajevo.

16        Q.   Thank you.

17             THE ACCUSED: [Interpretation] Can we tender this -- we would like

18     to tender this, please.

19             MR. TIEGER:  No objection.

20             JUDGE MORRISON:  That can be admitted.

21             THE REGISTRAR:  As Exhibit D1276, Your Honours.

22             THE ACCUSED: [Interpretation] Can we look at 65 ter 6609.

23             MR. KARADZIC: [Interpretation]

24        Q.   These are the minutes from a joint meeting of the Main Staff, the

25     Executive Board, and the Political Council of the SDS of the BiH held on

Page 14270

 1     the 11th of March, 1992.  Do you remember that at that point in time

 2     there was a conference underway under the auspices of Lord Carrington and

 3     Mr. Cutileiro which will result in the so-called Lisbon Agreement?

 4        A.   Yes, I remember that.  I think this was in the same hall where

 5     the meeting of the 19th of December was held, and I remember this because

 6     I think I spoke at this meeting.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] Can we have the next page, please.

 9             MR. KARADZIC: [Interpretation]

10        Q.   This is the third paragraph in the Serbian.  I think we will find

11     it in the English as well.  It was indicated -- this is actually the

12     third paragraph in the English.

13             "Furthermore, it has been stated that in the field ..." and then

14     it lists Trebinje, Banja Luka, Sipovo, Ugljevik, Novo Sarajevo, Doboj,

15     Ozren, et cetera.  There are serious problems which are the result of

16     inactivity and non-execution of the agreed policy.

17             And then the following paragraph states:

18             "There is a need for an urgent discussion regarding the

19     standpoint on the Yugoslav national army as a very sensitive issue.  The

20     first and main thing is one's own army with its own insignia, especially

21     as both Croats and Muslims have introduced their own army and their

22     insignia in their own areas."

23             First of all, do you agree that up until that time, even before

24     this was something that was stated at the conference, do you agree that

25     the Croats and the Muslims already had their own armed formations?

Page 14271

 1        A.   I am aware of that information, although I don't have any

 2     evidence of it because I didn't see those armed formations.

 3        Q.   Second, do you remember that as part of the Lisbon plan, the

 4     Lisbon Agreement or Cutileiro's plan, the idea was for all the

 5     constitutive parts to have their own national guards?  Other than the

 6     police they were also supposed to have their own militia or national

 7     guards?

 8        A.   Well, the Cutileiro Plan or the Lisbon Agreement are well known,

 9     but they were never actually implemented, they never went into force.

10     They were signed but the implementation was abandoned.  They were never

11     implemented.  So it's hard to say had it been implemented what the --

12     what form the implementation would have taken, how everything would have

13     been done.  But this case -- this agreement was not implemented.

14        Q.   Well, we will come to that.  All I wanted to ask was whether this

15     part of the minutes speaks about us having more harm than benefit from

16     the Yugoslav People's Army.  While the others were forming their own

17     armies, we were supporting an army that we could not actually command.

18        A.   Well, the Yugoslav People's Army as a multi-ethnic entity ended

19     up in Serbian hands.  Muslims, Croats -- Croats, Bosnians, and Slovenians

20     left the army leaving only Serbs there.  The SDS had a positive attitude

21     towards manning the ranks of the army.  The Serbs responded to the

22     call-up, to the regular and reserve forces.  So that army actually became

23     a predominantly Serbian army.  Their conduct at the beginning of the war

24     and who had what use or harm from it is something that I can speak about

25     only as it relates to Novo Sarajevo.  Anything else would be speculation

Page 14272

 1     and I would not want to do that.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] I would like to tender this

 4     document, please.

 5             MR. TIEGER:  No objection.

 6             JUDGE MORRISON:  That will be tendered -- exhibited.

 7             THE REGISTRAR:  As Exhibit D1277, Your Honours.

 8             THE ACCUSED: [Interpretation] Thank you.  Can we look at 1D3487

 9     again, the interview, 1D3487.  Page 42 in the Serbian and page 39 in the

10     English.

11             MR. KARADZIC: [Interpretation]

12        Q.   Do you agree that the document we know as the Variant A and B and

13     you confirmed was distributed without any particular recommendations by

14     the parties, that it should be adhered to?

15        A.   As I said, the A and B variant document was distributed, people

16     read it, and they were obliged to return it to you.  The document was not

17     discussed, it was not put to the vote, it was not amended or augmented.

18     It was simply promoted there and people understood it in different ways,

19     some as an obligation, some less so, some were confused, and so on.  In

20     any event, at the meeting we did not have time to read the document

21     thoroughly.  We just were briefly informed about it, did not have time to

22     read all of the elements.  Only later during the war I managed to get a

23     copy and I read it from beginning to the end.

24        Q.   There is a charge in the indictment which states that

25     Mr. Cizmovic was the person responsible on my behalf for the

Page 14273

 1     implementation of that document in the field.  From January 1992 onwards,

 2     did Mr. Cizmovic come to your municipality?  And my advisor did ask you

 3     that on this page of the interview, and you said that he did not.  Did

 4     anyone come to monitor the application of the Variant A and B document

 5     and was there any insistence from the party on the implementation of that

 6     document?

 7        A.   No one came to Novo Sarajevo.  As for the role of

 8     Mr. Jovan Cizmovic, I think that he was some kind of co-ordinator for

 9     inter-regional co-operation at the regional level, the Serbian autonomous

10     provinces or regions that were proclaimed.  As for the document itself,

11     later when reading it we did see a passage where the implementation of

12     the document was possible only with your personal approval, and in the

13     document you are indicated as the person who decides if the document

14     would be implemented and how it would be implemented.  As for

15     Novo Sarajevo, there were no contacts or any visits from the government

16     to that area.  We were left to our own devices to do as best we could.

17        Q.   Thank you.

18             THE ACCUSED: [Interpretation] Can we now look at P2568, please.

19     P2568 and page 73 in e-court.

20             MR. KARADZIC: [Interpretation]

21        Q.   You are being asked here by Judge Hanoteau:

22             [In English] "Those who were there and those who received the

23     document, were they in a position to make any comments ..."

24     [Interpretation] And so on and so forth.  And your answer was:

25             [In English] "Well, they did have the possibility; it wasn't

Page 14274

 1     forbidden.  They could have taken the floor, and they could have made the

 2     comments they wanted to make.  But given the atmosphere in the Assembly,

 3     given the emotions, given the atmosphere, it was perhaps not

 4     conducive ..." and so on.

 5             [Interpretation] And then the Judge asks you further:

 6             [In English] "So if I understand you correctly, the emotional

 7     atmosphere that prevailed was one of fear."

 8             [Interpretation] And can we look at the following page, please,

 9     in the English.  Your answer:

10             [In English] "Well, you could put it that way.  One could say

11     that there was fear, fear of being out-voted, the fear of Bosniak and

12     Croat dominance."

13             [Interpretation] And can we now look at page 170 of this

14     document.

15             Mr. Stewart asks you:

16             [In English] "Mr. Neskovic, I'll put this to you, then:  Are you

17     saying that apart from the Variant A and B instructions, as you put it,

18     that you were not yourself aware of any instructions, directions, or

19     guide-lines given to municipalities from the higher levels of the party

20     in late 1991 or early 1992?"

21             [Interpretation] Your answer is no, right?

22        A.   Yes, the party did not give out any instructions because it was

23     the Assembly of the Serbian people in Bosnia-Herzegovina that was issuing

24     series of enactments from 22nd October until 19 January 1992, and those

25     were the basic documents, the fundamental documents, on the basis of

Page 14275

 1     which everyone acted.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] Can we now go back to 1D3487.

 4     1D3487, page 32 in Serbian and 33 English.  30 in English and 32 in

 5     Serbian.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   You were asked first:

 8             "Who conceived Crisis Staffs in municipalities in the first

 9     place?  Was that ever discussed in the organs of the party?"

10             And your answer is:

11             "I don't think so.  As far as I remember from the transcripts,

12     no.  There was great diversity.  Already at that time you had an

13     institutionalised Krajina that established Crisis Staffs at the level of

14     Krajina.  In other places, you did not have Crisis Staffs and there were

15     none at the level of Bosnia-Herzegovina."

16             When you were asked why was a Crisis Staff set up in your

17     municipality, you answer:

18             "The first Crisis Staffs were established based on some

19     instruction from the government, that was in Djurovic's locality."

20             And when you were asked which date, you said:

21             "It was early April, perhaps the 10th of April.  That

22     Crisis Staff fell apart, it had held only one meeting, and in that

23     Crisis Staff I was in charge of office space."

24             And a bit further down:

25             "The Crisis Staff stopped working at that point after only one

Page 14276

 1     meeting.  Djurovic went to Belgrade."

 2             Is it indeed your position as you stated it in this document, and

 3     was it indeed the case that everyone did as they saw fit?

 4        A.   Yes, I believe according to the instructions from the government

 5     Djurovic formed a Crisis Staff.  He was chairman of the Executive Board

 6     in Novo Sarajevo municipality.  He had great reservations about Variant A

 7     and B.  He didn't want to apply it.  He tried to avoid it.  He thought

 8     that he could attain his objectives within the legal framework in the

 9     municipality.  He formed this Crisis Staff that fell apart after just one

10     meeting, and he himself left Grbavica and went to Belgrade.  That's how

11     it was.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] Can we now see D407.  I hope we can

14     see the English.  This is already in evidence.

15             MR. KARADZIC: [Interpretation]

16        Q.   This is an excerpt from the instructions for the work of

17     Crisis Staffs in municipalities issued by the government of the Serbian

18     Republic Bosnia-Herzegovina.  Is it the instruction to which you made

19     reference earlier?

20        A.   It's from 1990, but I never read it even at the time and didn't

21     care for it.  We took a negative attitude towards instructions from the

22     government.  I don't know the contents but I know of its existence and I

23     know that it was on its basis that Crisis Staffs were formed.

24        Q.   It says:

25             "The Crisis Staff takes over all the prerogatives and functions

Page 14277

 1     of Municipal Assemblies in war time whenever Assemblies are unable to

 2     convene ..."

 3             And then in point 2 we see who makes up the Crisis Staff.  3, its

 4     task is to defend territories and defend the population.  Number 4,

 5     number 9 --

 6             THE ACCUSED: [Interpretation] Can we see the next page?

 7             MR. KARADZIC: [Interpretation]

 8        Q.   -- the Crisis Staff is duty-bound to create conditions for the

 9     work of international humanitarian organisations.  Number 9, the

10     Crisis Staff is duty-bound to create proper conditions for the work of

11     international peacekeeping and humanitarian organisations and to enable

12     unhindered passage of convoys with humanitarian aid ..." et cetera.

13             Number 10:

14             "Treat non-combatants and the wounded humanely in keeping with

15     the ICRC, also prisoners of war, and act in every way in accordance with

16     the laws of Serbian Bosnia-Herzegovina."

17             Regardless of the fact that you have not read this instruction,

18     did you basically act in keeping with these provisions in your

19     municipality?

20        A.   No.

21        Q.   For instance, did you co-ordinate the work of the authorities to

22     protect the territory and defend the population?

23        A.   No.

24        Q.   Did anyone else do it?

25        A.   Well, the police and the Territorial Defence and later the army

Page 14278

 1     had to take care of that.  The Crisis Staff that I presided over created

 2     independently of this instruction our own work.  We thought the position

 3     of the government to be very inappropriate.  The government is shifting

 4     its own responsibility to municipalities.  Municipalities are supposed to

 5     do their own work, and the government did not even tour the localities or

 6     offer any assistance.  The way I see it, the government shifted the

 7     burden of the crisis to municipalities and it sort of loses power.  The

 8     Crisis Staff that I set up with Sarovic was not based on this

 9     instruction.  We did not care for government's instructions.

10        Q.   Are you trying to say that the government had no great influence

11     on municipalities and the municipalities did not get any assistance from

12     the government?

13        A.   Speaking for Novo Sarajevo, we did not get any assistance.  But

14     the government did have influence because they had all the funds and

15     resources.  The municipalities did not have their own resources and did

16     not have the funding to deal with any issues.  This inadequate policy

17     remained in place throughout the war.  The whole burden of the war was

18     shifted onto municipalities.  I believe the government was not working

19     properly and put a greater burden on municipalities than they were able

20     to withstand.

21        Q.   Do you agree that your grudge against the government is perhaps

22     justified because the government was close to you, but do you agree that

23     at this time towards the end of April, the government could not have any

24     good communication or even physical connection with more remote

25     municipalities?

Page 14279

 1        A.   I don't think so.  The government was able to have communication

 2     if they wanted to have it.  I stand by my position that the government

 3     acted very irresponsibly towards municipalities, shifting the burden of

 4     the war onto them.  Those people in Pale could have known if they wanted

 5     to, they could have helped if they had wanted to.  They had all the

 6     power, all the money, all the resources.  It was in their hands, it was

 7     up to them.  The government could have received information if it had

 8     wanted to.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] This document is in evidence.  Can

11     we go back to the interview, 1D3487.

12             MR. KARADZIC: [Interpretation]

13        Q.   While we're waiting, do you agree that, from the beginning,

14     everyone hoped that it was not going to be a war, just a crisis, a

15     short-lived one, and that's the reason why Crisis Staffs were formed

16     first and the Presidencies of municipalities were set up only later?

17        A.   I would not say so.  It would be logical to create Crisis Staffs

18     before the war.  It's only when the crisis really sets in that the

19     Crisis Staffs are supposed to be established.  We were all hoping at that

20     time that the war would not escalate to that extent and that the JNA and

21     the Presidency of the republic with all their meetings will do everything

22     to avoid the war.  And I believe you and Izetbegovic indeed made efforts

23     to find a peaceful solution; however, the problems surpassed your

24     capacities.

25             In order to get a good outcome, a more positive attitude was

Page 14280

 1     required from the Croatian President Tudjman and the Serbian

 2     President Milosevic because the crisis could not be resolved peacefully

 3     without their involvement.  We were all hoping that there would finally

 4     be some agreement between the presidents of the various republics.

 5     However, those hopes were dashed.

 6             THE ACCUSED: [Interpretation] Can we see page 34 in Serbian and

 7     32 in English.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   You say here already from the 12th of May, when the army was

10     established, Mladic said he did not recognise the Crisis Staffs.  Do you

11     recall that it turned out the Crisis Staffs were unable to influence the

12     army, they were not recognised, and that is one of the reasons why they

13     ceased to be?

14        A.   No, it's about something else.  The government very cunningly

15     shifted the burden of the war onto municipalities and Crisis Staffs, and

16     then in the end of May they found that the Crisis Staffs were not doing a

17     good job, that it was not a good solution for managing municipalities.

18     Then the Crisis Staffs were disbanded, and then the Presidency was

19     established.  It lasted only ten days.  And then the decision was changed

20     again to set up war commissions.  So it was all very haphazard and

21     random.  It was unclear what the authorities at the level of Bosnia and

22     Herzegovina were going to do about the authorities in municipalities.

23     There were several solutions, Crisis Staffs, Presidency, and war

24     commissions.

25             And as far as Mladic is concerned and the army, he had great

Page 14281

 1     reservations about this new SDS.  They favoured the League of Communists

 2     and they were very sorry that this party fell through in the elections,

 3     and then they accepted the SDS as a necessary evil, hoping all the time

 4     that other parties would come into power, such as the Serbian radicals,

 5     and that they would get greater powers and a better position in Belgrade.

 6     So generally speaking, high-ranking officers did not like the SDS very

 7     much as the main, national party.

 8        Q.   On page 34 and I believe English page 32 or it's the same page,

 9     you say -- now about Grbavica, that's before the bolded "Krasno."  And

10     now Grbavica, this Crisis Staff, it was all on paper.  You're making

11     believe that there is a Crisis Staff, but you are completely impotent.

12             Was that really your belief, that it was something on paper

13     without any powers?

14        A.   There were two different periods.  When Grbavica was not under

15     the control of the Serbian army and the Crisis Staff was in Vrace.  What

16     I said here refers to that period.  You have great obligations and facing

17     great expectations from the population, but you can't do anything.  The

18     situation is completely different in May when the Serbian army took

19     Grbavica over, the situation changed for the better.  They found a large

20     number of well-organised people in Grbavica, prepared to defend

21     themselves.  There were proper resources and proper capacity to work.  So

22     these are two distinct periods, before the take-over of Grbavica and

23     after.

24        Q.   Before the take-over of Grbavica you say the people organised

25     themselves.  Now, could the Crisis Staff guide these processes, prevent

Page 14282

 1     any crimes from being committed, or influence the events in any way

 2     before the army took control of Grbavica?

 3        A.   Well, it could have done so in the municipalities where it had

 4     the resources.  If you had warehouses, depots, medicines, fuel, and other

 5     such resources that you can use for the people, you could.  But if you

 6     don't have those resources, then you couldn't do anything.  And secondly,

 7     you could wield an influence if you were superior above the -- to the

 8     military units and so on.  If you were a commander, you could effect

 9     security; but if you weren't in charge in any way, then you couldn't

10     wield any influence on the security issues.  So for you to be able to

11     wield an influence, you needed resources, backup.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] May we now have page 33 in Serbian

14     and 31 in English, staying with the same document.

15             MR. KARADZIC: [Interpretation]

16        Q.   In your answer there in the middle, "Well, I personally," that

17     sentence -- no.  But this Crisis Staff, you say, dissolved and nobody

18     from the government or the Assembly came, nobody from the commission came

19     or Presidency, and the people were left to fend for themselves because of

20     the so-called officials.

21             "Only Miljko Sarovic and I stayed on in the area and so did

22     Prijic, and I talked to Miljko, Prijic, about what we were to do, and

23     then at Vrace we single-handedly formed a Crisis Staff according to our

24     own -- by our own accord without asking the government for instructions."

25             Is that the right description?  You said you were left to fend

Page 14283

 1     for yourselves; is that right?

 2        A.   Yes.

 3             THE ACCUSED: [Interpretation] Now may we move on to page 35 of

 4     the Serbian and 32 of the English.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   We have a brief exchange between you and my advisor.  From the

 7     10th of April to the 10th of May, you were in the Crisis Staff, that's

 8     what the person says.  Then you say "yes."  Who did you report to in that

 9     period?  Your answer:

10             "Nobody."

11             The question was:

12             "Did you have telephone lines?"

13             Your answer:

14             "There were none."

15             "Q.  All right.  Did anybody from the leadership visit you up to

16     the 10th of May?

17             "A.  Nobody."

18             And a little further down the page or on the next page in

19     English:

20             "We did that all on our own without consulting any authority at

21     Pale."

22             And a little further down again, you say:

23             "Except for Mucibabic, no other high-ranking official came to ask

24     us how we were.  I might have gone to Pale on one occasion to ask for

25     some resources from the municipality for coffins, but the people from the

Page 14284

 1     government really left us in the lurch.  They never even asked about us

 2     nor did we ask about them" --

 3             JUDGE MORRISON:  Yes, Mr. Tieger.

 4             MR. TIEGER:  I'm at a loss to understand why in the course of

 5     recounting this lengthy answer that has to do with contact -- the --

 6     there is skipping over the portion about someone who did come.  So if

 7     that's going to be read into the record and stand on that basis, it needs

 8     to be read out in its entirety.

 9             JUDGE MORRISON:  Dr. Karadzic, you can see Mr. Tieger's point.

10             THE ACCUSED: [Interpretation] We will be tendering the entire

11     document, but what I'm just doing now is, for the purposes of

12     cross-examination, making a short selection.  Otherwise, we're not going

13     to skip over everything, we're going to tender the whole document in due

14     course, but we're trying to save time during the cross-examination.

15             JUDGE MORRISON:  Well, that's appreciated, Dr. Karadzic, but as

16     long as the point that Mr. Tieger has raised is plain, that if you're

17     going to have information in, then the whole of the information needs to

18     be taken into account.

19             THE ACCUSED: [Interpretation] It's not Milomir Vuckovic, it's

20     Mucibabic.  I did mention Mucibabic.  I just skipped the upper part.  So

21     Mucibabic did come and I said that.  And Mucibabic wasn't an official.

22     He came as some sort of commissioner with instructions, bearing

23     instructions.  But as I say, we'll place the whole document at your

24     disposal.

25             May we have 36 in Serbian now, please, and 34 in English.

Page 14285

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Would you like to say something more?  Do you consider this

 3     interview to be complete?  Would you like to add anything on the topic

 4     that we're discussing, that is to say, the visits to Novo Sarajevo?

 5        A.   Well, I don't know what you have in mind.  Milomir Mucibabic was

 6     a sort of commissioner from the government, but otherwise, nobody came

 7     from the government.  And the atmosphere was a very negative one,

 8     negative towards the government and towards you too because it was

 9     considered that you should have stayed on in Sarajevo, remained there and

10     shared the destiny of the rest of the population and not have gone to

11     Pale.  And the prevailing opinion was that the population was left in the

12     lurch and that that was why there was this negative attitude towards the

13     authorities in Pale.  Otherwise, the rest is as I have stated there.

14        Q.   Thank you.  Now, you're asked, staying with that page:

15             "Did you have any contacts with other Crisis Staff in Serbian

16     Sarajevo municipalities?"

17             Your answer was:

18             "No, we could not have.  I just went once to attend a meeting

19     because we had to take the roundabout route.  We were physically cut off

20     from Ilidza, Hadzici, Ilijas, and so on.  So you would need a whole day

21     to get there.  So we went to Pale.  Nobody invited us nor did we go,

22     actually.  I just went once or twice.  Once there was an army uprising

23     and a civilian rebellion."

24             And then you go on to describe how you presented a sharply worded

25     petition and that:

Page 14286

 1             "Radovan said nothing, said not a word," that is to say, I didn't

 2     oppose anything, "nor did Krajisnik, but it was rather unpleasant because

 3     we wrote all sorts of things against the leadership and we aimed more at

 4     the government which had taken up," and so on and so forth.

 5             So as the Crisis Staff and the leadership of the municipality,

 6     you had to solve problems such as coffins for those who had been killed

 7     and so on and so forth, and that's why you went to Pale, whereas you had

 8     absolutely no contact with the government and the authorities in

 9     Sarajevo?

10        A.   Well, I think I went to the government when it was in -- put up

11     in the Kikinda building.  That's the first time I went.  I don't think

12     the Army of Republika Srpska had still been established.  There was a

13     Territorial Defence and a brigade down there of the Territorial Defence,

14     that's all there was because of the war, and people were killed.  And so

15     it was necessary to procure coffins for those unfortunate people, and I

16     was rather surprised because I thought it was the Ministry of Defence

17     that took care of that, including coffins.  But I think I went to see --

18     well, one of the ministers in Kikinda anyway and I resolved the problem

19     of these coffins.  I think that they were manufactured at Sokolac.

20             So that was my first contact with the government, and I didn't

21     understand why the Crisis Staff now which had a role in the Municipal

22     Assembly had to deal with coffins for the dead.  I thought that there was

23     some military institution that would deal with things like that, but

24     unfortunately, we confirmed that the government had shifted the burden to

25     the municipalities and it was the municipalities that had to take care of

Page 14287

 1     everything, including coffins for the soldiers killed.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] May we have page 37 in Serbian and

 4     34 in English now, please.

 5             MR. KARADZIC: [Interpretation] And that is where you describe the

 6     argument over the petition and the rigorous stand you took vis-à-vis the

 7     leadership.  Page 34 of the English said:

 8             "We had a serious argument on account of the petition.  We put

 9     serious accusations on the leaders that they were going to sell out

10     Sarajevo, betray us, sell us out that it wouldn't be ours.  We had a

11     fierce disagreement about them giving up the airport.  That was one item.

12     The other item was that we wanted to know what the borders were.  People

13     were asking and we wanted to prevent deaths" and so on and so forth.

14             Do you stand by that position expressed there, that the local

15     authorities had a lot of criticism to make of the government and the

16     central organs?

17        A.   Not only the authorities, but the population as well.  The

18     problems that the authorities had went way beyond what they were capable

19     of doing.  And it was especially difficult because there were no leaders

20     and officials and higher organs to give you any guide-lines.  You were

21     left to fend for yourself, to do what you could given the circumstances,

22     which was a very difficult position to be in.  And I remain by the stand

23     that the government did very little to help the municipality there.

24        Q.   Thank you.

25             THE ACCUSED: [Interpretation] May we now have P2568, please.  I

Page 14288

 1     think that's the right number.  Or first of all D885, please.  D885 next.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   It's a report of yours to the president of the Presidency of the

 4     Serbian Republic of Bosnia-Herzegovina dated the 5th of June, 1992.  Do

 5     you recognise this report and written that way with a reference number

 6     and the date and as set out, is that how reports are generally written?

 7        A.   Yes, this is my report and I think I wrote it in just one copy.

 8     I think you were to have it photocopied.  I haven't got a copy of it

 9     myself, so I haven't had a chance to read it through again.  But yes,

10     that is the report I sent to you on the 5th of June, 1992, and I think I

11     wrote it in Bistrica at Mount Jahorina and I think I handed you the

12     document personally.

13        Q.   Thank you.  You are stating here that an Executive Board has been

14     formed as an executive organ of the municipality and that you were taking

15     care of the population, that all refugees from the occupied territories

16     and people who were left homeless had been taken care of in the areas of

17     Tilava, Lukavica, and so on.  Then you go on to speak about food

18     supplies, local communes made lists of civilians which included their

19     first and last names, and food supplies amounting to 50 per cent of peace

20     time supplies were distributed to those on the lists.

21             THE ACCUSED: [Interpretation] Next page, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   When you say the population, food supplies for the population,

24     did that refer to the Serbian population or to the population in general

25     regardless of nationality or religion?

Page 14289

 1        A.   The entire population.  I think we had two food kitchens open.

 2     At Grbavica we had people in charge of distributing that food and we

 3     tried to have it honestly distributed as far as possible.  We had food

 4     shortages to begin with, but then the French army stepped in, UNPROFOR,

 5     and they brought in vast quantities of food to Grbavica and throughout

 6     the war they fed the population of Grbavica.  So the population of

 7     Grbavica can be grateful to the French UNPROFOR which helped the

 8     population, and then the food that they brought to us on a daily basis we

 9     further distributed.  So that was the French -- the assistance provided

10     by the French section of UNPROFOR.

11        Q.   Thank you.  You go on to speak of food supplies for the army.

12     Now, the next section, health care and medical corps.  You say a health

13     centre with five surgeries were formed and civilians were treated as well

14     as everybody else, and during combat action it functioned as a military

15     hospital.  So you were left without a health centre and you had to

16     establish a new one; is that right?

17        A.   Well, yes, we were left without a health centre; however, this

18     was a relatively easy problem to resolve because there were surgeries at

19     Grbavica, well staffed, so they just continued working and we didn't have

20     to invest any great efforts.  Quite simply, the medical staff continued

21     doing their work, the same staff that worked before the war in the

22     surgeries.  And at Grbavica there was a very well-known surgery with very

23     professional staff and had all the resources necessary to function.

24        Q.   When you say that it provided assistance to civilians and all

25     people alike, did that refer to the Muslims and Croats as well living in

Page 14290

 1     Grbavica?

 2        A.   Yes, both in terms of food and medical assistance.  I think there

 3     was a lady doctor at Grbavica.  She was a Bosniak.  Now, as far as food

 4     was concerned, we had to make lists of people requiring meals in public

 5     kitchens and I think that the French would control this, control -- look

 6     at the lists to see if they were multi-ethnic or if they were just

 7     mono-ethnic.  But as I say, the medical assistance did apply to all

 8     citizens, regardless of nationality or whatever.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] May we turn to the next page,

11     please.

12             MR. KARADZIC: [Interpretation]

13        Q.   Under point 6 you talk about the attitude towards Muslims and

14     Croats and you say:

15             "Meetings are frequently held, especially in Grbavica, of

16     citizens of all nationalities and we pick a person in charge about all

17     entries made, a head for every building responsible for the situation in

18     his building, and we informed the Muslims that they would be safe if they

19     were militarily neutral towards us.  And so far the situation has been

20     good.  We visited the nunnery in Gornji Kovaci ci and discussed

21     co-operation, loyalty, and the nuns' safety."

22             Now, my first question is this:  Do you agree or do you know that

23     the selection of a head for every building was in keeping with the Law on

24     All National Defence -- All People's Defence?

25        A.   No, I don't know about that.

Page 14291

 1        Q.   Second, do you agree that it was a good solution, that is to say,

 2     if some were -- someone were to commit a crime, a Muslim were to commit a

 3     crime, that the police was allowed to do their work without holding

 4     rallies or something?

 5        A.   Well, these heads were not appointed for that reason, but they

 6     were appointed for other reasons.

 7        Q.   Thank you.  We saw a footage -- we saw footage of this convent in

 8     Kovacici.  Were they Catholic?

 9        A.   Yes, it was at Gornji Kovacici, the convent there, and they were

10     nuns who had been there for a long time and then left later on.  They

11     were Croat nuns, Catholics.  Yes, it was difficult for them.

12        Q.   Thank you.  Do you agree that this was a good example of how we

13     expected the municipal authority to function and that in the eyes of the

14     leadership your -- their respect for you grew?

15        A.   Well, I don't know.  But I had a video-tape from the joint

16     meetings that we held with the Bosniaks and Croats, and I think that this

17     was a good example of how one should behave given war-time circumstances.

18     Unfortunately, it didn't last long because later on, during 1992, for

19     instance, the situation radically changed.  So I'm very sorry that this

20     did not go on for longer.

21        Q.   Thank you.  I wanted to say what you were doing at your level in

22     the municipality, was it in keeping with what we wanted to be done or did

23     you elicit only my critique?

24        A.   I was doing it of my own accord, not expecting praise or

25     criticism.  I did not have a care for what the government in Pale was

Page 14292

 1     doing because I had too much on my plate and I wasn't worried about

 2     whether -- whatever leadership agreed or disagreed.  No, I did not

 3     actually receive any criticism from the leadership over this.

 4        Q.   Thank you.

 5             THE ACCUSED: [Interpretation] Can we see again 2568, P2568,

 6     page 129 in e-court.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   From line 8 the question:

 9             [In English] "Now, the last sentence in the first paragraph of

10     item 6 of the June 5th report, as I mentioned earlier, says, 'Secretly,

11     the police applied the usual procedure to people who were engaged in

12     military activities against us.'

13             "If you know, what was the usual -- what was the procedure that

14     the police was applying to Muslims and Croats?"

15             [Interpretation] Answer:

16             [In English] "That meant that since all the Muslims had been

17     asked to surrender their weapons on a voluntary basis, and they did that,

18     the Commander Major Petkovic said, 'Since you have done that, the army

19     won't search your flats.  We'll have a Muslim at each entrance who will

20     be in charge of that entrance and will ensure that everyone is there

21     every night ..."

22             [Interpretation] And a bit further down, line 20:

23             [In English] "... and this concerned the Muslims who didn't want

24     to surrender their weapons and they acted against the Army of

25     Republika Srpska.  They provoked action over the radio, or there was

Page 14293

 1     sniper fire because they believed that those who were carrying a weapon

 2     were no longer citizens; they were soldiers.  And if any inhabitants

 3     noticed such a person, they should go to the civilian police and report

 4     on the fact, and then further police procedures would be implemented.

 5     And it meant that if anyone noticed such a person in their building, they

 6     should be reported."

 7             [Interpretation] That is the sort of thing you did not say at

 8     meetings in order not to upset the citizens.  This is how the protection

 9     in Grbavica worked; correct?

10        A.   It was very difficult.  This was some sort of preventive

11     confidence.  The war made a confusion between civilians and the military.

12     It was very hard to distinguish in the city who is civilian and who is

13     combatant, because you can see a civilian in the street, he goes back

14     into his house, takes up a weapon, and he is no longer a civilian.  Then

15     he leaves his rifle behind and becomes a civilian again.  It was very

16     hard to distinguish in the city.  And we were trying to warn Croats and

17     Bosniaks that if they do not attack the Army of Republika Srpska, they

18     have the same rights as any other citizens.  But if they act against the

19     army, even by radio or passing on information, they would lose their

20     status of civilians and they would be investigated by the police.  So if

21     anyone notices such a person, they are required to report it to the

22     police.

23        Q.   In the same document, page 113, here you say line 2:

24             [In English] "Initially the situation was fairly good, given the

25     wartime conditions.  But sometime in the second half of 1992 - perhaps

Page 14294

 1     that was in July or in August - certain groups started to expel the

 2     Muslims and made them flee to the other side of Miljacka.  In Grbavica,

 3     there -- we have to distinguish between Grbavica I, where our

 4     Crisis Staff was located and where the civilian authorities were located,

 5     and there was also Grbavica II, which resembled Stalingrad; it was a

 6     military position ... and I think that the Muslims were expelled in

 7     droves from Grbavica II ..."

 8             THE ACCUSED: [Interpretation] Page 115 now, please.

 9             [In English] "As far as Grbavica I is concerned, as far as I can

10     remember, this did not go on for days and days.  I believe that this only

11     occurred on one day, but it was a terrible day, an ugly day, and these

12     very ugly things happened.  On that day, individuals were expelled and

13     made to cross over to the other side ..."

14             [Interpretation] And so on.

15             [In English] "There was a commander, major, called Dragan

16     Petkovic.  He also treated them very correctly because he lived

17     there ..." and so on and so on.

18             [Interpretation] These things that happened on this day, were

19     they done by an organised unit under somebody's control or was it some

20     other elements?

21        A.   I can't remember that date in August, but on that day I ran to

22     the apartment of Olja Varagic, and there was my friend there also from

23     radio and television, and I wanted to stay there for one day to help if

24     somebody comes to the door.  So I don't know who was doing this, but it

25     was totally unnecessary.  It was criminal to treat innocent citizens from

Page 14295

 1     Grbavica like this and to expel them to the other side, to mistreat them,

 2     to rob them.  The military police, the military prosecutor's office

 3     should have taken this situation under control.

 4        Q.   But that was certainly against the will of your civilian

 5     authorities in Grbavica, wasn't it?

 6        A.   The army never asked us for anything.  We did not even have

 7     contact with them.  We were even kidnapped once by the army.  They put us

 8     into their vehicles and took us to the front line.  So we did not even

 9     dare approach the army, let alone had any influence on them.  We had

10     none.

11        Q.   Thank you.  But you confirm here that Major Dragan Petkovic

12     treated Muslims and Croats fairly?

13        A.   Dragan Petkovic treated Muslims fairly, Croats and Serbs fairly,

14     making no distinction.  But I believe sometime later in the summer,

15     Petkovic was transferred.  He didn't stay there.  I think he was sent to

16     Zvornik.  So I can say that within his own field of authority,

17     Dragan Petkovic was a decent person, treated everyone fairly, and I

18     believe Muslims and Croats who still live in Grbavica can testify to

19     that.

20        Q.   This man whom you visited in order to give him protection was

21     your work colleague, a Muslim?

22        A.   Yes, we used to work together at Radio Television Sarajevo.

23             THE ACCUSED: [Interpretation] Can we now see 1D3487 again,

24     page 39 Serbian, 36 English.

25             MR. KARADZIC: [Interpretation]

Page 14296

 1        Q.   While we're waiting, what was the source of that danger to your

 2     friend whom you went to protect?  Was it the police or the army or

 3     neither?

 4        A.   There were armed people in uniform all over the place.  You

 5     couldn't know to which institution, to which unit they belonged.  There

 6     was no way of knowing.  You could not tell who was a member of the army

 7     and who was a paramilitary.  Both wore uniforms and both carried weapons.

 8     Only the military police was able to do that, but they were pretty idle,

 9     unfortunately.  As for this man Djipa, Batko was dangerous to him.

10             THE INTERPRETER:  Could the witness please repeat the last part

11     of his answer.  The interpreter didn't catch it.

12             JUDGE MORRISON:  Sorry, can the witness please repeat the last

13     part of your last answer.  The interpreters were unable to understand it

14     for interpretation.

15             THE WITNESS: [Interpretation] Orhan Djipa, his life was in

16     jeopardy from the person called Veselin Vlahovic, known as Batko.

17     Because on one occasion Batko had arrested Orhan Djipa and it was only

18     Simo Sipcic's quick reaction, that man was a military policeman, that

19     saved Djipa's life.

20             MR. KARADZIC: [Interpretation]

21        Q.   Now you see on this page my advisor asked you:

22             "Was there talk about any incidents or crimes against Muslims at

23     that meeting?"

24             You say:

25             "No.  Radovan kept his silence, whereas Moma tried to iron it

Page 14297

 1     out.  He didn't say anything specific.  He just said we shouldn't be

 2     afraid, there was a leadership, that they are thinking about Sarajevo."

 3             Was it the occasion when you filed a petition against the

 4     leadership, and in this answer you confirm that there was no information,

 5     no reports, about crimes against Muslims?

 6        A.   At that meeting concerning the petition in Kikinda attended by

 7     you, Krajisnik, General Tolimir, General Mladic, and four or five of us

 8     from municipality Novo Sarajevo, and Prstojevic from Ilidza municipality,

 9     the main topic was what would happen with Sarajevo and the status of

10     Sarajevo, that was the main topic, and we didn't discuss anything else.

11             THE ACCUSED: [Interpretation] Can we see page 42 in Serbian,

12     39 in English.  We have these pages.

13             MR. KARADZIC: [Interpretation]

14        Q.   And you say:

15             "A system remained in Grbavica I controlled by the army under the

16     command of General Markovic --" sorry, that's Petkovic.  He's now

17     major-general.  "He calmed the situation down as much as possible.  They

18     did not allow searches or expulsions, and the people started approaching

19     them slowly as people you can trust, Muslims, Croats, and Serbs.

20     Petkovic had an apartment there before in Banja Luka Street."

21             In other words, are you trying to say -- sorry.

22             "Petkovic used to have an apartment in Banjalucka Street, so

23     people knew him there and the officers were rather tolerant and even the

24     police who were there were rather tolerant, except some people who were

25     trying to create problems."

Page 14298

 1             In other words, are you trying to say that citizens were able to

 2     approach the regular forces, the army and the police, and they would be

 3     met with understanding and given protection?

 4        A.   I can only talk about a short period in the early days of the war

 5     when Major Petkovic was there.  He did inspire confidence.  As for

 6     others, the Muslims and Croats from Grbavica treated the Serbian

 7     authorities very decently and tried to self-organise themselves to

 8     contribute to finding solutions to problems.  They tried to work together

 9     with others and they did not even protest against the work obligation.

10     Some even joined the army.  But the only thing they couldn't tolerate was

11     to be humiliated or mistreated.  That was a period in the early days.

12     However, when Petkovic, and later Novakovic, left, the situation changed

13     for the worse.

14             Now, to what extent the military police, the military security,

15     the state security, the civilian population and the military prosecutor's

16     office and the military courts were understanding of the problems

17     experienced by Muslims and Croats, I don't know.  Only Muslims from

18     Grbavica can tell you that.

19             All I know is that in Novo Sarajevo and in Grbavica the organs of

20     security had a major presence, the military and state security.  There

21     were two police forces, military and civilian, plus the command of the

22     army, and even, I believe, in the summer of 1992 a military prosecutor's

23     office and the military court were established.  So citizens had

24     somewhere to go.  Now, whether these institutions were equally open to

25     all of the citizens, I don't know.  You would have to ask Bosnians and

Page 14299

 1     Croats to what extent they had access to these institutions.

 2        Q.   Is it correct that Pofalici are a neighbourhood in your

 3     municipality that remained under the control of the BH army, whereas it

 4     was a majority Serbian or exclusively Serbian neighbourhood?

 5        A.   At the beginning Pofalici was not under the control of the

 6     BH army, at least not at of it.  One part was under the control of the

 7     Serbian Territorial Defence and then there started fighting between the

 8     Serbian Territorial Defence and the BH army.  And Pofalici then came

 9     under the control of the BH army.

10        Q.   Do you agree that on the 14th and 15th of May, the civilian

11     population were slaughtered in Pofalici where several dozens, if not

12     hundreds, of Serbs lost their lives?

13        A.   We have heard terrible testimony of people who had managed to

14     escape.  We weren't able to see it for ourselves.  We haven't got

15     concrete proof because we were quite a long way away from the area, but

16     we can conclude that something -- we were able to conclude that something

17     terrible had happened in Pofalici on the basis of eye-witness accounts of

18     people who managed to escape to the other side.

19        Q.   Pofalici are across the river from Grbavica, the other side of

20     the river and the main road; right?

21        A.   They're opposite the town and much further away, not only on the

22     opposite bank of the river but on the opposite side of the town.

23        Q.   You mean the hilly area?

24        A.   Yes.

25        Q.   Thank you.  Now, this event with the suffering of the Serbs in

Page 14300

 1     Pofalici, did it upset the situation and did it undo the peace that you

 2     were able to reach at Grbavica and the security situation regarding the

 3     Croats and the Muslims?

 4        A.   Well, quite certainly it had a negative effect.  Now, how far and

 5     to what extent, I wouldn't like to speculate.  I can't speculate on the

 6     consequences of that particular occurrence.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] May we have page 42 in Serbian and

 9     39 -- ah, we've got those pages on our screens.

10             MR KARADZIC: [Interpretation]

11        Q.   Towards the bottom of the page and then we'll turn to the next

12     page.  You were asked:

13             "In that period, during this period, while everything was fine,

14     did you have contacts with Dr. Karadzic?"

15             And you ask:

16             "In Grbavica?"

17             And the answer is:

18             "Yes.  You had no contacts with him at all?"

19             And your answer is:

20             "No, we had no contact whether Grbavica was liberated or not --

21     whether Grbavica should be liberated or not.  And we didn't ask him from

22     the beginning, nor did they ask us."

23             And now we come to another question.  That's right, next page,

24     fine.  That's fine.

25             "Was he informed of the events that took place in this

Page 14301

 1     municipality or not?"  That was the question you were asked.

 2             And the answer is:

 3             "The first time I informed him was in the letter I took, but I

 4     had no idea whether he was informed by other people or not -- or rather,

 5     whether he informed other people or not, I don't know."

 6             And then the next question is:

 7             "Did you inform him that everything was fine in the municipality,

 8     that everything was done in keeping with the regulations, the law?"

 9             And your answer is:

10             "I informed him on the 5th of June for the first time.  I hadn't

11     informed him prior to that.  I hadn't been informing him prior to that."

12             "So, did you inform him that Muslims were still there and that

13     everything was fine?"

14             And your answer was:

15             "Well, I informed him by giving him a list of all the elements,

16     the details, and I had forgotten about that.  When I saw that the

17     Prosecution had this report of mine, they gave it to me for a few moments

18     to refresh my memory.  I didn't manage to read the whole document, but I

19     think that I informed him in detail and as systematically as I could and

20     knew."

21             Now the next question is:

22             "And what was his reaction?"

23             And the answer is:

24             "I don't know.  He got it from me at that meeting and read it

25     later.  I think that he used it later and kept saying that the situation

Page 14302

 1     he had in Grbavica was all right.  All that was going on down there, I

 2     think that his reaction was positive.  Also Nikola Koljevic's reaction

 3     was positive and so was UNPROFOR's."

 4             Do you agree with what you said there in the interview?  Do you

 5     stand by that now?

 6        A.   With respect to the events that I referred to in the report, yes.

 7     There was a positive reaction on the part of Nikola Koljevic, and you

 8     seem to be all right with it.  Nikola Koljevic came and I think there was

 9     a positive reaction from UNPROFOR which supported the population

10     throughout.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Excellencies, I'm moving over to

13     another area now, so-called Batko area, so perhaps this would be a good

14     time to pause for the day.

15             JUDGE MORRISON:  Yes, I think that's correct, Dr. Karadzic,

16     rather than start a new topic which would have to be stopped in two or

17     three minutes' time.

18             We will rise for today and recommence at 9.00 a.m. tomorrow

19     morning.

20                           --- Whereupon the hearing adjourned at 1.42 p.m.,

21                           to be reconvened on Tuesday, the 7th day of

22                           June, 2011, at 9.00 a.m.