Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15147

 1                           Wednesday, 22 June 2011

 2                           [Open session]

 3                           [The accused entered court]

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

 5             JUDGE KWON:  Good morning, everyone.  We will give our ruling on

 6     the disclosure violation motion as it relates to the upcoming witness

 7     Ristic.

 8             With respect to the accused's 51st motion for finding of

 9     disclosure violation and to postpone testimony of Nebojsa Ristic and the

10     accused's 52nd motion for finding of disclosure violation and for

11     sanctions, the Chamber has considered the oral submissions made by

12     Mr. Robinson and the written response filed by the Prosecution opposing

13     the 51st and 52nd motions.  Given the limited volume of material in the

14     last batch of disclosure which pertains to Nebojsa Ristic's testimony and

15     Mr. Robinson's estimate of the time which will be required to review that

16     material, the Chamber is satisfied that the accused will have had

17     sufficient time to consider this, this newly disclosed material, and

18     incorporate it, if necessary, into his cross-examination of Mr. Ristic by

19     the time of Mr. Ristic's scheduled testimony.  Given the length and

20     content of the new material, the Chamber is not convinced that the

21     accused has been prejudiced by this late disclosure, although it once

22     again reflects very badly on the disclosure practices of the Prosecution.

23             In these circumstances, the requested postponement of or

24     exclusion of Nebojsa Ristic's testimony is unwarranted.  The Chamber will

25     issue a full written decision in due course which addresses the other

Page 15148

 1     issues raised in the motions.

 2             That said, let us bring in the witness.

 3             Good morning, Ms. Gustafson.  I take it that you will lead the

 4     witness.

 5             MS. GUSTAFSON:  Yes, Your Honour.  Thank you.

 6                           [The witness entered court]

 7             JUDGE KWON:  Good morning, sir.  If you could kindly --

 8             THE WITNESS: [Interpretation] Good morning to you, sir, and to

 9     everyone present in the courtroom.

10             JUDGE KWON:  If you could take the solemn declaration, please.

11             THE WITNESS: [Interpretation] I solemnly declare that I will

12     speak the truth, the whole truth, and nothing but the truth.

13             JUDGE KWON:  Thank you, Mr. Dzambasovic.  If you could take a

14     seat and make yourself comfortable.

15             THE WITNESS: [Interpretation] Thank you.

16             JUDGE KWON:  Yes, Ms. Gustafson.

17             MS. GUSTAFSON:  Thank you, Your Honour.

18                           WITNESS:  ASIM DZAMBASOVIC

19                           [Witness answered through interpreter]

20                           Examination by Ms. Gustafson:

21        Q.   Good morning, Mr. Dzambasovic.  If you could state your full name

22     for the record, please.

23        A.   My name is Asim Dzambasovic.

24        Q.   Thank you.  And if we could have 65 ter 90247 on the screen,

25     please.

Page 15149

 1             And, Mr. Dzambasovic, do you recognise this document as an

 2     amalgamated witness statement that was read back to you in B/C/S and that

 3     you signed just a few days ago on the 18th of June, 2011?

 4        A.   Yes.

 5        Q.   Thank you.  And I'd just like to correct one clerical error in

 6     the statement if we could go to page 4 and zoom in on paragraph 10,

 7     please.

 8             Now, Mr. Dzambasovic, I know this is in English so I just mention

 9     the context.  This is the paragraph that discusses the underground

10     command and communications facility in Han Pijesak called Goljak.  Do you

11     recall that portion of your statement?

12        A.   I recall it.

13        Q.   And in the middle of the paragraph there's a sentence that

14     contains a grammatical error.  The sentence reads:

15             "I think the unit was either the 367th Communications Regiment."

16             Could you please clarify what the name of this communications

17     unit was?

18        A.   It was a unit of the federal secretariat for National Defence,

19     367th Regiment, so that part of the unit, that facility on Goljak,

20     belonged to the 367th Communications Regiment, that entire facility

21     belonged to that unit.  That was not a unit of the 4th Corps, but rather

22     an independent unit of the federal secretariat for National Defence.

23        Q.   Thank you.  And with that clarification does this statement -- is

24     this statement true and does it accurately reflect what you said at the

25     time it was taken?

Page 15150

 1        A.   The statement is true and it is based on my own experience, the

 2     things I saw, heard, and experienced myself.

 3        Q.   And if I asked you the same questions that you were asked when

 4     you gave this statement, would you give the Court the same answers that

 5     are contained in that statement?

 6        A.   Absolutely so, except that perhaps there would be a more detailed

 7     explanation.  I -- in other words, I know far more than I put in my

 8     statement.

 9        Q.   Thank you.

10             MS. GUSTAFSON:  With that I tender the amalgamated statement.

11             MR. ROBINSON:  No objection.

12             JUDGE KWON:  Thank you.  That will be admitted.

13             THE REGISTRAR:  As Exhibit P2828, Your Honours.

14             MS. GUSTAFSON:  And now I'll read a summary of the witness's

15     92 ter statement.

16             Asim Dzambasovic, a Bosnian Muslim, was the Chief of Staff of the

17     216th Mountain Brigade of the JNA from September 1990 until 6 April 1992.

18     The commander of the 216th Brigade which was based in Han Pijesak was

19     Colonel Dragomir Milosevic.  The 216th Brigade was subordinated to the

20     4th Corps of the JNA, commanded by General Djurdjevac.  The area of

21     responsibility of the 216th Brigade included Rogatica, Sokolac,

22     Vlasenica, and Han Pijesak.

23             During late 1991 and early 1992, Mr. Dzambasovic experienced

24     changes in the JNA and the 216th Brigade.  Colonel Milosevic transferred

25     duties away from Mr. Dzambasovic and excluded him from brigade planning.

Page 15151

 1     JNA units and equipment were moved to areas with a majority Serb

 2     population.  For example, units were relocated from Lukavica to Sokolac

 3     and Pale.  SDS leaders from Rogatica and nearby municipalities met

 4     regularly with Dragomir Milosevic in Han Pijesak.  JNA weapons were

 5     distributed to the Serb population and Serb volunteers were armed,

 6     equipped, and incorporated into JNA units.  A volunteer unit under the

 7     command of Rajko Kusic, a prominent Rogatica SDS member, was formed in

 8     March 1992 and placed under the command of the 1st Battalion of the

 9     216th Brigade.  His unit was responsible for terrorising mainly non-Serb

10     civilians.  Mr. Dzambasovic raised his concerns about these issues with

11     Colonel Milosevic and General Djurdjevac.  No action was taken by either

12     officer to address these concerns.

13             In late March or early April 1992, Mr. Dzambasovic learned about

14     a mobilisation of Serbs.  On 6 April he met with Colonel Milosevic who

15     told Mr. Dzambasovic that he could not longer guarantee his safety.

16     Mr. Dzambasovic then left the JNA, made his way to Sarajevo, and on 13

17     April 1992 reported for duty with the republican Territorial Defence.

18             And that concludes the summary.

19        Q.   Mr. Dzambasovic, at the time you left the JNA and your position

20     in the 216th Brigade, what was your rank?

21        A.   At the time I was a lieutenant-colonel.

22        Q.   And in your statement you describe a transformation of your

23     treatment in the JNA in the latter part of 1991 and early 1992.  For

24     example, you discuss how you were not provided with information that you

25     should have received, that certain duties were taken away from you, and

Page 15152

 1     that non-Serb officers felt insecure, and I refer to paragraphs 57 and 82

 2     of the statement.

 3             My question for you is:  Did you discuss these issues, either at

 4     the time or later on, with other non-Serb JNA officers; and if so, how

 5     did their experiences in the JNA compare with yours?

 6        A.   When I had occasion to, I did, not only with officers from my own

 7     brigade but also from officers from other units of the 4th Corps.  On

 8     several occasions I personally went to Lukavica, which is the garrison

 9     where I had been posted before my arrival -- before my move to

10     Han Pijesak, and I knew a lot of officers there.  And I discussed this

11     issue with them as well and they most -- most of them had the same

12     opinion as mine or similar.

13        Q.   Thank you.

14             MS. GUSTAFSON:  And if we could have 65 ter 23158 on the screen,

15     please.

16        Q.   Mr. Dzambasovic, do you recognise this map as a map of Rogatica

17     municipality that you made some markings on a few days ago?

18        A.   Yes.  I recognise both the map and most of the places indicated

19     there.

20        Q.   Now, this is -- this map is discussed at paragraph 123 of your

21     statement.  I'd just like to ask a couple of further questions.  In

22     the -- just above the centre and just to the right of that, so in the

23     upper right-hand quadrant of the map, there's an oval-shape circle around

24     the village of Borika.  Is this the area that you marked in which

25     Rajko Kusic's unit operated as you describe in your statement?

Page 15153

 1        A.   That is the central part -- territory of his activities.

 2     However, the wider area is the area where he conducted patrols,

 3     Borika-Rogatica, Borika-Visegrad, and Borika-Zepa, those were the routes.

 4        Q.   And at the time of this map above Rogatica you've marked where

 5     the municipality of Han Pijesak appears just at the very top of the map.

 6     Which ethnic group was in the majority in Han Pijesak in 1991, if you

 7     know?

 8        A.   Well, I do know that perhaps not with absolute precision, but I

 9     know the Serb population had the majority.

10             MS. GUSTAFSON:  I tender that map, Your Honours, and I note that

11     we are waiting a translation of the B/C/S text that appears above the

12     map.

13             JUDGE KWON:  Are you suggesting to mark this for identification

14     pending that translation?

15             MS. GUSTAFSON:  Yes.  Thank you, Your Honour.

16             JUDGE KWON:  We'll do that.

17             THE REGISTRAR:  That will be MFI P2829, Your Honours.

18             MS. GUSTAFSON:  And if we could have 65 ter 07951 now on the

19     screen, please.

20        Q.   Now, this is a report of the 1st Podrinje Light Infantry Brigade

21     to the Drina Corps command dated the 25th of February, 1993, and signed

22     by Rajko Kusic.  This report, Mr. Dzambasovic, is discussed in some

23     detail at paragraph 119 of your statement.  So I'd just like to ask one

24     or two questions about it today.

25             MS. GUSTAFSON:  If we could go to page 2 of this document in both

Page 15154

 1     languages.  And if we could focus on the top third of the document.

 2        Q.   And approximately -- starting on the third line down there's a

 3     passage that begins:

 4             "At that time a group of about 40 Serbian young men, SDS

 5     activists, returned to Rogatica municipality and volunteered to attend

 6     courses for anti-sabotage activities in education centres in Pazaric,

 7     Pancevo, and Han Pijesak, taught by patriotic JNA officers.  That unit

 8     was the first organised formation of Serbian army in Rogatica

 9     municipality and it was deployed on plateau Borika from the 3rd of March,

10     1992."

11             Now, Mr. Dzambasovic, to what extent is that information in the

12     report consistent with the information you had at the time about the

13     formation of Rajko Kusic's unit?

14        A.   This information that is presented by Kusic as unit commander

15     absolutely correspond with the information that I provided to you in my

16     statement.  There's only one difference in view of a particular date.

17     Here it says the 3rd of March, but the arming of the unit and the

18     establishment of the unit actually took place in Gucevo on the 4th of

19     March, 1992, so there's just this one day of difference but that doesn't

20     really matter.

21        Q.   Thank you.  And if you could just look on the same page about

22     four lines down from where I just finished reading, there's a passage

23     that begins:

24             "During that time SDA armed forces introduced terror and genocide

25     against Serbian people of Visegrad municipality."

Page 15155

 1             And two lines further down it reads:

 2             "Immediately after Visegrad, SDA armed formations from Rogatica

 3     municipality started their activities as follows:  Maltreating Serbs and

 4     preventing them to join their working places, killing of soldier on

 5     leave, Mihajlovic Drazen, and attempting to kill villagers of Mandra in

 6     Borika area.  All this led Serbian people to confront Ustashas in the

 7     armed conflict and undertake certain military activities as the freedom

 8     of movement for the Serbian people was rapidly decreasing and the normal

 9     life was no longer possible."

10             Based on your knowledge of the situation in Rogatica and the

11     surrounding municipalities at the time, is this report on the threat by

12     SDA armed forces against Serbs accurate?

13        A.   The facts referred to in this report are absolutely inaccurate.

14     I personally talked to the representatives of the government in Rogatica,

15     or rather, of the Serb people, specifically with Mr. Batinic and Vujic,

16     and I never heard that they had any problems whatsoever in terms of being

17     terrorised by the Muslim people in any way.  However, we had a lot of

18     complaints from the organs of government and the Muslims, that it was the

19     Serbs who terrorised people in many areas and that that, indeed, had

20     happened.  So these facts are actually the other way around.  If they are

21     honest, the top people of the SDS in Rogatica can confirm this as well,

22     the persons I talked to at the time.

23        Q.   Thank you.

24             MS. GUSTAFSON:  I tender this report, Your Honours.

25             JUDGE KWON:  Yes, that will be admitted.

Page 15156

 1             THE REGISTRAR:  As Exhibit P2830, Your Honours.

 2             MS. GUSTAFSON:

 3        Q.   Mr. Dzambasovic, in your statement you described in some detail

 4     the arming of the Serb population and Serb volunteers in the Rogatica

 5     area, and I refer to paragraphs 41 through 75.  At the time that you left

 6     the JNA in early April, are you able to tell the Trial Chamber to what

 7     extent the Muslim population in Rogatica and its surroundings was armed

 8     compared with the Serb population?

 9        A.   I personally never went -- never dealt with that problem so I do

10     not know the actual statistics involved.  However, what I do know from my

11     conversations with many people, that is to say they had hunting weapons,

12     those who had them legally, and also they had some personal weapons, as

13     in military weapons that they had bought at the time,

14     assuming - well - there would be a crisis and what actually did happen

15     later would happen.  Now, I would not know anything more specific than

16     that.

17        Q.   So just to get back to my question, are you saying you're not

18     able to provide a comparison of the level of arming of the Muslim

19     population versus the Serb population?

20        A.   The Serb population was armed by the JNA, almost fully.  Compared

21     to that, the Muslim population was not armed.  So these statements are

22     absolutely correct, the extent to which somebody was armed or unarmed.  I

23     said that I did not know the actual numbers involved.

24        Q.   Thank you.  And in paragraphs 76 to 79 of your statement, you

25     explained that after the second mobilisation in September 1991, the

Page 15157

 1     relationship between the Serb officers in your brigade and the SDS was

 2     that of a brotherhood.  And you described how SDS officials from Rogatica

 3     and surrounding municipalities would frequently visit with

 4     Colonel Milosevic at the barracks.  Now, my question for you is:  Did

 5     Colonel Milosevic hold any similar meetings with politicians of other

 6     parties to your knowledge?

 7        A.   As far as I know, there were no meetings with politicians of

 8     other parties.  However, what happened primarily had to do with

 9     Srebrenica, Vlasenica, Olovo, Kladanj.  Activists of the SDS, they came

10     to the barracks and that was a precedent in army practice up until then.

11     That is what we, as professional soldiers, did not consider normal, to

12     see political representatives coming into army barracks and asking for

13     whatever.

14        Q.   And what message, if any, did this -- these activities and this

15     relationship send to you about the role of the JNA?

16        A.   Well, I personally, since I was Chief of Staff, that is to say,

17     ex officio deputy commander of the brigade, felt that the most.  Whenever

18     I had an opportunity, I discussed that with Commander Milosevic.  I also

19     talked to the corps commander to bring this practice to an end if we are

20     the JNA as such.  If we are going to honour the principles of how a

21     military organisation should function, then this practice has to be

22     brought to an end; however, that never happened.

23        Q.   Thank you.

24             MS. GUSTAFSON:  That concludes my examination-in-chief and I'd

25     just like to tender the associated exhibits other than the two that have

Page 15158

 1     been admitted.

 2             JUDGE KWON:  Any objections, Mr. Robinson?

 3             MR. ROBINSON:  No, Mr. President.

 4             JUDGE KWON:  Very well.  They will be admitted and given numbers.

 5             MS. GUSTAFSON:  And, sorry, Your Honour, one final matter.  I've

 6     just been informed by Mr. Reid that we now have a translation for

 7     MFI P2829, if that can be admitted now.

 8             JUDGE KWON:  The legend of the map?

 9             MS. GUSTAFSON:  Yes, Your Honour.

10             JUDGE KWON:  Yes, we take your word and that will be admitted in

11     full.

12             MS. GUSTAFSON:  Thank you.

13             JUDGE KWON:  Mr. Karadzic.

14             MR. ROBINSON:  Excuse me, Mr. President, before we commence the

15     cross-examination, I want to alert the Chamber that a part of the

16     cross-examination -- in fact a great part of the cross-examination will

17     relate to this witness's ability to give evidence relevant to our case

18     concerning the events in Sarajevo.

19             And Dr. Karadzic will be then proceeding under Rule 90(H)(i),

20     which allows him to ask questions other than those which are contained

21     within the scope of direct examination and I just wanted to alert you to

22     that.

23             JUDGE KWON:  Thank you.

24             Mr. Karadzic.

25             THE ACCUSED: [Interpretation] Thank you.

Page 15159

 1                           Cross-examination by Mr. Karadzic:

 2        Q.   [Interpretation] Good morning, Mr. Dzambasovic, and at the same

 3     time I wish to express my gratitude to you for having met with me and my

 4     associates before testifying here.  So I believe that that will help us

 5     in avoiding any kind of lack of clarity.

 6        A.   Good morning.

 7        Q.   Briefly I would like to remind you of what you said on different

 8     occasions so far.  For example, in the Kupreskic case, transcript page

 9     1255 [as interpreted], you say - and that was on the 29th of February,

10     1999 - that at the beginning the Army of Bosnia and Herzegovina had a

11     lack of clothing, so they fought against the Serbs wearing their own

12     civilian clothes; right?

13        A.   Well, yes.  For the most part that was correct in the beginning.

14        Q.   Thank you.  You also said, for instance, in your statement of

15     September 2002 and October 2002, paragraph 6 and paragraph 1, that, for

16     instance, officers who were non-Muslims, or rather, who were Serbs went

17     to these areas.  And I asked you during our interview whether it was

18     customary, for example, that in Belgrade, a Macedonian was commander of

19     the military district, like Apostolski, and then Avramovic, a Serb in

20     Zagreb elsewhere, and so on?

21        A.   Yes, as the army functioned from Slovenia to Macedonia, that's

22     the way it was.  However --

23        Q.   We'll get to that, we'll get to that.

24             JUDGE KWON:  Just a second.  What's the date of his first

25     statement in Kupreskic case?  1999?

Page 15160

 1             THE ACCUSED: [Interpretation] Yes.

 2             JUDGE KWON:  Thank you.

 3             THE ACCUSED: [Interpretation] 95-16-T, page 12255.

 4             JUDGE KWON:  Yes, please proceed.  Yes.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation].

 7        Q.   Then you said in your statement of September 2002 - October 2002

 8     on page 11, 30, 41, paragraph 9, 11, 342, that in 1990 in September the

 9     JNA in a way tried to restrict the Territorial Defence by way of the

10     decision of Bajcetic, commander of the Territorial Defence, that the arms

11     of the Territorial Defence be entrusted to the JNA, and you interpreted

12     that as an attempt to disintegrate the Territorial Defence.  Is that

13     correct?

14        A.   That is an official document, that is to say, of the republican

15     TO staff.

16             JUDGE KWON:  Yes.

17             MS. GUSTAFSON:  That's all right, Your Honour.  The question was

18     answered.  I was just going to ask for a precise quote from that

19     statement.

20             JUDGE KWON:  Thank you.

21             THE WITNESS: [Interpretation] May I proceed?  So this was an

22     official document of the commander of the republican staff of

23     Territorial Defence.  We professional soldiers, at the moment this

24     arrived in JNA units -- actually, the explanation given to us was that

25     this was a document that had to do with rationalisation, not to keep

Page 15161

 1     weapons in a single -- in two different locations but in a single one.

 2     From a certain point of view that was rational and normal, if you have

 3     two depots and then now you have one.  However, that was not the

 4     intention of this weapon transfer, it was the other way around.  The JNA

 5     wanted to control everything, all equipment, all weapons, so that at some

 6     point in time they would be the only ones that were able to use these

 7     weapons, that is to say, only the JNA not the Territorial Defence units

 8     in the area where they were.

 9             MR. KARADZIC: [Interpretation].

10        Q.   What I'm waiting for is the interpretation.  So I would like to

11     ask you kindly to pause a bit between my question and your answer so that

12     it can be interpreted.

13             Was this issued on the 13th of September, 1990, and was that

14     almost three months, or rather, two months before the first multi-party

15     elections?  Was that done by the old socialist, or rather, communist

16     government?

17        A.   Well, I don't know exactly when the elections were held.  I don't

18     know the exact dates.  If that was so, then yes.  If the elections took

19     place later, then that was done by the Territorial Defence, or rather,

20     the republican leadership of the TO and the JNA, the old ones as you had

21     put it.

22        Q.   Thank you.  Was your interpretation of this an assumption that

23     they were afraid of the outcome of the multi-party elections and that

24     they wanted to place arms under their own control?

25        A.   Well, we in the army, generally speaking, were against such

Page 15162

 1     elections.  On the basis of what people did not know but intimated that

 2     there would be this corralling into mono-ethnic enclosures, and that is

 3     what we found unacceptable.

 4        Q.   Thank you.  And then in your statement of September/October 2002

 5     in paragraph 4, and then in paragraph 3 as well, you confirmed that the

 6     SDA and the SDS obstructed mobilisation, saying to reserve officers and

 7     soldiers that they should not respond to mobilisation call-up and that

 8     even the police obstructed mobilisation in a way; is that right?

 9        A.   This was an absolute precedent and that is indeed what happened.

10     Both leaderships, both the Muslim and Serb leadership at the time of this

11     first mobilisation obstructed this mobilisation.  This was officially

12     confirmed by the leadership of the command of the 4th Corps in the report

13     on the realisation of this mobilisation, and I think that you have that

14     document.

15        Q.   Thank you.

16             JUDGE KWON:  Mr. Dzambasovic, if I could remind you again that

17     you need to put a pause between the question of Mr. Karadzic and your

18     answer so that the whole conversation could be interpreted into the

19     working languages of the Tribunal, please.

20             Yes, Mr. Karadzic.

21             THE WITNESS: [Interpretation] Very well.  Thank you.

22             THE ACCUSED: [Interpretation] Thank you, Your Honour.

23             MR. KARADZIC: [Interpretation]

24        Q.   Is it true that the JNA had their own assessment of the political

25     developments and that they based those assessments, or rather, that they

Page 15163

 1     had these assessments about why there was this kind of attitude toward

 2     mobilisation?

 3        A.   The JNA always made assessments and evaluated the situation.  In

 4     every scenario of planning, the former JNA also took into account the

 5     issue of the political situation in the area of responsibility and that

 6     in -- from the highest level up to the lowest levels.

 7        Q.   Thank you.  In your statement of 13th June 2000, in paragraph 7,

 8     you confirmed, or rather, you stated that the political leadership of the

 9     SDA and the SDS obstructed mobilisation, in late June 1991, or rather,

10     the 29th of June, 1991, and that only 60 per cent of people who received

11     the call-up actually responded?

12        A.   Yes, that's correct.  Those figures and percentages, I really

13     don't know them off the top of my head but if that's what I said then

14     that's what it was.

15        Q.   Thank you.  In the same statement in paragraph 6 you state that

16     that came as a surprise to you, the mobilisation itself, because in your

17     assessment it was expensive, complicated, and it disrupted the everyday

18     life of people.  And you said that that kind of mobilisation would be

19     normal in major crisis, but that you did not consider that your country

20     was in such a crisis at that point in time.  What did you mean by "your

21     country"?

22        A.   What I meant by "my country," I meant specifically the area of

23     responsibility of my unit, which is five to six municipalities, Rogatica,

24     Vlasenica, Han Pijesak, Sokolac, and we assessed that it was not

25     justified to mobilise the whole brigade because we had already had

Page 15164

 1     mobilisations before that but it was only a military exercise.  And when

 2     this came about we also considered it to be a military exercise.

 3     However, on this occasion the entire brigade was mobilised, which means

 4     all its resources, human, technical, materiel, everything had to be

 5     mobilised and that was way too expensive and too complicated.  And we did

 6     not believe that there were reasons justifying that kind of mobilisation

 7     at that time.

 8        Q.   Thank you.  At this time in Yugoslavia, was there an emergence of

 9     a new element when Croatia and Slovenia declared their independence and

10     the conflict in Slovenia began?

11        A.   Well, yes.  This was at a time when the conflict in Slovenia

12     broke out, that's correct.

13        Q.   Do you recall that at that time Slovenia took control of the

14     outer borders of Yugoslavia, the outer borders that were on Slovenian

15     territory?

16        A.   Yes, I do recall the TV programmes that we watched and also I

17     remember the reports that we received.  Practically Slovenia's TO took

18     control of its borders and the JNA then took their own steps.

19        Q.   If we were to assume that your country was Yugoslavia and not the

20     Romanija-Birac region, would your position then have been different?  So

21     if Yugoslavia was in jeopardy, would there be reason enough for

22     mobilisation?

23        A.   Well, in theory that's correct.  However, our unit was not a

24     large unit, not in terms of the entire Yugoslavia.  So had the 4th Corps

25     been mobilised, the entire 4th Corps, and had we been told that this was

Page 15165

 1     the crisis in question then perhaps that would have been justified.

 2     However, this was done at a local level and in such a way that we in fact

 3     never received a specific mission.  So that was totally absurd.  On the

 4     one hand your entire unit was being mobilised, and on the other hand you

 5     had no idea why that was the case, and that's how it was.

 6        Q.   But you yourself could not draw a parallel and a conclusion that

 7     because of the crisis in Slovenia that's why this was done?

 8        A.   Well, we could only assume that; however, neither in theory nor

 9     in practice was it ever the case that we would not know what our

10     assignment was.  And on this particular -- in this particular situation

11     we never received any specific assignment.  And then when we went with

12     part of our unit to Zaluzani near Banja Luka, again we had no idea why we

13     were doing that.

14        Q.   Thank you.  So you were moved, transferred to the west, towards

15     Slovenia, in other words, because Banja Luka is some 200 to 300

16     kilometres to the west, closer to the fighting in Slovenia?

17        A.   Yes, well certainly it's closer to Slovenia than Sarajevo, by all

18     means.

19        Q.   Thank you.  You say that up until the second mobilisation at the

20     end of July 1991 the SDA and SDS still had the same position vis-a-vis

21     the JNA and they were not inclined to support it; correct?

22        A.   Well, yes, you could say it that way.  At that first -- during

23     that first period in June and July, well, one could say that there was

24     general chaos both at the political and the military levels.

25        Q.   And then there was an occurrence where representatives of the SDA

Page 15166

 1     went to Zaluzani and re-called their supporters from the brigade that

 2     were posted in Zaluzani; correct?

 3        A.   Yes, correct.  At that time, representatives of the SDA from two

 4     municipalities, Rogatica and Vlasenica, arrived there and all those

 5     members who did respond to mobilisation, they re-called them, they put

 6     them on buses.  These people left all their weapons there in the meadows

 7     on the side of the road, they got on the buses, and went back home.

 8             THE ACCUSED: [Interpretation] Could we now please pull up --

 9     please bear with me.  I would like to show you a document on ELMO.

10             MS. GUSTAFSON:  Could I just ask if this is in the list of

11     cross-examination documents; and if so, a reference number.

12             THE ACCUSED: [Interpretation] I'm afraid it is not; however, if

13     you do object we can tender it on another occasion.  I just want to show

14     it to the witness to -- because of something that he has said.

15             MR. KARADZIC: [Interpretation]

16        Q.   Is this a document from the Socialist Republic of

17     Bosnia-Herzegovina, the Executive Council of Vlasenica, dated the 8th of

18     July, 1991, whereby our joint Presidency of Bosnia and Herzegovina is

19     being informed that, in early morning hours, citizens gathered in the

20     area of Vlasenica outside the city hall for mobilisation purposes.  And

21     it says that the Municipal Assembly had provided transportation and

22     the -- they organised transportation for those people who were mobilised

23     to be returned home.  Is this the document that is referring to that same

24     event?

25        A.   Well, yes, I would say think so.

Page 15167

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Could we tender this with an MFI?

 3             JUDGE KWON:  Ms. Gustafson.

 4             MS. GUSTAFSON:  Obviously, Your Honour, we have no ability to

 5     review this document at this time.  If we could reserve any objections we

 6     might have.

 7             JUDGE KWON:  We'll mark this document for identification.

 8             THE REGISTRAR:  As MFI D1373, Your Honours.

 9             THE ACCUSED: [Interpretation] Thank you.

10             MR. KARADZIC: [Interpretation]

11        Q.   And then in your statement of the 22nd, or rather, the

12     September/October statement of 2002, in paragraph 3 you say that Muslims

13     in July and then in September during the second mobilisation drive,

14     Muslims and Croats boycotted the mobilisation or that they responded in

15     order to return the weapons that had been issued to them; is that the

16     case?

17        A.   Yes, that's correct.  Well, basically there was some political

18     decisions that were made then, and as of September the response of

19     Muslims and Croats to call-ups was practically non-existent or very, very

20     small.

21        Q.   Thank you.  The crisis in Slovenia had by that time abated a

22     little; however, it had now moved to Croatia where there were blockades

23     of various barracks and so on; correct?

24        A.   Well, yes.  As far as I know there were several instances where

25     several barracks in Croatia were blocked by protesters.  I don't know

Page 15168

 1     exactly at what time that was.

 2        Q.   Thank you.  You then go on to say that on the 17th of September -

 3     and you stated that in your statement of 13th June, 2000 in paragraph 6 -

 4     that they -- that old plans had to be ignored and new plans had to be

 5     established -- had to be developed because the old plans had anticipated

 6     threats from NATO or the Warsaw Pact, whereas the situation on the ground

 7     was now different; correct?

 8        A.   Well, yes.  That was the major upset that happened then.

 9     Whenever a war-time plan was drawn up, it was the practice in the army

10     that the Chief of Staff together with his staff developed this plan and

11     the assignment would always be received from a superior command.

12     However, on this occasion I was told by my commander that all those old

13     plans had to be scrapped and that new plans have been drawn up.  In other

14     words, I was totally excluded from the planning, as well as all other

15     officers who were non-Serb.  I never saw the content of those plans, I

16     didn't know what they contained, and I don't know that to this day.

17        Q.   Well, we will get to the issue of distrust or trust that they had

18     in you, but let's move on now.  In the same statement, paragraph 7, you

19     say that it was almost exclusively Serbs who responded to this call-up

20     and that this upset the ethnic balance in the JNA and that it was only

21     then in September 1991 that the SDS and the JNA began drawing closer

22     together, or rather, could we say that the JNA was increasingly seeking

23     support from the Serbian ethnic group and asking for their assistance in

24     mobilisation?

25        A.   Well, I said that during the first mobilisation the position of

Page 15169

 1     the SDS and SDA were the same as far as mobilisation was concerned;

 2     however, during the second mobilisation their positions have changed.

 3     The SDS was in full support of the JNA and mobilisation at this time, so

 4     that is where the difference arose, that's where the positions changed.

 5     And that is something that I mentioned a little earlier when I said that

 6     SDS leaders from these municipalities which were in the area of

 7     responsibility of my brigade came to me announced and unannounced at all

 8     times of day and had contacts and meetings with Milosevic.

 9        Q.   Thank you.

10             JUDGE KWON:  Just a second.

11             MS. GUSTAFSON:  I'm sorry to interrupt, Your Honour, I just

12     wanted to point for the record that the previous question referring to

13     plans in anticipation of threats from NATO or the Warsaw Pact

14     mis-characterised the witness's prior statement.  It took me some time to

15     find it because the reference given by Mr. Karadzic was incorrect.  Thank

16     you.

17             JUDGE KWON:  Thank you.

18             You can move on, yes.

19             MR. KARADZIC: [Interpretation]

20        Q.   It's the statement from 2000, paragraph 5 one of these matters

21     and 6 the other one.  But basically -- yes, paragraph 6.  Basically --

22     actually, can you confirm that all the way up until that moment the

23     entire military doctrine, the doctrine of Yugoslavia, counted on threats

24     coming either from NATO or from the Warsaw Pact and that these plans had

25     become useless and changed; right?

Page 15170

 1        A.   Well, in this specific case in terms of what happened, that is

 2     true.  Until 1991, the JNA had war plans that included elaborated plans

 3     in case of an aggression either by NATO or the Warsaw Pact, so that is

 4     correct.

 5        Q.   Thank you.  Since you mentioned these contacts now between the

 6     local authorities and the JNA, let us establish one thing.  In that zone

 7     was it the SDS and the SDA that were in power?  Was there power-sharing

 8     in these municipalities where you were?

 9        A.   In all these municipalities -- well, it depended.  Where there

10     was a majority Serb population, Serbs held most of the important offices

11     and the other way around, so that is correct.  That is how they

12     functioned.  Now, I don't know the exact date when all of these

13     authorities were split up like the MUP and everything else, the Serb and

14     the non-Serb, et cetera.

15        Q.   For example, in Rogatica the president of the municipality was a

16     Muslim and Serb was the head of the Executive Council; right -- [No

17     interpretation]?

18             THE INTERPRETER:  The interpreter did not hear the end of the

19     question.

20             THE WITNESS: [Interpretation] I don't know who his deputy was but

21     I don't know whether he was a Muslim, but the majority population in

22     Han Pijesak was Serb, so I think both the chief and his deputy were Serbs

23     and there was a Muslim in the Executive Board.  I don't remember exactly.

24             MR. KARADZIC: [Interpretation]

25        Q.   Thank you.  Now, in your statement from September 2002 in

Page 15171

 1     paragraph 5 you said that Kusic was a volunteer in the army at that point

 2     in time and that he had not been mobilised, rather, he volunteered?

 3        A.   Exactly.  I had never heard of Kusic or seen him until then.  He

 4     appeared -- well, I don't know exactly how many times and I don't know

 5     how much that matters anyway, but very often he appeared as some

 6     representative of the SDS.

 7        Q.   Representative of the SDS or the representative of the local

 8     authorities?

 9        A.   Well, probably it is the local authorities from the area that he

10     came from.  I don't know which particular offices people held and that

11     was not exactly my line of work, so that's what I have to say.

12        Q.   Thank you.  Further on, you say in your statement of

13     September 2002, paragraphs 5 and 6, that in 1991 and in early 1992,

14     Milosevic, then-Colonel Milosevic, heard that in Vares the neighbouring

15     municipality, the HOS was established, the Croatian armed forces.  And he

16     disguised himself as a medical person and went out to reconnoitre; right?

17        A.   Yes, that's what he told me.  In the building of the municipal

18     staff that is on the outskirts of Vares, I didn't go there, there was a

19     unit with HOS insignia and he said that he went in an ambulance dressed

20     as a doctor or a nurse to that particular area to reconnoitre and that is

21     what he established.

22        Q.   Thank you.

23             MS. GUSTAFSON:  Your Honour, again that statement does not appear

24     in paragraphs 5 and 6 of the 2002 statement.

25             JUDGE KWON:  But the witness confirmed it.

Page 15172

 1             MS. GUSTAFSON:  Yes, Your Honour.  It just makes our job much

 2     more difficult if we don't get accurate references.

 3             JUDGE KWON:  I have no means to check whether it's correct or

 4     not, but please be precise in giving references, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Well, please give me enough time

 6     and then I'm going to be very precise, but that is contained in this

 7     paragraph, that the HOS was established and that Milosevic disguised

 8     himself as a doctor and went out to reconnoitre, that is contained

 9     somewhere else.  But we don't have enough time, so I am actually

10     summarising and I'm kindly asking Mr. Dzambasovic, who has been very kind

11     to us, to confirm but I really don't have time.

12             JUDGE KWON:  Then would you be happy, Ms. Gustafson, if

13     Mr. Karadzic just asked questions without giving any reference?

14             MS. GUSTAFSON:  Yes, Your Honour.

15             JUDGE KWON:  Let us proceed.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   You confirmed that, in the beginning of 1992 in Central Bosnia,

19     Muslim armed forces were established, the so-called M-O-S, MOS; right?

20        A.   I told you that that was a unit that was formed.  I don't know

21     the exact date officially, but you do have this document.  They were

22     established in the territory of Zenica.

23        Q.   The previous question, the H-O-S, the Croatian armed forces, do

24     you remember that that armed formation was established by the extremist

25     Croatian Party of Rights that is an heir to the Ustashi traditions of the

Page 15173

 1     Second World War?

 2        A.   Well, as regards all these names that were being used from the

 3     Second World War, that is what the JNA called them, all of those who were

 4     against us in the Second World War.  So this HOS is included.

 5        Q.   Thank you.  Please try to understand why I am waiting.  I am

 6     waiting for the interpretation and you can follow it yourself and you can

 7     wait for it to finish.

 8             This formation, the MOS, who did it report to?

 9        A.   According to the documents I saw, it was the 3rd Corps of the

10     BH army.

11        Q.   Thank you.  And before the Army of Bosnia-Herzegovina was

12     established, who did it report to?  Because you said that they were

13     formed in the beginning of 1992?

14        A.   Well, only God almighty knows that.  I never went in there, never

15     saw that unit.

16        Q.   Thank you.  During the interview I asked you and at the time you

17     could not remember information about the Patriotic League, when it was

18     established exactly and how it was organised.  Can you remember more

19     today?

20        A.   As far as the Patriotic League is concerned, I really don't know

21     anything.  I was not involved in this organisation in any way or from

22     then until the present day did I attend any meeting that had anything to

23     do with that.  Quite simply, I didn't want to do anything in that

24     connection.

25        Q.   Thank you.  What about the JNA and the intelligence service of

Page 15174

 1     the JNA, were they following this mass organisation called the

 2     Patriotic League?  Did you hear of this kind of monitoring and analysis?

 3        A.   As a JNA officer, of course I heard about it.

 4        Q.   Thank you.  Did you hear that in September 1991 the SDA passed a

 5     decision on the active monitoring of everything that was happening in the

 6     Yugoslav People's Army?

 7        A.   No.  This is the first time I hear of it, so it is only right

 8     this moment that I know it.

 9        Q.   Thank you.  Do you agree that such activities are forbidden by

10     the Law on Defence and the Army and the Law on All People's Defence?  I'm

11     not asking you to confirm that they were doing that, but is it not

12     generally known that that is forbidden, spying on the army?

13        A.   Well, that's a question that is both complicated and simple.  All

14     armies in the world are being spied on and it is forbidden to spy on any

15     army in the world.

16        Q.   Thank you.  Then you stated that meetings were held in

17     February 1992 between the minister of the interior, Alija Delimustafic;

18     the chief of state security of Bosnia-Herzegovina, Branko Kvesic;

19     Delimustafic's deputy, Vitomir Zepinic; then-Colonel Vasiljevic; Tumanov;

20     Simic; and Colonel Milosevic.  And then, as you said, they divided up

21     tasks between the JNA and the MUP and it was Aleksandar Vasiljevic who

22     informed you about that, he was a colonel then.  Is that correct, that in

23     February 1992 they were involved in the same mission, the same task, the

24     army and the MUP?

25        A.   I was not present at the meeting itself that was held, but I was

Page 15175

 1     there in that particular location.  As for Aco Vasiljevic, I had a very

 2     close relationship with him because for a while he was my commander.  As

 3     we were having coffee he told me that they tried to regulate obligations

 4     with the MUP by way of providing for the safety of citizens through the

 5     establishment of joint patrols that would include representatives of the

 6     army and representatives of the MUP.  From time to time these patrols

 7     would go to trouble spots in that area of responsibility.

 8        Q.   Thank you.  Do you know that when there was a lack of manpower in

 9     the JNA the Presidency of the SFRY reinforced their decision on the right

10     to involve volunteers in the JNA?

11        A.   At the time I did not have very specific information, except that

12     Milosevic had informed me that this method would be applied, namely, that

13     volunteers would be taken into army units.  Later on I saw documents

14     supporting that.

15        Q.   Thank you.  Do you agree that in our system every reserve officer

16     and every reserve soldier had his war-time assignment and was considered

17     to be a soldier in the reserve who could be called up or who could

18     volunteer if there were to be a war crisis?

19        A.   Well, the Law on National Defence and on military obligation

20     regulated that in detail.  I'm not aware of each and every detail right

21     now, but that was the way it was.  All of those who were of military age

22     and were able-bodied were deployed in various units.  Those who were not

23     able-bodied were in the civilian protection and in other units in order

24     to help in possible crises.

25        Q.   Or were supposed to have work obligation as their own war

Page 15176

 1     obligation; right?

 2        A.   There was that possibility too, work obligation in case there was

 3     a crisis.

 4        Q.   Thank you.  Further on you say that towards the end of March,

 5     from the 24th until the 26th, a crisis broke out in Rogatica.  Roadblocks

 6     were set up and they were removed at the intervention of

 7     Colonel Milosevic; right?

 8        A.   These roadblocks were placed in the second half of March.  In

 9     relation to that, the political leadership from Rogatica provided us with

10     information and the corps commander, General Djurdjevac, and from my

11     brigade it was Milosevic and myself, we went to Rogatica.  We held a

12     meeting with the leadership of the municipality.  They informed us about

13     the situation in detail.  And then practically we went out to remove the

14     roadblocks.  The first roadblock was the one that was placed by the

15     Muslims, and then about 500 metres away from that, on the road leading

16     from Rogatica to Borika on the bridge, there was a Serb roadblock.  This

17     roadblock that was placed by the Muslims, they removed straight away, as

18     soon as I walked out.  It was just formal.

19             When we came to the barricade that was placed by the

20     Serbs - maybe I should put this in soldierly fashion - the soldiers that

21     were around the roadblocks, Serb soldiers, they threatened us a bit.  And

22     then Milosevic got out of the car, went up that hill where the army had

23     been deployed, spoke to Kusic, came back, and half an hour later the

24     Serbs removed their roadblock as well.

25        Q.   Thank you.  Today on page 8 of today's transcript you confirmed

Page 15177

 1     that as for the area of responsibility of your brigade the young men who

 2     were trained in Pazaric, Pancevo, and Han Pijesak had returned to it.  Is

 3     Pazaric basically 100 per cent Muslim; and the infrastructure in Pazaric,

 4     Pancevo, and Han Pijesak, did that belong to the JNA?

 5        A.   I'm sorry.  First of all, I think that you did not word the very

 6     beginning properly.  Could you just repeat what you said.

 7        Q.   On page 8 you confirmed that at the time -- actually, you

 8     confirmed what was written by --

 9        A.   Yes, that's right.

10        Q.   -- what Kusic wrote in his report, that at the time these young

11     men came back, those who had trained in Pazaric, Pancevo, and

12     Han Pijesak.  The first question:  Is Pazaric practically 100 per cent

13     Muslim populated?

14        A.   Pazaric is a very small local commune.  Its population is about

15     1500.  Since that was a training centre for all units that were

16     completing the military academies in Sarajevo, yes.  As for the structure

17     of the population itself, it was majority Muslim.  I asked you to correct

18     what you said because it wasn't me, I didn't write that.  That's what

19     Kusic wrote in his report, and I confirmed that that was a training

20     centre, Pazaric is, Pancevo is -- or rather, they were, in the JNA.

21        Q.   Thank you.  Here you also state that the Zepa commander,

22     Avdo Palic, Lieutenant-Colonel Avdo Palic, informed you of his contacts

23     and meetings and my arrival, my and Dukic's visit to Han Pijesak, and the

24     movement of the political leadership; correct?

25        A.   Avdo Palic at the time was a member of our command; he was an

Page 15178

 1     artillery officer.  And at this time when government representatives who,

 2     as I had already mentioned, began to work closely with the JNA and since

 3     he was in Han Pijesak at the time -- in that area at the time, he

 4     informed me in Han Pijesak on several occasions that you and Rajko Dukic

 5     went there on a couple of occasions where you held some meetings but he

 6     didn't know what those meetings were about, nor did I.

 7        Q.   Thank you.  Where were those meetings held, with whom?

 8        A.   Well, with Commander Milosevic, but I don't know exactly where it

 9     was, whether it was in Han Pijesak or elsewhere, I don't know.

10        Q.   Thank you.  On the one hand you say that you knew that

11     Colonel Milosevic was distrustful of you, and on the other hand

12     Avdo Palic trusted you, as well as other officers, non-Serb

13     officers - and this is what you said on pages 5 and 6 of today's

14     transcript and you confirmed it today - when you said that other non-Serb

15     officers came to you to inform you of their concerns.

16        A.   Well, yes, that's totally logical and it's correct.  Milosevic

17     and I were on very good terms up until the first mobilisation.  We went

18     out together every evening, we took walks.  After that, when what

19     happened happened, I can say that he did not dare go out with me anymore,

20     not because he was afraid of me but because he was banned from doing that

21     or he was -- there was a ban imposed on him from doing that by the Serb

22     people.

23             THE ACCUSED: [Interpretation] Could we now briefly take a look at

24     1D3708.

25             MR. KARADZIC: [Interpretation]

Page 15179

 1        Q.   Is this a document from the 4th Corps command, the security organ

 2     is sending information on what they learned about the activity of the SDA

 3     in the territory of Han Pijesak, and this was on the 30th of October,

 4     1991; correct?

 5        A.   Yes, that's correct, if that's what it says.

 6        Q.   Thank you.  They inform here that they had a conversation with

 7     Jusuf Jusufovic.  Did you know this man?

 8        A.   I knew the man personally.  For a while he was the chief of the

 9     municipality and for a while Milosevic and he and I were friends

10     together, and even during the euphoric period when weapons were being

11     distributed he was one of those that got a weapon.

12        Q.   Thank you.  Is it correct that this Jusuf Jusufovic felt unsafe

13     because of his pro-Yugoslav stance and that's why he was issued a weapon

14     for his own personal protection?

15        A.   Well, listen, that's how it was at the time.  There were

16     individual people, Muslims, Serbs, or Croats, at the time who had a

17     different take on everything, they had a different view of the situation

18     of -- or rather, their views departed from what had happened during the

19     multi-party elections.  And all those people were in jeopardy of sorts,

20     they were unsafe.

21        Q.   Would you please take a look at the part of the report where it

22     refers to the situation in Rogatica and Vlasenica on villages that wanted

23     to establish a new municipality and then that the SDA leadership had

24     numerous contacts with Osman Brka and Irfan Ajanovic.

25             THE ACCUSED: [Interpretation] And then could we have the next

Page 15180

 1     page, please.

 2             MR. KARADZIC: [Interpretation].

 3        Q.   Do you agree that the JNA is referred to here -- that the JNA's

 4     here in fact pointing out these people:  Salih Mehovic, Muhamed Kuc,

 5     Himzo Mujkic, Mehmedalija Memisevic, Jusuf Ivojevic, Enes Jusupovic - not

 6     the Jusuf Jusufovic - that they point them out as extremists here.

 7             THE ACCUSED: [Interpretation] Now can we have the next page.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Were you aware of these assessments of the people?

10             JUDGE KWON:  Before you answer.

11             Yes, Ms. Gustafson.

12             MS. GUSTAFSON:  I heard a question there and I'm not sure the

13     witness had the chance to read the page and answer the question.

14             JUDGE KWON:  Would you like to read that document again, the

15     previous page, or are you following the question?

16             THE WITNESS: [Interpretation] I did understand the essence by

17     looking at this; however, unfortunately, this document, since it was

18     produced by the JNA, we should have been the first to receive it, we the

19     people in the unit and this is, in fact, the first time that I see it.

20             THE ACCUSED: [Interpretation] Can we just scroll down to the end

21     so that we see whose signature appears there.  That's on the following

22     page.

23             MR. KARADZIC: [Interpretation]

24        Q.   Do you know a Lieutenant-Colonel Petar Simovic?  Was he in the

25     intelligence service of the 4th Corps?

Page 15181

 1        A.   I know him personally.  He too attended a meeting where Tumanov,

 2     Vasiljevic, Delimustafic, and the others that we mentioned a moment ago

 3     were, so I know him personally, I know Simovic personally.  He was the

 4     chief of security.

 5             JUDGE KWON:  Can we see the first page.

 6             Mr. Dzambasovic, I take it this is a report of information

 7     written by security service in the JNA corps command.  Did the -- did a

 8     Chief of Staff in a brigade receive all the reports written by the

 9     security service in the corps command?

10             THE WITNESS: [Interpretation] Your Honour, this report was

11     drafted by the 4th Corps command.  However, the information contained in

12     it came from my assistant for security, the assistant in my brigade.

13     This happened in the area of responsibility of the 216th Brigade, all of

14     the events mentioned here.  My organ or the individual in the brigade who

15     was in charge of security was supposed to inform me of this and of course

16     then forward this report, as he did.  And in fact, this is the first time

17     that I see it, this report.  My assistant, my organ, was not

18     Lieutenant-Colonel Simovic, it was a captain --

19             THE INTERPRETER:  The interpreter did not catch the name.

20             THE WITNESS: [Interpretation] -- it was his responsibility to

21     show me a document of this nature and then forward it to the command,

22     whereas here we see that this document is sent by the 4th Corps command

23     as information, as a report.  I don't know if this is sufficient by way

24     of answering.

25             JUDGE KWON:  Then my question is again whether a report by the

Page 15182

 1     security in the brigade go through a Chief of Staff or commander of the

 2     brigade to the upper level security organ?

 3             THE WITNESS: [Interpretation] I understand your question.  The

 4     security organ reported to the commander, or rather, the Chief of Staff.

 5     It could forward the information without informing -- without our

 6     knowledge.  However, he would have to inform us subsequently that he had

 7     done that.  In other words, he could send, as a security organ,

 8     independently a report to his superior security organ, yes.

 9             JUDGE KWON:  Thank you.

10             Back to you, Mr. Karadzic -- I note the time.  It's time to take

11     a break.  And we'll have a break for half an hour and resume at 11.00.

12                           [The witness stands down]

13                           --- Recess taken at 10.32 a.m.

14                           --- On resuming at 11.04 a.m.

15             JUDGE KWON:  I don't see the witness.

16             I was told that, Mr. Karadzic, you have something to raise with

17     us.

18             THE ACCUSED: [Interpretation] Yes.  Thank you for giving me this

19     opportunity.  I'd like to say, or rather, to remind you that I agreed

20     that General Karavelic's statement should be admitted because at that

21     point in time he was on the list of Prosecution witnesses.  However, once

22     the statement was admitted, the Prosecution withdrew the witness and it

23     was transformed into a 92 bis.  This witness here is our last opportunity

24     to hear from a commander of the BH army about the developments in

25     Sarajevo, what the balance of forces was, and what the circumstances

Page 15183

 1     were.  It is based on this that I am seeking additional time because the

 2     Defence could find this witness's evidence helpful.  The question of time

 3     is a great obstacle for the Defence.  I do make a lot of errors because I

 4     try to shorten my questions and I try to do as much as possible in as

 5     little time as possible, and it is to my detriment more often than not.

 6             JUDGE KWON:  Two questions.  I didn't follow your comment on

 7     General Karavelic's statement.  Probably Prosecution can help us.  In

 8     what context did we admit that and could -- do you have that number for

 9     that -- or Mr. Robinson?

10             THE ACCUSED: [Interpretation] I can do that.  I offered one

11     passage from the statement where General Karavelic states that the

12     Sarajevo Romanija Corps engaged artillery just as his 1st Corps did.  The

13     Prosecution then tendered the entire statement into evidence.  Now, since

14     this witness was on the list of the coming witnesses, I did not oppose

15     the application.  Now, once the Prosecution got -- once their application

16     based on 92 bis was granted, they withdrew the witness.  And this witness

17     here who is now testifying is a senior officer of the BH army and he's

18     one of our last opportunities to talk to and elicit information on what

19     the events in Sarajevo were.

20             JUDGE KWON:  I'll come to the second issue.

21             Yes, Ms. Gustafson.

22             MS. GUSTAFSON:  Thank you, Your Honour.  Just on the point of

23     General Karavelic's statement, if Your Honours please, Ms. Edgerton knows

24     more about that than I do if she could address the Court on that issue.

25             JUDGE KWON:  I'm not sure she knows the issue.  I think it arose

Page 15184

 1     in recent days, but I don't think that has direct relation to this issue.

 2             I'll come to this issue.  I read this witness's 92 ter statement,

 3     but nowhere I found what he did during the war.  But you referred to him

 4     as being a commander of the ABiH?

 5             MR. ROBINSON:  Yes --

 6             JUDGE KWON:  Do you confirm that, Ms. Gustafson?

 7             MS. GUSTAFSON:  Yes, Your Honour.  And you're correct, that none

 8     of that evidence appears in his statement because that's not the reason

 9     that we called the witness and that's not the topics that we elicited

10     from him, but it is correct.

11             JUDGE KWON:  But as a commander of the ABiH he may be able to

12     answer questions in relation to Rule 90(H) questions.

13             MS. GUSTAFSON:  He may, Your Honour.  And we leave it in the

14     Court's hands.  I just point out that, because this is an entirely new

15     topic that is not covered in the evidence that the Prosecution elicited,

16     it's very short notice for us to deal with these new topics and the

17     documents.  And if the accused would like to do this in the future I

18     think it would be fair that we have some advance notice that this will be

19     done and of the documents that will be used on these topics falling under

20     90(H).  Thank you.

21             JUDGE KWON:  Do you know what rank and what position he took

22     during the war, what commander he was?

23             MS. GUSTAFSON:  I believe at some point, the point the accused is

24     interested in, he was the Chief of Staff of the 1st Corps of the ABiH.

25             JUDGE KWON:  And the rank?

Page 15185

 1             MS. GUSTAFSON:  At some point he became a general, but I can't

 2     confirm when.

 3             JUDGE KWON:  Thank you.

 4             THE ACCUSED: [Interpretation] If I may respond and explain.

 5             JUDGE KWON:  Yes.

 6             THE ACCUSED: [Interpretation] Starting from late 1992 up until

 7     autumn of 1993, the witness was the Chief of Staff of the 1st Corps.  In

 8     the course of the interview he was kind enough to make certain markings

 9     on our maps that we would like to present here today.  I think this

10     should have been a clear indication enough of our interest in these

11     matters, all the more so since the list of Prosecution witnesses does not

12     include Mr. Karavelic any longer.  He's been transformed into a 92 bis

13     witness and there are no other witnesses on their list who could testify

14     to these issues.

15             JUDGE KWON:  In addition to this session, how much longer would

16     you need to conclude your cross-examination, Mr. Karadzic?

17             THE ACCUSED: [Interpretation] At least until the end of today if

18     I cannot be granted any more time tomorrow.

19                           [Trial Chamber confers]

20             JUDGE KWON:  You'll have that, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you very much.

22             JUDGE KWON:  But if you could -- we'll see how it proceeds.

23             Let's bring in the witness.

24             MS. GUSTAFSON:  Just for the record, Your Honour,

25     General Karavelic is not a 92 bis witness.  This witness was dropped from

Page 15186

 1     our witness list.

 2             JUDGE KWON:  Yes, that's what Mr. Karadzic said.

 3             THE ACCUSED: [Interpretation] But his statement remains.

 4             JUDGE KWON:  I don't think it has anything to do with this

 5     witness.  Let's get on with the evidence.

 6                           [The witness takes the stand]

 7             JUDGE KWON:  I apologise for your inconvenience.  There was

 8     something we need to deal with in your absence.  Please make yourself

 9     comfortable, General.

10             THE WITNESS: [Interpretation] Thank you.

11             JUDGE KWON:  Yes, Mr. Karadzic.

12             THE ACCUSED: [Interpretation] Thank you.

13             MR. KARADZIC: [Interpretation].

14        Q.   We left off discussing the document by the security and

15     intelligence structure.  Can you tell us, did this service, security and

16     intelligence service, have its own chain of command in addition to

17     commanders and deputy commanders?  Did it have its own chain of command

18     to the top?

19        A.   Yes, it did.  It was referred to as the professional chain of

20     command, as it were.  All the other services had their own respective

21     chains of command and were in touch one with another.

22        Q.   Thank you.

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

24     please.

25             MS. GUSTAFSON:  No objection.

Page 15187

 1             THE ACCUSED: [Interpretation] We have the translation.

 2             JUDGE KWON:  Did you say you have translation for this?

 3                           [Trial Chamber and Registrar confer]

 4             JUDGE KWON:  I was told that it seems to exist but it hasn't been

 5     uploaded, but for the clarity why don't we mark it for identification for

 6     some time.  We give the number.

 7             THE REGISTRAR:  As MFI D1374.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Another clarification, please.  Do you agree that

10     Jusuf Jusufovic, who was of pro-Yugoslav and pro-JNA orientation was a

11     Muslim?

12        A.   Yes, that's right.

13        Q.   Thank you.  I would now like to take you back to our discussions

14     during the interview.  Do you agree that the structure of the Army of

15     Bosnia-Herzegovina, the make-up of it, was more or less a reflection of

16     that in the -- of that in the JNA?

17        A.   Yes, you are right.  It made no sense to change the structure.

18     It was better to simply assume it.

19        Q.   Thank you.  Do you agree that the better part of active-duty

20     officers holding important positions in the Army of Bosnia-Herzegovina

21     had originally come from the JNA?

22        A.   Yes.  This was definitely true for the corps level.  At the level

23     of corps we had former JNA officers.  At lower-level commands there were

24     both JNA officers and officers who had not been active-servicemen up to

25     that point.

Page 15188

 1        Q.   Were they reserve force officers and officers who were simply

 2     more capable than others?

 3        A.   Yes.  There were those who had come from the reserve force as

 4     well as those who had not been soldiers but had the requisite

 5     qualifications for specific posts.  For instance, construction engineer

 6     or a mechanical engineer, he could have been in the technical service; an

 7     economist could have been assigned to a quartermaster service, et cetera.

 8        Q.   Thank you.  Because of the shortage of time, I have to skip over

 9     many topics, although you would have been a precious witness on these

10     issues.  You did confirm that as an army you had major difficulties with

11     lower-level commanders, some of whom were outright criminals.  For

12     instance, up until the autumn of 1993, Caco and Juka Prazina were

13     commanders and this was a major problem in Sarajevo; is that right?

14        A.   Yes, that's absolutely correct.  A number of officers holding

15     commanding positions at crucial points when certain structures were being

16     reorganised or when the Army of Bosnia-Herzegovina wanted to introduce

17     order and put in place a proper military structure in keeping with

18     regulations, a decision was made that such commanders should be properly

19     rid of.

20        Q.   Thank you.  In November of 1992 you relocated to Sarajevo and

21     became the Chief of Staff of the 1st Corps.  You stayed in this position

22     until when exactly in 1993?

23        A.   Sometime in August 1993, I think mid-August 1993 when I

24     transferred to the General Staff.

25        Q.   Was this a promotion?

Page 15189

 1        A.   Well, in our structure, yes, it was.

 2        Q.   Thank you.  Mr. Dzambasovic, I would now like to present to you

 3     what it is that we know.  I will not be referring to all the documents,

 4     only the more relevant ones.  I will tell you what we knew about the

 5     disposition and the infrastructure and the forces of the 1st Corps in

 6     Sarajevo proper.  Do you agree with me that the 1st Corps deployed some

 7     of its forces in the town proper and others in Hrasnica, atop Igman, at

 8     Pazarici and Tarcin, and elements of its forces were to the east of

 9     Nisici plateau and the general area.  Is that right?

10        A.   The 1st Corps had a very broad area of responsibility and

11     included elements of forces in the town and elements of forces in the

12     general area.  I think you have that information on the map.

13        Q.   You told us that it wasn't possible to adhere to all the rules of

14     engagement when it came to the evacuation of civilians and infrastructure

15     as well as in positioning headquarters and weapons further away from

16     residential areas; is that right?

17        A.   Yes, that's absolutely correct.  Since the area of responsibility

18     in the town was a very narrow strip, it was impossible to make sure that

19     military units go about their daily business and engage in combat outside

20     of residential areas.  It was impossible because of the lay of the ground

21     and because of the way the area of responsibility ran.

22        Q.   Thank you.  With your assistance I'd like us to go through the

23     situation as it existed during the time when you were Chief of Staff.

24     Please answer with a yes or no or I don't know to save time.  Of course

25     you're quite free to say -- to confirm or simply say that that was not

Page 15190

 1     the case or that you don't know.

 2             Did the 1st Corps have up to 60.000 men in Sarajevo?

 3        A.   According to the information I had, that was roughly the figure,

 4     around 60.000 soldiers.  There are documents specifically listing the

 5     head count as per individual units.  This is something that I cannot tell

 6     you off the top of my head.

 7        Q.   Under whose command was the special or the guards unit called the

 8     Black Swans?

 9        A.   The unit was part of the 1st Corps and the General Staff.  It

10     changed over time but I can't tell you exactly what these times were.

11     But at any rate, it was both a part of the 1st Corps and the

12     General Staff.

13        Q.   Which -- so if the first commander of the armed forces was

14     Sefer Halilovic and then it was Rasim Delic; is that right?

15        A.   Yes, and before Halilovic there was Hasan Efendic, he was the

16     commander of the republican TO staff.  He was replaced by Sefer and he in

17     turn was replaced by Delic.

18        Q.   Is it true that the command of the armed forces of

19     Bosnia-Herzegovina was in the Branica company premises across from the

20     central prison facility in Sarajevo?

21        A.   Right.

22        Q.   Is it true that General Stjepan Siber, a Croat, and Jovan Divjak,

23     together with their associates, were stationed in the Svjetlost

24     publishing house, across from the town market?

25        A.   Yes.  General Divjak was in the Svjetlost building but

Page 15191

 1     General Siber was elsewhere, I can't tell you where exactly or what

 2     the -- I know where it is, a couple of -- 300 metres away but I don't

 3     know what the name of the building was.

 4        Q.   But that's at any rate close to the town market where the park

 5     dedicated to literary writers is?

 6        A.   That's close to the JNA hall.  The Svjetlost building is across

 7     from the town market.  Now, Siber was in a building which was close to

 8     the JNA hall and I can't recall the name of it.

 9        Q.   It was the Vase Miskina Street now called the Ferhadija street

10     that divided the town marketplace from the JNA hall?

11        A.   Yes.

12        Q.   Did the Main Staff building the Paljike airfield during the war

13     between Visoko and Kakanj?

14        A.   No.  It was not finished, although construction works did start.

15        Q.   Thank you.  Did the 1st Corps of the BH army have within it 15

16     brigades, and before your arrival there and before you transformed it, it

17     also had several reserve units?

18        A.   Before I took up my duty there, the corps had several small

19     units.  I don't know whether there were 15.  I could tell you what they

20     were called.  Well, let's say 15 more or less.  At a certain point in

21     time, we reorganised the corps in order to amalgamate these units and

22     improve the system of control and command.

23        Q.   And this reorganisation coincided with your arrival within the

24     corps?

25        A.   Well, it happened two or three months later.  We carried out this

Page 15192

 1     reorganisation together with General Staff members.

 2        Q.   Thank you.  The first commander of the 1st Corps was

 3     Mustafa Hajrulahovic, was he not, a former JNA officer; and he was

 4     replaced by Vahid Karavelic, another former JNA officer.  Is that right?

 5        A.   That's right.

 6        Q.   Thank you.  The Chief of Staff, Asim Dzambasovic, likewise, a

 7     former JNA officer; as well as Esad Pelko, Ismet Dahic, Mesud Dzenanovic,

 8     et cetera?

 9        A.   Ismet Dahic was not in the 1st Corps during my time there.

10        Q.   Thank you.  I have to skip some of these positions.  Imsirevic

11     was from the JNA, Ekrem Imsirevic was from the JNA, Dervisevic was from

12     the JNA; is that right?

13        A.   Yes.

14        Q.   Thank you.  The command of the 1st Corps of the BH army, was it

15     posted in the building of the former Radio Sarajevo across from the

16     Jugobanka building?

17        A.   Yes, that's where the command of the 1st Corps was at number 7.

18        Q.   Thank you.  Did the operations centre or was the operations

19     centre at the disco in Danijela Ozme street, also number 7?

20        A.   Yes.

21        Q.   Thank you.  Did the -- was the forward command post of the

22     1st Corps in the building of Visoko in the Siz building in Novo Sarajevo

23     settlement?

24        A.   While I was the Chief of Staff -- while I was the Chief of Staff,

25     the 1st Corps did not have a forward command post.  After 1994 there was

Page 15193

 1     a former -- forward command post in Visoko.

 2        Q.   Thank you for the clarification.  I would just appreciate the

 3     interpreter to correct something.  The street is Danijela Ozme Street

 4     number 7, across from the Jugobanka building.  Is it correct that this

 5     street, Danijela Ozme, is some 400 to 500 metres away from the Presidency

 6     of Bosnia building?

 7        A.   Yes, that's correct.

 8        Q.   Now I would like to list the brigades that existed and were then

 9     amalgamated.  There was the 1st Muslim Brigade in Buca Potok sector;

10     correct?

11        A.   The 1st Muslim was not there.  It was the 1st Motorised Brigade.

12     The MTVR means the motorised brigade.  PBR stands for mountain brigade.

13        Q.   Thank you.  So the 1st Motorised Brigade was at Bistrik; correct?

14        A.   The 1st Mountain Brigade.  If you know the garrison command,

15     where that was, it had some facilities, some barracks facilities, which

16     was on the premises or within the perimeter of the former JNA garrison.

17        Q.   Well, I'm using the old names and I believe that you assume those

18     same names.  So was the 1st Brigade --

19             THE INTERPRETER:  Could the accused please repeat the name of the

20     brigade.

21             JUDGE KWON:  The interpreters couldn't follow the names of the

22     brigade.

23             MR. KARADZIC: [Interpretation].

24        Q.   The 1st Mountain Brigade was, in other words, in the sector

25     Bistrik, the 1st Motorised in Buca Potok sector.  Was the 12th Brigade at

Page 15194

 1     first in Vogosca and then later it was renamed and became the

 2     111th Brigade?

 3        A.   It was in that area, however, not in Vogosca itself but west of

 4     Hum in the direction of the traffic engineering faculty and across from

 5     the Pretis building, towards Poljane.

 6        Q.   Thank you.  Was the 2nd Motorised Brigade in the area of

 7     Alipasin Most and the neighbourhood of the same name?

 8        A.   Yes.

 9        Q.   Was the 3rd Motorised Brigade in Stup?

10        A.   Yes.  Later on it was renamed and became the 102nd Brigade.

11        Q.   Was the 4th Motorised Brigade in Hrasnica?

12        A.   Yes.

13        Q.   Was the 3rd Mountain Brigade deployed in Sedrenik area?

14        A.   Yes.

15        Q.   It later became 105th Brigade; correct?

16        A.   Yes.

17        Q.   Was the 5th Motorised -- Mountain Brigade in Dobrinje settlement?

18        A.   The 5th Motorised Brigade before March was in Dobrinje.

19        Q.   Thank you.  Was the 6th Mountain Brigade in Hrasno area and

20     Hrasno Brdo?

21        A.   Yes, it was in the area of Hrasno Brdo up until the

22     restructuring.  After that, together with 105th, it merged with the 105th

23     and became 101st.

24             THE INTERPRETER:  Interpreter's correction.

25             MR. KARADZIC: [Interpretation]

Page 15195

 1        Q.   Thank you.  Was the 7th Mountain Brigade in Kosevo area?

 2        A.   Yes.

 3        Q.   Was the 8th Motorised Brigade deployed in the very centre of town

 4     near Skenderija?

 5        A.   Well, I have never heard of the 8th.  Maybe there was another

 6     name but the 8th was certainly not.

 7        Q.   What about the 9th Motorised, was it also down-town?

 8        A.   That's what was later -- that was later the 105th.

 9        Q.   And the 10th Mountain Brigade?

10        A.   Well, that's the so-called Tarcin Brigade.  It was on the

11     northern slopes of Trebevic and Zlatiste.

12        Q.   Thank you.  The 11th Mountain Brigade, that was in Vasin Han;

13     correct?

14        A.   I don't know anything about that brigade.  That may have been

15     before my time, that's the 2nd -- the 152nd Brigade.

16        Q.   Yeah, that's what it became later.

17        A.   Yes.

18        Q.   Thank you.  And the 13th Specialised Brigade was at Stup;

19     correct?

20        A.   Well, probably those small units, all these names, the 13th, I

21     don't know it but probably that's because all those lesser units were

22     later merged into larger units.

23        Q.   Thank you.  Now, talking about the 185th, that was the

24     2nd Mountain Brigade in 1992.  Is it correct that its command post was on

25     the premises of the foreign languages school in Vase Miskina Crni Street

Page 15196

 1     number 17?

 2        A.   Yes, it was in Vase Miskina Street.  I didn't know the name of

 3     the building itself but it was on Vase Miskina Street, I can confirm

 4     that.

 5        Q.   An auxiliary command post was on the premises of the barracks --

 6             THE INTERPRETER:  The interpreter did not catch which barracks.

 7             THE WITNESS: [Interpretation] Well, that was the logistics unit

 8     that was there.  They had a forward detachment -- a forward squad

 9     deployed elsewhere.

10             MR. KARADZIC: [Interpretation]

11        Q.   Well, later on we are going to show in e-court the composition of

12     152nd.

13             THE ACCUSED: [Interpretation] Could we please have 1D3699 in

14     e-court.

15             MR. KARADZIC: [Interpretation].

16        Q.   Do you recognise this area?  We see the command of the 152nd at

17     Vasa Miskina and on top we see the command of the 3rd Battalion.  Is this

18     the area of responsibility of this brigade, the 2nd Mountain Brigade,

19     which later became 152nd Brigade?

20        A.   Well, according to the way it is configured here, yes, although I

21     can't see any command posts that would be denoting that that is the area

22     of responsibility, at least I can't see it shown here.

23             THE ACCUSED: [Interpretation] Can we have 3686, please, 1D3686.

24             MR. KARADZIC: [Interpretation]

25        Q.   Very well.  Would you please date and initial this map?

Page 15197

 1             JUDGE KWON:  I don't think he needs to sign this because he

 2     didn't mark anything.  He confirmed as it is and we can admit it as it

 3     is.

 4             THE REGISTRAR:  As Exhibit D1375, Your Honours.

 5             THE ACCUSED: [Interpretation] Could we now see the area of

 6     responsibility of the 105th Brigade.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Would you please take a look at what we have before us now.  The

 9     areas marked in green, would that be the area of the 105th Brigade?

10        A.   Well, based on the lay of the land, yes, I would say that,

11     although I don't see any indicators there.

12        Q.   Could you please take a pen and mark the boundaries of the

13     105th Brigade.

14             THE ACCUSED: [Interpretation] Could the usher please assist the

15     witness.

16             THE WITNESS: [Interpretation] Well, it's difficult to do on this

17     map unless you can show me another map with place names because I don't

18     know how to orientate myself.  I don't see how I can -- how I can

19     determine the area of responsibility.  You need four points in order to

20     determine an area of responsibility and those points have to be known.

21             JUDGE KWON:  Yes, Ms. Gustafson.

22             MS. GUSTAFSON:  Your Honour, before this exercise goes any

23     further, we object to the use of this type of Defence-created exhibit, at

24     least it appears to be created from -- by the Defence and contains all

25     kinds of information that we are not able to verify and we don't have the

Page 15198

 1     source material for.  And as you can see from the witness's answer, he's

 2     not entirely comfortable with this map either.

 3             JUDGE KWON:  Would you like to respond, Mr. Karadzic?

 4             THE ACCUSED: [Interpretation] This is a frozen image of something

 5     that we represented here, and now I'm asking Mr. Dzambasovic to tell me

 6     whether the zone marked with a green line, that is to say, Grdonj,

 7     Sedrenik, does that correspond roughly --

 8             JUDGE KWON:  No, I'm not asking you to ask the question.  You

 9     didn't answer the points Ms. Gustafson raised, how it was created and how

10     they can verify when they have no material to confirm.

11             THE ACCUSED: [Interpretation] That's why we have the witness

12     here, to confirm it.  Remember that when we watched this we put the

13     cursor on every point and then the document shows up on the basis of

14     which each and every one of these locations was marked.  However,

15     Ms. Gustafson was not in the courtroom then, but we believe that the OTP

16     is a single body.

17             JUDGE KWON:  Do you remember the general, General Dzambasovic,

18     stated that he -- it's difficult to do on this map unless you have or you

19     can show me another map with place names because he doesn't know how to

20     orientate himself.

21             Yes, Ms. Gustafson.

22             MS. GUSTAFSON:  Just on the accused's point about this being

23     raised before, it was -- this same information in this same format was

24     presented with an earlier witness, protected witness, and we - as

25     Mr. Karadzic points out, the points had references to source material.

Page 15199

 1     We've had a chance to look at some of that source material and we do find

 2     misrepresentations and inaccuracies.  And in addition, we find that the

 3     source materials relate to the entire period of the conflict, so there is

 4     inconsistencies in the time-frame of the underlying source material.  So

 5     if that's what this is based on, we have a further objection as to the

 6     accuracy and the reliability of this underlying information.

 7             JUDGE KWON:  You wouldn't have any problem if the Defence is

 8     going to produce this map through one of the Defence experts in the

 9     future?

10             MS. GUSTAFSON:  That would certainly be more appropriate,

11     Your Honour.

12             JUDGE KWON:  I'll consult my colleagues.

13                           [Trial Chamber confers]

14             JUDGE KWON:  The Chamber's decision is as follows.  We'll mark

15     this map for identification until we are satisfied with its correctness

16     and whether it's consistent with the source material, until we hear from

17     a witness.  But until then we'll mark it for identification and proceed

18     with this map and we see how the witness would be able to answer the

19     questions.

20             Yes, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Before --

22             JUDGE KWON:  So you should start -- I don't think the witness

23     will remember the entire question.  So you start anew with this map.

24             MR. KARADZIC: [Interpretation].

25        Q.   Mr. Dzambasovic, not going into details street by street, this

Page 15200

 1     layout of the 105th and 115th on the northern slopes of Trebevic, before

 2     it was the 10th Mountain Brigade, then the 152nd, the 111th, the one that

 3     you describe from Hum to Vogosca, the 2nd, or rather, the 102nd one and

 4     the 1st, and at Stup and so on, does this roughly correspond to what you

 5     know as the areas of responsibility of these brigades?

 6        A.   This map roughly does correspond to that.  Since I know these

 7     areas very well, I can tell you about the broader area of responsibility

 8     where the brigade was in terms of the actual geographic locations

 9     involved.  Here I don't have particular geographic locations that I can

10     relate to.

11        Q.   Thank you.  If this is satisfactory, then let us ask

12     Mr. Dzambasovic to do this on a map that he has kindly marked already,

13     1D3716, please.

14             JUDGE KWON:  In the meantime we'll give an MFI number for this.

15             THE REGISTRAR:  That will be MFI D1376, Your Honours.

16             THE ACCUSED: [Interpretation] Could the upper right-hand quadrant

17     please be enlarged.

18             MR. KARADZIC: [Interpretation]

19        Q.   These are your initials here.  You initialled this and you marked

20     this on this map in your own time; right?

21        A.   Yes.

22        Q.   Could the right-hand third be marked now, the right-hand third of

23     the map.  Do we need to zoom in a bit more, Mr. Dzambasovic?

24        A.   No, not really.

25        Q.   Could you please mark this now.  We see the zone of the 105th,

Page 15201

 1     the 152nd, the 115th to the right of this line.  Could you please help us

 2     and mark it.

 3        A.   These are command posts and I marked the zones or areas of

 4     responsibility for you on the other map, and I think it would be more

 5     appropriate if we did that on that other map, the topographic map.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can we then have this map admitted

 8     because it's already been initialled by Mr. Dzambasovic?

 9             JUDGE KWON:  Are those writings done by General Dzambasovic?  Or

10     whose writing is this?

11             THE WITNESS: [Interpretation] It's my handwriting.

12             JUDGE KWON:  Probably we need translation, Ms. Gustafson.

13             MS. GUSTAFSON:  Yes, Your Honour, otherwise no objection.

14             JUDGE KWON:  Yes, we'll mark this for identification pending

15     English translation.

16             THE REGISTRAR:  As MFI D1377, Your Honours.

17             JUDGE KWON:  Yes.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can we have 1D3715.  That is also a topographic map that was

20     marked by General Dzambasovic.  Thank you.

21             MR. KARADZIC: [Interpretation]

22        Q.   Do we need to zoom in or can you confirm the areas of

23     responsibility on the basis of what we see now?

24        A.   Yes, of course I can confirm on the basis of what we see now.

25        Q.   Would you like to mark something else?

Page 15202

 1        A.   There's no need for that, only if you need something.

 2        Q.   Could you please then indicate to the Trial Chamber what this map

 3     is.  You also marked some mortars here and some mechanised -- well, you

 4     marked that somewhere, didn't you?

 5        A.   Yes.

 6        Q.   This disposition of the brigades, not taking into account the

 7     changes in names, did it remain more or less the same until the end of

 8     the war?

 9        A.   In 90 per cent of all cases.

10        Q.   Thank you.

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

12             JUDGE KWON:  Yes, we'll mark it for identification.

13             MS. GUSTAFSON:  Your Honour, I'd just like to put on the record

14     that neither this map nor the prior map were on the list of

15     cross-examination documents.

16             JUDGE KWON:  You can explain it to me, Mr. Robinson.

17             MR. ROBINSON:  Yes, I can.  When we had our interview with

18     Mr. Dzambasovic in the prison the other night, he was kind enough to

19     offer to take the blank maps and do some homework and put in these

20     markings.  And when he arrived here in court just before he began the

21     cross-examination he handed to me the two maps that he had filled in.  So

22     we didn't actually have possession of them until a few minutes before his

23     testimony started.

24             MS. GUSTAFSON:  That would be appropriate for an e-mail to us

25     informing us of that late information.

Page 15203

 1             JUDGE KWON:  I agree.  Pursuant to current practice, the Defence

 2     is required to give notice to the Prosecution of the documents it is

 3     going to use during the cross-examination before it starts.  You can do

 4     it -- could have done it a bit earlier.

 5             I'm sorry to interrupt the flow of evidence, but if I can ask a

 6     question to Ms. Gustafson.

 7             In -- with respect to the prior notice you stated that - it's at

 8     page 38 of today's transcript:

 9             "And if the accused would like to do this in the future I think

10     it would be fair that we have some advance notice that this will be done

11     and all the documents that will be used on these topics falling under

12     Rule 90(H)."

13             In terms of Rule 90(H) line of questioning what do you have in

14     mind in terms of prior notice?

15             MS. GUSTAFSON:  Your Honour, this is akin to an

16     examination-in-chief on topics that aren't covered in the Prosecution's

17     evidence favourable to the Defence case.  So some kind of advance notice

18     akin to what would be given for direct examination in our view would be

19     appropriate.

20             JUDGE KWON:  Does it mean that the Defence is required to reveal

21     their strategy before Prosecution start examination-in-chief?

22             MS. GUSTAFSON:  Well, I'm not sure it would be their strategy,

23     Your Honours, but the simple fact that they will cover certain topics

24     that the Prosecution is now eliciting from the witness and a list of

25     documents they intend to use with the witness.  Given that it has nothing

Page 15204

 1     to do with the direct examination by the Prosecution, it shouldn't --

 2     nothing that happens in the examination-in-chief by the Prosecution

 3     should impact on the way the Defence proceeds under these -- under new

 4     topics elicited under Rule 90(H), so I don't see any unfairness there.

 5             JUDGE KWON:  Thank you.

 6             Would you like to respond -- I'm sorry to discuss in your

 7     presence, but very briefly, Mr. Robinson.

 8             MR. ROBINSON:  Yes, Mr. President.  I think this is a situation

 9     where when a witness comes here we don't know the scope of his knowledge

10     and we didn't learn of it until our interview with him as to whether it

11     would be advisable to his ask him these kinds of questions.  At the

12     interview, Ms. Gustafson was present so she heard all of the same things

13     that she's hearing now.  But in any event there is no rule that requires

14     us to make that kind of disclosure, but I think as a matter of practice

15     we could certainly attempt to do that in the future.  If we know we're

16     going to examine a witness on topics outside of the scope, we can try to

17     at least give whatever kind of notice we have to the Prosecution.  I

18     don't have any problem in doing that.

19             JUDGE KWON:  Thank you.

20             Let's carry on, Mr. Karadzic.

21             Have we admitted this one?  So we'll admit this and -- but we'll

22     mark it for identification pending English translation.

23             THE REGISTRAR:  As MFI D1378, Your Honours.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 15205

 1        Q.   Do you know that the 1st Battalion of this 152nd, or rather,

 2     2nd Brigade had its command post in an abandoned house by Piljina Kafana

 3     at Vasin Han?

 4        A.   I don't know whether that was an abandoned house.  The 1st

 5     Battalion -- now, where did it have its command post somewhere in

 6     Faletici.  Which house that is, I don't know, but I know that it is in

 7     the area of Faletici.

 8        Q.   Thank you.  The 2nd Battalion in the Jajce barracks?

 9        A.   Yes.

10        Q.   The 3rd Battalion, the command post was also in the Jajce

11     barracks?

12        A.   Well, that I don't know, whether it was in the Jajce barracks

13     because its location was a bit risky.  I think it was only the 2nd one

14     that was there.

15        Q.   Thank you.  The Mixed artillery battalion had its command post in

16     the Zmajevac barracks about a kilometre and a half or 2 kilometres away

17     from Podhrastovi; right?

18        A.   Whose mixed artillery battalion?

19        Q.   Of the 152nd.

20        A.   The 152nd did not have a mixed artillery battalion, I think.

21        Q.   At the time when you were there?

22        A.   Yes.  And not even later.  I think --

23        Q.   M-A-D, is that what it was called?

24        A.   No, no.  I think that's a mistake, you're mistaken there.  Within

25     the 1st Corps there was a light artillery battalion of the PVO.  LAD PVO,

Page 15206

 1     that would be the abbreviation, and that was in the area of the Zmajevac

 2     barracks.

 3        Q.   Thank you.  They had one howitzer of 105-millimetres on the

 4     training-grounds of the Zmajevac barracks; right?

 5        A.   No, that I don't know.  That is too small for the Chief of Staff

 6     of a corps.  I really didn't go into each and every artillery piece.

 7        Q.   Thank you.  Is it correct that the logistics units was in Jajce

 8     barracks and in the Injis cafeteria, which used to be the Herzegovina

 9     restaurant near the cathedral where the officer cadre went for their

10     meals?

11        A.   It is correct that the brigade command took their meals at this

12     restaurant.  Now, as for their logistics battalion, I don't know where

13     that was.

14        Q.   Is it correct that this restaurant is in the square between the

15     cathedral and the Vase Miskina Crni Street which is now the

16     Ferhadija Street?

17        A.   Yes, that's correct.

18        Q.   Thank you.  So yes, to be more precise, it's on the corner of the

19     street.  Now, did you know that the BH army had a special MUP unit

20     attached to it called Lasta, which together with the Black Swans,

21     Crni Labudovi, a special unit of the Main Staff participated in joint

22     operations?

23        A.   Well, from time to time that unit took part together in combat

24     with the Black Swans unit.

25        Q.   Thank you.

Page 15207

 1             Could we now just go quickly through the positions of the 105th

 2     which was earlier known as the 9th Mountain Brigade.  Was the command

 3     post of this brigade in the Sipad building in Trampina Street, next to

 4     the central park.

 5        A.   Yes.

 6        Q.   Was the alternative command post at the Ivan Cankar elementary

 7     school as well as the rear command post?

 8        A.   I have no idea where that school is, but, no, they did not have a

 9     forward command post.  The 9th only had a command post.

10        Q.   Here it says an alternative command post?

11        A.   Well, yes.  The forward -- well, maybe it was a rear command

12     post, maybe that's what this is a reference to.  There's something that

13     is not quite clear there.

14        Q.   Did this brigade -- was this brigade in its entirety deployed, as

15     we saw a little earlier in the Sedrenik area up to Grdonj, and that it

16     had its lines at Grdonj below Spicasta Stijena, so were they in this

17     area?

18        A.   Yes, that's correct.

19             JUDGE KWON:  Mr. Karadzic, when you say "here," do you mean this

20     map?

21             THE ACCUSED: [Interpretation] Well, it says on the map "105th."

22             MR. KARADZIC: [Interpretation]

23        Q.   However, below that, within the golden line, would you agree,

24     General Dzambasovic, that this was the area of responsibility of the

25     105th Brigade?

Page 15208

 1        A.   Yes.  In general terms, yes, this would be the area of

 2     responsibility.

 3        Q.   Thank you.  The image that we showed earlier, did it correspond

 4     roughly to this, our image?

 5        A.   You mean the one without any geographic names?  Yes, it would --

 6     it approximates that area.

 7        Q.   Thank you.  Do you agree that its area of responsibility was at

 8     Hladivode, where it linked up with the 152nd, then Mala Brda,

 9     Rijeka Potok and Kobilja Glava?

10        A.   That was the defence line that you just described.

11        Q.   That was the area facing the enemy, right, the army of the VRS?

12        A.   Yes.

13        Q.   Thank you.

14             THE ACCUSED: [Interpretation] Could we now take a look at 1D3689,

15     please.

16             MR. KARADZIC: [Interpretation]

17        Q.   While we are waiting for it to come up, do you agree that this

18     brigade had up to seven battalions, four motorised, one MAD, one

19     logistics battalion, an engineer battalion, sabotage, and reconnaissance

20     company, a military police company, and an anti-nuclear, biological, and

21     chemical weapons company?

22        A.   The establishment structure of these brigades is probably --

23     contained these units.  However, I don't know the lower-level units

24     within this brigade.  I don't know what exactly they were.  However, none

25     of these subordinate units was fully manned as it should be per

Page 15209

 1     establishment.  In other words, not a single brigade had an artillery

 2     unit.  They had artillery weapons, but a unit that was prescribed by the

 3     establishment, there was not a single brigade in the town that had that.

 4        Q.   Thank you.  Now, can you see in this map of the city, can you

 5     recognise where the area of responsibility was of the 105th Brigade?  You

 6     see that we have the Kosevo stadium there?

 7        A.   Yes, I can see it.  Well, this roughly corresponds to its area of

 8     responsibility.  Again, we don't have any geographic features, but based

 9     on these facilities and some of the buildings that are shown there, I

10     could confirm that this is roughly the area of responsibility of the

11     105th Brigade.

12        Q.   Thank you.

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

14             JUDGE KWON:  Yes, Ms. Gustafson.

15             MS. GUSTAFSON:  We have the same objections to this map as the

16     previous Defence-created map.  There appear to be locations marked here

17     and we don't have the underlying information.  If the information is what

18     was provided previously in the earlier presentation then we have concerns

19     about its reliability.

20             JUDGE KWON:  All that Defence did in relation to this map was to

21     mark -- indicate or locate the -- some or command posts of the alleged

22     105th Brigade and we heard the evidence from the witness that those

23     locations are roughly corresponding to the location.  Do we need some

24     expert witness in relation to this further?

25             MS. GUSTAFSON:  I understood the witness's answer to be that this

Page 15210

 1     roughly - roughly - corresponded to the area of responsibility of the

 2     105th Brigade, and again he had concerns about the nature of the map and

 3     his ability to identify that area of responsibility.  He did not confirm,

 4     as far as I could see, the locations of these command posts it seems to

 5     be of the brigade.

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  General, can I ask you this:  By answering, "Well,

 8     this roughly corresponds to its area of responsibility," did you mean

 9     that the locations indicated as the command posts are -- approximately

10     correspond to the actual locations?

11             THE WITNESS: [Interpretation] No.

12             JUDGE KWON:  Could you clarify.  What did you mean by "area of

13     responsibility"?  While -- because we did -- do not see any area of

14     responsibility in this map.

15             THE WITNESS: [Interpretation] Yes.  We cannot see it from this

16     map, but we said that this red line is a kind of border, and visually, I

17     guessed that this is roughly the area of responsibility of the

18     105th Brigade.  However, the command posts -- all I know for sure is that

19     the brigade command post was in Trampina Street in that building that was

20     mentioned earlier.  As for all the other command posts of the subordinate

21     units, I'm not sure where they were, nor did I confirm that these were

22     indeed those locations.  I'm not sure where the command posts of those

23     lower units, those subordinate units, were.  In other words, the area of

24     responsibility is a larger area which has a certain depth and width, and

25     within that area you would deploy commands and units.  And roughly

Page 15211

 1     speaking, this does correspond to that area of responsibility.  But as

 2     for the precise locations of the posts, command posts, of subordinate

 3     units within the zone, that I don't know.  I don't know where they are.

 4                           [Trial Chamber confers]

 5             JUDGE KWON:  Given the weight of the evidence if admitted, the

 6     Chamber sees no point of admitting this with this witness.  Let's

 7     proceed.

 8             THE ACCUSED: [Interpretation] Thank you.  Then we will try to

 9     make this more visible and use it on some other occasion.

10             MR. KARADZIC: [Interpretation]

11        Q.   Now, do you recall that the 1st Battalion had a command post in a

12     private home near Mehina Kafana?  You must have known that; we all know

13     where Mehina Kafana is, Mehin's Cafe.

14        A.   I know where Mehina Kafana is but that was not where the command

15     post was.  It was at the meteorological building.

16        Q.   The command post of the 2nd Battalion was at the seismological

17     agency; is that correct?

18        A.   That's why I told you that I didn't know the deployment of

19     subordinate units and I'm not absolutely certain where they were and

20     that's why I cannot give you any precise information about the

21     deployments and the areas where the subordinate units were.

22        Q.   Thank you.  Do you know by any chance whether the command post of

23     the 3rd Battalion was in the kindergarten building?

24        A.   Yes.

25        Q.   Was the command post of the 4th Battalion at the physical

Page 15212

 1     education faculty at Kosevo?

 2        A.   I'm not sure about that.

 3        Q.   Do you know that the command post of the reconnaissance and

 4     sabotage company was -- it used to be at Juvala Nitraka street and then

 5     later on it was at the bakeries in Breka?

 6        A.   Thank you.  I don't know and I've never been there.

 7        Q.   Do you know that the command post of the engineering battalion

 8     was in the Jazija Omanovic elementary school building?

 9        A.   No.

10        Q.   Did you know that the command post of the logistics battalion was

11     at the Ivan Cankar elementary school and then later moved to Bosna export

12     company on Romanijska Street?

13        A.   I don't know of any logistics units and where they were deployed

14     and I wasn't really interested in that.

15        Q.   Did you know that the military police company was in Pcelica

16     kindergarten in Svetozara Markovica Street?

17        A.   No.

18        Q.   Thank you.  I would now like to talk about the 1st Motorised

19     Brigade.  Do you know where it was deployed, the 1st Motorised Brigade?

20        A.   I know where -- what its area of responsibility was and where its

21     command post was.

22        Q.   Was the command post in Bosna Lijek -- in the building

23     Bosna Lijek and then later on moved to the Magros building in

24     Blagoja Parovica Street?

25        A.   I only know about the Magros building.

Page 15213

 1        Q.   Was the rear command post in Pofalici on the premises of the

 2     prison there and then later on moved to Marsal Tito barracks?

 3        A.   I don't know.

 4        Q.   Were the command posts 1 and 2 in Zivkovici village, on Zuc, and

 5     2 on Orlic hill?

 6        A.   While I was the Chief of Staff of the 1st Corps, the forward

 7     command post of the 1st Brigade was in Jezera village, that was south of

 8     the Zuc hill, some 200 to 300 metres away.  As for the other locations

 9     I'm not aware it was ever there.

10        Q.   What about the command post number 3, do you know it was in

11     Velesici next to the repair shop --

12             THE INTERPRETER:  The interpreters cannot follow at this speed.

13             JUDGE KWON:  If you could slow down; interpreters couldn't

14     follow.  Could you repeat your question.

15             MR. KARADZIC: [Interpretation]

16        Q.   The third command post of this brigade, was it in Velesici 100

17     metres from the new repair shop, auto repair shop, the trig points X

18     58025 and Y 32650?

19        A.   I don't know.  I already said that I don't know the deployments

20     and the positions of those subordinate units and it was not really within

21     my competence.  I was not even supposed to know.  I was not required to

22     know their locations.

23        Q.   Thank you.  Then I will skip the lower-level units and let's move

24     on to brigade level.  Do you know that the 2nd Motorised Brigade as it

25     was called earlier was later renamed and became the 111th Motorised

Page 15214

 1     Brigade, whereas the 95th became the Vitez Brigade or the

 2     Viteska Brigade?

 3        A.   Well, no.  That was the 1st Brigade, the 1st was later called the

 4     111th that we just mentioned.  And then later on it was renamed again and

 5     it was called the Viteska Brigade or Knight Brigade or the Glorious, I

 6     think that was the name that it was given, but I'm not sure which of the

 7     two.

 8        Q.   Was its area of responsibility between Miljacka River, Astro

 9     factory, over the Zuc hill to the north towards Vogosca?

10        A.   The area of responsibility of the 1st, or rather, the

11     111th Brigade was between the Zuc hill running to the north-east towards

12     the transportation technical faculty, via Slatina village, Kromolj, and

13     then Grdonj -- I'm sorry, I got confused.  Via Slatina village.  So

14     that's the area.

15        Q.   And then towards the centre of town it went all the way to the

16     Astro factory where the 154th had its command post?

17        A.   You've confused it.  The 1st Brigade, or rather, the 101st had a

18     command post in Magros and the second one, I think it was the 112th, had

19     its command post at this location that you just referred to.

20        Q.   Dzemala Bijedica 144, opposite Astro; right?

21        A.   Yes, that's right, that's the second one.

22        Q.   Thank you.  Then I'm not going to ask you about the firing

23     positions of this brigade either.

24             Can we now have a look at the 102nd Brigade and where it was.

25     Before it was called the 3rd Motorised Brigade or perhaps I've confused

Page 15215

 1     that too?

 2        A.   That's correct.

 3        Q.   Was it in the area of Stup from the wire factory, Alipasino Polje

 4     towards Stup, towards Ilidza?

 5        A.   It had its command post at the wire factory and it defended the

 6     area towards Stup, or rather, part of the student dormitories in

 7     Nedzarici and then all the way down to the Energoinvest factory called

 8     TAT and then the area to the north-west towards Rajlovac, that is to say

 9     moving from Stup to Rajlovac to that underpass roughly, that's where it

10     was.

11        Q.   Thank you.  In Vladimir Peric Valter at Stup was there an

12     alternative command post there and was there a forward command post at

13     the Lav restaurant?

14        A.   I went to that first facility that you referred to, that was the

15     forward command post.

16             JUDGE KWON:  Just a second.  While following this line of

17     evidence, can we see the exhibit D1377 so that we can follow a bit more

18     easily.

19             Please proceed.  That's the marked position of the ABiH marked by

20     this witness.

21             THE ACCUSED: [Interpretation] Thank you, Your Excellency.  That

22     would really help us.

23             MR. KARADZIC: [Interpretation].

24        Q.   So we can see here where you marked the command post of the

25     102nd, that is Valter Peric; right?

Page 15216

 1        A.   I think it is at Stup.  I don't know which building exactly but

 2     it was in that area.

 3        Q.   Thank you.  What about the 1st Battalion, the command of the

 4     1st Battalion, was it at the elementary school Pavle Goranin and the

 5     forward command post at a private house in Stup, which I believe you

 6     decided on through one of your orders?

 7        A.   It's possible that that's what I did, but as for the deployment

 8     of these lower-ranking units, I really don't know.  Quite simply, I

 9     happen to know some of them but I don't know this one.

10             THE ACCUSED: [Interpretation] Your Excellencies, do you believe

11     it would be useful if we asked the general to mark roughly with this

12     electronic pen the area of the 2nd Brigade to the best of his knowledge?

13             JUDGE KWON:  If he can.  Just -- could you wait -- would you like

14     to ask to zoom in this map further?

15             THE WITNESS: [Interpretation] If possible, that would be good.

16             THE ACCUSED: [Interpretation] The left-hand third.

17             JUDGE KWON:  General, could you wait a bit further till assisted

18     by our usher.

19             Mr. Karadzic asked to zoom in to mark the 2nd Brigade.  We see a

20     number 2 there.  Yes.  I think that's sufficient.

21             Could you wait -- could you wait.

22             THE WITNESS:  Thank you.

23             [Interpretation] Can I mark it now?

24             MR. KARADZIC: [Interpretation]

25        Q.   Please do.  You marked the tank, right, you marked the forward

Page 15217

 1     command posts.  Can you roughly mark the area of responsibility of the

 2     2nd or the 3rd or the 102nd?

 3        A.   [Marks] That would be it roughly.  The area of responsibility of

 4     the 102nd Brigade that goes from the Miljacka River towards the Dobrinja

 5     river, that is to say --

 6        Q.   South.

 7        A.   From the north to the south.

 8        Q.   And on the north?

 9        A.   No, no.  The 2nd is up there.  It's above the road leading

10     through Rajlovac, that is to say to the north of the road to Rajlovac is

11     the 2nd Motorised.  And to the south of the road to Rajlovac is the area

12     of the 102nd.

13             THE ACCUSED: [Interpretation] Can I ask you to please hand over

14     this drawing to the general, and if he accepts it.

15             [In English] Thank you.

16             MS. GUSTAFSON:  Your Honours, perhaps there could be some

17     explanation.  It's unclear what this document is and we've never seen it

18     before.

19             JUDGE KWON:  Yes.

20             THE ACCUSED: [Interpretation] It's from our map that we created.

21     It's just supposed to jog Mr. Dzambasovic's memory so that he remembers

22     whether that's the way it was.

23             JUDGE KWON:  Let's put it on the ELMO.

24             THE ACCUSED: [Interpretation] You can do it electronically as

25     well.  It has a number.  It can be called up -- actually, no, the ELMO is

Page 15218

 1     better.  I'd be sorry to lose the one that we have here.

 2             JUDGE KWON:  What is your question, Mr. Karadzic?

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Does this help you mark the borders on the electronic map, or

 5     rather, the boundaries of the 102nd?

 6        A.   It would be easy for me to tell you all of that if I just had the

 7     names that I referred to a moment ago.  The names cannot be seen here.

 8     You just see the buildings marked there.

 9        Q.   Do you see --

10             THE INTERPRETER:  The interpreter did not hear the rest of the

11     question.

12             THE WITNESS: [Interpretation] That I see.

13             MR. KARADZIC: [Interpretation]

14        Q.   If you were to call up 1D3696 you would see every one of the

15     names?

16        A.   Well, if that's possible.

17             JUDGE KWON:  In the meantime why don't we ask the witness to sign

18     and date the current marked map as it is now.

19             General, could you do that?

20             THE WITNESS: [No interpretation]

21             THE INTERPRETER:  The interpreter could not hear the witness.

22             MR. KARADZIC: [Interpretation]

23        Q.   The 22nd I think.

24        A.   [Marks]

25             JUDGE KWON:  We keep this map.  Should we give it a number?

Page 15219

 1             THE REGISTRAR:  D1379, Your Honours.

 2             JUDGE KWON:  We have a break and come back to this issue after

 3     the break.  We resume at 1.00.

 4                           --- Recess taken at 12.32 p.m.

 5                           --- On resuming at 1.01 p.m.

 6             JUDGE KWON:  Where were we?  Could we upload the last map marked

 7     by the witness, D1379?

 8             General, I don't think I've fully understood the meaning of these

 9     markings.  Could you explain to us again?

10             THE WITNESS: [Interpretation] These are tactical signs used by

11     the former JNA and taken on by the BH army.  These are tactical signs

12     representing brigade command posts.  Wherever you have this sign it

13     stands for a command post of the brigade.  It's an area where the command

14     staff of a brigade is stationed.  And - excuse me - these are the various

15     facilities housing command posts.

16             JUDGE KWON:  I meant the black line you marked just now.

17             THE WITNESS: [Interpretation] The black line, well that's an

18     approximation of the area of responsibility of the 102nd Brigade.  These

19     are roughly the boundaries of the area of responsibility.  Though

20     admittedly I did make the same markings on the topographical map and I

21     should perhaps not have done the same thing here.

22             JUDGE KWON:  Thank you.  Now I understand.

23             Back to you, Mr. Karadzic.  Please continue.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 15220

 1        Q.   I do understand that you would not be familiar with the battalion

 2     command posts since you were higher up, but do you know that it was in

 3     the Djokic primary school that the 2nd Battalion of the Brigade was

 4     stationed whereas the manoeuvre battalion was in a kindergarten at

 5     Cengic Vila?

 6        A.   Well, as I speak I don't know the location of either the school

 7     or the kindergarten.

 8        Q.   Thank you.  The 155th or the 5th, did you mark its location in

 9     the centre of Dobrinja?

10        A.   Yes.  I don't know the name of the street but I do know the

11     building where it was housed.

12        Q.   Was it in the Sipad building in the Mitsubishi avenue?

13        A.   I don't know the name of the street but it is the Sipad building.

14        Q.   Thank you.  Perhaps you could make another marking on the same

15     map and we'll admit it, the area of responsibility of the 5th Brigade in

16     the Dobrinja neighbourhood with the exception of the airport

17     neighbourhood?

18        A.   I did mark the area of responsibility on that other map because

19     we have place names there, and I did orient myself in making the markings

20     with respect to the place names that I don't have on this map.

21        Q.   Yes, I agree with you.  Did this brigade have two special units

22     Hazet Hamza [phoen] and El Fatih?

23        A.   I don't know about that.  It's the first time I'm hearing these

24     names.

25        Q.   Thank you.  Do you know how many battalions there were in the

Page 15221

 1     1st, later 105th, Brigade?

 2        A.   As far as I remember, it had four battalions.

 3        Q.   Thank you.  You don't know, do you, the composition of the mortar

 4     batteries and artillery and armoured assets of the 105th?

 5        A.   I don't think the 105th had any of these assets, and I did

 6     emphasize that none of the brigades had an armoured or anti-tank unit or

 7     an artillery unit by their very establishment.  Some of the brigades had

 8     artillery pieces.  Only one brigade, the 1st one, 111th, had several

 9     tanks, most of which were in a state of disrepair because there were no

10     spare parts to repair them.

11        Q.   Thank you.  Can I attract your attention to the area of

12     responsibility of the 101st Brigade, its command post, it was formerly

13     the 1st Brigade, or rather, the 6th Mountain Brigade.  It was set up as

14     the 6th Mountain Brigade for Hrasno?

15        A.   Yes, that's right.  It became the 101st.  Its command post was in

16     the Viktor Bubanj barracks where the court of Bosnia-Herzegovina is

17     housed today.

18        Q.   Thank you.  The first commander was Nedzad Ajnadzic a JNA officer

19     who later became a commander of the 1st Corps or the 11th Division?

20        A.   He was the brigade commander and he replaced Karavelic as the

21     corps commander.

22        Q.   Thank you.  Did General Ajnadzic write a book about the defence

23     of Sarajevo and the combat that took place within Sarajevo?

24        A.   Yes, he did.

25        Q.   Thank you.  Can all the participants see the markings in respect

Page 15222

 1     of the 101st or should we ask the witness to mark the location?

 2        A.   This is where the 101st Brigade was situated, that's the

 3     Viktor Bubanj barracks.

 4             JUDGE KWON:  We see it so we can proceed, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Am I right in saying that these markings indicate the brigade

 8     command posts of the 1st, 2nd, 101st, 102nd, 5th, and the forward command

 9     post of the 2nd, this is the area where we have the small flag, slightly

10     dented, but it is not a triangle.  It's rather a dented rhomboid.

11        A.   What's your question?

12        Q.   In this part of the map can we see the command posts of the HVO,

13     Kralj Tomislav, is that right, that's the command post of the brigade?

14        A.   Well, it was housed in a primary school building.  I don't know

15     its name.

16        Q.   And west of that location is the command post of the

17     1st Motorised Brigade; right?

18        A.   Yes, at Magros.

19        Q.   Next we have the 2nd Motorised further west, which is in the

20     Astra area?

21        A.   Yes, the 102nd.

22        Q.   The 102nd is close to the television, is it right?

23        A.   It's -- the 102nd was housed in the wire factory, wire and cables

24     factory.  Well, I know it was in that particular compound.  I'm not sure

25     about the very building.

Page 15223

 1        Q.   Then we have the two forward command posts of the 2nd and the

 2     102nd and then we have the command post of the 5th?

 3        A.   Yes.

 4        Q.   Thank you.  Can we now see the eastern part of town, please.

 5             JUDGE KWON:  Probably we need to upload D1378.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   I would like to direct your attention to the 10th Mountain

 9     Brigade, later renamed 115th; is that right?

10        A.   I think that the 10th and the 1st formed the 115th at a later

11     stage.  While I was the chief of the corps staff it was the 10th.

12        Q.   Thank you.  And its area of responsibility ran from the river

13     Miljacka to the south, including the northern slopes of Trebevic and up

14     until the positions of the VRS?

15        A.   Yes, all the way to Zlatiste and the Vrace monument beyond the

16     Jewish cemetery, that area, stretching on towards Zlatiste.

17        Q.   Not Slatina, Zlatiste.

18             Could you please indicate for us with a cursor, we can see Vrace,

19     can we not, in the direction of the 101st we see Vrace and the monumental

20     complex there?

21        A.   Yes, we can see it, though I can't make it clearly.  Perhaps we

22     could zoom in a bit.

23        Q.   Cicin Han, Mrakusa, Kovacici, all the way to Vrbanja, all of that

24     was covered within the area of responsibility?

25        A.   Yes, roughly the area you just indicated.

Page 15224

 1             JUDGE KWON:  General -- yes.  Now is it better?

 2             THE WITNESS: [Interpretation] Yes, it is much better now.

 3             JUDGE KWON:  Don't touch it, please, wait until assisted.  Yes.

 4             Would you like the general to mark something, Mr. Karadzic?

 5             THE ACCUSED: [Interpretation] Well, I'd appreciate it if the

 6     general could mark the area between the Vrbanja bridge and the VRS

 7     positions all the way to Miljacka and the 115th Brigade positions.

 8             THE WITNESS: [Marks]

 9             MR. KARADZIC: [Interpretation]

10        Q.   Thank you.  And all the way up there to Vidikovac; right?

11        A.   This is roughly the area of responsibility south of the Miljacka

12     which covers Soukbunar, Skenderija, Bostarici, and the neighbourhood of

13     Cicin Han Lipa.  This is roughly the area of responsibility of the 10th

14     Mountain Brigade.  Now, north-east of the area along the length of the

15     Miljacka, including the quarry - which you know where it is - this

16     section of the Stari Grad municipality south of the river Miljacka is the

17     area of responsibility of the 1st Mountain Brigade.

18        Q.   And when they merged it all became the area of responsibility of

19     the 115th; right?

20        A.   Yes, it became the area of responsibility of the 115th.

21        Q.   Thank you.  You marked the brigade command post as located in the

22     command of the 2nd Military District?

23        A.   Well, the command was not housed in that building.  It's beyond

24     that.  There was a ground floor structure, prefabricated structure, which

25     housed the command of the 10th Brigade.  Now, the very building of the

Page 15225

 1     2nd Military District is some 20 metres away.

 2        Q.   Thank you.  Do you think whether Carrington 2 on the 6th of April

 3     square where the 2nd Battalion was housed at the -- it had -- that the

 4     5th Battalion had its forward command post there, you can tell us if you

 5     don't know?

 6        A.   No, I told you already that I can't testify to the location of

 7     the command posts of the units of a lower level.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can we have the map admitted,

10     please.

11             MR. KARADZIC: [Interpretation]

12        Q.   And if you could place your initials and date the map, please?

13             JUDGE KWON:  Yes, that will be done.

14             THE REGISTRAR:  Exhibit D1380, Your Honours.

15             THE ACCUSED: [Interpretation] Can we stay with the map for a

16     while.

17             MR. KARADZIC: [Interpretation]

18        Q.   Do we see the HVO Kralj Tvrtko Brigade on the edge of the map,

19     can you see that there?

20        A.   Yes, it was housed in a school building.  I don't know the name

21     of the school.  That was the command post of the HVO brigade precisely

22     where I marked it.

23        Q.   Thank you.

24             Did the artillery brigade of the 1st Corps --

25             JUDGE KWON:  Unfortunately the Registry has lost the previous

Page 15226

 1     marking.  If necessary, we'll ask the witness to kindly to mark those

 2     lines again if you wish, Mr. Karadzic.

 3             THE ACCUSED: [Interpretation] Yes, the area of responsibility of

 4     the 10th and 1st, which later merged into 115th.  This is what the

 5     general is well aware of.  It's where Kovacici and Grbavica are located,

 6     the Vrbanja bridge, Cicin Han and everything else that came under the

 7     area of responsibility.  It's the western boundary, is it not.

 8             THE WITNESS: [Interpretation] This is of the 1st Brigade and this

 9     is of the 10th.

10             JUDGE KWON:  Previously you marked some lines to the right of

11     this map, did you not?

12             THE WITNESS: [Interpretation] I did that now as well.

13             MR. KARADZIC: [Interpretation]

14        Q.   It's the right-hand side boundary of the 1st which later became

15     115th; right?

16        A.   Yes.

17             JUDGE KWON:  Very well --

18             THE WITNESS: [Interpretation] The northern boundary runs along

19     the river.  That's why I didn't mark it.  I wanted the map to be as clear

20     as possible.

21             MR. KARADZIC: [Interpretation]

22        Q.   Thank you very much.

23             JUDGE KWON:  Did we save it or did we lose it again?

24             There seems to be a technical difficulty but whether we can use

25     the video image -- yes, we will use that.  Let's proceed.

Page 15227

 1             THE ACCUSED: [Interpretation] Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Can we have 1D3613 just for a moment so that you can confirm for

 4     us, perhaps, the HVO command posts.  Do you agree that the HVO is

 5     actually a Croatian military formation, or rather, a formation, military

 6     formation, of the Croatian people in Bosnia-Herzegovina that fought

 7     within the BH army at the time?

 8        A.   The HVO brigade in Sarajevo was within the 1st Corps of the Army

 9     of the Republic of Bosnia-Herzegovina, whereas the HVO units outside of

10     Sarajevo, many of them rather, were not within the BH army.  They were a

11     separate formation.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] Can we have 1D3683, please.  This

14     is not it.  1D3683.

15             MR. KARADZIC: [Interpretation].

16        Q.   The command of Kralj Tvrtko Brigade was there, was the command of

17     the battalion here and the command of the company there.  This company

18     was facing the Serb part of Grbavica; right?

19        A.   The command was at the school that I showed you a moment ago.

20     For a while it was deployed from Skenderija towards Elektroprivreda that

21     is to say on the right bank of the Miljacka, or rather, from Marin Dvor

22     by the national museum and then to Elektroprivreda, roughly that is where

23     its area of responsibility was, in that territory.  That's where this

24     brigade was deployed.  In fact, it was a smaller unit.

25        Q.   Thank you.  Could you please mark Marin Dvor here and then -- and

Page 15228

 1     then the western boundary.  You see where Marin Dvor is?  You see where

 2     the Assembly and government building is, where it says command of the

 3     3rd Battalion, is that it?  And then the trams, remember that?

 4        A.   I can't find it yet.  I can't identify it.

 5             JUDGE KWON:  Just a second, please.

 6             You seem to be very persistent in using this kind of map.

 7             Yes, Ms. Gustafson.

 8             MS. GUSTAFSON:  Thank you, Your Honour.  The same problems arise

 9     with this map.  The witness can only confirm the brigade command posts

10     that he has already marked on another map.  He hasn't confirmed these

11     other locations that the Defence have indicated on this map for which we

12     have no source information.  And if Mr. Karadzic intends to have the

13     witness mark this map, I'd just like to indicate now that we would object

14     to its admission because of this unsourced and unsubstantiated

15     information contained within it.

16             JUDGE KWON:  This is rather simple or simpler than compared to

17     other ones.  This is a Google map and he placed for locations -- we

18     haven't heard a question in relation to this document.

19             MS. GUSTAFSON:  Your Honour, I understood the -- that

20     Mr. Karadzic asked for confirmation of these command posts and the

21     witness answered that he could only confirm the command post of the

22     brigade which he had already marked.  So --

23             JUDGE KWON:  Yes.

24             MS. GUSTAFSON:  -- from his answer I understood that he could not

25     confirm the other locations which is where my concerns arise from.

Page 15229

 1             JUDGE KWON:  He didn't ask about other posts, and rather he

 2     proceeded to ask the witness to mark Marin Dvor.

 3             MS. GUSTAFSON:  At line --

 4             JUDGE KWON:  Mr. Karadzic --

 5             MS. GUSTAFSON:  -- sorry --

 6             JUDGE KWON:  -- I would like you to proceed with your next point.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation].

 9        Q.   If you haven't identified Marin Dvor but if you look at the

10     bifurcation where it says --

11             JUDGE KWON:  Mr. Karadzic, the witness has marked location of the

12     command post of the HVO brigade.  I don't see a further point of --

13     further exploring with this witness on this point.  Why don't you move to

14     your next topic.

15             THE ACCUSED: [Interpretation] Thank you.  We can do that, I

16     agree.

17             MR. KARADZIC: [Interpretation]

18        Q.   Can we now see Hrasnica, however, on the map that -- just a

19     moment, please.  Let's see which is going to be the best-suited map for

20     that.  1D3716 -- I beg your pardon, 3715 would be better.

21             JUDGE KWON:  Exhibit D1378.

22             THE ACCUSED: [Interpretation] The southern third, the lower

23     third, could that be enlarged, please, a bit more than this.

24             MR. KARADZIC: [Interpretation].

25        Q.   General, did you mark in yellow the zone of responsibility of the

Page 15230

 1     4th Motorised Brigade that was later named the 104th and had its area of

 2     responsibility from Hrasnica to Sokolovic Kolonija, Butmir, all the way

 3     to the airport runway?

 4        A.   Yes, yes, that's the area of responsibility approximately.

 5        Q.   Thank you.  The Butmir end of the tunnel was also within its area

 6     of responsibility; right?

 7        A.   The exit from Sarajevo was on the Butmir side, that is to say the

 8     exit from the tunnel was in the area of responsibility of the 4th, or

 9     rather, 104th.

10        Q.   Was the command post of the brigade in the building of the new

11     post office in Hrasnica?

12        A.   It was in the building, but I don't know whether it's the new

13     post office.  I just know which building it was.

14        Q.   Thank you.  Do you know that the alternate command post was in

15     Stanogradnja and the forward command post in Vrhovi, the road up on the

16     hill?

17        A.   This alternative command post, as you call it, I don't know.  But

18     at Hrasnicki Stan that's where the forward command post was, between the

19     mountains of Igman and Hrasnica there is a macadam road.

20        Q.   It would be very helpful if you knew the command posts of the

21     lower-ranking units, for example, the 3rd Battalion in Sokolovic

22     Kolonija, the supermarket, the command post of the 4th in the cultural

23     centre in Butmir.  Did you know that, the command post of the 2nd in the

24     hotel, or rather, in the second high-rise near the post office in

25     Hrasnica, did you know that?

Page 15231

 1        A.   No.  I did not even tour these lower-ranking commands.  This I

 2     know because I personally went to the commands of all the brigades.  As

 3     for battalion commands, I hardly ever went to battalion commands.

 4        Q.   Thank you.  This has already been admitted, this map, so I don't

 5     think -- well, to the south of Hrasnica, is that where Mount Igman is and

 6     further south do we have Mount Bjelasnica and was this taken by the 100

 7     or the 4th Brigade of the Army of Bosnia and Herzegovina and kept

 8     throughout the war?

 9        A.   Yes, to the south of Hrasnica is Mount Igman and even further

10     south Mount Bjelasnica.

11        Q.   Thank you.  Was the artillery of the 1st Corps on Mount Igman,

12     the artillery that was not in the city itself?

13        A.   In the city itself there wasn't any artillery.  I've said that.

14     These were individual artillery pieces.  Out of town there was artillery,

15     especially in the area of Igman, because that was the most favourable

16     position for such weaponry.

17        Q.   Thank you.

18             JUDGE KWON:  General, if you could tell us the difference between

19     artillery and individual artillery pieces.  We are not experts on the

20     artillery.

21             THE WITNESS: [Interpretation] I was asked whether artillery units

22     were there.  An artillery unit cannot be a single artillery piece or just

23     two artillery pieces.  There weren't any such units in the city, that is

24     to say that the smallest formation in the artillery is an artillery

25     platoon.  It has four artillery pieces up to six, depending on the type.

Page 15232

 1     And then there is a battery and then there is an artillery battalion, and

 2     so on.  So within the city itself --

 3             JUDGE KWON:  Thank you, that's sufficient.  In the interpretation

 4     we didn't hear the word "unit," so that's sufficient.

 5             Let's proceed, Mr. Karadzic.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Do you know of the composition of that artillery brigade on

 9     Mount Igman?

10        A.   According to establishment, there wasn't an artillery brigade on

11     Mount Igman.  It didn't have that much equipment.  Roughly, that unit was

12     at the rank of an artillery battalion, that is to say it should be around

13     16 to 18 artillery pieces of different calibre and for different

14     purposes.

15        Q.   From 90-millimetres up to 105-, 122-, 155-; right?  Howitzers.

16        A.   In principle, those are artillery pieces, everything you

17     mentioned just now.  Now, as for the types that were there, I really

18     cannot say, I don't know.  But there was a unit that was roughly at the

19     level of an artillery battalion.

20        Q.   16 pieces approximately?

21        A.   Yes.

22        Q.   All of the valley of Sarajevo including Pale, was it within the

23     range of these artillery pieces?

24        A.   Only 152-millimetre cannons and 130-millimetre guns, according to

25     technical tactical characteristics with special ammunition had a range of

Page 15233

 1     over 20 kilometres.  As far as I know, the army had only two

 2     152-millimetre guns in this area.  All other artillery pieces did not

 3     have a range that exceeded 10 to 15 kilometres.

 4        Q.   Thank you.

 5                           [Defence counsel confer]

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Let us now identify locations where combat equipment was

 8     manufactured.  Do you remember a centre called CNP was established?

 9        A.   Of course I knew as Chief of Staff this centre, except that I

10     never went there, but I know that something was being manufactured in the

11     factory called Vaso Miskin Crni and some equipment was manufactured in

12     the factory called Zrak.  That is a factory of the former JNA, a factory

13     manufacturing optical instruments.

14        Q.   Thank you.  Now we'll like to go through these locations.  Let us

15     just see whether Faik Kulovic was chief and Berko Zekovic deputy chief

16     for the production base Mirko Greho?

17        A.   I don't know either one of them, I really don't.  So the field of

18     logistics is something that we staff officers were not exactly interested

19     in.  This was mostly done by officers from the logistics sector.  I only

20     knew by way of information that something was being manufactured at these

21     two facilities.  What we were interested in was whether we had that for

22     when we needed it or not.

23        Q.   May I just remind you of some of these things and then you can

24     tell me whether you know that or not.  Was there any production at the

25     faculty of mechanical engineering?

Page 15234

 1        A.   I really don't know.

 2        Q.   What about explosive charges for grenades, was that ongoing at

 3     the tobacco factory?

 4        A.   This is the first I've ever heard of it, although I never entered

 5     the factory compound during the war.

 6        Q.   Thank you.  At the Astra factory were shells and grenades also

 7     filled with explosives?

 8        A.   I don't know where that factory is and I haven't heard of that

 9     either.

10        Q.   What about the wire factory, did you hear that it was used for

11     this kind of manufacturing?

12        A.   I know the wire factory, I've already said that to you a moment

13     ago, that was the command of the 102nd Brigade, but for that kind of

14     manufacturing I was not aware of it.

15        Q.   Thank you.  You know about Zrak?

16        A.   Yes.

17        Q.   Sighting devices and the like?

18        A.   Yes.

19        Q.   At the faculty of chemistry?

20        A.   I don't know anything about that, really.

21        Q.   In the Vaso Miskin Crni factory equipment for shells of 60 and 82

22     millimetres?

23        A.   The only thing I know about that factory is that some shells were

24     manufactured there, but I never entered the premises either.

25        Q.   Also explosives at the Sarajevo brewery?

Page 15235

 1        A.   No.

 2        Q.   Thank you.  The manufacturing of footwear for soldiers at

 3     Kozni Kombinat Visoko in the Marsal Tito Street?

 4        A.   I really don't know about this kind of manufacturing of textiles

 5     and other equipment that was needed by the quartermaster corps but I

 6     never visited these locations.

 7        Q.   The factory Alhos, did they manufacture uniforms?

 8        A.   It is possible that uniforms were manufactured at Alhos but not

 9     just military uniforms because I think that there was not sufficient --

10     there weren't any fabrics for that purpose so I think that they used the

11     fabrics that they had.

12        Q.   Do you know that in Hrasnica, between two high-rises, mortars

13     were manufactured in workshops?

14        A.   No.

15        Q.   Would you agree with me that the military -- the defence industry

16     from before was at Saniteks which produced various types of shells, up to

17     700 pieces per day, the factory of medical equipment and medicines?

18        A.   Bosna Lijek and Saniteks, as the name suggests, it is normal to

19     expect them to produce medical equipment and, or rather, medical supplies

20     and medicines and this is the first time I hear that they also

21     manufactured other resources.

22        Q.   Feroelektro, did you know that it manufactured spare parts for

23     artillery pieces and ammunition?

24        A.   I believe that Feroelektro was destroyed, so I don't think -- I

25     don't know anything about that.

Page 15236

 1        Q.   Thank you.  We'll skip the less-prominent such factories or

 2     places of production.

 3             Is it correct that the 4th Motorised Brigade and the Pazarici and

 4     Tarcin units later merged and became the 14th Division which belonged to

 5     the 1st Corps but was outside the town centre itself?

 6        A.   Those units did merge to become a division and the division was

 7     formed by the command, or rather, the corps.

 8        Q.   Thank you.  I will no longer insist.  You told us what you knew.

 9             THE ACCUSED: [Interpretation] Let me just ask, I believe this map

10     has already been admitted into evidence so we don't have to tender it

11     again.

12             JUDGE KWON:  Yes.  It has been admitted already.  Just a second.

13                           [Trial Chamber and Registrar confer]

14             JUDGE KWON:  Yes, of course we did mark it for identification

15     pending the translation of those legends.

16             THE ACCUSED: [Interpretation] Thank you.

17             Could we now quickly see D339, please.

18             MR. KARADZIC: [Interpretation]

19        Q.   On the 5th of February, 1993, you were the Chief of Staff within

20     the 1st Corps, correct, that was your position?

21        A.   Yes.

22        Q.   Thank you.  Is this an order from the commander,

23     Mustafa Hajrulahovic, Talijan, an order to disband the mixed artillery

24     rocket brigade of the 1st Corps in Sarajevo and to distribute those

25     resources and send them to other units.  So a 120-millimetre mortar

Page 15237

 1     battery is being sent to the 3rd Motorised Brigade; a 105-millimetre

 2     howitzer battery is sent to the 1st Motorised Brigade; a self-propelled

 3     howitzer battery with all personnel and materiel technical means is to be

 4     sent to the 6th Motorised Brigade; the command reconnaissance battery to

 5     be deployed within four rocket units and so on.  So do you recall that

 6     this was an order to reorganise the part of the corps?

 7        A.   Well, yes.  This was part of the restructuring, but as I

 8     mentioned earlier it says here "disband the mixed artillery rocket

 9     brigade," but you can see when you look below where it says "battery,

10     battery, battery," that those weren't -- that wasn't really a brigade.

11     As I've already said, the 1st Corps did not have a single unit that was

12     of brigade level.  We called it -- we called them brigades, but in fact

13     they did not have the equipment and the weapons that would qualify them

14     as brigades.

15        Q.   Thank you.  This has already been admitted into evidence.  It's a

16     D exhibit.  Can we now have 1D3706.

17             Can you confirm that what we see in the lower left third, there

18     is Grdonj Brdo and then Spicasta Stijena next to it, we see some

19     trenches, communication trenches, both above and below?

20        A.   I cannot really confirm that.  I see that it's a settled area and

21     I see that there are streets running through those settlements.  Now,

22     what communications trenches you are referring to, I really can't tell.

23        Q.   Very well.  Can you recognise, can you see in the lower left-hand

24     corner, can you recognise a cemetery there?

25        A.   This is indeed a cemetery.

Page 15238

 1        Q.   And the barren area above, is that the Grdonj hill, the Grdonj

 2     Brdo, and then there is a relay facility on top of the hill?

 3        A.   If this is the cemetery next to the Podhrastovi hospital then to

 4     the north of it we do indeed see the Grdonj Brdo.  So I don't know if

 5     this is that cemetery or another cemetery.  So there is this cemetery but

 6     there is another one on Grlica Brdo, both of these cemeteries are in the

 7     same area.  So if what you're showing me here is next to the Podhrastovi

 8     hospital, then north of it is indeed Grdonj Brdo.

 9        Q.   Thank you.  Now, can you confirm that the top of the hill, of

10     this hill, Grdonj Brdo, and the slopes, the southern slopes, facing the

11     city, that they were under the control of the BH army?

12        A.   The Grdonj Brdo was under BH army control for about two --

13             JUDGE KWON:  I don't think the witness has confirmed Grdonj from

14     this map or this photo image.

15             THE ACCUSED: [Interpretation] Can we now see the image as we saw

16     it originally?  Can the general -- so that the general can see

17     Spicasta Stijena.

18             MR. KARADZIC: [Interpretation].

19        Q.   Is this Spicasta Stijena next to Grdonj Brdo?

20        A.   Well, can you show me which one?

21        Q.   Well, the only Stijena, or rock, that you can see in this image.

22        A.   Well, I don't see any rock.

23        Q.   Well, to the east of Grdonj Brdo, is that Spicasta Stijena, or

24     Peaked Rock?

25        A.   Well, I can't really tell you by looking at this map.  I know

Page 15239

 1     where Spicasta Stijena is, but I cannot really recognise it on this map.

 2        Q.   Very well.  Thank you.

 3             THE ACCUSED: [Interpretation] Can we then have 65 ter 0748,

 4     please.  I believe that all the participants in the courtroom are

 5     familiar with this landscape and that the Trial Chamber is also familiar

 6     with it.  65 ter 07048.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   That is a portion, a section, of the map of the Chief of Staff of

 9     the 1st Corps which office you held or which post you were at for a

10     while.

11             THE REGISTRAR:  That's Exhibit P1058, Your Honours.

12             THE ACCUSED: [Interpretation] Can we now blow up the boundary,

13     the border, between the central part and the top part.  Could we just

14     blow up the portion above the number 152.

15             MR. KARADZIC: [Interpretation]

16        Q.   General, can you now see Grdonj Brdo, elevation 96; and then

17     Hladivode, and so on?  Can you see it now?

18        A.   Well, yes, now I can see it clearly.

19        Q.   This is a map that was produced by your corps, and here we see

20     the 105th Brigade, the 1st Mountain Battalion, the 2nd Mountain

21     Battalion, mortar units, and then at the very top of Grdonj Brdo and its

22     southern slopes, they are under BH army control; correct?

23        A.   Yes, that's correct, but I have to say that these are not mortar

24     units deployed there.  These are weapons.  That's what this symbol

25     indicates.  This is one single artillery piece.  If it were to denote

Page 15240

 1     mortars, then it would be a circular distribution of weapons.  So these

 2     are artillery pieces, but it is correct this is the area of

 3     responsibility, or rather, the area that was under the control of the BH

 4     army and that stretched to the south of Grdonj Brdo and Hladivode that we

 5     can see on the map to the east.

 6        Q.   Thank you.  Are the lines rather close one to the other here near

 7     Grdonj Brdo, whereas in other areas they're more far apart?

 8        A.   Well, that's correct.

 9        Q.   Could you please now take a look at the area below 105bbr.  There

10     is a small flag symbol.  Is that the area between the Kljuc factory and

11     the large park?

12        A.   Well, yes, I think so and I think I marked that area.  So yes,

13     that's probably that location.  Just a minute, please.

14        Q.   Can you see the park right next to it and then further towards

15     Kosevo?

16        A.   Yes, I can see it.  That's exactly the spot.  Maybe 50 or 100

17     metres up or down.  We can't be absolutely precise because it's just a

18     map, but yes that's the general area.

19        Q.   Thank you.  Can you confirm that these triangular flags are

20     battalion commands?

21        A.   Yes, a triangle map indicates a command post of a battalion or an

22     artillery battalion.

23        Q.   Thank you.  And we see also that there is the 4th Battalion

24     there, mountain battalion.  Can you see that the 115th Brigade is close,

25     or rather --

Page 15241

 1             THE INTERPRETER:  Interpreter's correction.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   -- the 152nd, do you see that area, that's -- Ive asked you about

 4     it earlier?

 5        A.   Yes, and you said that it was close to the cathedral on

 6     Vase Miskina Street, the 152nd Brigade.

 7        Q.   Thank you.  Can we now go a little bit more to the west on this

 8     map -- or rather, just a moment, please.

 9             General, can you see that above the military hospital we can see

10     a howitzer on the hospital?

11        A.   Well, this is a tactical symbol for a gun or a cannon, and a

12     tactical symbol for a machine-gun.

13        Q.   Thank you.  Will you please mark it with a circle and could the

14     usher please assist us with electronic pen.

15        A.   [Marks]

16        Q.   Would you please put a number 1 there and then also mark the

17     military hospital compound and put a number 2 there.

18        A.   [Marks]

19        Q.   Can you see below it the military hospital compound?

20        A.   Well, if this is what it is I think so, but I'm not sure.

21        Q.   Thank you.

22             THE ACCUSED: [Interpretation] Could we now admit this section of

23     the map into evidence.

24             MR. KARADZIC: [Interpretation]

25        Q.   And, Witness, would you please initial this and put a date and

Page 15242

 1     also --

 2             THE INTERPRETER:  The interpreter did not hear the last part of

 3     the question.

 4             THE WITNESS: [Interpretation] Yes, these are mortars and I

 5     believe they belonged to the 115th Mountain Brigade.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Thank you.  Would you please put your initials and the date in

 8     the right-hand bottom corner.

 9             JUDGE KWON:  Mr. Karadzic, because you overlapped, the

10     interpreters didn't hear the last part of your question.  Could you tell

11     us what it was and make -- get a confirmation from the witness.

12             THE ACCUSED: [Interpretation] I believe that I asked whether

13     these were mortars of the 115th Brigade on the hill-sides of Trebevic and

14     the witness confirmed that.

15             MR. KARADZIC: [Interpretation]

16        Q.   Correct?

17        A.   Yes, that's correct, these are mortars.

18        Q.   Can I ask you then, above the indication where the 152nd Brigade

19     was at Vasin Han, was one of those weapons a cannon, one is a mortar, and

20     one a howitzer?

21        A.   Yes.  One of them is a recoilless gun, one of them is an

22     anti-aircraft gun, and one of those weapons is a mortar.

23        Q.   Thank you.  And to the east next to the number 1bb there is a

24     mortar and a [indiscernible].  What's that?

25        A.   Well, that's an anti-aircraft gun, a machine-gun.

Page 15243

 1        Q.   The so-called PAM, P-A-M.  Thank you.

 2             THE ACCUSED: [Interpretation] Now could we admit this, please.

 3             JUDGE KWON:  Yes.

 4             THE REGISTRAR:  Exhibit D1381, Your Honours.

 5             JUDGE KWON:  Just for planning purposes, how much more would you

 6     have?

 7             THE ACCUSED: [Interpretation] Well, I don't know how much time

 8     the Prosecution will need for its re-direct, but would it be possible to

 9     also get some extra time tomorrow with this witness because we have a

10     number of documents that were signed by this witness that I would like to

11     show him.  I will make a selection.  I won't use every single document,

12     but this man was a Chief of Staff for a period of almost a year.

13             JUDGE KWON:  Very well.  Let us proceed.

14             THE ACCUSED: [Interpretation] Could we now move to the western

15     part of this map of the town.  Thank you.

16             MR. KARADZIC: [Interpretation]

17        Q.   Could you mark, put a number 1 at Velesici.

18             Can you see the bus terminal and then Pofalici and then Velesici?

19        A.   Yes, I can see it now.

20        Q.   Put a number 1 to mark Velesici, number 2 at the railway station.

21        A.   [Marks]

22        Q.   Number 3 for Vrbanja bridge, can you see it?

23             You can see Grbavica; right?

24        A.   Well, yes, I can but I don't know which of these bridges would be

25     the right one.  I don't want to make a mistake.  I believe that this is

Page 15244

 1     it.

 2        Q.   Thank you.  Would you now please look at the deployments of the

 3     101st Brigade at Hrasno and Hrasno Brdo and could you explain what we see

 4     there.

 5        A.   What we can see there is that there is a command post of the

 6     105th and -- 101st and 143rd Brigade there at the same location.  But I

 7     have to add that these units and these -- this equipment was not within

 8     the area of responsibility of the 1st Corps in the town itself while I

 9     was the Chief of Staff.  This is the situation as it was after 1994 when

10     it was possible to move through the tunnel, to get in and out of it.

11        Q.   Well, they were called something else but they were in the same

12     area of responsibility, weren't they?

13        A.   Well, they had different names there, but I don't know what this

14     143rd unit is, for instance.  I don't know what that unit was.

15        Q.   Can we see mortars there and anti-aircraft weapons?  Can you tell

16     us what weapons we can see there, what symbols?

17        A.   To the south, this is an anti-aircraft machine-gun.

18        Q.   That's number 4; right?  Put a number 4 there, please.

19        A.   South-east from the brigade command there are mortars and

20     south-east from the brigade, the command post of the brigade, we have

21     mortars.  I'll put a number 5 there.  And I think I can't see any other

22     equipment and hardware there.

23        Q.   Thank you.  Would you please initial this and date it on the

24     left-hand side near Vrace.

25        A.   [Marks]

Page 15245

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

 2     please.

 3             JUDGE KWON:  Yes.

 4             THE REGISTRAR:  Exhibit D1382, Your Honours.

 5             THE ACCUSED: [Interpretation] Can we get the next westerly

 6     section of the town, please.  A bit back, a bit more to the east, to the

 7     east, please.  Thank you.  This is fine.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Can we see Halilovici here and was there a barrack there?

10        A.   There was a barrack, a JNA barrack, in Halilovici.  It was a

11     motorised battalion.

12        Q.   Thank you.  Can we see the television building here and the

13     radio -- the radio television building, the main building?  We can see

14     Otoka and then Dzemala Bijedica Street and then we get to Halilovici.

15        A.   Well, I know where all those buildings are but I just have to

16     find my bearings on this map.  Well, if this is the television complex,

17     compound, where I'm pointing with my pen.  Can you see it?  Novi Grad

18     municipality and the television compound.  I think that's the area here.

19        Q.   Well, would you use the pen, please.

20        A.   Well, I don't know if this is that facility.

21        Q.   Very well.  Now, do you agree that the entire area beyond the

22     television compound is an industrial area, that the Zica factory is

23     there, that Jastreb factory is there?

24        A.   Well, that is true, it was an industrial area which stretched

25     from Otoka all the way to Alipasin Most, Alipasin Bridge.  In other

Page 15246

 1     words, this was a stretch -- an area stretching east-west and that whole

 2     area was an industrial zone.

 3        Q.   Would you please then draw a line and connect Otok -- from Otok

 4     towards the north towards Dzemala Bijedica Street and the one-time

 5     Drinska Street.

 6        A.   [Marks]

 7             THE INTERPRETER:  Interpreter's note:  The interpreter could not

 8     hear the witness because he was not speaking into the microphone.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Thank you.  Would you please date and initial this.

11        A.   [Marks]

12        Q.   Now we are entering the zone of the 2nd or later 102nd Brigade,

13     or rather, the 3rd Brigade that later became 102nd?

14        A.   Well, I wasn't listening to what you were saying because I was

15     trying to mark this.

16             JUDGE KWON:  General, did you say something while making those

17     markings?  The interpreters couldn't hear you.

18             THE WITNESS: [Interpretation] While I was putting these markings

19     I was -- I didn't say anything.

20             JUDGE KWON:  Very well.

21             Yes, Mr. Karadzic.

22             We'll admit this separately.

23             THE REGISTRAR:  Exhibit D1383, Your Honours.

24             THE ACCUSED: [Interpretation] Could we now move further west,

25     please.  And then can we move it up a bit.  Thank you.

Page 15247

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Now can we see Nedzarici here that was under the VRS control --

 3     VRS army control and then we see the 155th and the 1st, 3rd, and

 4     5th Brigades that are in the neighbourhood.  In other words, Dobrinja,

 5     Alipasino Polje, and then Stupsko Brdo settlements; correct?

 6        A.   You have all this information on the map itself and I think this

 7     is rather reliable or accurate.

 8        Q.   Thank you.  Are these markings for mortars to the north of

 9     Vidikovac or Vlakovac or whatever the name may be towards the upper edge?

10        A.   Yes, two mortars.

11        Q.   Thank you.  Since we haven't marked anything, can we lift the map

12     to see all of Dobrinja.  Mojmilo, we see a marking for a mortar or what

13     is the other one?  Is it for an anti-aircraft gun?  Do you see the

14     separation line now in Dobrinja, red and blue, and at Mojmilo Hill we

15     have a few - what are they?

16        A.   [No interpretation]

17             THE INTERPRETER:  The interpreter did not hear the answer.

18             MR. KARADZIC: [Interpretation]

19        Q.   So machine-guns, anti-aircraft and then the triangle is the

20     command post of some battalion?

21        A.   The 1st Battalion; that's written there.

22        Q.   And in Dobrinja itself there is the command post of the 155th,

23     formerly the 5th Brigade and a few command posts of battalions, the 1st,

24     2nd, and 3rd, and a few mortars; right?

25        A.   Exactly.

Page 15248

 1        Q.   Would you please sign this as well and put the date.

 2             JUDGE KWON:  Did he mark anything?  I don't think so.

 3             Could you take a look at the transcript, page 101, line 4.  You

 4     followed-up with some questions.  Please check whether we missed

 5     anything.  His answer was not interpreted, what at Mojmilo hill, red and

 6     blue.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   May I ask you to mark on Mojmilo hill the command post of the

 9     1st Battalion and then the mortar and then these three PAMs.  Perhaps

10     there's more of them but three are marked.

11        A.   [Marks]

12        Q.   And then this straight line goes to the north and that is the

13     zone, or rather, it is a line where -- no, it's actually a battalion

14     line; right?

15        A.   Yes.

16        Q.   A battalion line, thank you.  Then here in Dobrinja, can you put

17     a circle around the command post and -- of the brigade I mean and the

18     command posts of the battalions.

19        A.   [Marks]

20        Q.   We see this for ourselves, don't we?  We can see the mortars?

21        A.   Only one battalion command post is marked here and three

22     battalions are marked, the 1st, 2nd, and 3rd.  And there is no number at

23     this command post that is marked here.

24        Q.   Does that mean that that is the disposition of the battalions,

25     that they don't have a command post marked?

Page 15249

 1        A.   Yes.  This one was to the north of Dobrinja and these two were

 2     south-east.

 3        Q.   Thank you.  Can you now put the date and your initials?

 4        A.   [Marks]

 5        Q.   Did you know that in Dobrinja and Omladinskih Radnih Brigada

 6     Street there was a prison?  I believe that it was in the basement of the

 7     post office and the bank.

 8        A.   This is the first time I hear of it.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] Can this section be admitted.

11             JUDGE KWON:  Yes.

12             THE REGISTRAR:  Exhibit D1384, Your Honours.

13             THE ACCUSED: [Interpretation] Can we now have the south, that is

14     to say to scroll the map up significantly.  And then a bit to the west.

15     And now could you lower it a bit.

16             MR. KARADZIC: [Interpretation]

17        Q.   Is this Igman, what you see now?

18        A.   Yes.

19             THE ACCUSED: [Interpretation] Can we lower the map now.  A bit

20     more, please.  Thank you.  Thank you.

21             MR. KARADZIC: [Interpretation]

22        Q.   What we see is the area of responsibility of the 4th, formerly,

23     and then the 104th.  Is this Hrasnica?

24        A.   Yes.

25        Q.   Is this one command post of this brigade in Sokolovic Kolonija?

Page 15250

 1        A.   According to the marking, yes, but it's not in the town of

 2     Hrasnica where it was before.

 3        Q.   How do you explain that?  There is nothing for the 104th.  Is

 4     this the 14th Division so the commander was not -- was not really

 5     involved in this?

 6        A.   Commanders had to be involved in all matters.  Why nothing was

 7     marked -- well, probably he did not provide the corps command with

 8     information.  I don't know when this map was made.  The command probably

 9     did not have this information and that's why it was not marked.

10        Q.   Thank you.  We are not going to mark anything here because we

11     cannot see any original markings.

12             THE ACCUSED: [Interpretation] Can we look at the upper left-hand

13     corner and see who drafted the map and signed it.

14             JUDGE KWON:  I think we also have a name on the bottom right

15     part.  Bottom, bottom right part.  Down.  Yes.

16             THE ACCUSED: [Interpretation] That's right.

17             MR. KARADZIC: [Interpretation]

18        Q.   Do you know this gentleman, Rizvo Pleh, then-Chief of Staff, and

19     his signature?

20        A.   Yes, I know him personally.

21        Q.   Thank you.  So it is an authentic map, although it is not

22     complete in view of the 14th Division?

23        A.   Just a moment, please.  Could we just see the upper left-hand

24     corner.  Could we see what unit.

25        Q.   The 12th Division.

Page 15251

 1        A.   According to what I see now, I don't know whether at the time the

 2     104th was within the 12th Division.

 3        Q.   It was within the 14th; right?

 4        A.   Well, according to the information on the map, as I have seen it

 5     just now, the 104th was not within this 12th Division.  And that is why

 6     that information is not contained, the information pertaining to that

 7     brigade.

 8        Q.   Thank you, General.

 9             THE ACCUSED: [Interpretation] Can we now have 1D3703.

10             MR. KARADZIC: [Interpretation]

11        Q.   Are you familiar with this area towards Spicasta Stijena and

12     these are trenches of the Army of Bosnia-Herzegovina?

13        A.   I know the area in its natural environment, but if you just look

14     at this it can be anywhere.

15        Q.   Do you know that the trenches were there facing each other?

16        A.   I know that the trenches were only 50 metres apart in some areas,

17     but I do not know whether this is actually that terrain.  I cannot see it

18     on the basis of this map.

19        Q.   Thank you.  Then I'm not going to torment you with this any

20     longer.

21             THE ACCUSED: [Interpretation] 3701, can we have that document,

22     please.

23             MR. KARADZIC: [Interpretation]

24        Q.   Do you know the name Meho Podrug?

25        A.   No, I don't know who the man is.

Page 15252

 1        Q.   You don't know where this monument is then?

 2        A.   No.  Now I see it for the first time.

 3        Q.   Thank you.  Then we're not going to deal with it.  Thank you.

 4             THE ACCUSED: [Interpretation] 1D913, can we have that, please.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Do you agree that this is a record of an interview of

 7     Vlatko Vukovic, son of Tihomir, on the 30th of March, 1993?

 8        A.   On the basis of what is written here, that's that record but I'm

 9     not familiar with the content or with the person that gave this

10     statement.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can we move on to the second page.

13             MR. KARADZIC: [Interpretation]

14        Q.   Can you see this here:

15             "From the beginning of the war ..."

16             This is a statement of this person, the Kosevo Hospital was

17     secured by --

18             THE INTERPRETER:  Interpreter's note, we cannot find it in either

19     language.

20             MR. KARADZIC: [Interpretation]

21        Q.   Can you look at this paragraph and it says that Juka's wolves

22     were where the pharmacy was.  Are you familiar with this deployment of

23     these units led by Juka and the Green Berets?

24        A.   While these units existed I was not in Sarajevo.  So as for all

25     of Juka's units that he had in town, that is, we established a single

Page 15253

 1     unit, the 2nd Independent Battalion.  This is the first time I see this.

 2     I don't know any one of these units.  That was probably in the initial

 3     period of the war.

 4             JUDGE KWON:  Probably this was not asked.

 5             Did you know that Kosevo Hospital was secured by the

 6     Green Berets?

 7             THE WITNESS: [Interpretation] I don't know, really.  First of

 8     all, that unit did not exist in our corps.  So initially that unit was

 9     not within the corps, that is to say the unit of the Green Berets did not

10     exist.  So whether someone was a member of the Green Berets, that is

11     something I really don't know about or how many such people there were.

12             MR. KARADZIC: [Interpretation]

13        Q.   Thank you.  What is the current name of the former JNA street?

14     Is it called the Green Berets Street?

15        A.   I think so.  I think so.  I'm not sure.

16        Q.   Does that mean then that they were outside of the control of the

17     1st Corps, these Green Berets?

18        A.   Well, these units I think at the time when I was Chief of Staff,

19     they did not exist at all, that is to say -- well, rumour had it that

20     they existed before the 1st Corps was established.  But as a unit, I

21     never heard of their existence and I did not know that there was a unit

22     outside the corps that was called the Green Berets.  I did know of the

23     name, namely, that some units were formed from the ranks of the

24     Green Berets.  That's the point.  I really don't know anything about

25     these units.

Page 15254

 1        Q.   Except for them being incorporated in the 1st Corps?

 2        A.   No, no.  Those who used to be in those units, depending on who

 3     was where, were transferred to the units that were established by the

 4     1st Corps, as was the case with Juka's units.  So he had his bases

 5     throughout town.  And then out of all of these bases and out of all of

 6     these units we barely managed to establish an independent battalion.

 7        Q.   Thank you.

 8             JUDGE KWON:  Mr. Karadzic, it's time for us to rise for today.  I

 9     think we have given you sufficient time to cover your case which was not

10     covered by the examination-in-chief.  Do you still need more time?

11             THE ACCUSED: [Interpretation] If the Defence and the Prosecution

12     could share a session tomorrow, I think that we would manage to tender

13     the documents that were either written by the witness or read by the

14     witness.

15             JUDGE KWON:  Can you tell us how much you would need for your

16     re-direct examination?

17             MS. GUSTAFSON:  At this point about five minutes, Your Honour.

18                           [Trial Chamber confers]

19             JUDGE KWON:  You will have three-quarters of an hour, up to

20     three-quarters of an hour tomorrow morning.

21             THE ACCUSED: [Interpretation] Thank you.

22             JUDGE KWON:  We'll continue tomorrow, General.  In the meantime

23     probably you are aware of it but you are not supposed to discuss with

24     anybody about your evidence.  Do you understand that, General?

25             THE WITNESS: [Interpretation] Yes, thank you.

Page 15255

 1             JUDGE KWON:  Thank you.

 2             9.00, tomorrow morning.

 3                           --- Whereupon the hearing adjourned at 2.31 p.m.,

 4                           to be reconvened on Thursday, the 23rd day of

 5                           June, 2011, at 9.00 a.m.