Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15371

 1                           Friday, 24 June 2011

 2                           [Open session]

 3                           [The witness takes the stand]

 4                           [The accused entered court]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Mr. Karic.  I hope you had a good rest.

 8             THE WITNESS: [Interpretation] Good morning.

 9                           WITNESS:  HAJRUDIN KARIC [Resumed]

10                           [Witness answered through interpreter]

11             JUDGE KWON:  Yes, Mr. Karadzic.  You have five minutes.

12             MR. ROBINSON:  Excuse me, Your Honour.  Just one point of

13     information.

14             Does Rule 15 bis apply when you don't have the reserve Judge

15     sitting?

16             JUDGE KWON:  Thank you for your reminder.  We're sitting pursuant

17     to Rule 15 bis, with Judge Flavia Lattanzi being away due to her personal

18     urgent matters.  Thank you, Mr. Robinson.

19             Yes, Mr. Karadzic.

20             THE ACCUSED: [Interpretation] Good morning, Excellencies.  Good

21     morning to all.

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

23        Q.   [Interpretation] Good morning, Mr. Karic.

24        A.   Good morning.

25        Q.   Mr. Karic, who beat you at Pale, out of the people you know?

Page 15372

 1        A.   Well, this man, Kusic, I don't know what his first name is.  I

 2     didn't know really know him.  I knew him a bit, and then I didn't know

 3     him.

 4        Q.   He is no longer alive; right?

 5        A.   No, that's not the one.  This is another one, a younger one.

 6     It's not Rajko Kusic.  It's a younger one.

 7        Q.   You said that the guards did not beat you, so he wasn't a guard;

 8     right?

 9        A.   I don't know who a guard was, who was a guard.  I couldn't see

10     anyone, really.

11        Q.   Is it correct, Mr. Karic, that this Fehim Hrvo lost his life at a

12     check-point because he did not want to stop because he had an automatic

13     rifle and a hand-grenade in his car?

14        A.   That, I do not know.

15        Q.   Is it correct that this other one had a heart attack and that he

16     died in the operating room?

17        A.   Which other one?

18        Q.   You said the three died?

19        A.   That's right.  And he didn't die of a heart attack.  He died of

20     the beatings.  They were beaten.

21        Q.   Thank you.  What was Braco Paradzina, what office did he hold,

22     the one who cautioned you to seek shelter?

23        A.   I know before the war, he had his own transportation business.  I

24     don't know what he was then.

25        Q.   He was not an official in the municipality; right?

Page 15373

 1        A.   I don't know.

 2        Q.   What about Centrotrans; who was this Mico Danojlovic, what did he

 3     do there?

 4        A.   He worked in Sarajevo, in a warehouse in Centrotrans.  When the

 5     war broke out, he was sort of a boss, he was sort of the guy in charge.

 6     I don't know what to call him.

 7        Q.   Oh, a warehouse worker was the boss.  Did he have the authority

 8     to dismiss you?

 9        A.   Well, I don't know whether he had the authority to do that, but

10     he told me not to come anymore.

11        Q.   And then you said that for a while you did not go out because

12     they started arresting Muslims; right?

13        A.   That's right.

14        Q.   Sir, this Nasko Smajic, who died of a heart attack, you say he

15     did not die of a heart attack?

16        A.   What do you mean, heart attack?  They beat him black and blue.

17     They killed him by beating him.  They were beaten with rifle-butts,

18     sticks, they kicked them.  They did all sorts of things.

19        Q.   We're going to ask for medical documentation, sir.  We're going

20     to ask for Pale to inform us about everything.

21             Let me put this to you, Mr. Karic, saying how things actually

22     were:  You had close relations with your brother-in-law, Ibro, and that

23     is where you sought shelter when Paradzina told you to leave before

24     things calmed down.  Then they called you to come to work.  Then you

25     worked.  Then you were transferred to the ticket office, because there

Page 15374

 1     was more work at the ticket office because of the large number of

 2     refugees.  Then you heard of this operation on the 22nd of May in

 3     Renovica.  Then you were hiding until the 30th of May because you knew

 4     that you were linked to Ibro, and then you were arrested; right?

 5        A.   That is not right.

 6        Q.   What is not right from amongst all of this?

 7        A.   What you say, that you were -- that I was linked to Ibro, that he

 8     was --

 9             JUDGE KWON:  Just a second.  Yes.

10             JUDGE BAIRD:  Mr. Karadzic, may I make a suggestion.

11             You're now putting your case to the witness, are you not?  Now, I

12     would suggest that as you put one suggestion, you give him a chance to

13     answer yea or nay.  He answers.  Then you put another one.  And so at the

14     end of the day, he will have answered all the suggestions, and not just

15     the last one.  I would suggest this.  Thank you.

16             THE ACCUSED: [Interpretation] Thank you, Your Excellency.

17             But, again, it's due to time.  All my mistakes are due to a lack

18     of time.

19             MR. KARADZIC: [Interpretation]

20        Q.   So all the things up to Ibro, you thought all the other things

21     were right; right?

22        A.   I don't think that I was hiding.  I simply couldn't walk around.

23     I was afraid to go out.  I had no reason to hide.  I had no reason to

24     think that -- well, a person is afraid.  You hear all sorts of things,

25     you hear all sorts of bad things.  And what you claim, that I was hiding

Page 15375

 1     at Ibro's and went to Ibro, first of all, I wasn't staying with Ibro.  I

 2     was staying with my father-in-law and mother-in-law.  What you're saying

 3     that some kind of thing happened, I don't know about that because that

 4     happened after all of that.  I don't know.  You're accusing me of

 5     something that is not true.

 6        Q.   All right, we'll take it slowly.  You went to work.  You passed

 7     by Serb check-points, they checked your ID, and they let you go after the

 8     car would be checked; right?

 9        A.   You mean when I was coming from Sarajevo?

10        Q.   And when you went to Sokolac.

11        A.   Yes.

12        Q.   When you went to Sokolac and when you went to Renovica; right?

13        A.   That's right.

14        Q.   The Serb drivers brought you food?

15        A.   Well, that happened once.  And it wasn't a driver, it was a

16     conductor, but it's all the same.

17        Q.   People who were not in authority and not in government,

18     Paradzina and then later on this Miso Danojlovic, advised you to get

19     away, to seek shelter, and then after that, two or three days later, they

20     called you to come back to work; right?

21        A.   That's right.

22        Q.   Then you saw and heard that the operation in Renovica was

23     underway on the 22nd of May.  Until then, you worked normally; right?

24        A.   Well, it wasn't exactly normal, but I was working.

25        Q.   Did you see and hear that there was this operation underway in

Page 15376

 1     Renovica?

 2        A.   I saw some people setting out, but I said what Lazar said

 3     yesterday.  It's not that I realised where they were going and why.

 4        Q.   After that, from the 22nd of May until the 30th of May, you did

 5     not go to work; right?

 6        A.   That's right.

 7        Q.   The 30th of May, you were arrested, you were brought into

 8     custody, and you made a statement on the 31st of May; right?

 9        A.   Well, it's not that I gave a statement.  It was just along the

10     way, in the camp, when this man just asked me a few questions.  It was

11     just a few sentences.  It was no statement.

12        Q.   Sir, there was fighting in Praca, Bogovici, and in other Muslim

13     villages that had surrendered weapons?

14        A.   As far as I know, no.

15        Q.   Then you were in this cultural centre, in prison, where

16     28 Muslims were brought in, fighters from Renovica, and you say 60, and

17     then you say 150 to 200?

18        A.   I explained that to you yesterday.  100, 200, 300, it doesn't

19     really matter at all, and I don't know that.  And all of those who were

20     brought in, they were brought in before me, that is to say, the 22nd, and

21     I was brought in on the 30th.  First of all, they were not fighters or

22     soldiers; they were civilians.

23        Q.   At line 15, the witness said that as far as he knew, there was

24     not any fighting in the villages where had handed over their weapons, and

25     that's not in the transcript.

Page 15377

 1        A.   How can I know?  I'm not interested in that at all.

 2        Q.   Do you know that Praca was returned to the Muslims after the war

 3     and that they formed the municipality of Pale, Praca?

 4        A.   That happened afterwards, after the war, so this division of

 5     sorts.

 6        Q.   Do you know --

 7             JUDGE KWON:  Mr. Karadzic, now it's for you to put your last

 8     question.

 9             MR. KARADZIC: [Interpretation]

10        Q.   In Kula, nobody beat you, and at least once you reported to go

11     out to work.  And you were taken there kindly because better food was

12     received there, as well as cigarettes and tobacco, just like other

13     prisoners?

14        A.   That's not the way it was.

15        Q.   How was it?

16        A.   I did not report for that.  This man, this sergeant, took me

17     there, I don't know, to have an egg or something like that.

18             THE ACCUSED: [Interpretation] Thank you.

19             JUDGE KWON:  Thank you, Mr. Karadzic.

20             Mr. Hayden.

21             MR. HAYDEN:  No questions, Mr. President.

22             JUDGE KWON:  Thank you.

23                           [Trial Chamber confers]

24             JUDGE KWON:  Very well.

25             Mr. Karic, that concludes your evidence.  On behalf of the

Page 15378

 1     Tribunal and the Bench, I thank you for your coming again all the way to

 2     The Hague to give it.  We appreciate it very much.  You are free now to

 3     go.

 4             THE WITNESS: [Interpretation] Thank you.

 5                           [The witness withdrew]

 6             JUDGE KWON:  Who is the next witness, Mr. Gaynor?

 7             MR. GAYNOR:  The next witness, Mr. President, will be

 8     Nebojsa Ristic, and we'll be calling this witness viva voce,

 9     Mr. President.

10             JUDGE KWON:  Thank you.  Let's bring in the witness.

11             And your estimate of time for your direct is ...?

12             MR. GAYNOR:  It remains one hour and a half, Mr. President.

13                           [The witness entered court]

14             JUDGE KWON:  Good morning, sir.

15             If you could take the solemn declaration, please.

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

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

18                           WITNESS:  NEBOJSA RISTIC

19                           [Witness answered through interpreter]

20             JUDGE KWON:  Thank you, Mr. Ristic.  Please make yourself

21     comfortable, please be seated.

22             THE WITNESS: [Interpretation] Thank you.

23             JUDGE KWON:  Thank you.

24             Mr. Gaynor.

25             MR. GAYNOR:  Thank you, Mr. President.

Page 15379

 1                           Examination by Mr. Gaynor:

 2        Q.   Could you state your full name for the record, please?

 3        A.   My name is Nebojsa Ristic.  My father's name is Cedomir.

 4        Q.   What is your date of birth?

 5        A.   The 9th of January, 1972.

 6        Q.   What is your nationality?

 7        A.   Serb, Orthodox.

 8        Q.   What was your occupation in the period between mid-April 1992

 9     until the end of the conflict?

10        A.   I worked on the security detail of the president of

11     Republika Srpska.

12        Q.   Was there a slight change in your duties in mid-1994?

13        A.   Well, up until mid-1994, I worked on providing security for the

14     buildings where the president and his family were staying.  And from

15     mid-1994, I was only in charge of his personal security.

16        Q.   Who was your formal employer during that entire period?

17        A.   Up until May 1992, I was an employee of the Serb

18     Democratic Party.  I worked on the security of the president of the

19     party, the SDS, and their buildings.  And from May 1992, when the MUP was

20     established, I was an employee of the Ministry of the Interior of

21     Republika Srpska in the State Security Sector.

22        Q.   Now, I want to focus on the locations where President Karadzic

23     lived and worked during the period April 1992 until the end of the

24     conflict.

25             First of all, could you explain to the Court, where did

Page 15380

 1     President Karadzic live from April 1992 until late 1995?

 2        A.   President Karadzic lived or resided with his family at

 3     two locations between April 1992 and the end of the conflict in 1995.

 4     The first location was at the Panorama Hotel complex, or to be precise,

 5     there was a weekend cottage above the hotel complex that we referred to

 6     as Villa Sipad.  The second location was a family home at the other end

 7     of Pale in a place called Krivace.

 8        Q.   When, approximately, did President Karadzic move his residence

 9     from Villa Sipad to Krivace?

10        A.   Towards the end of 1993.

11        Q.   I want to focus now on the locations where the president worked

12     while he was in Pale.  Could you tell Their Honours where he worked in

13     Pale?

14        A.   At the time between 1992 and 1993, the president's office was at

15     three locations.  The first one was in a building called Kikinda.  Then,

16     at the end of 1992, the office was relocated to the Panorama complex of

17     buildings, to a building called Mali Dom.  Finally, in 1994 it was

18     relocated to the administrative building of the Famos factory.

19        Q.   Was his -- were his offices located at Famos until the end of the

20     conflict from 1994?

21        A.   Yes, until the end of the conflict.

22        Q.   I want to clarify your earlier answer.  You said between 1992 and

23     1993, the president's office was in three locations.  Did you mean to say

24     between 1992 and 1995, the president's office was in three locations?

25        A.   Yes, my apologies.  That's what I meant.

Page 15381

 1        Q.   Now, I want to turn to the Villa Sipad.  Were you -- during your

 2     duties guarding the Villa Sipad, were you based in the villa, itself, or

 3     in a different building?

 4        A.   While I was performing my duties, I was at the building, itself.

 5     Otherwise, when I was off duty, I was always nearby, within the compound.

 6        Q.   And where in the building were you based, and where did the

 7     president and his family sleep?

 8        A.   I had a room in the Hotel Panorama, whereas the president and his

 9     family were residing at the facility that I secured; namely, Villa Sipad.

10        Q.   Now, within the Villa Sipad, could you tell Their Honours,

11     briefly, the communications facilities that were available that you saw

12     there?

13        A.   At the Villa Sipad, we had a telephone line, a radio set, and

14     there was a military telephone line there, a field telephone set.

15        Q.   Was there any back-up electricity generator at the Villa Sipad?

16        A.   Yes.

17        Q.   Do you happen to know how it worked or whether there was fuel for

18     it?  Do you happen to know anything about it?

19        A.   Power cuts were quite frequent during that period of time, and

20     these generators would switch on automatically whenever it happened.  As

21     for how they were fueled, I truly don't know.

22        Q.   Now, after President Karadzic and his family moved to the house

23     at Krivace, did the electricity generator remain at Villa Sipad?

24        A.   I think that the generator was also moved to the house at

25     Krivace.

Page 15382

 1        Q.   Did you personally act as a courier at Villa Sipad?

 2        A.   My sole duty was that of a security detail, though whenever it

 3     was necessary for me to deliver something to a certain location, I did.

 4        Q.   Were there others who performed courier duties at Villa Sipad?

 5        A.   Yes, there were people assigned to that duty, since they were

 6     couriers working for the president's office.

 7        Q.   Do you know the Republic Communications Centre in Pale?

 8        A.   Yes.

 9        Q.   Did the couriers ever take communications to or from the

10     Republic Communications Centre?

11        A.   They would convey messages.  There was communication between the

12     centre and the office.

13        Q.   Now, President Momcilo Krajisnik, the president of the Assembly,

14     where was he living during this period?

15        A.   He also lived in the Hotel Panorama complex.

16        Q.   And Ms. Biljana Plavsic, where did she live?

17        A.   She would come to Pale occasionally and had a place to stay

18     there.

19        Q.   Do you recall --

20        A.   [Indiscernible]

21        Q.   Sorry, I didn't catch your last answer there, Mr. Ristic.  Could

22     you repeat it, please?

23        A.   Ms. Biljana Plavsic also had her rooms at the Hotel Panorama

24     complex, but she was there more rarely than the president of the

25     Assembly, the speaker.

Page 15383

 1             MR. GAYNOR:  Could I request 65 ter 2021, and if we could go to

 2     page 8 of that, please.

 3        Q.   Do you recognise this building that's circled?

 4        A.   Yes.

 5        Q.   What is it?

 6        A.   This is the building where the president stayed with his family

 7     from late 1993 onwards.  This is the building at Krivace.

 8        Q.   Is that your handwriting at the top of the photograph with the

 9     date, 19th February 2009?

10        A.   Yes.

11             MR. GAYNOR:  Can we go to page 9 of this same 65 ter number,

12     please.

13        Q.   What is that building?

14        A.   I think it's the same building, it's the same house at Krivace

15     where the president stayed.

16        Q.   Did you mark on this photograph the points marked "1" and the two

17     points marked "2"?

18        A.   Yes.

19        Q.   Could you explain what those points refer to?

20        A.   Under "1" is the house where the security personnel stayed.  That

21     was our base.  My colleagues and I stayed there.  Under "2" are the

22     houses that the MUP forces used to secure the building.

23        Q.   Within the house, itself, do you know what communications

24     facilities were present there?

25        A.   I do know that they had recourse to telephone.

Page 15384

 1             MR. GAYNOR:  I'd like to move now to the first page of this same

 2     exhibit.

 3        Q.   Do you recognise that building?

 4        A.   Yes.

 5        Q.   At the top, we see some words and the date and a signature.  Is

 6     that your handwriting and is that your signature?

 7        A.   Yes, it is.

 8        Q.   What is this building?

 9        A.   It's the Kikinda building where the office of the president of

10     Republika Srpska was housed initially.

11        Q.   Did you know any of President Karadzic's staff who worked at this

12     building?  No need to give names.

13        A.   Yes.

14        Q.   Do you know how communications would reach the president while he

15     was at work at this building?

16        A.   Well, for the most part, it was standard procedure.  You -- the

17     messages would reach the president's secretary, and she would convey them

18     further.

19             MR. GAYNOR:  Could we go to the next -- sorry, to the third page

20     of this exhibit, please.

21             We see some writing in the middle of this photograph.

22             Perhaps we could zoom in a little bit on the right-hand part of

23     this photograph.

24        Q.   And if you could tell us what that building is, Mr. Ristic,

25     please.

Page 15385

 1        A.   This is Mali Dom, part of the Panorama complex.  This was the

 2     place where the president's office was housed after it was moved from the

 3     Kikinda building.

 4             MR. GAYNOR:  Could we zoom in a little further on that building,

 5     Mr. Registrar, please.

 6        Q.   What floor was the president's cabinet --

 7             MR. GAYNOR:  Sorry, not the circled building, Mr. Registrar.

 8     It's the building -- thank you.

 9        Q.   Now, on that building on the screen in front of you with the

10     arrow pointing towards it, on what floor was the president's cabinet?

11        A.   On the ground floor.

12        Q.   Who was based on the first floor?

13        A.   This was where the office of the president of the

14     National Assembly was.

15        Q.   And who was based on the top floor?

16        A.   There were offices of the vice-presidents of the republic,

17     Mr. Koljevic and Madam Plavsic.

18        Q.   Do you know how communication would reach this particular

19     building?

20        A.   Well, mainly over the telephone and by way of the courier

21     service.

22        Q.   You've told us already that this building was within the

23     Panorama Hotel complex; is that right?

24        A.   Yes.

25        Q.   And did the Panorama Hotel complex have a back-up electricity

Page 15386

 1     generator?

 2        A.   Yes.

 3             MR. GAYNOR:  Can we move, please, to page 7 of this exhibit

 4     number.

 5        Q.   What does this photograph depict?

 6        A.   Well, the next location of the president's office that was within

 7     the compound of the Famos factory.

 8        Q.   On this photograph, we see writing at the top indicating this is

 9     Famos, and we see a number of figures on the photograph.  Did you mark

10     this photograph, yourself?

11        A.   Yes.

12             MR. GAYNOR:  Mr. Registrar, could we zoom in on the building with

13     all the figures on it.

14        Q.   Could you explain what "X" denotes?

15        A.   Well, the place where the president's office was.

16        Q.   And just briefly for Their Honours, could you run through what

17     "1," "2," "3," "5," "6," and "7" refer to?

18        A.   "1" is the entrance.  "2" is the back door.  "3" is the offices

19     where we were staying.  "4," you cannot see it here, is the entrance into

20     the compound; that is where the barrier is as well.  Then "5" is the

21     restaurant where -- where the security people had their meals.  Then "6"

22     is the other restaurant for guests and -- I mean clients, guests.  The

23     president had his meals there and all the officials.  "7" is the building

24     that was used as a school or the university.  I don't know which one.

25        Q.   How would communications reach the president's office within the

Page 15387

 1     Famos complex?

 2        A.   Well, for the most part, it was by telephone, PTT lines.

 3        Q.   Were you personally responsible for taking incoming calls and

 4     dealing with outgoing communications by telephone?

 5        A.   No.

 6        Q.   Did this Famos complex have access to its own electricity back-up

 7     generators?

 8        A.   Yes.

 9             MR. GAYNOR:  Could we zoom out back to the original size, please,

10     Mr. Registrar.

11        Q.   I think we see number 4 on this photograph.  Now, Mr. Ristic,

12     could you just remind us what number 4 denotes?

13        A.   Well, the entrance into the compound.  That is where the barrier

14     was and also the desk, the entrance desk.

15             THE INTERPRETER:  The interpreter did not hear the end, the very

16     end of the witness's answer.

17             MR. GAYNOR:

18        Q.   Could you repeat your answer, in particular the last part of your

19     answer, please, for the interpreter?

20        A.   Well, there was a fence, a wall around the rest of the factory.

21     You couldn't enter the compound anywhere else but there.

22             MR. GAYNOR:  Could we move now to page 6 of this exhibit number.

23        Q.   What is the set of buildings we see in this photograph?

24        A.   Well, also like the previous photograph, the Famos factory

25     compound, but from a different vantage point.

Page 15388

 1        Q.   Did you, with a pen, mark something to the -- on the left part of

 2     this photograph?

 3        A.   Yes.

 4        Q.   What did you mark there?

 5        A.   I marked the building that was used by the Ministry of Defence of

 6     Republika Srpska.

 7        Q.   Did you ever see any persons in military uniform at the Famos

 8     complex?

 9        A.   Since it was the Ministry of Defence that was there, there were

10     uniformed persons there.

11        Q.   Now, the Trial Chamber has heard evidence that President Karadzic

12     was also the supreme commander of the army.  Are you aware of that?

13        A.   Yes.

14        Q.   Are you aware of any meetings that took place in Pale with senior

15     military figures?

16        A.   Yes.

17        Q.   Could you describe, more or less, how often such meetings would

18     take place?

19        A.   Well, I cannot say exactly, but I know that more often there were

20     meetings in the beginning, that is to say, in 1992 and 1993.  Afterwards,

21     it was less frequently.  I don't know, I'm not sure.

22        Q.   Did you recognise any of the military figures who would attend

23     those high-level meetings?

24        A.   Well, for the most part, yes.

25        Q.   Could you just give us a few names of who would come, to the best

Page 15389

 1     of your recollection?

 2        A.   Well, for the most part, these were people who made up the

 3     Supreme Command, I mean, highly-positioned officers of Republika Srpska

 4     who had different duties.  They all came.  I really wouldn't want to

 5     single anyone out.  Well, anyway, they did come.

 6             MR. GAYNOR:  And, Mr. President, I'd like to tender 65 ter 21021.

 7             JUDGE KWON:  In the meantime, I would like those markings and

 8     legend to be interpreted.  In particular, I saw page 5, this drawing done

 9     by the witness, and all are written in Cyrillic.  I think it would be

10     better off if we had translation.

11             MR. GAYNOR:  Yes.  I believe we've up-loaded a translation of

12     most parts of this exhibit number.

13             JUDGE KWON:  But still --

14             MR. GAYNOR:  We will make sure that that is done.

15             JUDGE KWON:  In the meantime, we'll mark it for identification.

16             MR. GAYNOR:  Thank you, Mr. President.

17             THE REGISTRAR:  As MFI P2841, Your Honours.

18             MR. GAYNOR:  Could I now call up, please, 65 ter 23169.  This is

19     a map of Pale, dating from approximately 1994, prepared by the

20     Government of the United States.

21        Q.   When this map comes up, Mr. Ristic, if you could see if you could

22     find the Panorama complex on it.

23             Do you see the Panorama complex?

24        A.   Yes.

25        Q.   Now, I'd like you to take a pen, with the assistance of the

Page 15390

 1     Usher, and mark six locations on this map, simply put a circle at each

 2     location and then a figure.

 3             Now, if you could circle the Panorama complex and put down "1."

 4             JUDGE KWON:  Could you wait until you're assisted by the Usher.

 5             Yes, please proceed.

 6             MR. GAYNOR:  Thank you, Mr. President.

 7        Q.   Could you circle the Panorama complex and put down the

 8     figure "1"?

 9        A.   [Marks]

10        Q.   Circle the Famos complex and put down the figure "2."

11        A.   [Marks]

12        Q.   Could you mark the direction of the Kikinda complex?

13        A.   [Marks].  I think this is it.

14        Q.   Could you put down the figure "3" there, please?

15        A.   [Marks]

16        Q.   Is the house at Krivace on this map?

17        A.   No.

18        Q.   Could you just indicate approximately where it was, in terms of

19     direction?

20        A.   [Marks].  It's in this direction, somewhere around here [marks].

21        Q.   Could you put down a "5" there, please?

22        A.   [Marks]

23             JUDGE BAIRD:  I think that should be "4," Mr. Gaynor.

24             MR. GAYNOR:  Indeed.  We can use "4" for the next one.  Thank

25     you, Your Honour.

Page 15391

 1        Q.   For the Republican Communications Centre, and as far as you're

 2     able to tell, could you circle its approximate location and put down the

 3     figure "4"?

 4        A.   Sorry.  Which number?

 5        Q.   Number 4 for the Republic Communications Centre.

 6        A.   Very well.  [Marks]

 7        Q.   Finally, could you put down Dom Kulture and mark "6," please?

 8        A.   [Marks]

 9        Q.   Could you put your signature and date at the bottom of the map,

10     please?

11             JUDGE KWON:  Today is the 24th of June.

12             THE WITNESS: [Marks]

13             JUDGE KWON:  This will be admitted.

14             THE REGISTRAR:  Exhibit P2842, Your Honours.

15             MR. GAYNOR:  I'd like to move now to a separate topic.

16        Q.   Mr. Ristic, do you know the name Miroslav Deronjic?

17        A.   Yes.

18        Q.   Who was he?

19        A.   He was a civilian official in the party, the

20     Serb Democratic Party, in the town of Bratunac.

21        Q.   Did he ever come to visit President Karadzic?

22        A.   Yes.

23        Q.   Could you give the Court a general picture of how often he would

24     come to Bratunac to visit the president -- sorry, how often he would come

25     to Pale to visit the president?

Page 15392

 1        A.   Well, he came maybe more than others.  Well, not a lot more, not

 2     a lot less.  He did come.  He was maybe in this group that visited the

 3     president more.

 4             JUDGE KWON:  Mr. Gaynor, if you could ask the witness how he did

 5     know Mr. Deronjic.

 6             MR. GAYNOR:  Yes.  Thank you, Mr. President.

 7        Q.   Could you answer that, please, Mr. Witness?  How did you know

 8     Mr. Deronjic?

 9        A.   Well, by virtue of the fact that he came there.  We were

10     duty-bound to know who was coming to see the president.  I don't know how

11     it was that I found out that it was actually Mr. Deronjic the first time.

12     Probably, I heard that from my colleagues or from the secretary.

13        Q.   Did you observe Mr. Deronjic's interactions with

14     President Karadzic?

15        A.   No.

16        Q.   Did you form any view as to whether they were on friendly terms

17     or unfriendly terms?

18        A.   Well, one got the impression that they were on friendly terms.

19        Q.   What gave you that impression?

20        A.   Well, as he was being received and as they were saying goodbye.

21        Q.   Continue your answer, Mr. Ristic.  What was it about when he was

22     being received and saying goodbye that led you to form the impression

23     that they were on friendly terms?

24        A.   Well, quite simply, they greeted each other cordially.  When he

25     was received, you could see that they were pleased, and also when they

Page 15393

 1     were saying goodbye.  At least that's my impression.  I don't know.

 2        Q.   Now, do you know the name Arkan?

 3        A.   Yes.

 4        Q.   Did you ever see President Karadzic and Arkan together?

 5        A.   Yes.

 6        Q.   Where was that?

 7        A.   It was in Bijeljina in 1995.

 8        Q.   What was the occasion?

 9        A.   Well, there was a review of that military unit, a military

10     parade.  And the president came to greet the parade, and I was on his

11     security detail.

12        Q.   Do you happen to know the purpose of that parade?

13        A.   I don't know exactly, really.

14        Q.   Now, while the president was in Pale between April 1992 and the

15     end of the conflict in late 1995, would he spend more of his time at his

16     residence or would he spend more of his time at his cabinet?

17        A.   He spent more time at his office than at the residence.

18        Q.   Was it the duty of your security detail to be kept informed of

19     his whereabouts while he was in Pale?

20        A.   Yes.

21        Q.   While he was at his cabinet, what were his -- what would he

22     generally be doing there, to the best of your knowledge?

23        A.   Well, for the most part, he was in meetings and performed other

24     duties that arose.

25        Q.   Were the meetings with civilian or with military people?

Page 15394

 1        A.   Most of the meetings were with civilian people.  But, of course,

 2     since he was the supreme commander, military officers came there as well.

 3        Q.   What kinds of civilian people would he hold meetings with?

 4        A.   In the main, they were presidents of crisis staffs of various

 5     towns in Republika Srpska.

 6        Q.   You've told the Court that towards the latter end of the

 7     conflict, you were assigned to the personal protection of the president;

 8     is that right?

 9        A.   Yes.

10        Q.   Would you personally travel with the president if he was

11     travelling outside Pale?

12        A.   Yes.

13        Q.   Where would those trips go to, generally speaking?

14        A.   Mostly, across Republika Srpska.

15        Q.   Could you tell us a little more about that?  Where, in

16     particular, in Republika Srpska would he go?

17        A.   We would go to Zvornik, Bijeljina, Banja Luka, Trebinje, Bileca,

18     Jajce, Mrkonjic, I mean Mrkonjic Grad, and so on, other places too.

19             MR. GAYNOR:  I'd like to call up now P2784, please.

20        Q.   When this document arrives on your screen, you'll see that it's a

21     communication dated the 3rd of August, 1995, which refers to a trip by

22     President Karadzic to Srebrenica which was due to take place on the

23     4th of August, 1995.

24             Now, I want to focus, first of all, on the addressees of this

25     communication.  We see the third addressee.  Could you look at that,

Page 15395

 1     please, Mr. Ristic?  It says:  "Main Staff of the VRS - OB Sector."

 2        A.   Yes, I see that:  "GSS VRS OB Sector."

 3        Q.   And what was the OB Sector?

 4        A.   I presume Intelligence and Security Sector.

 5        Q.   This trip, to the best of your knowledge, did it, in fact, take

 6     place, the trip to Srebrenica on the 4th of August, 1995?

 7        A.   Yes.

 8        Q.   Did you accompany the president on that trip?

 9        A.   Yes.

10        Q.   Now, you'll see the route described in this trip.  I want you

11     to -- just to focus on the route described.  It's in the third paragraph

12     down, and you'll see it says:

13             "Pale to Sokolac."

14             I want to note there's an error in the English translation.  It

15     should read "Pale to Sokolac."

16             Anyway, Mr. Ristic, it says:

17             "Pale-Sokolac-Han Pijesak-Vlasenica-Milici-Bratunac-Srebrenica."

18             Do you see that?

19        A.   Yes.

20        Q.   Was that the route that the convoy, in fact, took on the

21     4th of August?

22        A.   Yes.

23             JUDGE KWON:  Did you omit Zvornik on purpose?

24             MR. GAYNOR:  Sorry.  The route, Mr. President, does not refer to

25     Zvornik.  It says -- it should say:

Page 15396

 1             "Pale-Sokolac-Han Pijesak-Vlasenica-Milici-Bratunac-Srebrenica."

 2             JUDGE KWON:  I'm sorry.  I read the wrong lines apparently.

 3     Thank you.

 4             MR. GAYNOR:  Thank you, Mr. President.

 5        Q.   I'd like you, Mr. Ristic, to help us understand this route.

 6             MR. GAYNOR:  And so I'd like to call up a map.  That's 02227A.

 7             Can I suggest, Mr. President, that I provide Mr. Ristic with a

 8     hard copy of the map from which the electronic copy is taken so he can

 9     orient himself?  The Defence has seen this.

10             JUDGE KWON:  Yes, no problem.

11             MR. GAYNOR:  I'm providing Mr. Ristic with a portion of

12     65 ter 02227, and the version on the screen is a further smaller portion

13     of that.

14        Q.   Mr. Ristic, take your time on this, but if you could look at that

15     map and see if you can identify the towns of Milici, Bratunac and

16     Srebrenica.

17             THE ACCUSED: [Interpretation] May I inquire as to why we don't

18     have the map from July 1995 without the military markings, because this

19     map has nothing to do with that trip.

20             MR. GAYNOR:  Your Honours, I'm simply asking the witness to mark

21     the road route from Milici to Bratunac-Srebrenica.  I won't be asking

22     anything else about this map.

23             JUDGE KWON:  And we're not taking anything else, other than the

24     routing.  Let's proceed.

25             MR. GAYNOR:  Thank you.

Page 15397

 1        Q.   Witness, can you -- have you found Milici, Bratunac and

 2     Srebrenica on that map?

 3             Did you hear my question, Mr. Ristic?

 4        A.   Yes.  I've found them, all of them.

 5             MR. GAYNOR:  Could I ask the Registrar to further enlarge the map

 6     just a little more.

 7             Thank you, that will do.

 8        Q.   Could you take a pen and, with the Registrar's assistance, mark

 9     the road, the portion from -- the road as it comes in from Vlasenica to

10     Milici to Bratunac to Srebrenica?

11             JUDGE KWON:  Could you wait until -- is it okay, Mr. Gaynor?

12             MR. GAYNOR:  Yes, I believe that's okay, Mr. President.  Thank

13     you.

14             JUDGE KWON:  Very well.  Let's proceed.

15             THE WITNESS: [Interpretation] I don't see Vlasenica on this map.

16     I can only find Milici.

17             MR. GAYNOR:  That's fine.

18        Q.   Could you mark the route from Milici to Bratunac to Srebrenica?

19        A.   [Marks].  That would be it.

20        Q.   Right.  So this depicts the road as it comes in from Vlasenica to

21     Milici, to Bratunac, to Srebrenica; is that correct?

22        A.   Yes.

23        Q.   Could you sign and date that, please?

24        A.   [Marks]

25             MR. GAYNOR:  I'd like to tender that, Mr. President.

Page 15398

 1             JUDGE KWON:  Yes, that will be admitted.

 2             THE REGISTRAR:  As Exhibit P2843, Your Honours.

 3             MR. GAYNOR:  Could I call up, please, 65 ter 02062.

 4             THE ACCUSED: [Interpretation] May I suggest that the date of the

 5     4th of August be written there, or perhaps we should have it in the

 6     transcript.  What I'm concerned about is:  Why should we have a map from

 7     July 1995 depicting a route that was taken on the 4th of August, 1995?  I

 8     simply don't see why this military situation should be tied in with this

 9     trip.

10             JUDGE KWON:  The Chamber has taken your point, rest assured.

11             Let's proceed.

12             MR. GAYNOR:  The document which will be appearing on our screens

13     now is a communication from Beara, of the Intelligence and Security

14     Sector of the Main Staff, to the Security Department of the Drina Corps,

15     dated the 3rd of August, 1995.

16        Q.   Now, could you help us with the one thing here?  Do you see,

17     Mr. Ristic, that this is from the Intelligence and Security Sector of the

18     Main Staff of the VRS?

19             Would you like it to be blown up a little?

20        A.   Yes, please.  I can see it.

21        Q.   Thank you.  Is that the entity you referred to in the previous

22     document?

23        A.   I don't understand the question.  Could you repeat it or clarify

24     it?

25        Q.   Yes, I will, indeed.  In the last document, I asked you about an

Page 15399

 1     entity described as the OB Sector of the Main Staff.  Now, in this

 2     document, we see a reference to the Intelligence and Security Sector.

 3     That's on the second line of the top of the document.  Do you see that?

 4        A.   I do, yes.

 5        Q.   Is this the same entity that you described earlier, when I asked

 6     you what the OB Sector was?

 7        A.   You mean the other dispatch that was sent to them?  Yes, it was

 8     sent to them and to police stations, as far as I could see.

 9        Q.   Who was primarily responsible for the security of the president's

10     convoy?  Was it the police or was it the army?

11        A.   It was the police, the State Security Sector.

12        Q.   What, therefore, was the role of the army?

13        A.   From what I can read here, it seems that their role was to secure

14     a stretch of the road and to report back any information, since the

15     presence of a number of enemy groups was noted in the areas of Bratunac

16     and Srebrenica.

17        Q.   This document, as you can see, refers to a trip on the

18     4th of August, 1995, by President Radovan Karadzic, and refers to the

19     portion of the route from Sokolac to Han Pijesak to Vlasenica to Milici

20     to Bratunac to Srebrenica.  Do you see that?

21        A.   Yes, I do.

22        Q.   Does this appear to be a reference to the same trip that we've

23     been talking about that took place on the 4th of August, 1995?

24        A.   That is the trip; no doubt about it.

25             MR. GAYNOR:  I'd like to tender that for admission,

Page 15400

 1     Mr. President.

 2             JUDGE KWON:  Mr. Gaynor introduced this document as something

 3     written by Mr. Beara.  Do you know his rank?

 4             THE WITNESS: [Interpretation] No.

 5             JUDGE KWON:  This will be admitted.

 6             THE REGISTRAR:  As Exhibit P2844, Your Honours.

 7             MR. GAYNOR:  I'd like to call up now, please, 02132, please.

 8        Q.   Now, you've previously had the opportunity to look at this,

 9     Witness, and as we can see, it's scarcely legible in this form.  And if

10     we go to page 4, we'll see a handwritten version of it.

11             If we can go to page 4, please.  Page 3, possibly.

12             Now, if you look at this document, towards the end of the

13     paragraph which is paragraph 2, and just above paragraph 3, do you see

14     that portion?  It reads:

15             "The president of Republika Srpska and the commander of the DK

16     were in Srebrenica, in the brigade's area of responsibility, today."

17        A.   Yes.

18             MR. GAYNOR:  Now, if we go back to the first page of the B/C/S

19     version, and if we can keep the English.  Could we enlarge, as much as

20     possible, please, Mr. Registrar, the portion of the document that we've

21     just been looking at, which is the bottom portion of paragraph 2.  Thank

22     you very much.

23        Q.   I think you can see, in the typewritten version as well, that

24     there's a reference to the commander of the DK.  Do you see that?

25        A.   Truly, I don't.

Page 15401

 1             MR. GAYNOR:  Perhaps we can enlarge the last couple of words of

 2     the bottom of paragraph 2, Mr. Registrar.

 3             And I'd like to correct my words.  Earlier, I said this was a

 4     typewritten version.  It's not a typewritten version.  It appears to be a

 5     teletyped version.

 6        Q.   If you can see it, say so.  And if you can't, we can inspect it

 7     later and Their Honours will have that opportunity.

 8             Do you see the reference to the commander of the DK?

 9        A.   Yes, I see the last line, as well as the "DK Commander," if

10     that's what you're referring to, yes.

11        Q.   Do you happen to know who the commander of the Drina Corps -- of

12     the DK was on the 4th of August, 1995?

13        A.   No.

14        Q.   This refers to a trip, obviously, by the president, as well as

15     the commander, to the area of responsibility of the Drina Corps on the

16     4th of August, 1995.  Do you believe this to be a reference to the same

17     trip that we've been referring to earlier?

18        A.   I think it is the same trip.  It was the only one.  But I don't

19     recall any commander of the Drina Corps being with us -- or, rather,

20     being with the president.

21             MR. GAYNOR:  I'd like to tender that, Mr. President.

22             JUDGE KWON:  Yes, that will be admitted.

23             THE REGISTRAR:  Exhibit P2845, Your Honours.

24             MR. GAYNOR:  Mr. Registrar, could you bring up P2242, page 88 in

25     English, page 102 in B/C/S.  This is the appointment diary for

Page 15402

 1     President Karadzic for 1995.  It's already in evidence.

 2             Mr. Registrar, could I have page 88 in English, page 102 in

 3     B/C/S.

 4        Q.   If you look at the first two lines of this page, Mr. Ristic, you

 5     see a reference to:

 6             "4th of the 8th, 1995, 0900 - Srebrenica - visit."

 7             Do you see that?

 8        A.   Yes.

 9        Q.   Is that consistent with what you have told us earlier about the

10     visit to Srebrenica on the 4th of August, 1995?

11        A.   Yes.

12        Q.   Now, we won't be looking at any more documents, Mr. Ristic.

13     Thank you.

14             What did you do at Srebrenica when you arrived there on that day,

15     the 4th of August, 1995?

16        A.   Well, we attended the erection of a cross on a nearby hilltop.

17     It was more of a religious ceremony.  I don't really know what it was

18     really about because I was preoccupied with security issues.

19        Q.   Did you go into the centre of the town of Srebrenica?

20        A.   Well, as we were passing through, we did stop for a while.

21        Q.   What did you do in the centre of the town of Srebrenica?

22        A.   We visited an Orthodox Church, the one in the centre.

23        Q.   What was the purpose of the visit to the church?

24        A.   Well, quite simply, we went to see the site, and we found it

25     completely destroyed.  And we realised that the enemy forces had been

Page 15403

 1     keeping their chickens there while they were staying in the area.  You

 2     could tell by the excrements that were left behind.

 3        Q.   Was the church, in fact, destroyed, was it completely destroyed?

 4        A.   Well, you could only tell that it was a church by its contours.

 5     It was completely devastated.  Otherwise, there was no icons, no

 6     frescoes, everything was destroyed, but the walls were still standing.

 7             JUDGE KWON:  Mr. Ristic, not limited to that church, you said a

 8     while ago that when you -- let me find it.  Yes.  You simply went to see

 9     the site, referring to Srebrenica, and:

10             "... we found it completely destroyed."

11             Could you describe to us, as much as possible in detail, the

12     degree it was destroyed, the destruction?  Could you do that?  The degree

13     of destruction of Srebrenica town, as much as you can remember now.

14             THE WITNESS: [Interpretation] Well, as I was passing through

15     Srebrenica, my impression was that it wasn't that destroyed or at all;

16     perhaps only in the areas close to the confrontation lines, where

17     fighting was going on.  But in the town proper, it was not -- there was

18     no destruction at all.

19             JUDGE KWON:  But when you said, in line 19:

20             "Well, quite simply, we went to see the site, and we found it

21     completely destroyed," could you clarify?

22             THE WITNESS: [Interpretation] I meant the church and the grounds

23     around the church.

24             JUDGE KWON:  Thank you.

25             THE WITNESS: [Interpretation] You're welcome.

Page 15404

 1             MR. GAYNOR:

 2        Q.   Did you see a mosque or a minaret in the centre of Srebrenica?

 3        A.   No.  I don't remember, really.

 4        Q.   Was there any comment within the party that you were with as to

 5     any destruction of a mosque in Srebrenica town or in the environs of

 6     Srebrenica town?

 7             THE ACCUSED: [Interpretation] Leading and suggesting something

 8     that the witness did not confirm.  The witness did not confirm that the

 9     mosque was destroyed.  He said that he didn't recall seeing anything.

10             JUDGE KWON:  The point has been taken by Mr. Gaynor.

11             Yes, Mr. Gaynor.

12             MR. GAYNOR:  I'll move on, in fact.

13        Q.   At the religious ceremony, you refer to a cross.  Was it a

14     blessing of a cross or was it a blessing of something else?

15        A.   Well, my personal impression was that this was planned to be a

16     monumental site, like a memorial complex, and it was more of the

17     consecration of the ground, rather than anything else.  At any rate, it

18     was a religious ceremony.

19             MR. GAYNOR:  No further questions, Mr. President.

20             JUDGE KWON:  Thank you.

21             We'll have a break for half an hour and resume at 11.00.

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

23                           --- On resuming at 11.01 a.m.

24             JUDGE KWON:  Mr. Ristic, you will be further asked by

25     Mr. Karadzic in his cross-examination.

Page 15405

 1             Yes, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] Thank you, Excellency.

 3             Good morning to everyone.

 4                           Cross-examination by Mr. Karadzic:

 5        Q.   [Interpretation] Good morning, Mr. Ristic.

 6        A.   Good morning.

 7        Q.   May I ask you to make a pause between my question and your

 8     answer, and that applies to me as well, in order for everything to be

 9     entered into the transcript.

10             For example, on page 32, line 22, it was recorded that you said

11     that chickens were being kept in the church.  Is it true that this is

12     what you said, that domestic animals were kept there, and that according

13     to the dung found there, that included cattle and other animals, not only

14     chickens?

15        A.   It is quite true that I said that there was cattle, but I never

16     mentioned chickens.  And I concluded that based on the dung found there.

17        Q.   Thank you.  Let me ask you this:  It concerns this critical day

18     in Sarajevo.  Is it true that on the 4th and 5th of April, you were on

19     duty securing the premises of the Serbian Democratic Party at

20     Holiday Inn Hotel?

21        A.   Yes.

22        Q.   Do you remember that my family, whom you escorted via Vraca, left

23     Sarajevo at the 11th hour, virtually, under the hail of bullets?

24        A.   Yes, I remember that clearly.

25        Q.   Do you remember me sitting in the hall of the Holiday Inn and

Page 15406

 1     waiting for Mr. Izetbegovic so that both of us could go to a television

 2     studio, and also Mr. Kljuic from the HDZ was to join us, in order to

 3     appeal to the people, via television, to preserve peace and to try and

 4     prevent war?

 5        A.   I know that you appeared on television with these gentlemen that

 6     you mentioned.  Yes, I remember that.

 7        Q.   Thank you.  Do you remember that on that occasion, I gave an

 8     interview to Novi Sad TV, Milijana Baletic, the journalist, who recorded

 9     my meeting with Muhamed Cengic whilst we were waiting for

10     Alija Izetbegovic?

11        A.   I know this female journalist.  I know that she was there.  And I

12     know that you gave an interview to her, but I don't know what about.

13        Q.   Thank you.  Do you remember that my security detail did not allow

14     me to go back to Holiday Inn, but they escorted me from the TV studio to

15     Lukavica?

16        A.   Yes, I do.

17        Q.   Do you remember that on the morning of the 5th, while we were

18     still at Holiday Inn, my flat was fired at from a machine-gun, and that

19     after that it was looted and demolished, and that all our valuables,

20     clothes, and other belongings were still there, that not a single item

21     had been removed?

22        A.   Yes, I remember that, and I personally saw this footage.  I

23     believe that this footage was made by Mr. Mirko Caberlo [phoen].

24        Q.   They're having a problem with this last name.  Do you remember

25     that until the very last moment, we hoped that war wouldn't break out,

Page 15407

 1     and for that reason we did not evacuate either the archive of the SDS or

 2     our family belongings from my family flat, and that we virtually fled the

 3     town just to save our lives at the last minute?

 4        A.   Yes, I remember that this evacuation was urgent and quick and

 5     that there was no time for any extensive preparations.

 6        Q.   Do you agree that even before that, we did not remove anything

 7     that belonged to us anywhere and that we did not believe that we should

 8     leave Sarajevo?

 9        A.   As far as I know, nothing was evacuated beforehand.

10        Q.   Thank you.  After you have escorted my family, through the

11     fighting that was in Vraca already underway, you continued to Holiday Inn

12     to continue your duty on the premises of the Serbian Democratic Party and

13     to keep an eye on Professor Aleksa Buha and the journalist Baletic; is

14     that correct?

15        A.   Yes, among other things.  There were other people there as well.

16        Q.   Were you accompanied by Branko Kovacevic, also an official in the

17     party and some other people, but was there anyone present there from the

18     police, except you, who were actually working for our political party?

19        A.   I was captured alongside Vlado Ilic, who was also a security

20     officer from the Ministry of Interior of Bosnia-Herzegovina.  There was

21     Miroslav Karabatov [phoen] there as well, but I don't know which position

22     he held, and also Branko Kovacevic.

23        Q.   Thank you.  Is it true that you had coffee with the journalist

24     and the hotel staff, and that in the meantime, a huge crowd of people

25     gathered between Holiday Inn and the Assembly building of the Republic of

Page 15408

 1     Bosnia-Herzegovina, and that at one point this crowd burst into the

 2     hotel?

 3        A.   Yes, yes.  We were in the office of the deputy manager of the

 4     hotel.  That was Milan Jevtic at the time.  He was there on the premises,

 5     and Milijana Baletic, the journalist, and other members of the staff were

 6     there as well.  We were just having coffee when this happened, when these

 7     people burst in.

 8        Q.   Prior to that, did any of the Serbs fire, did you have sniper

 9     rifles or marksmen, or was there any activity conducted by the Serbs from

10     inside the hotel, Holiday Inn?

11        A.   We were there just to provide security.  There were no snipers,

12     and none of the Serbs opened fire.  We didn't notice anyone bearing arms

13     in the hotel.

14        Q.   Thank you.  Now that you mention Vlado Ilic being armed, is it

15     true that the first seven people from my security detail were assigned to

16     me from the joint MUP -- or by the joint MUP, and that before the

17     Special Brigade of the JNA was disbanded, had been at the JNA and then

18     were transferred to the MUP of Bosnia-Herzegovina; is that correct?

19        A.   As far as I know, it is.

20        Q.   Towards the end of April or in May, you were admitted into the

21     MUP of Republika Srpska.  Is it true that a vetting procedure was

22     conducted on that occasion and that you had received clearance, and that

23     applied to everyone who wanted to work in the Security Department?

24        A.   Yes, it's true.  I was checked, both physically and mentally, and

25     I passed all these tests.

Page 15409

 1             THE ACCUSED: [Interpretation] It's not recorded here that your

 2     pass was also checked.

 3             THE WITNESS: [Interpretation] Yes, yes.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Let's go back for a moment to Holiday Inn.  This crowd burst in

 6     and asked you to surrender.  Vlado Ilic asked, Who do we surrender to,

 7     counting that he was a policeman and that they were just a mob?

 8        A.   Yes.

 9        Q.   Did they arrive there in any official capacity?  Did they

10     resemble police officers or members of the military, or were they

11     resembling a mob, more than that?

12        A.   They resembled anything but any organised unit either from the

13     police or the military.  They resembled a mob, as you put it.

14        Q.   Thank you.  When Ilic, being a police officer, refused to

15     surrender, is it true that they threw a grenade into your room?

16        A.   Yes.

17        Q.   Is it true that you managed to hurdle this grenade back into the

18     corridor and that it exploded there on the spot?

19        A.   Yes, it is.

20        Q.   And at that point, did they start shooting from the top of the

21     surrounding buildings at your room from outside, through the windows?

22        A.   Yes.  After a while, they started shooting, and bullets started

23     coming through the window of the office where we were.

24        Q.   Thank you.  Were you captured there and taken to prison?

25        A.   We were captured.  And after we had been tortured, they took us

Page 15410

 1     to a prison.

 2        Q.   Describe this torture for us.

 3        A.   Physical abuse, beatings, psychological torture with lots of foul

 4     language, humiliation, and so on and so forth.

 5        Q.   Are you trying to say that this was not a proper arrest, but,

 6     rather, a lynch?

 7        A.   We would have been lynched had not the rest of the special unit,

 8     made up of Muslim and Croat special police officers, had come and rescued

 9     us from being lynched by this crowd.

10        Q.   How did you personally fare through this torture?

11        A.   Horribly.  It was difficult.  When I was captured, it was

12     discovered that 12 of my ribs were broken, I was bruised, and the rest of

13     it.

14        Q.   Thank you.  You were detained at the Public Security Station at

15     Logavina.  Were you beaten there as well?

16        A.   Yes, we were.

17        Q.   Did they force you to sing certain songs there?

18        A.   Yes, they did.

19        Q.   Which songs?

20        A.   Well, mainly the songs that are characteristic of the Muslim

21     people and that denote them, and things like that.

22        Q.   Thank you.  How many other Serbs were with you in the prison in

23     Logavina?

24             MR. GAYNOR:  Mr. President, I'd just like to note this appears to

25     be along the lines of tu quoque evidence.  The evidence being elicited,

Page 15411

 1     in our submission, is not particularly of assistance to Your Honours.

 2             JUDGE KWON:  Yes, I tend to agree.  And it's time to move on to

 3     another topic, Mr. Karadzic.

 4             Do you have any observation, Mr. Robinson?

 5             MR. ROBINSON:  Yes, Mr. President.

 6             This is an incident for which -- the sniping of protesters at the

 7     Holiday Inn, for which the Serbs have been blamed for that, and I believe

 8     there has been some evidence already that -- in our trial, that that was

 9     the part of the beginning of the war where the Serbs were sniping from

10     the SDS contingent --

11             JUDGE KWON:  I understand, so that's why I let it go for some

12     time.  But a detailed description I don't think will assist the Chamber

13     in such a detail.

14             MR. ROBINSON:  Very well.

15             MR. KARADZIC: [Interpretation] Thank you.

16        Q.   So after that, you were exchanged, you were medically treated,

17     your past was checked, and then you were employed by the police and

18     assigned to secure the facility where I and my family lived; is that

19     correct?

20        A.   Yes, it is.

21        Q.   Villa Sipad was mentioned here.  Am I right if I say that it was

22     a very bad and poor building and that this villa in no way could be

23     described as a luxurious building?  This was a very small weekend

24     cottage?

25        A.   You're absolutely right.  We just called it that.

Page 15412

 1        Q.   Thank you.  Is it true that there were frequent power cuts, and

 2     that even if the generator was working, due to the lack of electricity, I

 3     had difficulty in communicating with somebody else elsewhere in the

 4     country?

 5        A.   It is true that there was electricity cut off quite often.  I

 6     don't know what problems you had with communication systems, but I know

 7     that communication links were severed.

 8        Q.   Is it true that the radio set that Mr. Gaynor asked you about was

 9     used by you within the range of five kilometres in order to keep you

10     abreast of my movements, whether I was going to the Assembly or to attend

11     a meeting?

12        A.   Yes, it served for security purposes, and it covered these radios

13     at Pale and it provided contact with your security.  We were in touch

14     with them.

15        Q.   Is it true that we could not communicate with Sokolac or Sarajevo

16     via this radio set, let alone other places in Republika Srpska?

17        A.   Yes, it is true.

18        Q.   Today, on page 18, you were asked about meetings with military

19     personnel from the Army of Republika Srpska.  Do you remember that

20     military personnel, including Mladic and Gvero and commanders of the

21     Sarajevo Romanija Corps, on their route from Lukavica to Han Pijesak and

22     back, had to pass through Pale?

23        A.   Yes, they had to on this particular section.

24        Q.   Do you agree that quite a few of these meetings were just a

25     matter of courtesy, they stopped by to greet me?

Page 15413

 1        A.   Yes, that was my impression.  I would agree with you.

 2        Q.   Do you remember that you knew that from August 1994 until the end

 3     of the war, the relationships between the civilian and military

 4     structures were frosty and disrupted?

 5        A.   Yes, and I do remember that.

 6        Q.   On page 21, you were asked about Mr. Deronjic.  Do you agree that

 7     Mr. Deronjic never came to see me privately, but that he always came as a

 8     representative of municipal authorities?  So is it true that Mr. Deronjic

 9     ever visited me at my home or not?

10        A.   I don't remember him visiting you at your home, and I really

11     couldn't think of any reason why that should have happened.

12        Q.   Do you agree that Mr. Deronjic was a student of

13     Professor Koljevic and that they were acquaintances rather than with me?

14        A.   Well, I'm not sure that I know much about that.

15        Q.   Thank you.  Did you notice that I received anyone in a cold

16     fashion, or was I courteous and polite towards everyone, including

17     Deronjic?

18        A.   You were kind and polite towards everyone.  You received them

19     cordially.

20        Q.   Thank you.  You had an opportunity, weren't you [as interpreted],

21     to see me receiving representatives of the international community?  Were

22     these meetings also amicable and cordial and always ended with a lunch?

23        A.   Well, yes, for the most part, just as you described.

24        Q.   Thank you.  Can we then agree that Mr. Deronjic was not given any

25     better or worse reception than anyone else who came to see me?

Page 15414

 1        A.   Yes, we can agree on that.  I said that he was received by you in

 2     a cordial manner.

 3        Q.   Thank you.  On page 23, you were asked today something about

 4     Arkan and my encounters with him.  Do you agree that you never saw me

 5     having any contact with Arkan either before or after that?

 6        A.   As far as I know, there was just that one encounter.  That's as

 7     far as my knowledge goes.  And I was present there when you met him as I

 8     described.

 9        Q.   Thank you.  Was that a military ceremony that involved the lining

10     up of units that had returned from the region of Banja Luka?

11        A.   Yes.

12        Q.   Thank you.  When you started travelling with me, did you

13     accompany me on my trips to Belgrade?

14        A.   Yes, I did.

15        Q.   Did you notice or did somebody told [as interpreted] you that in

16     Belgrade, I had contacts with Mr. Arkan?

17        A.   No, I did not notice that, and I never heard of you having any

18     contact with Arkan during your stay there, of course.

19        Q.   Thank you.  Did you find out or did you see for yourself that I

20     communicated with him over the phone?  Did he ever call me or did I ever

21     call him whilst you were with me?

22        A.   I don't know.

23        Q.   You don't know that there were any contacts?

24        A.   No, I don't know that there were any contacts.

25        Q.   Did my friends, like Nogo, Djogo, Brana Crncevic, Momo Kapor and

Page 15415

 1     others come to my home?

 2        A.   Yes, they did.

 3        Q.   Those are mostly authors, artists, et cetera?

 4        A.   Yes, the ones that you mentioned are mostly writers, poets,

 5     painters.

 6        Q.   Now, talking about my travels, did you ever see or hear that I

 7     ever went to a casino to gamble?

 8        A.   That never happened while I was with you, nor do I know anything

 9     to that effect.

10        Q.   Thank you.  Do you remember that I asked you, who were on my

11     security detail, a dozen of you, I always asked you to be modest and to

12     always treat citizens and everyone else with whom you come into contact

13     in a civilised and polite manner?

14        A.   Yes, and I acted accordingly.

15        Q.   Is it true that I did not expect you to be involved in anything

16     else, other than providing security, and that all of you were worse off,

17     in terms of wealth, after the war than you were before the war?

18        A.   It's correct.

19        Q.   Do you know what my position was with regard to any unlawful

20     actions and my opposition to any sort of manipulative activities,

21     bribery, corruption, and do you know that I always insisted strictly that

22     all those who were involved with me in the political life should be

23     clean, crystal clean, on that score?

24        A.   Yes, I know about that.  I'm familiar with that.

25        Q.   For a while, you were present in the buildings where I resided

Page 15416

 1     with my family.  Were you able to observe me, personally, or my family

 2     becoming richer and richer on any score?

 3        A.   I was there, and I saw nothing that would indicate that you were

 4     accumulating any sort of wealth.  What I can say is that you were, in

 5     that respect, the same, you and your family, from Day 1 until the end.

 6        Q.   How were we?  What do you mean?

 7        A.   Well, you were as you had always been.  You did not gain anything

 8     of material value.  You did not change in that respect.

 9        Q.   Can you tell Their Honours what sort of attitude I had, as well

10     as my family, towards you, all of the members of the security detail?

11        A.   We had a very proper and decent relationship, full of mutual

12     respect and trust.

13        Q.   Thank you.  Would you agree with me that I spent a great deal of

14     time in Geneva, Brussels, Lisbon, attending various international

15     conferences, and that I was frequently away from home?

16        A.   Yes, I do agree you were away travelling quite often, especially

17     in the early days of the conflict, in 1992 and 1993.

18        Q.   Do you agree that at the time when you started accompanying me on

19     my travels, you were unable to communicate with anyone but the escort

20     detail within the range of five kilometres?

21        A.   Well, yes.  We had the mobile radio set which -- the range of

22     which was not very far.

23        Q.   Thank you.  And do you agree that I didn't have anything that

24     would be more sophisticated?  They knew that I didn't have a telephone or

25     a radio in my car, and I wasn't able to communicate with anyone outside

Page 15417

 1     of the range of three to five kilometres? ^

 2        A.   Yes, I do agree.  And if we learned anything over the radio set

 3     we had, we would be the ones communicating it to you.

 4        Q.   Thank you.  You were shown a telegram today which informed the

 5     security structures of the imminent passage of the president and other

 6     functionaries.  On that occasion, they were on their way to Srebrenica.

 7     Was this the usual sort of dispatch which was intended to provide

 8     information to the military and the police?

 9        A.   Well, yes.  This was just one of the many travels and one of the

10     usual dispatches accompanying it.

11        Q.   Thank you.  Do you agree that a motorcade of some three to

12     five cars was not a daily occurrence, and it was important for the army

13     and the police to know who it carried so that they know how to conduct

14     themselves?

15        A.   Yes, I do agree.  At that time, there weren't many vehicles to be

16     had, and fuel was scarce, and it was a rare occurrence, really, to see

17     two cars travelling together in a column.

18        Q.   Thank you.  Do you agree that there was always the risk of

19     running into either a sabotage group, or a group of stragglers of the

20     enemy army, or combat?

21        A.   Yes, I do agree.  Of course, there was always that risk.

22        Q.   Did you see or hear that we visited the residents of Donji Vakuf

23     at a time when we were actually being showered by shells?

24        A.   Yes.  I was there, I was present.

25        Q.   Do you remember that shells started landing around us at the

Page 15418

 1     point when we were heading towards Bronzani Majdan, close to Banja Luka?

 2     Mortar shells were landing all around us?

 3        A.   Yes, I do remember that.

 4        Q.   Do you recall that the police suggested that luxury cars or

 5     civilian clothing should not be used, because then it would give an

 6     indication of an important delegation coming, which would place at risk

 7     both those involved and the residents of the area visited?

 8        A.   Yes.

 9        Q.   Am I right if I say that it was for those reasons only that I

10     would, on occasion, put on a military uniform, and that I did not

11     normally wear one at Pale?

12        A.   Yes, of course, and this was what the security structure advised

13     you, too, to do, and that's why you wore the military uniform, as you

14     said.

15        Q.   Thank you.  You mentioned presidents of crisis staffs.  Do you

16     agree that after the 1st of June, most of the crisis staffs were

17     abolished?  And when you said so, did you mean presidents of

18     municipalities and local authorities, who visited the government in order

19     to obtain some sort of assistance?

20        A.   Well, I wasn't familiar with their roles, and I don't know how

21     long the staffs existed.  I know that they were presidents of

22     municipalities, presidents of crisis staffs.  The purpose of their visits

23     was mainly what you said and to get information.

24        Q.   Thank you.  Now I'd like to ask you about the situation at Pale.

25             Do you remember that I was able to rub shoulders, as it were,

Page 15419

 1     with the Croats and Muslims who were residents at Pale?

 2        A.   Well, of course.  There were many such opportunities, especially

 3     in the early days around the break-out of the conflict in 1992.

 4        Q.   Do you recall also that the mosque and the Catholic Church at

 5     Pale remained intact?

 6        A.   Yes, I do recall that.

 7        Q.   Do you recall that my hairstylist, who had a private salon in the

 8     Hotel Panorama building, was a Croat?

 9        A.   I know the person, but I didn't know her ethnicity, though most

10     probably she was Croat.

11        Q.   Thank you.  Can you tell us, was Pale a dangerous place to be for

12     Croats and Muslims, during the time you were there, or was it quite safe?

13     To be more precise, did you hear of a single incidence of prosecution or

14     any sort of abuse against the Muslims and Croats at Pale?  I'm not asking

15     about Renovica.

16        A.   No, I didn't.

17        Q.   You described the trip to Srebrenica.  Was it a brief journey,

18     and was the return trip on that same day?

19        A.   Yes, it was just a short journey, and we returned in the

20     afternoon of the same day.  I don't when, exactly.

21        Q.   Is it true that there was no commander of the Drina Corps or any

22     other official -- or any other officer of the VRS with us?

23        A.   Well, as far as I remember, there was not a single VRS officer

24     with us.

25        Q.   Is it true that we never visited the municipality either at

Page 15420

 1     Bratunac, Vlasenica, Milici, Han Pijesak, Srebrenica?  Wherever we went,

 2     we never visited any representatives of local authorities?

 3        A.   As far as I remember, we did not visit either the municipalities

 4     or local authorities.

 5        Q.   Do you agree with me that there were no encounters with either

 6     the military or civilian authorities during that journey?

 7        A.   I do.

 8        Q.   Do you remember that we visited a church which was roofless, it

 9     didn't have any doors, there were just the walls standing, frescoes were

10     devastated, and, as you say, there were excrements of various sorts of

11     farm animals?

12        A.   Yes, I do remember that.

13        Q.   Do you also remember that we next attended a prayer service next

14     to a cross deep into the mountain, where a religious ceremony was taking

15     place?

16        A.   Yes, and I did say so in response to the Prosecutor's question.

17        Q.   I do agree with you, but I'm afraid it's not clear that it was

18     not in Srebrenica, itself.  It was deep in the hills?

19        A.   Well, I did say that it was a hill close to Srebrenica.  I don't

20     know the specifics, but it was pretty distant.

21        Q.   Thank you.  Do you know that it is part of our tradition that

22     where somebody was killed or perished, initially, where the intention is

23     to make a memorial site of sorts, you would first erect a cross, with the

24     intention of going on to build a memorial site which never ends up built?

25        A.   Yes.

Page 15421

 1        Q.   So you will agree with me that the character of this trip was --

 2     of this visit, that is, was solely religious, and it boiled down to this

 3     religious service?

 4        A.   Yes.

 5        Q.   In addition to the church, the destroyed church that we visited,

 6     did you have any knowledge at the time of anything else happening in

 7     Srebrenica, other than a military operation?  Were there any indications

 8     of there having happened anything else but a military operation?

 9        A.   The only knowledge I had was about the military operations, and

10     the groups of stragglers who were fleeing the area, but were still

11     lingering in the general area.  And I knew that there was still some

12     fighting going on.

13        Q.   Thank you.  Since there were no meetings taking place indoors,

14     rather, everything was taking place outdoors, did anyone at this

15     particular meeting mention any sort of killings or unlawful actions in

16     Srebrenica?  Were there any comments, innuendos, made to that effect?

17        A.   I don't recall any such thing happening, any comments.

18        Q.   Can we say that you were present during that visit, and that as

19     you returned from it, you didn't have any knowledge of either destruction

20     or killings in Srebrenica?

21        A.   Well, you can put it that way.  We returned without knowing

22     anything about any killings or destruction taking place in Srebrenica.

23        Q.   You formed an impression.  You were close by.  You were treated

24     by the family quite openly.  There were no encounters hidden from you.

25     So can you tell us, as a whole, what was my attitude toward crime or

Page 15422

 1     unacceptable sort of treatment of either the Serbs or the Muslims?

 2        A.   Well, you always condemned any crime, regardless of who it was

 3     directed against.  You were opposed to that, and you would protest and

 4     speak your mind accordingly whenever it happened, and in quite strong

 5     language.

 6        Q.   Mr. Ristic, how would you characterise me; as a tolerant, mild,

 7     or as a distant person, rigid, strict?  Was I the sort of person who had

 8     a great deal of tolerance in him and who was open and available to all

 9     those who wanted to get in touch with me?  Was I easily reachable, was I

10     open to encounters?

11        A.   As far as I, myself, am concerned, I have nothing but positive

12     opinion of you.  You could be reached easily, and you were quite a

13     tolerant person.  When I say that you could be reached easily, you would

14     receive everyone, talk to everyone, and tried to see what you could do to

15     address a matter.

16        Q.   Thank you.  Do you agree that many people wanted to take a

17     photograph with me and that it was, indeed, possible for all, and not

18     even you, as the security detail, were able to prevent this from

19     happening?

20        A.   Yes, I do recall this, because we had quite a lot of difficulty

21     with this, in terms of providing security.

22        Q.   Thank you.  You were able to see the various secretaries at work,

23     and you were shown a book that they maintained of my appointments.  Would

24     you agree that very often I would leave my office late at night,

25     sometimes at 2.00 or 3.00 in the morning, but, at any rate, after

Page 15423

 1     8.00 p.m.?

 2        A.   Yes, of course.  You spent long days at the office.  And when you

 3     came home, you only had a couple of hours sleep before you returned to

 4     the office again.

 5        Q.   Thank you.  Do you agree with me that the secretaries would keep

 6     note of who would go into my office, the date, hour, and when they went

 7     out of the office, as well as all my telephone contacts?

 8        A.   Yes, I know that records were kept.  I don't know the details.

 9        Q.   Is there anything you'd like to say that I haven't asked you

10     about, Mr. Ristic, and something that the Prosecutor has asked you about,

11     is there anything that you would like to state?

12        A.   No, there isn't anything I would like to add or state.

13             THE ACCUSED: [Interpretation] Thank you.

14             Your Excellencies, my examination is finished.

15             Thank you, Mr. Ristic, for coming here and testifying.

16             THE WITNESS: [Interpretation] Thank you, you're welcome.

17             JUDGE KWON:  Mr. Gaynor, do you have any re-examination?

18             MR. GAYNOR:  Yes, I do have some re-examination, Mr. President.

19             JUDGE KWON:  Please go ahead.

20                           Re-examination by Mr. Gaynor:

21        Q.   First of all, I want to talk a little about your statement of a

22     few minutes ago, that when you were in Srebrenica on the 4th of August,

23     1995, that there was no reference at all to any killings of any kind.

24     Was there any reference at all to the Serb soldiers who had died during

25     the Srebrenica operation?

Page 15424

 1        A.   I don't remember.  The impression I gained was that the memorial

 2     was in the memory of all the Serbian victims in the area.  I think that

 3     was mentioned now, be it soldiers or civilians who perished in and around

 4     Srebrenica during the war until 1995.

 5        Q.   Is it your belief that no Serb soldiers died during the

 6     Srebrenica operation?

 7        A.   I don't think nobody was killed.  That's my opinion.  I don't

 8     have any knowledge of it.

 9        Q.   At the religious ceremony, was there any acknowledgment of the

10     sacrifice of any Serb soldiers during the Srebrenica operation?

11        A.   Definitely not.  It was only at a later date when I learned

12     certain things about Srebrenica from the media.  I could not believe my

13     ears.  During my visit to Srebrenica, there was nothing to make that

14     impression on me.  I thought that this was simply some sort of a

15     propaganda campaign.

16        Q.   Going back to the religious ceremony, who provided security for

17     the president at that ceremony?

18        A.   The chief of security, who was my superior too.

19        Q.   Were there any military personnel whatsoever present at the

20     religious ceremony?

21        A.   No, there weren't.  As I said, no military personnel was present

22     at the ceremony.  There was no army close to us.

23        Q.   Do you know where, exactly, the ceremony was held?

24        A.   It was a hill above Srebrenica which could not be reached by car.

25     I do recall us going there on foot, and the slope was quite steep.  We

Page 15425

 1     went up-hill, and we helped the president climb it.  That's why I

 2     remember it.  But I don't know the exact location.  I can't remember.

 3        Q.   How far was the hill from the town of Srebrenica?

 4        A.   I can give you an assumption.  Let's say, perhaps,

 5     five kilometres.  But, at any rate, in the Srebrenica surroundings.

 6        Q.   Perhaps we can call up the map that you marked earlier and you

 7     could help us identify where that hill was.

 8             MR. GAYNOR:  Could I request 02227A, please.

 9             Could we zoom in on the area around the town of Srebrenica.

10        Q.   I can provide you with a hard copy of this map, Mr. Ristic, if

11     that would help you identify where this hill was.

12             JUDGE KWON:  And also why don't we zoom in further --

13             MR. GAYNOR:  Thank you, Mr. President.

14             JUDGE KWON:  -- concentrating on Srebrenica, I think.  Much

15     further.  I think the circled area appears to be Srebrenica.

16             MR. GAYNOR:  That's correct, Mr. President.

17             JUDGE KWON:  To the right, further, further.  To the right.  The

18     other way around.  No, the other way around, further.

19             You see Srebrenica there, so we zoom in further.  Zoom in.  Go

20     down, let's go down.  No, no, the other way.  Yes, go down further.  Go

21     down, go down.  Yes.  We can zoom in once again.

22             Can you mark the place, Mr. Ristic, now?

23             THE WITNESS: [Interpretation] I can't even begin to guess where

24     we could have been.  I really don't know even in which direction it was.

25     There's no way for me even to guess, never mind mark the place.  I'm

Page 15426

 1     really sorry.  Even if I were in Srebrenica, I wouldn't be able to find

 2     the place, and I can't find my way around the map.

 3             MR. GAYNOR:  I'll continue, Mr. President.

 4        Q.   You told us earlier that the hill was five kilometres, I think

 5     you said, from the town of Srebrenica; is that correct?

 6        A.   Approximately.  I assumed that it was that distance, but I don't

 7     have the precise information of the name of the hill or how far it was.

 8     I just know that it was close by and it was a hill near Srebrenica,

 9     that's all.

10        Q.   In one of the documents that was shown to you earlier, there is a

11     reference to the presence of enemy groups in this part of Bosnia.  Do you

12     remember that?

13        A.   Yes.

14        Q.   Now, were you concerned for the president's security as you were

15     escorting him to that hill?

16        A.   Yes, of course.

17        Q.   Were you aware that Srebrenica had fallen several months earlier

18     and had fallen under control of the Serb Army?  Several weeks earlier;

19     correction.

20        A.   Yes, I knew that.  We also knew that there were some Muslim armed

21     groups who had fled, who were withdrawing towards the Central Bosnia

22     territory.

23        Q.   Was the army presence around Srebrenica a concern for the

24     security of the president as he attended the religious ceremony at that

25     hill about five kilometres from Srebrenica, by which I mean were the

Page 15427

 1     military also concerned about the president's security?

 2        A.   I really don't know.  This was usual for us.  We did this

 3     throughout the war.  We were always in a certain state of stress.  There

 4     was always that note of tension that an incident can happen at any time,

 5     that we were in a state of war, and that we were not safe wherever we

 6     went.

 7        Q.   Is it your evidence to Their Honours that the security for the

 8     president, as he attended that ceremony, consisted only of his personal

 9     security detail?

10        A.   Yes, his personal security detail and just the regular security

11     that escorted us from the special unit of the MUP.  They went with us.

12        Q.   There was absolutely no military presence whatsoever as the

13     president went to the religious ceremony and at the religious ceremony;

14     is that your evidence?

15             THE ACCUSED: [Interpretation] I think that this has already been

16     answered.

17             JUDGE KWON:  Sometimes certain questions can be re-asked again,

18     in particular given the answers in a previous set of questions.

19             Yes, please go ahead.  This is okay.

20             MR. GAYNOR:  Thank you, Mr. President.

21        Q.   Could you answer that question, please, Mr. Ristic, or would you

22     like me to repeat it?

23        A.   There's no need to repeat it.  As far as I know and remember, I

24     didn't see any member of the military, I didn't see any soldiers or

25     officers.

Page 15428

 1             MR. GAYNOR:  I'd like to call up, please, 03199E.

 2             If we could zoom in on that building, please.  There's no

 3     translation.

 4        Q.   Do you recognise that building, Mr. Ristic?

 5        A.   I know this is an Islamic religious facility.  I don't know which

 6     one, though.  All of these buildings are similar, as far as I'm

 7     concerned, so I don't know exactly where this one is.

 8             MR. GAYNOR:  Well, I'll just inform Their Honours and the Defence

 9     that this is a combination of three stills from a video taken on the

10     14th of July, 1995, in Srebrenica town.  We'll return to this later in

11     the trial.

12        Q.   Did you see a building that looked like this in the centre of

13     Srebrenica on the 4th of August, 1995?

14             THE ACCUSED: [Interpretation] I think this was answered as well,

15     that he is squeezing his own witness about things that he didn't see and

16     which he had already answered.

17             JUDGE KWON:  He wasn't asked specifically whether he remembers

18     having seen a building which is similar to this at the time when he

19     visited Srebrenica.

20             Mr. Ristic, can you answer the question?  The question was

21     whether you saw a building that looked like this in the centre of

22     Srebrenica on the 4th of August, 1995.

23             THE WITNESS: [Interpretation] I don't recall seeing it.

24             MR. GAYNOR:  I can tender this as an exhibit now, Your Honours,

25     on the basis of what the witness has said.

Page 15429

 1             THE ACCUSED: [Interpretation] On what grounds, I kindly ask?

 2             MR. GAYNOR:  On the ground that the witness was in the centre of

 3     Srebrenica town and he did not observe this minaret on the 4th of August,

 4     1995.

 5             JUDGE KWON:  We have no information at this moment that this is

 6     at the centre of Srebrenica.

 7             MR. GAYNOR:  Very well, Mr. President.

 8             JUDGE KWON:  Shall I mark it for identification?

 9             MR. GAYNOR:  Please, Mr. President.

10             JUDGE KWON:  When you have some -- can present some foundation

11     for this.

12             MR. GAYNOR:  Yes, we'll be returning to it later.

13             JUDGE KWON:  Yes, we'll do that.

14             THE REGISTRAR:  As MFI P2846, Your Honours.

15             JUDGE KWON:  You wanted to say something, Mr. Karadzic?

16             THE ACCUSED: [Interpretation] The witness said -- the witness

17     said that he did not recall seeing it, not that, I did not see it.  I do

18     not recall seeing it.

19             JUDGE KWON:  Yes, that has been noted, and that's why we're

20     marking this for identification.

21             MR. GAYNOR:

22        Q.   Now, in one of your answers to Mr. Karadzic's questions,

23     Mr. Ristic, you said that you returned to Pale on the afternoon of the

24     4th of August, 1995.  Do you recall that?

25        A.   I said that we returned the same day, in the afternoon, yes, in

Page 15430

 1     the evening hours.  In any case, we did return quickly, considering the

 2     type of the trip.  We did return the same day.  I don't remember exactly

 3     at what time.

 4        Q.   Was it -- keeping in mind that it was the 4th of August, was it

 5     daylight when you returned to Pale?

 6        A.   Yes, yes, I think it was still day, daylight.  I think it was,

 7     and that's why I said that we went and returned while it was still day.

 8        Q.   Did you follow the same route home; that is to say, from

 9     Srebrenica to Bratunac to Milici, along the road that you marked earlier

10     for Their Honours?

11        A.   Yes.

12        Q.   Now, in your answers with Mr. -- your answers to Mr. Karadzic,

13     you said that you did not stop at any point along the route.  Did you

14     stop even for a rest break, a meal break, a drink of any kind, even a

15     brief stop?

16        A.   I really don't remember any details of that trip.  There were

17     many trips.  I don't know.  I cannot even remember if we stopped anywhere

18     to freshen up.  I really don't remember.

19        Q.   Is it therefore possible, yes or no, that you may have stopped in

20     the town of Bratunac?

21        A.   It's possible, but it was probably just a short stop for us to

22     take a little break, Bratunac-Milici.  It's possible.

23             MR. GAYNOR:  I'd like to call up now 03199F.

24        Q.   While that's coming, could you describe the location of the Serb

25     Orthodox Church in the centre of -- in Srebrenica town where you saw

Page 15431

 1     evidence that animals had been kept?  Was that in the centre of town or

 2     where was it?

 3        A.   It was the first time that I was in Srebrenica, and I just passed

 4     through, so I really wasn't aware where the centre of the town was.  I

 5     assumed that because there were some buildings around, that it was the

 6     kind of extended centre where the church was located.

 7             MR. GAYNOR:  Your Honours, there will be evidence led later in

 8     the trial that this is the same location as the photograph you saw

 9     earlier.

10        Q.   My question to Mr. Ristic is simply this:  Do you see that

11     location, Mr. Ristic?  Can you recognise that at all?

12        A.   No, I don't recognise it.

13        Q.   And simply to clarify your evidence on this point, would you --

14     do you recall at all whether you saw a minaret during your visit to the

15     Serb Orthodox Church and your walk within the town of Srebrenica, or did

16     you not see a minaret during your period in Srebrenica town?

17        A.   We didn't walk through Srebrenica.  We went by cars, and I didn't

18     see any.  I don't remember seeing anything similar to what we're seeing

19     in this photograph, no.

20        Q.   Did you at any stage learn of the killing of Muslim men and boys

21     in large numbers in the Srebrenica area?

22        A.   No, I didn't know that at the time.  I didn't have any

23     information about it.  I knew that military or combat operations were

24     underway, but I didn't have the information.  No, I didn't know.

25        Q.   When did you first hear of that?

Page 15432

 1        A.   I don't know exactly.  I can't really say.  I think through the

 2     media.  It was after -- some time after the date that it happened.  A lot

 3     of time went by since, and then I received information about it with a

 4     dose of reserve.

 5        Q.   And can you put a date as to when you first became aware of the

 6     killings of Muslim men and boys in Srebrenica?

 7        A.   No, no, I can't.

 8        Q.   I want to return to the question of radios.  Did you -- as a

 9     member of the president's personal detail, did you have a personal radio

10     for your work?

11        A.   Yes.

12        Q.   Did other members of the president's security detail each have

13     their own radio?

14        A.   Yes, he had his own radio and his own code.

15        Q.   In your evidence, in response to questions put to you by

16     Mr. Karadzic, you referred to the radio at the Villa Sipad, and you said

17     that that radio -- you agreed with the suggestion that that radio had a

18     radius of about five kilometres.  Do you recall that?

19        A.   I do.

20        Q.   What was the radius of the personal radio which you carried on

21     your person?

22        A.   Well, yeah, it was about the same as that one, but the more

23     powerful radio station had a range of perhaps up to seven kilometres.  It

24     was a stationary one in the base with the president.

25        Q.   Was that a mobile radio?  Could you carry it in your hand?

Page 15433

 1        A.   The one that was at the base was a stationary one.  It was

 2     installed there and it was located there.  The other ones were mobile

 3     radio stations, Motorolas.

 4             MR. GAYNOR:  I want to look now at the radios which were carried

 5     in the presidential convoy.  And if we could bring up, please, an

 6     exhibit.  I'll just get the number now.  P2784 --

 7             JUDGE KWON:  Are you tendering this photo?

 8             MR. GAYNOR:  Sorry, yes.

 9             JUDGE KWON:  That being the case, we'll mark it for

10     identification.

11             MR. GAYNOR:  Very well.  Thank you, Mr. President.

12             THE REGISTRAR:  MFI P2847, Your Honours.

13             MR. GAYNOR:  I'm not sure what the timing is, Your Honours.

14     Please feel free to stop me whenever you want.

15             JUDGE KWON:  Ten minutes.

16             MR. GAYNOR:  Thank you, Mr. President.

17             Could we call up P278 --

18             THE ACCUSED: [Interpretation] It's not clear to me on what basis

19     this photograph is being admitted through this witness.  He didn't

20     recognise it, he didn't see it at the time.  Simply, I don't see the

21     sense of admitting it through this witness.

22             JUDGE KWON:  It's just marked for identification, and if later on

23     it turns out that this is to be the centre of Srebrenica, we have the

24     evidence that the witness couldn't recall this site.  That's just simply

25     like that.

Page 15434

 1             Yes, let's proceed.

 2             MR. GAYNOR:  Thank you, Mr. President.

 3             If we could look at P2784, please.

 4        Q.   This concerns questions which were put to you in

 5     cross-examination concerning the president's access to communications

 6     during convoys.

 7             Now, if we look at the next page in English, please, and the

 8     final paragraph in your version, Mr. Ristic.

 9             I'll read out the relevant portion.  Well, really, it relates to

10     the call-signs Beta 1, Beta 11 and Beta 31.  Do you see that?

11        A.   Yes, but the last one is Beta 31, not 13.

12        Q.   Thank you.  Now, are those call-signs, Beta 1, Beta 11 and

13     Beta 31, are they references to radios carried by you and other members

14     of the president's security detail?

15        A.   Yes, and these are call-signs for security detail members.

16        Q.   Are these your personal radios of your -- of your group of

17     colleagues?

18        A.   Yes.

19        Q.   How would you make contact with the RS MUP personnel along the

20     convoy route to inform them of the approach of the convoy?

21        A.   Well, the dispatch was sent.  They were taking these other

22     measures.  They were waiting for us and then escorting us.  I don't know

23     as for radio links.  We didn't have any.  We were not in range until we

24     got within -- very close.  I mean, it had a range of five kilometres, so

25     when we got very close, then we could communicate with them.  Otherwise,

Page 15435

 1     the links were used to -- for us to communicate amongst ourselves, among

 2     the parties in the convoy.

 3        Q.   You said one of your duties, I think earlier, was to receive

 4     messages coming in for the president.  I think you said that in your

 5     response to answers to Mr. Karadzic.  Do you recall that?

 6        A.   I really -- I don't remember.  Could you please repeat it for me?

 7             MR. GAYNOR:  Yes.  If you would give me one moment, please.

 8             There was a reference.  I'm not able to find it right now.  I can

 9     return to this after the break, Your Honours.

10             I can move now to another subject or we can take the break now,

11     as Your Honours wish.

12             JUDGE KWON:  How much longer would you expect?

13             MR. GAYNOR:  It would take no more than about 15 minutes.  There

14     are some issues which arose in the cross-examination.  I would like to

15     consult with a couple of my colleagues about those prior to --

16             JUDGE KWON:  Very well.  If it is convenient, then we'll take a

17     break now.

18             MR. GAYNOR:  Thank you, Mr. President.

19             JUDGE KWON:  We'll have a break for an hour, and we'll resume at

20     1.30.

21             MR. GAYNOR:  Thank you, Mr. President.

22                           --- Luncheon recess taken at 12.26 p.m.

23                           --- On resuming at 1.33 p.m.

24             JUDGE KWON:  Yes, Mr. Gaynor.

25             MR. GAYNOR:  Thank you, Mr. President.

Page 15436

 1        Q.   Mr. Ristic, in his questions to you, Mr. Karadzic put to you the

 2     fact that you accompanied him on visits to Belgrade.  Do you remember

 3     that?

 4        A.   Yes.

 5        Q.   How would you travel when you accompanied the president on his

 6     visits to Belgrade?

 7        A.   By car, most of the time.

 8        Q.   And when you did not travel by car, how would you travel?

 9        A.   Well, a few times by helicopter.

10        Q.   I want to move to the question of radios.  This was something I

11     briefly addressed before the break.

12             At page 46, Mr. Karadzic raised with you the questions of radios

13     within the presidential convoy, and he said, in his question:

14             "Do you agree that I didn't have anything that would be more

15     sophisticated?  They knew that I didn't have a telephone or radio in my

16     car, and I wasn't able to communicate with anyone outside the range of

17     five to ten kilometres?"

18             Your answer was:

19             "Yes, I agree, and if we leaned anything over the radio set we

20     had, we would be the ones communicating it to you."

21             Do you remember that question and answer?

22        A.   Yes.

23        Q.   What kind of information would you be communicating to the

24     president in those circumstances?

25             THE ACCUSED: [Interpretation] Objection.  The witness said "had

Page 15437

 1     that been the case, we would have."  He did not put it this way.  [In

 2     English] "If/would." "If/would."

 3             MR. GAYNOR:  That's not how it came out in the English

 4     interpretation, Mr. President.

 5             JUDGE KWON:  I think that question includes the question whether

 6     he had ever conveyed a message to you, so I think the witness can answer

 7     the question.

 8             Yes, Mr. Ristic.

 9             THE WITNESS: [Interpretation] I did not have an opportunity to

10     convey any kind of information, and I do not recall that anyone else did.

11     But, basically, we would have done that because we were the only ones who

12     had the communications equipment.

13             MR. GAYNOR:  I'll move on to the trip of the 4th of August, 1995,

14     that we discussed earlier.

15        Q.   Now, during his cross-examination, Mr. Karadzic put to you a

16     couple of questions and answers, and I'm going to read those out to

17     refresh your memory.

18             He said:

19             "Since there were no meetings taking place indoors, rather,

20     everything was taking place outdoors, did anyone at this particular

21     meeting mention any sort of killings or unlawful actions in Srebrenica?

22     Were there any comments, innuendos, made to that effect?"

23             Your answer was:

24             "I don't recall any such thing happening, any comments."

25             The next question was:

Page 15438

 1             "Can we say that you were present during that visit, and that as

 2     you returned from it, you didn't have any knowledge of either destruction

 3     or killings in Srebrenica?

 4             "A.  Well, you can put it that way.  We returned without knowing

 5     anything about any killings or destruction taking place in Srebrenica."

 6             Do you remember that exchange?

 7        A.   Yes.

 8        Q.   Now, on the route the convoy took, which you've marked earlier,

 9     the convoy, both to and from Srebrenica, passed through a settlement

10     called Kravica.  Do you wish to see the map to confirm that?

11        A.   There's no need for a map.  I know, roughly, where that is.

12        Q.   Do you know of a warehouse at Kravica?

13        A.   No.

14             MR. GAYNOR:  I'd like to call up, please, 03199G.  This

15     photograph dates from 1996, I believe.  It will be tendered later in the

16     trial.

17        Q.   The picture you're seeing, do you recognise that building at the

18     bottom at all, Mr. Ristic?

19        A.   Yes, yes.

20        Q.   What is that building?

21        A.   I don't know.

22        Q.   Well, can you see the distance between that building and the

23     road?

24             MR. GAYNOR:  If Mr.  Registrar could push the picture so that the

25     road is visible.  Thank you.

Page 15439

 1        Q.   Do you see the distance between the building and the road,

 2     Mr. Ristic?

 3        A.   I do.

 4        Q.   Now, the Trial Chamber has been made aware - this is adjudicated

 5     fact 1075 - that on the evening of the July 13th, 1995, approximately

 6     1.000 Bosnian Muslim men were executed at this location.  And Beara and

 7     Deronjic and others began organising the burials of those executed.

 8     That's Fact 1709.

 9             Have you ever heard of those events?

10        A.   No.

11        Q.   Was there any discussion -- sorry, one other thing.  The

12     Trial Chamber has also been made aware of the fact that the men executed

13     were taken there from the meadow at Sandici, which is also on the convoy

14     route.  Was there any discussion as you passed Kravica or as you passed

15     Sandici to those events?

16        A.   I don't remember, I don't know at all.  Kravica, I know it as a

17     location from earlier on, because a crime had been committed against Serb

18     civilians in Kravica in 1992 or 1993; I can't remember exactly.  That is

19     how I know that place, Kravica, and that we passed through it.  That's

20     why I remember it.  I don't remember it by anything else.

21             THE INTERPRETER:  I kindly ask the Prosecutor to clarify the word

22     missing at page 23, line 13.  Thank you.

23             MR. GAYNOR:  I'll make that clarification.  One moment, please.

24             JUDGE KWON:  Page 23?

25             THE INTERPRETER:  Is it page 68, perhaps; interpreter's

Page 15440

 1     correction.  The sentence:  "Was there any," and then there's a missing

 2     word, "between there and ..."

 3             JUDGE KWON:  Line 24.

 4             MR. GAYNOR:  Yes.

 5        Q.   My question was this:  I was referring to the fact that the

 6     Trial Chamber has been made aware of the fact that 1.000 to 1.500 Bosnian

 7     Muslim men were captured and detained at Sandici Meadow and then brought

 8     to Kravica warehouse, and where they were executed, and their burial was

 9     organised by Beara and Deronjic and others.  My question was:  Was there

10     any discussion within your convoy relating to those events during the

11     trip or after you returned to Pale?

12        A.   No.  Had there been any, I would have remembered it.

13             THE INTERPRETER:  The interpreter did not understand the end of

14     the sentence.

15             MR. GAYNOR:

16        Q.   Would you repeat your answer, please, sir?

17        A.   No, there was no discussion in relation to these killings,

18     because had that happened, that is a big thing, I would have remembered

19     it.

20        Q.   You worked for Mr. Karadzic or President Karadzic until what

21     year?

22        A.   2000, the year 2000.

23        Q.   Did you ever hear him express any remorse about events which took

24     place in Srebrenica in July 1995?

25        A.   I don't know what to say to you by way of an answer to that

Page 15441

 1     question.

 2        Q.   Could you answer the question?  Did you ever hear him express

 3     remorse for the events which took place at Srebrenica in July 1995?

 4        A.   No.

 5             MR. GAYNOR:  I have no further questions in redirect.

 6             The picture of Kravica warehouse which is on the screen, could I

 7     request that that be MFI'd, Mr. President?

 8             JUDGE KWON:  I don't see the need to MFI it at this time.

 9             MR. GAYNOR:  Very well.  Very well, Mr. President.  No further

10     questions.  Thank you.

11             THE ACCUSED: [Interpretation] Please, two brief clarifications.

12             JUDGE KWON:  Which is what?  Tell us first, before putting the

13     question.

14             THE ACCUSED: [Interpretation] First, Mr. Gaynor implied that the

15     witness had said that I had known about these events and that I did not

16     state my views on them.  And the second question is as if the witness had

17     observed Sandici and been aware that we had passed through some Sandici.

18     And then the third has to do with the helicopter that we travelled on.

19     Those are three brief questions.

20             JUDGE KWON:  Very well, proceed.

21                           Further Cross-examination by Mr. Karadzic:

22        Q.   [Interpretation] Mr. Ristic, Mr. Gaynor asked you, and you

23     confirmed, that sometimes there was travel to Belgrade by helicopter.  Am

24     I right if I say that these were large MI-8 medical helicopters for the

25     evacuation of wounded persons and that we landed by the VMA, the Military

Page 15442

 1     Medical Academy in Belgrade?

 2        A.   Yes, these were helicopters that transported seriously-wounded

 3     persons to the Military Academy, the Military Medical Academy in

 4     Belgrade.  MI-60 -- no, MI-8, actually.

 5        Q.   And we used that, we availed ourselves of that opportunity to

 6     travel; it wasn't that the helicopters came for us?

 7        A.   Yes, yes, we availed ourselves of that opportunity, and also for

 8     security reasons, because sometimes roads were cut off, there were

 9     offensives around Zvornik, as far as I can remember, and that is why we

10     were -- that is why you used this.

11        Q.   Thank you.  Mr. Gaynor asked you whether you saw some men in

12     Sandici.  Were you actually aware of us passing through some Sandici?

13        A.   No, I wasn't aware of that, nor do I know to this day where this

14     Sandici is.

15        Q.   Third question:  He asked you whether I expressed any remorse

16     with regard to what had happened in Srebrenica.  Did you ever come to

17     realise that I had actually learned what had really happened in

18     Srebrenica?

19        A.   My impression was that you did not at all have any

20     responsibility, that you knew something that you should express your

21     remorse over, I mean, really.

22        Q.   In the environment where I was, was there any conversation to

23     that effect, except for what you mentioned, the media, what had happened

24     in Srebrenica?

25        A.   No, no.  I find all of this foreign, everything regarding

Page 15443

 1     Srebrenica, only from the media.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             JUDGE KWON:  Just a couple of questions for you, Mr. Ristic.

 4                           Questioned by the Court:

 5             JUDGE KWON:  Can we know the -- your date of birth, if you don't

 6     mind, or at least your year of birth?

 7        A.   On the 9th of January, 1972.

 8             JUDGE KWON:  Thank you.  Are you still in the police now?

 9        A.   No.

10             JUDGE KWON:  Can I ask what you are doing now?

11        A.   Now?  Now I'm in trade.

12             JUDGE KWON:  Earlier on, you said you worked for Mr. Karadzic

13     until the year of 2000.  Is that correct?

14        A.   Well, 2000, sort of.  I don't remember exactly until when.

15             JUDGE KWON:  Do you remember when he stepped down from the

16     Presidency?

17        A.   No, I don't remember.  I can assume when it was.  I don't know

18     exactly.

19             JUDGE KWON:  But you served as his security guard, or personal

20     security, after he stepped down from the Presidency?

21        A.   I was an employee of the Ministry of the Interior all the way up

22     until then.  That was my duty.

23             JUDGE KWON:  Thank you.

24             I think that concludes your evidence.  I'm sorry.

25                           [Trial Chamber confers]

Page 15444

 1             MR. GAYNOR:  No further questions.

 2             I just wanted to say that the translation has been up-loaded off

 3     the photographs marked by Mr. Ristic for P2481.

 4             But I have no further questions for Mr. Ristic.  Thank you,

 5     Mr. President.

 6             JUDGE KWON:  And that will be checked and will be sorted out

 7     later on.

 8             Thank you, Mr. Ristic.  That concludes your evidence.  On behalf

 9     of the Trial Chamber and the Tribunal, as a whole, I'd like to thank you

10     for your coming all the way to The Hague to give it.  Now you are free to

11     go.

12             THE WITNESS: [Interpretation] Thank you.

13             THE ACCUSED: [Interpretation] Thank you, on behalf of the Defence

14     as well.

15             THE WITNESS: [Interpretation] Thank you.

16                           [The witness withdrew]

17             JUDGE KWON:  Before we call the next witness, can I make this

18     observation, Mr. Tieger.

19             I note that while the Prosecution had originally estimated that

20     it would require one and a half hours to examine this witness and present

21     his evidence pursuant to Rule 92 ter, actually, Mr. Ristic ultimately

22     testified entirely viva voce, and Mr. Gaynor only used one hour and

23     fourteen minutes to examine him in his examination-in-chief.  So in light

24     of this experience, and given that the use of Rule 92 ter does not always

25     seem to result in a reduction of the in-court time used by the

Page 15445

 1     Prosecution, I would, therefore, recommend you to consider, where

 2     possible and, in particular, when it would not increase the time for your

 3     examination-in-chief, leading witnesses viva voce, as opposed to

 4     presenting them pursuant to Rule 92 ter, as in the case of Mr. Ristic.

 5             MR. TIEGER:  Well, of course, we'll take the Court's comments on

 6     board.

 7             May I simply note that the comparison in this case may be a bit

 8     misleading for a number of reasons.  I've also found myself in that

 9     situation, and it can be the result of a variety of factors, including,

10     under the circumstances, jettisoning material that would otherwise be

11     considered useful, the fact that a re-calculation of the amount of time

12     that would have been devoted to a 92 ter, plus some viva voce, wasn't

13     made in light of the decision to go totally viva voce, and the particular

14     witness involved.  But, nevertheless, I understand the Court's point, and

15     we will certainly pass it on to every member of the team and consider it

16     accordingly.

17             JUDGE KWON:  Thank you.

18             MR. GAYNOR:  Thank you.  I'll excuse myself, Mr. President.

19             JUDGE KWON:  Thank you.

20             MR. GAYNOR:  Thank you.

21             JUDGE KWON:  Do you need a break?

22             MR. TIEGER:  It will certainly take Ms. Uertz-Retzlaff a few

23     moments to log on.  I don't see any reason why we couldn't break for a

24     few minutes so she could do that comfortably, but I leave that to the

25     Court.

Page 15446

 1             JUDGE KWON:  We'll break for five minutes, then.

 2                           --- Break taken at 1.56 p.m.

 3                           --- On resuming at 2.03 p.m.

 4                           [The witness entered court]

 5             JUDGE KWON:  Good afternoon, sir.

 6             If you could kindly take the solemn declaration, please.

 7             THE WITNESS: [Interpretation] Good afternoon.

 8             I solemnly declare that I will speak the truth, the whole truth,

 9     and nothing but the truth.

10                           WITNESS:  MILORAD DAVIDOVIC

11                           [Witness answered through interpreter]

12             JUDGE KWON:  Thank you, Mr. Davidovic.  Please be seated, and

13     make yourself comfortable.

14             Good afternoon, Ms. Uertz-Retzlaff.

15             MS. UERTZ-RETZLAFF:  Good afternoon, Your Honours.

16             JUDGE KWON:  Please.

17                           Examination by Ms. Uertz-Retzlaff:

18        Q.   Good afternoon, sir.  Please state your full name.

19        A.   My name is Milorad Davidovic.  I was born on the

20     13th of February, 1951.

21        Q.   Thank you.  Mr. Davidovic, you provided a statement to the

22     Office of the Prosecutor in 2005, and you also testified here at the

23     Tribunal in the case against Momcilo Krajisnik in 2005 and in the case

24     against Mico Stanisic and Stojan Zupljanin in 2010; is that correct?

25        A.   Yes.

Page 15447

 1        Q.   In the last few days, did you have an opportunity to review an

 2     amalgamated statement consolidating relevant parts from your previous

 3     statement and testimonies?

 4        A.   Yes.

 5             MS. UERTZ-RETZLAFF:  I would ask that Exhibit 65 ter 90250 be

 6     brought up on the screen, and we need the first page in both languages,

 7     please.

 8        Q.   And, Mr. Davidovic, as it is coming up, it is a statement dated

 9     22nd June 2011.  Is this the amalgamated statement that you reviewed and

10     later on signed?

11        A.   Yes.

12        Q.   In relation to paragraph 40 in the amalgamated statement, where

13     you describe a visit to Pale and the transport of weapons and equipment,

14     do you wish to clarify a point related to the transport of equipment and

15     weapons?

16        A.   I don't know if anything needs clarifying on this issue.

17        Q.   On this first occasion that you went to Pale, did you bring

18     weapons with you and equipment?

19        A.   The first time I went there, I brought along some equipment,

20     several uniforms, and short-barrelled weapons.  The second time I went

21     there, we went by helicopter, and we brought along a larger amount of

22     equipment and weapons.

23             MS. UERTZ-RETZLAFF:  Thank you.

24             Your Honour, the witness has the amalgamated statement in front

25     of him.  I don't know whether you mind that.  Otherwise, we would have to

Page 15448

 1     always pull up that particular paragraph here in electronic form.  It

 2     would be much quicker to simply refer him to the statement.

 3             JUDGE KWON:  Yes.

 4             MS. UERTZ-RETZLAFF:  Thank you.

 5        Q.   And in relation to paragraph 77 in the amalgamated statement, you

 6     refer to the elite units in the RS MUP, and you also mention

 7     Dusko Malovic and their degree of skills and training.  Do you wish to

 8     clarify to which elite units you are referring and what their skills were

 9     at that time?

10        A.   I said that those units were called special units and that they

11     did undergo some training, which meant that they were professionally

12     trained to accomplish their mission, whatever the circumstances.  I did

13     not gain the impression that it was an elite unit which was fully

14     equipped and one which could carry out everything that they were told to

15     do.  They were volunteers, and from what I know, Dusko Malovic was an

16     active-duty serviceman who gathered these men at Sokolac, trained them,

17     and that's how they created conditions for work.

18        Q.   Thank you.

19             MS. UERTZ-RETZLAFF:  Your Honour, with the exception of these

20     two clarifications and additions, just one additional point.

21        Q.   Can you affirm that the amalgamated statement of 22nd June 2011

22     accurately reflects the evidence you provided to the Office of the

23     Prosecutor and the Tribunal?

24        A.   Yes.

25        Q.   Mr. Davidovic, would you provide that same evidence to the Court

Page 15449

 1     if questioned on the same matters here today?

 2        A.   Yes.  It wouldn't be the same, in terms of every word, but I'm

 3     sure that I would repeat 99 per cent of what I said earlier on without

 4     any problems.

 5             MS. UERTZ-RETZLAFF:  Your Honour, I would like to tender this

 6     statement for admission under Rule 92 ter.

 7             MR. ROBINSON:  Excuse me, Mr. President.

 8             I would like to be heard about this, but I think it would be more

 9     prudent to be heard outside the presence of the witness.  Would you mind

10     to excuse the witness so that I could be heard more fully?

11             JUDGE KWON:  Yes.

12             I apologise for your inconvenience, Mr. Davidovic.  There are

13     certain matters to discuss in your absence.  If you could please excuse

14     yourself for a moment.

15                           [The witness stands down]

16             MR. ROBINSON:  Mr. President, I was wondering whether or not you

17     would consider, in part, in light of what your comment was at the end of

18     the last witness, to whether this witness could be heard viva voce,

19     rather than by admission of his amalgamated statement under 92 ter.

20             In addition to the time element, which the Prosecution has

21     reserved three hours for the direct examination of this witness, so it's

22     possible that there may not be much of a time savings, there are some

23     other aspects of this witness's testimony that would make, in our

24     submission, it more appropriate for viva voce testimony.

25             First, it's going to be very contentious, and you could see from

Page 15450

 1     the allegations that the witness makes against Dr. Karadzic, himself,

 2     that there are many things in his statement that we don't accept and, in

 3     fact, find offensive.

 4             And, secondly, the amalgamated statement contains matters that we

 5     think are irrelevant and prejudicial, concerning allegations of

 6     corruption, gambling, extortion of -- or proceeds of extortion going to

 7     Dr. Karadzic, so we think there are things in the amalgamated statement

 8     that ought not to be admitted into evidence under any circumstances.

 9             For all of those reasons, we would ask that the Chamber consider

10     hearing this witness viva voce, rather than under 92 ter.  Thank you.

11             JUDGE KWON:  Before I hear from the Prosecution, I note that

12     submission is too much belated.  I could not but say that.

13             Yes, Ms. Uertz-Retzlaff.

14             MS. UERTZ-RETZLAFF:  Yes.  And, Your Honours, I have spent

15     two days now going, with the witness, through the amalgamated statement,

16     and I can actually say using the amalgamated statement would be an

17     enormous time saving because the witness has so many additional --

18     additional little details that he would want to tell the Court, which we

19     wouldn't really need, but he's a person who is very meticulous and wants

20     to tell the details.  Definitely, if we would have to have his evidence

21     live, it would take definitely two days, or even more than that.  So the

22     time saving in this situation is definitely a point, an important point.

23             The testimonies that he gave in the past took days and days, and

24     I think it's not a good -- it's not a good example to do this.

25             The witness, of course, gives a lot of information in relation to

Page 15451

 1     the character of Mr. Karadzic and his war profiteering, as I may call it

 2     that, and I think it is relevant to this case.  And, definitely, I assume

 3     that he will spend a lot of time in cross-examination dealing with these

 4     claims that the witness makes in his amalgamated statement, and he has

 5     the right to do so, and I expect him to do so.

 6             And just one additional point.  I, myself, will not address these

 7     kind of matters any further in my examination-in-chief.

 8                           [Trial Chamber confers]

 9             JUDGE KWON:  Mr. Robinson, the Chamber does not see the need to

10     convert the nature of this witness into a viva voce witness.  The fact

11     that the content of the witness's evidence may be contentious does not

12     necessarily warrant that witness to be heard live, and in addition to the

13     fact you raised the issue too belatedly.  We don't see any prejudice by

14     admitting his statement pursuant to Rule 92 ter, in particular given his

15     answer to the question by Ms. Uertz-Retzlaff.

16             So we deny your motion.

17             Let's bring in the witness.

18             MR. ROBINSON:  Mr. President, if I could just also indicate that

19     if you look at the associated exhibits - this is on a different

20     topic - we have an objection to some of them, and I just thought I should

21     let the Prosecution know.  There's about 14 statements of third parties

22     that are contained in the associated exhibits, and we don't think that

23     it's appropriate to admit those.

24             JUDGE KWON:  Yes.  We'll deal with them when we come to that

25     issue.

Page 15452

 1                           [The witness takes the stand]

 2             JUDGE KWON:  My apologies again for you, Mr. Davidovic.  We'll

 3     continue.

 4             MS. UERTZ-RETZLAFF:  Your Honour, I would like to tender this

 5     92 ter statement now into evidence.

 6             JUDGE KWON:  That will be admitted as the next Prosecution

 7     evidence.  We'll give the number.

 8             THE REGISTRAR:  Your Honours, the statement of the

 9     Witness Davidovic under 65 ter 90250 shall be assigned Exhibit P2848.

10     Thank you.

11             MS. UERTZ-RETZLAFF:  Your Honour, with your leave, I would like

12     to read a brief summary of the witness's evidence.

13             Mr. Milorad Davidovic, a police officer by profession, served in

14     various positions within the Republican Police in Bosnia and Herzegovina

15     before the war, including the Police Station in Bijeljina.  In the second

16     half of 1991, he moved to the Federal Secretariat of Internal Affairs in

17     Belgrade (the Federal SUP).  And in his capacity as a member of the

18     Federal SUP, he executed several assignments in Bosnia and Herzegovina

19     during the period relevant to the indictment.

20             Mr. Davidovic observed the transformation of the Bosnia and

21     Herzegovina police structure and the emergence of the Bosnian Serb

22     Ministry of Interior (the RS MUP), and its police formations and their

23     co-ordination and co-operation with the Bosnian Serb civilian and

24     military authorities, as well as police and paramilitary forces from

25     Serbia.

Page 15453

 1             The witness was involved in and familiar with the co-ordination

 2     and co-operation between the Bosnian Serb leadership, including the

 3     accused, and the Belgrade authorities, including officials from the

 4     Federal SUP and officials from Serbia.

 5             Mr. Davidovic, while on duty in the Federal Commission visiting

 6     Bosnia and Herzegovina, noticed the arming of the local population in

 7     Bosnia in late 1991 and early 1992, and the build up of the reserve

 8     police forces.  He, himself, was involved in the transfer of weapons and

 9     equipment from the Federal SUP to the RS MUP with the assistance of the

10     Yugoslav People's Army, the JNA.

11             Mr. Davidovic was instructed by the Federal SUP to transfer with

12     a group of police officers to Bosnia and Herzegovina in spring of 1992 to

13     establish -- to assist in the establishment of the RS MUP; in particular,

14     the establishment and training of a special-purposes unit.

15             During this time, the witness observed the presence of

16     paramilitary forces in Sarajevo in 1992 and the criminal activities of

17     such troops as well as those of Bosnian Serb forces.  At a meeting with

18     Ratko Mladic and the accused at Lukavica Barracks, he complained about

19     the looting by Serb troops.

20             The witness, in his official capacity as well as a citizen of

21     Bijeljina, directly observed a policy of forcible removal of non-Serbs

22     and crimes committed against them in several areas in Bosnia-Herzegovina,

23     including Bijeljina, Brcko and Zvornik.  He, in particular, realised that

24     the Serbian Democratic Party designed and executed a policy of the

25     systematic removal of non-Serbs from Bijeljina from May 1992 until and

Page 15454

 1     including 1995.

 2             Non-Serb residents were dismissed from their jobs, subjected to

 3     various forms of persecution, including arbitrary arrests, detention and

 4     murder.  Organised looting was conducted by local Serbs, including

 5     policemen, as well as paramilitary and volunteer forces from Serbia that

 6     were allowed to commit crimes against non-Serbs with impunity.

 7             The witness became aware that the accused and other Bosnian Serb

 8     leaders regularly visited Bijeljina on their way to and from Belgrade and

 9     were closely associated with Serb officials in Bijeljina and financially

10     benefitted from the money and valuables obtained from the non-Serbs.

11             Mr. Davidovic, in conversations with Mico Stanisic, the accused,

12     as well as others, realised that the accused and other members of the

13     Bosnian Serb leadership knew about the presence of paramilitaries in

14     Bijeljina and Zvornik.  He took part in a meeting in Belgrade in which

15     the accused and Arkan participated and activities were planned.  He also

16     observed the presence of Arkan's men in the Lukavica Barracks when the

17     witness had the meeting with Mladic and the accused.

18             Mr. Davidovic and a group of policemen from the Federal SUP came

19     to Bijeljina in the summer of 1992 and took part in a joint action by the

20     military and the police in Bijeljina, Brcko and Zvornik to arrest members

21     of the paramilitary formations who at that time committed crimes against

22     the Serb population as well, including against officials from Pale.  The

23     witness's activities to establish law and order, and his insistence to

24     protect all citizens, including non-Serbs, led to a deterioration of his

25     relations with the local Crisis Staff in Bijeljina.  The Bijeljina

Page 15455

 1     Municipal Assembly undertook efforts to have the witness expelled from

 2     the municipality for arresting too many Serbs and for general anti-Serb

 3     behaviour.  Although many members of the paramilitary formations were

 4     arrested, the witness noticed that the persecution of non-Serbs continued

 5     in Bijeljina.

 6             During his efforts in Brcko, Mr. Davidovic visited the Luka Camp

 7     detention facility in Brcko.  At that time, the camp held about

 8     70 Muslims, including children.  The witness, while participating in the

 9     arrest of members of the Yellow Wasps in Zvornik because of looting,

10     robbery and theft, obtained information about various other crimes,

11     including murders, which they had committed there.

12             In the course of his duties in the Federal SUP, Mr. Davidovic

13     travelled to an Assembly session in Pale in 1993 in which the

14     Vance-Owen Peace Plan was rejected by the Bosnian Serbs despite the fact

15     that Slobodan Milosevic and the Greek prime minister attended this

16     session and were in favour of the plan, and expressed that.

17             Your Honour, that completes the summary, and I have now to ask

18     further questions.

19             JUDGE KWON:  Yes, please.

20             MS. UERTZ-RETZLAFF:

21        Q.   Mr. Davidovic, you described your career in the police from 1974

22     onwards, and you also mentioned that you became a chief inspector in the

23     Federal SUP.  Is this a high-ranking position?  And if so, can you tell

24     us where it is positioned within the hierarchy of the Federal SUP?

25        A.   Yes.  Can I just make one correction, please?

Page 15456

 1             You said that I was transferred to the Federal SUP.  Let me tell

 2     you that I wasn't transferred.  I went to the Federal SUP of my own will,

 3     upon my own request.  I wasn't transferred by an organ, republican or

 4     otherwise.

 5        Q.   Yes, thank you.  Thank you, Mr. Davidovic.  But can you answer my

 6     question, where your position as chief inspector is situated in regard of

 7     hierarchy?

 8        A.   When I moved to the Federal SUP, I was assigned to the post of

 9     the chief inspector of the police for the former Yugoslavia.  Later on, I

10     became deputy commander of the Federal Brigade to the post of the chief

11     inspector, so I was among the 10 top-most officials and my number was

12     number 5, which also denotes the ranking in the leadership structure.

13        Q.   And when you were in Bosnia and Herzegovina or when you were

14     communicating with others, on which level would you do this?  On which

15     level were your partners, your counterparts?

16        A.   It was the minister of the interior of Republika Srpska and his

17     deputy, Cedo Kljajic.  In other words, Mico Stanisic and Cedo Kljajic.

18        Q.   As far as you communicated with military, on what level would

19     that be?

20        A.   Solely through the corps commander and the Main Staff of the Army

21     of Republika Srpska.

22        Q.   In your statement, you describe the joint commission you were

23     part of in September 1991 and how you -- how you investigated and checked

24     the status of the reserve police.  In this context, did you also visit

25     the SRB -- the police station in Pale?  And if so, what was the situation

Page 15457

 1     there in relation to reserve police and arming?

 2        A.   We visited several centres of the Security Service at the time.

 3     Within individual centres, we went to see some of the local SUPs in

 4     several locations.  When we were checking the work of the Sarajevo

 5     centre, we were told to tour several stations.  One was Station Centar,

 6     then Station Pale, and Kiseljak, I believe.  We went about our work,

 7     looking through the records, et cetera, and we established that there was

 8     a sharp increase in the head count of the reserve force.  And depending

 9     on the ethnic make-up of a given location, that would be reflected in the

10     make-up of the reserve force.  And when we got to --

11             THE INTERPRETER:  The interpreter didn't catch the location.

12             THE WITNESS: [Interpretation] ... we realised that there was a

13     major increase in the reserve force.  We weren't given proper records,

14     but we realised -- well, we realised, actually, that there was a

15     fluctuation of personnel, though not a major increase.  And when we went

16     to the various intersections around Pale, we realised that the

17     check-points that were around the perimeter of Pale were manned mostly by

18     individuals of Serb ethnicity and by those who had joined the MUP only

19     recently through the reserve force.  However, there would always be one

20     or two active policemen among the reserve policemen who had been there

21     from before, and this is something that we noted down in our report that

22     we submitted to both the republic and federal SUPs.

23        Q.   The interpreters didn't catch the name of the location that you

24     went in Pale.  Do you recall which other location you mentioned?

25        A.   I was talking about other locations where I was to previously,

Page 15458

 1     and then I discussed our visit to Pale and the resulting report that we

 2     sent to the MUP of Bosnia-Herzegovina and the Federal SUP.

 3        Q.   You, yourself, referred in your statement to the fact that in

 4     1990, the Bosnia-Herzegovina reserve police had a strength of about

 5     60.000 to 70.000.  What was the increase in 1991/1992 when you checked on

 6     this data?

 7        A.   Well, it was treble the amount -- the number of personnel that

 8     there used to be, three or four times -- three- or four-fold was the

 9     increase in most of them.

10        Q.   You described your tasking and activities in Vraca in the spring

11     of 1992, and you have already provided a lot of details and referred to

12     several intercepted conversations.  However, I would like to address one

13     more intercepted conversation with you in this context.

14             MS. UERTZ-RETZLAFF:  And I would like to have

15     Exhibit 65 ter 30701 brought up on the screen.

16        Q.   And as it is coming up:  It is a transcript of an intercepted

17     conversation, dated 21st of April, 1992, between you and Mr. Goran Saric.

18             Mr. Davidovic, do you remember this conversation with --

19        A.   Yes.

20        Q.   And Mr. Saric is who?

21        A.   I know Mr. Saric from before the conversation that we had.

22     Mr. Saric completed the Secondary School for the Police Force and then

23     graduated from the Police Academy.

24        Q.   Mr. Davidovic, we wouldn't need all the details.  He was a

25     policeman, then?

Page 15459

 1        A.   Yes, he was an active policeman.  He was assistant to the

 2     commander of the Novi Grad Police Station.

 3             MS. UERTZ-RETZLAFF:  Can we please have page 4 in the English,

 4     the top part, and page 2 in the Serbian, the bottom part, please.  Yes.

 5        Q.   And Mr. Saric is telling you that Bijeljina and Zvornik, as well

 6     as Krajina, is solved, and that it is known who owns that.  What does he

 7     refer to here?

 8             THE ACCUSED: [Interpretation] This is calling for speculation.

 9     If this isn't something that is noted down in the conversation, how can

10     the witness know what was meant 20 years later?

11             JUDGE KWON:  No, your objection is overruled, Mr. Karadzic.  The

12     witness can answer as far as he can remember.

13             Yes, Mr. Davidovic.

14             THE WITNESS: [Interpretation] In the conversation I had with

15     Goran, I asked him to come and see us at the school in Vraca.  His

16     response was that he didn't know what to do because the situation was

17     quite serious in Sarajevo.  He said that in Zvornik, in Bijeljina, that

18     the situation was more or less resolved, and I think he meant that it was

19     safe, that the Serbs had taken over power, and that this was no longer

20     the problem.  The problem was the town of Sarajevo and how it was going

21     to be resolved, and that's what he means here.

22             MS. UERTZ-RETZLAFF:  And can we please have the bottom part of

23     page 4 in the English, and in the Serbian, page 3, the lower part.

24        Q.   Mr. Davidovic, you are referring here to Wednesday or Thursday,

25     the 6th or the 7th, as your date of arrival in Pale.  Taking into account

Page 15460

 1     this is April that you are talking, when would that -- what would that

 2     be -- what kind of date would that be?

 3        A.   Yes.  Precisely those days, yes, those dates.

 4             MS. UERTZ-RETZLAFF:  Your Honour, I request this exhibit to be

 5     admitted into evidence because the witness is one of the speakers.

 6             JUDGE KWON:  Yes, that will be done.  We will admit it as

 7     Exhibit P2849.

 8             MS. UERTZ-RETZLAFF:

 9        Q.   Mr. Davidovic, in your statement, you refer to the school, the

10     Vraca school in which you were situated, and you also mentioned the

11     communications that you had there, the means of communications.  Did they

12     function all the time while you were there?

13        A.   Yes.  They had full communication with Belgrade and with the

14     other organs.  I contacted Bijeljina, so I was in contact with them.  At

15     that point in time, everything was functioning.

16        Q.   And in this context, do you know whether the RS MUP had

17     communications with the CSBs and the SJBs?

18        A.   I think that on the whole, there was always communication, with

19     some small interruptions vis-a-vis certain organs, but very often the

20     communication would be re-established in some other way.  So there were

21     communications.  If there were -- if the telephone lines were down, then

22     there would be courier communication.  So it wasn't that no communication

23     whatsoever could not take place over a longer period of time.

24             MS. UERTZ-RETZLAFF:  I would ask that Exhibit 65 ter 08153 be

25     brought up on the screen, please.

Page 15461

 1             And as it is coming up:  It is a fax of the chief of the

 2     CSB Bijeljina to the RS MUP and, as it says here, to the minister, on the

 3     29th of April, 1992.

 4        Q.   Mr. Jesuric is referring here to his visit to the Zvornik SJB.

 5     According to police practice, would CSB chiefs make regular contacts with

 6     the SJBs in their field, in their area?

 7        A.   There were faxes, and beforehand there were teleprinters there,

 8     so they stayed there.  But most of the communication was by fax, and

 9     telephones, and the special communications that the Republican SUP has.

10     This is special communication only between two MUPs; that is to say that

11     there are no other lines that can interfere with that communication.

12        Q.   And how frequently would the CSB communicate with the SJBs in

13     their area?

14        A.   Well, they needed to have daily communication.  When the centre

15     covers certain local organs, it has daily communication with them.  They

16     ask for information, they communicate and so on.  This is customary

17     practice on a daily basis.  Sometimes even several times a day, the

18     centre would communicate with the local organ.

19        Q.   And would the police chiefs in the SJBs [sic], as Mr. Jesuric is

20     doing here, inform the minister about their contacts and occurrences?

21        A.   Yes.  Precisely, that is their function.  And this document that

22     you showed, in which Predrag Jesuric, the chief of the CSB from

23     Bijeljina, is informing the minister about the situation in Zvornik, I

24     would just like to refer to the date when this brief dispatch is being

25     sent.  And it says that the situation is normal and that there are no

Page 15462

 1     serious disruptions in public law and order.  And in that period of time,

 2     there were crimes being committed, there was looting, and the

 3     Yellow Wasps were fully functional.  So I think that this information is

 4     not correct.

 5             JUDGE KWON:  Ms. Uertz-Retzlaff, in your question, did you refer

 6     to police chiefs in the SJBs, as Mr. Jesuric?

 7             MS. UERTZ-RETZLAFF:  CSBs.

 8             JUDGE KWON:  It should read "CSBs"?

 9             MS. UERTZ-RETZLAFF:  CSBs, yes.

10             I would like to -- Your Honour, I request the admission of this

11     document into evidence.

12             JUDGE KWON:  Yes, this will be admitted.

13             THE REGISTRAR:  Your Honours, 65 ter document 8153 shall be

14     assigned Exhibit P2850.  Thank you.

15             MS. UERTZ-RETZLAFF:  Can I have another document now pulled up,

16     and that is 65 ter 08278.

17             And it is a very similar document, as we can see here.

18     Mr. Jesuric is now -- is also writing again to the ministry, minister and

19     deputy minister, and it's from the 24th of April.

20        Q.   Just one question in relation to this, Mr. Davidovic.  Can you

21     tell us how frequent such correspondence between the CSBs and the

22     minister would be?  What would be the regular practice?

23        A.   As a rule, the chief of the CSB has to have daily communication

24     with the minister.  When problems crop up in the meantime, then he may

25     communicate several times a day.  There are some periods of time when he

Page 15463

 1     would not communicate with the minister over two days if nothing special

 2     had happened.

 3             MS. UERTZ-RETZLAFF:  Thank you.

 4             Can this document also be admitted?

 5             JUDGE KWON:  Yes.

 6             THE REGISTRAR:  Your Honours, 65 ter document 8278 shall be

 7     assigned Exhibit P2851.  Thank you.

 8             MS. UERTZ-RETZLAFF:

 9        Q.   Mr. Davidovic, you have mentioned your assignments in Sarajevo,

10     and we do not need to go into this detail.  But you refer, in

11     paragraph 50 - but you don't need to look at it right now - that you

12     also, at some point in time, had to defend the front-line near the

13     Jewish cemetery.  Only one question to that.

14             Which other Serb formations were in that area?

15        A.   Members of the army were there and of the active police from

16     Sokolac, who had also come to that area, and among them there were

17     members of the station from Sarajevo who were also sent to that line,

18     that defence line at the Jewish cemetery.

19        Q.   Did you also -- were there also any paramilitary forces at the

20     Jewish cemetery, to your knowledge?

21        A.   In the beginning, no.  In the beginning, it was more or less

22     volunteers who had come and who were led by Slavko Aleksic.  They were

23     volunteers, primarily locals from the surrounding area or Sarajevo.  They

24     were volunteers, and they were under the command of the army and they

25     were not paramilitaries.

Page 15464

 1        Q.   Mr. Davidovic, you also describe, in relation to your front --

 2     your being on the front-lines you describe in paragraph 52, you describe

 3     looting and disorder that you observed, and you referred to people crying

 4     and being upset.  What people were targeted when you observed this

 5     happening?

 6        A.   At the Jewish cemetery, between the lines, and at the command

 7     where we were, there were residential buildings where people lived, and

 8     every day this is what would happen:  In apartments where Muslims lived,

 9     or where they were living then, ethnic Serbs would move in or barge into

10     those apartments and take things out of them, including technical

11     equipment and whatever was valuable in those apartments.  These were

12     active-duty and reserve personnel and locals who were trying to resolve

13     status-related issues in that way; to get into someone else's apartment,

14     to thereby have a place to live, and so on.

15        Q.   Thank you.  Mr. Davidovic, in paragraph 54 and 55 of your

16     statement, you refer to a talk that you had with Karadzic and Mladic in

17     the Lukavica Barracks, and about how you told them about the looting and

18     that that needed to be stopped.  You mentioned that while this talk took

19     place, some Arkan's men arrived, and that Karadzic and Mladic then spoke

20     about it.

21             Can you tell us what, actually, Mladic and Karadzic said in

22     relation to Arkan's men coming there?

23        A.   When I was at this meeting between myself and Ratko Mladic, it

24     was not expected, but Mr. Karadzic entered the room unannounced.  Before

25     he had entered, I had started talking to General Mladic and telling him

Page 15465

 1     about this looting, about beating people, and so on, and I told him about

 2     some of these moving scenes that I had seen, where people were crying and

 3     despairing over such situations.  When Mr. Karadzic entered, five or

 4     ten minutes later someone said that part of Arkan's unit had arrived.

 5     Some young men had come.  I remember this very well, because we went out

 6     to see.  And in front of the command where Ratko Mladic was, a few

 7     vehicles stopped, and among them there was a Golf that had its roof cut

 8     off.  And these young men introduced themselves as members of Arkan's

 9     unit who had come to help in the liberation of Sarajevo.

10             Then we went into the office, and the conversation continued on

11     that topic.  General Mladic was very angry when he saw these people,

12     because he was totally against the paramilitaries coming, particularly

13     Arkan's unit, and he said, Who sent them, how come they were there?  And

14     then in response to that, Mr. Karadzic said, It's all right, we asked

15     them to come.  They should help with the liberation of Sarajevo.  And, If

16     they can do it, let them do it.  Let them take whatever they can take.

17             MS. UERTZ-RETZLAFF:  Your Honour, I would like to have -- no,

18     I think it takes too much time.

19        Q.   In your statement, you also mentioned an encounter with the

20     paramilitaries in various places, and you, in particular, spoke about a

21     certain Carli with the Red Berets in Sarajevo, and you also mentioned

22     Zika Crnogorac.  And in this context, you, in fact, mentioned - and that

23     is paragraph 103 - that you saw a video with Zika Crnogorac, that you

24     saw.  Do you remember that?

25        A.   When I talked about coming to Sarajevo, I didn't say that Arkan

Page 15466

 1     was in Sarajevo.  I said that there was a person there who was the

 2     commander of that unit that had come, and they called him Carli.  I never

 3     learned his name.  That was a unit that had come, equipped by the MUP of

 4     Serbia.  Carli is what he was called.  However, Arkan was not in that

 5     area.  He was in the area of Zvornik, Bijeljina, elsewhere, whereas

 6     Zika Crnogorac - sorry for interrupting - was not there.  Zika Crnogorac

 7     was in Brcko.

 8        Q.   Yes, but we come to this in more detail.  I actually want to

 9     stick with Zika Crnogorac only very briefly, and for this I would like to

10     have the video 65 ter 45235 being played.  And we only want to see

11     certain parts of it.

12             Before we start doing this:  Mr. Davidovic, have you seen a video

13     depicting an award ceremony of the unit of special operations in Kula

14     while you prepared for the testimony?  Did you review this video in

15     parts?

16        A.   I did view that footage, parts of it, although I have to say that

17     I had had it earlier on.  I still have it to this day, and I know it.

18     I've known it from before, too.

19             MS. UERTZ-RETZLAFF:  Can we please have the part 00:22 until

20     00:1:10 being played.

21        Q.   And if you just would tell us whom you see.

22                           [Video-clip played]

23             THE WITNESS: [Interpretation] This is Mr. Jovica Stanisic, and on

24     the right is Legija.  He is reporting to him in Kula.  Also,

25     Jovica Stanisic.  This is Mr. Kertes, Vucetic.  This is Zika Crnogorac at

Page 15467

 1     the left.

 2             MS. UERTZ-RETZLAFF:  Thank you, that is sufficient.  But I'm a

 3     bit surprised.  I thought we have a running transcript, because --

 4             JUDGE KWON:  My information is we do have the transcript, but

 5     it's impossible to present it together with the video.

 6             MS. UERTZ-RETZLAFF:  What would be best would be, actually, if

 7     the translation booth would have the two transcripts.

 8             JUDGE KWON:  So shall we do it next week?

 9             MS. UERTZ-RETZLAFF:  Oh, yeah.  Yes, we can do that, definitely.

10     I thought it would be here underneath.  I'm sorry.

11             JUDGE KWON:  Very well.

12             I note the time, Ms. Uertz-Retzlaff.  It's time to rise for the

13     week.  This week we have been very efficient and productive, so much so

14     that we have been hearing seven witnesses, starting from Ms. Hanson.

15             We'll rise, and we'll resume 9.00 on Tuesday next week.

16             Please do have a nice weekend, Mr. Davidovic.

17             MS. UERTZ-RETZLAFF:  Your Honour, you usually remind the witness

18     not to talk.

19             JUDGE KWON:  Yes, I was about to.

20             MS. UERTZ-RETZLAFF:  Oh, sorry.

21             JUDGE KWON:  And in the meantime during the break, you're not

22     supposed to discuss with anybody else about your testimony.  Do you

23     understand that, Mr. Davidovic?

24             THE WITNESS: [Interpretation] Yes, fully.

25             JUDGE KWON:  Thank you.

Page 15468

 1                           [The witness stands down]

 2                           --- Whereupon the hearing adjourned at 3.00 p.m.,

 3                           to be reconvened on Tuesday, the 28th day of June,

 4                           2011, at 9.00 a.m.