Tribunal Criminal Tribunal for the Former Yugoslavia

Page 17170

 1                           Friday, 22 July 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 11.00 a.m.

 6             JUDGE KWON:  Good morning, everyone.  As noted, we are sitting

 7     pursuant to 15 bis.

 8             Mr. Karadzic, are you on your own today?

 9             THE ACCUSED: [Interpretation] No.  I have a case manager, but he

10     is doing his best to provide documents to the Prosecution and to find the

11     numbers of the existing documents.

12                           [Trial Chamber and Registrar confer]

13             JUDGE KWON:  The court deputy has an announcement.

14             THE REGISTRAR:  Yes, Your Honours.  Directive number 3 which was

15     tendered by the accused last evening was actually not in evidence, so

16     it's not translated, so it will be MFI D1601 and it's 65 ter 06314.

17             JUDGE KWON:  Thank you.

18             Yes, Mr. Karadzic, you have 40 minutes.

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

20             Good morning, Excellencies.  Good morning to everyone.

21                           WITNESS:  REYNAUD THEUNENS [Resumed]

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

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

24        A.   Good morning, Mr. Karadzic.

25        Q.   Since we do not have too much time, I will do my best to finalise

Page 17171

 1     this in a nice and efficient manner and I will put as short possible

 2     questions as I can.

 3             THE ACCUSED: [Interpretation] Can we now have 65 ter 05314.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   And I believe you have made reference to this document in one of

 6     your footnotes.

 7             THE REGISTRAR:  This is Exhibit P3035.

 8             JUDGE KWON:  3035.

 9             THE REGISTRAR:  Exhibit P3035.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   Do you agree, since you are familiar with this document, right,

13     that it defines the formation of the organisation in terms of command and

14     control of the Army of Republika Srpska; is that correct?

15        A.   Yes, Your Honours, that is correct.  And for your information, it

16     is footnote 201 in the second part of the report.

17        Q.   Thank you.

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

19             I believe we need the next page in the English, item 4.

20             MR. KARADZIC: [Interpretation]

21        Q.   Do you agree that item 4 entitled:  "Command and control of

22     operational groups on the front line" is being implemented by the Main

23     Staff of the Army of SR Bosnia and Herzegovina, and that it is directly

24     subordinate to the Presidency of SR Bosnia and Herzegovina?

25        A.   Yes, Your Honours.  That is what the document states, and I

Page 17172

 1     explained also in my examination that the term "operative groups" is, in

 2     fact, used in this document for the course of the VRS.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] Can we have the last page in the

 5     Serbian so that we can see the signature.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Is this my signature and the earlier stamp of the Republic of

 8     Srpska?

 9        A.   Yes, Your Honours.  Mr. Karadzic signs as the president of the SR

10     BiH Presidency.

11        Q.   Thank you.  Do you remember that in the Law on the Army,

12     operative and, of course, tactical command over the army is the

13     responsibility of the Main Staff?

14        A.   Indeed, Your Honours, whereby of course the Main Staff is

15     responsible to the Supreme Command -- I mean, the Supreme Command is only

16     introduced in November 1992, but prior to the Supreme Command, the

17     Main Staff is responsible -- the command of the Main Staff is responsible

18     to the president of the SRBiH Presidency.

19        Q.   Thank you.  This is already in evidence, and then on page 123 of

20     this section which refers to me in part 2 under (c), you said directive

21     number 7 was amended on the 31st of March, 1995, by directive 7(1).

22     Did -- was the Main Staff authorised to amend this directive to adapt it

23     and to convert it into an executive order?

24        A.   I mean, if we would apply the principles of command and control,

25     the Main Staff would be allowed to do so after the authorisation of the

Page 17173

 1     supreme commander.  But it would be good to see this amendment to the

 2     directive number 7, because maybe a reference is made to an oral order --

 3     another order of the supreme commander in order to explain that indeed

 4     the amendment has been made with the authorisation or maybe on the

 5     instruction of the supreme commander and the Supreme Command.

 6        Q.   Thank you.  We don't have time to call it up.  I would like to

 7     ask you the following in principle:  Were the directives forwarded to the

 8     Main Staff from the state leadership, and then was it the Main Staff who

 9     was implementing it?  Or in other words, did they serve as a basis for

10     the Main Staff to form their own executive decisions?

11        A.   Indeed, Your Honours.  We have discussed that in my examination,

12     where we have seen, for example, an order by the Drina Corps which

13     implemented actually the tasks that were set in directive number 6 for

14     the Drina Corps.  And there are other examples.  And this goes down

15     through the chain of command until the lowest-level units in accordance

16     with the principles of single authority and unity of command.

17        Q.   Thank you.

18             THE ACCUSED: [Interpretation] Can we now look at D01140.

19             MR. KARADZIC: [Interpretation] I owe it to you because I didn't

20     show it yesterday.

21                           [Trial Chamber and Registrar confer]

22             THE ACCUSED: [Interpretation] D01140, yes.

23             JUDGE KWON:  Very well.  Shall we go into private session

24     briefly?

25             THE ACCUSED: [Interpretation] Or maybe we shouldn't broadcast

Page 17174

 1     this, but I don't think that it is subject to any restrictions.

 2             JUDGE KWON:  Just a second.  Sometimes it is prudent not to say

 3     that a certain document should not be broadcast in public session.  I was

 4     told this is a document under seal.  Is it -- I wanted to check whether

 5     it is sufficient not to broadcast this document.

 6                           [Private session]

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 17175











11  Pages 17175-17179 redacted. Private session.















Page 17180

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10                           [Open session]

11             THE REGISTRAR:  We're now in open session.

12             THE ACCUSED: [Interpretation] Can we have 1D2613.

13             MR. KARADZIC: [Interpretation]

14        Q.   I owe you that as well in relation to the order of

15     Colonel Andric.  It's General Andric now.  1D2613.

16             It is part of S25392, report of the Secretary-General, but our

17     number is -- yes.  Can we have the page before this one, please.  Let us

18     just see what they are referring to.  The last digits of the ERN number

19     should be 544.

20             JUDGE KWON:  I think this --

21             THE ACCUSED: [Interpretation] Next one then.  Perhaps it was

22     typed out in a different way.  Can we have the next one.

23             MR. KARADZIC: [Interpretation]

24        Q.   Please, do you see the top:

25             [In English] "On the basis of the Agreement of 22nd of May ..."?

Page 17181

 1             [Interpretation] Do you see that in the preamble they are

 2     referring to that meeting?

 3        A.   Your Honours, I see that there is a reference to an agreement of

 4     22nd of May, 1992, but I'm -- I'm not familiar with the contents of the

 5     agreement.

 6        Q.   This is a meeting that was held on the 30th of September, but

 7     there is a reference to the meeting of the 22nd of May.  And now we're

 8     moving on to the agreement of the 22nd of May.  551 is the ERN number

 9     that I'd like to see now.  551 are the last three digits of the ERN

10     number.  A bit further down.  These people met.  And let us see where.

11     It says that they met in Geneva on the 22nd of May.

12             Two pages further down.

13        A.   Mm-hmm, okay.

14        Q.   2.3, let's look at that, and then the fourth paragraph of that,

15     "the displacement ...":

16             [In English] "The displacement of the civilian population shall

17     not be ordered unless the security of the civilians involved or

18     imperative military reasons so demand.  Should such displacements have to

19     be carried out, all possible measures shall be taken in order that the

20     civilian population may be received under satisfactory conditions of

21     shelter, hygiene, health, safety, and nutrition."

22             [Interpretation] Do you remember that six days after this, on the

23     28th of May, Andric included this aspect in his orders?

24        A.   Your Honours, the order by the then-Colonel Andric spoke about

25     the move of civilians; I mean, Muslim women and children.  I don't

Page 17182

 1     remember that he explained the conditions or the surrounding conditions

 2     or the context in his order, nor that he referred to any agreement that

 3     had been concluded in Geneva on the 22nd of May.  It may well be that the

 4     two are linked, but I can't establish that link.  It may also be that

 5     there's just a coincidence in timing.

 6        Q.   Why not?  From the 8th of April until the 28th of May, why did he

 7     not issue that kind of order?  We asked that yesterday.  It only happened

 8     on the 28th of May.  How can it be a coincidence?  Obviously he received

 9     this.  He received a copy of this agreement.  And he started involving

10     this in his orders.  It was only after the 22nd of May.  Did you find any

11     similar order of his before the 22nd of May?

12        A.   Your Honours, I did not find such an agreement prior to the one

13     dated the 28th of May, but that doesn't mean that there may not have been

14     any instructions to --

15        Q.   Oh, come on, don't.  We're not interested in your explanation.

16     We're interested in facts --

17             JUDGE KWON:  Mr. Karadzic, you're not here to argue with the

18     witness.  The witness has answered the question.

19             THE ACCUSED: [Interpretation] He did not answer the question.

20     He's expanding the question.  He's trying to harm the Defence.  I'm

21     asking him whether he found it or not.  I'm asking -- I'm not asking him

22     what it means.

23             MR. KARADZIC: [Interpretation]

24        Q.   You, sir, have shown that you are partial --

25             JUDGE KWON:  Mr. Karadzic, he said:

Page 17183

 1             "It may well be that the two are linked, but I can't establish

 2     that link.  It may also be that there's just a coincidence in timing."

 3     That's his answer, and whether it's credible or not can be debated later

 4     on.  It's not for you to argue with the witness.

 5             THE ACCUSED: [Interpretation] I would just like to state that the

 6     Defence sees bias in all of that, but let it be as you had said.  Can we

 7     have this document admitted.

 8             JUDGE KWON:  Mr. Theunens, Mr. Karadzic put that he sees bias in

 9     all of that.  If you'd like to comment.

10             THE WITNESS:  I mean, Your Honours, I explained my methodology in

11     the beginning, i.e., during the examination.  It's Mr. Karadzic's

12     observation.  I think, as you have explained several times, it's up to

13     the Trial Chamber to decide on these matters.

14             JUDGE KWON:  This has to be admitted under seal as well?  It

15     should be no problem.  We'll admit it.

16             THE REGISTRAR:  Exhibit D1603, Your Honours.

17             THE ACCUSED: [Interpretation] Can we have 1D30339

18     [as interpreted].

19             JUDGE KWON:  Probably you need to give the number again.

20             THE ACCUSED: [Interpretation] 1D01339.  I was convinced that we

21     had tendered that earlier.  1D01339.  Statement on Bosnia at the

22     London Conference.  Page 3, please.

23             MR. KARADZIC: [Interpretation]

24        Q.   Do you see (d) and (e)?  Please take a look at (d) and (e).

25        A.   Yes, I've seen them, Your Honours.

Page 17184

 1             THE ACCUSED: [Interpretation] Can we have the next page.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   (E) again.  Could you please focus on that, please.

 4        A.   Yes, I've seen them.

 5        Q.   Thank you --

 6             JUDGE KWON:  Probably the witness needs to see the first page

 7     briefly.  No, second page, next one.

 8             Yes, Mr. Karadzic, what is your question?

 9             THE ACCUSED: [Interpretation] Could we please have a look at the

10     last page.

11             THE WITNESS:  I'm fine with the first one.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you agree, Mr. Theunens, that Douglas Hogg, minister in the

14     foreign office of Great Britain, Radovan Karadzic, and

15     Nikola Koljevic - could you please show us the bottom of the

16     page - signed all of this.  And could you please read ii, the last

17     paragraph.

18        A.   Yes, I've read the paragraph.

19        Q.   So do you agree that on the 27th of August, 1992, we took the

20     obligation to create centres for refugees, that we would honour the

21     rights of all refugees and persons whose property was destroyed, and that

22     we would return a substantial portion of the territory once the agreement

23     is adopted?

24        A.   Your Honours, I can only say that, indeed, that is what the paper

25     states, what the document states.  But, I mean, the whole issue, when you

Page 17185

 1     look back at the conflict in Bosnia-Herzegovina with all these documents

 2     and agreements and signatures, is to what extent were they implemented?

 3     So I would only be able to answer the question if I could then also

 4     analyse reports and other, I mean, information on the degree of

 5     implementation of this agreement.  Now it is a piece of paper that has

 6     been signed and where we can all read what it states, but the actual

 7     value should be -- or resides in the degree of implementation.

 8        Q.   Once the Dayton Accords were signed, did we return the most

 9     valuable parts of, let's say, part of the city of Sarajevo, such as

10     Ilidza, Hadzici, Vogosca, et cetera?  Let's just talk about this.  Let's

11     forget about everything else.  Did we return all these territories?

12        A.   Your Honours, I just would like to emphasise, this is outside the

13     scope of my report, but, indeed, the Bosnian Serbs returned parts of

14     Sarajevo they controlled.  And, I mean, one just has to take into account

15     that the overall situation in December -- November/December 1995,

16     especially the, what I would call, strategic position of the

17     Bosnian Serbs was significantly different from the position they enjoyed

18     in August 1992.

19        Q.   Well, our position in August 1992 was a better and a stronger

20     one, wasn't it?  We were at the peak of our military power when we signed

21     this; right?

22        A.   That is correct, Your Honours, and that refers also to the --

23     again, the comments General Mladic includes when he signs -- indeed,

24     excuse me, the directive for further operations number 2, to say that

25     actually the gains the Bosnian Serbs have made, territorial gains, allow

Page 17186

 1     them to negotiate in the position of the stronger; that is footnote 361

 2     in part 2 of the report.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] Can this be admitted and

 5     regretfully I have to say that I would have needed many more hours for

 6     this witness, but that's how it is.  I hope that proper weight shall be

 7     attributed to some general statements.

 8             JUDGE KWON:  The final document will be admitted as

 9     Exhibit D1604.

10             Thank you, Mr. Karadzic.

11             Yes, Ms. Elliott.

12             MS. ELLIOTT:  May I please have P00956, which is the 16th

13     Assembly Session, and e-court pages B/C/S page 16, and in English,

14     page 20.

15                           Re-examination by Ms. Elliott:

16        Q.   Mr. Theunens, Mr. Karadzic said that the six strategic goals were

17     not military but rather political goals, over the last few days, and that

18     his statement on these six strategic goals at the 16th Assembly Session

19     was solely an expression of the political situation prevailing at the

20     time.  I'd like you to look at the discussion that follows the accused's

21     speech at the 16th Assembly Session.  And, here, on the screen, we have

22     Miroslav Vjestica, who, as I understand it, is a member of the Assembly

23     from Bosanska Krupa.  And I'm referring to the last paragraph in B/C/S

24     and in English, the portion at the beginning that says:

25             "I fully accept all the strategic goals that have been proposed,

Page 17187

 1     but with the proviso that they be operationalised and individuals

 2     appointed who shall be responsible for the activities related to each

 3     individual goal ..."

 4             And then I'd like to direct your attention to halfway down the

 5     page in English, and this is the next page in B/C/S, where he states:

 6             "For a year and a half, we have been preparing in the Serbian

 7     municipality of Bosanska Krupa ..."

 8             He goes on to explain the make-up -- the ethnic make-up of the

 9     municipality, that there are --

10             THE ACCUSED: [Interpretation] Objection.

11             JUDGE KWON:  Objection to what?  She was just showing the

12     document.

13             THE ACCUSED: [Interpretation] Yes, but this contribution that was

14     freely made by one of the delegates is connecting to me.  This is his

15     contribution that was entered into the conclusion.  This is not something

16     that I said.

17             JUDGE KWON:  No, it goes to the weight.  It's not for you to

18     object to this at this moment.

19             Yes, please proceed, Ms. Elliott.

20             MS. ELLIOTT:

21        Q.   I -- yes, Mr. Theunens, I'm referring you to the conversation or

22     the speech on this page, and then moving on to the portion where this

23     Assembly member states:

24             "Thank God, we did get to our borders because we knew that was

25     how we had envisioned them and drawn them, and you, people's deputies,

Page 17188

 1     know well that we had said that the right bank of the Una river would be

 2     our border ..."

 3             He continues on to discuss future operations in Bosanska Otoka,

 4     stating that:

 5             "In two to three days, we shall mine the bridge in Bosanska Otoka

 6     connecting it with Bosanski Novi.  This will be done.  I guarantee it."

 7             And then towards the bottom of the page in English, he states

 8     that:

 9             "There are no more Muslims in the Serbian municipality of

10     Bosanska Krupa ..."

11             And then at the very end of this page:

12             "Will they have a place to return to?  I think it ..."

13             And we have to go to the next page in English, please.

14             "I think it is unlikely after our president told us the happy

15     news that the right bank of the Una is the border."

16             My question for you, Mr. Theunens, is:  Does this passage you

17     have just reviewed relate to the issue of whether the accused's speech

18     had military implications at the 16th Assembly Session?

19        A.   Indeed, Your Honours.  I mean, it shows that the strategic goals

20     are implemented and have been implemented also -- I mean, on the terrain,

21     including through the use of military means, already prior to the public

22     announcement at the Assembly session.

23             MS. ELLIOTT:  If I can call up 65 ter 04197, please.  And while

24     this is coming up, it's a document issued by the War Presidency of

25     Bosanska Krupa, dated the 25th of May, 1992.

Page 17189

 1        Q.   And, Mr. Theunens, if I could direct your attention to items 2

 2     and 3 of this document.  Both are on page 1 of B/C/S, but you will have

 3     to go over to page 2 to complete item 3 in English.

 4        A.   I have read the English page, the first English page.

 5        Q.   Mr. Theunens, this document dates 13 days after the 16th Assembly

 6     Session.  Are you able to comment on this document and whether it bears

 7     any relation to the speeches by Mr. Vjestica or the accused at the

 8     16th Assembly Session?

 9        A.   Your Honours, I have to say that the ARK, I mean the Autonomous

10     Region of Krajina, is outside the scope of my report.  But I think that

11     the document is very straightforward in a sense that starting with the

12     second page, reasons, number -- the reason number 1 corresponds with the

13     strategic goal number 4, i.e., establishing a border on the Una and also

14     the Neretva, but that's another area.  And if we go back to the first

15     page in English, I believe that there is a reference on removing

16     population.

17             THE ACCUSED: [Interpretation] Can we get information as to whom

18     this proposal was sent, who signed it, and whether it was accepted or

19     not --

20             JUDGE KWON:  Mr. Karadzic, don't interrupt the witness's evidence

21     while he's speaking.

22             THE ACCUSED: [Interpretation] Not the witness.  I'm asking.  I

23     can't see who it is sent to.

24             JUDGE KWON:  Yes, please -- I think it's on the monitor on B/C/S

25     page.

Page 17190

 1             Yes, please continue, Mr. Theunens.

 2             THE WITNESS:  Yes, Your Honours.  So in the second point, a

 3     reference is made to "demolishing as many residential and other

 4     buildings, including ..." and so on.  One could make a link there to the

 5     first strategic goal because residents -- I mean, residential area or

 6     building is usually inhabited by civilians.  But the most obvious link is

 7     obviously to the fourth strategic goal, the establishment of a border on

 8     the Una.

 9             JUDGE KWON:  This document says "proposal," but proposal to what,

10     if you could know?

11             THE WITNESS:  I think -- we can see -- the document is drafted by

12     the War Presidency of the Serbian municipality of Bosanska Krupa, and I

13     would say that it's -- I mean, we have to see who signed it --

14             JUDGE KWON:  It says to the command of the first --

15             THE WITNESS:  Yeah, that is a unit of a local -- I mean, the

16     local Serb unit in the area there.  So the War Presidency sends a

17     proposal to them, and if we go on the second page maybe there is -- there

18     should be a name as to who signed it and what his position was.  It

19     seems --

20             JUDGE KWON:  B/C/S version.

21                           [Trial Chamber and Registrar confer]

22             THE WITNESS:  Yeah, it's not clear why -- I mean, the English

23     translation seems to be incomplete, but it's signed by Gojko Klickovic,

24     who is president of the War Presidency.

25             MS. ELLIOTT:  Your Honour, I'd ask that this document be marked

Page 17191

 1     for identification pending full translation.

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  MFI P3150, Your Honours.

 4             MS. ELLIOTT:  Can I please call up D00825, and page 13 in both

 5     the English and the B/C/S.

 6        Q.   While this is coming up, Mr. Theunens, this is the, I'll call it,

 7     memoirs of General Milovanovic, who you discussed yesterday with the

 8     accused.  And in particular, at T17142, the accused told you that the

 9     task that Milovanovic got was to protect the people.  And I'd like you --

10     to refer you to the last paragraph in English, and in B/C/S it's the

11     portion just above the subheading (b), starting with the reference to the

12     12th May 1992 session in Banja Luka, where he writes:

13             "The six strategic (military) objectives of the Serbian people

14     proceeded from this decision ..."

15             And then he discusses how they were implemented and says:

16             "In the realisation of their objectives, the Serbs used no other

17     means except their own armed power and diplomacy."

18             My question is:  Does this relate to the issue of whether the

19     accused's statement of the strategic objectives at the

20     16th Assembly Session had military implications?

21        A.   Yes, Your Honours, and what General Milovanovic states there, in

22     my view, corresponds with what I have stated earlier and put in my

23     report; that is, that the six strategic goals are the basis for military

24     orders, starting with the directives for further operations, and then the

25     development of subsequent orders throughout the chain of command within

Page 17192

 1     the VRS between May 1992 and, say, September 1995.  And, of course -- and

 2     that was also highlighted earlier, that in addition to the VRS, also the

 3     six strategic goals serve as a basis -- I mean, in addition to serving as

 4     a basis for military operations, they also serve as a basis for

 5     negotiations.  And obviously the two are coherent.  The goals one tries

 6     to achieve by conducting military operations, one can also -- one would

 7     also try to achieve them by the use of diplomacy during negotiations.

 8             MS. ELLIOTT:  Your Honour, I'd ask that these -- this page be

 9     added to Exhibit D00825.  As I understand it, only pages 30 and 31 of

10     this document are currently admitted.

11             JUDGE KWON:  Given that General Milovanovic was referred to

12     several times, how about admitting it in its entirety, given that it is

13     his?

14             MS. ELLIOTT:  Yes, Your Honour.

15             JUDGE KWON:  Do you object to it, Mr. Milosevic -- I'm sorry, my

16     apologies, Mr. Karadzic?

17             THE ACCUSED: [Interpretation] Well, if it has a prefix D, it

18     means it's been admitted.  What I'm interested in is to identify whether

19     this journal was compiled as a contemporaneous document or whether this

20     was written in hindsight.  This is our exhibit, and we introduced that as

21     a document reflecting the things that he saw in Bosnia at the time;

22     whereas this is something that was written afterwards, after he has

23     learned about the existence of the strategic goals.

24             JUDGE KWON:  Since Milovanovic was referred to in terms of his

25     statement, interview, I think we'll admit this in its entirety.  So it

Page 17193

 1     has been admitted, but we change the status as having been admitted in

 2     its entirety.

 3             Yes, Ms. Elliott.

 4             MS. ELLIOTT:  May I please have P00970, and starting with page 1

 5     in both languages.

 6        Q.   And while this comes up, Mr. Theunens, this is the

 7     50th Assembly Session which was held on the 16th of April, 1995, and you

 8     refer to this Assembly Session at part 2 footnotes 62, 1051, 1052, and

 9     1105.

10             And on page 1 that we're looking at now, I just ask you to

11     confirm that the minutes record that the accused was in attendance at

12     this session.

13        A.   Yes, that is what is stated on the first page.

14             MS. ELLIOTT:  And if I can ask if we can go to B/C/S page 18,

15     English page 22, please.

16        Q.   And again, I'm dealing with the topic of military awareness of

17     the strategic goals.  And what will come up on the screen is part of

18     General Mladic's speech that you have referred to in your report.  And

19     this is towards the end of the first paragraph in B/C/S and the end of

20     the fourth paragraph in English, where General Mladic states:

21             "The tasks of the army in this war stem from the known six

22     strategic objectives adopted by our Assembly which have not been carried

23     out to the full due to the lack of material and other support."

24             Mr. Theunens, does this relate to the issue of whether the

25     accused’s statements of the strategic objectives at the

Page 17194

 1     16th Assembly Session had military implications?

 2        A.   Indeed, Your Honours, and in my view, this corresponds with my

 3     conclusions in my report, whereby I didn't explicitly refer to this

 4     observation made by General Mladic at the 50th Assembly Session, but it

 5     is consistent with -- also with my conclusions -- or my conclusions are

 6     consistent with it.  That sounds better.

 7        Q.   Thank you.

 8             MS. ELLIOTT:  And if I can call up P00988, page 87 in the B/C/S

 9     and page 68 in the English.

10        Q.   What I'm calling up, Mr. Theunens, is a speech by the accused at

11     the 53rd Session on the 28th of August, 1995.  And starting from the --

12     reading from the bottom of the English here where the accused says:

13             "To tell the truth, there are towns that we've grabbed for

14     ourselves ..."

15             And I'll need the next page in English only, please.

16             And he continues:

17             "... and there were only 30 per cent of us.  I can name as many

18     of those as you want, but we cannot give up the towns where we made up

19     70 per cent.  Don't let this get around, but remember how many of us

20     there were in Bratunac, how many in Srebrenica, how many in Visegrad, how

21     many in Rogatica, how many in Vlasenica, in Zvornik, et cetera.  Due to

22     the strategic importance, they had to become ours.  And no one is

23     practically questioning it any more."

24             And my question is:  Can you explain if there's any relation

25     between this passage we've just reviewed and the accused's statement of

Page 17195

 1     the strategic objectives at that 16th Assembly Session?

 2        A.   Your Honours, these towns are essential in order to achieve

 3     strategic -- a number of the strategic goals.  Bratunac, Srebrenica,

 4     Visegrad, Rogatica, we refer -- and, actually, also Vlasenica and Zvornik

 5     we refer to the goal of eliminating the Drina as a border, i.e., the

 6     third strategic goal.  And obviously there's always the first strategic

 7     goal:  Separation of the Serbian people from the other people, that would

 8     also be -- is also implemented through the Serbian or Bosnian Serbs

 9     taking control over the towns we just identified.

10        Q.   Thank you.

11             MS. ELLIOTT:  That concludes my re-examination, Your Honour.  I

12     just want to make one note, which is that the accused pursued a number of

13     points about peace negotiations in his cross-examination of Mr. Theunens.

14     We have a report in evidence, the Treanor report referred to yesterday,

15     which is directly on point.  And the accused did not actually challenge

16     any aspects of the Treanor report that directly contradict many of the

17     assertions he's been making in court over the past few days, which he is

18     required to do under Rule 90(H).  We're not proposing to go through any

19     of the documents in this -- in relation to this issue through

20     Mr. Theunens, who's made it clear it's outside the scope of his report,

21     but I just wanted to advise that the Prosecution may bar table documents

22     in relation to this issue.  Thank you.

23             THE ACCUSED: [Interpretation] May I respond?

24             JUDGE KWON:  Let's deal with Mr. Theunens first.

25             Thank you, Mr. Theunens.

Page 17196

 1             THE WITNESS:  Thank you, Your Honours.

 2             JUDGE KWON:  I think that concludes your evidence.  Thank you for

 3     your coming to The Hague again.  Please have a safe journey back home.

 4             THE WITNESS:  Thank you, Your Honours.  Good-bye.

 5                           [The witness withdrew]

 6             JUDGE KWON:  Yes, Mr. Karadzic.

 7             THE ACCUSED: [Interpretation] Well, this question that was raised

 8     just now at the very end, that is something that we discussed with

 9     Mr. Bell, too.  He also accepted that I was persuading people to accept a

10     plan, according to which we were losing Drvar with a 100 per cent Serb

11     population.  As for challenging, it has to do with the fact that I do not

12     have enough time for these Prosecution witnesses.  I'm challenging

13     everything.  It is their creation.  I'm challenging everything except for

14     direct quotes.  It was done poorly and maliciously.  It cannot be said

15     now that I'm not challenging any of it.  I'm challenging all of it, but I

16     don't have time to expound.

17             JUDGE KWON:  As I believe there will be another time that issue

18     will be raised again, we'll deal with it when it arises.

19             There's one further matter the Chamber would like to raise before

20     we adjourn for the recess.  I note that we are still seized of the

21     Prosecution notification of the accused's non-compliance with the

22     Trial Chamber's order on selection of cases for DNA analysis and request

23     for further orders filed on 21st of June, this year.

24             With respect to this request, the Defence, the accused, filed its

25     response on 26th of June, 2011.  Speaking for myself, I'm not clear as to

Page 17197

 1     the meaning of what is contained in paragraphs 8 and 9 in this response,

 2     so it is ordered that the Defence -- to clarify what is stated in paras 9

 3     and 8 and elaborate on its basis in a week's time from now, i.e., by

 4     Friday, 29th July.  And the Prosecution response, if it so wishes, in two

 5     weeks' time from the receipt of the filing by the accused, i.e., by

 6     12th of August.

 7             And are there any matters to raise before the recess?

 8             Yes, Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] Since Mr. Robinson is in Moscow now

10     on Defence business as assigned by me, can we have a slightly longer

11     dead-line?  Can we have more time than up until the 29th of July?

12             JUDGE KWON:  This has been dealt with, in my understanding, by

13     Mr. Sladojevic.

14             THE ACCUSED: [Interpretation] But Mr. Robinson too, to a large

15     extent.

16             JUDGE KWON:  Let me check.

17             Then I'll give you three more days, by 3rd of July -- I'm sorry,

18     3rd of August, that's Wednesday, and then I think Prosecution will have

19     about ten days, by 12th.  Would it be plausible -- or by -- very well.

20     Defence is ordered to file it by 3rd of August, and Prosecution is to be

21     responding by 15th of August, Monday.

22             THE ACCUSED: [Interpretation] We'll do our best.  The Defence

23     will do its very best to do it.

24             JUDGE KWON:  In short, I didn't understand what it meant and how

25     it is possible, whether it is true, so I'd like to know the basis of such

Page 17198

 1     allegation.

 2             That's it.  And then we'll adjourn for -- until -- we resume at

 3     9.00 on 16th of August.  I wish everybody has a restful and refreshing

 4     recess, and I take this opportunity to thank again all the assistance by

 5     our precious staff members.  Thank you very much.

 6                           --- Whereupon the hearing adjourned at 12.11 p.m.,

 7                           to be reconvened on Tuesday, the 16th day of

 8                           August, 2011, at 9.00 a.m.