Tribunal Criminal Tribunal for the Former Yugoslavia

Page 17298

 1                           Wednesday, 17 August 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

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

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Mr. Witness.

 8             Mr. Robinson, you have someone to introduce.

 9             MR. ROBINSON:  I do.  Thank you very much, Mr. President.  Our

10     legal intern Hae Jin Choo is joining us for this first session this

11     morning.  Thank you.

12             JUDGE KWON:  Thank you.

13             Yes, Mr. Nicholls.

14             MR. NICHOLLS:  Good morning.  Thank you, Your Honours.

15                           WITNESS:  WITNESS KDZ-555 [Resumed]

16                           [Witness answered through interpreter]

17                           Examination by Mr. Nicholls: [Continued]

18        Q.   Good morning, Witness.

19        A.   Good morning.

20        Q.   All right.  I want to move ahead now and ask you some questions

21     about events in Zvornik which you've talked about in your statement and

22     before, and the first one is described in paragraph 93 and 94 of your

23     statement and that is the --

24             MR. NICHOLLS:  I think the witness can't hear.

25        Q.   Can you hear me now, sir?

Page 17299

 1        A.   Yes, because I didn't receive translation earlier, I would kindly

 2     ask you to repeat your question.

 3        Q.   I will.  I'm going to ask you now, moving ahead, about some

 4     incidents which occurred in Zvornik in the May-June period and earlier

 5     that you've talked about before, and the first one is in 93 and 94 of

 6     your statement and that relates to Celopek.  Was there a detention

 7     facility during that time in Celopek that you heard about?

 8        A.   Yes, as a citizen of Zvornik, I did hear that that existed.

 9        Q.   [Microphone not activated].

10             Which people were detained in Celopek, can you describe what you

11     heard?

12        A.   I heard that Muslims were being detained.

13        Q.   And which village were these Muslims from?

14        A.   I'm not sure.  I think it was Divic.

15        Q.   And describe what type of conditions you heard as a citizen of

16     Zvornik at the time these men were detained in?

17        A.   I don't have any details.  I just heard that they were detained

18     at the cultural centre in Celopek.

19        Q.   Which unit, force, group, who guarded these men from Divic in

20     Celopek?

21        A.   I don't know that.

22        Q.   All right.  Well, let me just try to remind you from your

23     statement and if you don't know, you can explain.  You stated that, in

24     para 94:

25             "As far as I know, Zuca's unit controlled the jail in Celopek and

Page 17300

 1     they were very abusive in their behaviour."

 2             One sentence later:

 3             "Terrible stories were being told in town about what Zuca and his

 4     men did in Celopek."

 5             So can you tell me what some of those terrible stories were that

 6     you heard about Zuca's men in Celopek?

 7             MR. ROBINSON:  Excuse me, Mr. President, I'm going to object to

 8     this.  I know that hearsay is allowed here at the Tribunal, but now we're

 9     just repeating rumours, and unless there's more foundation for what the

10     source of the information was that the witness is going to repeat in

11     court, I think it should be excluded.  Thank you.

12             JUDGE KWON:  I think Mr. Nicholls is trying to refresh his

13     memory, having heard his first answer, I think it's fair enough.

14             We'll see how the witness is able to answer the question.

15             Did you complete your question, Mr. Nicholls?

16             MR. NICHOLLS:  Yes, Your Honour.

17             THE WITNESS: [Interpretation] I don't have any direct knowledge.

18     What I stated is what is contained in my statement.  That is what I read

19     in the newspapers about their trial and that is what I heard from some

20     unofficial sources too.

21             MR. NICHOLLS:

22        Q.   And what were those unofficial sources?

23        A.   Well, it was being talked about.  These people were on trial, the

24     newspapers wrote about it, it was in the media, there was talk in town

25     that there were paramilitaries there - I'm not sure which ones - that

Page 17301

 1     they controlled that unit.  But I don't know any further details.

 2        Q.   I'm going to now ask you about an event that you may know more

 3     about, and that is Djulici and Karakaj technical school, moving on in

 4     your statement.  Now, Djulici, was that a Serb or an ethnic neighbourhood

 5     or area -- Serb or Muslim I mean to say.

 6        A.   Yes, Djulici was a purely Muslim town and there were a few other

 7     Muslim villages that gravitated towards that area.

 8        Q.   Now, in June 1992, approximately how many Muslim residents were

 9     in the Djulici area?

10        A.   Well, I don't know exactly but I think that about 3- or

11     4.000 Muslims gravitated in that area.

12        Q.   Why did they gravitate to that area?

13        A.   I mean, I'm not sure what gravitated means.  They are

14     geographically linked up, these villages around Djulici, that is what it

15     means as far as I'm concerned.

16        Q.   Thank you.

17             MR. NICHOLLS:  Could we go into private session, please.

18             JUDGE KWON:  Yes.

19                           [Private session]

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Page 17302











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Page 17308

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14                           [Open session]

15             MR. NICHOLLS:

16        Q.   Now, in June in Zvornik municipality, the area of Kozluk, the

17     Muslim area of Kozluk, how big was that area in terms of towns or

18     villages in the Zvornik municipality?

19        A.   Well, Kozluk is a small town that had a population of about 3- to

20     4.000 and perhaps 85 per cent were Muslim, but there were also a few

21     villages there, Skocic, Gornji Sepak, that are 4 or 5 kilometres away

22     from Kozluk.

23        Q.   In your statement you said it was the second-biggest city this

24     area comprised after Zvornik, is that right, second-biggest city after

25     Zvornik in the municipality?

Page 17309

 1        A.   Yes, the second-largest settlement.  You couldn't really call it

 2     a city.  It's a very small town.

 3        Q.   All right.  Thank you.  And I'm not, for time, going to go into

 4     the entire chronology, that in July were there Muslims -- by the end of

 5     July was the population of Kozluk -- the Muslim population of Kozluk

 6     still residing in Kozluk?

 7        A.   Well, the majority of them were still residing in Kozluk.

 8        Q.   Well, Witness, just -- I really do not want to spend a lot of

 9     time on this.  In your statement at paragraph 107 you say that:

10             "In June 1992, however, the situation changed and the Muslims at

11     Kozluk moved."  Not a few Muslims, not a small percentage, but that "the

12     Muslims of Kozluk moved."  Is that right or not right?

13        A.   I'm sorry, I wasn't paying attention to the date that you

14     mentioned, that was July 1992.  From the beginning of the hostilities

15     they remained living there until a date in June when they were removed

16     from Kozluk and they went to Hungary.

17        Q.   Thank you.  All right.  Now I want to move on again.

18             MR. NICHOLLS:  We should probably go into private session for a

19     moment, Your Honour.

20             JUDGE KWON:  Yes.

21                           [Private session]

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Page 17310











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Page 17311

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14                           [Open session]

15             JUDGE KWON:  We are in open session.

16             MR. NICHOLLS:  Thank you.

17        Q.   Now, Witness, can you tell me -- you've talked quite a lot about

18     these volunteers, paramilitaries.  Tell me as briefly as you can about

19     how they came to be arrested.

20        A.   Well, at the time I was in the commercial sector.  I don't know

21     any details.  All I know is that a special MUP unit came, led by

22     Milenko Karisik, together with some supporting personnel from another

23     unit.  Before that, the intelligence service gathered information about

24     their places of residence and just one morning all of them were arrested

25     and taken to the prison in Zvornik.  What surprised all of us, it was

Page 17312

 1     really a shock to all of us who were familiar with the developments in

 2     Zvornik, was that among those arrested was Marko Pavlovic.  I even think

 3     that Grujic, the president of the municipality, himself was surprised and

 4     that he called some services to try and intervene through some MUP

 5     channels, but he was told to leave it and to allow the judiciary and

 6     other organs to do their job regardless of everything else.

 7        Q.   And who was it who told him to leave it?

 8        A.   I don't know what you mean particularly.

 9        Q.   Well, you said that.

10             "... Grujic, the president of the municipality, himself was

11     surprised and that he called some services to try and intervene through

12     some MUP channels, but he was told to leave it ..."

13             That's what I mean, who was it who told him to leave it, in your

14     words, and not intervene?

15        A.   Yes, Karisik, he was in charge of that operation,

16     Milenko Karisik.  I think he was an officer in the police of

17     Republika Srpska, but I don't know which rank he held.

18        Q.   And do you recall an event which precipitated the arrest of the

19     paramilitaries in which they detained a minister of the government?

20        A.   Yes, there was talk in town that Mr. Ostojic, who was the

21     minister for information, was arrested at that time as well.

22        Q.   Just to be clear, arrested by the paramilitaries not by the

23     special police?

24        A.   Yes, yes, by the paramilitary troops stationed at Crni Vrh.

25        Q.   And when you said earlier in your answer about the judiciary and

Page 17313

 1     other organs to do their jobs, when the -- was that done, do you know

 2     what happened to these men after they were arrested, what their

 3     punishments were, how long they were held, that kind of thing?

 4        A.   I don't know how this process went along.  I know that another

 5     proceedings were conducted in Sabac.  Zuca's brother was convicted there

 6     and I think he committed suicide in prison.

 7             THE INTERPRETER:  Interpreters didn't hear the last sentence.

 8             JUDGE KWON:  Could you repeat your last sentence.

 9             THE WITNESS: [Interpretation] I don't know at all whether these

10     proceedings have been brought to a completion.

11             MR. NICHOLLS:

12        Q.   Thank you.  And now, other than some of the leaders, the - I'll

13     call them - rank-and-file members of these paramilitaries, do you know

14     what happened to them, whether they were tried, sentenced; or whether

15     they ended up returning to regular units?

16        A.   Well, not all members of the paramilitary were arrested on that

17     occasion.  Only their leaders were arrested and their units were

18     disbanded.  Some of the men were expelled back to Serbia, and I remember

19     that there was a list of people who were banned from crossing the border

20     to Republika Srpska.  That's as far as the leaders are concerned.  Among

21     ordinary members that contained and consisted of local people as well,

22     they were returned to regular units.

23        Q.   Thank you.

24             MR. NICHOLLS:  Now, I'd like to quickly bring up 22840 -- or,

25     excuse me, P01478.  And the English, please, as well as the Serbian

Page 17314

 1     transcript.  We can go to page 1 first.  I actually meant the cover --

 2             JUDGE KWON:  So this is Mladic's diary?

 3             MR. NICHOLLS:  Correct, Your Honour.

 4        Q.   Mr. -- we can go, please, straight to page 246 of the English and

 5     244 of the Serbian.

 6             Mr. Witness, this is the handwritten notebook kept by

 7     Ratko Mladic during the period that included June 1992, and I want to

 8     show you some pages from a meeting held in Zvornik on the 30th of June,

 9     1992.

10             MR. NICHOLLS:  And if I could have the -- I think it's easier to

11     use the typed Serbian rather than the handwritten.  There should be

12     two versions in e-court.  And again in the English it should be page 246

13     and one page -- sorry.  English page 246 and in the B/C/S 244.

14        Q.   Witness, while this is coming up, can I ask you if you have been

15     shown this document before?

16        A.   No.  This is the first time that I see this.

17             MR. NICHOLLS:  [Microphone not activated].

18             Back one page in the B/C/S to 243.

19        Q.   All right.  Witness, take a look first -- if you can, you can

20     read along in the version you understand.  I'd like you to look at the

21     people who attended this meeting in Zvornik on the 30th of June in the

22     afternoon.  General Mladic has entitled it:  "Meeting with

23     representatives of Zvornik municipality."  And he lists the people

24     present including himself and President, at that time, Karadzic.

25     Number 3 is the president of the Bratunac municipality, Ljubisav Simic.

Page 17315

 1     Did you know Mr. Simic?

 2        A.   Yes.

 3        Q.   Tell me how you knew him, whether it was a friend, whether it was

 4     through SDS, how -- just to how -- what your relationship was with him?

 5             JUDGE KWON:  Just a second, we are in -- just a second, we are in

 6     public session.  Is it okay?

 7             MR. NICHOLLS:  No, you're correct, Your Honour.  Thank you.

 8     We're probably better to -- I don't know what his answer will be so --

 9             JUDGE KWON:  Yes, we go back to private session.

10                           [Private session]

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23                           [Open session]

24             JUDGE KWON:  Yes, we are in open session, Mr. Nicholls.

25             MR. NICHOLLS:

Page 17316

 1        Q.   And, Witness, do you see as well at the top number 18, that

 2     Marko Pavlovic --

 3        A.   Yes.

 4        Q.   -- and Branko Grujic attended?  I'm just informing -- because you

 5     haven't seen this before, I'm showing you who was there.  Do you see

 6     that?

 7        A.   Yes, I do.

 8        Q.   All right.  Now, most of these persons speak, but I'm going to

 9     concentrate on those mainly from Zvornik.

10             MR. NICHOLLS:  Could we skip ahead two pages to page 249 of the

11     English and two more pages in the B/C/S as well.

12        Q.   And what I want you to concentrate on is what Branko Grujic,

13     listed here as representative of the interim government, reports to the

14     president and to Mladic at this meeting.

15             "We have 32.000 Serbs.

16             "We have successfully implemented the President's decision to

17     settle Divic and Kozluk with our children," it continues on the next

18     page.

19             Now, Divic I think you said is the area where the residents were

20     kept, you heard, in Celopek under terrible conditions?

21        A.   Yes, the majority of Divic residents were there.

22        Q.   All right.  If we continue --

23             MR. NICHOLLS:  We need to go to the next pages, please, in both.

24        Q.   Here Grujic speaks about Marko Pavlovic.

25             "Marko Pavlovic accomplished much until the formation of the

Page 17317

 1     brigade."

 2             And then Mr. Grujic describes problems with the paramilitaries,

 3     Zuca's group, et cetera.  Do you see that?

 4        A.   Yes.

 5        Q.   Okay.  I'm going to show you a couple more entries and then I'll

 6     ask you my question about these comments.

 7             MR. NICHOLLS:  If we could go over to the next page, please.

 8        Q.   Now, here, very simply, we see that the next speaker who

 9     General Mladic is taking notes of is Marko Pavlovic.

10             MR. NICHOLLS:  And can we continue to the next page where we

11     don't need to go through this part of the background he gives.

12        Q.   And here at the top Pavlovic also talks about what happened with

13     the voluntary -- with the volunteer formations.  And he says they:

14             "... enjoyed exceptional success, they were led by Arkan and

15     Seselj.

16             "Arkan's withdrew orderly, but some that stayed broke free of his

17     control."

18             MR. NICHOLLS:  And can we go over to the next page in both.

19        Q.   And here we see Pavlovic giving a briefing of what's happened,

20     the brigade's been formed, the problematic areas of Medjedja and Sapna,

21     entering the village of Kovacevici, where people fled because of

22     cowardice, conflicts, morale is not as good as it should be.  And at the

23     bottom:

24             "We were most active in evicting the Muslims ..."

25             We can go to the next page where it continues.

Page 17318

 1             "We brought peace to Sepak, Divic, and Kozluk.  Some of them

 2     wanted to move out, while we demanded it.

 3             "We had to evict some of the people also for the sake of our

 4     'heros' who fled from Kovacevici."

 5             And now I'll skip ahead to page 258 of the English, please.

 6             And I believe 256 of the B/C/S.

 7             Now, following these reports from the Zvornik head of the

 8     provisional government, the Zvornik TO commander, Mr. Simic, president of

 9     Bratunac municipality, reports.  And he speaks of his municipality and

10     says:

11             "Until 1968 it had a Serbian majority population.  Since then

12     they moved to Serbia.  So according to the last census it was 64:36 in

13     favour of the Muslims.

14             "In Bratunac municipality we now have two Muslims.

15             "We used to have paramilitary formations, today we have a clear

16     situation ..."

17             And then he goes on to other matters.

18             Now, I'd like your comment, Witness, on the way these

19     two municipality leaders and the TO commander from your municipality have

20     lauded and described the removal of the Muslims -- populations and

21     described that as bringing peace at the same time that they're

22     complaining about the actions of the paramilitaries who have broken free

23     from control.  Was that what was in fact going on in Zvornik and

24     Bratunac?

25        A.   Well, I have no comment on this.  I think that an expert of some

Page 17319

 1     sort would be better placed to comment on this than me.

 2        Q.   Well, I ask because you were present, Witness.  We've talked

 3     about the removal of the Muslims from Divic.  We've talked about the

 4     removal of the Muslims from Djulici.  We've talked about the removal of

 5     the Muslims from Kozluk.  This has been reported in a positive light.

 6     Was that -- you were -- you knew these people.  Was that the way it was

 7     considered at that time in Zvornik and, to your knowledge, Bratunac?

 8        A.   Well, let me tell you this, you are equating Divic, Djulici, and

 9     Kozluk, which in my view is like the difference between day and night.

10     Kozluk was evacuated under completely different circumstances as opposed

11     to those in Divic and Djulici.  The war was on and I myself also wasn't

12     very happy about going to work through Djulici where I was stopped once

13     and my weapons were seized from me.  And also, alternatively, the Muslims

14     didn't like having Serbs around when the war is going on.  If you have

15     your family, your children, around you and you feel threatened, there's

16     no other way to act.  I would have liked to have them at least

17     100 kilometres away from me and I think that they had the same wish when

18     it refers to me.

19        Q.   What happened to the mosques in Zvornik after the take-over in

20     early April?

21        A.   This enormous hatred that was increasing over the years ended in

22     the destruction of all churches and mosques in every village virtually.

23     That was one of the effects of the conflict.

24        Q.   All right.  So just does that mean that the mosques in Zvornik

25     were destroyed?

Page 17320

 1        A.   Yes.

 2        Q.   Do you know by whom?

 3        A.   I don't have any information, but they were not destroyed in war

 4     operations.  They were destroyed later when Zvornik became 100 per cent

 5     Serb when there were no Muslims left.

 6        Q.   All right.  July 19 --

 7             MR. NICHOLLS:  Can we go into private session for one moment?

 8             JUDGE KWON:  Yes.

 9                           [Private session]

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 4                           [Open session]

 5             JUDGE KWON:  Yes, now we are in open session.

 6             MR. NICHOLLS:  Thank you.

 7             At the beginning to identify the witness because I used the

 8     statement, which has not been admitted, so I think it would be best just

 9     for the record to now, if Your Honours think it's required, shall I show

10     the pseudonym sheet?  Because the statement has not been admitted which

11     he identified his name on.

12             JUDGE KWON:  Shall we admit the first page, cover page?

13             MR. NICHOLLS:  That's perfectly fine.

14             JUDGE KWON:  Yes, that will be done.  That will be admitted under

15     seal.

16             THE REGISTRAR:  As Exhibit P3158, under seal.

17             JUDGE KWON:  Thank you.

18             MR. NICHOLLS:  That concludes my examination-in-chief.

19             JUDGE KWON:  Very well.

20             We have about 15 more minutes to have a break, but if it is

21     convenient we may take a break now.

22             Yes, Mr. Robinson.

23             MR. ROBINSON:  Yes, thank you, Mr. President.  We need to bring

24     our case manager in also, so if we could do that, that would be good.

25             JUDGE KWON:  Shall we go into private session briefly.  There's

Page 17323

 1     some matter to deal with.

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25                           [Open session]

Page 17324

 1             JUDGE KWON:  And we'll break for 20 minutes and resume at 10.30.

 2                           --- Recess taken at 10.09 a.m.

 3                           --- On resuming at 10.32 a.m.

 4             JUDGE KWON:  Yes, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you, Excellency.  Good

 6     morning, Your Excellencies.

 7                           Cross-examination by Mr. Karadzic:

 8        Q.   [Interpretation] Good morning, Mr. Witness.  Good morning to all.

 9     First of all I would like to thank you, Mr. Witness, for having been so

10     kind as to communicate with the Defence by way of a videolink.  I hope

11     that that will help us be as specific as possible and expeditious as

12     possible.  I have to ask you -- I have to tell you that I asked for a lot

13     more time for cross-examination.  I was given a lot less.  So I'll try to

14     be as specific as possible so I need answers that are as brief as

15     possible, so I kindly ask you to provide answers that are as brief as

16     possible and please let us wait for the interpretation.  You didn't have

17     that problem with Mr. Nicholls but there is going to be a problem with me

18     if we overlap.  Is that all right?

19        A.   Yes.

20        Q.   Thank you.  Is it correct that we had not known each other before

21     you came to this position, and it wasn't as soon as you were appointed

22     but considerably later?

23        A.   Yes.

24        Q.   Is it correct that no one from the SDS headquarters interfered in

25     local personnel lists and that you were a candidate at local level?

Page 17325

 1        A.   Yes.

 2        Q.   During the old communist system, was it customary that certain

 3     positions in government would be allocated to the Serb people and the

 4     Muslim people and the Croat people where the said people were a majority,

 5     for instance, Croats?  And were you in a position that had been allocated

 6     to the Serb people and the party that won the votes of the Serb people

 7     nominates such a candidate?

 8        A.   Yes, reciprocity was always observed.

 9        Q.   Thank you.  Is it correct that the recommendation that the SDS

10     gave to local personnel commissions was that ministries should be given

11     proposals containing the names of two or three individuals, and then the

12     minister would have the freedom to select one particular candidate among

13     them?

14        A.   Yes.  I was on a list that contained three candidates and I was

15     appointed by Minister Alija Delimustafic.

16        Q.   All right.  We're not going to go into any detail.  So it wasn't

17     the SDS that appointed you.  The SDS proposed you as a candidate and the

18     minister appointed you; right?

19        A.   That's right.

20        Q.   Thank you.  Before the war and during this brief period of the

21     war, is it correct that you did not communicate with the SDS but only

22     with your ministry according to the lines involved?

23        A.   Yes.

24        Q.   Thank you.  Is it then also correct that you did not take part in

25     SDS policy-making, not even at local level let alone central level or

Page 17326

 1     higher levels?

 2        A.   Yes.

 3        Q.   Do you agree that many people or some people would try to sound

 4     more important by saying that they were communicating with ministers, the

 5     headquarters of the party, security services in Serbia, and so on; were

 6     there things like that going on, that people would try to represent

 7     themselves falsely?

 8        A.   Yes.

 9        Q.   Thank you.  I would like us to clarify a particular situation in

10     relation to Crisis Staffs.  Do you remember that at the level of the SDS

11     of the Republic of Bosnia-Herzegovina there was an ad hoc Crisis Staff

12     that had been established at the time of the roadblocks on the

13     1st of March?  It was headed by the president of the Executive Board,

14     Rajko Dukic.  Is that the Crisis Staff that you referred to in some of

15     your statements?

16        A.   Yes.

17        Q.   Thank you.  Did you see or come to realise that this Crisis Staff

18     ever functioned after the 3rd of March, after the roadblocks were put up?

19        A.   As far as I know, it did not function.

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24             JUDGE KWON:  Mr. Karadzic, let's go into private session briefly.

25                           [Private session]

Page 17327

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6                           [Open session]

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

 8             THE ACCUSED: [Interpretation] Thank you.

 9             MR. KARADZIC: [Interpretation]

10        Q.   With the permission of the participants, I am going to put

11     something to you, something that you said somewhere; and then if there is

12     any misunderstanding we are going to move into private session so that we

13     can have this sorted out.  Did you testify before to the effect that you

14     were not in charge of communications between yourself and the

15     headquarters of the party?

16        A.   Yes.

17             JUDGE KWON:  Just a second.

18             Yes, Mr. Nicholls.

19             MR. NICHOLLS:  I'm sorry to interrupt, but I would like to get

20     cite references where possible.  I just tell Mr. Karadzic as he moves

21     along in general.

22             JUDGE KWON:  Yes.  We go back to private session briefly.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 17328

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 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                           [Open session]

22             JUDGE KWON:  Yes, Mr. Karadzic.

23             THE ACCUSED: [Interpretation] Thank you.

24             MR. KARADZIC: [Interpretation]

25        Q.   Is it correct, therefore, that neither you nor Mr. Grujic had any

Page 17329

 1     contacts or channels of communication with the central organs?

 2        A.   Yes, that's right.

 3        Q.   Thank you.

 4             THE ACCUSED: [Interpretation] Now yet again can we move into

 5     private session briefly, please?

 6             JUDGE KWON:  Yes.

 7                           [Private session]

 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 17330











11  Page 17330 redacted. Private session.















Page 17331

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7                           [Open session]

 8             JUDGE KWON:  Yes, Mr. Karadzic.

 9             THE ACCUSED: [Interpretation] Thank you.

10             MR. KARADZIC: [Interpretation]

11        Q.   To the best of your knowledge, did Mr. Alic work in Zvornik on

12     linking up active-duty policemen and reserve policemen who were ethnic

13     Muslims in preparation of establishing a Muslim MUP?

14        A.   Yes.

15        Q.   Thank you.  Did this happen months before the outbreak of the war

16     and months before the agreement on the transformation of the MUP into

17     two MUPs?

18        A.   Yes.

19        Q.   Thank you.  I would like to ask you about a crisis that broke out

20     around the 20th of March.  Is it correct that in co-operation -- or

21     actually, that Alic, in co-operation with the chief of the station,

22     carried out a fake police exercise involving the active-duty police and

23     reserve police; and during this fake exercise he captured the arms depot

24     and that that was quite drastic, but a conflict was avoided because the

25     Serb side did not react?

Page 17332

 1        A.   Yes, that's right.

 2        Q.   Thank you.  Is it correct that at the time because of such

 3     actions even two months before the war broke out many Serbs did not dare

 4     sleep in Zvornik; rather, they went to Karakaj or Mali Zvornik across the

 5     Drina River?  Mali Zvornik is in Serbia?

 6        A.   Yes.

 7        Q.   Thank you.  Is it correct that this man, Alic, co-operated with

 8     the well-known Captain Hajro who was an active-duty military man deserted

 9     from the JNA in mid-1991 and worked on the establishment of the

10     Patriotic League in that area?

11        A.   Yes.

12        Q.   Are we talking about Hajrudin Mesic, who after being killed his

13     unit that attacked Zvornik often from Teocak was renamed the

14     Hajrudin Mesic Brigade?

15        A.   Yes.

16        Q.   Thank you.  Was Mr. Alic successful in infiltrating members of

17     the Patriotic League into the MUP reserve force of Bosnia-Herzegovina,

18     that he provided weapons for them, and in such an illegal manner created

19     the core of the future Army of Bosnia-Herzegovina?

20        A.   Yes.

21        Q.   Is it true that in that way the reserve police force was

22     infiltrated by well-known criminals and that they instilled fear in the

23     rest of the policemen?

24        A.   Yes.

25        Q.   Thank you.  In view of the fact that the party, the government,

Page 17333

 1     and all other institutions were either joint, in fact, or were sharing

 2     the same premises, is it true that you had learned that the Muslim side

 3     was involved in the preparation of plans for a possible blowing up of the

 4     Crveni Mulj dam in Zvornik which was actually a hazardous waste from the

 5     Glinica factory and would have contaminated all of the Serbian areas

 6     downstream and it would even harm Serbia in the process?

 7        A.   Yes.

 8        Q.   Do you remember knowing anything about plans to have the

 9     hydroelectric power-plant in Zvornik to be blown up as well as the

10     bridges on the Drina and that those were the plans devised by the

11     Patriotic League well before the outbreak of war?

12        A.   Yes.

13        Q.   Do you remember a crisis involving the dam in Visegrad, which is

14     upstream of Zvornik some 50 or 60 kilometres; is that right?

15        A.   Yes, that was common knowledge because there was live broadcasts

16     on TV of that crisis as it unfolded.

17        Q.   Is it correct that Murat Sabanovic, also another notorious

18     criminal who later became the star of the Army of Bosnia-Herzegovina, had

19     prepared explosive for the purpose of blowing up the dam in Visegrad,

20     that this was broadcast on television, and that Alija Izetbegovic and

21     General Kukanjac communicated with him live on TV, on which occasion

22     Alija Izetbegovic told him, "Don't do it for the time being."

23             Do you remember that?

24        A.   Yes, everybody in Bosnia knows about this case.

25        Q.   Thank you.  Did you understand this as part of the overall plan

Page 17334

 1     of destroying the bridges and dams from Gorazde to Zvornik?

 2        A.   Yes, the idea was to cut us off from Serbia.

 3        Q.   Thank you.  Do you know that - and you mentioned that in

 4     examination-in-chief - that the Muslim side was arming themselves, that

 5     the weapons was brought in a variety of ways from Vienna, Croatia, up to

 6     Bosanski Brod, and that the Patriotic League and the SDA distributed

 7     these weapons either free of charge or through sale?

 8        A.   Yes.

 9        Q.   Were you aware that a certain number of Muslims from Zvornik were

10     volunteers in the Croatian forces during the war between the JNA and

11     Croatia in 1991?

12        A.   Yes.

13        Q.   Thank you.  Do you know that the SDA used to send people who were

14     not policemen to attend certain courses, alleged courses, in Croatia and

15     that quite a few of them were sent from Zvornik to attend these courses

16     in 1991 in Croatia?

17        A.   Yes.

18        Q.   Was there a possibility for such training in Bosnia at the time

19     and was it really necessary -- first of all, was there a proper school

20     for the police officers in Bosnia-Herzegovina?

21        A.   Yes.

22        Q.   Don't you find it a little bit odd for a political party to send

23     people to attend police courses for people who are not members of the

24     police?

25        A.   Yes.

Page 17335

 1        Q.   Is it correct that on the 26th of July, 1991, in the

 2     youth library at Kula Grad, a branch of the Patriotic League was set up?

 3        A.   Yes.

 4        Q.   Does that mean that eight months before the outbreak of war a

 5     unit was formed close to the very centre of Zvornik municipality and that

 6     the Serbs didn't have any problem in finding out about this?

 7        A.   Yes.

 8             JUDGE KWON:  May I ask, Mr. Witness, how did you come to know

 9     that the Patriotic League was set up in 1991 in the youth library at

10     Kula Grad?

11             THE WITNESS: [Interpretation] Look, we had offices, I mean SDA

12     and SDS, it was a big office that was divided by a partition wall.  We

13     listened to each other.  They listened to what we were talking about and

14     we listened to them.  And one of their members later wrote a book about

15     their defence movement in Zvornik and he confirmed these dates in that

16     book.

17             JUDGE KWON:  Thank you.

18             Yes, Mr. Karadzic.

19             THE ACCUSED: [Interpretation] Thank you.

20             MR. KARADZIC: [Interpretation]

21        Q.   Did you obtain a video-tape showing the formation of a branch of

22     the Patriotic League in Godus village, which is your neighbouring village

23     in Zvornik municipality, and is that the unit that you mentioned as being

24     very well equipped which was intimidating in terms of the equipment that

25     they had?

Page 17336

 1        A.   Yes.

 2        Q.   Did you say that this unit was equipped close to standard of the

 3     NATO, did you say that in examination-in-chief?

 4        A.   Yes.

 5        Q.   And that was in October 1991; right?

 6        A.   Yes.  And there is a monument to this date standing at the

 7     location which testifies to this.

 8        Q.   Thank you.  Is it correct that the Patriotic League and their

 9     Main Board issued a directive for the defence of the sovereignty of

10     Bosnia-Herzegovina and instructions to that effect and that the

11     leadership and the political and military staff of the Patriotic League

12     was made up by the highest-ranking officials of the Muslims' part of

13     Bosnia-Herzegovina?

14        A.   Yes.

15             THE ACCUSED: [Interpretation] Just a little patience.  I would

16     like to show a document to the witness that displays and describes the

17     activities and plans of the Patriotic League and the composition of the

18     staff.  We'll get back to this as soon as we find this document.

19             MR. KARADZIC: [Interpretation]

20        Q.   Now, let me ask you this:  Was it crystal clear, not only to

21     officials in the Serbian part of the government but also to ordinary

22     people as well, that right before their eyes a powerful and elaborate

23     network of the Patriotic League was in the process of being developed

24     with units positioned in every village?

25        A.   Yes.

Page 17337

 1        Q.   We are going to show a document about that as well, but let me

 2     ask you this:  How did the Serbian people react to this information and

 3     to these preparations?

 4        A.   In view of the experience from history and since we were a

 5     minority, our reaction was fear.

 6        Q.   Who could have been this assumed, supposed enemy that this

 7     organisation was to target?

 8        A.   As far as the Patriotic League was concerned, the target were the

 9     Serbs.

10        Q.   Thank you.  Do you remember that when the SDA was being founded

11     on the 26th of May, 1990, a high-ranking official of Croatia and the

12     Croatian Democratic Community said that Croatia was going to defend

13     itself on the Drina, and was the Drina the boundary of the

14     Independent State of Croatia during World War II?

15        A.   Yes, I remember him saying that the border was going to be on the

16     Drina, and that made us fearful because that coincided with the

17     Independent State of Croatia, which had been fully supported by the

18     Muslims.  And we fared very badly in that period.

19        Q.   Thank you.  We'll go back to this process of military

20     organisation, but for now let me just establish a few things regarding

21     the paper called or the papers called Variants A and B.  In -- on page 82

22     of yesterday's transcript you spoke about this.

23             Do you agree that in the title it is said how the Serbian people

24     should behave under extraordinary circumstances rather than the SDS?

25        A.   Yes, and that is how we understood it on the Crisis Staff because

Page 17338

 1     the Crisis Staff had members from Ante Markovic's party, from the

 2     League of Communists, et cetera.  So we didn't see this as a partisan

 3     paper, but rather, a paper that would direct the behaviour of the Serbian

 4     people in a difficult situation.

 5        Q.   Thank you.  You mentioned that it did not reach you through

 6     ordinary party mail delivery.  You are an educated man, you know how

 7     documents look like, but let me ask you this:  In your view did this

 8     paper resemble more a kind of a general outline that has to be elaborated

 9     further rather than an adopted document?  Because it didn't have any

10     protocol number on the front page, that the signature says the

11     "Crisis Staff," which was non-existent, and that there was no signature

12     or stamp.  When we speak about regular party documents, did they have a

13     protocol number --

14             THE INTERPRETER:  Can the witness please pause before starting an

15     answer.

16             JUDGE KWON:  Sorry, you started a bit too early.  We didn't have

17     the full translation of the last part of the question.

18             THE ACCUSED: [Interpretation] Do I have to repeat my question?

19             JUDGE KWON:  Yes.  Did they have a protocol number and then --

20     start from there.

21             THE ACCUSED: [Interpretation] Yes.

22             MR. KARADZIC: [Interpretation]

23        Q.   My question is:  Was it customary practice for party papers that

24     are finalised and adopted and accepted has protocol number in its

25     heading, a date, and at the end of it it has a signature and a stamp?

Page 17339

 1        A.   Yes, that was customary procedure.  We had a protocol book in

 2     which we registered such documents.  We a secretary of our party, and we

 3     did not register it as a party paper because it did not arrive through

 4     the usual channels and by following the standard procedure when it

 5     concerned the party mail.

 6             JUDGE KWON:  I wonder whether you answered the question in

 7     relation to whether this paper resembled more a kind of general outline

 8     than an adopted document.

 9             THE ACCUSED: [Interpretation] I think that the best translation

10     would be a draft.  I don't know what the witness says.

11             THE WITNESS: [Interpretation] It is clear that this is not an

12     official document of any kind, judging by its contents, the missing stamp

13     and the protocol number.  So it's not a standard document but rather

14     something else.

15             JUDGE KWON:  Please continue, Mr. Karadzic.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   Is it true that nobody from the party headquarters ever called or

19     sent anyone in order to monitor the implementation of the plan contained

20     in that paper?

21        A.   That's correct.

22        Q.   In your previous statements as well as yesterday in

23     examination-in-chief you confirmed that this paper, in your opinion, was

24     exclusively for defence purposes, that you saw nothing negative in it,

25     and that particularly Variant B was aimed at providing the protection of

Page 17340

 1     people, women, pregnant women, population in general?

 2        A.   Yes.

 3        Q.   Do you agree that at this big meeting attended by 5- to

 4     600 people nobody either discussed or voted on this paper, but that it

 5     was rather distributed as a kind of flyer without any adoption thereof

 6     and discussion?

 7        A.   Yes.

 8        Q.   Thank you.  In view of the wording and the language used by the

 9     Main Staff, the Crisis Staff, and their advocating of support for the

10     JNA, and in view of the wording of that very paper, does it appear to you

11     reasonable that that paper came from well-meaning retired officers, army

12     officers, who recommended that people should conduct themselves in this

13     way if there should be a war?

14        A.   Well, that's one possible variant.

15        Q.   Thank you.  Now I'd like to ask you this:  Do you agree with me

16     that the goal, the objective, of the Muslim side was to subjugate the

17     entire territory of Bosnia-Herzegovina and put them under their own

18     control and that the goal of the Serbian party was actually adapting,

19     beginning from the maximum -- maximalist goal which would have been that

20     Bosnia-Herzegovina should be part of Serbia and that that was not the

21     plan of the Serbian Democratic Party, but that would have been the

22     maximalist option for a portion of the population?

23        A.   Well, yes, that's true.  That was never an option of the Main --

24     of the headquarters of the party.  It was just the wish of some of the

25     individuals.

Page 17341

 1        Q.   Thank you.  Would you agree that it was optimal that the -- what

 2     the Serbian Democratic Party was advocating, which was a Yugoslavia of

 3     six republics, was actually an optimum solution?

 4        A.   Yes.

 5        Q.   Would you agree with me that the next concession of the Serb side

 6     was to try and maintain a Yugoslavia consisting of four republics?

 7        A.   Yes.

 8        Q.   Do you agree that once it became clear that the Muslim and the

 9     Croatian side would proceed with their secession plans, our next

10     objective was to have the Serbian lands within Yugoslavia as one country?

11        A.   Yes.

12        Q.   Maybe you're not aware of it, but this idea actually came from

13     Mr. Izetbegovic.  Did you know that Mr. Izetbegovic proposed to me that

14     the Serb lands should remain within Yugoslavia?

15        A.   Well, only indirectly.  I read it in the papers.

16        Q.   Thank you.  Was our next concession the one where we accepted

17     that Bosnia and Herzegovina could be outside of Yugoslavia, provided that

18     we had our own constituent unit within Bosnia and Herzegovina?

19        A.   Yes.

20        Q.   Do you agree that our basic concern was that we should not be

21     over-voted by a majority, that we should not be made poorer, and was it

22     already your experience before the war - and you mentioned this yesterday

23     when you talked about Zvornik - where the budgets were used and actually

24     taken advantage of at the expense of the Serb people?

25        A.   Yes.

Page 17342

 1        Q.   Would you agree that our concept was that this -- these would not

 2     be borders, but rather, that there would be an administrative

 3     reorganisation of municipalities.  Thus, in Zvornik, for instance, there

 4     would be two municipalities, and Serb lands and Serb parts of the town

 5     and Serb quarters would be a Serb -- would constitute a Serb

 6     municipality, whereas the Muslim areas, Muslim parts of the municipality

 7     would constitute a Muslim municipality?

 8        A.   Yes.

 9        Q.   Were there any negotiations on the way in that respect and would

10     they have been successful had war not broken out?

11        A.   Yes, there were negotiations going on and we even discussed

12     details.  However, when war broke out and -- all of that fell through.

13        Q.   You mentioned yesterday that long before the war a Serb policeman

14     did not dare go on assignment, venture into a Muslim area, if they had an

15     assignment there, and that the same was true of Muslim policemen not

16     daring to venture into Serbian areas.  Was that one of the reasons why

17     the police station had to be transformed?

18        A.   Yes.

19             THE ACCUSED: [Interpretation] Could we now briefly move into

20     private session.

21             JUDGE KWON:  Yes.

22                           [Private session]

23   (redacted)

24   (redacted)

25   (redacted)

Page 17343

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 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                           [Open session]

23             JUDGE KWON:  Yes, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 17344

 1        Q.   Did all this contribute to the establishment of the Serbian

 2     municipality in Zvornik, and is it true that in the beginning this was

 3     just declarative and it was not actually put in place in real life?

 4     There was no official authority in the municipality?

 5        A.   Well, it was only a declaration.  We had no premises, no offices,

 6     nothing of that sort, but this was an attempt to exert political pressure

 7     on the Muslim authorities that were in the majority in order to get some

 8     gains for us.

 9        Q.   Yesterday you mentioned that Zvornik had been up until the 1960s

10     a majority-Serb area, but then there was a change in the ethnic make-up

11     of the municipality.  And we heard today that the similar situation

12     prevailed in Bratunac.  But can you tell us now whether this was the

13     result of a natural birth-rate, increase in the birth-rate, or whether it

14     was affected by settlement, deliberate settlement, of the ethnic groups

15     there?

16        A.   Well, as I've already said, it was a combination of both, natural

17     birth-rate and also a planned migration to the municipalities.

18        Q.   Thank you.  Yesterday you mentioned - and you also stated so

19     earlier in your statements - that a municipality was a state within a

20     state.  Was that an uncommon occurrence or was that in keeping with

21     Tito's doctrine of an armed populace and in keeping with the Law on

22     All People's Defence, where the municipality had a major role to play and

23     the president of the municipality was also the president of the defence

24     council of the municipality?  And were you familiar with this

25     administrative system of the former Yugoslavia and the Law on

Page 17345

 1     All People's Defence?

 2        A.   Well, I did say that it was a state within a state in view of

 3     two facts.  First of all, because it was a territorial principle where

 4     the territory was considered a territory of an armed populace, and also

 5     because we were completely cut off from other Serb areas.  There were no

 6     connections whatsoever between Zvornik and Pale and other areas.  They

 7     were all -- we were practically completely isolated.  We had no

 8     connections with them, and also following the principle of a

 9     self-organised government we organised ourselves.  And as we could see

10     yesterday, we even organised a way of funding our pensioners and finding

11     funds for salaries and pays.

12        Q.   Do you recall that among the documents of the municipal

13     authorities, the provisional municipal authorities, there were also

14     documents, appointments of judges and --

15             THE INTERPRETER:  The interpreter did not understand the second

16     half of the question.

17             MR. KARADZIC: [Interpretation]

18        Q.   So was this the result of the inability to communicate with the

19     centre of the Serbian authorities --

20             JUDGE KWON:  Could you repeat your question, Mr. Karadzic.

21             MR. KARADZIC: [Interpretation]

22        Q.   In the documents adopted by the provisional government and which

23     were published in the bulletin of the Zvornik municipality, there are a

24     number of appointments of judges, which is an eminently state function,

25     which -- because the municipal -- the Assembly was unable to meet was

Page 17346

 1     vested in me up until the end of the summer 1992 and only after the

 2     summer of 1992 it was within the competence of the Assembly.  So is that

 3     what you did in Zvornik municipality, because it was impossible for the

 4     state to appoint judges, that the municipality itself took it upon itself

 5     to do so?

 6        A.   Yes.  I recall that the provisional government in Zvornik

 7     appointed a misdemeanours judge and even a prosecutor for the

 8     municipality.

 9        Q.   Thank you.  And this was only the case up until the end of 1992,

10     but it did not occur later, after that?

11        A.   No.  After that it was done by the Assembly.

12        Q.   Thank you.  Now I would like to dwell a bit on the following.

13     You actually proclaimed a municipality, but it did not become operational

14     until April, what, 5 or 6?

15        A.   Well, yes, that's correct.  We actually broke away from the

16     municipality and then we tried to establish the offices, the police, the

17     various government functions, the police, the judicial functioning, and

18     so on.

19        Q.   Thank you.  You mentioned that in the fax that you received in

20     late March or early April, Momcilo Mandic informed you that the division

21     within the MUP was agreed and the restructuring of the MUP was agreed and

22     he referred to the Cutileiro Plan and the Izetbegovic-Karadzic agreement?

23        A.   Well, yes.  And it was also reported in the regular news that

24     there was an agreement reached in Portugal, and that as a result, the

25     then-minister of the interior, the -- Momcilo Mandic sent this telegram,

Page 17347

 1     where it was agreed that there would be a separation within the MUP and

 2     that there would be a Serbian MUP established but people could also

 3     choose to remain within the Muslim MUP.

 4        Q.   Thank you.  So it was not mandatory.  It was left to the free

 5     will of individuals?

 6        A.   Well, yes.  The principle of voluntary option was stressed.

 7        Q.   Were these negotiations on the transformation of the MUP

 8     conducted in good faith, were they carried out in a positive atmosphere,

 9     and was it envisaged that the equipment would be divvied up and did this

10     happen before the conflict and did it suggest that this would have a

11     positive outcome?

12        A.   Well, I heard this from the first time from Mr. --

13             THE INTERPRETER:  The interpreter did not hear the name.

14             THE WITNESS: [Interpretation] -- and he said then that we would

15     try and follow this.  We would ask people to actually opt for whatever

16     options they preferred.  We agreed on the division of the material assets

17     and everything else, premises, et cetera.

18             JUDGE KWON:  Could you repeat the name of the gentleman -- the

19     man who told that to you?

20             THE WITNESS: [Interpretation] This was Mr. Osman Mustafic, who

21     was the chief of the police station in Zvornik.

22             JUDGE KWON:  Thank you.

23             Yes, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 17348

 1        Q.   Is it correct, then, that in that case the Muslim MUP too would

 2     actually try to maintain law and order in Muslim areas, whereas the Serb

 3     MUP would take care of law and order in the Serb areas?  And did this --

 4     did the situation deteriorate when Muslim paramilitaries arrived in Serb

 5     areas and vice versa?

 6        A.   Well, that was precisely the intention of this whole agreement,

 7     to actually bring some order, to disarm the village guards, because it

 8     was hard to work for the police in view of all the weapons that were

 9     actually were -- had been distributed to both parties, to either side.

10        Q.   Thank you.  The false exercise where there was an attempt to

11     capture the public security station around the 20th of March, which was

12     conducted by Asim Alic, did he also use for this operation the

13     reservists, some of whom had been criminals?

14        A.   Well, yes, he did.  He used reservists and also some other

15     individuals who were not members -- active-duty police members.  And they

16     managed on that day or perhaps a day or two later or earlier to take

17     control of the police station.

18        Q.   Now I would like to shed some light on an incident where a number

19     of extremists, criminals, were issued uniforms and long-barrelled weapons

20     and they actually conducted patrols across the bridges before the war.

21     Now, how did this arming of criminals -- what kind of effect did it have

22     on Serbs?

23        A.   Well, sometime before the war the reserve force which was

24     actually strengthened by accepting new members and they did not -- they

25     even accepted some criminals who had been convicted convicts, convicted

Page 17349

 1     of serious crimes including murder and so on, and when they were issued

 2     uniforms and long-barrelled weapons and automatic weapons and when this

 3     became something -- a well-known fact among the citizens in Zvornik,

 4     where Zvornik was practically an ethnically cleansed town of Serbs, there

 5     were only Muslims there, there was only one street where Serbs lived,

 6     well, that had a very negative effect.  In the meantime, all of these

 7     policemen had also broken into their apartments and taken away their

 8     properties and their items from the apartments, and this only increased

 9     the tensions in Zvornik.

10        Q.   And that happened before the outbreak of the conflict; right?

11        A.   Yes, a few days before the conflict broke out.

12        Q.   So you confirmed during the examination-in-chief that for all of

13     two months many Serbs would not spend the night in Zvornik.  Just before

14     the conflict broke out, all the Serbs, practically all the Serbs, went

15     out either to Karakaj or to Serbia.  Was that some kind of propaganda on

16     our part or was this spontaneous?  Could anybody have talked the Serbs

17     into doing that or were they persuaded to do so by fear, authentic fear?

18        A.   In this case, it was fear for life and children and families.

19        Q.   Thank you.  You did not get part of the station when the split

20     took place, you had to move elsewhere?

21        A.   Yes --

22             THE INTERPRETER:  The interpreter did not hear the rest of the

23     witness's answer.

24             THE WITNESS: [Interpretation] We only took our personal weapons

25     and then we took two or three cars.  And all the rest, including

Page 17350

 1     telecommunications equipment and most importantly the weapons that were

 2     there, 400 long-barrelled weapons I think, the Muslims kept all of that,

 3     along with accompanying equipment, such as ammunition and so on.

 4             JUDGE KWON:  Mr. Witness, the interpreters didn't catch the first

 5     part of your answer, before you say:  "We only took our personal

 6     weapons ..."

 7             Could you repeat the first part of your answer, please.

 8             THE WITNESS: [Interpretation] Yes, this was the essence.  We just

 9     took our personal weapons.  We managed to get only the telecommunications

10     equipment that we had on ourselves and we managed to get two or

11     three cars.  And what was the most important thing was the arms depot and

12     they kept that.

13             JUDGE KWON:  Please bear in mind, too, that it is important to

14     put a pause between the question and answer.  Thank you.

15             Yes, Mr. Karadzic.

16             THE WITNESS: [Interpretation] Yes, I do apologise.

17             THE ACCUSED: [Interpretation] Thank you.

18             MR. KARADZIC: [Interpretation]

19        Q.   Do you remember that the Muslim-Croat Rump Presidency, against

20     the will of Mrs. Plavsic and Professor Koljevic and Professor Plavsic, on

21     the 4th of April, on the day of Ramadan, the end of the Ramadan fast,

22     declared general mobilisation of the Territorial Defence and the reserve

23     police in Bosnia-Herzegovina?

24        A.   Yes.

25        Q.   How could that have been understood?  Who was the enemy apparent?

Page 17351

 1     The JNA had not been declared the enemy yet, so were we, the Bosnian

 2     Serbs, the only presumed enemy left?

 3        A.   Yes.

 4        Q.   Thank you.  Is it correct that Branko Grujic on the 5th of April

 5     declared a test mobilisation and on the 8th of April a true mobilisation

 6     in the Serb municipality of Zvornik?

 7        A.   Yes.

 8        Q.   Was this preceded by a declaration of general mobilisation

 9     throughout Bosnia and also was it preceded by the killing of NCOs and

10     soldiers in Sapna?

11        A.   Yes.  Grujic's move was just a response, the only possible one,

12     to the mobilisation that they carried out.

13        Q.   Tell us, please, yesterday you said that at party level there was

14     some kind of enhanced duty service on the part of the SDA and the SDS and

15     the party Crisis Staff could only send reports and did not have any

16     authority to act; is that right?

17        A.   Yes.

18        Q.   Is it correct that only in the beginning of April, when this

19     conflict broke out, a municipal Crisis Staff was established as a

20     substitute for proper municipal government?

21        A.   Yes.

22        Q.   Yesterday you said that you left the Crisis Staff because you

23     were disappointed because you had not been elected to a particular

24     position that you had held.  Was this an automatic thing after all, and

25     during those few days were you on the Crisis Staff ex officio not by way

Page 17352

 1     of some kind of election or not as a consequence of your own choice or a

 2     choice having been made by somebody else?  If you need to move into

 3     private session for this, tell us.

 4        A.   No, it was ex officio, ex officio I was a member of the

 5     Crisis Staff because I held that particular position.  When I no longer

 6     held that particular position, I was no longer a member of the

 7     Crisis Staff.

 8        Q.   Thank you.  This is what I'm interested in now:  Let us identify

 9     what the initial positions of the Serb organs of government were in

10     Zvornik, and we are going to see whether that was in line with the

11     political positions of Serbs in Bosnia as a whole.  You mentioned that

12     the Serb side wanted to have a renowned cardiologist, a Muslim,

13     Dr. Muhamed Jelkic, stay on as a member of the Serb Crisis Staff and in a

14     way he was a member of the Muslim Crisis Staff; is that right?

15        A.   Well, what I said yesterday was that -- I mean, well, it was the

16     wish of the Serb Crisis Staff that Muhamed Jelkic be a kind of link

17     between the Serb and Muslim Crisis Staffs.

18        Q.   So was that in accordance with your view that there should be an

19     accommodation of views in order to reach agreement?

20        A.   Yes.

21        Q.   You were asked about the position of the Muslims after the crisis

22     broke out.  Is it correct that both in the police and in other organs and

23     in various companies including your own, there were Muslims and those who

24     worked received a salary as well?

25        A.   Yes, at the very beginning of the war.

Page 17353

 1        Q.   Do you remember that some lady by the name of Mirsada was

 2     appointed on the 1st of May to the Executive Board, or rather, the

 3     management board of Vitinka and that she's a Muslim too?

 4        A.   Yes, yes, I remember that.

 5             THE ACCUSED: [Interpretation] 1D4035, could we have a look at

 6     that, please.  Unfortunately, we have no translation.  I kindly ask for

 7     your understanding because this is viva voce after all and we have to

 8     find our way as we move along.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Is this a regular thing or actually is this a conclusion?  It is

11     the 21st of May and there is a number there and everything.  Is this a

12     conclusion stating that a provisional management board should be

13     appointed for the company of Vitinka, the chairman of the board is

14     Radenko Ristic, and members are Ljubo Jovic and Mirsada Mutapcic?

15        A.   Yes.

16        Q.   Thank you.

17             THE ACCUSED: [Interpretation] Can this be marked for

18     identification.

19             JUDGE KWON:  Yes, Mr. Nicholls.

20             MR. NICHOLLS:  Just what is this exactly?  Could I just know what

21     the title is?  I don't have a --

22             JUDGE KWON:  So, Mr. Witness, do you know this rather than being

23     unannounced of this document?

24             THE WITNESS: [Interpretation] This is an appointment of the

25     provisional management board of the company of Vitinka.

Page 17354

 1             JUDGE KWON:  Yes, you can read it, but are -- whether you are in

 2     a position to testify to this document.

 3             THE WITNESS: [Interpretation] I have to admit that this is the

 4     first time that I see it as a document.  Just like yesterday, I don't

 5     know what to say by way of comment.  I can only read it, but -- actually,

 6     it's the first time I see the document, but I know that Ms. Mirsada was

 7     one of the top people in Vitinka.  However, this is the first time that I

 8     see this document.

 9             MR. KARADZIC: [Interpretation]

10        Q.   May I ask this:  Do you know that there was no discrimination

11     against Muslims at that time?  This is May 1992.  Is that in accordance

12     with what happened where you were, people worked, received their

13     salaries, and were also appointed to high management positions, although

14     it was dangerous and difficult and unpleasant, but they were being

15     appointed nevertheless?

16        A.   Yes.

17             JUDGE KWON:  Yes, his evidence -- his answer will remain, but I

18     don't see the point of admitting this document through this witness.

19             THE ACCUSED: [Interpretation] Thank you.

20             Can we now have 1D30 -- actually, 4034.

21             MR. KARADZIC: [Interpretation]

22        Q.   During the examination-in-chief you spoke about attempts to reach

23     agreement and you talked about negotiations too.  Did Mr. Izet Mehinagic

24     take part in these negotiations?

25        A.   Yes.

Page 17355

 1             THE ACCUSED: [Interpretation] Can we please zoom in.  We have a

 2     translation too.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Can we have a look at this telegram.  Is it correct that

 5     Mr. Izet Mehinagic is sending a telegram to General Savo Jankovic,

 6     commander of the Tuzla Corps of the JNA, and it is being CC'd to General

 7     Kukanjac?  And I think we're going to see the date now.

 8             THE ACCUSED: [Interpretation] Can we see the bottom of this page,

 9     I think the date is the 5th -- no, it's the 8th, the 8th of April.

10             MR. KARADZIC: [Interpretation]

11        Q.   Can you tell us now -- I mean, we can all read it.  Can you tell

12     us what it says here, that Arkan was the main negotiator on the Serb

13     side, that the Serb representatives were beaten up.  Does this telegram

14     confirm everything that you had described as a break in these

15     negotiations?

16        A.   Yes.

17        Q.   It also says that an offer was made to Zvornik to lay down their

18     weapons and that the Crisis Staff of Zvornik decided on the ultimatum at

19     1600 hours and that his assessment was that the ultimatum would not be

20     accepted and that there would be an unprecedented massacre of the

21     unprotected innocent population.  Is it correct that the Muslim part of

22     the staff did not accept the terms for laying down weapons?

23        A.   Yes.

24        Q.   Do you agree that Mr. Mehinagic says down here that Zvornik is a

25     Yugoslav town and that the population is supposed to improve its attitude

Page 17356

 1     towards its own JNA and he says here this is only three days after the

 2     ambush and killing in Sapna; right?

 3        A.   Yes.

 4             THE ACCUSED: [Interpretation] Can we go further down to see what

 5     the handwritten note is.  No, actually, can we go up.  Can we go up --

 6     can we see the bottom -- or rather, the top of the page.  We have it in

 7     English too actually.

 8             JUDGE KWON:  Yes, we do.

 9             MR. KARADZIC: [Interpretation]

10        Q.   It says:

11             "Colleagues please forward this telegram urgently, as urgently as

12     possible ..."

13             Oh, yes, that's typewritten.  And it's handwritten that

14     General Jankovic should be informed to take measures to protect --

15        A.   Citizens in Zvornik.

16        Q.   Citizens in Zvornik and somebody from the command of the

17     2nd Military District signed this.  You don't know whose signature this

18     is?

19        A.   It says so up here, Colonel Kecman.

20        Q.   Colonel what?

21        A.   Colonel Kecman.

22        Q.   Uh-huh.  Is it Kosovac maybe?

23        A.   Possibly, but it's a colonel.

24        Q.   We can barely see.  It may be Keserovic, but this is the essence,

25     isn't it?

Page 17357

 1        A.   Yes.

 2        Q.   Thank you.  Do you know that this General Jankovic was forced to

 3     ask already on the 10th of April that action be taken against Kula Grad

 4     because they were firing at JNA soldiers on the right side, those who

 5     were guarding --

 6        A.   The hydroelectric power-plant.

 7        Q.   And the bridges too.

 8             THE ACCUSED: [Interpretation] We're going to call this up now,

 9     but can this telegram be admitted?

10             JUDGE KWON:  Yes.

11             THE REGISTRAR:  Exhibit D1605, Your Honours.

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

13     65 ter 00642 now.

14             THE WITNESS: [Interpretation] May I just add something?

15             MR. KARADZIC: [Interpretation]

16        Q.   By all means.

17        A.   I don't know if you noticed, but what we discussed, that dam, you

18     see this terrible ecological catastrophe that is being envisaged in this

19     letter because of these extremists or because of what they might do --

20        Q.   Muslim extremists?

21        A.   Yes.

22        Q.   Thank you.  That's also in accordance with your knowledge

23     concerning plans to blow up dams; right?

24        A.   Crveni Mulj, yes.

25        Q.   Please take a look at this document dated the 10th of April.

Page 17358

 1     General Jankovic who did not like the SDS at all; right?

 2        A.   Yes, Savo Jankovic was a real communist.

 3        Q.   Do you see that he is asking that on the 10th that on the 11th

 4     action be taken against Kula Grad, and he says:

 5             "We are demanding action in order to neutralise the forces

 6     attacking our units which are defending the bridges on the Drina River."

 7        A.   Yes.  I know that they did open fire.

 8        Q.   Thank you.  We have a Croatian intercept because they were

 9     listening in to our conversations, and it says that the local authorities

10     did not allow Arkan to liberate Kula Grad and that as a result he

11     demonstratively left Zvornik.  Do you know anything about that?

12        A.   Generally Arkan was ready to go and liberate Kula Grad

13     immediately but he only had about 20 men.

14        Q.   Thank you.  Had they not fired from Kula Grad, would it have been

15     ever liberated?

16        A.   I don't think so because that area is a purely Muslim populated

17     part.  However, it was impossible to live in Zvornik because it was

18     exposed to constant fire coming from that direction.

19             THE ACCUSED: [Interpretation] Can this document be admitted.

20             JUDGE KWON:  Yes.

21             THE REGISTRAR:  Exhibit D1606, Your Honours.

22             MR. KARADZIC: [Interpretation]

23        Q.   You took a position that self restraint by the Serbs with regard

24     to Asim Alic's and his criminals' action in taking over the public

25     security station was the one that prevented bloodshed.  Is that your

Page 17359

 1     view?

 2        A.   Yes.

 3        Q.   So a Crisis Staff was formed and it existed for a short period of

 4     time; is that right?

 5        A.   Yes.

 6        Q.   It was made up of personalities that were otherwise involved in

 7     some sort of government organs, and that was the basis on which they

 8     became members of the Crisis Staff not according to their political

 9     functions?

10        A.   Yes, I mentioned the president of the court, the misdemeanour

11     judge, and other Serbs who held offices as a result of the elections.

12        Q.   Is it correct - and if necessary, we may go into private

13     session - is it correct that you stated that you had never attended a

14     single meeting where there was any mention at all, let alone any debate,

15     about burning houses and forcing people to leave their homes?  We also

16     mentioned mosques.  Was it the government authorities that burned the

17     mosques, did they encourage that, and did they know who did it overnight?

18        (redacted) there was no debate

19     about the destruction of any religious facility, about any burning of

20     houses or dislocation of people.

21        Q.   You also spoke earlier about the fact that you never attended a

22     meeting where any mention was made of the need to kill the Muslims or to

23     attack or cleanse the Muslim villages; is that correct?

24        A.   I can say for certain --

25             JUDGE KWON:  Before you answer.

Page 17360

 1             Yes, Mr. Nicholls.

 2             MR. NICHOLLS:  I think we need a redaction, 62, 3.

 3             JUDGE KWON:  Thank you.

 4             THE ACCUSED: [Interpretation] Can we go briefly into private

 5     session.  I will state a reference and give my comment.

 6             JUDGE KWON:  Yes.

 7                           [Private session]

 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 17361

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             JUDGE KWON:  Yes, Mr. Karadzic.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC: [Interpretation]

12        Q.   Do you still subscribe to the view that the JNA with time became

13     predominantly Serb, among other things, due to the fact that the Muslims

14     did not want to respond to call-ups to carry out their mandatory military

15     service or to answer the call-up to join the reserve forces?

16        A.   Yes.

17        Q.   On the 4th or the 5th - and you mentioned that in

18     examination-in-chief - a non-commissioned officer was killed and a number

19     of soldiers were captured in Sapna.  Was this unit advancing in a combat

20     disposition or was it just moving towards Yugoslavia on the retreat from

21     the Tuzla region?

22        A.   They were just passing through Sapna, they were carrying out

23     their regular task, and they were just marching through.

24        Q.   Thank you.  I think that you mentioned that Semsudin Memovic

25     [phoen] or Muminovic, a career officer who commanded some 17- or 18.000

Page 17362

 1     men, a JNA unit made up of that number of men, deserted only on the 3rd

 2     of April and joined Hajrudin Mesic and the other deserters who had

 3     deserted much earlier, i.e., in mid-1991, and he took part in forming the

 4     units; is that correct?

 5        A.   Yes, it is.

 6        Q.   What was the effect on the Serbs of the killing of this peaceful

 7     JNA column passing through Sapna without any combat deployment?

 8        A.   Well, that triggered the action and this was the last straw which

 9     was conducive to any failure to control the situation.  All of the

10     refusal by the Muslims to respond to call-up, the recognition of Bosnia

11     and Herzegovina, the division of police stations, but this triggered

12     actually -- this incident triggered the conflict.

13             JUDGE KWON:  Mr. Karadzic, if it is convenient, we will take a

14     break now for half an hour and resume at 12.30.

15                           --- Recess taken at 12.01 p.m.

16                           --- On resuming at 12.33 p.m.

17             JUDGE KWON:  Yes, Mr. Karadzic.

18             THE ACCUSED:  Thank you, Excellency.

19             MR. KARADZIC: [Interpretation]

20        Q.   Let us dwell on these negotiations, Mr. Witness, for some time

21     longer.  Your view was, and you said that there was a video-tape, and you

22     said that you wanted to reach an agreement with the Muslims to avoid

23     anyone making any foolish move and that you wanted to await a solution

24     for the entire Bosnia and Herzegovina.  Was that position of the local

25     leadership consistent with the position of the Serbian people in its

Page 17363

 1     entirety?

 2        A.   Yes.

 3             THE ACCUSED: [Interpretation] Can we now look at how these

 4     negotiations were terminated and can we see 65 ter 40011.  This is a

 5     transcript of a video interview given by Mr. Zeljko Raznatovic, Arkan, in

 6     which he describes the events and it more or less coincides with your

 7     description.  So 65 ter 40011.

 8             JUDGE KWON:  I have been advised that it hasn't been released

 9     yet.

10             THE ACCUSED: [Interpretation] We perhaps can leave it for later

11     or for tomorrow, but I think it has been released.

12             MR. NICHOLLS:  I'm informed by Mr. Reid that it will take a

13     few minutes for us to do whatever needs to be done with that.  If there's

14     another question that can be asked.

15             JUDGE KWON:  Yes.  Thank you, Mr. Nicholls.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   Mr. Witness, apart from the Patriotic League, is it true to say

19     that the Muslims had other notorious paramilitary groups in Zvornik, such

20     as Dzamija Pigeons, Cobras, Black Swans, et cetera?

21        A.   Yes.

22        Q.   Were you acquainted with the leaderships of these paramilitary

23     groups?  Did people know them?

24        A.   Yes.

25             THE ACCUSED: [Interpretation] Can we now have a look at 1D40011

Page 17364

 1     [as interpreted].  1D4011, it's IIIA annex to report 674 of the

 2     Secretary-General from 1994.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Now, please look at this, this is annex III.A, S1994/674.  S

 5     stands for report of the Secretary-General.

 6             Can we now look at page 11 of this document.

 7             Can you see here that it reads the Muslims and Croats -- the

 8     Mosque Doves and Pigeons in Zvornik and the United Nations are citing the

 9     sources from which they acquired this information and it says that they

10     were using rifles from Hungary and Arabic countries.  Both you and the

11     rest of the people were aware of that?

12        A.   Yes, we were.

13        Q.   There are other municipalities mentioned as well.  This is a very

14     useful document that we are going to refer to quite often at a later

15     stage.

16             THE ACCUSED: [Interpretation] Can this be admitted into evidence.

17             JUDGE KWON:  You said this is a report of the Secretary-General?

18             THE ACCUSED: [Interpretation] This marking S1994/674,

19     annex III.A, usually indicates an official document of the

20     United Nations, or rather, the ones produced by the Secretary-General.

21     We can look at the heading of the document if necessary.

22             JUDGE KWON:  The first page of this document says its source is

23     "Submission of Permanent Mission of the Federal Republic of Yugoslavia to

24     the Commission of Experts."  So probably --

25             THE ACCUSED: [Interpretation] Your Excellency, I couldn't find

Page 17365

 1     this, but I see that it was circulated as an official UN document.

 2             JUDGE KWON:  Yes, probably, as you report, annexed this document.

 3             Mr. Nicholls.

 4             MR. NICHOLLS:  I'm not sure, Your Honours.  I can't see the front

 5     page other than what --

 6             JUDGE KWON:  Why don't we upload the first page of this document,

 7     the bottom part.  No, no, the up -- sources, yes, there.  But you should

 8     have entire document of this document.

 9             THE ACCUSED: [Interpretation] I believe it is a rather lengthy

10     document.  This is only a reference to the other identified groups,

11     whereas there is also information on other paramilitary groups as well.

12     If you don't mind, I would like to tender it.  There are sources

13     mentioned here, but this is a UN document.

14             JUDGE KWON:  Very well.

15             MR. NICHOLLS:  Just that, Your Honour, the sources as far as I

16     can see are a report titled "A New Genocide Against Serbs in Konjic Area"

17     by the Association of Serbs from BiH, a letter, and Tanjug news sources.

18     So I'll leave it with the Chamber.

19             JUDGE KWON:  Very well.  Separate from the issue of weight, how

20     much weight it should be given, but I don't think there's any issue as to

21     its authenticity.  So as such, we can admit it.  We'll give the number.

22             THE REGISTRAR:  Exhibit D1607, Your Honours.

23             THE ACCUSED: [Interpretation] If I may add, there is also a

24     letter of the Croatian representative mentioned as a source.

25             MR. KARADZIC: [Interpretation]

Page 17366

 1        Q.   Now, Witness, sir, was there also a group called the Cobras

 2     which, unlike the Mosque Doves which were in Konjic, were in Sapna or

 3     somewhere else?  Was there a group named -- called the Cobras?

 4        A.   Yes.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] Could we now see 1D3406.

 7             THE INTERPRETER:  Interpreter's correction:  4036.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Unfortunately we don't have a translation of this document.  This

10     is a document from the Croatian SIS, which is the Security and

11     Information Service of the Bosnian Croats from 1996, an official note.

12     If you take a look at this there is mention here of special-purpose units

13     called the Black Swans.  Did you know of the Black Swans?

14        A.   Yes.

15        Q.   Would you please now read the official date.  I believe that's

16     the seventh line from the bottom, the official date when this group was

17     established and so on.

18        A.   The official date when this unit was established was the

19     31st of March, 1992.  On that day on orders from Vahid Karavelic and the

20     said Captain Labud, Hase Tiric, the current commander of the Black Swans,

21     together with another 15 members of the Patriotic League went to

22     Bijeljina with a task of establishing a special-purpose unit, and

23     allegedly, at the time they engaged VRS in -- with the intention of

24     taking control of Bijeljina.

25        Q.   Thank you.  Now could I just remind you that on the

Page 17367

 1     31st of March, 1992, the VRS was not in existence as yet.  Would you

 2     agree?

 3        A.   Yes.

 4        Q.   Do you agree that Arkan arrived in Bijeljina on the 1st of April,

 5     some 10 or so hours after the crisis erupted in Bijeljina, that's a

 6     generally known fact?

 7        A.   Yes.

 8        Q.   From this document from Croatian sources, can we clearly see that

 9     Vahid Karavelic sent Captain Labud and this other person, Hase Tiric and

10     some other 15 members from the Patriotic League on the 31st of March to

11     Bijeljina and that they provoked the crisis, and Arkan only arrived after

12     the crisis erupted?

13        A.   Well, it's a well-known fact that Bijeljina was first taken over

14     by Muslims and that only later it was taken over by the Serbs.

15        Q.   Thank you.

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

17     document.

18             JUDGE KWON:  Having heard the witness's answer, do we need to

19     admit this document?

20             THE ACCUSED: [Interpretation] Well, I believe it could assist the

21     Trial Chamber with the context, and this is to show how the Croatian side

22     had information that this unit was established on the 31st and that

23     15 men had been sent to Bijeljina on the 31st.  We saw here -- we heard

24     evidence that the crisis in Bijeljina erupted on the 31st of March, in

25     the evening, and that it actually flared up on the next day, on the

Page 17368

 1     1st of April, after Arkan arrived.

 2             JUDGE KWON:  Mr. Nicholls.

 3             MR. NICHOLLS:  I'm just trying to see again what the date of this

 4     document is which I can't see on the screen.

 5             THE ACCUSED: [Interpretation] At the top of the page we see the

 6     date, the 9th of May, 1996.

 7             MR. NICHOLLS:  I think, Your Honours, that with the answers

 8     given, I don't see this document from that much time later assisting,

 9     but ...

10             JUDGE KWON:  And given the position that the witness would not be

11     in a position to comment on this document himself.  I will consult my

12     colleagues.

13                           [Trial Chamber confers]

14             JUDGE KWON:  We'll mark it for identification.

15             THE REGISTRAR:  As MFI D1608, Your Honours.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   Do you agree, Witness, that all these units from the

19     Patriotic League, then the Territorial Defence, the Green Berets, the

20     Cobras, the Mosque Doves and so on, later became part of the BH army,

21     although some of them still retained their old names?

22        A.   Yes.

23             THE ACCUSED: [Interpretation] Can we now take a look at 1D4037,

24     please.  We don't have a translation of this document either,

25     unfortunately, but I will make an introduction.  This is from Bosnia and

Page 17369

 1     Herzegovina, a document compiled on the 25th of August, 1997.  The

 2     ministry of -- the Croatian Defence Council, and it says additional

 3     information on the engagement of Dzemal Merdan, and so on and so forth.

 4             Could we see the next page, please.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   I would like to refer you to the bottom of the second paragraph:

 7     "In early 1991 ..."

 8             Could you please read out that sentence.

 9        A.   "In early 1991, in those towns where Muslims had an absolute

10     majority, small armed units local in character were established.

11             "As they were not linked up in their operations, the leadership

12     of the SDA in the course of March 1991 entrusted a number of its members,

13     Munib Bisic; the current brigadier general of the BH army, the chief of

14     the military mission of the BH federation, Hasan Cengic; Hasan Efendic,

15     and so on, that they out of the officer corps of the then-JNA, or rather,

16     of the Muslim -- of members of the Muslim ethnicity who had left JNA

17     units or intend to leave them, should form the corps which would take

18     care of military issues.

19             "A headquarters which was established in August was made up of

20     Sulejman Vranj, Rifat Bilajac, Meho Karisik, Sefer Halilovic,

21     Atif Saronjic, Mustafa Hajrulahovic, Feid Heco, Dervo Harbinja,

22     Salko Polimac, Alija Loncaric, Hajrudin Suman, Zijo Rasidagic,

23     Zaim Backovic, Kerim Lucarevic, and Hasan Cengic.  The commander of the

24     staff was Meho Karisik, the current BA general -- BH Army general."

25        Q.   So this is in March 1991; correct?

Page 17370

 1        A.   Yes.

 2        Q.   The information that the Croats had on Bosnia, was it something

 3     that was known by us as well?

 4        A.   Yes.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] I'd like to tender this document.

 7             JUDGE KWON:  Mr. Witness, do you know what this document is

 8     about?  It's dated 1997, isn't it?

 9             THE WITNESS: [Interpretation] Well, I -- this is a -- what I said

10     was that I knew about the leadership and the leaders they appointed.  I

11     don't know anything about the document itself, but I know these persons.

12             MR. NICHOLLS:  Could we go -- sorry, Your Honour, could we go

13     into private session for one moment.

14             JUDGE KWON:  Yes, we go into private session.

15                           [Private session]

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 17371











11  Pages 17371-17372 redacted. Private session.















Page 17373

 1   (redacted)

 2                           [Open session]

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

 4             JUDGE KWON:  Yes, Mr. Karadzic.

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

 6     65 ter 40011, please.

 7             MR. NICHOLLS:  Mr. Reid tells me that 4011A may be the correct

 8     document.

 9             JUDGE KWON:  4111A?

10             MR. NICHOLLS:  40011A.

11             JUDGE KWON:  Thank you.

12             THE ACCUSED: [Interpretation] This is a transcript of a TV

13     interview.  Here it says the president -- or in other words, he is being

14     interviewed in his capacity as the president of the Party of Serb Unity.

15             MR. KARADZIC: [Interpretation]

16        Q.   Now, while we wait for this to come up, sir, let me ask you this:

17     Do you know that this party and Arkan himself were investigated by OSCE

18     and that he was permitted to take part in the elections in Bosnia and

19     Herzegovina in 1996?

20        A.   Well, yes, I am aware of the participation of this party in the

21     election in 1996.

22        Q.   And his -- he received some funds from the OSCE for that purpose?

23        A.   Well, yes, as every other party, his party too received some

24     funds for the elections.

25        Q.   And his group of some 15 or so members of parliament entered the

Page 17374

 1     parliament, right, his party?

 2        A.   Well, yes, he also had his assemblymen in the Serbian parliament.

 3             THE ACCUSED: [Interpretation] Well, this is not the document that

 4     I had in mind.  The English version is ET V000-1946.  [In English] And

 5     again, 1946.  Transcript, English translation V000-1946.

 6             JUDGE KWON:  This bears the same number.

 7             Go up.

 8             THE ACCUSED:  But I have it completely different graphically.  It

 9     is with numbers --

10             JUDGE KWON:  Do you have the time-frame for that?

11             THE ACCUSED:  620.  00.00.00-00.06.20.

12             [Interpretation] 1430, so we should go back to 620.

13             MR. NICHOLLS:  It will take a couple minutes.

14             JUDGE KWON:  Thank you.  Yes.

15             THE ACCUSED: [Interpretation] All right, then I'll deal with

16     something else.

17             JUDGE KWON:  Do we not have the video itself?

18             THE ACCUSED: [Interpretation] We haven't prepared it.  We thought

19     this was faster.

20             JUDGE KWON:  If you have some other question, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Yes, yes, by all means, I'll deal

22     with something else.

23             MR. KARADZIC: [Interpretation]

24        Q.   Mr. Witness, you said here that after this arming took place and

25     organisation of the Patriotic League in Kula already in July 1991, you

Page 17375

 1     said that the Serb side was in a situation to ask for something as well,

 2     and you described going to Radmilo Bogdanovic.  When was that, what

 3     month?

 4        A.   The beginning of 1992.

 5        Q.   So for at least six months you hadn't done anything in that

 6     respect; right?

 7        A.   Well, I said yesterday that Grujic did something very minor

 8     before that, say in November 1991.

 9             THE ACCUSED: [Interpretation] Could we now please look at one

10     intercept where somebody is calling me from Zvornik, and that is

11     65 ter 31757.  Please have the English version as well.  Yes, right.

12             MR. KARADZIC: [Interpretation]

13        Q.   This is the end of August 1991.  Do you remember that until the

14     end of August 1991 there was hope that the historic Serb-Muslim agreement

15     would be reinforced, the one that Zulfikarpasic and I worked on with the

16     initial support of Izetbegovic?

17        A.   Yes.

18        Q.   Do you remember that at the end of July we were in Zvornik - let

19     us not mention the position you had then in Zvornik - and do you remember

20     that we had this big rally of Serbs and Muslims at the end of July 1991,

21     Mr. Zulfikarpasic and I, and that the hall was chock-a-block full of

22     Serbs and Muslims?

23        A.   Yes, I remember that.

24        Q.   Do you remember that Izetbegovic purportedly still supported that

25     document, but there was this group of SDA extremists that was shouting

Page 17376

 1     against the agreement and against Zulfikarpasic?

 2        A.   Yes.

 3        Q.   Do you remember that already then things were getting out of

 4     control and that although there was police protection for the safety of

 5     Mr. Zulfikarpasic, we did not dare go to have dinner at Vidikovac, so we

 6     got out through Karakaj, Caparde, Sekovici, Serb-held areas, to Sarajevo?

 7        A.   Yes, I remember that.

 8        Q.   Do you remember that towards the end of August Mr. Izetbegovic

 9     withdrew his agreement to that agreement?

10        A.   Yes.

11        Q.   So please let us have a look at this.  Somebody is asking to

12     speak to me, some Bogicevic from Zvornik.

13             Can we now have the next page, please.

14             I either was not there or I could not answer the phone.  And

15     finally when I hear what that was all about, I do answer the phone.  So

16     he is saying that some weapons are being distributed, and this is the

17     first time that Karadzic shows up here.  Do you see here towards the top

18     of the Serbian page it says:

19             "Zulfikarpasic and Karadzic were here in Zvornik and they had

20     problems and I don't know what, TV Belgrade," and so on and so forth.

21             Is he speaking about these problems with these SDA extremists?

22        A.   Yes.

23        Q.   Yes, it's around the middle in the English version.  Let me just

24     have a look at this for a moment, please.  He says -- right.  He says

25     that some weapons are being distributed and this secretary of mine is

Page 17377

 1     probably saying:  "Who distributed it, Karadzic?"

 2             And Bogicevic says:

 3             "No, not Karadzic."

 4             And this man says:

 5             "Then who was it?"

 6             And he says:

 7             "Brane Grujic distributed it."

 8             And then:  "Ah-ha," Bogicevic says, "SDS Zvornik president."

 9             And this other one says:

10             "Listen, I cannot believe that."

11             And can we have the next page now, please.

12             Obviously the situation was such that I had to answer the phone

13     and you see that I did answer the phone.  Isn't that right?

14             Now he's asking me whether I know Brano Vujic or Grujic and I say

15     I don't.  And he says, well, he's the president of the SDS.  And I say I

16     cannot know every president and I cannot believe that weapons are being

17     distributed.  Is that what it says here?

18        A.   Yes.

19        Q.   Thank you.

20             THE ACCUSED: [Interpretation] Can this be admitted?

21             JUDGE KWON:  I don't know what the witness testified to in

22     relation to this.

23             THE ACCUSED: [Interpretation] First of all, it was only then,

24     that is to say, the end of August, somebody was dealing with that.  The

25     witness thinks that it's November actually, and the witness himself went

Page 17378

 1     to see Bogdanovic only in the beginning of 1991, and that before this,

 2     the Muslim side had already set up its entire organisation.

 3             THE WITNESS: [Interpretation] I do apologise, it was the

 4     beginning of 1992.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   You were there in 1992?

 7        A.   Yes.

 8        Q.   The Muslims started organising themselves in March 1991; right?

 9        A.   That's right.

10             JUDGE KWON:  Sir, do you know who this Mr. Bogicevic is?

11             THE WITNESS: [Interpretation] Well, I don't know

12     Milorad Bogicevic in Zvornik.  To the best of my knowledge, no such

13     person exists there.

14             JUDGE KWON:  And do you know who Brane Vujic is?

15             THE WITNESS: [Interpretation] Probably they mean Brano Grujic, so

16     Grujic, Vujic.  Brano Grujic was president of the municipal board of the

17     SDS.  As for Vujic, I think that's a mistake.

18             JUDGE KWON:  Do you have any observation, Mr. Nicholls?

19             MR. NICHOLLS:  I have no objection to it being admitted,

20     Your Honour.  You will also see on the bottom of the second page in the

21     English they do use the name as Brano Grujic as the person distributing

22     weapons.  So I think it does tie-in to the topics the witness has

23     discussed.

24             JUDGE KWON:  Thank you.

25             We'll mark it for identification.

Page 17379

 1             THE REGISTRAR:  As MFI D1610, Your Honours.

 2             MR. NICHOLLS:  Thank you, Your Honours, the number, I think, for

 3     the clip we were looking for is 40011B.

 4             THE ACCUSED: [Interpretation] It is 6 minutes, 20 seconds

 5     probably.  Right?  Can we have that now?  There is a Serbian version too.

 6     Can we ask for the Serbian version to be on half of the screen for the

 7     witness's benefit.

 8             JUDGE KWON:  I'm afraid we don't have B/C/S version, so that's

 9     why I asked whether you -- we have clip -- the video itself.

10             THE ACCUSED: [Interpretation] Then I'd like to read it out, with

11     your leave.  This is what he says from line 22.  He's actually --

12     actually, from line 13 he is saying that in Erdut he was informed that

13     Serbs were being slaughtered in Bijeljina, that extremist Muslims --

14             JUDGE KWON:  Yes, Mr. Nicholls.

15             MR. NICHOLLS:  Sorry to interrupt.  Mr. Reid tells me he thinks

16     he can play the audio.

17             JUDGE KWON:  Yes, that's more convenient.  We can follow with

18     this transcript and the witness can follow the video clip itself.  Is

19     there a way in which the interpreters could follow this transcript while

20     watching the video?

21             THE ACCUSED: [Interpretation] We can give them the transcript.

22             MR. NICHOLLS:  We could have the transcript printed and

23     distributed that way.

24             JUDGE KWON:  While we are waiting for the transcript to be

25     distributed, shall we go into private session briefly.

Page 17380

 1                           [Private session]

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             JUDGE KWON:  And are we ready?  One further delivery.

10             I think we are now ready to view the video.  Can you play the

11     video?

12                           [Video-clip played]

13             THE ACCUSED: [Interpretation] From 6.20, please.  We don't need

14     all of this.

15                           [Video-clip played]

16             THE INTERPRETER: [Voiceover] "Commander of the Serb Volunteer

17     Guard.

18             "God help you, brothers and sisters.  I would also like to greet

19     these wonderful children because they are our future.  We live for the

20     sake of our children" --

21             THE ACCUSED: [Interpretation] I think that this is an election

22     rally.  Can we view it from 6.20.  We don't need to see all of it.  If we

23     get more time, I don't mind watching all of it, but I'm afraid that I'll

24     be wasting time.

25             MR. NICHOLLS:  I'm sorry, Your Honour, we may need to see the

Page 17381

 1     hard copy of the transcript.  Mr. Reid has printed the part up to 6.20,

 2     he thought that was what was being asked for.  This is the part we've got

 3     in the B/C/S as well.  I'm not sure he knows exactly -- we need to see

 4     exactly which text is requested because I think what --

 5             JUDGE KWON:  It's in the e-court.  With your personal computer

 6     you can follow.

 7             MR. NICHOLLS:  My understanding is what's in e-court goes from

 8     0 to 6.20, which is what has been printed and what is on the video.

 9             JUDGE KWON:  Yes.

10             MR. NICHOLLS:  So if it's from 6.20 later, then that means, as

11     far as I can understand, we don't have it.

12             JUDGE KWON:  Yes, the transcript says it's from the beginning

13     until 6.20.

14             THE ACCUSED:  Okay.  [Interpretation] Well, then let's play it,

15     but it seems to me that -- well, actually, it's more of an interview than

16     a presentation, but okay, let's have it played.

17             JUDGE KWON:  Shall we start from the beginning.  Yes.

18                           [Video-clip played]

19             THE INTERPRETER: [Voiceover] "President of the Serbian Unity

20     Party and commander of the Serbian Volunteer Guard.

21             "God help you, brothers and sisters.  I would like also to greet

22     these wonderful children because they are our future.  We live for the

23     sake of our children.  I would like to tell you that my wife Ceca wanted

24     to come with me, but since she is six months pregnant I did not allow it.

25     She sends her regards to all of you.

Page 17382

 1             "Brothers and sisters, you know that from the very first day, the

 2     Serbian Volunteer Guard has defended Serbian homeland, Serbian people,

 3     Serbian children, because by defending your children we were defending

 4     ours, because it would be our turn sooner or later.

 5             "And that is how it started and so we come to the moment when I

 6     was informed in Erdut that Serbian population was being slaughtered in

 7     Bijeljina, that extremist Muslim groups, certain Handzar divisions

 8     infiltrated Bijeljina, that genocide threatened Bijeljina.  We

 9     immediately responded to this appeal, although we were supposed to go and

10     defend Herzegovina.  Straight away we redirected our convoy and entered

11     Bijeljina during the night.  We fought the whole day and kept Bijeljina.

12     We defended the Serbian people.

13             "Then an appeal came saying that Zvornik was Muslim.  Two Serbs,

14     former officials, are negotiating with two Muslims, one of them was a

15     commander of Muslim army and the other president of the SDA.  I cannot

16     remember the names, because I lose my senses when it is them, I cannot

17     remember the names.  They negotiated in Mali Zvornik about the surrender

18     of Karakaj where Serbs -- some Serbs fled.  We came into that room in

19     Mali Zvornik.  I asked them who they were.  He said he was a Serb, he was

20     called that and that, representing that and that.  They are your

21     countrymen and I would not like to embarrass them here.  The other one

22     said the same.  The other two -- one said, 'I am the President of the

23     SDA' and the other said he was the would-be commander of their army.  I

24     asked the Serbs, 'What are you negotiating, who gave you the right to

25     betray Zvornik and the Serbian people here?'  And then we did not beat

Page 17383

 1     the Muslims, we beat the two Serbs because they betrayed all of you and

 2     Zvornik.

 3             "At 5.00 in the morning I ordered an attack on Zvornik and it was

 4     liberated, except for the tower up there, in record time.  Two of my

 5     officers were killed there - Ivan Okiljevic, a.k.a., Rambo, a young man

 6     who fought on all battle-fields and who was the engine of the volunteer

 7     guard, along with Major Zika.  Two fatalities, two officers in Zvornik,

 8     but with these losses and with that Serbian blood we marked this as a

 9     Serbian town.

10             "Let us get one thing clear, the Serbian Volunteer Guard

11     afterwards moved to other battle-fields.  We organised Serbian control

12     here, which has not been functioning well, Yellow and Green Wasps and

13     Blue Wasps appeared - I do not know their names - they were behaving

14     violently, so I had to put things in order once again when I was passing

15     through Zvornik.  I am saying this for the history, for the sake of

16     truth, and those who participated in combat here know that it was like

17     this.  Zvornik was free, Serbian Volunteer Guard went to other

18     battle-fields, and we set up the border on the Drina River.  If we had

19     not taken Zvornik and Bijeljina, take my word for it, the border would be

20     here on the Drina now, and God knows how many victims there would be

21     among the Serbian population."

22             THE ACCUSED: [Interpretation] Thank you.  I think we can stop

23     here.

24             MR. KARADZIC: [Interpretation]

25        Q.   Mr. Witness, is this an election rally, election rally, held in a

Page 17384

 1     hall in Zvornik?

 2        A.   Yes.

 3        Q.   To the best of your knowledge was there any hindrance by the OSCE

 4     or NATO, banning Zeljko Raznatovic, Arkan, and his party to participate

 5     in the political life?

 6        A.   No, they participated just like any other party.

 7        Q.   Does this description that he gave, although it was a bit

 8     summarised and suited for a political rally, but is the essence

 9     consistent with what you knew?

10        A.   Yes, it is.

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

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit D1611, Your Honours.

14             JUDGE KWON:  The date of this video is September 1996?

15             THE ACCUSED: [Interpretation] Yes, that's an election rally, but

16     he's talking about the events from April 1992.

17             JUDGE KWON:  Thank you.

18             THE ACCUSED: [Interpretation] Can we now look at 65 ter 40162 and

19     I think we have an English version, too, in e-court.  We are waiting for

20     the Serbian version.  This is a TV interview with Zeljko Raznatovic,

21     Arkan, from July and August 1994, production from July and August 1994.

22             Can we have ERN page in the Serbian with the last three digits

23     395.  I think that's page 8 and I believe that the same page is in

24     English as well.  The time is 1.16.35.  Yes, we have it in English.

25     1.16.35.

Page 17385

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Look at the Serbian version.  He's being asked here about his

 3     connections with the JNA and he says that he didn't have any contacts,

 4     that he didn't receive anything from them, that he was the sole source of

 5     financing the Serbian Volunteer Guard with which they procured weapons.

 6     He is talking about fighting in Croatia, Tenja, Ernestinovo, et cetera;

 7     is that correct?

 8        A.   Yes.

 9             THE ACCUSED: [Interpretation] Can we move two pages forward.

10     Time-frame 1.24.  Can we have the next page in the Serbian?

11             MR. KARADZIC: [Interpretation]

12        Q.   Look here where he says in the then-Bosnia-Herzegovina the

13     Muslims armed themselves, that there were over 300 Kalashnikovs in Janja,

14     600 Kalashnikovs in Bijeljina itself, and that a Croatian unit consisting

15     of Albanians had already been inserted into Bijeljina and was supposed to

16     assume power overnight in Bijeljina.  This means that all prominent

17     Serbs -- there was a list for the liquidation of all prominent Serbs who

18     were supposed to be killed in the 24 hours.  And then he goes on to

19     describe this one day of fighting, and when the fighting ceased he

20     describes the arrival of Mr. Abdic and Biljana Plavsic.

21             Was Mr. Abdic the Muslim member of the Presidency,

22     Biljana Plavsic the Serbian member?

23        A.   Yes.

24        Q.   He says here that they used automatic rifles from Croatia, that

25     there were four or five Serbs with their throat slit, they were

Page 17386

 1     experienced enough, and they speedily took it over.  Is that correct?

 2        A.   Yes.

 3             THE ACCUSED: [Interpretation] Can we now have time-frame 1.29.39.

 4     Page 13 in English.  We need page 12, I think, in Serbian.  It says:

 5             "After that you consolidated power here in Bijeljina ... a little

 6     bit later Operation Zvornik commenced."

 7             And he said that he had received information that the Muslims had

 8     taken over Zvornik.

 9             Is it correct that before this action the Muslims had taken over

10     Zvornik.

11        A.   Yes.

12        Q.   That the Serbian authorities and the Serbian people fled across

13     the river to Karakaj; is that correct?

14        A.   Yes.

15        Q.   Now I'd like to -- for you to look at the rest of this text, and

16     it says here that he thought that the Serbs entered negotiations with a

17     view to handing over Karakaj, which says that -- that --

18             JUDGE KWON:  Probably next page for B/C/S.

19             THE ACCUSED: [Interpretation] Yes, yes.  It's a different

20     sequence on the pages.

21             MR. KARADZIC: [Interpretation]

22        Q.   He says:

23             "We are going to give them Karakaj ..."

24             But in the previous document we thought that he believed that the

25     Serbs were there to negotiate the hand-over of the Serbian part of

Page 17387

 1     Zvornik.  Is that correct?

 2        A.   Yes, that's what the confusion was about.  Our two

 3     representatives were only discussing the division and we decided to wait

 4     peacefully for the final solution for the whole of Bosnia-Herzegovina.

 5        Q.   Here he repeats what you already said, who gave you the right,

 6     you have no right, no mandate.  He slapped them a couple of times on the

 7     face.  We didn't touch the Turks.  And he gave them a piece of paper and

 8     asked them to write down all the weapons that they had.  They wrote that

 9     they had 700 armed people and how those people were deployed.

10        A.   Yes.

11        Q.   Please read all of this from -- until 1.33.38, because it says

12     that eventually special units from Pale came and disarmed these

13     paramilitary formations all around Zvornik.

14        A.   Yes, that's the gist of it.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can this be admitted?

17             JUDGE KWON:  Yes, this will be admitted.

18             THE REGISTRAR:  As Exhibit D1612, Your Honours.

19             MR. KARADZIC: [Interpretation]

20        Q.   Mr. Witness, let us now focus on the issue of paramilitary.

21     Yesterday you were asked with the affirmative connotation in the question

22     about whether the government financed paramilitary troops.  Now my

23     question is:  Was the question of volunteers regulated by the law and by

24     a separate decision of the SFRY Presidency, whereby the volunteers were

25     completely put on equal footing with the soldiers from the regular army?

Page 17388

 1        A.   Yes.

 2        Q.   Is it correct -- I'm waiting for the interpretation.

 3             Is it correct that the reservists who were employed were called

 4     up to take part in exercises and received salary for that period, whereas

 5     those who were unemployed, it was the army who paid them daily allowance

 6     during exercises?

 7        A.   Yes.

 8        Q.   Is it correct - and I think you confirmed this already

 9     somewhere - that not a single organised unit came to Zvornik with the

10     exception of the Arkan's unit, which stayed there for a short period of

11     time, and that all the rest came as volunteers in their civilian clothes

12     and without weapons?

13        A.   Yes.

14        Q.   Is it correct that they were assigned to the Territorial Defence

15     and later to the Army of Republika Srpska and that quite a large number

16     of the volunteers remained on the lines and in the army and adhered to

17     their obligations?  On the other hand, some of them returned and became

18     renegades of a certain period of time, that is to say, paramilitary?

19        A.   [No interpretation]

20        Q.   Did any of them came as paramilitary in the first place or did

21     they come individually as volunteers, whereas the paramilitary formations

22     were later formed by those renegade elements and some local elements?

23        A.   Yesterday I said that they came individually and these

24     paramilitary formations were later formed.

25        Q.   Thank you.

Page 17389

 1             JUDGE KWON:  I'm afraid that because of potential overlap, his

 2     answer to your previous question was not reflected in the transcript.

 3             Did you say "yes" to that question?

 4             THE WITNESS: [Interpretation] Yes.

 5             THE ACCUSED: [Interpretation] Your Excellencies, I'd like to ask

 6     something before I show a particular document.  Since this is a viva voce

 7     witness and since the OTP spent about five hours, could I perhaps have

 8     the rest of tomorrow except for the time that is required for re-direct,

 9     because it would really be a pity.  This is a witness who took part in

10     government before the war and who saw a great deal during the critical

11     period of time.  It would be a pity to see him leave without being fully

12     examined.

13             JUDGE KWON:  The fact itself that the witness was changed into a

14     viva voce witness does not necessarily mean that you will have more time,

15     but we'll see tomorrow how much more you will need.  And please be

16     efficient as much as possible.

17             I think it's time to rise for today.  Do you have a further

18     question to put -- yes, Mr. Nicholls.

19             MR. NICHOLLS:  I would have one point I would like to make at the

20     end for just a minute in private session if we can.

21             JUDGE KWON:  It can be in the presence of the witness?

22             MR. NICHOLLS:  Probably better out of the presence.

23             JUDGE KWON:  Very well.

24             So that's it for today, Mr. Witness.

25             THE ACCUSED: [Interpretation] Excellencies, I hope that I'm going

Page 17390

 1     to get five hours at least but I'm hoping for more because of the extent

 2     to which this witness is beneficial for the Trial Chamber because the

 3     Prosecution spent almost five hours with this witness.  I've been

 4     allocated three and a half.  I hope it's not going to remain that way,

 5     only three and a half.  I would need all of tomorrow except for the time

 6     needed by the OTP.

 7             JUDGE KWON:  We'll deal with that matter first thing tomorrow.

 8             The witness can be excused.  Thank you.

 9                           [The witness stands down]

10             JUDGE KWON:  Oh, just a second.

11             Let's go into private session.

12                           [Private session]

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 17391











11  Page 17391 redacted. Private session.















Page 17392

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9                           [Open session]

10             JUDGE KWON:  I'm afraid, Mr. Harvey, it will be a long day for

11     you.  We rise.  Tomorrow, 9.00.

12                           --- Whereupon the hearing adjourned at 1.48 p.m.,

13                           to be reconvened on Thursday, the 18th day of

14                           August, 2011, at 9.00 a.m.