Tribunal Criminal Tribunal for the Former Yugoslavia

Page 17673

 1                           Tuesday, 23 August 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 2.16 p.m.

 6             JUDGE KWON:  Good afternoon, everyone.

 7             Good afternoon, sir.

 8             THE WITNESS: [Interpretation] Good afternoon, to you,

 9     Your Honour.  Good afternoon to all of those present in court today.

10             JUDGE KWON:  Thank you, Mr. Redzic.  If you could take the solemn

11     declaration, please.

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

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

14             JUDGE KWON:  Thank you.  Please make yourself comfortable.

15             Yes, Ms. Sutherland.

16             MS. SUTHERLAND:  Thank you, Your Honour.  Good afternoon.

17                           WITNESS:  IZET REDZIC

18                           [Witness answered through interpreter]

19                           Examination by Ms. Sutherland:

20        Q.   Good afternoon, Mr. Redzic.  Could you please state your full

21     name.

22        A.   Good afternoon.  Izet Redzic.

23        Q.   As we discussed earlier, part of your evidence in this case will

24     be submitted in writing, and we need to deal with the formalities in

25     relation to that submission first.

Page 17674

 1             You testified in the Krajisnik case over two days on the 30th and

 2     31st of August, 2004; is that right?

 3        A.   Yes.

 4        Q.   You've had the opportunity to review the audio recordings of the

 5     Krajisnik testimony, and there's one correction you wish to make, and

 6     that correction is to the transcript of the 30th of August, 2004,

 7     page 5005, line 18, the figure relating to the number of inhabitants in

 8     the municipality the Vlasenica currently states 34.817, and you say it

 9     should read 33.817; is that right?

10        A.   That's right.

11        Q.   And with that correction can you confirm that it accurately

12     reflects your testimony at the time?

13        A.   I confirm that it was correct.

14        Q.   And if you were asked today about the matters that you testified

15     to in the Krajisnik trial, would you provide the same information to this

16     Trial Chamber?

17        A.   Well, for the most part the same.  Yes.

18             MS. SUTHERLAND:  Your Honour, I seek to tender 65 ter 22599,

19     which is the witness' Krajisnik testimony of the 30th and 31st of August,

20     2004.

21             JUDGE KWON:  Yes.  Thank you.  That will be admitted.

22             THE REGISTRAR:  As Exhibit P3189, Your Honours.

23             MS. SUTHERLAND:  And with Your Honours' leave, I'll now read a

24     summary of the witness's written evidence.

25             The witness Izet Redzic is an engineer by profession.  After the

Page 17675

 1     multi-party elections in 1990, Mr. Redzic was appointed president of the

 2     Executive Board of the Vlasenica Municipal Assembly.

 3             The witness testified that from late 1991, Muslims began to be

 4     dismissed from their jobs and by mid-May 1992, all Muslims had been

 5     dismissed from their employment.

 6             By mid-1991, the witness had become aware of military activities

 7     in the Vlasenica area.  Paramilitary units were located at Milici,

 8     several kilometres from the town of Vlasenica.  These troops maltreated

 9     and harassed civilians and erected barricades.

10             Beginning around the end of June 1991, military commanders from

11     local units and units in Serbia, as well civilian authorities, including

12     the accused Mr. Karadzic, came to visit the paramilitary troops in

13     Milici.  These visits were reported on television and radio.  The SDS

14     formed the paramilitary units.  The witness became aware through members

15     of the Serb population that the local army and police were distributing

16     weapons to persons of Serb ethnicity.

17             In April 1992, tanks, artillery, and armed vehicles were deployed

18     in Vlasenica.

19             The witness, Mr. Redzic, headed the Muslim delegation in

20     negotiations between the end of March and the 11th of April, 1992,

21     regarding the division of the municipality into Serb and Muslim parts.

22     The Serb delegation was headed by Milenko Stanic [Realtime transcript

23     read in error "Stanisic"], the president of the Vlasenica Municipal

24     Assembly.  Stanic consulted with Rajko Dukic, the president of the SDS

25     BiH Executive Board.  The Muslim delegation was told to sign an agreement

Page 17676

 1     to divide the municipality, and that if the Muslims did not agree to the

 2     Serb demands, tanks would attack and the boundaries would be drawn in

 3     blood.  The witness therefore signed, under duress, an agreement creating

 4     the Serb municipality of Vlasenica, the Muslim municipality of Vlasenica

 5     and the municipality of Milici.  Stanic told the witness that the orders

 6     regarding the division of the municipality had come from high up.

 7             Mr. Redzic fled Vlasenica on 18 April 1992.  He testified that

 8     Muslim men, women and children from villages in the Vlasenica

 9     municipality were brought to and detained at Susica camp.  Women,

10     children, and some elderly men were then transported to Kladanj.  Most of

11     the male population remained in the camp.  Stanic told the witness that

12     the Muslim men at Susica were to be exchanged for Serbs.  The witness

13     later became aware that many of the men detained at Susica were killed.

14             The witness also describes a mass killing in the village of

15     Zaklopaca which occurred on the 16th of May, 1992.

16             Your Honour, that completes the summary of the witness's written

17     evidence.

18             JUDGE KWON:  Thank you.  Just for the record, page 3, line 19,

19     Milenko Stanisic should read Milenko Stanic.

20             MS. SUTHERLAND:  That's correct.

21             JUDGE KWON:  Yes, Ms. Sutherland.

22             MS. SUTHERLAND:

23        Q.   Mr. Redzic, were you born on the 19th of January, 1955, in the

24     village of Dzemat in the Vlasenica municipality?

25        A.   Yes, on the 19th of January, 1955, the village of Dzemat near

Page 17677

 1     Vlasenica.

 2        Q.   What is your ethnicity?

 3        A.   At that time I was a Muslim, and right now I'm declaring myself

 4     as a Bosniak.

 5        Q.   In order to orient the Trial Chamber, can you very briefly tell

 6     us where the municipality of Vlasenica is situated within Bosnia and

 7     Herzegovina and the names of the neighbouring municipalities?

 8        A.   The municipality of Vlasenica is in northeastern Bosnia.  It is

 9     50 kilometres away from Zvornik and 100 kilometres from Sarajevo.  The

10     neighbouring municipalities are Srebrenica, Bratunac, Zvornik, Kalesija

11     in part, Sekovici, Kladanj, Han Pijesak, and there's a small border with

12     Rogatica towards Zepa.

13             THE INTERPRETER:  Interpreters note:  Could the Prosecutor's

14     microphone please be switched off while the witness is speaking.  Thank

15     you.

16             MS. SUTHERLAND:

17        Q.   Mr. Redzic, I have a limited number of questions to clarify some

18     matters in relation to your written evidence which is now before the

19     Court.  You testified in the Krajisnik trial about the paramilitary units

20     located in Milici and this is at transcript page 5008.  You also

21     testified at transcript pages 5012 to 5014 that on several occasions you

22     held meetings with the chief commander of the army and commander of the

23     barracks in Han Pijesak to discuss the paramilitary units and the

24     mobilisation of the Territorial Defence, the TO, and the TO being put

25     under his command.  You said that the commander of the barracks was

Page 17678

 1     Colonel Milosevic, the same Milosevic who later became the commander of

 2     the Sarajevo-Romanija Corps; is that correct?

 3             THE INTERPRETER:  Could all unnecessary microphones please be

 4     switched off.  Thank you.

 5             THE WITNESS: [Interpretation] Correct.

 6             MS. SUTHERLAND:

 7        Q.   When you said the commander of the army and the commander of the

 8     barracks, were you referring to one and the same person?

 9        A.   The commander of the barracks was Dragoljub Milosevic, precisely

10     if we're talking about Han Pijesak.  He was commander of the barracks in

11     Han Pijesak.

12        Q.   I'm sorry, did you say Dragoljub Milosevic?

13        A.   Or is it Dragomir?  I don't know.  I know it's Milosevic.  And he

14     was commander in Han Pijesak of the regular military units.

15        Q.   When was your first meeting with the then Colonel Milosevic?

16        A.   Well, when the paramilitary brigade in Milici was established,

17     that was the summer of 1991, there was a great deal of tension because of

18     all the things that the Serb units did.  In that period of time, all the

19     way up until the aggression, I had contacts with Mr. Milosevic and his

20     deputy Asim Dzambasovic, so that I would get some promises in view of all

21     the problems that the Muslim population was facing at the time.  They

22     asked that all of these problems, and that is to say barricades,

23     provocations, shooting at religious facilities, et cetera, they asked me

24     to negotiate and try to resolve that so that these things no longer

25     happened.

Page 17679

 1        Q.   Thank you, Mr. Redzic.  I simply asked you when was the first

 2     meeting, but you have answered my -- what were going to be my subsequent

 3     questions, so we will move on.

 4             You also testified about military and civilian leaders visiting

 5     the paramilitary brigade, and this is at transcript pages 5016 to 5017.

 6     You state that Mr. Karadzic and other key SDS figures and other people in

 7     the BH government visited the units and that this was broadcast on

 8     television.  How often did this happen, these visits?

 9        A.   Well, the accused here knows that every seven days he came to

10     Zvornik, Srebrenica, Bratunac, Vlasenica, and co-operated with his key

11     people from the SDS in preparing the Serb people for a fight so that they

12     would turn against their Muslim neighbours and the few Catholics that

13     were there.

14        Q.   When did this happen?  What time period, if you recall?  Over

15     what time period was this occurring?

16        A.   Well, for the most part it was from the month of June onwards

17     until the aggression took place and the war started.

18        Q.   You mentioned -- you've mentioned twice now up until the

19     aggression and you just mentioned then when the war started.  Could you

20     put a -- for the Trial Chamber, what date or month was that?

21        A.   If it has to do with Vlasenica, that means that the JNA,

22     according to what people in Vlasenica knew, the Novi Sad Corps came

23     between the 22nd and 23rd of April.  They entered Vlasenica, and they

24     said that they liberated Vlasenica from someone.

25        Q.   Mr. Redzic, you testified that you left the municipality of

Page 17680

 1     Vlasenica on the 18th or 19th of April and that's at transcript page

 2     5053, and from there you went via Kladanj to Tuzla; is that right?

 3        A.   Yes.

 4        Q.   You stated that you initially kept in contact by telephone with

 5     Milenko Stanic and Brano Drakulic re: transporting people out and that's

 6     at transcript pages 5057 to 5058.  You further testified that you also

 7     had contact with people who fled Vlasenica to come to the area where you

 8     were residing and that's at transcript pages 5060 to 5062 and that these

 9     people told you about the attack on Vlasenica and the Susica camp.

10             MS. SUTHERLAND:  Your Honours, this is scheduled incidents

11     B-18.1, B-18.2 and C-25.3.

12        Q.   Mr. Redzic, are you able to explain who or what were the sources

13     of this information?

14        A.   As for my contacts and talks with Mr. Stanic and

15     Mr. Brano Drakulic, they lasted all the way up until mid-June while

16     telecommunications were still operating in that period.

17             In the second half of June, there was a total blockade and all

18     telephone communications were cut off, and I could no longer communicate

19     with these persons I mentioned.  However, talks continued with people who

20     were coming from Vlasenica through the woods.  They provided information

21     as to what was going on within Vlasenica and in the surrounding villages.

22     However, this had to do with ethnic Muslims.

23        Q.   Were you conducting these talks yourself or -- or who were these

24     talks being conducted by?

25        A.   Well, for the most part we actually had a service in Tuzla.  We

Page 17681

 1     were given some premises there, and we had people who were in charge of

 2     this.  Every citizen could come there, and our task was to provide any

 3     kind of accommodation to people and to take care of food and so on and so

 4     forth.  So since people came invariably, all of these citizens, all of

 5     these Muslims who came from Vlasenica, from any part of that area, they

 6     provided information.  They gave statements, rather, as to all the things

 7     that they had seen there.  All of that was recorded, and there were

 8     proper services that kept strict records about the statements that were

 9     given.

10        Q.   You also described, and this is at transcript page 5104, what

11     happened in the village of Zaklopaca on the 16th of May, 1992.

12             MS. SUTHERLAND:  Your Honours, this is scheduled incident A 15.2.

13        Q.   Mr. Redzic, you said that "83 civilians were killed, amongst them

14     five or six children, 80 per cent were women, the rest were men."  Who or

15     what was the source of this information?

16        A.   Well, when this happened as soon as the aggression broke out on

17     the 16th of May as you said, 1992, it is true that this many people were

18     killed.  These people had not been armed.  They were civilians, and at

19     the time some Muslims were still coming in.  It is important to mention

20     that on the 15th of May, in the bauxite mine, and that was the biggest

21     work organisation there, it accounted for 80 per cent of the economy of

22     Vlasenica, all Muslims were banned from that work organisation.  They

23     were not allowed to come there any more.  After that these mass killings,

24     executions, took place.

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

Page 17682

 1     witness's statement.

 2             MS. SUTHERLAND:

 3        Q.   Mr. Redzic, I'm sorry to interrupt you.  My question was:  Do you

 4     recall what the source -- who the sources or -- sources or sources were

 5     that informed you about the events that happened in Zaklopaca?  You

 6     mentioned -- sorry, you mentioned that people were coming, but do you

 7     recall specifically who in relation to that incident?

 8        A.   At the time it could be seen on Serb television too.  Serb

 9     television said that a certain number of people lost their lives there.

10     They said something that was not true, namely that these persons had been

11     armed.  I spoke about Stanic at the time, about what was going on in

12     Zaklopaca.  I said to him do you see what is happening in Zaklopaca and

13     he quite simply said no one can rule anyone else.  These people who fled

14     from Zaklopaca and the neighbouring villages, they were saying about what

15     had happened, how many people were killed, et cetera.  There are

16     witnesses who are survivors who were in the woods there.

17        Q.   Thank you, Mr. Redzic.

18             MS. SUTHERLAND:  That finishes my examination-in-chief,

19     Your Honour.

20             JUDGE KWON:  And you are minded to tender the associate exhibit

21     of this witness's transcript.  Microphone.

22             MS. SUTHERLAND:  Of the two associated exhibits, the first one

23     listed on the notification filed on the 7th July 2011 is already an

24     exhibit.

25             JUDGE KWON:  So we'll admit the 65 ter number 11468.

Page 17683

 1             MS. SUTHERLAND:  Yes, Your Honour, and that is simply an

 2     authentication sheet of the five recorded intercepts.

 3             MR. ROBINSON:  Excuse me, Mr. President.  I would ask what the

 4     point is of admitting the authentication sheet when the intercepts are

 5     not being admitted.

 6             MS. SUTHERLAND:  Your Honour, one of the intercepts

 7     Mr. Krajisnik [sic] asked to be admitted yesterday or asked to be MFI'd

 8     and that was MFI D1643 which is or was 65 ter number 30186.  So in that

 9     regard, Mr. Redzic listened to the audio of that intercept and confirmed

10     the speakers.  One of them was Mr. Bajagic and the other was

11     Mr. Karadzic.  So for that reason the authentication sheet is of some

12     benefit to Your Honours.

13             JUDGE KWON:  So at this moment you're not minded to tender those

14     intercepts themselves.  So whatever probative value they may have you are

15     now tendering the authentication by this witness.

16             MS. SUTHERLAND:  Yes, Your Honour.  In his transcript -- in his

17     Krajisnik transcript, he gave evidence that he had listened to the five

18     intercepts and that he recognised the voice of Mr. Bajagic and.

19             JUDGE KWON:  Bajagic, Bojagic?

20             MS. SUTHERLAND:  It's incorrectly spelled in yesterday's

21     transcript but it's B-a-j-a-g-i-c.

22             JUDGE KWON:  Zvonko Bajagic.

23             MS. SUTHERLAND:  Yes and that's at page 5076 and 5077 of the

24     Krajisnik transcript.

25                           [Trial Chamber confers]

Page 17684

 1             JUDGE KWON:  Yes.  That exhibit can be admitted.

 2             MS. SUTHERLAND:  Your Honour, we --

 3             JUDGE KWON:  Just -- we are going to give the number.

 4             THE REGISTRAR:  That will be Exhibit P3190.

 5             JUDGE KWON:  Yes, Ms. Sutherland.

 6             MS. SUTHERLAND:  And we can seek to tender them at a later stage

 7     through another witness who will authenticate them.

 8             JUDGE KWON:  Thank you.

 9             MS. SUTHERLAND:  In addition to Mr. Redzic's authentication.

10             JUDGE KWON:  Yes.  Now your examination-in-chief is over,

11     Mr. Redzic.  You will be further asked by Mr. Karadzic in his

12     cross-examination.

13             Yes, Mr. Karadzic.

14             THE ACCUSED: [Interpretation] Thank you.  Good afternoon,

15     Excellencies; good afternoon to all.

16                           Cross-examination by Mr. Karadzic:

17        Q.   [Interpretation] Good afternoon, Mr. Redzic.

18        A.   Good afternoon.  I have already said good afternoon.

19             THE ACCUSED: [Interpretation] Your Excellencies, with all due

20     respect, I would like to know whether it is the case that even now when

21     the Prosecutor exhibited the transcript of two days of testimony by this

22     witness and the testimony was provided in a case that resulted in a

23     conviction, can I still manage to challenge all of that within only an

24     hour and a half?

25             JUDGE KWON:  Mr. Karadzic ...

Page 17685

 1                           [Trial Chamber confers]

 2             JUDGE KWON:  As is the usual practice, we'll see how you proceed

 3     with your cross-examination.  Please get on with your cross-examination,

 4     Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you, but I have to say that

 6     getting such a short time, I make mistakes in haste, and that's a vicious

 7     circle that handicaps my defence.

 8             JUDGE KWON:  And also bear it in mind that we admitted entire

 9     testimony, which includes the cross-examination, which means you don't

10     have to repeat what was asked before.

11             THE ACCUSED: [Interpretation] Thank you.

12             MR. KARADZIC: [Interpretation]

13        Q.   Witness, you have said, and it's a fact, isn't it, that the

14     Municipal Assembly of Vlasenica had 60 deputies, including 26 from the

15     SDA, 27 from the SDS, and 7 from the united opposition; correct?

16        A.   Yes.

17             THE ACCUSED: [Interpretation] 65 ter 901127 is the document I

18     would like displayed in e-court.

19             JUDGE KWON:  Could you give the number again, Mr. Karadzic.

20             THE ACCUSED: [Interpretation] 901127.

21             JUDGE KWON:  There seems to be some mistake in number,

22     Mr. Karadzic.

23             THE ACCUSED: [Interpretation] With your indulgence, I'll check

24     now.  1D4054.  It's the same subject.

25             MR. KARADZIC: [Interpretation]

Page 17686

 1        Q.   All right.  Would you please see this is the outcome of the

 2     elections broken down by local communes.

 3             THE ACCUSED: [Interpretation] Can we see the next page.  Page 3,

 4     please.  That's the summary of the results.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Is this the final outcome of the elections including the number

 7     of votes and percentages added in hand?  Can you see this Serbian

 8     version.  21.986 people voted.  And then rubric 4 is SDS, rubric 5 is the

 9     opposition.  Column 7 is the SDA, and 8 are the reformist forces and I

10     don't know who else.

11             Can you hear me, Mr. Redzic?

12        A.   I can hear you, but I didn't understand you were addressing me.

13             The results are correct.  That's as I said.  There were 60

14     deputies before the outbreak of the aggression, 27 of the SDS; 26, the

15     SDA; and 7, the opposition.

16        Q.   Please, since we don't have enough time, whenever we can do

17     without a broader explanation, please answer with a yes or no.

18             You said in your earlier evidence, and you said that in your

19     statement in October, 12 October 1994, on page 00184597, is that the

20     elections reflected, in fact, the ethnic composition of the municipality;

21     correct?

22        A.   It's correct.  At that time there were two political parties, two

23     political movements, in fact, that had not established themselves yet as

24     political parties, and there were some opposition that was manipulated by

25     the SDS, because there was no way the Serbs would have gotten this number

Page 17687

 1     of votes if the ethnic composition had been observed, because the ethnic

 2     composition was not honoured, and you can see that from the fact that the

 3     entire opposition are Muslims.  That's a simple explanation, because the

 4     Serbs, according to the percentages, the Serbs could have gotten only 24

 5     seats.  All the rest are Muslims including perhaps 1 per cent of

 6     Yugoslavs and others.

 7        Q.   Thank you.  Do you know that you would be right on the condition

 8     that the polling had been accurate and honourable?

 9        A.   The census, you mean, was done very accurately and very honestly

10     because it was conducted by absolutely impartial people representing

11     Serbs and Muslims and every other community.

12        Q.   Do you know that the Serbs objected that the census had been

13     falsified and that's why it never passed verification in parliament?

14        A.   If anyone would have known that, I would have known that, because

15     I was a leader among these people, Serbs and Muslims and all the others.

16     I never heard of any such thing, nor was I told of -- of that by -- by

17     any Serb or Muslim representative.  Thank you.

18        Q.   And do you agree that the census was not ratified in the

19     parliament of Bosnia and Herzegovina?

20        A.   I simply don't believe that these results had not been accepted.

21     Perhaps maybe if the problems had already occurred, but I don't believe

22     it.  This is pure statistics, and for statistics there is a particular

23     institution in charge.  It's a different matter if the SDS did not accept

24     it, because they were working against the system, against the country to

25     break up everything that makes up Bosnia and its people.

Page 17688

 1        Q.   I believe that the answer to my previous question was not

 2     recorded in its entirety, so I'm asking you to speak slowly and answer

 3     more briefly.  Answer only to the point.  If we get more time, I'll be

 4     able to ask you more about it.

 5        A.   Very well.

 6        Q.   So you were the president of the Executive Board while

 7     Mr. Milenko Stanic from the victorious party was the president of the

 8     Municipal Assembly; correct?

 9        A.   Yes.

10        Q.   You say that Mr. Stanic did not have direct control over the

11     Secretariat for National Defence.  Was Milenko Stanic the president of

12     the National Defence council or was it you?

13        A.   Under the law and under the constitution of Bosnia-Herzegovina,

14     the National Defence Council is made up of the president of the Assembly,

15     the president of the Executive Board, the secretary for national defence,

16     the commander of the Territorial Defence, the chief of the MUP, and

17     presidents of the deputies' clubs from the Assembly of Vlasenica.  That

18     is the truth, and that is prescribed by law.  And it's not designated by

19     name who was a member.  It's not a problem if it's Milenko Stanic but it

20     is a problem if there is aggression from outside.

21             In this situation, the Serbs and the SDS took another path as you

22     directed them.  That's why the council was never able to properly

23     discharge its functions and play its part.  And they would not convene,

24     although I tried very hard to get people together but without any

25     success.

Page 17689

 1             I don't have to explain to you what instructions you gave to the

 2     Serbian people what they were to do, how to form Serbian Assemblies,

 3     Serbian municipalities.  You know it all, Karadzic, as well as I know it

 4     or anyone here in the courtroom and outside this courtroom.

 5        Q.   I kindly ask you, Mr. Redzic, you are not charged with anything

 6     or accused of anything, and I'm not attacking you.  I'm just looking for

 7     the truth together with you.  I'm just asking you were you the president

 8     of the National Defence Council?

 9        A.   I explained a moment ago of whom the National Defence Council is

10     made up of, and at that time the Serbian people from the SDS made

11     themselves available completely at -- to Karadzic and his legions.

12     Nobody was interested any more in the Assembly of Bosnia-Herzegovina.  At

13     that time, the National Defence Council did not exist at all.

14             JUDGE KWON:  So your answer was that the National Defence Council

15     did not exist at the time.  If the question is a simple one to which you

16     can say yes or no, please do so, because we have only limited time,

17     Mr. Redzic.

18             Please continue, Mr. Karadzic.

19             MR. KARADZIC: [Interpretation].

20        Q.   In your evidence in the Krajisnik case on the 30th and 31st of

21     August, 2004, on page 5012 you said, and I'm going to read it in English

22     now, I hope it's going to be interpreted to you correctly.

23             "[In English][Previous translation continues] ... According to

24     the law and constitution of Bosnia-Herzegovina, the Territorial Defence

25     and civilian protection are under the authority of the civilian

Page 17690

 1     authorities, and it could be mobilised in the case of natural disaster or

 2     other circumstances, storm, large-scale fires, and also the case of war."

 3             [Interpretation] Was the Bosnian constitution and the Bosnian Law

 4     on National Defence different from the federal law or was it identical?

 5        A.   Of course the republic had to harmonise their legislation and

 6     their constitutions to the federal state, but in that period, Yugoslavia

 7     was breaking up.  Republics were seceding, and many laws were adopted

 8     here at conferences in The Hague according to declarations and other

 9     documents.  Former federal laws were no longer applied in Croatia and

10     Slovenia and they were temporarily continuing to be applied in other

11     republics pending a solution that was to be found as the best solution

12     for everyone, all the peoples in the former Yugoslavia.

13        Q.   Mr. Redzic, let us stick to Vlasenica.  You say that in Vlasenica

14     there occurred a legal vacuum, and the laws and the constitution of

15     Yugoslavia were no longer applied.  When did that happen?

16        A.   When the aggression broke out in the Republic of Croatia.  From

17     that moment on, Serbian forces led by the SDS were fighting in every

18     possible way to make federal laws null and void and to apply instead the

19     laws of the Greater Serbia or some other common state they wanted.

20        Q.   With all due respect, Mr. Redzic, it's not up to you or to me to

21     talk about it today.  Let's talk about Vlasenica.  How did it come about

22     that you became the president of the National Defence Council when

23     according to the law it should have been Mr. Stanic?  And when were

24     federal laws and the constitution suspended in Vlasenica?  You were in a

25     position of power.

Page 17691

 1        A.   I kindly ask the gentleman who's asking me these questions to

 2     refrain from comment.  I am prepared to answer questions but not to

 3     listen to comment, because it misleads the witness.  He is leading me to

 4     give him the answers that suit him.  He asked me a question, and I told

 5     him I was not the president of the National Defence Council.

 6             JUDGE KWON:  Mr. Redzic, Mr. Karadzic is charged with serious

 7     charges here and he's entitled to put any questions as long as it's

 8     relevant and related to his charges.  The Chamber will monitor whether

 9     his questions are appropriate.  So unless prohibited by the Chamber, I

10     would like you to try to answer the question.  And it is for the Chamber

11     to monitor his cross-examination and then the Chamber will prohibit him

12     from making any inappropriate comment.  So unless indicated otherwise by

13     the Chamber, please answer the question.

14             Do you like the -- do you like the accused to repeat his last

15     question, Mr. Redzic.

16             THE WITNESS: [Interpretation] Yes, but briefly.

17             MR. KARADZIC: [Interpretation]

18        Q.   Thank you.  You have stated, and we'll find where, that you were

19     the president of the defence council in your municipality, and you told

20     us today that the federal law and the federal constitution were no longer

21     in force in Vlasenica from the moment when Croatia was attacked.  Can you

22     tell us when that happened according to whose decision and who decided

23     the federal laws would be suspended?

24        A.   It's not true that anyone made that decision but it's true that

25     there were talks were held in that town, talks to the effect that every

Page 17692

 1     problem in Yugoslavia has to be resolved by political negotiation, not by

 2     force.

 3        Q.   Mr. Redzic, were those talks about Vlasenica?

 4        A.   I don't know what you mean.  If you mean the negotiating team,

 5     then yes.

 6        Q.   Please, let us try to shed light on the developments in

 7     Vlasenica, not what happened all over Yugoslavia, but never mind.  Let's

 8     try to have this previous document admitted concerning the census.

 9             JUDGE KWON:  Yes.

10             THE REGISTRAR: [Interpretation] Exhibit D1645, Your Honours.

11             JUDGE KWON:  Yes, Ms. Sutherland.

12             MS. SUTHERLAND:  Your Honour, could I please ask Mr. Karadzic to

13     give me transcript references or page references to the statement where

14     he's saying that the witness is saying something.  For example, you were

15     president of the defence council in your municipality.

16             THE ACCUSED: [Interpretation] Thank you.  We'll find it if you

17     give me some time, because I did not expect the witness to go back on his

18     own statement.

19             MR. KARADZIC: [Interpretation]

20        Q.   But we've said that Milenko Stanic did not have direct

21     jurisdiction over the national defence.  There was a Secretary of

22     National Defence who was under your jurisdiction.

23        A.   The National Defence Council was a collective body, and it made

24     decisions jointly.  Neither Stanic or I had any control over it.  It's a

25     collective body that makes decisions based on a majority of votes.

Page 17693

 1        Q.   I said a moment ago the Secretariat for National Defence.  It's a

 2     part of the government, isn't it?

 3        A.   Yes.  It's a body of state administration.

 4        Q.   Thank you.  You have said, and that was in the statement of 12

 5     October 1994, 65 ter 22597, on page 3, that Becir Mekanic who was

 6     probably president of the municipality before the multi-party elections

 7     was replaced and went back to his job in the national defence; correct?

 8        A.   Yes.

 9        Q.   Is Mr. Mekanic a Muslim?

10        A.   Yes.

11        Q.   What was his position in the national defence?  He came to the

12     position of president of the Assembly from the national defence and went

13     back to his former job.

14        A.   What happened before the multi-party system, it's normal that any

15     citizen appointed to any position in the government retains his job.

16        Q.   We know that.  We don't need to --

17        A.   He was a desk officer in the national defence.  You shouldn't be

18     troubled about that.

19             JUDGE KWON:  Please do not overlap, and please put a pause

20     between questions and answers.

21             And, Mr. Karadzic, in particular to not start your question while

22     his answers are being translated.  Yes, Mr. Karadzic.

23             THE ACCUSED: [Interpretation] Thank you.

24             MR. KARADZIC: [Interpretation]

25        Q.   Mr. Turkovic was commander of the police station while the chief

Page 17694

 1     of the police station was this Milanovic; right?

 2        A.   I cannot give an accurate answer, because I left Vlasenica

 3     earlier.  I know that after the multi-party elections he was appointed

 4     commander of the Vlasenica police station.

 5        Q.   Wait a moment, please.  After the multi-party elections, the SDA

 6     and the SDS shared power.  The chief of the public security station was a

 7     Serb, Milanovic, and as was customary, the number two spot belonged to

 8     the other ethnic community and that was the Muslims there and that was

 9     Fadil Turkovic over there; right?

10        A.   That's right.

11        Q.   Thank you.

12             JUDGE KWON:  Yes, Ms. Sutherland.

13             MS. SUTHERLAND:  Excuse me, Your Honour, for interrupting, but

14     it's -- I'm just confused by the question and answer.

15             "Q. Mr. Turkovic was commander of the police station while the

16     chief of police station was this Milanovic; right?"

17             "A. I cannot give an accurate answer because I left Vlasenica

18     earlier.  I know that after the multi-party elections he was appointed

19     commander of the Vlasenica police station."

20             I'm wondering if Mr. Karadzic can clarify who the "he" is because

21     he talked about two gentlemen in the question and I don't know it's

22     supposed to be Milanovic but Bjelanovic.  Is that correct?

23             THE WITNESS: [Interpretation] Bjelanovic.

24             MR. KARADZIC: [Interpretation]

25        Q.   Bjelanovic.  Perhaps I did not articulate properly.  Bjelanovic,

Page 17695

 1     a Serb, and then Fadil Turkovic was commander of the uniformed part of

 2     the police, commander of the armed police; right?

 3        A.   The commander, yes, but it is the chief who holds all the keys in

 4     his hands, that is to say that the commander of the police cannot do

 5     anything without the approval of the chief of the police station.

 6        Q.   Thank you.  You said in that very same statement on page 3 that

 7     they were appointed by the ministry, yes, the Ministry of the Interior;

 8     right?

 9        A.   Well, that is something that both you and I know.  So proposals

10     are made by the municipality or, rather, the municipal organ or, rather,

11     the SDS and the SDA and then it goes to federal level and the appropriate

12     ministry gives its own consent.

13        Q.   Thank you.  Also in the same place you said it wasn't the

14     municipal authorities that could dismiss the chiefs of police, rather,

15     the chief and the commander; right?

16        A.   We, the municipal authorities could not operate that way, but the

17     political parties could.  It is the political parties, the ones that

18     dismissed people and appointed their own people.  We don't want to have a

19     vacuum here.  Let us understand each other properly.  Every political

20     party could propose its own people, of course, since they won the

21     elections so it was the SDA and the SDS and then at state level it is the

22     federal ministry that is in charge of actually giving consent and making

23     the actual appointment.

24        Q.   Thank you.  Let us clarify:  The municipal level could provide

25     proposals and as for changes in these appointments and dismissals, that

Page 17696

 1     was done by the ministry, right?

 2        A.   What is right is that the political parties were making the

 3     appointments.  In this situation that we were living in municipal

 4     structures practically had no powers whatsoever.  It was the political

 5     parties that made all these appointments and everyone knows how and in

 6     which way.

 7        Q.   Mr. Redzic, we have to be very specific.  This is a criminal

 8     case.  The political parties made proposals and the minister made

 9     appointments?

10        A.   Yes.  The federal minister as I've already said.

11        Q.   Thank you.

12             JUDGE KWON:  Just a second, yes, Ms. Sutherland.

13             MS. SUTHERLAND:  Mr. Karadzic's comments are inappropriate.  The

14     witness was simply asking [sic] his question.  If he doesn't like the

15     answer, then that's not our problem.

16             JUDGE KWON:  Yes, initially Mr. Karadzic's question didn't seem

17     to be correct in light of the final question he posed.  Let's proceed,

18     Mr. Karadzic.

19             MR. KARADZIC: [Interpretation]

20        Q.   You also stated in that statement on page 4 that around the 27th

21     of June, 1991, you became aware of the existence of irregular military

22     units and that these irregular military units were something that you

23     informed the national authorities in Sarajevo about; right?

24        A.   Well, yes, it's true and even before that units were being

25     established, materiel was being relocated and so on.  You know that full

Page 17697

 1     well.  You told your men where these vast amounts of weaponry were

 2     supposed to be relocated even in the spring of 1991 even before the

 3     aggression in Croatia or in that period.

 4        Q.   Are you trying to say that I had powers over the

 5     Yugoslav People's Army?

 6        A.   Absolutely.  Absolutely.  You had reached a compromise with

 7     Milosevic and the military leadership.  It was no longer a Yugoslav Army.

 8     It was cleansed of Catholics, Muslims, Macedonians, et cetera.  It was

 9     basically 99 per cent Serb, and it was you, Karadzic, and your horrible

10     units.  You were in charge.  And if we had weapons the way you did, there

11     would never have been that kind of suffering because you are free only

12     when you can display force against others.

13        Q.   Please let us focus on the facts.  Do you have any proof of me

14     having authority over the JNA, and if so, can you give this evidence to

15     the Trial Chamber or the Prosecution?

16        A.   As far as I know, at the highest level of the SDS there were

17     people who were in charge of talking to others and at a particular level.

18     Your role and task was to talk to Milosevic and, of course, through him

19     with the army as well.  You're the one who is responsible, not only in

20     view of the Bosniak Muslim people but also the Serb people and the

21     Catholic people.  You are responsible for everything that happened in

22     Bosnia, you and your followers.  You cannot excuse yourself from that.

23     Your own people are going to damn you for that.

24        Q.   Mr. Witness, with all due respect, if you want me to be convicted

25     leave political statements aside.  Provide facts that prove what you are

Page 17698

 1     trying to say and what you feel about me.  Give proof.  But now let us go

 2     back to what you said on different occasions, and please respond to

 3     questions.

 4             Is it correct that before the war -- or, rather, that you said

 5     that before the war there was no open conflict between the Serbs and

 6     Muslims in the Executive Board of the municipality and parliament but

 7     there were conflicts among the people?

 8        A.   That is not correct.  That is not what I said.  I said that there

 9     were no conflicts ever.  Man, do you understand what I'm saying?  People

10     respected themselves to such a high degree.

11        Q.   With all due respect, I will need a week to examine you,

12     Mr. Redzic, not only an hour and a half.  Please look at your statement

13     of the 12th of October, 1994.  That is 65 ter 22597.  On page 5, I'm

14     going to read it out so that the translation is better than the one I

15     provide.  So I'm going to read it out in English.

16             "[In English][Previous translation continues] ... Prior to the

17     beginning of the war there were no open conflicts between the Muslims and

18     Serbs in the Executive Council and the parliament, but there were

19     conflicts between people."

20             [Interpretation] Are you trying to say that the government

21     functioned properly but that there were conflicts and tensions among the

22     people?

23        A.   No, absolutely not.  That is taken out of context.  I was saying

24     that there were individual clashes like anywhere in the world.  Hoodlums

25     can fight and so what, but that there was any kind of hatred on ethnic

Page 17699

 1     grounds I categorically reject that.  And I'm not only talking about

 2     Vlasenica but all of Bosnia-Herzegovina.

 3        Q.   Thank you.  You said on the same page, the same document, you

 4     said that you believed that Serb officials in the Assembly and in the SDS

 5     were secretly preparing a war.  Is that what that you believed or is that

 6     something you have proof of?

 7        A.   In view of what I know, the truth as you know yourself is that

 8     the Serbs --

 9        Q.   Wait a moment, please.  I cannot --

10        A.   I'm going to give you five or six examples that will show that

11     you were, indeed, preparing everything that happened in

12     Bosnia-Herzegovina.

13             You know about the decisions of the establishment of the Serbian

14     Republic and also the instructions on the establishment of Serb

15     municipalities and local communes of municipalities.  You know

16     alternatives A and B, the solutions at first and second level.  All of

17     that is what you and people who thought like you did.  You know what the

18     other documents were that you adopted and that you implemented.  Are you

19     trying to say that you don't know, you don't know what you did for the

20     referendum?  Do you know to what extent you indoctrinated the people so

21     even those poor peasants the most honourable of people had to take up

22     arms and fight against Muslims and Catholics?  It is so ugly to be

23     putting these questions today when the entire world knows what you did.

24     May God forbid that you ever leave this courtroom otherwise who knows

25     what will happen.

Page 17700

 1        Q.   Mr. Redzic, please tell the Prosecution everything you know.

 2     Rest assured that they are going to use all of it if you have any such

 3     thing.  Now let us deal with your statements.  Let us see what your

 4     opinion is, what your feelings are, and what is your indubitable

 5     knowledge.  Before this Court we need to see what your knowledge is that

 6     cannot be disputed or challenged.  Please help us learn that.

 7             In this same statement on the same page 5 you said that people

 8     would confuse you with Stanic.  Is it not correct that Stanic is

 9     considerably younger than you are, considerably taller than you are, and

10     considerably lighter than you are?

11        A.   Yes, he is seven years younger and I repeat once again:  We know

12     that the rural area is rather illiterate both the Muslim and Serb areas

13     and that indeed these people did come to municipal structures to complain

14     about the distribution of weapons by the SDS to Serb members of that

15     political party.  That is the truth, and these people had never seen

16     either Stanic or myself.

17        Q.   So they came to see you to complain.  Serbs complained against

18     Serbs, and they came to see you.  You claim that they came to you because

19     they thought that you were Stanic and I claim that they came to you

20     because they knew that you were a Muslim but you were simply in power and

21     that they trusted you.  Why are you ruling that out?

22        A.   Absolutely not.  It's not their role to come and see a Muslim.

23     Their role was to come to complain to the key man of the SDS, and they

24     did not know that in a single room there was this secretary of mine and

25     Mr. Stanic's.  In view of everything that awaited us, all the problems

Page 17701

 1     that we were facing, don't you understand I told the secretary that if

 2     Stanic was not there she should direct everyone to see me, everyone who

 3     came there to that office, and that is how I found out what was happening

 4     in these villages that were 30 kilometres from the centre of Vlasenica.

 5     And sometimes some of these people would come to Vlasenica only twice a

 6     year, to the fair to sell their wheat and whatever else they produced.

 7     Don't you understand that, man?

 8        Q.   I don't know how to implore you, Mr. Redzic, just to answer my

 9     questions.  We don't have time for all of this.  We'll be here for a

10     week.  I'm going to put questions that require only a yes or no answer.

11             JUDGE KWON:  If you put the question that can be answered by yes

12     or no, Mr. Karadzic.

13             THE ACCUSED: [Interpretation] Thank you.

14             MR. KARADZIC: [Interpretation]

15        Q.   Did you state that they complained to you that Izetbegovic's

16     policy was to create a Muslim state and that Serbs would be killed if

17     they cannot defend themselves?  Is that correct?

18        A.   You should not take things out of context.  It is true that I and

19     Stanic visited Serb areas and that in conversations with people, Serbs,

20     we asked why they had so many weapons.  Even children, 15-year-old

21     children had automatic weapons, and I said why did you have all of that?

22     However, what they came to believe was that Alija would try to impose

23     some kind of dzamahirija and there would be some Turks that would be

24     killing them and whatever.

25        Q.   Thank you.  Have you heard of the Islamic Declaration?

Page 17702

 1        A.   Yes, I have heard of it, but perhaps you analyse it to a greater

 2     degree than I did.

 3        Q.   Thank you.  Did they protest with you against Bjelanovic who was

 4     not giving them any weapons?

 5        A.   Well, in general that's what they were saying, that it was only

 6     SDS members who were getting weapons and that they were not giving other

 7     Serbs weapons yet.  I tried to pacify them and say that once the SDS

 8     members receive weapons they would be receiving weapons too.  You

 9     understand that we were not little sheep, Radovan.  We realised what was

10     in the making.  We realised that there would be a genocide.  We needed to

11     have basic things at least and we had to tell the republican government

12     to tell the international community during negotiations that they should

13     provide weapons so the people could defend themselves.

14        Q.   Then you started arming the Muslims?

15        A.   What do you mean, arming?  No way.  The Muslim people only had

16     hunting guns that those who thought like you asked the people of

17     Vlasenica to return and even that could not save their lives.  They

18     killed so many people.

19             THE ACCUSED: [Interpretation] This is for the learned

20     Ms. Sutherland.  Mr. Redzic said that he was president of the Council for

21     National Defence in his statement of the 12th of October, 1994, on page

22     00148598 [as interpreted].

23             MR. KARADZIC: [Interpretation]

24        Q.   Mr. Redzic, I'll have to think of some way to do this more

25     efficiently.  Are you saying that in Vlasenica there was no unit of the

Page 17703

 1     Patriotic League, the staff of the Patriotic League, the commander of

 2     that unit, that all of that did not exist and the Muslim community in

 3     Vlasenica was not armed illegally?  Are you saying that or not?

 4        A.   I have to say the Patriotic League is absolutely not a military

 5     formation.  Those are patriots from all communities and they would

 6     explain, explaining to Serbs and Muslims and Catholics and other faiths

 7     that Serb SDS was not telling the truth, that they will lead them to

 8     catastrophe.

 9        Q.   Anyway there was an organisation of the Patriotic League in

10     Vlasenica?

11        A.   No, definitely not.

12        Q.   Do you know, witness, that apart from Croatian municipalities in

13     Western Herzegovina that would be the only municipality in Bosnia and

14     Herzegovina that would not have had a unit of the Patriotic League as

15     early as September 1991?

16        A.   I'm saying the Patriotic League is absolutely not a military

17     organisation.  It's a league of patriots that would try to dissuade the

18     people from following you and falling for your deceit and deception.  I

19     would have known in my position.

20        Q.   Can we briefly see 1D4055.  Do you see that this is a criminal

21     report against Mustafa Zildzic, and it says that early in 1992, in

22     January, February, March and April, he was in possession of an automatic

23     weapon that the citizens were prohibited from acquiring at all, and he

24     also had a large number of other weapons that he distributed amongst his

25     neighbours.  Did this man exist?

Page 17704

 1        A.   If he did distribute weapons, I would be surprised to hear that

 2     he's still alive, because in those times, such people would have been

 3     liquidated.  This man is alive, and he lives in Tuzla, and he works

 4     there.  Where does this criminal report come from, from what sources?  I

 5     don't know.  I can't comment.

 6        Q.   The MUP reported this to the public prosecutor in May, and you

 7     see that he survived the Serbian police and the Serbian courts,

 8     Mr. Redzic.  Although he not only had weapons in his personal possession,

 9     but he had an arsenal that he distributed to others.

10             THE ACCUSED: [Interpretation] Anyway, can this report be

11     admitted?

12             JUDGE KWON:  I wonder on what basis we can admit this.

13             Did -- Mr. Redzic, did you know that this man distributed the

14     weapons at the time?

15             THE WITNESS: [Interpretation] No way.  In that time I was not in

16     Vlasenica at all.  This is dated 8 May 1992.  I had left Vlasenica

17     already, but I'm just saying that I doubt this, because this person would

18     not be alive today if this document were correct.

19             MR. KARADZIC: [Interpretation]

20        Q.   Can I just clarify that this was committed in the first months of

21     1991 when Mr. Redzic was in Vlasenica?  You see the -- the passage in the

22     box.

23        A.   And this is early 1992.  What kind of report and what kind of

24     charges are these?  It's obvious that this document was prepared for

25     somebody's defence.

Page 17705

 1             This report was made in 1992.  It could have been done on New

 2     Year's Eve, Saint George's day.

 3        Q.   Are you trying to say this was forged for the purposes of my

 4     defence?

 5        A.   You said it.

 6             JUDGE KWON:  Ms. Sutherland, can I hear you on this matter?

 7             MS. SUTHERLAND:  Your Honour, I don't see anything about 1991 in

 8     the document.

 9             JUDGE KWON:  Can you see the page 1?

10             THE ACCUSED: [Interpretation] 1992.

11             THE WITNESS: [Interpretation] 1992.  21 April 1992.  It's written

12     at the bottom of the page.

13             JUDGE KWON:  I don't understand 1991 either, Ms. Sutherland.

14             THE ACCUSED: [Interpretation] Maybe it's a matter of

15     misinterpretation.  I said early 1992, several months in early 1992.  In

16     legal language it's called unidentified dates, but it's a continuous

17     activity.  It's not a one-off thing.

18             JUDGE KWON:  Yes, Ms. Sutherland.

19             MS. SUTHERLAND:  Just a moment, Your Honour.  Your Honour, the

20     witness, although, the witness said he wasn't aware of Mr. Turkovic

21     distributing weapons in the early part of 1992 when he was in the

22     municipality, it does go -- it does talk about events in the municipality

23     at that period of time, so I leave it to Your Honours whether the

24     document should be admitted or not.

25                           [Trial Chamber confers]

Page 17706

 1             JUDGE KWON:  Thank you, Ms. Sutherland.  On that basis we receive

 2     this document.

 3             THE REGISTRAR:  As Exhibit D1646, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Have you noticed, Witness, that he received these weapons from

 6     Mr. Turkovic?

 7        A.   I don't know anything about this document.  It looks suspicious

 8     to me.  I don't know from which sources it could have been obtained.  I

 9     would not like to comment, and it concerns a period when I had already

10     left Vlasenica.

11        Q.   Thank you.  Could we look at 1D4056.

12             MS. SUTHERLAND:  I'm sorry, Your Honour.  I was going to ask

13     Mr. Karadzic when the last document came up about the -- or the first

14     document came up about the census.  Where it's a lengthy document, if

15     it's a four or five-page document could Mr. Karadzic tell the -- perhaps

16     it might assist the witness if he knows the source of the document and

17     the person that's actually the author of the document.

18             JUDGE KWON:  Thank you.  Very kind of you, Ms. Sutherland.

19             I note the time, Mr. Karadzic.  We'll have a break for 25

20     minutes, after which I would like you to plan your cross-examination in a

21     more efficient way.  Please bear in mind that you don't have to put

22     everything to every witness.

23             We'll resume at 4.00.

24                           --- Recess taken at 3.35 p.m.

25                           --- On resuming at 4.06 p.m.

Page 17707

 1             JUDGE KWON:  Yes, Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Witness, believe me, I'm not trying to attack you in any way.

 5     I'm just searching for the truth.  You don't have to know everything, but

 6     it's important to me to know why, on what basis, you stated something.

 7     Let's deal with documents.  1D4056 is the document I would like to see

 8     next.

 9             Did the Party of Democratic Action deal with the issues of

10     establishing the Muslim MUP?

11        A.   No, not at all.  At that time, as far as the Muslims are

12     concerned, the party did not play any role.  They were state officials,

13     and they acted in accordance with the constitution and the law.

14        Q.   Thank you.  Did the parties send anyone from Vlasenica to a

15     training course in Croatia, a police course?

16        A.   Not that I know.

17        Q.   Could you look at this.  I believe there's a translation.  On 11

18     July 1991, Hasan Cengic, and somebody signed it on his behalf,

19     Hasan Cengic is the acting secretary of the SDA, and he sent, to

20     presidents of Executive Boards, this letter saying:

21             "Hereby attached we are sending you a copy of a document about

22     the admission procedure for candidates for the police force into the MUP

23     of Bosnia and Herzegovina."

24             Did you know about this?

25        A.   No.

Page 17708

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Can this be admitted?

 3             JUDGE KWON:  Is this related to Vlasenica, Mr. Karadzic?

 4             THE ACCUSED: [Interpretation] It says "To all presidents of

 5     Executive Boards."  It says "copied to," and this is left blank for all

 6     municipalities.

 7             JUDGE KWON:  Ms. Sutherland.

 8             MS. SUTHERLAND:  Your Honour, the witness said he was President

 9     of the Executive Board of the Municipal Assembly of Vlasenica.  He said

10     he knows nothing about this document.  There's no translation, and I

11     don't think it should be admitted at this stage.

12             JUDGE KWON:  Have we not admitted similar documents that talk

13     about these identical issues before, Mr. Karadzic?

14             THE ACCUSED: [Interpretation] There was a similar document, a

15     similar instruction.  This is just the cover letter, and what we had

16     admitted before was an instruction listing the names of certain

17     candidates.  This is part of this entire drive by the SDA.

18             JUDGE KWON:  If this is just a cover letter of the document that

19     has been admitted, that part can be admitted through a proper bar table

20     motion.  I don't think this is a proper witness to give foundation as to

21     this document, Mr. Karadzic.

22             THE ACCUSED: [Interpretation] Thank you.  We can do it that way

23     too.

24             Could we now see 1D4057.

25             MR. KARADZIC: [Interpretation].

Page 17709

 1        Q.   Do you know who Mirsad Srebrenikovic is?

 2        A.   No.  That is not the surname that we encountered in Vlasenica.

 3        Q.   He was in the ministry.  He was a priest, a hodza, assistant

 4     minister for religious affairs.

 5        A.   No way.  I think it's inappropriate that organs infiltrated into

 6     municipal institutions deal with priests and religious affairs, that such

 7     people should occupy such important positions.  I don't think it happened

 8     in the Vlasenica, in the republic or any other municipality.

 9        Q.   Are you saying that Mirsad Srebrenikovic was not a hodza or that

10     if he was, he was not assistant minister?

11        A.   I'm not saying that about the person you named.  Perhaps through

12     state authorities he was infiltrated to that position.  I don't know if

13     he ever occupied that position or how.

14        Q.   Look at this, the list of candidates admitted to a training

15     course for policemen.  Let us see the next page now.  You will see,

16     Witness, that there are less than 10 per cent Serbs on this list, and you

17     will see that there are candidates nominated from your municipality as

18     well.

19             We can leaf through the document.  Do you see that it's 90 per

20     cent Muslim, this force?

21        A.   I don't know, but I'll tell you the exact number of Serbs on the

22     police force in the active-duty police and the reserve police before the

23     aggression.  What you are stating are counter-indicators.  In the reserve

24     force of Vlasenica there were 80 per cent Serbs, between 70 and 80 per

25     cent, and in the active force there were also 70 to 80 per cent Serbs.

Page 17710

 1     And then the tables were turned.  I believe it was exactly the opposite.

 2     There were too many Serbs, disproportionately many to the actual ethnic

 3     composition of the municipality.

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

 5             JUDGE KWON:  Can we show him page 8 in B/C/S.  There are two or

 6     three -- two candidates from Vlasenica.  Do you by any chance know them?

 7             THE WITNESS: [Interpretation] Well, I don't know them personally,

 8     but I know their last names, and they live at these addresses that are

 9     referred to; that is where these families live.  However, I repeat once

10     again:  I don't know from which archives this material came and who

11     compiled this.

12             MR. KARADZIC: [Interpretation]

13        Q.   If it can help you, Mr. Witness, it's from the Ministry of the

14     Interior, the joint ministry of Bosnia-Herzegovina.

15             JUDGE KWON:  Show the first page.  Show the witness the first

16     page.

17             MR. KARADZIC: [Interpretation]

18        Q.   "To all chiefs of public security stations, the MUP of

19     Bosnia-Herzegovina," number such and such, the 12th of March, 1992.

20     Telegram, telefax.  It's their telex, actually.

21        A.   Yes, but I don't see a stamp.  In our part of the world, in

22     Bosnia, that is a sacred thing.  There has to be a stamp.  And I seem to

23     have the impression that this is incorrect, incorrect indicators that you

24     are showing me.

25        Q.   Sir, a telex cannot be signed or stamped at that time.

Page 17711

 1        A.   It can be seen.  It can be stamped in one way or the other.  This

 2     document is not binding.

 3             JUDGE KWON:  Yes.  This can be admitted.

 4             THE REGISTRAR:  As Exhibit D1647, Your Honours.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   1D4058.  Can we have a look at that, please.  Please, could you

 8     focus on this.  This is the prosecutor's office in Vlasenica.  It's a

 9     criminal report, number 1, Becir Mekanic, the person you mentioned.  He

10     was president of the municipality in the days of the Communists.

11             Now, this is what he is being charged with.  Number 5 is also a

12     man from Vlasenica, Fadil Turkovic.  Did you know Fadil Turkovic?

13        A.   Yes, we already talked about him.

14        Q.   He was in the police, right?

15        A.   Yes, yes.  Commander of the Vlasenica police.

16        Q.   Thank you.

17        A.   No, no, no.  Just a moment.  Please take a look at the date of

18     this document.  1993, the 17th of June, 1993.  The date itself associates

19     all the previous actions taken and the intentions with which these

20     actions were taken by certain parties.

21        Q.   Can we have a look at the next page to see what they're being

22     charged with.  You see what it says here?  Because, due to, they killed

23     five civilians in Rupovo Brdo.  Do you know where Rupovo Brdo?

24        A.   Yes, of course.  I worked at the bauxite mine.  It is only

25     logical that I should know all of that.  Now, whether they killed them,

Page 17712

 1     that is debatable.  I cannot testify as to whether they had killed them

 2     or someone else or whether they were killed in fighting or something like

 3     that.  I'm absolutely not going to say anything about that.  It is not

 4     for me to say, especially not to speak about that particular point in

 5     time.  I was far away in Tuzla and I was barley surviving.

 6             THE ACCUSED: [Interpretation] Excellencies, what do we do with

 7     this document?

 8             JUDGE KWON:  You will have another opportunity to tender this

 9     document.

10             THE ACCUSED: [Interpretation] Thank you.  1D4059.  Can we have

11     that.

12             MR. KARADZIC: [Interpretation]

13        Q.   Did you know Behto Kahrimanovic, Kasim's son?

14        A.   No.

15        Q.   Please take a look at the Serbian version.  Bosnia-Herzegovina,

16     the 8th of June, 1991.  So it was the joint Bosnia-Herzegovina.

17     Kahrimanovic is giving a statement.  He was a taxi driver in Vlasenica.

18     He had done his military service.  He's a Muslim, a citizen of the SFRY,

19     and so on and so forth.  And then further down what is encircled.  It

20     says four months ago the SUP of Zvornik took away two of my rifles and

21     one pistol.  Also the traffic police from Zvornik found in my car and

22     took away 1.119 bullets, including 500 for small-calibre gun, 444 for a

23     7.62 millimetre gun and so on and so forth.  And also in Holmec at the

24     border crossing, four M-48 rifles were found by the customs officials

25     that I bought in Austria with Amir Halilovic from Kula Grad in Zvornik.

Page 17713

 1             Can we have the next page now.  You seek the encircled part here.

 2     It says:

 3             "I proposed to Sulejman that his wife come along as well so that

 4     we would be less conspicuous and of his own initiative he took his son.

 5     Sulejman's wife Hura knew what we were taking along.  I believe that the

 6     child didn't know.  The two of them were sitting in the back...," and so

 7     on and so forth.  So it's your secretariat when you were in power in

 8     Vlasenica that took this statement.  Are you trying to say that you did

 9     not know about this?

10        A.   We were never in power in Vlasenica, we, I mean.  We were in

11     power together with the Serbs and other ethnic communities.  Now, whether

12     the statement is correct and who took this statement, whoever took this

13     statement was supposed to sign this and the appropriate organ was

14     supposed to verify this.  This has to do with a crime.  Not in any remote

15     backwater of the world would this kind of paper be valid.  Invoking our

16     own government, that defies common sense and --

17        Q.   Thank you, thank you.  I'm just asking you whether you knew that

18     your secretariat, your police, that is part of the executive government

19     that you headed, captured all of this and took this statement from the

20     perpetrator.

21        A.   I'm not aware of this, but I claim once again that these are your

22     versions, versions of yours and of people who think like you.

23        Q.   Thank you, thank you.

24             THE ACCUSED: [Interpretation] Can this be admitted?  It's very

25     important for the Defence what the witness does not know and what he

Page 17714

 1     should have known and what he should know and what he should be able to

 2     speak about.

 3             JUDGE KWON:  By now you have to know how to deal with the

 4     unfriendly, so to speak, unfriendly witnesses.  You may call

 5     Mr. Kahrimanovic later on.  There's no basis to admit this statement.

 6     We'll not admit this.

 7             THE ACCUSED: [Interpretation] 1D4060.  Can we have that, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Do you know that in June in the village of Hurici in your area

10     weapons were being distributed, and do you know that your police compiled

11     an official note about that?

12        A.   Well, I know the village of Sadici, the neighbouring village.

13     Together with the president, I toured that village.  I don't know

14     anything who could have distribute used anything?  Nothing, for heaven's

15     sake, man, I don't know anything about this.

16        Q.   Please take a look at this document from Vlasenica, the 17th of

17     June.  There is a signature of Milenko Sargic.  There is a number, too.

18     Who was Milenko Sargic?

19        A.   I think he was one of the inspectors there.  He was a hardened

20     member of the SDS and later on he proved to be the executor of your

21     policy and so on and so forth.

22        Q.   Do you see that information was collected to the effect that in

23     the village of Sadici, the hamlet of Hurici, weapons were being

24     distributed.  And Muslims lived in Sadici or Hurici, you just mentioned

25     that?

Page 17715

 1        A.   Serbs and Muslims.  Hurici is a hamlet inhabited by Muslims, yes,

 2     whereas Sadici includes Lazarevici and it's a mixed community anyway.

 3     The population is mixed Muslims and Serbs.

 4        Q.   Thank you.

 5             THE ACCUSED: [Interpretation] Can this be admitted.

 6             JUDGE KWON:  I take it there's no position.

 7             MS. SUTHERLAND:  That's correct, Your Honour.

 8             JUDGE KWON:  This will be admitted.

 9             THE REGISTRAR:  As Exhibit D1648, Your Honours.

10             THE ACCUSED: [Interpretation] 1D4061.

11             MR. KARADZIC: [Interpretation]

12        Q.   Have you heard of Operation Oroz?

13        A.   No.

14        Q.   This is your municipality, your Secretariat of the Interior on

15     the 24th of June, 1991.  Basic plan of engagement in Operation Oroz and

16     it says here that the security situation is complex in the republic and

17     inter-ethnic and even inter-republican relations have been disrupted and

18     that led to an increase in illegal weapons and ammunition trade.  This

19     station has information that confirms the assessment that the area of

20     Vlasenica municipality is not immune to this sort of occurrence either

21     and so on and so forth.  And it also says that Behto Kahrimanovic from

22     Kovacevici had weapons and ammunition seized from him.  We saw his

23     statement a moment ago.  Can we have the next page please.

24             Who was Mirhad Huremovic [phoen]?

25        A.   A person who worked in the MUP.  Let me just say something.  This

Page 17716

 1     report could only be compiled by the chief, that is, your man from the

 2     SDS.  That could be seen very nicely.  At that point the chief of MUP in

 3     Vlasenica, I mean at that time you hadn't divided Vlasenica.  At that

 4     time you were not creating any sort of major problem because you were

 5     carrying out preparations.  So it was your man who compiled this

 6     information so that it worked in your favour.

 7        Q.   You see, well, my man said that your man should be in charge of

 8     the file on Operation Oroz and will be directly responsible for that and

 9     for collecting information about the distribution of weapons.

10        A.   That is inaccurate.  Let us not try to persuade each other and

11     let us tire the gentlemen here.  It is incorrect.  You were preparing for

12     everything that would follow.  Totally incorrect.

13        Q.   Are you trying to say that there was no Operation Oroz and

14     Radomir Bjelanovic, a Serb, did not appoint Mirhad Huremovic a Muslim as

15     a person in charge of this operation of supervising what was going in

16     terms of weapons smuggling?

17        A.   You should call Huremovic and ask him about that.  They did not

18     inform me about many other things either.  They said that the MUP

19     belonged to the republican MUP directly.  I claim with full

20     responsibility that this is incorrect.  You should call Mr. Huremovic and

21     he should give you his view whether this is truthful or not, or whether

22     it's a forgery.

23        Q.   Thank you.  Could I have page 1 again.  Is this a usual type of

24     document in your municipality and could we find something like that in

25     the registers there?  You see here it has been registered.  Could we

Page 17717

 1     please have the first page in Serbian.

 2             Is this the usual way of writing up an official document?

 3        A.   One does know what an official document should look like.

 4     However, official documents can be forged, and you and your people were

 5     prepared to do anything if necessary to tear up everything that had to do

 6     with what happened over ten years and you could embark on such

 7     adventures.  I wouldn't be surprised at any of that.

 8        Q.   On the 24th of June, 2001, I wanted to tear up Bosnia; is that

 9     right?

10        A.   What year?

11        Q.   The 26th of June, 1991.

12        A.   A lot earlier.  A lot earlier.  You started these actions and

13     operations aimed at tearing up Bosnia, because it was too small for you,

14     52.000 square kilometres.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can this document be admitted?

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Exhibit D1649, Your Honours.

19             THE ACCUSED: [Interpretation] Can we have 1D4109.  Let us see how

20     I was dividing up Bosnia.

21             MR. KARADZIC: [Interpretation]

22        Q.   Do you know who Adil Zulfikarpasic was?

23        A.   Yes.

24        Q.   Is it correct that Adil Zulfikarpasic was the president of the

25     second-largest Muslim political party?

Page 17718

 1        A.   Yes.

 2        Q.   Unfortunately, we do not have a translation.  However, you have

 3     made me through your answer call up this document.  Do you see

 4     Radovan Karadzic and Adil Zulfikarpasic at a panel discussion in Zvornik

 5     since this is written in Cyrillic the date is the 17th of August, 1991.

 6     Please help the Trial Chamber and tell them:  Is that what is written

 7     here?

 8        A.   Well, I know what you had in your heads, I assume, and the fact

 9     that you were misleading Zulfikarpasic or was Zulfikarpasic trying to

10     prevent bloodshed in different ways also like other people who were in

11     power from the SDA.  In all sorts of ways we tried to avoid the bloodshed

12     that you were planning with your followers.

13             As for this here, I don't know.  You probably didn't --

14        Q.   Thank you.  It's easy to prove all of that.  You think that I got

15     a hold of this old political --

16        A.   [Overlapping speakers] [No interpretation]

17             JUDGE KWON:  If you do not pause before you start answering the

18     question, interpreters find it very difficult to follow.

19             Yes, Ms. Sutherland.

20             MS. SUTHERLAND:  Your Honour, I'm also finding it difficult to

21     follow.  This wasn't on Mr. Karadzic's list that he provided at the

22     beginning of this witness's cross-examination.  He said then it was only

23     because of the answer that the witness gave that he then called this

24     document up.  However, there's no translation, and I'm at a loss to

25     actually know what it says.

Page 17719

 1             JUDGE KWON:  True.

 2             MS. SUTHERLAND:  So I can give you no input whatsoever on the

 3     document.

 4             JUDGE KWON:  Yes.  I found it difficult to follow that his answer

 5     made him call up this document now.  But the last question was what?  The

 6     last question and answer, both the question and the answers were not

 7     reflected in the transcript, because both of you overlapped and you spoke

 8     simply too fast.

 9             What was your question, Mr. Karadzic?

10             MR. KARADZIC: [Interpretation]

11        Q.   My question was:  When I put the previous document to the

12     witness, the last one to be admitted, which shows that the smuggling of

13     arms in Vlasenica had reached large proportions and the Serb chief of the

14     police station appointed a Muslim police inspector to lead this drive,

15     this gentleman said the document was forged by me and my people who were

16     tearing up Bosnia.  My question was:  Is it the case that on 24 June,

17     1991, I was in favour of breaking up Bosnia, and he said yes.  And this

18     is a document showing that both Zulfikarpasic and I were fighting for

19     Bosnia to remain together.  This was a public debate.  It was mentioned

20     with other witnesses.  Zulfikarpasic was a long-time democrat.  He had

21     emigrated at one point and then returned.  We can very briefly summarise

22     this document and see what we both advocated.

23             JUDGE KWON:  And your question for the witness, Mr. Karadzic?

24             MR. KARADZIC: [Interpretation]

25        Q.   My question is, Witness, based on what do you claim that I wanted

Page 17720

 1     to see Bosnia divided when you see that on 18 August 1991 I was

 2     campaigning to keep Bosnia as it was with a very renowned Muslim

 3     politician, leader of a party?

 4        A.   On what basis do I claim that you were aiming to divide Bosnia?

 5     It's not difficult to prove.  There were many papers and documents that

 6     you passed on to lower levels.  By this time you had established

 7     everything that a parastate should have in its system.  You armed your

 8     paramilitaries.  You formed your paramilitaries.

 9             Now, this is questionable.  I don't know if this is an authentic

10     document.  Who wrote this?  I don't want to testify against this late

11     Adil Zulfikarpasic.  I don't want to comment on what you or he said

12     allegedly.

13        Q.   Do you know that we Bosnian Serbs, for the sake of this

14     agreement, gave up all our ideas for regionalisation and all the other

15     measures that had been already announced?  Do you know that this was a

16     major campaign that lasted two months, and you knew nothing about it?  It

17     lasted the whole of July and August.  Zulfikarpasic and I were literally

18     fighting for Bosnia to remain together.

19        A.   Yes, you did fight, and you managed to bring it down.  How -- how

20     can you say one thing and do something entirely different on the ground?

21     We know what the facts are, and you are trying to persuade us that you

22     were a peacekeeper, the person who caused the greatest genocide after the

23     Second World War, who misled all the people, all the Serbian people in

24     huge numbers who did not want to follow you originally.

25             THE ACCUSED: [Interpretation] Can this be admitted or MFI'd?

Page 17721

 1     This is a news report from that public debate where we said very

 2     important things.  If I may just quote from the middle of the second

 3     column where Zulfikarpasic explains that Izetbegovic had withdrawn his

 4     support for that agreement.  If I may read it out, or perhaps this can be

 5     MFI'd and then it can be useful to you if you want to look into this.

 6             JUDGE KWON:  Ms. Sutherland.

 7             MS. SUTHERLAND:  Your Honour, as is the practice of the Chamber

 8     not to admit newspaper articles, this is what it appears to me to be.  So

 9     I would object to it being admitted.

10             MR. ROBINSON:  Excuse me, Mr. President.  I think the practice is

11     not to admit newspaper articles from the bar table.

12             JUDGE KWON:  In light of the witness's answer that the accused

13     was misleading Zulfikarpasic at the time and Zulfikarpasic was trying to

14     prevent bloodshed in different ways, whether it may be relevant to

15     understand the context of what was happening at the time and given the

16     previous answers of the witness together with the witness's submission --

17     accused's submission.  I'll consult my colleagues.

18                           [Trial Chamber confers]

19             JUDGE KWON:  We'll mark it for identification.

20             THE REGISTRAR:  As MFI D1650, Your Honours.

21             JUDGE KWON:  Pending English translation.

22             MR. KARADZIC: [Interpretation]

23        Q.   1D4065 is the next document I would like to call up to see that

24     in Vlasenica while you were at the head of the executive authorities

25     there existed, indeed, the Patriotic League.  1D4065.

Page 17722

 1             Don't be confused by this date, 9 August 1992, because the

 2     document speaks of events that had started much earlier.  It says that

 3     the Chief of Staff of the PS of Vlasenica, Chief of Staff of the armed

 4     forces of Vlasenica, Adil Omerovic, graduated from the maritime academy

 5     and came to Vlasenica on 19 May.  And then further below -- could we see

 6     the next page.

 7             You see the first box.  The clerk in charge of personnel and

 8     personnel affairs, Zaim Aliustic, born in 1963, I suppose, graduated from

 9     a teachers' school, reserve officer, completed a course for commanders

10     and has been actively participating since December 1991 in defence

11     preparations of the Patriotic League.  And further below all these

12     documents show that the Patriotic League existed in Vlasenica as early as

13     that time; correct?

14        A.   This document was written in August 1992.  It originated probably

15     in the area of Cerska.  I cannot say anything about this document.  I was

16     not in Vlasenica then.  I was in Tuzla.  You can see the date.  You can

17     see who drafted it.  It has a stamp on it, but I have no knowledge about

18     it.  This is the first time I see it.  And you also quote names that are

19     not from the municipality of Vlasenica.  This man who is a graduate of

20     the maritime academy is not from Vlasenica at all.  I know none of these

21     people, and you are trying to put this paper to me as proof that the

22     Patriotic League existed.  And by the way, it was not a military

23     organisation.  Those were patriots who were trying to convince Serbs and

24     Muslims not to fall for your deception.

25        Q.   Let's see.  The staff of the armed forces of Tuzla, armed forces

Page 17723

 1     of Vlasenica.  Those are the addressees.  Is Cerska in Vlasenica

 2     municipality?

 3        A.   Yes, but there was free territory in Cerska.  This man who signed

 4     this and put a stamp here lived in Cerska, and there was a section that

 5     he authorised to maintain contact with other services.

 6        Q.   Thank you.

 7             THE ACCUSED: [Interpretation] Can this be admitted?  It proves

 8     that this man was active from December 1991 --

 9             THE WITNESS: [Interpretation] I'm not proving anything.

10             MR. KARADZIC: [Interpretation]

11        Q.   No.  The document proves that this man, Zaim Aliustic was active

12     on behalf of the Patriotic League beginning with December 1991.  I'm

13     addressing the Chamber now, Witness.

14             JUDGE KWON:  Can you -- Mr. Karadzic, you are using so many

15     untranslated documents.  We'll mark it for identification.

16             THE REGISTRAR:  As MFI D1651, Your Honours.

17             THE ACCUSED: [Interpretation] Thank you for your understanding,

18     but this is a witness who is much too baroque as so many things follow

19     from his statements.

20             MR. KARADZIC: [Interpretation]

21        Q.   Could we now see 1D4062, please.

22             MS. SUTHERLAND:  Your Honour, I'm sorry to interrupt, but I don't

23     understand Mr. Karadzic's last point.  This is a document that he listed

24     on his 65 ter list of documents, of cross documents that he's going to

25     use and so they should be translated.

Page 17724

 1             JUDGE KWON:  Yes.

 2             THE ACCUSED: [Interpretation] We would do it all if we had time.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Is this from the Municipal Staff of the armed forces of

 5     Vlasenica, Republic of Bosnia-Herzegovina, 19 July 1992?  So it's the

 6     Muslim segment; correct?  At that time, it was no longer a joint

 7     municipality.

 8        A.   I don't know where it was from.  Cerska, that's where the staff

 9     was at the time.  It refers to the armed forces of Vlasenica, which

10     should mean the entire complex of the municipality.

11        Q.   Look at the box in the first paragraph.  I quote:

12             "With the order on the disbandment of the original staff of the

13     Territorial Defence of Bosnia and Herzegovina and the formation of the TO

14     staff of the RBH, Muslim and Serbian staffs were set up based on ethnic

15     criteria.

16             "By 15 April 1992, as a commander -- as commander of the

17     Vlasenica TO, acting on my own orders, I set up our regional defence

18     sector staffs for Djile, Stedra and Vrsinje areas and appointed the

19     commander of TO detachments and anti-sabotage platoons which were set up

20     and mobilised.  Their first combat actions against the enemy lasted from

21     the 2nd to the 7th of May, 1992, after which they were smashed and parts

22     of them joined the Srebrenica and Zepa TOs.  Meanwhile, from 10 to 21

23     April, 1992, when the Chetniks stormed the town of Vlasenica, all

24     political business and state leaders fled, leaving the people at the

25     mercy of the occupiers...," and so on and so forth.  Do you know this

Page 17725

 1     Ferid Hodzic who wrote this?

 2        A.   I know Ferid Hodzic, but I don't know this document nor can I say

 3     anything about it.

 4        Q.   But is it true that this joint TO was disbanded on his orders and

 5     two ethnic ones were set up?

 6        A.   Of course not.  You know it is not up to local TOs to make such

 7     decisions.  The republic and regional authorities are the only ones

 8     competent and authorised to make such decisions.  So this cannot be a

 9     true statement.

10        Q.   Do you see that he refers to the disbandment of the regional

11     staff of the TO and the formation of the TO staff -- Muslim and Serbian

12     staff were set up.  Do you see that he refers in the first sentence to a

13     republic TO decision?

14        A.   If this were proper, he should have invoked a decision published

15     on such and such a date in the republic "Official Gazette" et cetera.  He

16     has to refer to the specific decision published in a specific official

17     gazette invoking article such and such of a specific law.

18        Q.   We have no better opportunity than you for someone from Vlasenica

19     to explain to the Chamber what went on in Vlasenica.  You are, perhaps,

20     the only chance for this Trial Chamber to hear a prominent Muslim from

21     Vlasenica who will explain to them what actually happened.  Please don't

22     be cross with me.  I'm not attacking you.  I only want to find out what

23     is what.

24             THE ACCUSED: [Interpretation] Can this be admitted?

25             JUDGE KWON:  Yes.

Page 17726

 1             THE REGISTRAR:  Exhibit D1652, Your Honours.

 2             JUDGE KWON:  In the meantime, Mr. Karadzic, your one and a half

 3     hours is up a while ago.  How much more do you need to conclude?

 4             THE ACCUSED: [Interpretation] Well, if I was to complete this

 5     properly I would need all day because so much was said on so many

 6     occasions that if you are going to give any weight to this witness I need

 7     to clarify all this today and to challenge it.

 8             JUDGE KWON:  Conclude your examination by the end of this session

 9     which means by 20 past 5.00.

10             THE ACCUSED: [Interpretation] Thank you.  Then I have to skip

11     certain things.  Could we now see 1D4064.  I will not deal with this

12     document after all.  Can we see 1D4065.

13             JUDGE KWON:  Is this not what we saw before?  Yes.  That's marked

14     for identification.

15             THE ACCUSED: [Interpretation] Yes, yes.  Sorry.

16             Could we see --

17             MR. KARADZIC: [Interpretation]

18        Q.   You said, Witness, that I used to come and inspect paramilitary

19     units more than once.  Do you know that the JNA had at least two major

20     mobilisation drives and that I'm -- and that those units in Milici were

21     from the reserve force of the JNA?

22        A.   No.  There was one mobilisation drive end of July 1991, although

23     even that was carried out circumventing all proper criteria while the

24     leadership of Yugoslavia should have specified the exact method of

25     mobilisation without calling up Muslims to kill Catholics in Croatia.

Page 17727

 1             It is important for the Trial Chamber to know.  The first

 2     mobilisation was carried out in end June 1991, and then early in July the

 3     Vlasenica brigade was sent to Zaluzani near Banja Luka because they were

 4     supposed to go to Okucani and further in Slavonia to kill Catholics and

 5     the population of Croatia.  That is the truth.

 6        Q.   I'm asking you about Vlasenica, in that region.  Please, was the

 7     army dividing people there and killing?  We'll leave it to the Court to

 8     decide.  I want to look at one intercept now, although I hate intercepts.

 9     It's 65 ter 30461, to show you whether I toured those units or I

10     encouraged state officials to do that.

11             THE INTERPRETER:  The interpreter did not catch the answer.

12             JUDGE KWON:  Mr. Redzic, unfortunately the interpreters could not

13     hear your previous answer.  Could you repeat.  When Mr. Karadzic talked

14     about the intercept, you answered in one way or another.

15             THE WITNESS: [Interpretation] Before that, before that I'm going

16     to say that the army that was located in Milici was mobilised by the SDS.

17     That is a para-creation.  So, Mr. Karadzic, you know full well that you

18     came there every week and stopped at Zvonko's tavern.  We knew every

19     moment you were going to Bratunac, Zvornik and all these municipalities.

20     We knew that at every moment.

21             As for intercepts and speeches, Karadzic and Zvonko, if we're

22     talking about December 1991, these are their last conversations.  By then

23     everything was done in order to bring all the Serbs together and mobilise

24     them.  This has to do with part of the Serb people who were avoiding

25     mobilisation.

Page 17728

 1             Zvonko is saying to him that nevertheless, they even made them go

 2     and they're inviting him to some kind of party, and he refused that

 3     because we know very well what you were doing, you, Karadzic.  We know

 4     that very well.

 5        Q.   How is it that you are aware of this conversation that I haven't

 6     displayed yet?

 7        A.   Well, when I testified for Naser's defence.

 8             JUDGE KWON:  Yes, Ms. Sutherland.

 9             MS. SUTHERLAND:  Not only that, Your Honour.  It's one of -- this

10     intercept is one of the five intercepts that he listened to before the

11     Krajisnik testimony, which is authenticated in exhibit MFI D1643 now.

12             JUDGE KWON:  But did the accused say it was a conversation

13     between him and Mr. Bajagic?  Let us see.  Let us upload that intercept,

14     30461.

15             MR. KARADZIC: [Interpretation]

16        Q.   While we're waiting, Mr. Witness, how was it that I was covered,

17     as you had it?  Was it some state organ that was covering my state

18     organ -- my movements or was it some other organ?

19        A.   The most ordinary people who were just sitting there and watching

20     what you were doing.  These were drunkards who were providing

21     information.  This has nothing to do with any state organ.  These were

22     drunkards, winos that saw you and your entourage coming and going.

23        Q.   Oh, sir, you said that I was covered wherever I went and that you

24     knew wherever I went?

25        A.   It was drunkards, winos, vagabonds that were covering you.

Page 17729

 1     They're the people who knew where you were.  You liked drinking and

 2     carousing too much.

 3        Q.   And these drunkards and vagabonds were providing information to

 4     you?

 5        A.   Well, we know through conversations and people were afraid.  I

 6     mean every movement of yours instilled fear in people, amazing fear

 7     amongst the Muslim people and the Catholic people and whoever.  It was

 8     fear that you instilled, an incredible fear that I can not explain to the

 9     Trial Chamber or to the other persons present here.

10        Q.   I kindly ask the Trial Chamber to take a look at the first page,

11     because the witness seems to be very familiar with this document.  Then

12     we're going to move on to the second page.

13             Do you agree you remember in advance although I did not say who

14     my collocutor was, do you agree that during this conversation I am saying

15     that state officials should go and visit JNA reservists, not party

16     officials?

17        A.   But of course.  You finished everything.  You had finished all

18     your preparations and everything and of course you as the top person of

19     the political party was trying to avoid all of that, but you will come.

20     You would come on one day to Zvonko's tavern, and you would stay there.

21        Q.   365, actually.  Can we have that page?  That's in Serbian.  2365.

22     That's the ERN number.  We haven't got time for all of this.

23             Yes.  Now, can we have this long bit where I'm speaking, can we

24     have that in English as well.

25             MS. SUTHERLAND:  It's on page 3.  Page 3.

Page 17730

 1             MR. KARADZIC: [Interpretation]

 2        Q.   I'm speaking to Koljevic who is in the room, and I'm saying that

 3     we helped the army.  "The party helped the army to form a volunteer's

 4     detachment.  There are 600 people and they will hoist the flag at 4.00

 5     tomorrow.  The army is there.  They're under JNA command.  They are

 6     wearing JNA uniforms," and so on.

 7             Now, it is a volunteer's unit, but we are manning war units.

 8     That is going to be a small rally tomorrow and it would be a good thing

 9     if one of us went.  I think it's better if someone from the state organ

10     go rather than the party and I'm suggesting Ms. Plavsic should go as a

11     member of the joint Presidency of Bosnia-Herzegovina.

12             As for this group of 600 or 700 soldiers in Milici, did you say

13     that that was an SDS paramilitary formation?

14        A.   No, no.  This was a lot earlier, 1991.  That's when units were

15     located in Milici, when they went to the front line in Croatia,

16     volunteers that were mobilised by the SDS.  I mean, this is 1991.  These

17     people went and then there were people who lost their lives at Vukovar

18     and elsewhere and also became disabled.

19        Q.   Thank you.

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

21     identification?

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  MFI D1653, Your Honours.

24             MR. KARADZIC: [Interpretation]

25        Q.   It is your thesis, Mr. Redzic, that am I right to say that it

Page 17731

 1     became that because the Muslims and Croats did not go to do their

 2     military service, their compulsory military service, and also they did

 3     not respond to the call-up in terms of the reserve force?

 4        A.   No.  The key reason is that it sided with the Serb people and it

 5     identified itself with what -- what's his name?  With all of Milosevic's

 6     ideas.  So you could see where the Serb -- or, rather, the JNA was.

 7        Q.   All right.

 8        A.   The Serb population, whatever --

 9             JUDGE KWON:  I forgot to tell you this, Mr. Redzic, but while you

10     are giving your answers to the questions posed by the accused, you are

11     actually addressing the Chamber.  Please bear that in mind, Mr. Redzic.

12             Yes, Mr. Karadzic.

13             MR. KARADZIC: [Interpretation]

14        Q.   You said today I don't know what the line was, that it had been

15     cleansed of the Croats and Muslims, the JNA.  Is that not what you said

16     today?

17        A.   Well, practically almost.  Very few Catholics and Muslims were

18     left but definitely it had already been cleansed and you know what the

19     reasons were.

20        Q.   Did they cleanse themselves or did somebody else cleanse them?

21        A.   Milosevic's ideology cleansed them, and also the JNA that served

22     Milosevic's ideology and later on Karadzic in Bosnia and Herzegovina.

23        Q.   All right.  Did you take part in this cleansing of the JNA of

24     Muslims?

25        A.   No way.  No.  No.  I never had the intention to do that, and also

Page 17732

 1     I did not want to allow the Muslim people to go to Croatia to kill

 2     Catholics.

 3        Q.   D1373.  During the first mobilisation in the month of July, did

 4     you go to the JNA camp near Banja Luka in an organised way involving two

 5     buses, and did you return -- actually, I don't know whether you went

 6     personally.  Did you send these buses, and did you have these soldiers

 7     returned home?

 8        A.   Yes.  I together with President Stanic.  We went with the parents

 9     of these children, these soldiers who had been unlawfully mobilised.

10     I -- actually, their objective was to send them against Croatia, Okucani,

11     wherever.  The president of the SDS and the president of the municipal

12     assembly were there too.  At the time their intentions were different.

13        Q.   Thank you.  Is this your signature?  Is this the document in

14     which you informed the Presidency of the Republic of Bosnia-Herzegovina

15     that many citizens rallied together and were against mobilisation and

16     there were two buses that were sent there?

17        A.   What do you mean, man, two buses?  Ten buses went, whatever.  But

18     you can see that.  What is this signature here?  So it is true that I

19     went with ten buses together with Mr. Stanic.  Women, children, brothers,

20     sisters, to get the troops that had been deceived and tricked into going

21     to Banja Luka and further on.

22        Q.   On the 7th of July, 1991, did you have any authority over the

23     Ministry of Defence of Yugoslavia?  Were you allowed to do this kind of

24     thing?

25        A.   The Presidency of Bosnia-Herzegovina -- actually, I and

Page 17733

 1     Mr. Stanic and the chief of the interior, we were informed by the

 2     Presidency of Bosnia-Herzegovina that no one should respond to the

 3     call-up because negotiations were underway.  Once they agree on this, we

 4     would be informed.

 5             Dispatches were being sent to me and Stanic and the minister of

 6     national defence who was a Serb.

 7        Q.   Thank you.  Is this your signature?

 8        A.   Well, possibly.  This last letter seems a bit suspicious.

 9             THE INTERPRETER:  The interpreters did not hear the number.

10             JUDGE KWON:  Mr. Karadzic, did you say the number for the next

11     exhibit -- next document?  Yes.  The interpreters didn't hear that.

12             THE ACCUSED: [Interpretation] 1D4066.  The previous document has

13     already been admitted.

14             MR. KARADZIC: [Interpretation]

15        Q.   Mr. Redzic --

16             JUDGE KWON:  I was told that previous document has been marked

17     for identification pending translation, and this seems to be the perfect

18     moment to admit it therefore.

19             MS. SUTHERLAND:  Yes, Your Honour.

20             JUDGE KWON:  Yes, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   Had you committed a crime when you did what the previous document

24     describes, a crime against the security of Yugoslavia?

25        A.   I think that that was not the case, because at that time there

Page 17734

 1     was no Yugoslav Army.  By then they had definitely sided with the Serb

 2     people and --

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

 4     answer.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Thank you.  Please look at this.  Is this a document of your

 7     municipality --

 8             JUDGE KWON:  The interpreters didn't hear the last part of the

 9     answer due to your overlap, Mr. Karadzic.

10             What did you say after having said, "By then they had definitely

11     sided with the Serb people, and --"

12             THE WITNESS: [Interpretation] And the SDS in Bosnia.

13             JUDGE KWON:  Thank you.  Yes, Mr. Karadzic.

14             MR. KARADZIC: [Interpretation].

15        Q.   Is this a document of yours that refers to securing buildings,

16     employees, guards in streets, et cetera?  Is this proof, some proof, of

17     an increase in tensions and threats to -- to the security of officials in

18     the municipality?

19        A.   I want to have a look at this entire document.  I want to see

20     whether it is my own document, and I see here that all the members took

21     part, the Serbs included, but I want to have a look at all of it.

22        Q.   Could I have the next page, please.  If you're done, you ask for

23     the next page.

24        A.   Could we have the next page.

25        Q.   Is this your signature?

Page 17735

 1        A.   Yes.

 2        Q.   Thank you.

 3             THE ACCUSED: [Interpretation] Could this be admitted?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  Exhibit D1654, Your Honours.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   65 ter 30339.  Could I have that, please.  And once again I

 8     kindly ask the Trial Chamber to reconsider.  You will not have another

 9     opportunity of hearing as a witness a high official from Vlasenica.  This

10     is the last opportunity of hearing as a witness such an official here,

11     and we will have to deal with Vlasenica considerably, and there is no one

12     who could replace this witness.

13             Sir, take a look at this Tihomir Savkic, probably?

14        A.   Cavkic, Cavkic.

15        Q.   I see.  He is talking to Rajko Dukic president of the executive

16     board of the SDS and director of your bauxite company; right?

17        A.   Yes.

18        Q.   Now, Cavkic says that there is gunfire there.  It's not that

19     exciting, but there is some shooting going on.  And Dukic says that we

20     attended a meeting at the Assembly at Krajisnik's office, and that we

21     were all there, myself included.  And Dukic says, "What?  There is some

22     kind of gunfire?"  And Cavkic says, "About 20 minutes ago there was some

23     shooting.  About half an hour ago there was shooting."

24             "Where?"

25             "Near our building."

Page 17736

 1             "Ah-ha near our building.  Was the police notified ...," and so

 2     on and so forth.

 3             So in the month of October there was shooting, and this man is

 4     informing Rajko Dukic about that.

 5             Were you aware of that shooting?

 6        A.   I have no idea.  This is Sarajevo.  This man Cavkic is not from

 7     our area, if you think that he's talking about Vlasenica.

 8        Q.   You think he's not talking about Vlasenica?  Why would he be

 9     providing information to Rajko Dukic?

10        A.   Rajko Dukic was president of the SDS, for heaven's sake, man.

11     From all parts of Bosnia-Herzegovina Serbs from Bosnia-Herzegovina are

12     going to be calling him and me.  They're not going to be calling me and

13     Alija Izetbegovic and I don't know who else or somebody from the ranks of

14     the Croatian people.

15        Q.   All right.  Then we're not going to tender this at all if you

16     don't know where this happened.

17             Can you -- actually, let me put it this way:  Did you agree with

18     the Serb Democratic Party and the Serb people to establish two

19     municipalities in Vlasenica, and do you know how many towns exist that

20     consist of two or more municipalities?  Do you agree with that, that

21     there are such towns?

22        A.   Well, the point is not in having one or two or three

23     municipalities.  The point is that a joint entity was being divided into

24     two, a Serb and a Muslim one.  I'm sure that all the persons present here

25     have all these documents that show that we were simply doing this for the

Page 17737

 1     simple reason, man, that there would not be any kind of excessive

 2     behaviour on the part of the Muslim people so you and your followers

 3     would use that as a pretext for killings, rape, looting, destruction.

 4     That is why this was troublesome.

 5        Q.   Mr. Redzic, the Serb side accepted to leave Yugoslavia on the

 6     condition that they have their own autonomy in Bosnia.  Did you negotiate

 7     with the SDS in good faith or were you buying time, and were you

 8     deceiving the Serbs as Alija Izetbegovic was telling you, as you had

 9     said?

10        A.   We're aware of all these stories.  What kind of negotiations

11     could be taking place at that moment?

12        Q.   Wait a moment.  Yes or no, did you do it or did you not do it?

13        A.   No, no, no if you put a question to me, I did not have the

14     intention of having Vlasenica divided at all because I knew that nothing

15     would happen if there were to be a division and even if it happened why

16     were 2.400 Bosniaks killed, why were so many women raped, why was there

17     such a great deal of material destruction and looting, whatever.  Let us

18     start from that.

19        Q.   Wait a moment.  We agreed on the transformation of Vlasenica into

20     a Serbian and Muslim municipality but you didn't mean it seriously?

21        A.   This was --

22             JUDGE KWON:  No.

23        A.   -- done under duress.

24             JUDGE KWON:  This is not a place for debate.  Mr. Karadzic, the

25     Chamber is not minded to extend the time for your further

Page 17738

 1     cross-examination.  You have five minutes to conclude your

 2     cross-examination.

 3             THE ACCUSED: [Interpretation] I say with regret that the

 4     Trial Chamber deprived me of the right to question this witness properly.

 5     This witness has not been questioned.  Now, in the remaining five minutes

 6     I want to see 3515.  And I have to say I don't intend to defend myself in

 7     the way my predecessor did.  Of course they were convicted.  I don't want

 8     a make-believe trial.  I want a proper trial or none at all.  With a

 9     witness who is saying this kind of thing, if he's going to be given any

10     attention at all, I want one day to question him on his evidence in

11     Krajisnik and one day on his evidence in my case.  With his evidence

12     standing this way, it's no wonder Krajisnik was convicted.  The

13     cross-examination in Krajisnik was not good, and he and his lawyer

14     admitted it was not good.

15             JUDGE MORRISON: [Previous translation continues] ... A succession

16     of commentary is just using the time that you could have used to ask a

17     question.  You're losing focus.

18             THE ACCUSED: [Interpretation] This is not the document I wanted.

19     I wanted 1D3501.

20             Your Excellencies, with all due respect, it's much more important

21     for me that this trial be fair than to stick to some dead-lines.

22             JUDGE KWON:  The Chamber is paying utmost care so that the trial

23     is a fair one.  Let's proceed.

24             MR. KARADZIC: [Interpretation]

25        Q.   Is this a document authorising the negotiators to restructure the

Page 17739

 1     municipality?

 2        A.   I don't know.  The date is on the 13th of April.  I believe the

 3     document was signed on the 11th of April.  This date is 13 April 1992.  I

 4     don't know who signed it.  Could we see the last page?

 5        Q.   Milenko Stanic signed it.  Could we see the next page?

 6        A.   That's his version and yours.

 7        Q.   You accepted this, but you didn't mean it seriously, did you?

 8        A.   We meant it seriously.  We seriously meant that the negotiations

 9     are going no way, that it was pure farce and that you were going to

10     attack us very soon and that the Muslim people would suffer exactly what

11     they suffered later.

12        Q.   Thank you.  We have it in the papers, but I don't have time for

13     it now.  Did Izetbegovic advise you to drag your feet while you evacuate

14     people from Vlasenica?

15        A.   We on the ground reported and informed Mr. Izetbegovic, who was

16     not even aware of the situation prevailing in our municipalities.  We

17     were telling him what was happening to the Muslim people, and then he

18     said, "Try to buy time as much as possible while you evacuate people

19     towards Kladanj."  He wasn't even aware of all this.  He believed you

20     more than he believed our people on the ground, and he listened to the

21     international community.

22        Q.   How many people did you manage to evacuate before the conflict

23     broke out?

24        A.   I don't know exactly.  I know the Vlasenica part of the

25     municipality and the neighbouring villages were evacuated in large part

Page 17740

 1     to Kladanj.  The area that was closer to Cerska and Nova Kasaba they went

 2     to Cerska and Nova Kasaba, but I can't give you the exact figure, how

 3     many people managed to leave Vlasenica, but from the reports we got from

 4     Cerska, every time somebody would come from there in view of the total

 5     number of Muslims --

 6        Q.   Leave aside Cerska, Kladanj and Kasaba and Konjevic Polje.  You

 7     managed to evacuate the rest?

 8        A.   From the town itself people managed to leave, those who intended

 9     to, although Serbs had promised to guarantee their safety.  Those same

10     people disappeared and no one knows what became of them, 90 per cent of

11     them.

12        Q.   You mean those you evacuated?

13        A.   No, no, no.  Best of all, I didn't evacuate anyone.  People left

14     on their own after hearing what happened in Zvornik, Bijeljina, Bratunac.

15     People were coming from those areas talking of massacres and killings.

16             THE ACCUSED: [Interpretation] Can this document be admitted, and

17     see 1D4067.

18             THE WITNESS: [Interpretation] This is an inaccurate document,

19     Your Honours.

20             JUDGE KWON:  Thank you, Mr. Redzic.

21             We'll admit it.

22             THE REGISTRAR:  As Exhibit D1655, Your Honours.

23             THE ACCUSED: [Interpretation] 1D4067, please.

24             JUDGE KWON:  Just for your understanding, Mr. Redzic, admitting a

25     certain document does not mean that the Chamber admits what is contained

Page 17741

 1     in the document.  We will take into account what you said in the

 2     courtroom.

 3             And, Mr. Karadzic, I take it this is the last question for you.

 4             THE ACCUSED: [Interpretation] Well, I would like to ask you for

 5     two or three very brief questions after this, only with a yes or no

 6     answer.

 7             JUDGE KWON:  Very well.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Is this your document, sir?

10        A.   Yes, this is even my handwriting, but the date is a forgery.

11     This was done before the holiday of Bajram where we gathered and agreed

12     to organise festivities on the occasion of Bajram.  And Bajram, if I

13     remember, in 1992 fell on the 4th of April.  And here we listed exactly

14     what everyone took upon themselves to do, who would organise the

15     celebration, who would take care of the slaughtering of lambs, and these

16     were festivities that we wanted to invite Serbs to.  And Serbs planted a

17     story in some newspaper that Redzic planned the slaughter of the Serbian

18     population, whereas I in my life never even saw a chicken slaughtered.

19             THE ACCUSED: [Interpretation] Can we zoom in on the part where it

20     says this will be Black Friday for the Serbs?

21             THE WITNESS: [Interpretation] How come this is suddenly

22     typewritten?  This is really ridiculous.

23             MR. KARADZIC: [Interpretation]

24        Q.   Does it say call the president of SO Tuzla, Besnagic [phoen] to

25     address our refugees?  The General Staff orchestrates all this operation.

Page 17742

 1     Columns of refugees, et cetera, to free up Friday --

 2        A.   To free children from school.

 3        Q.   And do what next?

 4        A.   Organise a cultural event and festivities on the occasion of

 5     Bajram.  Look what you encircled, saying that Serbs should be killed.

 6     How can you say that?  You can see.  It's obvious what this writing is

 7     all about.

 8        Q.   Is this your handwriting?

 9        A.   Yes.  What is handwriting without the parts that you added in

10     order to label me.  This story was even planted in the newspaper, and the

11     newspaper later printed a denial.  The newspaper said it was an

12     honourable good man and this whole thing was not at all what it was said

13     to be.

14             THE INTERPRETER:  The interpreter did not hear the number

15     Mr. Karadzic called.  Speakers are overlapping now.

16             JUDGE KWON:  The last question of yours, Mr. Karadzic, and the

17     answer were not interpreted because of the overlap.  I would like to

18     repeat -- like you to repeat your question and answer, and I'll -- but

19     before that, could you explain to us what this document is about?  It

20     is -- the typewritten part was added by the Defence or by the Serb

21     authority later on?

22             THE ACCUSED: [Interpretation] No.  The Defence got hold of this

23     document the way we see it here.  It has been faxed from somewhere, and

24     this is page 2 of a larger document, annex number 12 from some

25     collection.  There is a reference to sheep for slaughter, herd for

Page 17743

 1     slaughter --

 2             THE WITNESS: [Interpretation] Your Honours, may I explain

 3     something?

 4             JUDGE KWON:  Yes, Mr. Redzic.

 5             THE WITNESS: [Interpretation] This is a sheet from an agenda,

 6     from a diary.  These contents could not be here, especially not in

 7     Cyrillic.  This was typed in later to create a false picture, for

 8     Karadzic to maybe portray me as a terrorist, but fortunately we have very

 9     smart, intelligent people sitting here who will not allow that.

10             JUDGE KWON:  But the handwritten parts are your handwriting.  You

11     can confirm that except for the date.

12             THE WITNESS: [Interpretation] Yes, yes, yes.

13             JUDGE KWON:  Very well.

14             THE WITNESS: [Interpretation] But, Your Honours, this is --

15             JUDGE KWON:  Yes, please continue, Mr. Redzic.

16             THE WITNESS: [Interpretation] I think this was a brief

17     presentation where Muslims gathered and everyone was given a specific

18     duty to help organise festivities for the holiday of Bajram.  It was not

19     meant against anyone.  One person was to procure lambs, and Serbian

20     leaders from the SDS even were invited to these festivities.  They ate

21     the meat with us and the sweets too.

22             JUDGE KWON:  Yes.  Mr. Karadzic, do you remember the part which

23     were not reflected in the transcript, your last question and the answer?

24             THE ACCUSED: [Interpretation] Yes.

25             MR. KARADZIC: [Interpretation]

Page 17744

 1        Q.   Were you convicted to ten years' imprisonment by the

 2     Military Court for that operation to subvert the defence capabilities of

 3     the country and hauling away reservists from the camp in Zaluzani?

 4        A.   There was a trial and the Military Court, including

 5     Major Ostojic, indicted me, and I was defended by lawyer Bajnagic

 6     [phoen].  He told me that in my absence I was convicted under the

 7     Criminal Code of the SFRY, Article 205, paragraphs 1 and 3, I believe,

 8     and that he expects ten years' imprisonment.  I never got the judgement

 9     in writing, but that's all I know about it.

10        Q.   Did you run away from Vlasenica on the 18th of April because of

11     this and that Milenko Stanic in his own car drove through Serb territory

12     via Tisca away?

13        A.   I'm not denying about Mr. Stanic.  It was agreed, however, that

14     Professor Vukic take me to the territory on the border of Kladanj

15     municipality.  However, he did not accept, and he just called me and

16     said, "Good luck, Redzic."  And in Tisca, what saved me only God knows.

17        Q.   Then who gave you a lift?

18        A.   I took Sevko Huric's [phoen] car, Sevko and late cantonal Judge

19     Avdic and another man took the same car.

20        Q.   Thank you.  I'm sorry the Trial Chamber decided to abbreviate

21     this questioning.  Maybe you will get a subpoena from us in the Defence

22     case.

23             JUDGE KWON:  Are you able to follow -- scroll back the

24     transcript?  I'm not sure how important it is, but at page 69, lines 11,

25     12, there because of the overlap your question and the witness's answer

Page 17745

 1     were not reflected in the transcript.  If you remember the question, I

 2     would allow you to put that question again.

 3             THE ACCUSED: [Interpretation] I think the question had to do with

 4     the judgement of the Military Court, and I repeated it now.

 5             JUDGE KWON:  Thank you.

 6             Do you have --

 7             THE ACCUSED: [Interpretation] We have that judgement.  We have

 8     many other documents.  We haven't even touched upon the issue of the

 9     conflict in Vlasenica itself.  There are many outstanding issues that

10     this witness could help us with.

11             JUDGE KWON:  How long would you need for your re-direct

12     examination, Ms. Sutherland.

13             MS. SUTHERLAND:  Your Honour, I don't have any re-examination of

14     the witness, but in relation to the last document, because there was

15     quite a bit of discussion about it --

16             JUDGE KWON:  We're going to mark it for identification.

17             MS. SUTHERLAND:  Thank you, Your Honour, because there's no

18     translation.

19             JUDGE KWON:  We need to be satisfied as to its authenticity as

20     well.

21             MS. SUTHERLAND:  And that was --

22             JUDGE KWON:  -- and provenance.

23             MS. SUTHERLAND:  -- my next question.  I was going to ask

24     Mr. Karadzic.  He stated that the Defence got hold of this document but

25     didn't say from where and I would like to know whether he's prepared to

Page 17746

 1     tell the Chamber the source of the document, where he obtained the

 2     document from.

 3             JUDGE KWON:  Can you help us, Mr. Karadzic?

 4             MS. SUTHERLAND:  And could we inspect the original?

 5             THE ACCUSED: [Interpretation] I see it's attachment -- or annex

 6     number 12 from some collection.  I have to research with my Defence the

 7     origins of this document.  Because it's only going to be MFI'd, we will

 8     have time to find out.

 9             JUDGE KWON:  Yes.  We'll give the number, being marked for

10     identification.

11             THE REGISTRAR:  As MFI D1656, Your Honours.

12             MS. SUTHERLAND:  And, Your Honour, before we break I wanted to

13     correct the record.  Transcript page 55, line 14, at least on the

14     transcript that I have in front of me I misspoke when I said MFI D1643.

15     In fact I should have said Exhibit P3190 when I was talking about the

16     authentication sheet.

17             JUDGE KWON:  Mm-hmm.

18             MS. SUTHERLAND:  Thank you.

19             JUDGE KWON:  Thank you.

20             Mr. Redzic, then that concludes your evidence in this trial.  On

21     behalf of the Chamber, I would like to thank you for your coming to

22     The Hague to give it.  Now you are free to go.

23             We rise all together.

24             THE WITNESS: [Interpretation] Thank you.

25             JUDGE KWON:  We will have a break for 25 minutes and resume at

Page 17747

 1     6.00.

 2                           [The witness withdrew]

 3                           --- Recess taken at 5.36 p.m.

 4                           --- On resuming at 6.01 p.m.

 5             JUDGE KWON:  Yes, Ms. Elliott.

 6             MS. ELLIOTT:  Thank you, Your Honours.  Before the witness is

 7     brought in, I just wanted to advise that he should be provided with a

 8     Rule 90(E) warning as he has been treated as a suspect in his prior

 9     interviews with the Office of the Prosecutor.

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

11             THE ACCUSED: [Interpretation] May I?

12             JUDGE KWON:  Yes.

13             THE ACCUSED: [Interpretation] I didn't manage to find the right

14     page that pertains to whether the previous witness was a president -- was

15     the president or just a member of the National Defence Council, so I

16     withdraw that question.

17             JUDGE KWON:  Thank you.

18                           [The witness entered court]

19                           THE WITNESS:  DRAGAN VIDOVIC

20                           [Witness answered through interpreter]

21             JUDGE KWON:  Good evening, sir.

22             THE WITNESS: [Interpretation] Good evening.

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

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

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

Page 17748

 1             JUDGE KWON:  Thank you.  Please be seated and make yourself

 2     comfortable.

 3             Mr. Vidovic, before you start giving evidence, I would like to

 4     draw your attention to a particular Rule here at the Tribunal.  Under

 5     this Rule, Rule 90(E), you may object to answering a question from the

 6     Prosecution or the accused or from the Judges if you believe that -- that

 7     your answer will incriminate you.  When I say "incriminate," I mean that

 8     something you say may amount to an admission of your guilt for a criminal

 9     offence or could provide evidence that you have committed an offence.

10     However, even if you think your answer will incriminate you and you do

11     not wish to answer the question, the Tribunal has the discretion to

12     oblige you to answer the question, but in such a case, the Tribunal will

13     make it sure that your testimony compelled in such a way shall not be

14     used as evidence in another case against you for any offence other than

15     false testimony.

16             Do you understand, sir, what I have just told you?

17             THE WITNESS: [Interpretation] Up to a degree.

18             JUDGE KWON:  If you have any questions, I'll be happy to answer

19     them.

20             THE WITNESS: [Interpretation] I have none.

21             JUDGE KWON:  Thank you.

22             Ms. Elliott.

23             MS. ELLIOTT:  May I please call up 65 ter 90249.

24                           Examination by Ms. Elliott:

25        Q.   And, sir -- Mr. Vidovic, sir, would you please state your full

Page 17749

 1     name for the record.

 2        A.   Dragan Vidovic.

 3        Q.   Mr. Vidovic, do you recall meeting with Mr. Nicholls and

 4     Mr. Blaszczyk on the 29th of May, 2011, in Belgrade and in the presence

 5     of your lawyer Mr. Stojanovic?

 6        A.   I do.

 7        Q.   Did you listen to the audio recording of that 29 May 2011

 8     interview here in The Hague?

 9        A.   Yes.

10        Q.   And the answers you gave in that 29 May interview, were they

11     accurate and would you provide the same information today?

12        A.   Yes.

13             MS. ELLIOTT:  Your Honours, I'd ask that the audio recording of

14     the interview along with the English transcript which is uploaded as

15     65 ter 90249 be admitted as the next exhibit, but I'd ask that it be

16     admitted under seal, and for that I would need to go into private

17     session.

18             JUDGE KWON:  Yes.  Let's go into private session.

19                           [Private session]

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 17750

 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                           [Open session]

21             THE REGISTRAR:  As Exhibit P3191 under seal and Exhibit P3192,

22     Your Honours.

23             JUDGE KWON:  Yes, Ms. Elliott.

24             MS. ELLIOTT:  Thank you.  Now I'll provide a summary of

25     Mr. Vidovic's statement.

Page 17751

 1             Mr. Vidovic was assigned to the Karakaj company in Zvornik.  The

 2     platoon commander was Dragan Ristanovic and the company commander was

 3     Milan Blagojevic.  The witness was assigned by Commander Ristanovic to

 4     guard Karakaj Technical School when he arrived at the school he found

 5     paramilitary formations were present including Pivarski.  The witness

 6     worked three-day shifts.  During this time the witness was responsible

 7     for guarding approximately 500 to 600 Muslim prisoners held in the big

 8     hall of the Karakaj Technical School.  The detainees were tightly packed

 9     into the hall.  Pivarski ordered the witness and other guards to beat the

10     detainees.  The witness did not see anyone murdered during his shift or

11     any dead bodies at the school.

12             On the third day, five or six buses from the Drinatrans company

13     arrived.  The witness, on order of Commander Ristanovic, travelled on one

14     of the buses to Pilica, the buses were driven under police escort, and

15     the detainees were taken to Pilica Dom Kulture where a lot of soldiers

16     wearing the SMB coloured uniforms were waiting for them.  The prisoners

17     went into the Dom and the witness returned to his home in Karakaj.

18             That completes the summary.

19        Q.   Mr. Vidovic, do you recall testifying in the Grujic trial in

20     Belgrade in 2009?

21        A.   I do.

22        Q.   Now, I'm just going to ask you a few questions that relate to two

23     topics you discussed in your Grujic testimony.  The first topic:  Do you

24     recall whether you heard any reports of gunfire from around the school

25     during the time that you were guarding the Karakaj Technical School?

Page 17752

 1        A.   No.

 2        Q.   If I could please have 65 ter number 23241 on the screen and page

 3     24 in the English, page 19 in B/C/S.  And where I'm referring is in the

 4     middle of the page in B/C/S.  And here, Mr. Vidovic, it records questions

 5     where the Presiding Judge was asking you about whether you heard

 6     something like that was happening and your response, and this is at the

 7     top of the English is:

 8              "Whether that happened or not -- they say it didn't.  Some say

 9     there was shooting.  I don't know."

10             And then it carries on and the Presiding Judge says:  "Who did

11     you hear it from, from the guards or ...?"

12              And your answer was "That was the talk in the village, when

13     there was gunfire around the school."

14             Mr. Vidovic, does that refresh your memory as to whether there

15     was talk around the school that there was gunfire around the school?

16        A.   I've already said that there was no gunfire when I was there.

17     Now, whether there was any afterwards, I don't know.

18        Q.   My question was whether you heard reports of gunfire around the

19     school, not you personally, but whether there was talk of people hearing

20     gunfire around the school.

21        A.   I don't remember.

22        Q.   You can see the transcript in front of you.  Is what you told the

23     Presiding Judge in the Grujic trial accurate and correct?

24        A.   Where is that?  I cannot see it.

25        Q.   It's in the middle of the page on B/C/S, and it's where the

Page 17753

 1     Presiding Judge asks you:  "Who did you hear it from, from the guards

 2     or ...?"  And your answer's recorded as:  "That was the talk in the

 3     village, when there was the gunfire around the school."

 4             THE ACCUSED: [Interpretation] May I kindly ask that this be read

 5     out verbatim?  "They say that there wasn't any, and some people say

 6     shooting."  I don't know.  So over there it says that there was talk and

 7     that there wasn't.  So why would we skip one of the two variants?

 8             JUDGE KWON:  She read that part earlier on, but I'm not sure

 9     whether the witness read that part as well.

10             Now do you see the part, Mr. Vidovic?

11             THE WITNESS: [Interpretation] No.

12             JUDGE KWON:  Do you find the question of the Presiding Judge

13     where he asked or she asked:  "And when you're not there, did you hear

14     about something like that happening?"  And you answered:  "Whether that

15     happened or not -- they say it didn't.  Some say there was shooting.  I

16     don't know."

17             Did you find that part?

18             Why don't we collapse the English.

19             THE ACCUSED: [Interpretation] Now it's the first sentence from

20     the top, if I may be of assistance.

21             JUDGE KWON:  And could you read it carefully and then answer the

22     question by Ms. Elliott.

23             THE ACCUSED: [Interpretation] I beg your pardon.  I do apologise.

24     My mistake.  One further down.  One line down.

25             Can the page go down so that we see another answer?

Page 17754

 1             JUDGE KWON:  If you read that part, could you let us know so that

 2     Ms. Elliott can put you a question.

 3             THE WITNESS: [Interpretation] Did it happen?  Did it not happen?

 4     Some people say shooting.  Shooting.  I don't know.

 5             I don't know what to say.  While I was there, there was no

 6     shooting, and now what people were saying in the village ...

 7             JUDGE KWON:  But the question -- why don't you put your question

 8     again.

 9             MS. ELLIOTT:

10        Q.   My question, Mr. Vidovic, is whether you heard any talk around

11     the village of gunfire being heard from the school.

12        A.   No.  Maybe there was talk like that, but no one told me.

13             MS. ELLIOTT:  Very well.  I'll move on, Your Honours.

14             JUDGE KWON:  Thank you.

15             MS. ELLIOTT:

16        Q.   Mr. Vidovic, do you recall tell the Court in Belgrade that you

17     saw a Tamic truck at the Karakaj Technical School?

18        A.   First they asked me whether I had seen corpses and whether the

19     truck was taking corpses away, and I said no.  And a Tamic was there.  I

20     saw it by the school out there.

21             MS. ELLIOTT:  Your Honour, if we could briefly go into private

22     session.

23             JUDGE KWON:  Yes.

24                           [Private session]

25   (redacted)

Page 17755

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11                           [Open session]

12             THE REGISTRAR:  We're back in open session, Your Honours.

13             MS. ELLIOTT:

14        Q.   Mr. Vidovic, just to clarify for the record, when you saw that --

15     when you said that you saw a Tamic was there, that was during your guard

16     duty at the Karakaj Technical School; is that correct?

17        A.   But not on at that day.  I saw it afterwards.

18        Q.   And when you say "afterwards," you mean either on the second or

19     third shift that you worked at the Karakaj Technical School?

20        A.   Yes.

21        Q.   This is the last topic I'm going to ask you about, Mr. Vidovic.

22             MS. ELLIOTT:  I please call up 65 ter 19140A.

23        Q.   Mr. Vidovic, do you recognise what is shown in this photograph?

24        A.   Yes.

25        Q.   Could you please describe for the Court what this photograph

Page 17756

 1     shows and how you're familiar with the contents of the photograph.

 2        A.   This is a photograph of the slaughterhouse, Gero's former

 3     slaughterhouse.  Now it is mine.

 4        Q.   Since when have you owned this facility?

 5        A.   I'm not sure, but 2000 -- I'm not sure.  Say 2002, 2003.

 6        Q.   Did you purchase this directly from Mr. Gero, if there is such a

 7     person?

 8        A.   Yes.  My father, brother, and Gero were there, because the land

 9     on which the slaughterhouse was built was owned by my late father.  The

10     slaughterhouse was built as a temporary building.

11        Q.   Thank you, sir, for answering my questions.

12             MS. ELLIOTT:  Your Honour, those are all my questions.  I just

13     need to deal with the associated exhibits, and the only one of the

14     associated exhibits I'm tendering is 65 ter 08235 through this witness.

15             JUDGE KWON:  Shall we admit the picture first, the photo first?

16             MS. ELLIOTT:  Oh, yes.  Thank you.

17             JUDGE KWON:  Yes.  That will be given a number.

18             THE REGISTRAR:  Exhibit P3193, Your Honours.

19             JUDGE KWON:  And we come to associated exhibits.  There are five

20     of them.

21             MS. ELLIOTT:  Yes, Your Honour.  Two have already been admitted,

22     23119 was admitted as P3185, and 07232 was admitted as P3186.

23             In terms of the remaining three, I'd like them all admitted but

24     with the rule that it form an integral part of the statement.  The only

25     one that I think this witness had any meaningful comment on was 08235,

Page 17757

 1     the payroll for the Karakaj company.

 2             JUDGE KWON:  Thank you.  So you're tendering only that exhibit.

 3             MS. ELLIOTT:  Yes, Your Honour.

 4             MR. ROBINSON:  No objection.

 5             JUDGE KWON:  That will be admitted.

 6             THE REGISTRAR:  Exhibit P3194, Your Honours.

 7             JUDGE KWON:  Thank you, Ms. Elliott.

 8             MS. ELLIOTT:  Thank you.

 9             MR. ROBINSON:  Excuse me, Mr. President, a small matter.  Could

10     we clarify the private session material to open session in light of the

11     answer that was received?

12             JUDGE KWON:  Could you -- could you expand?  I don't follow,

13     Mr. Robinson.

14             MR. ROBINSON:  Well, maybe I'm wrong, but I suspected that out of

15     an abundance of caution the Prosecution had asked to go into closed

16     session expecting the witness to give an answer that might reveal the

17     identity of a protected witness, and then the answer didn't reveal the

18     identity of the protected witness.

19             JUDGE KWON:  Ms. Elliott.

20             MS. ELLIOTT:  I think out of an abundance of caution I would need

21     to go into private session again, Your Honour.

22             JUDGE KWON:  Yes.  We'll do so.

23                           [Private session]

24   (redacted)

25   (redacted)

Page 17758

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10                           [Open session]

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

12             JUDGE KWON:  Yes, Mr. Karadzic.

13                           Cross-examination by Mr. Karadzic:

14        Q.   [Interpretation] Good evening, Mr. Vidovic.

15        A.   Good evening.

16        Q.   I should like to thank you for having met with the Defence, and I

17     believe that like in other cases, it will help me be more efficient in

18     the use of time and ask brief questions to get brief answers.

19             Let me start with what you said on page 83.  "My father, brother,

20     and Gero were ..."

21             Do you mean to say that they used to be co-owners of that

22     butcher's shop even earlier?

23        A.   The land belonged to my father, and the provisional building was

24     Gero's property.

25        Q.   Thank you.  You mentioned the late Dragan Ristanovic as a CO,

Page 17759

 1     commanding officer.

 2        A.   Yes.

 3        Q.   Is it true that he got killed in combat?  You confirmed that in

 4     65 ter 23241, page 4, which is a transcript.

 5        A.   Yes.  He was killed at Snagovo.

 6        Q.   Thank you.  In the transcript, page 58, 65 ter 23241, page 9, did

 7     you say that Pivarski put the fear of God into everyone and in his own

 8     unit and in the whole town of Zvornik everyone feared him and no one was

 9     able to command him?

10        A.   Precisely.  He was all-powerful, as our people say, God himself.

11        Q.   One page further in the same document did you say that in the

12     Technical School Centre you found people guarding Muslims, wearing

13     camouflage uniforms, carrying automatic weapons, and that was when you

14     heard the names of Pivarski, Mrki, and others?

15        A.   Yes.

16        Q.   Thank you.  On page 13 of the same document, you said that on

17     Pivarski's orders, while Pivarski cursed you and threatened you that he

18     would beat you up, you had to hit three or four prisoners.

19        A.   Yes.  He spoke to me a couple of times with many profanities, and

20     he said he would beat me up if I don't hit them, so I hit three or four

21     people with a police baton just to stay safe myself, to keep out of

22     trouble.

23        Q.   Is it true that Pivarski's threats were to be taken seriously?

24     He often slapped about his own soldiers.  He sometimes stripped them

25     naked.  And is it true that he once stripped naked a member of our own

Page 17760

 1     civilian authorities, tied him to a goal post at a stadium and beat him?

 2        A.   That's correct.

 3        Q.   If you want to tell his name, we'll have to go into private

 4     session.

 5        A.   Yes.  That man was tied to a goal post, stripped naked, and

 6     beaten up in Celopek.  He was beaten by Pivarski and his men.

 7        Q.   Was it an official of Republika Srpska?

 8             THE ACCUSED: [Interpretation] Could we briefly go into private

 9     session?

10             JUDGE KWON:  Yes.

11                           [Private session]

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 17761

 1        Q.   On page 18 of the same document, or number 67 of the transcript,

 2     you told the commander:  "Let us find a way out of here," because nobody

 3     dared address Pivarski, and you were trying to make yourself scarce

 4     together with the commander.  Was it the commander Ristanovic?

 5        A.   Yes.  That's what I said to him.

 6        Q.   Was Ristanovic able or did he dare to say anything to Pivarski?

 7     Did Ristanovic command Pivarski or the other way around?

 8        A.   Pivarski commanded everyone in Zvornik.

 9        Q.   Thank you.  You mentioned today and also on that transcript, page

10     19, that you did not see any of the prisoners suffocate.  Is that true?

11        A.   Yes.

12        Q.   Is it true that you corrected this transcript on page 22, the

13     statement that you had never seen Brano Grujic?  Is it true that you

14     never saw Brano Grujic around the Technical School centre?

15        A.   Yes, that is true.  I don't know how that mistake occurred.

16     Maybe it was interpretation or something.  I only heard that Brano Grujic

17     had said to Ristanovic that he would be going for an exchange.  It's not

18     that I heard Brano Grujic himself.  I heard that Brano Grujic said that

19     to Dragan, and Dragan told me about it.

20        Q.   Thank you.  Is it true that on five to six buses, each holding 50

21     to 60 people, these people were taken from the Technical School to Pilica

22     for their exchange?

23        A.   Yes.  It was two of those double buses, and in total there were

24     five to six buses.

25        Q.   To the best of your knowledge, who ordered Mr. Ristanovic to

Page 17762

 1     carry out that mission?

 2        A.   Pivarski.

 3        Q.   Is it true that in that period, at that time, there was complete

 4     lawlessness in Zvornik, people feared for their lives, Serbs and Muslims

 5     equally, and that the authorities in town did not function at all?

 6        A.   Quite right, until they were arrested.  There was no law.  You

 7     had to obey Pivarski and the others who ruled at that time.  Until the

 8     day when they were arrested.

 9        Q.   You say here that both Serbs and Muslims feared for their lives.

10     Were some of the prisoners local Muslims or were they all brought from

11     the mountains?

12        A.   There were no local Muslims from Karakaj and Zvornik, only

13     because our neighbours were left alone, lists were made, and they left

14     peacefully going to Serbia.

15        Q.   The Muslims went mostly to Serbia; correct?

16        A.   Yes.

17        Q.   Were there any Muslims, your neighbours, who did not leave for a

18     long time, who were left alone after interviews were conducted with them

19     and remained there to live?

20        A.   There was with us a man called Nijaz, originally from Memici, but

21     he had lived for 10, 15 years, perhaps, in Karakaj.  He was with us in

22     our company, and he had had interviews at the command and continued

23     there, stayed there for another three or four months, I think.

24        Q.   Thank you.  Did he then stay as long as he wanted and nobody made

25     any trouble for him?

Page 17763

 1        A.   Yes.

 2        Q.   When were those prisoners taken for that exchange?  When they

 3     were taken for the exchange, do you know that throughout the war it often

 4     happened that the Muslim side rejected an exchange that had been agreed

 5     earlier and everything fell through?

 6        A.   Such information was not available to me.  I couldn't know.

 7        Q.   Is it true that there was one of Pivarski's soldiers on each bus

 8     and one local member of the Territorial Defence guarding 50 to 60 people

 9     on the bus?

10        A.   Yes.  That's how it was in our area.

11        Q.   Is it true that Pivarski insisted on involving you local people

12     in the beatings and that he wanted to control you because he put one of

13     his own men together with one member of the Territorial Defence on each

14     bus?

15        A.   Most probably.

16        Q.   In other words, did you feel controlled by Pivarski, you

17     personally, and your men?  Did you feel that Pivarski and his group were

18     controlling you?

19        A.   All the time.  We were constantly supervised by him, and he

20     commanded us, sometimes directly, sometimes through Dragan Avdic.

21        Q.   At that time was there any power in Zvornik able to confront him?

22        A.   No.

23        Q.   Was his activity mostly aimed at Karakaj and the suburbs as

24     opposed to Zuca, who operated in your area?  Do you know who Zuca was?

25        A.   Yes, I heard of Zuca.  He was the same as the other one.  I

Page 17764

 1     believe - how do you say it? - with experience.  They were experienced.

 2     They knew how to go about it, and they scared all of us, and they did as

 3     they pleased.

 4        Q.   Thank you.  You spoke to the Prosecution also in 2002 and again

 5     on the 29th of May, 2011.  That's 65 ter 90249.

 6             THE ACCUSED: [Interpretation] May I ask if the Prosecution

 7     tendered that transcript as well, or is it part of a larger document,

 8     larger exhibit?

 9             JUDGE KWON:  I don't think that has been tendered.

10             MS. ELLIOTT:  Your Honour, that's the transcript we tendered as

11     his -- this witness's 92 ter statement, 90249 and A would be the public

12     redacted version.

13             JUDGE KWON:  Yes.  I was mistaken with the Grujic trial number.

14             Yes, we have it.

15             THE ACCUSED: [Interpretation] I thought we had only Grujic's

16     transcript, so I overlooked this one.

17             MR. KARADZIC: [Interpretation]

18        Q.   So on pages 7 and 8 of that document, you said and I will read in

19     English so that you get better interpretation than mine.

20             "[In English] There were paramilitaries on each shift, roughly

21     10, 15, at any -- any one time.  I believed that Grujic,

22     Dragan Spasojevic and Pivarski were responsible for bringing the

23     Muslims -- Muslim prisoners in Karakaj Technical School.  The civilian

24     and military police were involved in bringing them to KTS.  I heard this

25     from the people I was working with.  I cannot remember their names."

Page 17765

 1             [Interpretation] And then you say about the Karakaj school, you

 2     say yes, and then the question goes – (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9             JUDGE KWON:  You can --

10             THE ACCUSED: [Interpretation] I apologise.

11             JUDGE KWON:  Yes.  I think we can continue now.  With the proper

12     redaction.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17                           [Open session]

18             THE REGISTRAR:  We're back in open session, Your Honours.

19             MR. KARADZIC: [Interpretation]

20        Q.   Is it correct that you had not seen this Brano, whereas the other

21     one took his colleague somewhere?  Also, did you hear that this colleague

22     was supposed to mediate in the exchange and that he was sent to Muslim

23     territory?

24        A.   Brano Grujic, I did not see him.  The other one I did see when he

25   (redacted)

Page 17766

 1   (redacted)

 2        Q.   And that's the only time when you saw this man; is that right?

 3        A.   Who?

 4        Q.   The one who got his colleague.

 5        A.   Yes.

 6        Q.   Thank you.  Is Memici a Muslim village in an area where these

 7     people were taken prisoner, those who were detained, that is?

 8        A.   Memici is on the other side, on the road between Zvornik and

 9     Tuzla.  Please --

10             JUDGE KWON:  Yes, continue, Mr. Vidovic.  Then we come back to

11     you.  Yes, Ms. Elliott.

12             MS. ELLIOTT:  Your Honour, we need -- I need to address the issue

13     of redactions.  I'm not sure if --

14             JUDGE KWON:  I think that's been taken care of.  Are we talking

15     about line 17?

16             MS. ELLIOTT:  Yes, line 17 and 18.

17             JUDGE KWON:  Yes.  Please continue, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] Thank you.

19             MR. KARADZIC: [Interpretation]

20        Q.   When this transport took place, towards Pilica, that is, it was

21     stated that that was for the purposes of an exchange.  Did you see any

22     kind of misdeed, any kind of beating or killing in Pilica?

23        A.   No.  No.  I was there only a bit, only while the prisoners got

24     off, and we went back.  The bus driver and I went back to Karakaj.

25     Afterwards, I went home.

Page 17767

 1        Q.   Thank you.  How is it possible that 50 or 60 detainees are being

 2     escorted by only one man, one in front and one in the back, and in what

 3     mental state were these detainees?

 4        A.   Well, when they found out that they were being exchanged, of

 5     course they would not make any problems.  Everything was all right.

 6     There was no excessive behaviour.  It was not that they were exhausted or

 7     very tired or anything like that.  Maybe they looked the way they did

 8     because they were told that they were being exchanged.

 9        Q.   They were a bit more cheerful?

10        A.   Yes.

11        Q.   Is it correct that Pivarski could issue orders to the police and

12     give them assignments?

13        A.   I've already said that he could issue orders to everyone in

14     Zvornik.

15        Q.   Thank you.  Is it correct that he ordered that two police

16     vehicles escort that convoy to Pilica, and did every bus have two, or did

17     the entire convoy have one vehicle in front and one in the back?

18        A.   Two vehicles in total, one in front and one in back.

19        Q.   Thank you.  You were asked in this same interview, on page 20,

20     whether you knew who the commander of the Territorial Defence of Zvornik

21     was, and you said that you did not know; right?

22        A.   That's right.

23        Q.   And you also said that you had heard of Marko Pavlovic, but you

24     did not know what position he held.

25        A.   Yes.

Page 17768

 1        Q.   You only heard the name; right?

 2        A.   Yes.

 3        Q.   Is it correct that volunteers had the right to a salary and that

 4     they were paid by the municipality where they had reported?

 5        A.   I don't know whether they had that right, but they took whatever

 6     they wanted.

 7        Q.   You mean they prevailed and they took what they wanted.

 8        A.   But of course.

 9        Q.   Did anyone dare deny them a salary?

10        A.   Maybe that person who would oppose them would be denied of his

11     life.

12        Q.   Is it correct that most of the territorials and volunteers went

13     into the hills on guard duty, whereas Pivarski and his men were in town?

14        A.   Yes.

15        Q.   Did you go out to guard duty, and how long were your shifts?

16        A.   I did go on guard duty in seven-day shifts.

17        Q.   It's guard duty in the hills, not by the school; right?

18        A.   Yes.  On the separation line between Karakaj and Lipovica,

19     Radakovci.

20        Q.   Thank you.  How far away were you from Karakaj as the crow flies

21     when you were at the front line on that hill?

22        A.   As the crow flies, perhaps about a thousand metres.

23        Q.   Thank you.  If there would be bursts of gunfire up there and so

24     on, would that be heard in Karakaj?

25        A.   Yes.

Page 17769

 1        Q.   Do you know anything about events in Gero's Slaughterhouse?

 2        A.   I don't know a thing.

 3        Q.   How was the rest of these groups received, and do you remember

 4     the atmosphere before and afterwards, and who carried out the arrest?

 5        A.   I don't know who it was, but people were thrilled when they were

 6     finally arrested and detained.

 7        Q.   What was the situation in terms of public law and order after

 8     their arrest?

 9        A.   Afterwards, things were brought into order.

10        Q.   Who brought this order about in Zvornik?

11        A.   Well, there was the civilian police.  The civilian police.

12        Q.   After that did the municipal government have a say again?

13        A.   Yes.  They were stabilised.

14        Q.   Did you hear --

15             JUDGE KWON:  Mr. Karadzic, shall we rise for today?

16             THE ACCUSED: [Interpretation] Well, Your Excellency, I thought

17     that perhaps we could let the witness go, because I don't think I have

18     many -- many questions for him any more if --

19             JUDGE KWON:  I have to find out whether it's okay with our staff.

20     How long would you need to conclude?

21             THE ACCUSED: [Interpretation] Not more than five minutes.

22             JUDGE KWON:  Thanks to the indulgence of the staff, we continue.

23             Yes, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 17770

 1        Q.   On page 26 of this interview, you were asked whether you had

 2     recognised any of the Muslims who had been detained and what you felt --

 3     or, rather, whether you had felt bad about what you had seen and whether

 4     you recognised anyone, and you say their villages were up in the hills,

 5     Djulici, Klisa, and so on, and you say that you think that there might

 6     have been someone from Lupa but that there weren't any other prisoners.

 7     Did you know any of them?

 8        A.   There were quite a few people I knew.  I didn't know many by

 9     name, but I knew a football player who played football in Karakaj with

10     us, Lolic.  He was a conductor at Drinatrans.

11             I knew a lot of them not by their names, actually, because quite

12     a few of them worked in Glinica, in Karakaj where I worked.

13        Q.   Thank you.  Did the fighting go on all the time throughout the

14     war and were a lot of dead and wounded soldiers of ours come from that

15     area?

16        A.   Yes.  Quite a few were brought in dead or wounded, quite a few.

17        Q.   Could one be sure that for a while there would not be any

18     fighting, even when there was a cease-fire that was declared?  Did you

19     still have to be cautious at the front line, and were the cease-fires

20     often violated?

21        A.   Of course you have to be cautious.  You cannot relax at any

22     moment.

23        Q.   Could you trust the cease-fires or were they violated often?  Can

24     one say that there was shooting every day almost?

25        A.   No one trusted anyone, and there was shooting.

Page 17771

 1        Q.   Can you say that after that, during the war years in Zvornik

 2     there was relative peace and that things got better as the months went

 3     by?

 4        A.   Yes.

 5        Q.   Are you aware of the fact that almost two-thirds of the -- of the

 6     municipality were controlled by the Muslims and that we controlled only

 7     very few Muslim villages, actually, and that roughly speaking, everybody

 8     controlled their own part of the municipality?

 9        A.   Yes.

10        Q.   Is it correct that in Kozluk and Divic most of the Muslims who

11     had fled during the war returned in the meantime?

12        A.   I think about 80 per cent, if not even 90 per cent.

13        Q.   Thank you.  Do you know whether the Serbs returned to Serb

14     villages that remained in the federation?

15        A.   They are coming back, but perhaps 5 or 10 per cent.

16        Q.   Thank you very much.  I believe that there is no need to disturb

17     you any longer.

18        A.   You're welcome.

19        Q.   Thank you for your testimony.

20        A.   You're welcome.

21             JUDGE KWON:  Ms. Elliott.

22                           Re-examination by Ms. Elliott:

23        Q.   Just one matter, Mr. Vidovic.  Mr. Karadzic asked you a question

24     which was who ordered Mr. Ristanovic to carry out that mission, and he

25     was referring to the five or six buses from Karakaj Technical School to

Page 17772

 1     Pilica, and your answer was, "Pivarski."

 2             My question is:  Do you know who commissioned those five or six

 3     buses?

 4        A.   Maybe I did not hear it right.  Five or six buses.  They

 5     together, but since I think they say that Brano had promised them, then

 6     Brano did that.

 7        Q.   So your evidence is that Brano Grujic organised the buses, and

 8     Brano Grujic was arranging the exchange of the prisoners.  Is that fair?

 9        A.   Probably, because I don't know.  Dragan Ristanovic just said that

10     Brano Grujic had said that they should be exchanged, and that is why I

11     think that it's Brano Grujic, Dragan, and this Pivarski.

12        Q.   If that's the case that you don't know and you're relying on

13     statements made to you by Mr. Ristanovic about Brano Grujic, why did you

14     answer Mr. Karadzic's question with Pivarski?

15        A.   Yes.

16        Q.   So it would be incorrect to say that to the best of your

17     knowledge it was Pivarski who ordered the buses and the transfer of the

18     people for their exchange?

19        A.   No, no.  I heard that from Dragan, that Brano said that they

20     would be exchanged, and Pivarski was there.  There, I assume that that's

21     it.

22             THE ACCUSED: [Interpretation] May I just put one question?

23             JUDGE KWON:  Yes.

24                           Further cross-examination by Mr. Karadzic:

25        Q.   [Interpretation] Would Pivarski's men be on the bus if Pivarski

Page 17773

 1     were not in charge of that?  He did not have many men; right?

 2             MS. ELLIOTT:  Your Honour, this question calls for speculation on

 3     the part of the witness, I believe.

 4             JUDGE KWON:  Yes.  I agree.

 5             Yes, Mr. Vidovic, now your evidence is over.  On behalf of this

 6     Chamber and the Tribunal as a whole, I would like to thank you for coming

 7     to The Hague.  You're now free to go, but we'll rise all together.

 8             THE WITNESS: [Interpretation] Thank you.

 9             JUDGE KWON:  We'll resume tomorrow afternoon, quarter past 2.00.

10                           [The witness withdrew]

11                           --- Whereupon the hearing adjourned at 7.08 p.m.,

12                           to be reconvened on Wednesday, the 24th day

13                           of August, 2011, at 2.15 p.m.