Tribunal Criminal Tribunal for the Former Yugoslavia

Page 18744

 1                           Wednesday, 14 September 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.18 a.m.

 6             JUDGE KWON:  Good morning, everyone.  My apologies on behalf of

 7     the Tribunal for the confusion as to the courtroom.  The Appeals Chamber

 8     had to have its hearing in Courtroom I.

 9             If somebody could take a look at Judge Baird's computer?  Mine is

10     working and we are sitting pursuant to Rule 15 bis with

11     Judge Howard Morrison sitting in the Appeals hearing of Lukic and Lukic.

12     Before we continue with the cross-examination of this witness I have to

13     ask Mr. Robinson the -- whether your submission yesterday or motion to

14     strike out the cross-examination part of this witness in his previous

15     transcript is something we have to rule upon?  Was it a serious motion?

16             MR. ROBINSON:  Well, we would prefer actually to have an adequate

17     time for cross-examination and keep the entire transcript intact, but in

18     the alternative we prefer to have more time for Dr. Karadzic's

19     cross-examination, if you have reduced his time as a result of the

20     inclusion of the Brdjanin cross.  So our preference is to keep it all

21     together but give him enough time.

22             JUDGE KWON:  Yes.  That's consistent with our understanding.

23                           [Trial Chamber confers]

24             JUDGE BAIRD:  Mr. Robinson, we weren't sure whether it was

25     something on which we had to rule so we thought we would get from you

Page 18745

 1     exactly what your situation was.

 2             MR. ROBINSON:  No, I don't think you have to explicitly rule on

 3     that.

 4             JUDGE BAIRD:  Splendid.  Thank you very much, indeed.

 5             JUDGE KWON:  Very well.  Thank you.  Mr. Karadzic, please

 6     continue.

 7                           WITNESS: MIRZET KARABEG [Resumed]

 8                           [Witness answered through interpreter]

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

10             MR. KARADZIC: [Interpretation] Good morning, your Excellency and

11     good morning to everybody.  I'm hearing the English now on channel 6.

12     Can you hear the English.

13             JUDGE KWON:  If you give it a try again.

14             MR. KARADZIC: [Interpretation] I hope everything is working now.

15        Q.   Good morning, witness.

16        A.   Good morning.

17        Q.   Because of protected witnesses, I'm not going to refer to you as

18     your -- I sometimes refer to names but, Mr. Karabeg, is it true and

19     correct that the Muslims, the officers, tried to dissuade you from armed

20     action against the Serbs in Sanski Most?

21        A.   No.  There is no barracks there, no officers or anything

22     military, any military posts at all.

23        Q.   But a prominent officer, Muslim officer, was later the commander,

24     the corps commander, wasn't he?

25        A.   Yes.  Mehmed Alagic.  Mehmed Alagic retired and Mehmed Alagic

Page 18746

 1     dealt with different affairs.  He didn't contact us in any way.

 2     Mehmed Alagic was in Travnik when he was expelled.

 3        Q.   Thank you.  Can we now take a look at 1D00013 next, please, on

 4     e-court.  Before that he was an active JNA officer, was he not?

 5        A.   Yes, he was.

 6        Q.   Would you focus on the Serbian version that's been highlighted

 7     and this is an official note tailed [as interpreted] by the police, the

 8     Security Services Centre, and it says here that the subject is

 9     Mehmed Alagic.  It gives his particulars and paragraph 2 says that he was

10     going to be the commander of Territorial Defence in Sanski Most.  That he

11     was earmarked for that.  Can you read this passage?

12        A.   Yes, I can.

13        Q.   Well, read what it says there in that paragraph in the rectangle.

14             It says here - does it not? - that the leaders of the SDA,

15     Kurbegovic, Redzo; Karabeg, Mirzet; Sejfo Krantic; Halilovic, Nijaz

16     conducted talks, tried to persuade him to join them.

17             JUDGE KWON:  Just a second.  Yes, Ms. Sutherland?

18             MS. SUTHERLAND:  Good morning, Your Honour, Mr. Karadzic is

19     putting to this witness a statement of another witness which the

20     Trial Chamber was dissuading him from doing previously.  He can simply be

21     putting any proposition he wishes to put to the witness without doing it

22     in this manner, in my submission.

23             JUDGE KWON:  Yes.  I quite agree with you, Ms. Sutherland.

24             MR. KARADZIC: [Interpretation] With all due respect, I have to

25     disagree, with all due respect for the Trial Chamber and everybody else.

Page 18747

 1     This isn't a statement.  It's an official note made by a secret police

 2     policeman.  And it records what they learnt, the information gathered.

 3     It is not Alagic's statement as such.

 4             JUDGE KWON:  Not quite different from the statement.  It is a

 5     result of its investigation or interview of this third person.  You can

 6     just put your proposition to the witness.

 7             MR. ROBINSON:  Excuse me, Mr. President.  If I can just intervene

 8     on Dr. Karadzic's behalf.  Yesterday, Dr. Karadzic asked this witness

 9     whether or not the Muslims were arming themselves and the answer that he

10     got at first was, no, that's what you say, Dr. Karadzic, and then maybe

11     some people were arming themselves.

12             It was only after Dr. Karadzic showed him the book in which he

13     was the executive editor, one of the editors, that the witness not only

14     acknowledged that the Muslims were arming themselves but that he,

15     himself, participated in the financing of the purchase of those arms

16     which was in the book.  Now if Dr. Karadzic is limited to simply putting

17     propositions to a witness without confronting the witness with sources of

18     that information, then he's not going to be as effective and the

19     cross-examination will not be as correct as it can otherwise be, as

20     productive for the Chamber as well.  So I think he's entitled to do what

21     he's doing.

22             JUDGE KWON:  Mr. Robinson, I do not disagree with you.  What he

23     first has to do is to put his proposition to the witness and then he can

24     confront the witness with some other third party statement if possible --

25     if necessary.  But don't start with reading out third party statements.

Page 18748

 1     That's what I'm telling him.

 2             MR. ROBINSON:  Very well.  I think that's very correct,

 3     Mr. President.

 4             MR. KARADZIC: [Interpretation] Thank you.  I first asked about

 5     Alagic and the witness denied it.  He said that Alagic did not engage

 6     anyone.  He said that Alagic had nothing to do with them.  Now this

 7     document shows that this particular witness, among those three or four

 8     men, tried to persuade Alagic to accept becoming the Territorial Defence

 9     commander.  It was unsuccessful, but later on, he did take it up.  So can

10     you say -- can you tell us that this is what it says, that the

11     6th Krajina was strong and that you didn't need to do that.

12        A.   It was like this.  You are putting something to me which comes

13     from your organs, established erroneously and falsely by your organs.  I

14     didn't know Alagic at all before the war, nor was Alagic interesting in

15     any way.  And you are now putting this document to me from the security

16     station in Prijedor where it says what it says.  You could have said

17     whatever you like, that I'm a murderer or that the person who sent the

18     document can say that.  Give me a document from a neutral side, from --

19     by our side.  Don't send me documents from the Banja Luka Security

20     Services Centre or what does it say here, Prijedor, it says which anybody

21     could have wrote.  That is your view of affairs, your thoughts.  So

22     you're doing that all the time.  You're presenting your views that you

23     were right because you killed 758 people in Sanski Most because allegedly

24     they were guilty of something, of intending to do something, and so on

25     and so forth.  So read the header of this document, read what it says at

Page 18749

 1     the top.  Can we zoom down, please so that we can see the top of the

 2     document?  No persuasion, no discussion.  It says here security centres

 3     Banja Luka, Prijedor department, and so on and so forth.  So it's their

 4     organs, their authority, their men, their people, and who knows what they

 5     did.  I don't.  And now we should trust this document.

 6        Q.   Thank you.  Mr. Karabeg, all I'm saying is that General Alagic

 7     mentions you as one of four men who tried to recruit him and he said that

 8     he tried to dissuade you and to tell you that the 6th Krajina Brigade was

 9     a very strong brigade, it wasn't me that tried to persuade you of this.

10             JUDGE KWON:  You heard the witness's -- from the witness how or

11     what he thinks about this document.  That's what you received.  Otherwise

12     you need to call General Alagic if necessary.  Don't argue with the

13     witness.  Just get on with the evidence you heard from the witness.

14             MR. KARADZIC: [Interpretation] Unfortunately, Mr. Alagic has died

15     since but this is a state organ and this was recorded by that state

16     organ, and I just wanted to put it to you because Karabeg accepts the

17     fact that they had organisation and arms, he accepts that only when he's

18     shown documents which state that.

19        Q.   Now, can we take a look at 65 ter 4988 next, please?  Is it true

20     and correct, Mr. Karabeg, that you knew that the Serbs knew about all

21     your actions, militarily organised actions and your arming?  Isn't that

22     true?

23        A.   Well, I don't know.  All I can do is laugh at that question of

24     yours.

25        Q.   All right.  Now, can we have page 161, in Serbian, and it is 151

Page 18750

 1     in English.  It is the diary of the late Rasula.  Can we turn to the

 2     previous page to see the date, which is 4 May 1992.  Just briefly, in

 3     Serbian, the previous page to be displayed just to see the date.  It was

 4     a session held on 4 May 1992.  And it says KS, diacritic, and then 1992.

 5     Now, can we go back to the page we were on a moment ago?  Next page,

 6     please.  So we are interested actually in those two pages.

 7             It says the SDA, the areas of responsibility in the town.  The

 8     first town command, the old fire station.  The second town command, the

 9     primary school, elementary school.  That's right.  Thank you, that's

10     fine.  Second town command, the Vuk Karadzic elementary school.  The

11     third town command was Zdena Pobrijezje, probably a firm and then the

12     commander, Sabic.  Then we don't know who this Chief of Staff is, it just

13     says Chief of Staff.  Then the civilian protection commander,

14     Ivan Filipovic and then added another name, Fajko, and then the chief of

15     the public security station, Suad Sabic and so on and so forth.  The

16     chief of artillery, Colic, Mirsad.

17             Did you know these people, did you know Nihad Kljucanin; Sabic,

18     Suad; Mehmed Alagic; and the other names listed there, Mirsad Colic and

19     so on?  Did you know them?

20        A.   I'd never heard of Mirsad Colic.

21        Q.   Maybe his name is Calic?

22        A.   I really can't say.  I don't know.

23        Q.   Did you know Adem Zukic, for example?

24        A.   No, I didn't.

25        Q.   Who was the chief of artillery in Sanski Most, the Muslim

Page 18751

 1     artillery, I mean?

 2        A.   Radovan Karadzic.  You're putting something to me which your

 3     closest associate wrote, and wrote in his diary at that.  And now you're

 4     trying to display that as being evidence.  When that diary was supposed

 5     to be adopted as an original document, you brought that into question at

 6     this Tribunal because of that word that was introduced here.  So that's

 7     what I'm saying.  Yes, the commander of the artillery was

 8     Radovan Karadzic.  That's what I'm saying.

 9        Q.   Don't be angry at me.  You can just --

10        A.   No, I'm not angry, I'm not angry.

11        Q.   You can say no.

12        A.   Well, I said no.

13        Q.   May we turn to the next page, please?  Let's look at the

14     left-hand side, the number of armed units and their distribution,

15     disposition.  There are two detachments and two companies in Sana, then

16     the 1st Company, 2nd Company, independent company, and then an

17     independent platoon and so on.  Then we have Modra, Zenkovici, Lukavice,

18     Cirkici; they are all villages.  Each village had a platoon or

19     detachment.  Kamengrad, et cetera.  Was that the case or not?

20        A.   No, it wasn't.

21        Q.   Thank you.  May we now take a look at the right-hand side?  Now,

22     Trnova, is that a Muslim village?

23        A.   Yes, it is.

24        Q.   And what about Caplje, and Tomina?  Tomina is half-half, isn't

25     it?  There is Vrhpolje, has a detachment, Hrustovo, a detachment, Stara

Page 18752

 1     Rijeka, Majdan, Bartikovci, a detachment, Dzevar, a platoon.  Are those

 2     all Muslim villages?

 3        A.   Yes, they are.  Small Muslim villages.

 4             Your Honours, I would like to ask you to ask him not to put these

 5     documents to me because they were written by Nedeljko Rasula, his closest

 6     ally and he wrote whatever he felt like writing down in his diary.  As

 7     far as I know, they put into question their own material, the evidence

 8     just because of a word that was introduced in the Latin script.

 9             JUDGE BAIRD:  Mr. Witness, may I say this:  Dr. Karadzic is

10     defending himself and he is entitled to put these documents to you.  It

11     will be entirely a matter for you --

12             THE WITNESS: [Interpretation] I apologise.  Very well.

13             JUDGE BAIRD:  It will be entirely a matter for you if you accept

14     it or you don't.  You just say so.  But he's entitled.  Thank you.

15             JUDGE KWON:  Moreover, if I can add this to what Judge Baird said

16     is that this document was introduced by the Prosecution during their

17     examination-in-chief of your evidence.  So that is further reason for

18     Mr. Karadzic to be entitled to put anything to you.  But it is for you to

19     say you don't know or do you know.  It's for you to accept or not.  Yes.

20     Mr. Karadzic.

21             MR. KARADZIC: [Interpretation] Thank you.  May we turn to the

22     next page, please, to see what was going on in Fajtovci.

23        Q.   Is Fajtovci a Muslim village too?

24        A.   Well, yes, I think it is, yes.

25        Q.   It says 20 automatic rifles, two PAPs, 40 to 50 pistols, 45 to 50

Page 18753

 1     pistols, Ismet Alagic and Said Horozovic, commander and deputy commander.

 2     Sehovci, 20 automatic rifles, a total of 72 armed individuals, et cetera,

 3     et cetera.  May we turn to the next page, please?  Another page, please,

 4     next page.  On the left bank in Sanski Most, who was -- who was on the

 5     left bank, Muslims, weren't they, mostly, the majority?

 6        A.   Well, roughly, yes.

 7        Q.   Thank you.  Now, take a look at the composition of the

 8     independent company on the left bank.  Said Besic, Ermin Sabic,

 9     Jasmin Jakupovic, Bekir Kovacevic and so on and so forth.  All of them

10     together made up the independent company.  There are snipers there,

11     mortars there, infantry, artillery, technical backup and so on and so

12     forth, logistics.  So, this is what the intelligence learnt by the Serb

13     side about your military strength in town and around the town in the

14     villages.  Do you say that that is not correct or that you didn't know

15     about it?

16        A.   It's not true.  Let me tell you something now.  A man who is from

17     Sanski Most, and who was at Manjaca, he was missing a leg, he didn't have

18     a leg and he was caught as if he was climbing a 7-metre high tunnel and

19     firing with a sniper.  They captured him and said that that that's what

20     he was doing.  So that's the kinds of documents you're showing me.  This

21     is just not true.

22        Q.   Do you mean to say that the Muslims in Sanski Most did not have

23     any snipers and that they didn't use snipers to kill?

24        A.   That's what I'm saying.  They did not.

25        Q.   I'd like to tender these pages into evidence, please.

Page 18754

 1             JUDGE KWON:  Were they included in the part you tendered

 2     yesterday?

 3             MS. SUTHERLAND:  No, Your Honour.

 4             JUDGE KWON:  Yes, they will be added.

 5             THE REGISTRAR: [Overlapping speakers]

 6             MR. KARADZIC: [Interpretation] Staying with that document, can we

 7     look at page 155 in Serbian and 141 in English?

 8             JUDGE KWON:  Just for the record, can I know the Exhibit number

 9     of Mr. Rasula's diary?

10             THE REGISTRAR:  Yes, Your Honour, that's Exhibit P3329.

11             MR. KARADZIC: [Interpretation] May we zoom in to the right-hand

12     side?

13        Q.   Do you read the Cyrillic script?  You do, don't you, Mr. Karabeg?

14        A.   Well, when it's printed, yes, but I'm not so good with

15     handwriting.

16        Q.   Colonel Basara here says that Redzo told him that it wasn't a

17     good idea that he came with the army, with soldiers, and he says that he

18     said that the MUP could be painlessly divided, and then Redzo wielded his

19     influence and persuaded me not to bring in the army.

20             And then he goes on to say the driver noticed that they were

21     deploying snipers on the roofs and that this was organised by the

22     Muslims.

23             Do you see that?  Do you see that Mr. Basara and you said of him

24     that he was neutral, that he wanted to -- you said that he wanted to

25     protect the Muslims from the Serb extremists.  Now, was it his job to

Page 18755

 1     protect the Serbs from Muslim extremists as well?

 2        A.   Let me tell you, when I said this, I said that he'd led us

 3     astray, he duped us.  We thought he was protecting us, but we knew

 4     straight away which side he sided with.  We know who he was because he

 5     brought in the 6th Krajina Brigade from Pakrac.  We know what he did to

 6     Sanski Most.  I said that he duped us.  We thought that he wanted to do

 7     what he said, but he did something quite different altogether.

 8             JUDGE KWON:  Mr. Karadzic, you can go on with this witness on

 9     these matters, but I think you can't simply complain about your shortage

10     of time.

11             MR. KARADZIC: [Interpretation] Your Excellency, I want to put

12     evidence to this witness, as you had said, evidence that the Prosecution

13     relies upon.  This Basara noted that he had been deceived and that

14     snipers shooters were lining up.  The witness had to see that and then

15     let him say that he did not see it.

16             JUDGE KWON:  Bear that in mind, we'll consider how you conduct

17     your cross-examination when you ask for further time or extension of --

18     further extension of time at the end of your cross-examination.  Bear

19     that in mind.

20             MR. KARADZIC: [Interpretation] Thank you.  Can this be admitted?

21             JUDGE KWON:  Yes, this page will be added.

22             MS. SUTHERLAND:  Your Honour, this meeting of 20 April was --

23             JUDGE KWON:  Already in the evidence?

24             MS. SUTHERLAND:  Part of the evidence, yes.

25             JUDGE KWON:  Thank you very much.

Page 18756

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Mr. Witness, in your statements, you focused on the census and

 3     you said that there were more Muslims and that there were a couple of

 4     thousand less Serbs.  As a man who hails from a family that was not an

 5     Ustasha family, are you going to confirm or deny that in the

 6     Second World War at Susnjar, in a single go, in a single operation, 5.300

 7     Serbs were killed by the Ustashas.  Are you denying that or confirming

 8     that?

 9        A.   Denying it.

10        Q.   That is not true?

11        A.   We always laugh at this Serb data of yours.

12        Q.   Thank you.  Are you trying to say that among those Yugoslavs

13     there weren't any Serbs and that there wasn't a majority of Serbs in 1991

14     when Muslims and Croats were no longer in favour of Yugoslavia and the

15     elections in which -- that Rasula won, don't they show that Sanski Most

16     was majority Serb?

17        A.   Not necessarily.  Because in Sanski Most there were a great many

18     citizens who were of Bosniak ethnicity, who worked in Austria, Germany,

19     Slovenia and other countries and therefore they could not vote in the

20     election and that's why the Serb side won.

21        Q.   Do you accept --

22             JUDGE KWON:  Yes, Ms. Sutherland?

23             MS. SUTHERLAND:  Your Honour, I was rising just because of the

24     compound nature of the question, if Mr. Karadzic can put single questions

25     to the witness, it's preferable.

Page 18757

 1             JUDGE KWON:  Thank you.  Let's continue.

 2             MR. KARADZIC: [Interpretation] Thank you.

 3        Q.   Do you agree, Mr. Karabeg, that as for the overall number of

 4     neighbourhoods in Sanski Most, Serbs were an absolute majority in 45, a

 5     relative majority in 2, and that the population was mixed in 20, whereas

 6     the Muslims had 16 neighbourhoods with a majority of their own, then one

 7     mixed neighbourhood or actually eight mixed neighbourhoods?

 8        A.   I don't agree with that.

 9        Q.   Thank you.  You said, Mr. Karabeg, that Serbs wanted to proclaim

10     the entire municipality of Sanski Most a Serb municipality?

11        A.   Yes, and that's what they did on 3 April 1992.

12        Q.   Is it correct, Mr. Karabeg, that their proposal was to set up two

13     municipalities, a Serb municipality and a Muslim municipality, out of the

14     existing local communes of Sanski Most?

15        A.   Well, let me tell you.  I don't know whether they were thinking

16     of creating two municipalities.  They just wanted a division.  They just

17     wanted to have Sanski Most divided.

18        Q.   Divided into two municipalities, right?

19        A.   We were not discussing two municipalities.  Just a division.

20     That is what the Serb side persistently asked for.

21        Q.   Thank you.  So during the direct examination, you said that one

22     side of a street was to belong to the Serbs and the other side to the

23     Muslims.  In Sarajevo, Zagreb, Belgrade, Mr. Karabeg, in all of these

24     places where there are several municipalities, don't administrative

25     boundaries run down streets or even within a single building?

Page 18758

 1     Administratively doesn't one part belong to one municipality and another

 2     one to another municipality?

 3        A.   You did not understand what I was saying, when I was explaining

 4     this.  I said even one house.  It wasn't like half/half.  It wasn't

 5     Bosniak people on one side, Serb people on the other side.  A street

 6     would be 200 metres long, Serb people, Serb.  And then there is

 7     interruption and then Bosniaks live there, and then that is Muslim.

 8     That's as you put it.  So this street of one kilometre or two is

 9     interrupted every 200 metres in that way, that it should be either Serb

10     or Muslim.

11        Q.   Thank you.  So you accept that Serbs were only counted --

12     counting on Serb concentrations and that Muslim concentrations should be

13     a Muslim municipality, right?

14        A.   I accept that, but that wasn't all of it.  There was quite a bit

15     of the Muslim parts that the Serbs wanted for themselves.

16        Q.   Thank you.  Now I'm going to read a summary out to you.  Muslim

17     population concentrations.  Tell me, was this supposed to be the Muslim

18     or the Serb municipality?  This is it:

19             Sehovci, Trnova, Skucani Vakuf, Podbrezje, Okrec, Naprelje,

20     Modra, Lukavica, Kijevo, Husinovci, Hrustovo, Gornji Kamengrad,

21     Donji Kamengrad, Gorice, Dzevar, Denisevci, Mahala, Muhici, are all of

22     these concentrations Muslim?

23        A.   For the most part.

24        Q.   Did the Serbs want to include in their own municipality any one

25     of these concentrations?

Page 18759

 1        A.   They wanted to include everything and they did include

 2     everything, ultimately, in their municipality.

 3        Q.   Thank you.  Can we have 65 ter 04992?  This is a statement of

 4     reasons for the establishment of the Serb Municipality of Sanski Most.

 5     In English, these local communes are already listed.  Those that are part

 6     of the Serb municipality.  So can we have this same page kept in English?

 7     Can we have page 2 in Serbian?  Muslim -- actually the next one.  This

 8     was just identification.  Have a look at this now.  It's in the Latin

 9     script, it's in Serbian so you can read it.

10        A.   I'd like to have this enlarged, please, if possible.

11        Q.   Sehovci, Trnova, Skucani Vakuf, it's simply not there, nor is

12     Podbrezje, Okrec, Naprelje, Modra, Lukavica, Kijevo, Husinovci, Hrustovo,

13     Gornji Kamengrad, Donji Kamengrad, Gorice, Dzevar, Denisevci, Mahala,

14     Muhici, none of those local communes are there, those where there are

15     large concentrations of Muslim population.  So the Serb Municipality of

16     Sanski Most consists of the following local communes.  As you can see,

17     all of those that were not included --

18        A.   We have just had a polemic.  You said that Caplje was a large

19     Muslim concentration, Fajtovci as well, and on this list I see both

20     Fajtovci and Caplje.

21        Q.   Are there Serb hamlets in Fajtovci and Caplje?

22        A.   Well, let me tell you, we've just had a polemic.  You mentioned

23     that Caplje and Fajtovci had large Muslim populations and that is true

24     and I see this here on this list that they would be part of the Muslim --

25     of the Serb municipality.

Page 18760

 1        Q.   Do you know that there are Serb hamlets in that local commune?

 2        A.   I don't know which hamlets exist there.

 3        Q.   Thank you.  Can this document be admitted?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  Exhibit D1679, Your Honour.

 6             MS. SUTHERLAND:  Your Honour, I do note that part of this exhibit

 7     is already -- was exhibited yesterday as P3304, the decision of the

 8     Serbian people the Sanski Most municipality of 25 March.  And also the 3

 9     April --

10             JUDGE KWON:  What do you mean by part of this exhibit?  Which is

11     the more complete one?

12             MS. SUTHERLAND:  The one that was exhibited yesterday I think has

13     signatures on it.

14             JUDGE KWON:  Thank you.

15             MS. SUTHERLAND:  And also the last part of it, the decision dated

16     3 April because this consists of two different documents.  That was also

17     exhibited as a document that was shown to Mr. Karabeg in his Brdjanin

18     testimony and I'm just trying to find the exhibit number for that.

19             JUDGE KWON:  In conclusion, there is no need to admit it

20     separately?

21             MS. SUTHERLAND:  I don't think so, Your Honour.  I mean, there

22     are different versions of it.  This is unsigned but it's the same

23     documents.

24             JUDGE KWON:  If I get confirmation from Mr. Robinson or

25     Mr. Karadzic, we can just do without admitting it.  Let's proceed.  Thank

Page 18761

 1     you, Ms. Sutherland.

 2             MS. SUTHERLAND:  Sorry, 3 April decision is P03325, so they are

 3     both in evidence already.

 4             MR. KARADZIC: [Interpretation] Thank you.

 5        Q.   Mr. Karabeg, do you accept that the Serb side envisaged that

 6     there should be a Muslim municipality as well as a Serb municipality and

 7     that they should have both their respective Municipal Assemblies, police

 8     stations and so on?  Is that what the Serb side envisaged and your side

 9     refused?

10        A.   No.  The result of that is that on 3 April 1992, the Serbs

11     proclaimed the municipality of Sanski Most to be a Serb municipality and

12     it was annexed to Banja Luka.

13        Q.   Thank you.  Was Sanski Most already part of the community of

14     municipalities of Banja Luka?

15        A.   No, not of Banja Luka.  Of Bosanska Krajina.  You know that there

16     are two Krajinas, Ljuta Krajina, around Cazin, and Bosanska Krajina

17     around Banja Luka and that's the one we belonged to before the war.

18        Q.   Can we have Rasula's diary?  That is 65 ter 4988, or perhaps it

19     has a joint P number but that's the number anyway, and then the Serb

20     version, 154, and in English, it's page 139.  Did you attend this meeting

21     when General Talic and Colonel Basara came on 20 April and Major Zeljaja?

22        A.   Yes.

23        Q.   Thank you.  Can we zoom in on the left where it says in Cyrillic

24     the meeting on 20 April, it says:

25             "Present, Mirzet, Redzo, Sabic, Ante and Vlado."  Vlado is

Page 18762

 1     probably Vlado Vrkes, a Serb?

 2        A.   Yes.

 3        Q.   Thank you this is what Redzo says:

 4             [As read] "The official position of the Muslim people is to

 5     observe the peace.  The SDA abided by the agreements and will of the Serb

 6     people."

 7             He reads the proclamation of the parties from 15 April 1992,

 8     agreement to carry out divisions in the municipality.  Do you see that,

 9     Mr. Karabeg, that Redzo, in your presence, informed General Talic that

10     agreement had been reached to carry out divisions in the municipality?

11        A.   Please, these are Rasula's thoughts.  General Talic would not

12     have come had all of that been well and fine.  They would not have

13     addressed him.  He had deceived us too, because we thought the army, the

14     JNA, that it was the people's army, but it immediately sided with you,

15     which is only natural because more than 90 per cent of the officers were

16     ethnic Serbs.

17        Q.   Thank you.  Do you see that he is actually referring to Redzo's

18     words, he is not phrasing this himself?  It says "Redzo:"

19        A.   He can say whatever he wants.

20        Q.   Thank you.

21        A.   He can say whatever he wants.

22        Q.   Do you remember, from yesterday's document, the meeting at the

23     Islamic religious community, that it is said that time should be bought,

24     there should be procrastination, do you remember that?

25        A.   I say the same to that document too.  These are your thoughts.

Page 18763

 1     This is your way of thinking.  I do not know whether that kind of meeting

 2     was ever held at the Islamic community.

 3             JUDGE KWON:  Mr. Karabeg, a minute ago you said he can say

 4     whatever he wants.  Who did you have in mind?

 5             THE WITNESS: [Interpretation] Rasula, the author of the diary.

 6             JUDGE KWON:  Not Redzo?

 7             THE WITNESS: [Interpretation] No, no, not Redzo.  The author of

 8     the diary.

 9             JUDGE KWON:  So according to this diary, Redzo allegedly said

10     that.  So you are denying that, you are denying that Redzo said this?

11             THE WITNESS: [Interpretation] That's not true.  That is not true.

12     We tried not to be seen or heard at that meeting.  We were so humble

13     because the military representatives were in charge of the meeting.  They

14     were trying to represent themselves as some kind of peacemakers, who

15     would ease all these tensions.

16             JUDGE KWON:  Thank you, Mr. Karabeg.  Please continue,

17     Mr. Karadzic.

18             MR. KARADZIC: [Interpretation] Thank you.

19        Q.   Is it correct that at that meeting, Talic said, agree any which

20     way you want but do it fast and do it in peace?

21        A.   Let me tell you this:  This meeting was held and certain

22     conclusions were reached.  Within that framework we suggested to

23     General Talic that he personally reads these conclusions on Radio Sanski

24     Most through the media because then that would carry more weight, and the

25     Serb people would accept that.  However, it was stated that that was

Page 18764

 1     technically impossible.  We said, "General, please, you have a telephone

 2     here.  Do call Radio Sana, and ask them to carry live what you will say

 3     now."  And he said, "No, I'm in a hurry."  He said what you said just

 4     now:  Do that and meet as soon as possible to get this done.

 5             We agreed on a meeting at 6 p.m., that is to say 1800 hours, not

 6     knowing anything.  It was the municipality building.  We had a meeting

 7     there, in front of the municipal building there was barbed wire,

 8     hedgehogs, two APCs.  All of that was encircled.  No meeting, no nothing.

 9     However, General Talic said to me, Karabeg, you as the representative of

10     the authorities, if anything is wrong, please feel free to phone me, use

11     this number.  He gave me his telephone number.  I think I called him on

12     Wednesday.  This meeting was on Monday and I just remember that when

13     I did phone him and when I told the man at the telephone exchange who it

14     was I was surprised that in about 20 seconds, I had General Talic on the

15     line.  I explained what the situation was, as you had put, nothing doing,

16     the Serb side does not accept this, Rasula does not accept this, and he

17     used a sort of swear word and said, "What is this?  Why is Rasula not

18     accepting this?  I'll see about that with him."  The next day was the

19     holiday of Banja Luka.  And I was watching the news and I saw a videoclip

20     from that meeting where there was Karadzic, Mrs. Plavsic, General Talic

21     and all the rest.  They were all sitting there and I sort of said to

22     myself, my goodness, why did he deceive me, why did he lie to me?  And

23     that's the way it was all the time after that.  This is what they

24     resorted to.  This is how they deceived us.

25        Q.   Thank you.  Mr. Karabeg, I'm not going to check whether I was at

Page 18765

 1     Banja Luka at a particular point in time and why that would have been a

 2     bad thing for political personages to attend the celebrations of

 3     Banja Luka Day.  But let's leave that aside.  Are you saying that on 4

 4     April, the Serbs declared that all of Sanski Most was the Serb

 5     municipality?

 6        A.   I don't know whether it was the 3rd or the 4th of April but it

 7     was the Serb Municipality of Sanski Most.

 8        Q.   Thank you.  Can we have a look at this diary again, in English

 9     [as interpreted] 152 and in English, 138.

10             Please look at this.  Could this be zoomed in?  The handwritten

11     part, please.

12             Please look at this, Mr. Karabeg.  What it says here, on 16

13     April, the 2nd assembly of the -- the second session of the Assembly of

14     the Serbian Municipality of Sanski Most.  So you see that there was a

15     Serbian part and you said that they claimed the entire one.  Look at the

16     agenda, please.  The information on the results of the elections and

17     inter-party agreement allocation of seats.  So on 16 April they were

18     still counting on the fact that there would be a Muslim municipality as

19     well, is this what it says here?

20        A.   I don't know what it says here.  I can't see well.  Let me tell

21     you.  There was the time when we discussed not about the divisions.

22     First, they started with the police, they wanted people to sign a loyalty

23     oath.  There were Serbian police, they wanted everyone to carry Serbian

24     insignia and they wanted a Serbian flag, with four Ss, to be flying over

25     the police building and they wanted this to apply to everything.

Page 18766

 1        Q.   Mr. Karabeg, do you see here that under item 5 they speak about

 2     the transformation of the public security station?  Do you wish to say

 3     that the Muslims and Croats who would remain to work in the Serbian

 4     police station were not supposed to swear loyalty to their employer and

 5     to promise that they would apply laws in their work?

 6        A.   Well, why should there be a Serbian police when we used to have

 7     the police of Bosnia-Herzegovina?  It was lawful, it worked well, and it

 8     was broken apart by the Serb side who wanted some paramilitary or

 9     para-forces to be established and who wanted staff to declare loyalty and

10     so on.

11        Q.   Could we have the next page, please?  You used to mention the

12     SDK, the public audit service, and you used it as an example of something

13     that Serbs had done wrong, right?

14        A.   Yes.

15        Q.   Could we see 140 in Serbian and, in English, 124?  While we are

16     waiting for that, Mr. Karabeg, did you understand that there was a

17     political process underway in Bosnia and Herzegovina according to which

18     the Serbs were to accept an independent Bosnia and Herzegovina and they

19     wanted their conditions to be met, the conditions for them accepting an

20     independent Bosnia-Herzegovina and you were all the while deceiving them

21     through these false negotiations?

22        A.   What do you mean false negotiations?

23        Q.   Well, you saw in that document that it said that you should stall

24     it and you should procrastinate in order to gain time.

25        A.   That's what you say.

Page 18767

 1        Q.   Look at this, please.  A, B and C, look at C, please.  Violation

 2     of all federal regulations, from the constitution to the laws, fiscal

 3     laws, the only regulations that are insisted upon are those according to

 4     which the federal state has obligations and not us.  Then item 2.  This

 5     is the session of the Executive Board, Mr. Karabeg, on 16 March.  Do you

 6     remember this?

 7        A.   Not really.

 8        Q.   But you were a member of the Executive Board of your municipality

 9     and you were the president.  Oh, no, I'm sorry, I apologise.  This

10     material was prepared for the session.

11             JUDGE KWON:  Yes, Ms. Sutherland?

12             MS. SUTHERLAND:  I can see the date.  It says for the

13     Executive Committee session and it's dated 3 March.

14             JUDGE KWON:  Yes.

15             MR. KARADZIC: [Interpretation]

16        Q.   Do you see the Serb position, Mr. Karabeg, namely that the public

17     audit service, the SDK, under the influence of the Muslim side is

18     undermining, is destroying the federal state, undermining regulations,

19     and, then under item 2, it speaks about the unlawful cessation of work of

20     the public audit service and separatist behaviour in Sanski Most and so

21     on?  Do you see that the Serb side was making you aware of the fact that

22     the SDK, the public audit service, was acting unlawfully, acting in

23     violation of the federal and republican enactments and laws?

24        A.   Well, let me tell you something.  The flow of funds was in the

25     direction of Sarajevo, which is only natural, and what they were trying

Page 18768

 1     to do was to divert it, to divert the flow of funds and to make the SDK,

 2     the public audit service, work unlawfully.  This was done pursuant to

 3     your wishes, to you, your desires and you wanted to replace this

 4     perfectly decent person in Sarajevo who was at the head of the DSK.

 5        Q.   Could we see 1D?

 6             THE INTERPRETER:  Could the accused please repeat the number?

 7     The interpreters didn't hear the number.

 8             MR. KARADZIC: [Interpretation] And could this page and the

 9     previous one be admitted, please?  No ruling was made regarding that.

10             JUDGE KWON:  Could you repeat the number you want to show us

11     next?

12             MR. KARADZIC: [Interpretation] 1D4245.

13             JUDGE KWON:  And with respect to the addition of additional pages

14     from Rasula's diary, they are not included in your exhibit,

15     Ms. Sutherland?

16             MS. SUTHERLAND:  The 16 -- 16 ...

17             THE ACCUSED: [No interpretation]

18             JUDGE KWON:  Just a moment, Mr. Karadzic.

19             MS. SUTHERLAND:  My apologies.  The 16th of April session wasn't

20     and also this reference to this 3rd of March was not either.

21             JUDGE KWON:  In light of the extensive use or reliance on this

22     Rasula's -- Mr. Rasula's diary, is it not a good idea to admit it in its

23     entirety or through bar table motion.  Mr. Robinson because you objected

24     to admission of this and Mr. Karadzic is heavily relying on it now.

25             MR. ROBINSON:  Yes, that's correct and I think our position is

Page 18769

 1     one of principle, to be consistent.  Because we still believe that we

 2     should have the right to only those portions admitted which are discussed

 3     in court, but if the Chamber finds it more suitable to admit, as you've

 4     done with the Mladic diaries, the whole thing, then we understand that.

 5     But in principle we think that the rights of the accused are better

 6     protected when only those parts of materials from an unavailable witness

 7     are discussed with the witness in court and can be cross-examined.

 8             JUDGE KWON:  Very well.  Understood.  I leave it to the parties.

 9     Those pages will be added.  Yes, Mr. Tieger?

10             MR. TIEGER:  I would just add one thing if there is an emphasis

11     on principle.  This is something that Mr. Robinson and I have discussed

12     and I believe agreed upon.  The confrontation issue is not a matter of a

13     bright-line principle but is a question of weight and I think this -- we

14     maintain the position that there certainly are documents which are

15     coherent and integral and should be admitted as such.  This is a document

16     which has been admitted in numerous previous cases under just that

17     rationale and the issues addressed by Mr. Robinson, as we've discussed go

18     to weight.  So I think he wants to maintain his adherence to a basic

19     underlying principle but I believe that he recognises that that gives way

20     in certain circumstances to the practicalities of a particular document

21     and the issue of how much weight is accorded to various portions, given

22     the totality of the evidence.

23             JUDGE KWON:  In any event, this is a good subject to be

24     considered as a subject of a bar table motion in the future.  Let's

25     continue, Mr. Karadzic.  Have you uploaded the document?

Page 18770

 1             MR. KARADZIC: [Interpretation] Yes.  It's been uploaded now.

 2     Could we zoom into the left column where it says, invitation to the

 3     non-Serb municipalities to join in.  Yes, the left side.

 4        Q.   Do you see this here?

 5             JUDGE KWON:  Yes, Ms. Sutherland?

 6             MS. SUTHERLAND:  Is there a translation available, Your Honour,

 7     in e-court?  Because I don't have one.

 8             MR. KARADZIC: [Interpretation] This has already been adopted with

 9     Mr. Treanor.  I don't know what D number it was assigned.

10             JUDGE KWON:  No.  This is a newspaper article, is it?

11             MS. SUTHERLAND:  Apparently Mr. Reid informs me it's D286.

12             JUDGE KWON:  Thank you.

13             MR. KARADZIC: [Interpretation] Could we zoom -- rather scroll

14     down, please?

15        Q.   See, Mr. Karabeg, the Association of Municipalities of Banja Luka

16     invited other municipalities.  Please look at the end of this text.

17     Signed by Ribar, in order for Bosnian Krajina finally to stop being poor

18     and destitute.  So on 4 May 1991, they send out an invitation to the

19     Cazin Krajina and non-Serb municipalities to join them in order to

20     experience just like they did an economic revival.  We see the

21     translation here.  Whereas your position is that the Serbs wanted to --

22     wanted Sanski Most to annex to some other Serb municipalities and you

23     wanted Sanski Most to join Cazin Krajina where the majority of residents

24     were Muslim, right?

25        A.   Yes.  This was an invitation, and anybody could send out an

Page 18771

 1     invitation.  And we didn't want this.  We didn't want to join

 2     Cazin Krajina.  We wanted to join Bihac, and our wish was fully

 3     justified.  Sanski Most had been destroyed, torched, people killed by

 4     those from Banja Luka, and it was liberated later on by those from Bihac.

 5        Q.   Mr. Karabeg, we are discussing 1991 and early 1992 here.  There

 6     was nothing wrong at the time.

 7        A.   Well, I'm simply making a comparison.  It would be the same.

 8        Q.   Thank you.  Could we see 4988, please, the diary?  English page

 9     126.  In Serbian, 142; in English, 126.  In that meeting, attended by

10     Adil, Mirzet, Ankica, most likely these are people from the SDK, and you

11     say that you should all sit down to discuss how to take over the power?

12             JUDGE KWON:  Just a second.  Whenever we show the document, we

13     just collapse the English page and zoom in the B/C/S page so that the

14     witness can follow.  The Chamber can follow the English pages on our

15     personal computers.

16             MR. KARADZIC: [Interpretation] Thank you.  Could we see page 142

17     in Serbian, if we are going to show only the Serbian text.  I'm not sure.

18     142, please.  The right side, please, the right side.  It says here --

19             MS. SUTHERLAND:  Sorry to interrupt, can Mr. Karadzic advise what

20     meeting this is?  Sorry.

21             MR. KARADZIC: [Interpretation] Well, the witness will be in a

22     better position to tell us this.  This is the meeting of the SDK, the

23     public audit service.  They discussed the chief of the public security

24     station and so on.

25        Q.   Where was this meeting held?

Page 18772

 1        A.   Which one?

 2        Q.   Well, this one in which you participated, where Adil said that

 3     the judicial system should abide by the inter-party agreements and so on

 4     and you said that you needed to sit down and agree on how to take over

 5     power?

 6        A.   With whom?

 7        Q.   Could we scroll up, please?  Three pages prior to this, we see

 8     that this was the 3 March.  This was the preparation for the session of

 9     the Executive Board so there was a meeting on -- there was a session on

10     3 March 1992 where you discussed the unlawful work of the SDK and so on.

11     These are your words.

12        A.   Which ones?

13        Q.   Well, these ones here, do you see them?

14        A.   I don't.

15        Q.   Well, it says here, Mirzet, the leadership in the electric

16     utility company, talk to Bosko and so on then it says that the work of

17     the public security station or rather the chief of the public security

18     station is not good, and so on.  Could we scroll down, please?

19             MS. SUTHERLAND:  Your Honour, I'm sorry to interrupt again but

20     I'm really not following in e-court which meeting Mr. Karadzic is

21     referring to.

22             MR. KARADZIC: [Interpretation] If we go two pages before this, we

23     will see that this is what was said on 3 March 1992 during the session of

24     the Executive Board.  Two pages back.

25             JUDGE KWON:  I think page 124 in English is the page which we saw

Page 18773

 1     earlier on today for the Executive Committee session, 3 March 1992.

 2             MS. SUTHERLAND:  Thank you, Your Honour, I just saw something

 3     about November 1991 on the screen and that was what confused me.  My

 4     apologies.

 5             MR. KARADZIC: [Interpretation] Could we now --

 6             JUDGE KWON:  Mr. Karabeg, do you follow what this meeting is

 7     about?

 8             THE WITNESS: [Interpretation] I don't know.  I would like to

 9     know.  Perhaps I would remember who attended the meeting because you're

10     now asking me about 1992 and it's 2011 now.

11             JUDGE KWON:  So Mr. Karadzic, in order to put your question, just

12     put your question one by one so that the witness can follow your

13     questions.  So you should have shown this first page and explained what

14     this meeting is about and then you can come to his statement.  But in any

15     event, I note the time.  It's time to take a break.  We will have a break

16     for half an hour and resume at 11.00.

17                           --- Recess taken at 10.28 a.m.

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

19             JUDGE KWON:  Very well.  Where were we?  We were on Mr. Rasula's

20     diary.  Go back to page 126.  And what was your question, Mr. Karadzic?

21             MR. KARADZIC: [Interpretation]

22        Q.   If we get to page 126, you say there, inter alia, to sit down and

23     reach an agreement on the takeover of power.  What did you mean by that,

24     unless you meant everyone taking over their own municipality?

25        A.   I don't know what you're saying.

Page 18774

 1             JUDGE KWON:  Just a second, page 126 for English and --

 2             MR. KARADZIC: [Interpretation] Yes, yes.  In English, it's 126.

 3     And it's 142 in Serbian.

 4             JUDGE KWON:  Right side.

 5             MR. KARADZIC: [Interpretation] Yes, yes, on the right-hand side;

 6     Mirzet.

 7        Q.   See that here?  You talked to Bosko and Bosko said to you that it

 8     was the fault of the parties?

 9             JUDGE KWON:  Further down, further down.  Yes.

10             MR. KARADZIC: [Interpretation] Thank you.

11        Q.   See, here you are, Mirzet, somebody wrote down what you had said

12     and you said among other things, the second sentence, to sit down and

13     reach agreement on the takeover of power.  On 3 March, that's what you

14     said, right?

15        A.   I don't remember that.  Especially now that you say Bosko, which

16     Bosko?  Bosko who?

17        Q.   Further down, you say the chief of the SJB is not good, should be

18     changed.  That's the public security station.  That's at your request.

19     Was he changed?

20        A.   I could not have anyone replaced or I could not make such

21     requests.  If a political party appointed someone, it was only that

22     political party that could have replaced him.

23        Q.   Did the SDS actually carry out what you had asked for, to replace

24     Mr. Majkic?

25        A.   I can only laugh at that.  I can only laugh at that.

Page 18775

 1        Q.   Was he replaced?

 2        A.   I don't know because I was arrested on 25 May.

 3        Q.   After that, was Vrucinic appointed who was not a member of any

 4     party and you confirmed that?

 5        A.   That's what you're saying.

 6        Q.   That's what you're saying.

 7        A.   It's you who says that.

 8        Q.   You said that in your statements and I do not have time to call

 9     that up.  You said that he was a person who did not belong to a political

10     party?

11        A.   I never said that.

12        Q.   I'm going to show it to you later.  Can we have this page

13     admitted?

14             JUDGE KWON:  Yes.  This will be added.

15             MR. KARADZIC: [Interpretation]

16        Q.   Mr. Karabeg, in the beginning of April, did an explosion take

17     place in a Serb yard and did that lead to mass gatherings of armed

18     persons of Muslim and Serb ethnicity?

19        A.   I do not remember that.  I just know that there was an explosion

20     in a coffee bar.

21        Q.   A Serb coffee bar?

22        A.   Yes.

23        Q.   Thank you.  Can we have 65 ter 05002?

24             THE REGISTRAR:  This is Exhibit P3324, Your Honours.

25             MR. KARADZIC: [Interpretation] I'm not sure that that's the

Page 18776

 1     number.  A bit of patience, please.  Here it is, that's the document.

 2        Q.   Look at this.  This is an assessment of the current security

 3     situation in the area of Sanski Most.  The centre of the security

 4     services of Banja Luka, the state security sector and it says -- can you

 5     read this?

 6        A.   I can.  Could it be enlarged a bit more, if possible?  Right.

 7     Now it's fine.

 8        Q.   It says here that the situation had deteriorated and that it's

 9     characterised by, can we scroll down, ignoring the law, a chill in

10     intra-national interethnic relations, tensions that lead to more

11     organised self-protection of the population, a rise in crime and also

12     aggravated conditions in the work of the organisations of the interior.

13             Can we see the second page from the bottom now?

14             A bit more, please.

15             Thank you.  This is it.  You see this?  The latest case of a mass

16     gathering of armed population of Muslim ethnicity in Sanski Most and a

17     pretext for that was planting an explosive against persons of Serb

18     ethnicity and that led to requests for dividing the territory of the

19     municipality.

20             Can we go further down?  It's 14 April.  So that you can see the

21     date.  So it's 14 April.  And the Serbs are not counting on Sanski Most

22     being theirs.  It is only the Serb municipality that they consider to be

23     theirs.

24             Can we have the heading, please?

25             You see this, it's 14 April.  Do you remember that, do you

Page 18777

 1     remember that gathering?

 2        A.   The author, please?  I'd like to see the author of this document.

 3        Q.   Secret agents, or, rather, secret service agents.

 4             JUDGE KWON:  Top of the page.

 5             THE WITNESS: [Interpretation] No, no, no, no, no.  The lower part

 6     of the page where the author is.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   No, this is operative 16600.  It's on the top of the page.  They

 9     used code names.  They used codes.  They do not sign their names.  That's

10     how they operate.

11        A.   That doesn't mean anything to me but I told you until 6 April and

12     after 6 April chaos reigned when the assembly was no longer working, when

13     the Serbs obstructed everything with a view to proclaiming Sanski Most

14     what they actually did on 3 April 1992, and they asked for the milicija,

15     the police, to be the Serb police, that they wear Serb insignia and that

16     they hoist a Serb flag on the police building.

17        Q.   Thank you.  Can this document be admitted?  I beg your pardon,

18     actually take a look at this.  You said in your statement of the 24th and

19     25th of July 1991 [sic], that is page 7, 22130, 65 ter 22130.  I'm going

20     to read that out now in English.  So that it is translated better than if

21     I were translating it myself.  It's not a quote.  This is the essence:

22             [In English] [As read] "Vrucinic had a map of Sanski Most and the

23     Serbs had a proposal to -- of how to divide Sanski Most into two

24     opstinas, Serb and non-Serb, a street by street, opstina-wise division.

25     Vrucinic was the one with the proposal because he was not representing

Page 18778

 1     any party, and that this time he was still the head of the municipal

 2     planning department."

 3             [Interpretation] Later on, was he appointed chief of the joint

 4     police?

 5        A.   No.

 6        Q.   Was he elected head of the Serb police?

 7        A.   I heard that that did happen, because I was detained then.

 8     I heard about that.

 9        Q.   All right.  Let us now look at 65 ter 04832.  While we are

10     waiting for that, the municipality of Srbac, was it called the

11     Serb Municipality of Srbac?

12        A.   I don't know.  I just know it as Srbac.

13        Q.   Why?  Because there were no conditions there for having a Muslim

14     municipality.  Did you notice, Mr. Karabeg, that the prefix Srpska, Serb,

15     is only assigned in places where there would be a separate Muslim and

16     Croat ethnicity -- municipality and it never said Serb when it was just

17     that kind of population and that municipality?

18             THE INTERPRETER:  Interpreter's note:  We did not hear the

19     answer.

20             JUDGE KWON:  Mr. Karabeg, could you kindly repeat your answer?

21             THE WITNESS: [Interpretation] I know that the municipality of

22     Srbac is called Srbac.  I don't know if it has any prefix or any other

23     name.

24             MS. SUTHERLAND:  Your Honour, I'm sorry for interrupting

25     Mr. Karadzic but I see the LiveNote says Mr. Karadzic said that the

Page 18779

 1     witness's statement was 24th and 25th of July 1991.  The statement is

 2     1999 so I don't know whether it was a mistake with the court reporter or

 3     Mr. Karadzic actually said 1991.

 4             JUDGE KWON:  Yes.  He referred to 65 ter 22130 and then the list

 5     of documents says that it was taken in 1999.  I think it's misspoken.

 6             MR. KARADZIC: [Interpretation] If that's what I said, it was a

 7     slip of the tongue.  It was either my slip of the tongue or the

 8     interpreter's.

 9        Q.   Mr. Karabeg, Crisis Staff of the Serb Municipality of

10     Sanski Most, the Serb part, on 25 April 1992, certain conclusions are

11     being defined and can we now have a look at conclusion number 7?  Please

12     take a look at this.  I don't know if there is a translation for this

13     yet.  What was that?  There should be a translation.  Could the other

14     participants please be given a translation.  Look at what it says.  Boro

15     and Vlado are being entrusted with establishing contact with the

16     representatives of the Muslim and Croat people, asking them to be loyal

17     in the -- loyal in the existing organs of authority of the

18     Serb Municipality of Sanski Most and that they should be told that they

19     would be guaranteed all rights stemming from employment, civic rights and

20     full equality of rights.

21             You see the Serb municipality said that a number of Croats and

22     Muslims would go on working in their government.  Do you see that?

23        A.   Well, let me tell you.  First of all I see this name:  The

24     Serb Municipality of Sanski Most.  I do not see anything that says the

25     part that is Serb.  Let me say another thing.  After that assembly

Page 18780

 1     meeting that was not held, I was frozen out.  They didn't let me enter

 2     the building.  I already spoke about that on the 17th and 18th of April,

 3     that we were in the municipality and left the municipality.  I was given

 4     a decision as if I had been dismissed from my work because I did not

 5     report for work.  However, the municipality building was blocked, there

 6     was barbed wire, hedgehogs, APCs.  I have that decision.  That is the way

 7     you did things.  So you make sure that people cannot come to work and

 8     then they are dismissed from work because they had not come to work for

 9     seven days.  And that is a document that states that and I happened to

10     find that in my dossier, in my file at the municipality only after the

11     war.

12        Q.   Tell me, the Muslim organs of government and the police station

13     and the president of the municipality and everybody, didn't they just

14     transfer to the left bank where they started setting up their own

15     authorities?

16        A.   No.  No.

17        Q.   Let me just take a look at this.  Was it the fire department?

18     No, what is there on the left bank?  Some company whose building was used

19     for that?

20        A.   I don't know.  I know that in that division, that they proposed

21     to us and maybe you heard about it, that they proposed that we have the

22     Sipa building.

23        Q.   Sipad?

24        A.   Sipa, not Sipad.

25        Q.   Sip?

Page 18781

 1        A.   Yes, Sip Sava where 90 per cent of the employees are Serb and

 2     they wanted to transfer us there so that we would create chaos, that we

 3     would have those people there.  You know all the proposals of the Serb

 4     side were such that they were actually imposing problems upon us.  They

 5     wanted us to have a chaotic situation in which we could not live or work

 6     properly and that turned out to be true indeed, after 25 May 1992 when we

 7     were arrested and when Sanski Most was shelled.

 8        Q.   Thank you.

 9             And this Sip building, is that in the Muslim part of town?

10        A.   Well, predominantly, no.  The majority is that, yes, but you said

11     it was the left bank of the Sana.

12        Q.   Is that the case?

13        A.   It's the left bank but, no, you cannot say predominantly,

14     although indeed there are quite a few Serb neighbourhoods there and how.

15     Dabar, Palanka, Lipnik [phoen], not to enumerate all of them.

16        Q.   Thank you.

17             THE ACCUSED: [Interpretation] Actually, could this document

18     please be admitted?

19             JUDGE KWON:  Ms. Sutherland, I'd like to hear from you in

20     relation to the previous document 5002.  It's security -- evaluation on

21     security situation, as well as this one.

22             MS. SUTHERLAND:  No objection, Your Honour.

23             JUDGE KWON:  Yes.  I was told that the 5002 was already admitted

24     as Prosecution Exhibit.

25             MS. SUTHERLAND:  I was just looking at that one again,

Page 18782

 1     Your Honour, and thinking exactly the same thing.

 2             JUDGE KWON:  Yes, that was exhibit, could you give the number?

 3             THE REGISTRAR:  P3324.

 4             JUDGE KWON:  Thank you.  We will admit this Crisis Staff

 5     document.

 6             THE REGISTRAR:  As Exhibit D1679.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Mr. Karabeg, is it true, or rather how many of you were arrested

 9     in late May in Sanski Most?

10        A.   Let me tell you, a large number were arrested, sent to prison

11     building, to the Betonirka building, to the Vuk Karadzic school.

12        Q.   Do you know the number?

13        A.   I don't, because on 25 May I was arrested myself so I couldn't

14     learn of the number.

15        Q.   Was it 500?

16        A.   I don't know.  I think approximately, yes.

17        Q.   So approximately 500?

18        A.   I think so but don't quote me on this.  This is what I heard from

19     others.

20        Q.   And how many of them were released?  Do you know that 41 per cent

21     were released after checks were made whereas 59 per cent were kept on and

22     then sent to Manjaca?

23        A.   Let me tell you, I knew that four or five transports were sent to

24     Manjaca, the largest one was on 7 July 1992.  As for people being

25     released, I was in prison when two elderly men, over 70, arrived.  They

Page 18783

 1     brought us two pieces of bread.  They said that they had been kept in the

 2     hall and then they were released and they were leaving and they gave us

 3     their two pieces of bread.  One was called Rahmija and the other one was

 4     called Beco.  It was in late June, early July.  On the 28th of August

 5     1992, I found myself at Manjaca and there I met the first one, Rahmija

 6     and I asked him what are you doing here?  Weren't you released?  He said

 7     you know what they gave us the papers as though they were releasing us

 8     but as soon as we left, somebody else arrested us and I was sent to

 9     Manjaca and Beco was sent elsewhere.  So this is what they did.  They

10     falsely released people and then arrested them again.

11        Q.   Well, we'll check that.  Isn't it true that you said that the

12     last large convoy of refugees from Sanski Most arrived in Travnik in 1995

13     and then you met them there?

14        A.   Yes.

15        Q.   And isn't it true that in Sanski Most, before the war broke out,

16     there were almost 30.000 Muslims?

17        A.   Well, I said that there were 28,300, according to the census from

18     1991.

19        Q.   How do you explain, Mr. Karabeg, that out of 28.000 Muslims, only

20     400 to 500 extremists were arrested, justifiably or not?  Those were the

21     people who the Serbs considered to be extremists.  And how do you explain

22     that as late as 1995, there were still Muslims in Sanski Most leaving the

23     place?

24        A.   Let me tell you how I explain it.  Do you think that only those

25     who were arrested in May were sent to Manjaca only during that period of

Page 18784

 1     time?  You did that throughout the war, up until the 17th of September,

 2     all the way up until then.  Do you know how many people remained in

 3     Sanski Most on 12 October 1995?  575 residents out of 28.300 residents

 4     and if you're going to mention these figures, well, don't focus only on

 5     one period of time.  Look at the whole period of time, from May of 1992

 6     until Sanski Most was liberated in October 1995.  Look at what was done

 7     during the entire period of time.

 8        Q.   Mr. Karabeg, in Sanski Most, in the town of Sanski Most, there

 9     could not have been 28.000 of non-Serbs.  This figure applies to the

10     entire municipality, not to the town itself, and then in 1995 you found

11     575 residents only, and that was after heavy fighting between Serb and

12     Muslim forces; isn't that right?

13        A.   Yes.

14        Q.   All right.  Could we now see 65 ter 04906?  Could we now see what

15     this is about?  These are the minutes of the 11th session of the

16     Executive Board of Sanski Most Municipal Assembly held on 14 August 1992.

17     Could we see page 4, please?  Look at what it says here, Kalacun asked

18     the president of the Executive Board to present the general view of the

19     government of the Autonomous Region of Krajina concerning the moving out

20     of the Serb state.  Rasula, Nedeljko, this is what he says:

21             "We don't have a general position.  We don't have instructions.

22     Nobody is forced to move out.  The basic attitude is that the citizens

23     should decide where they want to live.  If somebody wants to move out,

24     they should be allowed to move out with certain supervision and

25     protection.  Those who wish to remain in the municipality will be allowed

Page 18785

 1     to stay only if they had not bloodied their hands or took part in any

 2     underhanded activities.  Those who wish to move out will have to bear the

 3     costs of that themselves because we have no money for it."

 4             And then M. Lukic adds:  "According to the international law,

 5     people cannot be prevented from moving out.  Those who wish to leave

 6     should be allowed to do that and those who wish to stay should be allowed

 7     to do that too."

 8             This was not written up for the media, Mr. Karabeg.  This is the

 9     session of the Executive Board held in August 1992.  Do you see that this

10     is why in March of 1995, you were still having convoys of people arriving

11     and there was a difference between Muslims who had left and Muslims who

12     had stayed?

13        A.   Well, I'm telling you what I heard from others, 14 August 1992,

14     I was already arrested at that time.  I was arrested back on 25 May.  I

15     don't know what was happening in Sanski Most.  I had no personal insight

16     into that, what was happening from 1992 until 1995.  However, I'm

17     conveying the stories of people who were there, who knew.  I told you

18     about the torture, mistreatment.  Had people had the relevant papers, all

19     of them would have left because they were exposed to terrible abuse.

20     However, they needed to obtain visas, they needed to have money for

21     travel.  It wasn't that hard reaching Travnik but then from Travnik one

22     had to travel on to Croatia, to Slovenia and to other Western countries.

23     I am telling you what others told me.  I can't tell you anything about

24     what happened in Sanski Most between May 1992 until 1995.

25        Q.   Thank you.  You said that initially people had to sign consent on

Page 18786

 1     placing their property at the disposal of the municipality.  Do you know

 2     of any case where some real property was transferred to somebody else,

 3     where the ownership was transferred to somebody else?

 4        A.   Well, those were few cases of abuse and foul dealing.  You know

 5     what the procedure is, what procedure needs to be implemented in order

 6     for ownership to be transferred.

 7        Q.   Do you remember that in one of your testimonies, you confirmed

 8     that you were offered the opportunity to set up a Muslim municipality?

 9        A.   Listen, we've been discussing it back and forth all day today.

10        Q.   Was this offered to you or did you not accept it?

11        A.   No.  Nothing was offered to us.  Only the Serbs were offered to

12     have their own municipality, and these games were played until the 3rd of

13     April 1992, when the assemblymen of SDS from the assembly, and some

14     highly educated Serbs, got together and adopted an illegal decision

15     proclaiming the Serbian Municipality of Sanski Most.

16        Q.   Thank you.  Could this document be adopted, please?

17             JUDGE KWON:  Ms. Sutherland?

18             MS. SUTHERLAND:  No objection.

19             JUDGE KWON:  Very well.  That will be admitted.

20             THE REGISTRAR:  As Exhibit D1680, Your Honours.

21             MR. KARADZIC: [Interpretation] Could we now see 22133,

22     65 ter 22133?

23        Q.   17 April 1992, in a coffee bar of Toma Delic, was there a meeting

24     that you attended there?

25        A.   Yes, I was there as a guest.

Page 18787

 1        Q.   Thank you.  Could we now see page 1609?  6109, I apologise.

 2     6109.  On 27 May 1992 -- no, that's not the right document.  We need

 3     22133, please.

 4             JUDGE KWON:  Which is his 92 ter statement?

 5             MS. SUTHERLAND:  Yes, the Brdjanin testimony.

 6             MR. KARADZIC: [Interpretation] Perhaps that's included too.  But,

 7     yes, this is the testimony from the Brdjanin case, if that's been

 8     admitted, then, yes, yes, that's the right document.  It is.  Now, let me

 9     read out to you what you said back in Brdjanin.

10             MS. SUTHERLAND:  Sorry, 22133 is all of his previous testimony.

11     22133A is the Brdjanin testimony only.

12             JUDGE KWON:  Yes.

13             MR. KARADZIC: [Interpretation] Thank you.

14        Q.   I will read out to you what you said back at the meeting.  You

15     say:

16             [In English] [As read] "On behalf of the SDS, there was Vrkes

17     Vlado, Boro Savanovic and Tomo Delic and that was in his cafe.

18             "Q.  What was discussed at that meeting?

19             "A.  I think it was conducted in a tolerant atmosphere.  In fact,

20     Tomo Delic treated us to drinks, and he said that we should resolve the

21     problem and that we would continue the talks, the most probable solution

22     would be to split up the municipality building, that half would be given

23     to us and half to the SDS."

24             [Interpretation] On 17 April, Mr. Karabeg, the Serbs offered you

25     half of the municipal building to set up your Muslim municipality, and

Page 18788

 1     now you're saying that the Serbs wanted the entire municipality for

 2     themselves.

 3        A.   That's true.  The Serbs took the entire police building.  We went

 4     there and I think that further in my testimony you can see that,

 5     Tomo Delic portrayed himself as a great peacemaker.  There were three or

 6     four kilos of lamb roasts there, several bottles of wine, et cetera, and

 7     we had talks there, and Tomo told us there, "Leave the municipal

 8     building.  We cannot suppress and control our extremists who want to

 9     attack you."  And there were police workers there.  And later on, we

10     found out that Tomo Delic was the leader of those extremists, the Serb

11     Defence forces, the SOS.  And when meeting us, he was begging us to agree

12     to this because they couldn't control their extremists.  I remember that

13     meeting very well.

14        Q.   Is it true what you stated back in Brdjanin?

15        A.   Yes, yes.

16        Q.   Tell me, please, is it true, did I understand you well, you

17     wanted half of the building but you didn't want the municipality to be

18     split, right?

19        A.   Let me tell you.  We were housed in the municipal building

20     because the people had been chased out from the police building because

21     they refused to carry Serb insignia and they didn't want to sign the

22     loyalty oath.

23        Q.   Thank you.  Is it true that you had the Green Berets and that

24     you, your police commander, was at the same time the commander of the

25     Green Berets and that this is why you refused to divide the police force

Page 18789

 1     because the Serbs did not have their Green Berets and whereas you did?

 2     Did you have Green Berets?

 3        A.   There were some in Vrhpolje and Hrustovo.  What have you got

 4     against those Green Berets?

 5        Q.   Sir, we have nothing against two Green Berets unless they have

 6     two tonnes of explosive material.

 7        A.   That's what you're claiming.

 8        Q.   Well, let me show you the document.  1D00011.  While we are

 9     waiting, do you know that we banned and expelled the Serb armed forces,

10     the SOS?

11        A.   That's the first I hear of it.

12        Q.   Thank you.  Please look at this.  This is the municipal court of

13     Sanski Most in 1997, that is to say after the -- after Sanski Most was

14     taken over by the Army of Bosnia-Herzegovina.  This is the decision

15     declaring Enver Burnic dead.  And please look at the bottom of the

16     highlighted portion.  It says here that both proposed witnesses, in their

17     statements, stated that Enver Burnic was very patriotic, and he expressed

18     his patriotism when, as a commander of police in Sanski Most, he refused

19     to accept the legality and legitimacy imposed by the authorities of the

20     Serb aggressor and actively worked on preparing armed resistance to the

21     Serb aggressor, and he wore on his uniform the insignia of the

22     Patriotic League, the lilies.  Did you know Enver Burnic?

23        A.   Certainly.

24        Q.   Thank you.  Did he take part or, rather, is what it says here,

25     what the Judge says here Ahmet Tatarevic, is what he says here true

Page 18790

 1     because it was signed by the judge, Ahmet Tatarevic.  Do you know the

 2     judge?

 3        A.   Yes, I did know him.

 4        Q.   And is what it says here true, about this man Enver?

 5        A.   Well, to tell you the truth, I doubt it very much because usually

 6     things are exaggerated with the statement of reasons.

 7        Q.   Thank you.  I'd like to tender this document into evidence now,

 8     please.

 9             JUDGE KWON:  How is this relevant, Mr. Karadzic?

10             MR. KARADZIC: [Interpretation] Well, it's relevant in relation to

11     the subject of the police and the division of the police and why they

12     didn't accept the transformation of the police force into two stations,

13     because they had their goals and objectives, and their chief of police

14     worked to prepare an armed struggle.  And he changed the insignia, not

15     the Serbs.

16             THE WITNESS: [Interpretation] That's what you say.

17             JUDGE KWON:  Ms. Sutherland?

18             MS. SUTHERLAND:  Just a moment, Your Honour, if I may have a

19     moment.

20                           [Prosecution counsel confer]

21             MR. KARADZIC: [Interpretation] You can take a look at the last

22     page in Serbian, the signed and certified page.

23             MS. SUTHERLAND:  Your Honour, I don't think the witness has

24     confirmed anything in this document.

25             JUDGE KWON:  And it's very difficult on the part of the Chamber

Page 18791

 1     to find the relevance of this decision.  We will not admit this,

 2     Mr. Karadzic.

 3             MR. KARADZIC: [Interpretation] Well, I can't tell you now once

 4     you've made your decision but I'd like to say that this is court

 5     evidence, that the joint commander of the police station, Enver,

 6     worked --

 7             JUDGE KWON:  You will have another opportunity to tender this.

 8     You do not have much time with this witness.  I think it's almost about

 9     five minutes left and I don't know how much more time you will be asking

10     for but plan your cross-examination to be focused.  Or it will be too

11     late.

12             MR. KARADZIC: [Interpretation] Well, I had hoped to have the

13     whole day today or at least this session.  Because you see we are

14     presenting documents which call into question the testimony of this

15     witness.  I can't overrule his statements through any other witness but

16     through him.

17             JUDGE KWON:  Plan your cross-examination to be able -- so that

18     your cross could be concluded by the end of this session, which is 12.30.

19     We'll see.

20             MR. KARADZIC: [Interpretation] Thank you.  May we now have

21     65 ter 05125, please?

22        Q.   Take a look at this document, please, it's dated 5 August 1992.

23     The security services centre of Banja Luka and it links this up to the

24     material of the MUP of the Socialist Republic of Serbia, it's strictly

25     confidential, and it says -- well, can you read it?  You can read it

Page 18792

 1     yourself.  It says, in the Sanski Most area, in the last two months in

 2     Sanski Most municipality, there has been a great deal of activity by

 3     certain paramilitary groups that have broken free from the army command,

 4     and which are waging their private actions which are reflected in the

 5     fact that they are putting explosives, planting explosives, setting fire

 6     to houses, killing, looting, and another -- committing other crimes

 7     against the Muslim and Croatian population in order to gain -- for

 8     material gain and to persuade them to leave.  That's the first paragraph.

 9     And I'm just going to read the last sentence of the second paragraph

10     which reads, "The SOS, we registered four such groups including the

11     so-called SOS, the former paramilitary formations of 30 men strong, which

12     was formally put under the command of the war unit here as a sabotage

13     platoon but nobody has full control over it."

14             Can you see that, Mr. Karabeg?  Can you see that Tomo was right

15     when he said forces were in existence which were outside their control

16     and this was in August, the problem existed as far as August?

17        A.   You didn't understand me.  Tomo Delic was at the head of the SOS.

18     And he duped us.  He was at its head.  And now you're presenting all this

19     material that this document was written, and all the rest of it.  It's 5

20     August.  So from 25 May to 5 August, they could have done many things,

21     and did do them, but you're denying this whole period.  You say that none

22     of that happened.  And this whole conversation boils down to the fact

23     that the Serbs, that the Serb side, did not do any of these things and

24     that it was all under control.

25        Q.   Well, the Serb authorities are pointing this out two months from

Page 18793

 1     5 August backwards two months to the end of May, for two full months they

 2     were running amok and they asked that they be disbanded.

 3        A.   I want to say it wasn't just the 25th of May, from the 25th of

 4     May.  It started in April, the beginning of April.

 5        Q.   I'd like to tender this document, please.

 6             JUDGE KWON:  Yes, this can be admitted.

 7             THE REGISTRAR:  As Exhibit D1681.

 8             MR. KARADZIC: [Interpretation] Can we now have 65 ter 05077 next,

 9     please?

10        Q.   Take a look at this, Mr. Karabeg.  On 30 May, which means a lot

11     before the other affair, the Serb forces of Sanski Most make a

12     proclamation and complain that they are being treated or they are

13     complaining of their treatment and that they want to go elsewhere.

14     Because they are not welcome in Sanski Most and haven't been welcome by

15     the authorities.  And because of the very complex security situation and

16     counter-propaganda, and applying the provisions of the formation of the

17     SOS of Sanski Most, "We hereby proclaim... "  and then it goes on to

18     say -- may we zoom down the page, please -- I hope that the other

19     participants can follow the translation.

20             "Because individuals and the authorities are expanding their

21     propaganda to belittle our contribution, we have decided to leave this

22     territory and to fight for the ideals of Serbian, Serbian Republic of

23     Bosnia-Herzegovina and to protect the Serbian people, to struggle for

24     this outside Sanski Most and we shall be informing -- and that the area

25     command will inform you of this."

Page 18794

 1             So that was at the end of May, Mr. Karabeg.  They were forced to

 2     leave Sanski Most.  Do you see that?

 3        A.   Well, don't ask me again.  I said I know nothing about that.  I

 4     know nothing about the situation after the 20th of May, 1992.  So please

 5     don't, refrain from asking me.

 6        Q.   But you said that nobody touched them, whereas they were

 7     interfered with.

 8        A.   I didn't say anything.

 9        Q.   Very well.  Thank you.  I tender this.

10             JUDGE KWON:  On what basis do you think we should admit this,

11     Mr. Karadzic?

12             MR. KARADZIC: [Interpretation] Directly contradictory to what the

13     witness claimed.

14             THE WITNESS: [Interpretation] Well, I'm telling you:  Don't ask

15     me.  I know nothing about that.  I know nothing about the situation after

16     the 25th of May 1992.  You're showing me a document that was written

17     after my arrest.

18             JUDGE KWON:  Mr. Karadzic, Mr. Karabeg is saying he doesn't know

19     but how is this document contradicting his statement?

20             MR. KARADZIC: [Interpretation] But he said a moment ago that

21     until 5 August they worked unimpeded whereas here it shows that that was

22     not true.  This document shows that that's just not correct, that even

23     before that they were pushed into a corner, that the authorities pushed

24     them into a corner and that they became one of those uncontrolled

25     elements that the authorities were criticising.

Page 18795

 1             THE WITNESS: [Interpretation] Well, you said yourself the 5th of

 2     August.  You mentioned 5 August yourself.  And then you said all this

 3     yourself, the 30th or whatever the date was.  You're speaking about these

 4     matters yourself.  I'm telling you that I know nothing about these

 5     matters.  They are your documents, the ones you're presenting.

 6             JUDGE KWON:  Mr. Karabeg, Mr. Karadzic was addressing the

 7     Chamber.  Can you had help us, Ms. Sutherland, in this regard?

 8             MS. SUTHERLAND:  Your Honour, as you've noted, the witness -- it

 9     doesn't -- this document doesn't contradict anything the witness has said

10     because he said he can't speak to the document.

11                           [Trial Chamber confers]

12             JUDGE BAIRD:  Dr. Karadzic, is this document dated at all?

13             JUDGE KWON:  30 May.

14             MR. KARADZIC: [Interpretation] Yes, the 30th of May.

15             JUDGE BAIRD:  Thank you.

16                           [Trial Chamber confers]

17             JUDGE KWON:  Mr. Karadzic, we will not admit this document.

18             MR. KARADZIC: [Interpretation] Very well.  We'll have to wait for

19     another witness.

20        Q.   Now, Mr. Karabeg, do you know that the Serb side tolerated the

21     existence of the Muslim armed forces and the Green Berets themselves in

22     town, and considerable forces in Hrustovo, Vrhpolje and Kamengrad, right

23     up until they launched offensive operations against the Serbs, the Serb

24     civilians and the Serb army?

25        A.   Let me tell you, I only knew about the forces in Hrustovo and

Page 18796

 1     Vrhpolje because the population organised themselves over there in those

 2     two places and they were members of the Territorial Defence to begin with

 3     and when the Serb forces attacked them, and surrounded them, and took

 4     about 30 -- they took about 30 Serb officers prisoner and forced the

 5     people to go up for an exchange in Serbian Krajina, so those Serb

 6     officers were returned.  But the people managed to gain their freedom.

 7        Q.   Thank you.  Is it correct that to help those captured Serbs, the

 8     people from Hrustovo, Vrhpolje, Kamengrad, were allowed to pass on to

 9     free territory in Bihac, as it was called?

10        A.   Yes, but only the other two places, not Kamengrad, Hrustovo and

11     had Vrhpolje and that was their aim.

12        Q.   May we have 1D00030 next, please.

13             JUDGE KWON:  Yes, Mr. Karadzic, is there any problem?

14             MR. KARADZIC:  There is something technical about wind.

15     I already once suffered a terrible pain in my back because of the cold

16     wind.  And it's going to repeat.

17             JUDGE KWON:  As did one of my colleagues already.  Yes, I hope

18     that can be sorted out very soon.

19             MR. KARADZIC: [Interpretation] Thank you.  May we now look at

20     page 40?  39.

21        Q.   Take a look at the highlighted portion.  It's a book that you're

22     well aware of, and you were in the editing board.  Do you see there who

23     the key people were in Bosnia-Herzegovina in the formation of the

24     Patriotic League and Green Berets?  The names are Sefer Halilovic;

25     Sulejman Vranj, Sule; Munib Bisic; Brko -- is Atif Saronjic from Sanski

Page 18797

 1     Most, for example?

 2        A.   As far as I know, no.

 3        Q.   Then there is Mustafa Hajrulahovic; Rifat Bilajac; Zico Suljevic;

 4     Meho Karisik; et cetera.  May we go on to the next page.  Anyway have you

 5     heard of these people and did you know that they were members of the

 6     Patriotic League?

 7        A.   Yes, I have heard of these people, they were all in the war.

 8        Q.   Now, take a look at Sanski Most.  Just before the highlighted

 9     portion, it says:

10             [As read] "The situation in Sanski Most, when it comes to

11     preparations for the defence of the municipality, and including the

12     municipality and defence preparations during 1991 and beginning of 1992,

13     was not satisfactory.  As far as I know, the Patriotic League in

14     Sanski Most did not exist."

15             JUDGE KWON:  Just a second.  Are we on correct page?

16             MR. KARADZIC: [Interpretation] Yes, we are.  But I don't know

17     about the English, the English page.

18             JUDGE KWON:  What's the page number of this?  40.  Does it start

19     with "Parallel to the increasingly more prominent presence"?

20             MR. KARADZIC: [Interpretation] Yes, yes, yes, that's it.

21             JUDGE KWON:  Yes.  I think it's next paragraph.  Please continue.

22             MR. KARADZIC: [Interpretation]

23        Q.   Mr. Karabeg, look at this highlighted portion.  It says parallel

24     with the increased presence, et cetera.  It says that the Green Berets, a

25     group like that, was active in the town proper, and in another document,

Page 18798

 1     it says, in the Mahala or centre of town and Muhici.  You saw that

 2     yesterday, did you not?

 3        A.   Yes.

 4        Q.   So you okayed -- authorised this book and Vrhpolje, Trnovo,

 5     Hrustovo and part of Kamengrad are all mentioned but you see that it

 6     existed in the town itself.  You were one of the editors of this book so

 7     that's right, isn't it?

 8        A.   Yes.

 9        Q.   May we look at the next page, please?  Mr. Karabeg, can you

10     see -- the -- first we can look at the part up here, where there is a

11     reference to blockaded roads, I don't have to read out all of it.  You

12     can look at it yourself.  What happened in April.  And then the presence

13     of locals who were armed.  Ifet Hukanovic led them, procured weapons.

14     I see Madam Sutherland.

15             JUDGE KWON:  Yes, Ms. Sutherland.

16             MS. SUTHERLAND:  Your Honour, I'm sorry to interrupt again but

17     just back on that question, the compound question that Mr. Karadzic asked

18     the witness:  "So you okayed, you authorised this book and Vrhpolje,

19     Trnovo, Hrustovo, part of Kamengrad are all mentioned but you see this

20     existed in the town itself ...," and then the second, the third question,

21     you're one of the editors of the book and then we get the answer, yes.

22     Perhaps if Mr. Karadzic can clarify which -- what the witness was

23     answering yes to.

24             JUDGE KWON:  I thought the witness answered yes to all of his

25     question but Mr. Karabeg, could you confirm, do you remember the question

Page 18799

 1     and answer?

 2             THE WITNESS: [Interpretation] I just confirm that I'm one of the

 3     editors of that book.  He asked me whether I was one of the editors.  He

 4     asked that at the beginning and the end of his question.  And I said yes.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   And you approved of the book as truthful and correct?

 7        A.   Not me.  It was the entire team.

 8        Q.   Please take a look at this encircled part where it says -- look

 9     at this part, 300 locals who were armed in Vrhpolje, is that what it says

10     here, intensive preparations beginning of April, roads were blocked

11     around the village, also armed guards were placed there and also

12     specially designed -- designated patrols were supposed to monitor enemy

13     activity and follow the entire area.  Is that what it says there?

14        A.   Well, that is what is written there.  You had all of Sanski Most

15     under your control.  I was never denying that Vrhpolje and Hrustovo, and

16     I said people had self-organised themselves there and that they were

17     putting up resistance.

18        Q.   But it says there that Muslims did that and it's saying Vrhpolje?

19        A.   I'm not denying that.  In Vrhpolje and Hrustovo there are no

20     Serbs, it's Muslims who were there.  I did not challenge that.

21        Q.   Thank you.  Can we see the bottom of that page and then the next

22     page?  You see here that on 15 April, there was a review.  Can we have

23     the next page, please?

24        A.   Just a moment, read it until the end.  What was it?

25        Q.   The Territorial Defence of Vrhpolje.

Page 18800

 1        A.   That's right, that's right.

 2        Q.   Next page.  The top of the next page, please.  Have a look at

 3     this:  300 armed soldiers, the late Arif Hukanovic commanded them,

 4     Beco Buljubasic, former JNA captain, and so on.  And look further down.

 5     The first clash took place between the 14th and 15th of May.  Actually,

 6     the forces of Vrhpolje deployed around the school put up an unexpectedly

 7     strong resistance to the aggressor and the enemy was forced to withdraw.

 8             So on the 14th and 15th of May, there were clashes already

 9     because a Serb unit was defeated there.  Can we have the next page?

10             Please focus on this where it says, actually, Avdic's and

11     Hukanovic's assessment was that offensive combat operations should start

12     and losses in personnel and materiel should be inflicted upon the enemy.

13             And then it says, where the platoon from Sanica advanced and the

14     other platoon, and so on and so forth.

15             So Mr. Karabeg, this is not the Territorial Defence.  These are

16     manoeuvring units that are launching offensives against Serb

17     neighbourhoods.

18        A.   That's what you say.

19        Q.   That's what this book says.

20        A.   We have just said that it was the Territorial Defence and now

21     you're denying it.  You are quoting from the book and you say that it's

22     the Territorial Defence, 300 armed men, and now you are denying it.  The

23     Territorial Defence is legal.  It's a legal formation of the state of

24     Bosnia-Herzegovina.

25        Q.   Thank you.  Is the Territorial Defence authorised to attack Serb

Page 18801

 1     neighbourhoods?

 2        A.   Well, you attacked all of Sanski Most.  You had it all cut up and

 3     you held all of it ultimately and you will already declared it the Serb

 4     Sanski Most.

 5        Q.   Can this be admitted, this part of the book?

 6             JUDGE KWON:  That will be added to the MFIed exhibit D1677.

 7             MR. KARADZIC: [Interpretation] 65 ter 5445.

 8        Q.   Serb Republic of Bosnia-Herzegovina, Autonomous Region of

 9     Krajina, Crisis Staff Banja Luka, on 11 May.  To the presidents of all

10     the municipalities, so it is in the plural, to the presidents of

11     municipalities.  And these are the conclusions, namely that the deadline

12     for handing over illegally procured weapons has been extended until the

13     14th of May 1992 at 2400 hours.

14             Paragraph 2:  [As read] "The deadline that expired today was

15     extended at the request of citizens of all ethnic backgrounds and as was

16     explained by a desire to have weapons returned in a peaceful way and

17     without police interventions."

18             Do you remember that this was proclaimed, that weapons should be

19     returned?

20        A.   Yes, but unfortunately that pertained only to the Serb people --

21     actually Bosniaks and Croats.

22        Q.   Can this be admitted?  Actually, what is written here does it not

23     say that persons of all ethnic backgrounds are asking for an extension of

24     the deadline?

25        A.   Well, what is written is one thing but what was actually carried

Page 18802

 1     out was a different thing altogether.  You write it up and you implement

 2     it.

 3             MR. KARADZIC: [Interpretation] Thank you.  Can this be admitted?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  As Exhibit D1682, Your Honours.

 6             MR. KARADZIC: [Interpretation] 65 ter 05118.

 7        Q.   Please take a look at this, public security station of

 8     Sanski Most is informing the Security Services Centre of Banja Luka and

 9     it says, "Pursuant to your letter we hereby provide information on which

10     weapons have been handed over until now."

11             Some weapons were seized, some were handed over.

12             If necessary, we can have this enlarged for you.

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

14             JUDGE KWON:  Did you say anything, Mr. Karabeg?

15             THE WITNESS: [Interpretation] He asked me whether this should be

16     enlarged and I said that it should be enlarged and now I can see it on

17     the screen.

18             MR. KARADZIC: [Interpretation]

19        Q.   LP 283.  Lkar 23.  Automatic rifles, for instance, 230.

20     Semi-automatic rifles, 155.  Then hand grenades, 2.  And look at

21     explosives, 3.000 kilograms, three tonnes of explosives were handed over.

22     And let us look further down, it says during the search, another 140

23     kilograms of explosive were found that had not been surrendered until

24     then voluntarily?

25        A.   Yes.

Page 18803

 1        Q.   It's the lower part of the table.  Did you see in those minutes

 2     what Sabic was saying, who was in charge of procuring explosives, and

 3     that's what the book also says that some explosives were obtained.  Who

 4     got these explosives and for what purposes?

 5        A.   Let me tell you, you are showing me a document that I'm not aware

 6     of because I was under arrest.  Now you are saying to me that on the

 7     basis of that order, decision, what was proclaimed was some voluntary

 8     surrender of weapons, what the CSB Banja Luka did.  I am telling you that

 9     this only had to do with the non-Serb population.  You are denying that.

10     You are saying that that pertained to the entire population.  Now, I

11     don't know what you want me to tell you on the basis of all of this.  I

12     don't know about any of this.

13        Q.   Can we have the last page?

14             JUDGE KWON:  What's the point of showing another page, having

15     heard the witness, what he's going to say about this document?  It's

16     simply a waste of time, Mr. Karadzic.

17             MR. KARADZIC: [Interpretation] The signature is that of a person

18     who did not belong to any political party, and that is what the witness

19     himself said, and this person was Mr. Vrucinic who was appointed as the

20     chief of the public security station.  He is a professional and he is

21     providing information on what was surrendered and what was seized.  This

22     is a summary.  This is what the police came to learn.  And I wanted him

23     to see the signature.

24             THE WITNESS: [Interpretation] Can I answer?  I was on very good

25     terms with this Vrucinic and I held him in high regard.  I was arrested,

Page 18804

 1     I was taken to prison and then transferred to Betonirka and then from

 2     Betonirka, I was returned to prison again.  There was this young man

 3     whose name was Tonci, who was a Serb guard, and one morning he called me

 4     at 5.00, he told me to stand up and to spread my arms and legs, and he

 5     started beating me.  He beat me from 5 until 7 o'clock.  I left, and then

 6     when he came to work again, when his shift came again, after two days, he

 7     called me in yet again at the same time, he beat me with a truncheon and

 8     I left.  And next time he called me in again and again he started beating

 9     me and he beat me -- let me just finish, please, let me finish.

10             JUDGE KWON:  No, Mr. Karabeg, I'm sorry to interrupt you but do

11     you have anything to add about this Mr. Vrucinic?

12             THE WITNESS: [Interpretation] Yes.  No, he does belong to a

13     political party.  He was DP.  He would not have been appointed chief of

14     the Serb police, the then milicija, if he was not a man who belonged to a

15     political party.  Yes.

16             MR. KARADZIC: [Interpretation]

17        Q.   But the SDP, not the SDS, right?

18        A.   What do you mean SDP?  What are you on about?  What did you have

19     there except for the SDS?  Who accepted, yes, and those who did not

20     accept, hand grenades were thrown.

21        Q.   A moment ago, you said SDP?

22        A.   I did not, you said that.

23             MR. KARADZIC: [Interpretation] Can this be admitted this document

24     on the surrender of weapons?

25             JUDGE KWON:  I don't see any basis to admit this document through

Page 18805

 1     this witness.

 2             MR. KARADZIC: [Interpretation] All right.  All right.

 3        Q.   You were arrested on the 25th of May.  On the 26th you were

 4     interrogated for the first time?

 5        A.   The 25th of May.

 6        Q.   You said in your statement dated the 24-and-5 July 1999, on page

 7     9, 22930, you said that some Papric said to Kurbegovic, you see, Redzo,

 8     where this led to, where this -- what is this, this forecast, where this

 9     forecast led your people and then you said, all right, we are in prison

10     but why don't you let Meho Kaplic go?  He's retarded.  And then you say

11     later he was released.  In one statement you say after one hour.  And

12     during the direct examination, you said after one day.  Is this correct,

13     what you said here?

14        A.   To tell you the truth, I do not remember exactly.  I just know

15     that he was released.  Papric walked in with a beret, a Green Beret, SOS

16     as you would put it, yes, Meho was released, yes, I just don't know when.

17     I don't remember.

18        Q.   All right.  Can we briefly look at 65 ter 18922?  Do you know

19     that in the Serb Municipality of Sanski Most, there was civilian

20     protection that dealt with civilians?

21        A.   I don't know about that, because from the 25th of May 1992, I was

22     under arrest.

23        Q.   Do you know that Radio Sana in Sanski Most said the civilians

24     from Mahala and Muhici should go to the stadium until they deal with the

25     extremists?

Page 18806

 1        A.   You say that I'm an extremist and I was under arrest and I did

 2     not have an opportunity of listening to that radio.

 3        Q.   Thank you.  Let us see what the civilian protection says here for

 4     this period from 15 July until 15 October 1992.  After war operations in

 5     the territory of town, the staff took part in evacuating the population

 6     that was not involved in resistance, transferring them to other parts of

 7     town.  So it's not only within the same municipality but within the same

 8     town, from a neighbourhood where there was fighting, the population is

 9     being evacuated into a different part of town.  Do you remember that that

10     is obligatory on the basis of the Law on National Defence?

11        A.   Let me tell you, do mention at least one citizen of Serb

12     ethnicity who was killed in town, whereas I will tell you about tens of

13     non-Serb citizens who were killed in Sanski Most.  Except for Vrhpolje.

14     Now, you tell me that.

15        Q.   Thank you.  And who was the first casualty in Sanski Most?

16        A.   I don't know.

17        Q.   All right.  Can we scroll up and see what else the civilian

18     protection was doing?

19             JUDGE KWON:  I don't see the point of putting this document, in

20     particular, this was not translated.  I would like you to move on to your

21     next topic.  Your time is limited, Mr. Karadzic.

22             MR. KARADZIC: [Interpretation] Thank you.  Could we see 1D00015,

23     please.

24        Q.   This is the list of the soldiers killed in Jasenovac.  Could we

25     see the next page, please, these were the soldiers of the 6th Brigade who

Page 18807

 1     were killed upon arriving in Sanski Most.  Could we see the next page,

 2     please?  Dobrijevic, Predrag in Trnovo.  Cedo Lazic near Hrustovo.  Goran

 3     Rajlic in Podvidaca.  He was wounded by a Muslim extremist who ambushed

 4     him.  Vaso Stupar in Bosanski Milanovac, Mirko Cicic in Caplje.

 5     Rade Malic in Hrustovo.  Are all of these Serbs killed by Muslims?

 6        A.   That's what you claim.

 7        Q.   Well, it says so in the document.

 8        A.   Well, that's your document.  That's your blabbering.

 9        Q.   And then to go on, one page after other, Hrustovo, Tramosnja, all

10     of these people were killed there, just this document lists 17, 18, who

11     were killed from ambush in Kruvari and so on.  So you do not take into

12     account this, this document was not drafted for propaganda reasons, this

13     is a record?

14        A.   Well, tell me who, where and who killed them?

15        Q.   [No interpretation]

16        A.   Did you hear of Tramosnja?  You mentioned that these people were

17     killed in Tramosnja, Gornja Tramosnja and Donja Tramosnja.  There was not

18     a living soul there, no Croats, no Muslims, who lived there.  There were

19     no people living there.  Some who did commit some murders ended up in

20     prison.  And you just are adding up various pieces of information here.

21        Q.   So there was some Serbs in prison, right?  Do you mean Betonirka

22     or at the police station?

23        A.   In prison.  Prison is a prison.  And Betonirka was a camp.

24        Q.   Mr. Karabeg, do you know that Adil Draganovic upon coming to

25     Sanski Most found at least 30 investigations pending against the Serbs

Page 18808

 1     who had armed -- harmed some Muslims and that to this day, people are

 2     prosecuted pursuant to those criminal reports and investigations?

 3        A.   I don't know about that.  It is possible but I don't know about

 4     that.  And about them being put on trial, I don't know about that.

 5     Although it's possible.

 6        Q.   In Betonirka they held investigations, they interviewed people,

 7     some of you, and then some were released and some were returned to

 8     prison, right?

 9        A.   No.  Betonirka was vacated on 7 June and 550 residents of

10     Sanski Most municipality were transported, whereas the seven of us from

11     Betonirka were sent back to prison where we remained until 28 August when

12     we were transported to Manjaca as well.

13        Q.   You said that Vujanovic -- who was in charge of the prison, would

14     come to protect the prisoners, right?

15        A.   Well, there are all kinds of stories circulating about Vujanovic.

16     I personally --

17        Q.   He was the warden and then there were guards coming in and out.

18     Did you say that people came there to take revenge because they had been

19     given a bad grade at school or they had some unsettled personal accounts?

20        A.   Yes.  I had one such case.

21        Q.   Where it was personal?

22        A.   Where they came to beat me.  And one man protected me and got me

23     out.  His name was Savic.

24        Q.   And who are those people who came to beat you, were those some

25     old unsettled accounts?

Page 18809

 1        A.   No, nothing of the sort.  I didn't know those people.  They wore

 2     olive-drab uniforms.  I was in garage number 3.  They called my name,

 3     came out, there were three men standing in front of me.  One of them

 4     said, balija, just look at you, look at the sight of you, go wash your

 5     face.  And then there was some water source, 30 to 50 metres away.

 6     I went there, I turned the faucet, there was no water coming out.  And

 7     the man who had shouted at me just look at your sight, he came to me and

 8     he said, you know what he said?  He said Mirzo, I'm sorry, forgive me, I

 9     had to mistreat you.  I had no other choice.  I need to provoke you

10     because the other two came with me to beat you.  I will try to get you

11     out of this.  This is how that story ended.  I went back to the prison

12     building and nobody touched me, so there were some decent people.

13        Q.   Thank you.  And in your statement, on 24th and 25th of July 1999,

14     65 ter 22130, page 12, you said that Vujanovic was still the commander of

15     the prison, that he visited you and others, he didn't beat anyone, and he

16     would come to protect the prisoners, right?

17        A.   Let me tell you, I have nothing bad to say about Drago Vujanovic,

18     I personally have nothing.  Now as to other things that may have happened

19     I know nothing about that.  But when it comes to me he treated me fairly.

20        Q.   But you said it in this statement.

21        A.   It's possible, it's possible.  I don't want to smear him.

22        Q.   Is it possible that you were suspected of being given a list by

23     Osman Brka of the Serbs to be liquidated and of the list of Serb young

24     men who were to be circumcised and girls to be raped?

25        A.   No, there was no such list.  This was published in the media in

Page 18810

 1     Sanski Most, that I was in charge for raping Serb children, no, for

 2     circumcising the boys up to the age of three, for raping girls ages 6 to

 3     10 and this was the propaganda aired on Radio Sana, they said that they

 4     found lists on me.  And you know what people are like.  Nobody wondered

 5     whether that was normal, whether anybody could come up with such an idea.

 6     Everybody said how stupid can you be and have those lists on you.  That

 7     was the propaganda at the time.  Even the Bosniaks said that when I was

 8     arrested.  They said, look at how stupid he is.  He actually had those

 9     lists on him.  That was the power of that propaganda.

10             MR. KARADZIC: [Interpretation] Could I have a bit more time?

11             JUDGE KWON:  How much do you have in mind, Mr. Karadzic?

12             MR. KARADZIC: [Interpretation] Well, we have quite a lot of

13     documents which would be relevant for this witness.  I don't know how

14     much time, perhaps 20 odd minutes in the next session.  We will

15     prioritise the documents during the break.

16                           [Trial Chamber confers]

17             JUDGE KWON:  We will take a break, Mr. Karadzic, after which you

18     will have 15 minutes to conclude.  We will resume at 1.30.

19             MS. SUTHERLAND:  Your Honour, we are only sitting until 13.45

20     today.

21             JUDGE KWON:  We need to break half an hour so shall we resume at

22     five past 1.00?  Thank you for that.

23                           --- Recess taken at 12.31 p.m.

24                           --- On resuming at 1.05 p.m.

25             JUDGE KWON:  Yes, Mr. Karadzic.

Page 18811

 1             MR. KARADZIC: [Interpretation] Thank you.

 2        Q.   Mr. Karabeg, what you've just described, this brawl, the beating

 3     that you described, was the man's name Veselinovic?

 4        A.   Veselinovic did some beating too but I didn't mention that.

 5        Q.   Thank you.  Is it correct that you let Veselinovic go from the

 6     firm, you sacked him, and that he used the occasion to get his revenge on

 7     you and beat you up?

 8        A.   Well, I didn't dismiss him.  I didn't sack him.  He dismissed

 9     himself.  If you want me to explain, I can.  He didn't turn up for work,

10     he was a bad worker, and I was the head of the service, the commission

11     expelled him, he felt this, he asked me whether he could get an agreement

12     releasing him from his duties because he wanted to go to Italy, and then

13     when I was in Betonirka he made me clean the toilet, he made me kneel and

14     he went over me at that point, well, he behaved normally but I thought he

15     was going to beat me but the worst thing was this expectation, my waiting

16     with him looming above me for 15 or 20 minutes and then 15 minutes later

17     he swore at my -- called me a balija, he said, you see, I'm giving you a

18     job to do, whereas you didn't want to give me my job.  He was a guard in

19     Betonirka.

20        Q.   And he started beating you, is that right?

21        A.   Yes.  And my whole head was bloody.

22        Q.   And he told you he let you know that that's because he was sacked

23     and you spoke about that in your 1995 statement, on page 6 and 7, right?

24        A.   Yes.

25        Q.   Thank you.  I think you mentioned a professor being beaten

Page 18812

 1     because he gave somebody a bad mark, a teacher being beaten up, something

 2     like that?

 3        A.   I don't remember.

 4        Q.   Let's throw some more light on a particular matter.  There are

 5     quite a lot of differences in your statement.  I haven't got time to go

 6     over all differences and discrepancy, however the last meeting you had

 7     with your friends was in hodza's house, right, on 25 May -- April?

 8        A.   Which friends?  Which friend or friends?

 9        Q.   Let me just check if it was April or May.  It was 25 May,

10     Redzo Kurbegovic, Nihad Kljucanin, and Rifat Bahtic, Haso Osmanovic and

11     so on and so forth.

12        A.   That is possible.  But it wasn't in hodza's house.

13        Q.   At the Islamic community, their building or what?

14        A.   Yes, that's right.

15        Q.   Thank you.  Now, up until that time, had many people, both Serbs

16     and Muslims, left the town, left Sanski Most?

17        A.   Well, let me tell you, yes.  Especially the young people, the

18     youth, whom they wanted to forcefully mobilise into the JNA, so to avoid

19     going to the battle front in Croatia.

20        Q.   And then you, Hasib Kamber, and Bahtic, and that is on page 39,

21     Ziklija Bahtic you said that they should be more active because their

22     families were out of town.  You gave them radios and told them to report

23     on the situation in town; is that correct?

24        A.   No, it's not.

25        Q.   In that statement of 13 September 1995, page 39, that's what it

Page 18813

 1     says.

 2        A.   No.  I didn't give those assignments to anybody.

 3        Q.   At that meeting, not perhaps you personally, but Rifet Bahtic and

 4     Hasib Kamber were they there and were their families out of town?

 5        A.   Well, I don't know whether their families had left town but they

 6     were at the meeting.

 7        Q.   Thank you.  Now, this same statement of September, 22128, page 3

 8     you say that the imam's house, hodza's house in Sanski Most, you say that

 9     Fajko Biscevic -- Faik Biscevic or whoever noticed that daily meetings

10     would be too obvious and that you had decided to meet the following

11     morning at 11.00, right?

12        A.   Yes.

13        Q.   Why too obvious, Mr. Karabeg?  Why couldn't you meet normally,

14     publicly?

15        A.   Well, we worked underground, illegally.  We weren't allowed to

16     breathe, to move around.  Do you think it was a free territory like it is

17     here?  You know best how it was.

18        Q.   It says there that these two were given radios and that they were

19     told to report back about the situation in town.

20        A.   Well, I never said that but it is possible.

21        Q.   And then you were arrested in the meantime so there was no next

22     meeting, right?

23        A.   Yes.

24        Q.   Now, your arrest, do you link that up with these secret meetings

25     and the distribution of the radio stations and everything else?  Do you

Page 18814

 1     link the two?

 2        A.   Well, let me tell you they weren't secret meetings as far as we

 3     were concerned, they weren't.  But they mistreated us, they persecuted

 4     us, they followed us, followed our every step.  They had masses of people

 5     to do that.  Some were honest, some were dishonest, some were thieves.

 6     But anyway, we were followed, monitored.

 7        Q.   There are quite a few inconsistencies and I would like to remind

 8     you of one.  Is it true and correct that you said that Basara arrived

 9     with the intention of keeping the peace and protecting the non-Serbs from

10     the extremists?

11        A.   Yes.  We even put his name forward.  We wanted to make him

12     honorary citizen of Sanski Most.  But we didn't know what role he was

13     actually playing.  It was common knowledge what Basara turned out to be

14     throughout that period.  So he was playing a double role, a two-faced

15     game, and as I say, we even proposed put him forward for honorary citizen

16     because we thought he was doing a good job to begin with.

17        Q.   Then you said that he attended the Municipal Assembly sessions?

18        A.   No, I didn't attend.

19        Q.   Well, you said that in your statement of 1999, on page 3, on the

20     24th and 25th of July 1999, to be exact, page 93 -- page 3.  But then in

21     2002, you reneged and said you weren't certain whether he attended.

22        A.   That's what I'm saying.  Basara could not have attended because

23     Basara arrived at the end of March 2002 [sic] as the commander of the

24     6th Brigade.  He came from the Pakrac theatre of war, and when I said

25     that we even proposed him, we wanted to proclaim him honorary citizen of

Page 18815

 1     Sanski Most, well, you know it was only the Municipal Assembly which

 2     could reach such a decision, and so if that was the case he would have

 3     been at the assembly.

 4        Q.   So is it true that you did not have direct insight into the

 5     functioning of the Crisis Staff?  Did you mean the Muslim Crisis Staff or

 6     the Serb Crisis Staff or both?

 7        A.   Well, I don't know which statement of mine you are referring to.

 8        Q.   But you did have an insight into the work of the Muslim Crisis

 9     Staff, right?

10        A.   It wasn't the Crisis Staff.  The Muslims did not have a Crisis

11     Staff.  We had a body at the level of the municipality.

12        Q.   What was the name of that body?

13        A.   Well, it was similar to the term Crisis Staff.  I can't quite

14     remember now.

15        Q.   Thank you.  Now, do you agree that the Army of Republika Srpska

16     took a decision on 12 May at the assembly meeting and -- that the army

17     came into existence as of 20 May when the JNA withdrew?

18        A.   I'm not sure I understood your question.  What was the date you

19     mentioned?  What's that first date?

20        Q.   The first date is 12 May where the assembly took the decision to

21     form an Army of Republika Srpska.  Up until the 19th of May it was the

22     JNA and the Army of Republika Srpska came into existence as of 20 May,

23     right?

24        A.   Which assembly?

25        Q.   The Serbian Assembly in Banja Luka.

Page 18816

 1        A.   I don't know.  I can't say.

 2        Q.   Now, I'm a little unclear about this because in your 1999

 3     statement on page 8 you said that Talic [phoen] told you that he would

 4     inform Karadzic of the conduct of the Serbs in Sanski Most, Rasula and

 5     others.  Now, that was from the 22nd of April.  Now, do you accept that

 6     on 22 April, the Army of Republika Srpska did not exist and Talic could

 7     not, nor did he want to report to me about anything because I wasn't in

 8     charge of that army?

 9             THE INTERPRETER:  The interpreter did not hear the answer.

10             JUDGE KWON:  Just a second.  Mr. Karadzic, interpreters did not

11     hear the witness's answer.  What was your answer?  Could you repeat it?

12             THE WITNESS: [Interpretation] I don't know.

13             MR. KARADZIC: [Interpretation]

14        Q.   Did you say that Talic told you that he would inform Karadzic?

15        A.   Well, that's what I said, that he swore when he mentioned Rasula

16     and that he would inform him and that he would deal with the matter.

17        Q.   But he didn't say that he would inform Karadzic, right?

18        A.   I don't remember.

19        Q.   Thank you.  Now, tell me, please -- you're looking at me so that

20     is a warning for me to wind up, I think.  Now, do you accept that in the

21     Sana valley, that it was aflame on 23 May with an attack at the

22     check-point in Hambarine and that in the Sana river valley there was an

23     elite unit of the Muslim Patriotic League at that time?

24        A.   The Sana valley is a broad concept.  You can ask me just about

25     Sanski Most.

Page 18817

 1        Q.   Well, did you hear that the conflicts in neighbouring Prijedor --

 2     how far is Prijedor, 50 kilometres away?

 3        A.   28 to 30 kilometres.

 4        Q.   Right.  30 kilometres.  Do you know that the conflicts began

 5     there on 23 May with the killing of Serb soldiers, Serb reservist

 6     soldiers at a check-point?

 7        A.   I just heard what you did in Prijedor.  And how much you did, and

 8     how many people you killed and how many you expelled, but I didn't know

 9     that.

10        Q.   If I tell you that Mirza Mujadzic writes in an article that he

11     cannot understand how, at the end of May 1992, in the Sana valley, the

12     elite unit of the Patriotic League was routed so quickly and then you

13     say, and now you say that Sanski Most, the forces in Sanski Most, 900

14     armed men, were not part of that brigade?

15        A.   Let me tell you, I am Mirzet Mirza Karabeg.  So don't ask me

16     about Mirza Mujadzic.  Ask me.

17        Q.   Thank you.  Now, is it true that part of these people who were

18     arrested, Kurbegovic and others, that they were released very quickly

19     afterwards?

20        A.   Where?  Kurbegovic was arrested together with me and transported

21     to Manjaca and from Manjaca he went to Bijeljina and spent another year

22     and a half there.

23        Q.   But in your statement, you said that these men were released

24     soon, quickly afterwards.  Now, who was released?  Who else was released

25     from your cell?  You were in cell number 2, right?

Page 18818

 1        A.   Yes.  In prison, in prison.

 2             MS. SUTHERLAND:  Excuse me, Your Honour, could Mr. Karadzic just

 3     give me a transcript page for the reference to the statement, please,

 4     sorry a page number for the statement he's referring to?

 5             MR. KARADZIC: [Interpretation] Yes, I will, straight away, with

 6     pleasure.  Just bear with me a moment.

 7        Q.   While I'm looking for that, who interrogated you, Mima or Stanic

 8     and what was their profession?

 9        A.   I was interrogated by several people but at the beginning it was

10     Stanic, Rajkica.

11             JUDGE KWON:  Mr. Karadzic, time to conclude.

12             MR. KARADZIC: [Interpretation]

13        Q.   Was he a professional investigator?

14        A.   No.

15        Q.   A reserve?

16        A.   He was a judge in Sanski Most.  Unfortunately, he roams around

17     freely and he is a lawyer in Prijedor today.

18        Q.   Thank you.  Just to answer Madam Sutherland, it is the statement

19     to the Bosnian authorities given in 1995 and page 7.  You say:

20             [As read] "Fajko Biscevic; Kurbegovic, Redzo; Sabic, Suad;

21     Talic, Bego and another man whom I don't know -- whose name I don't know,

22     these people were released three days later and Emir Seferovic,

23     Said Sinanbegovic, Hasanbegovic and others were in my cell?"

24        A.   It was only Bego Talic who was released.  All the rest of them

25     were with me right up until the end and some of them spent more than a

Page 18819

 1     year or a year and a half in Batkovici, the camp there.  I was released

 2     from Manjaca and on 31 October 1992, I was exchanged.

 3        Q.   Thank you.  So Bego Talic was a Muslim too but he was released,

 4     right?

 5        A.   Well, Bego cannot be a non-Muslim.

 6        Q.   Thank you, and my last question:  Is it correct that at the

 7     police station, at the station, Macura beat someone or rather he was a

 8     policeman before the war, came to the station, and beat Kljucic saying,

 9     what have you done to make these two communities not be able to live

10     together?

11        A.   Yes.  Nihad and me.  He came to beat us, he came into our cell in

12     the prison and beat us.

13        Q.   And he accused you of bringing about a situation whereby the two

14     communities could not live together any more?

15        A.   Well, I don't know what he said but I know what he said about me

16     at the pre-election meetings.  I told the people, come out to vote, and

17     whole families should come out to vote.  Grandfathers, grandchildren, and

18     so on.  And he took that to be the disruption of brotherhood and unity

19     and he beat me and he beat me very badly.  I don't know about Nihad, I

20     know that he threatened Nihad with something too but I can't say.

21             But let me add you always had some excuse to beat someone.  If

22     somebody were looking from outside, they would say, well, these people

23     are quite right to beat them because you always found some excuse.  You

24     blame me for disrupting brotherhood and unity, for inciting the people,

25     young and old, to go and vote.

Page 18820

 1        Q.   Mr. Karabeg, I don't think that anybody must be allowed to be

 2     beaten but in your statement of July 1999, on page 12, you said that

 3     Macura beat people and said that you should be blamed for the hostile

 4     relationship between the two ethnic communities who could no longer live

 5     together side by side, that you said that.

 6        A.   I said -- I did not, no but he blamed me for disrupting

 7     brotherhood and unity.

 8        Q.   You said that the two communities could no longer liver together?

 9        A.   Yes.

10        Q.   Here is the statement:

11             JUDGE KWON:  No.  It's -- you said a minute ago that was your

12     last question.  And then continue.  It's difficult to find the

13     significance of these lines of questions.  Your last question.

14             MR. KARADZIC: [Interpretation] Your Excellency, I cannot --

15             JUDGE KWON:  Please put your last question and you can submit

16     later on.

17             MR. KARADZIC: [Interpretation] That was my last question.  I just

18     wanted to tell you that I cannot disclose what will be stated in the

19     final arguments because Ms. Sutherland is going to use that and act

20     accordingly and I know exactly what I'm aiming at.

21             JUDGE KWON:  Very well.  Do you have any re-examination,

22     Ms. Sutherland?

23             MS. SUTHERLAND:  Yes, Your Honour.

24                           Re-examination by Ms. Sutherland:

25        Q.   Mr. Karabeg, I'd like you to look at one document.  On page --

Page 18821

 1     today's transcript, page 22 and at pages 43 and 44.  There were questions

 2     put to you by Mr. Karadzic in relation to the police force and swearing

 3     of the loyalty oath.  This is on page 22.  If I could have 65 ter number

 4     004818, please.  If we could go to -- Mr. Karabeg, we can see there that

 5     this is a -- you have mentioned earlier in your testimony that -- during

 6     cross-examination at one point, that it all started on 11 April 1992,

 7     when the police were asked to sign the loyalty oath and put the insignia.

 8     This is a document from the CSB in Banja Luka dated 10 April and if

 9     I could just draw your attention to paragraph 3 on page 3 of the English,

10     and I think it's on page 3 going over to page 4 of the B/C/S.

11             JUDGE KWON:  We collapse English.

12             MS. SUTHERLAND:

13        Q.   Paragraph 3 says:

14             [As read] "Upon the receipt of the new post assignments,

15     authorised employees will have to sign a solemn declaration, the text of

16     which is identical to that of the solemn declaration from the previous

17     Law on the Internal Affairs and the employees were given the deadline of

18     15 April 1992 to sign the declaration.  Those who fail to sign the

19     declaration by that date will have their employment with the SRBiH

20     Ministry of Internal Affairs terminated."

21             And then paragraph 4:  "Police employees shall wear ..."

22             JUDGE KWON:  Next page.

23             MS. SUTHERLAND:

24        Q.   "Police employees shall wear new uniforms and sleeve insignia

25     with the word 'milicija' written in the Cyrillic script and blue berets

Page 18822

 1     with the tri-coloured flag (red, blue and white) badge."

 2             Is this consistent with what you were trying to explain earlier

 3     in your testimony today?

 4        A.   Yes.

 5             MS. SUTHERLAND:  I tender that document, Your Honour.

 6             JUDGE KWON:  Admitted.

 7             THE REGISTRAR:  As Exhibit P3330, Your Honours.

 8             MS. SUTHERLAND:  Just one other matter, Your Honour, earlier

 9     today at transcript pages 49 to 51, there was a document discussed in

10     relation to the SOS, if you recall, and Mr. Karadzic sought to admit it,

11     and Your Honours asked for my assistance in relation to whether it

12     contradicted the witness's evidence and I said to you that it hadn't

13     because the document was dated 30 May 1992.  And he couldn't -- said he

14     couldn't talk about it and then Your Honours conferred and decided that

15     you didn't want to admit the document.  In fact, when I read the

16     transcript back in the break, it's not inconsistent with this witness's

17     evidence because the witness does speak about the SOS committing acts

18     prior to 30 May 1992, so in that regard, I would have no objection to the

19     tendering of this document.

20             JUDGE KWON:  We admitted a document which refers to SOS group,

21     which was 65 ter 5125 and was admitted as Exhibit D1681.  What we didn't

22     admit was an announcement regarding -- by Serbian Defence Forces on

23     30 May.

24             MS. SUTHERLAND:  Yes, Your Honour, that was 65 ter 05077.

25             JUDGE KWON:  Yes.  So the Chamber found that two cases to be

Page 18823

 1     different.  But now you --

 2             MS. SUTHERLAND:  I think the proposition that Mr. Karadzic was

 3     putting to the witness was that this is a document dated 30 May and see,

 4     it shows that these forces were being impeded in doing what they wanted

 5     to do.

 6             JUDGE KWON:  Sorry to interrupt you but you're moving now to --

 7     for those -- that document to be admitted?

 8             MS. SUTHERLAND:  Your Honour, I have no objection to the document

 9     being admitted simply because in the document it does refer to --

10             JUDGE KWON:  But we already ruled on it.  Unless you move to

11     tender that, we will not revisit the issue.

12             MR. ROBINSON:  Can we move for reconsideration?

13             JUDGE KWON:  There will be another opportunity to -- for the

14     Chamber to admit that document.  Not this time.  We leave it at that.

15             MS. SUTHERLAND:  Very well, Your Honour, and just a couple of

16     other matters.  Yesterday, we said that we would get back to the Chamber

17     in relation to MFI D1678 which was discussed at transcript page 18741, it

18     was a document that had -- I stated that the MFI said it was a partial

19     translation or a summary translation.  In fact it is a full translation

20     done by AID.

21             JUDGE KWON:  Yes.

22             MS. SUTHERLAND:  So the MFI status can be taken off that document

23     if Your Honours are minded to do that. [Overlapping speakers]

24             JUDGE KWON:  That was our observation.  That will be admitted in

25     full.  Thank you.

Page 18824

 1             MS. SUTHERLAND:  Another document yesterday, the book, the large

 2     book which was MFIed, D1677, and certain pages that Mr. Karadzic has put

 3     to Mr. Karabeg have been admitted.  I just wanted to make sure that we

 4     are reserving our right to tender other parts of the book once the book

 5     has been translated.

 6             JUDGE KWON:  Yes.

 7             MS. SUTHERLAND:  And finally --

 8             JUDGE KWON:  You're done with your re-examination?

 9             MS. SUTHERLAND:  Yes, Your Honour, thank you.

10             JUDGE KWON:  So we can excuse the witness.

11             MS. SUTHERLAND:  Yes, I just have one other document which was

12     put by the Defence to Mr. Karabeg and I wanted to know whether it was

13     being admitted in its totality and that was 0 -- 1D00015, which is also

14     65 ter number 05097.

15             JUDGE KWON:  I think it was admitted previously as D6.  You mean

16     the list of killed soldiers in Sanski Most?

17             MS. SUTHERLAND:  Yes, Your Honour.

18             JUDGE KWON:  If my recollection is correct that was admitted when

19     our first witness came, Ahmet Zulic.

20             MS. SUTHERLAND:  I'm sorry, Your Honour and I led that witness

21     and I overlooked that matter.  Thank you.

22             JUDGE KWON:  Thank you.

23             Then it concludes your evidence, Mr. Karabeg.  On behalf of our

24     Chamber and the Tribunal as a whole, I would like to thank you for your

25     coming to The Hague to give it.  Now you are free to go.

Page 18825

 1             THE WITNESS: [Interpretation] I would like to thank you, too, for

 2     working so properly.

 3                           [The witness withdrew]

 4             MS. SUTHERLAND:  Your Honour, Mr. Gaynor and I need to switch

 5     places.

 6             JUDGE KWON:  I'm not sure it's practicable to continue but could

 7     you let us know who the next witness is?

 8             MR. GAYNOR:  The next witness, Mr. President, is KDZ-379.

 9             JUDGE KWON:  Oh, yes.  Shall we go into private session briefly?

10                           [Private session]

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 18826

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

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

10             Unless there are any other matters to raise, to be raised, we

11     will adjourn for today and resume tomorrow at 9.00.

12                           [Trial Chamber and registrar confer]

13             JUDGE KWON:  There is Lukic and Lukic case, yes.  We will resume

14     at 1.30 tomorrow.

15                           --- Whereupon the hearing adjourned at 1.40 p.m.,

16                           to be reconvened on Thursday, the 15th day of

17                           September, 2011, at 1.30 p.m.