Page 20837

 1                           Thursday, 3 November 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.03 a.m.

 6             JUDGE KWON:  Good morning, everyone.  Would the witness kindly

 7     take the solemn declaration.

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

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

10             JUDGE KWON:  Thank you, sir.  Please make yourself comfortable.

11             Yes, Ms. Sutherland.

12                           WITNESS:  NENAD KREJIC

13                           [Witness answered through interpreter]

14             MS. SUTHERLAND:  Good morning.

15                           Examination by Ms. Sutherland:

16        Q.   Sir, please state your full name.

17        A.   My name is Nenad Krejic.

18        Q.   As we discussed the other day, part of your evidence is -- in

19     this case is going to be submitted in writing, and we need to first deal

20     with the formalities associated with that submission.  You provided a

21     statement to representatives of the Office of the Prosecutor of the ICTY,

22     and you've also testified as a witness in the BH state court and also

23     before this Tribunal in the Stanisic and Zupljanin trial on the 1st and

24     2nd of September, 2010.  You've subsequently had an opportunity to review

25     the audio recordings of your testimony in the Stanisic and Zupljanin case

Page 20838

 1     and you wish to provide a number of clarifications.  These clarifications

 2     were read back to you and you agreed with them, and I think the simplest

 3     way for me to do it is go through the clarifications as you indicated and

 4     then if you can simply affirm with a yes or a no whether I have stated

 5     the clarification you wish to make correctly.

 6             So the first clarification is in relation to English transcript

 7     page 14046, and this is in 65 ter number 0 -- 90287, and it's starting at

 8     line 13, and you wished to clarify that your answer where you said:

 9             "In our municipality --"

10             I'll start again, quote:

11             "In our municipality there had been no war crimes, no mass or

12     multiple murders, and the public saw this incident as something that is

13     going to besmirch our municipality."

14             And the clarification that you wanted to make is that it doesn't

15     imply that the massacre at Koricanske Stijene occurred in the territory

16     of the Skender Vakuf municipality which was subsequently renamed the

17     Knezevo municipality; that is correct?

18        A.   I am not sure that I understood the last bit of your question

19     properly.  When you were talking about Koricanske Stijene and its

20     location, although during proofing we did clarify that.  Could you please

21     repeat that bit.

22        Q.   Basically the correction you wanted to make to the transcript

23     page at 14 -- it wasn't a correction, it was a clarification, at

24     transcript page 14046, was just the fact that when you referred in your

25     answer to "there had been no war crimes, no mass or multiple murders,"

Page 20839

 1     and the public saw this incident as something that was going to look

 2     badly upon your municipality, what you -- what you want to clarify is

 3     that this incident at Koricanske Stijene, at the actual site, occurred --

 4     didn't occur on the territory of the Knezevo municipality, what was

 5     formally known as the Skender Vakuf municipality.  And, in fact, you

 6     pointed that out in subsequent transcript pages, and that's at transcript

 7     page 14093, starting at line 25.  You made reference to this fact that

 8     the site where the incident took place was in fact not on Knezevo

 9     municipality territory, and you also pointed it out again at transcript

10     page 14100, starting at line 22.  And that was the clarification that you

11     wanted to -- to make, wasn't it?

12        A.   Yes.  Now I understood you, and I can answer that that was indeed

13     the case.

14        Q.   And the next clarification that you wanted to make is at

15     transcript page 14030 starting at line 10, and you wished to clarify that

16     in addition to the city of Knezevo - and this is when you were

17     questioned, you were looking at the map, the ethnic breakdown map - and

18     you wanted to clarify that in addition to the city of Knezevo, Muslims

19     also lived in two small suburbs of the city of Knezevo called Sapani and

20     Bastina, and both those suburbs are approximately 1 kilometre from the

21     town of Knezevo, and they have approximately 30 houses in each.  And

22     additionally, at line 13 on the same transcript page, you wanted to

23     clarify that there is actually a Croatian village of Pavlovici, but it is

24     located in the Croat part of the municipality in the south-west area and

25     not in the Serb part of the municipality in the north-west area, because

Page 20840

 1     you were taken to the map and you said that there is no village called

 2     Pavlici -- Pavlovici in the north-east area, and you're actually

 3     clarifying that, in fact, there is one there in the north-east area but

 4     there's also one in the south-west area which is where the Croat -- the

 5     Croat population lived; is that correct?

 6        A.   Yes.

 7        Q.   The next clarification you wished to make was at transcript page

 8     14035 starting at line 9, and in there you wished to clarify your answer,

 9     "The last convoy to leave Prijedor," by stating that it's actually the

10     second-to-last convoy that arrived from Prijedor.  Is that the

11     clarification you wished to make to that transcript page?

12        A.   We had problems during proofing with regard to this particular

13     answer, because you and I together established that in the transcript, it

14     was erroneously interpreted.  We listened to the audiotapes subsequently.

15     I didn't say at the time that the convoy left from Prijedor as it was

16     transcribed.  I said that that convoy came from Prijedor.  I did not want

17     to particularly clarify this, so we established that last year during my

18     testimony in the Zupljanin/Stanisic case I said, and that was confirmed

19     by listening to the audiotape that, that convoy came from Prijedor.  I

20     never knew that it was misrecorded.  However, in my clarification I only

21     clarified that that was the penultimate convoy that came from Prijedor

22     for as much as I knew and not the last one.

23        Q.   Thank you for that clarification, Mr. Krejic.  The next

24     clarification is in relation to transcript page 14125 starting at line

25     21, and that was when there was discussion about the Law on Internal

Page 20841

 1     Affairs, and at one point your answer at line 21, instead of beginning

 2     with the word "Yes," it should have started with "I don't remember that

 3     specific provision," but the remainder of the answer is correct that you

 4     give in the transcript.  Is that right?

 5        A.   That's right.

 6        Q.   The next clarification you want to make is at transcript page

 7     14127 starting at line 16, and the clarification is that there the answer

 8     which begins your answer "Yes," it appears from -- from that that you're

 9     agreeing that the road was blocked throughout the war, which was put to

10     you as part of the question, and you wish to clarify that the "Yes"

11     referred to part of the question related to a Croat and not to the part

12     of the question about the road being blocked, and you wanted to stress

13     that the road was not blocked throughout the war.  Is that correct, the

14     clarification as I've just stated it?

15        A.   Yes.

16        Q.   And finally a clarification on transcript page 14129, starting at

17     line 11.  You wish to clarify that the answer "Yes" at that point is not

18     entirely accurate but that you clarified it in your further response

19     after the break that was immediately taken, and that's at transcript page

20     14130, line 1.  Is that the -- the clarification you wish to make?

21        A.   Yes.

22        Q.   Mr. Krejic, with those clarifications, do you agree that the

23     transcript accurately reflects what you said at the time you gave

24     evidence?

25        A.   Yes.

Page 20842

 1        Q.   If you were asked today about the matters you testified to in the

 2     Stanisic and Zupljanin case with the clarifications that we've just gone

 3     through, would you provide the same information to the Chamber, and that

 4     is even if you couldn't formulate everything in the same words, the

 5     essence would be the same?

 6        A.   Yes, that's correct.

 7             MS. SUTHERLAND:  Your Honour, I tender 65 ter number 90287, which

 8     is the witness's Stanisic/Zupljanin testimony.

 9             JUDGE KWON:  Yes, that will be admitted.

10             THE REGISTRAR:  As Exhibit P3760, Your Honours.

11             MS. SUTHERLAND:  And with Your Honours' leave I'll read a summary

12     of the witness's written evidence.

13             Mr. Krejic is a Bosnian Serb from the Skender Vakuf municipality

14     which was renamed Knezevo.  During the relevant time period the witness

15     was the chief of the Skender Vakuf/Knezevo SJB.  The witness testified

16     about the aftermath of the mass killing at Koricanske Stijene on the 21st

17     of August, 1992.  This is scheduled incident B, 15.6.

18             The witness testified that he visited the site shortly after the

19     massacre and saw between 150 and 200 bodies.  He was told by policemen

20     that members of the SJB Prijedor had admitted that they had killed the

21     people at Koricanske Stijene.  The witness was also told by men from his

22     police unit that the perpetrators had robbed the persons on the convoy of

23     money and gold.

24             Further, the witness testified that immediately after viewing the

25     site of the massacre, he reported his findings to Stojan Zupljanin, his

Page 20843

 1     superior, who was chief of the Banja Luka CSB.  Shortly thereafter, the

 2     witness travelled to Banja Luka with Milan Komljenovic and Vladimir

 3     Glamocic who was the president of the Executive Board -- sorry, president

 4     of the municipality of Skender Vakuf, and Vladimir Glamocic who was

 5     President of the Executive Board of the Municipal Assembly for a meeting

 6     with Stojan Zupljanin.  Also present at the meeting were Milomir Stakic

 7     and Simo Drljaca from Prijedor, the president of the Municipal Assembly

 8     and the chief of police respectively.  There were also others in this

 9     meeting, and you discussed the removal of the bodies of the massacre.

10             The witness testified that people from Prijedor were present at

11     the meeting -- sorry.  I'll start again.  The witness testified that

12     people from Prijedor who were present at the meeting admitted that

13     killings at Koricanske Stijene had been committed by policemen from

14     Prijedor.  The witness testified that at the meeting, Stojan Zupljanin

15     read a dispatch sent by Radovan Karadzic ordering the municipal leaders

16     from Prijedor and Skender Vakuf/Knezevo to deal with the matter.

17             The witness testified that four or five days after the incident,

18     members of the 22nd Brigade of the Army of Republika Srpska, the VRS,

19     brought into the Skender Vakuf/Knezevo SJB a survivor of the massacre at

20     Koricanske Stijene.  Pursuant to an order from Zupljanin, the witness

21     personally transported a survivor of the massacre to Banja Luka security

22     service centre.  In addition, the witness testified that he also attended

23     a meeting in Banja Luka on the 30th of August, 1992.  That meeting was

24     chaired by Republika Srpska Minister of Defence Bogdan Subotic and

25     attended by RS MUP and civilian authorities from Banja Luka, Prijedor,

Page 20844

 1     and Skender Vakuf/Knezevo where the recovery of the bodies from the

 2     massacre was discussed.

 3             The witness testified that after the meeting, Bogdan Subotic and

 4     other persons present at the meeting travelled to the site of the

 5     massacre.  The witness testified that at the second visit of the site, he

 6     saw that the site of the massacre was not secured and that the civilian

 7     protection from Skender Vakuf/Knezevo had cut down shrubbery and

 8     underbrush to cover the bodies.  The witness identified police officers

 9     involved in the recovery of the bodies when he was shown a video-tape.

10             Your Honours, that concludes the summary of the witness's

11     evidence.

12             Mr. Krejic, I have no additional questions for you.  Thank you

13     very much.

14             JUDGE KWON:  Shall we deal with associated exhibits.

15             MS. SUTHERLAND:  Yes, Your Honour.  In relation to the

16     transcript, if I may, which is now Exhibit --

17             JUDGE KWON:  P3760.

18             MS. SUTHERLAND:  Yes.  There are a number of procedural matters

19     which are dealt with within Mr. Krejic's testimony, and I was going to

20     ensure that those transcript pages were redacted from the -- those

21     procedural matters were redacted from the transcript that will form part

22     of the exhibit, and if Your Honour wishes me to do read the transcript

23     page references and where those procedural matters unrelated to the

24     witness's evidence are dealt with.

25             JUDGE KWON:  If the Defence does not object to, you can relay

Page 20845

 1     with the court deputy later on.

 2             MS. SUTHERLAND:  Yes.  Thank you, Your Honour.  And I seek to

 3     have admitted all the associated exhibits.

 4             JUDGE KWON:  In relation to 65 ter 5554, list of members of

 5     Special Police detachment, can you upload it?

 6             MS. SUTHERLAND:  Yes, Your Honour.  I'll make sure that that's

 7     done.

 8             JUDGE KWON:  Well, shall we upload it now so that we can see the

 9     document.

10             MS. SUTHERLAND:  Oh, I'm sorry.

11             JUDGE KWON:  While it is being uploaded, 65 ter number 23497 and

12     23498, and as well as 23499, I take there's no objection from the Defence

13     to add these documents to the 65 ter list.

14             MR. ROBINSON:  That's correct, Mr. President.

15             MS. SUTHERLAND:  Your Honour, we have the document on the screen

16     now.

17             JUDGE KWON:  Very well.

18             MS. SUTHERLAND:  05554.

19             JUDGE KWON:  I wanted to check and make sure that while the

20     English page -- English version is of 20 pages, the B/C/S version is only

21     7 pages.  Is it correct?

22             MS. SUTHERLAND:  Your Honour, I'm -- I don't have the document,

23     I'm sorry, in front of me.

24             JUDGE KWON:  That's why I wanted to upload it.

25             MS. SUTHERLAND:  If we can go to the last page of the B/C/S.  And

Page 20846

 1     the last page of the English.  Your Honour, I'm sorry, there does appear

 2     to be an anomaly in the --

 3             JUDGE KWON:  And the witness referred to only two pages out of

 4     these 20 pages, so if you'd like to deal with this, I'd like to -- I'm

 5     sorry.  I correct.  If you'd like to tender this, I would like you to

 6     deal with this document with the witness now.

 7             MS. SUTHERLAND:

 8        Q.   Sir, do you -- do you recognise this document that was shown to

 9     you in -- in your Stanisic/Zupljanin testimony?

10             MS. SUTHERLAND:  If we could go back to page 1, please.

11        Q.   Do you -- do you recognise this document as the document that was

12     shown to you?

13        A.   With the Trial Chamber's leave, I would like to say a few words

14     about the summary that the Prosecutor has just read out and then I will

15     answer the question.  With your leave, Your Honours.

16             JUDGE KWON:  By all means, Mr. Krejic.

17             THE WITNESS: [Interpretation] I don't know if this has been

18     misinterpreted or something.  I'm not a Bosnian Serb.  I don't know if

19     there are such Serbs at all.  I'm a Serb by ethnicity, and I hail from

20     the state of Bosnia and Herzegovina.  I am a Serb.  I was born in

21     Bosnia-Herzegovina.  I am not a Bosnian Serb.

22             And another very important thing, I have a lot of objections, but

23     there is a key objection that I would like to refer to, and that is that

24     on two occasions it was mentioned at those meetings that were held in

25     Banja Luka we spoke about the removal of the bodies.  One can get an

Page 20847

 1     erroneous impression that there were two meetings where I participated

 2     actively and that the only subject of those two meetings was to eliminate

 3     the bodies from the crime site at Koricanske Stijene, which cannot be

 4     correct.

 5             MS. SUTHERLAND:  I can follow up.

 6             JUDGE KWON:  Thank you.  Yes.

 7             MS. SUTHERLAND:  I can follow up with that.

 8        Q.   Mr. Krejic, by the word -- when I used the word "removal," which

 9     was contained in the Stanisic/Zupljanin testimony, do you mean to recover

10     the bodies for -- to be used so that -- for forensic examination and

11     other things on it done to the bodies, for example, burials?

12        A.   At those meetings we discussed a number of things.  Firstly, we

13     established that a crime had been committed, that there were bodies

14     there, and we discussed the launching of investigation and procedure, not

15     just the removal, as you simply put it.  And then when you said

16     "removal," in the same breath you said to move the bodies and to bury

17     them, but there were other things mentioned as well.  For example, that

18     those bodies should be moved, that they should be taken out from the --

19     from that gorge and buried.  There were discussions about launching

20     investigation and prosecuting all those who were responsible for -- for

21     the crime.

22        Q.   Mr. Krejic, can you look at the document that's on the screen,

23     which is the document that was shown to you during your

24     Stanisic/Zupljanin testimony.  We can see that it's a list of the members

25     of the Banja Luka CSB Special Police detachment and it's the payroll for

Page 20848

 1     August 1992.  It lists 167 names there.  Were you aware of this Special

 2     Police detachment attached to CSB Banja Luka?

 3        A.   Yes, I was.

 4        Q.   And looking -- looking at the names there on the first page, are

 5     any of those -- you said that you -- no, I'm sorry.  I withdraw that

 6     question.

 7             Are you aware of these people being in the special detachment?

 8     The names that you see on this first page.

 9        A.   I know only some of these people, not all.

10        Q.   And the people that you know, can you say the number next to

11     their name?

12        A.   Perhaps I know some people by sight, but I don't know that the

13     person's name is, for instance, Mirko Lukic, although I happen to know

14     the man.  I'll only tell you the names of those people where I can match

15     the face with the name.

16             Number 2, Ljuban Ecim; then 3, Zdravko Samardzija; number 4,

17     Nenad Kajkut; number 7, Trifko Buha; number 10, Danko Kajkut; 12,

18     Stevo Karakas.  Number 15 and 18, two last names -- in fact, the same

19     last name, Prastalo, I don't know which one I know, Ranko or Dragan, then

20     Milan Bosancic.

21             JUDGE KWON:  I don't think you meant the witness to go through

22     one by one of each item.  Can we see just 7 -- page 7 in both versions.

23     Both here it ends with the number 169.  The B/C/S version stops here, but

24     the English version goes on to page [Overlapping speakers] --

25             MS. SUTHERLAND:  Yes, Your Honour.  Mr. Reid has advised me that

Page 20849

 1     the additional pages should have been removed when the document was

 2     uploaded, and they will be removed.

 3             JUDGE KWON:  Very well.  And then two further questions in

 4     relation to 65 ter number 23498 and 23499, while we grant the leave to

 5     add these documents to 65 ter list, but I note that two are identical

 6     documents while the latter is the one to which the witness added some

 7     additional marks.  So I don't think we need to admit the first one.  Do

 8     you agree?

 9             MS. SUTHERLAND:  Your Honour, I only have 65 ter number 23498.

10             JUDGE KWON:  Are you not tendering 23499?  It's on --

11             MS. SUTHERLAND:  Yes, Your Honour, you're right.  No, but they

12     were both -- yes, we only need one of them.  You're right.  I'm very

13     sorry about that.

14             JUDGE KWON:  No problem.  And just to make sure the last -- the

15     video-clips, 40573 A and B, although they are from the same video-clip,

16     you are tendering those two separately.

17             MS. SUTHERLAND:  Yes, Your Honour.  That's the way that -- --

18             JUDGE KWON:  Very well.

19             MS. SUTHERLAND: --  I was advised they should be tendered.

20             JUDGE KWON:  Otherwise, are there any objections to the admission

21     of associate exhibits?

22             MR. ROBINSON:  No, Mr. President.

23             JUDGE KWON:  Thank you.  With the exception the 23498, all those

24     will be admitted into evidence and be given numbers in due course by the

25     court deputy.

Page 20850

 1             Well, Mr. Krejic, your testimony in other -- in the previous

 2     proceedings was admitted in it's entirety in lieu of your

 3     examination-in-chief in this trial.  Now you will be further examined by

 4     Mr. Radovan Karadzic in his cross-examination.  Do you understand that?

 5             THE WITNESS: [Interpretation] Yes.

 6             JUDGE KWON:  Very well.

 7             Mr. Karadzic.

 8             THE ACCUSED: [Interpretation] Good morning, Your Excellencies.

 9     Good morning to everyone.

10                           Cross-examination by Mr. Karadzic:

11        Q.   [Interpretation] Good morning, Mr. Krejic.

12        A.   Good morning.

13        Q.   Thank you for kindly meeting with the members of my Defence team.

14     I hope that will help us conduct this cross-examination expeditiously,

15     and I will try to put questions that could be answered with yes or no.

16             I'm sorry that because of some administrative circumstances I was

17     not able to meet with you personally.  I just want you to know it did not

18     depend on me.

19             So that the Chamber and other participants in this process get an

20     image of the area, I should like to ask you to mark certain points on a

21     map, and I would like to call up 1D4275.

22             THE ACCUSED: [Interpretation] Thank you.  Could we now zoom in on

23     the beginning of the western third, where the cursor was.  Exactly.

24     Thank you.  Could we now zoom in on Skender Vakuf.  Now it's somewhere in

25     the middle.  Could we zoom in a bit more but still leave the neighbouring

Page 20851

 1     municipalities on the screen.  Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Mr. Krejic, may I ask for your assistance.  This is an ethnic map

 4     of Knezevo which borders on Mrkonjic Grad, Banja Luka, Celinac,

 5     Kotor Varos, Jajce, and Travnik; correct?

 6        A.   I just don't understand if these are pre-war municipalities and

 7     the pre-war municipality of Knezevo or the current municipality of

 8     Knezevo after the war.

 9        Q.   I'm waiting for interpretation, and I would like you to do the

10     same.  This is a pre-war map, pre-war situation.

11        A.   I'm not sure it's pre-war.  I don't think so.

12        Q.   Thank you.  I'll try to remind you.  Is it true that the lower

13     bottom concentration of 15, 20 villages in Okur [phoen], are these

14     Croatian settlements across the Ugar canyon, which separates Croatian and

15     Serbian settlements?  I believe it's called Dobratic.

16        A.   Yes, correct.  The entire area is called Pougarje, named after

17     the Ugar River, and Dobratici was one of the four local communes before

18     the war.  And nowadays -- and this area was taken out of the pre-war

19     Knezevo municipality to form a separate municipality called Dobratic

20     which belongs to the Federation of Bosnia-Herzegovina.

21        Q.   Could we agree to begin with that there are no Muslim villages in

22     what remains and that the Muslims lived in Skender Vakuf, that is to say

23     Knezevo?

24        A.   Yes.  We have just cleared that up with the Prosecutor.  In the

25     little town of Knezevo itself and two smaller suburbs, Sapani and

Page 20852

 1     Bastina, which are one kilometre from the centre of town each, they

 2     contained very few houses.

 3        Q.   Could you mark Koricanske Stijene on this map very roughly, the

 4     place of the incident.

 5        A.   I couldn't, because when I told you at the outset that I don't

 6     think it's a map of pre-war Knezevo, I believe it's a map of Knezevo as

 7     it is now, Koricani is now within the Knezevo municipality, whereas it

 8     was not before the war.

 9        Q.   Could you mark then the Ugar River and the concentration of

10     Croatian places.

11        A.   The Ugar River, as you said, it's canyon separates -- I'm sorry

12     about this.

13             I don't know if I've drawn it correctly, but this red line

14     separating the Croatian and Serbian population is where the Ugar River

15     flows.  My hand is shaking a little.

16        Q.   Could you mark Dobratic municipality with number 2.

17        A.   [Marks]

18        Q.   And could you help us while the map is still on display, where

19     Koricanske Stijene is, the site of the incident.

20        A.   I think that this boundary is the boundary separating the pre-war

21     Knezevo from Travnik, and that's approximately where the river Ilomska

22     runs, and that's where the site of the incident would be.  Approximately.

23        Q.   Could you put number 3 there.

24        A.   [Marks]

25        Q.   And so that we make it easier for later, this Muslim

Page 20853

 1     concentration of villages, is it Siprage or Vecici?

 2        A.   This is Siprage and the surrounding villages.  Vecici is further

 3     to the north, next to Kotor Varos.

 4        Q.   Mark Siprage with 4 and Vecici with 5.

 5        A.   [Marks]

 6        Q.   And one more thing.  Could you draw a line, to the best of your

 7     recollection, where the front line or the separation line was throughout

 8     the war.  We lost some ground occasionally at Vlasici, but the remaining

 9     front line remained the same.  Where was the front line in the summer of

10     1992?

11        A.   Yes.  You've corrected yourself in that last question.  The front

12     line did move throughout the war.  And there was one front line up until

13     the capture of Jajce, and after that it changed.  Now you've said summer

14     1992.  Do you want to know where the front line was then?

15        Q.   Yes.  The more important part is closer to Vlasici and Travnik,

16     whereas Jajce was within our territory at some point, but I'm interested

17     in the area closer to Travnik.  Were these Travnik villages covered?  Was

18     the front line towards Vlasici within the boundaries of the municipality?

19        A.   Yes.  Something like this.

20        Q.   Put number 6 there, please.  That's the front line, the

21     separation line at the time.

22        A.   [Marks]

23        Q.   And you did not fight with Dobratici all the time, did you?

24        A.   I hope you don't mean myself.

25        Q.   Certainly not.

Page 20854

 1        A.   No, especially at the beginning of the war there was an

 2     understanding between Knezevo municipality -- or, rather, that part of

 3     Knezevo municipality made up of Croats that we should avoid conflict of

 4     all sorts, and we had no reason to fight anyway.  You've already

 5     mentioned that there's a deep canyon of the Ugar River there, and it has

 6     always separated the 100 per cent Croatian area on one side and the

 7     Serbian side.  There was no reason for war between them, and we displayed

 8     restraint and containment until the war when some other circumstances

 9     that prevailed that were beyond the control of the civilian authorities

10     of Knezevo or Dobratici.  We had a sort of gentlemen's agreement until

11     then.

12        Q.   Before we remove this map, could you please confirm that towards

13     the south closer to Travnik and Jajce there was constant fighting, and at

14     Vlasici the front line moved all the time depending on the successes

15     achieved, and they were the successes of the other side rather than ours?

16     Did it move all the time?

17        A.   I apologise.  We advanced only in 1992 when Jajce fell, when we

18     took Jajce and the Croatian part of Knezevo municipality, but we are

19     talking about the slopes of Vlasici and Galica mountain in the direction

20     of Turbe.  Throughout the war, the line that I marked by number 6 was

21     exactly as you defined it.  We did not make any advancements.  It was as

22     it was.  And then in the course of 1994, we suffered losses, which means

23     that the line was moved, but it was moved at our expense.

24        Q.   Thank you.  And now could you please tell us -- you mentioned in

25     the case of Ivankovic in Sarajevo that the unit under the command of a

Page 20855

 1     serious man, Slobodan Celic, was the closest to the place of the event.

 2     However, according to you, that unit was a few kilometres away from

 3     the -- the event.  It was closer to the front line; right?

 4        A.   Yes, that's right.

 5        Q.   Could you please put number 7 next to the place where that unit,

 6     the closest unit, that is, was deployed.

 7        A.   I apologise.  I'm really not very good at making the markings.

 8     The markings should be a bit more to the right, on the very border.  It

 9     would be more or less here.

10        Q.   Can you please put number 7 under your marking.

11        A.   [Marks]

12        Q.   Thank you.  You seem to be right, because there is a border next

13     to number 3.  It is possible that the municipality border was there

14     before the war.

15             And now can you please put the date on the map, and can you sign

16     it.

17        A.   [Marks]

18        Q.   Thank you.

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

20             JUDGE KWON:  Yes.

21             THE REGISTRAR:  Exhibit D1880, Your Honours.

22             THE ACCUSED: [Interpretation] Thank you.

23             MR. KARADZIC: [Interpretation]

24        Q.   Now I would like to immediately move on to the key tragic event

25     in the Ivankovic case, which is 65 ter 22155.  65 ter 22155, on page 11,

Page 20856

 1     you stated that Mr. Zupljanin ordered you to take a professional from the

 2     police with you and to go to place of the event to see what had happened

 3     and then to urgently come back to Knezevo and report back to him; is that

 4     correct?

 5        A.   Yes.

 6        Q.   Thank you.  In the same case, on page 13 you stated that the

 7     purpose of that was for you to provide your chief with the highest

 8     quality information.  You were supposed to learn the details first, and

 9     then you were supposed to get in touch with the police unit, a platoon

10     that was subordinated to the Army of the Republika Srpska and was

11     deployed somewhere in the vicinity during the time when fighting was

12     going on for Jajce; is that correct?

13        A.   Yes.

14        Q.   Thank you.  And then you were asked where that was, and you said

15     that it was some 4 or 5 kilometres forward, and you have just marked the

16     place where that unit was deployed at the separation line -- or, rather,

17     the front line; right?

18        A.   Yes.

19        Q.   Thank you.  On page 14, in the same case you described your

20     conversation with the commander Slobodan Celic, whom you highly

21     respected, and you said that during that conversation, several people

22     approached you.  They all had impressions to share with you and about

23     your encounter with the perpetrators, policemen from Prijedor, and you

24     said that the policemen from Prijedor showed money, gold, and also that

25     one of them allegedly said that he had secured the future of his whole

Page 20857

 1     family.

 2             Did they tell you that the other people did not hide anything and

 3     that they showed a lot of interest in the valuables that they had stolen

 4     from the victims?

 5        A.   According to what police members from my public security station

 6     told me, one could say that that was indeed the case.

 7        Q.   Thank you.  Did you gain an impression in all that that there was

 8     a rather small group of perpetrators and that a very important motive, if

 9     not the only one, was financial gain, the financial gain that was

10     acquired in such a gruesome way?  You're a policeman.  When they told you

11     how they had behaved, did you get an impression that that group was not

12     big and that they were motivated by theft?

13        A.   Yes.  I immediately knew that the group was not big.  However, I

14     could also say that one of the motives was theft.  I can agree with you

15     on that.  However, I thought then, and I still think now, that those men

16     were just sick.  They were mental cases, if I can put it that way,

17     because only a lunatic, a sick mind, can commit such a crime.  And then I

18     would put theft and -- theft and financial gain in the second -- second

19     place.

20        Q.   In the same case, on page 14 you explained that you had a

21     telephone conversation with Mr. Zupljanin, that you conveyed information

22     to him, and then he ordered you to come to the centre early in the

23     morning, to the security services centre in Banja Luka, together with the

24     president of the municipality and the president of the executive board,

25     and you did that on the following morning, and that was your first

Page 20858

 1     meeting with Mr. Zupljanin after the event; is that right?

 2        A.   Yes.  That was my first and only meeting with Mr. Zupljanin,

 3     because Mr. Zupljanin did not attend the second meeting.

 4        Q.   Thank you.  And then on page 15, you went on to say that

 5     Mr. Zupljanin called the meeting to order and that the meeting started by

 6     him saying that something terrible had happened, something that should

 7     not have happened.  Were you then clear?  Did you understand that

 8     Mr. Zupljanin was horrified by the event?

 9        A.   Yes.

10        Q.   Thank you.  And then on page 16 of the same transcript in the

11     same case, you explained that people from Prijedor were also present

12     there, and you repeated that -- or, rather, it was repeated in the

13     summary.  And you said in your testimony that you remember that he said

14     to people from Prijedor that not a single murder can be covered up or may

15     be covered up.  Even if we all agree that we should cover up one single

16     murder, it cannot be done.  And there's no chance in hell that such a

17     mass murder could be covered up, and we will certainly not do anything in

18     that direction.  Is that correct?

19        A.   Yes.

20        Q.   Thank you.  And then in the Zecevic case, which is 1D4547 to the

21     Prosecutor's question as to whether Mr. Zupljanin spoke about the

22     perpetrators of the crime and the need for them to be arrested, you

23     answered that Mr. Zupljanin took the position that everything had to be

24     done by the book, according to the law, including an on-site

25     investigation, the identification of the bodies and everything else that

Page 20859

 1     is envisaged by the law; is that correct?

 2        A.   Yes.

 3        Q.   Can we then conclude that at that first meeting your assessment

 4     and your impression was that your chief, the chief of the security

 5     services centre, Mr. Zupljanin, acted in a very professional way as

 6     regards -- as regarded that crime?

 7        A.   Yes.

 8        Q.   Thank you.  In the Zupljanin case, which is 1D4548 - now it has a

 9     92 ter or P number - on page 14048 to the Prosecutor's question as to how

10     Mr. Zupljanin reacted to all that, you said:

11             "When I met Chief Zupljanin privately, that morning before the

12     meeting I noticed that he was rather upset.  He was visibly upset.  He

13     condemned the incident very clearly in no uncertain terms."

14             I'm going to read in English.

15              "[In English] He condemned the incident strenuously as he called

16     a spade a spade.  He said it was a crime, and he took more or less the

17     same position as we from Knezevo did."

18             [Interpretation] Is this correct?

19        A.   Yes.

20        Q.   Thank you.  On the same page, starting with line 11, you say that

21     there was a lot of clamour.  Zupljanin insisted that the bodies should be

22     removed from the place of the incident, that the bodies should be

23     identified and finally buried, and at one point he reacted very fiercely

24     towards Simo Drljaca.

25             "[In English] He told him in no uncertain terms that he would

Page 20860

 1     insist on Prosecuting the perpetrators of this -- of that crime."

 2             [Interpretation] Did you confirm in the Zupljanin case that

 3     Mr. Zupljanin lost his calm and started shouting when somebody mentioned

 4     a possibility of covering up the crime, that Zupljanin lost it at that

 5     point?

 6        A.   Yes.  I knew Mr. Zupljanin.  He was quite a composed person.  I

 7     had never seen him react in that way, not before that or after that

 8     event.  Not only did he shout, but he also threatened and waved his

 9     finger at people.

10        Q.   You went on to say on page 14078 and 14079, and I will read in

11     English.

12             "[In English] Zupljanin was stunned and he said loud and clear,

13     are you aware that one murder or crime cannot be concealed, let alone

14     crime of this massive scale?  Forget about it.  We have to be serious and

15     get our act together and deal with the -- in a proper way."

16             [Interpretation] And then you went on to say on the following

17     page.

18             [In English] "This is a crime."

19             [Interpretation] And then to the question:

20             "[In English] And then you said earlier, he said at that point

21     that there would be an investigation and the perpetrators would be

22     punished."

23             [Interpretation] Your answer:

24             [In English] "Yes, because as I remember, Simo Drljaca again

25     reacted with contempt towards what Stojan Zupljanin said.  And I must say

Page 20861

 1     I had never seen Stojan Zupljanin lose his calm.  This time he was really

 2     wagging his finger and saying that somebody --"

 3             [Interpretation] Very well.  So you repeated this verbatim before

 4     the court of Bosnia-Herzegovina and in the case here at this Tribunal.

 5        A.   Yes.  That was indeed the case.

 6        Q.   Thank you.  And in the Zecevic case, which is 1D4547, on page 14

 7     you stated that Zupljanin reiterated that that was a horrendous crime and

 8     that he was reading from a dispatch or a message where it said that the

 9     president of the Republika Srpska, Karadzic, who at the time was

10     attending a peace conference either in London or somewhere else, had said

11     that they had to deal with that, that their leaderships of the two

12     municipalities had to deal with that; is that correct?

13        A.   Yes, I've said that.

14        Q.   However, you did not see whether it was a dispatch or a message

15     noted down in some way.  That was Stojan's interpretation.

16        A.   He was holding some sort of document that looked like the

17     dispatches that we used to receive, normally, and I thought then and

18     still think now that I couldn't be 100 per cent sure.  It's possible it

19     was a dispatch, because it was nothing difficult to type up on the

20     communication device that we used at the time, the teletype, and it

21     wasn't difficult to display it as if it had been sent to us from

22     somewhere, but knowing Chief Zupljanin, I'm more inclined to think that

23     he made up the whole story with the dispatch in order to drop your name

24     to get more authority among the people of Prijedor on whom he otherwise

25     had no great influence.

Page 20862

 1        Q.   It seems to follow from that that the residents of Prijedor were

 2     rather independent even from Banja Luka, which was no more than 50

 3     kilometres away.

 4        A.   I will limit my answer only to my line of work, that is to say

 5     public security.  Indeed, when we had meetings before the war and during

 6     the war, Chief Zupljanin held these meetings at the collegium, attended

 7     by all chiefs of public security centres in the area of Banja Luka, and

 8     at these meetings we gained a very clear impression, in fact it was

 9     perfectly clear, that he had next to no influence at all on the leading

10     people from the public security station of Prijedor, and I mean first and

11     foremost Simo Drljaca.  And even the other public security stations,

12     Novi Grad, Bosanska Dubica, and other places at the foot of Mount Kozara

13     acted similarly to Simo Drljaca, and I believe that was one of the

14     reasons why the centre of public security of Prijedor was established as

15     separate from Banja Luka; wherein, the Prijedor Public Security Station

16     became the leader, whereas the other stations that I enumerated fell

17     under that centre and thus definitively broke up with Banja Luka for

18     which they had no great respect.

19        Q.   The others probably don't know this, but the Serbs have this

20     autonomous streak.  Whenever they can, they want to be independent from

21     the superior level of management or whatever.

22        A.   Yes, I agree.  That's one of our great flaws as a people.

23        Q.   In the Ivankovic case, 65 ter 22155, pages 18 and 19, you were

24     asked about the survivors.  Prosecutor Terzic asked you about the

25     survivors, and then you explained that the people from the military

Page 20863

 1     security brought a man one morning, and the man was around 40, short, and

 2     he was turned over to you.  They said they had found him wandering

 3     blindly in the area where the incident had happened.

 4             You informed Chief Zupljanin, and he told you that you should get

 5     in your car, go get the man, and that you were personally responsible for

 6     his health and safety and for bringing him to Banja Luka.

 7             Can you conclude from that that Zupljanin had a concern that

 8     somebody might wish to remove that witness, the eyewitness of the event,

 9     if they ever learned of his existence?

10        A.   Absolutely correct.

11        Q.   Thank you.  Then you continued on page 19 of the same document

12     talking to Prosecutor Terzic.  You said you were sitting together in the

13     car.  You didn't notice that the man had any injuries, and he seemed

14     comforted by your words that this deed had been perpetrated by people who

15     were not really human and that it was a horrible crime, but he didn't say

16     anything.

17        A.   I don't think you understood very well what I said, actually.

18     Everything is true in your question except that he was comforted or acted

19     positively.  He didn't react in any way at the beginning, either

20     positively or negatively.  He seemed frozen, and he did not even seem to

21     be a fully alive person who would dare to speak up or say anything.  He

22     didn't even seem like he was fully conscious.  I was trying to comfort

23     him, to say that what happened, happened, but now you are safe.  What was

24     done was obviously done by savages, beasts.  But at first he didn't react

25     in any way.

Page 20864

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

 2     break now.  We will resume at 20 to 11.00.

 3                           --- Recess taken at 10.20 a.m.

 4                           --- On resuming at 10.44 a.m.

 5             JUDGE KWON:  Yes, Mr. Karadzic.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   You -- you are right.  I'm sorry.  I'm trying not to read.  I'm

 9     trying to interpret what it says so that we would gain time.  So I'll try

10     to be as specific as possible, that is.

11             When you testified in Zupljanin, pages 14048, 1D4548 is the

12     number -- or, rather, 92 ter, from line 21 onwards you were asked whether

13     you talked to Zupljanin about what would happen to the survivor that you

14     brought.  So you said that you asked and that he said to you that this

15     person would be handed over to the Swiss Red Cross.

16             Was it clear to you that Zupljanin believed that it was better to

17     hand him over to an International Red Cross than any local institution or

18     the federation?

19        A.   Yes.

20             JUDGE KWON:  Transcript page again, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] 14048.

22             MR. KARADZIC: [Interpretation]

23        Q.   Was that your understanding?

24             JUDGE KWON:  This is the page that we saw earlier on, but I don't

25     find that passage on that page.

Page 20865

 1             THE ACCUSED: [Interpretation] From line 21 through 24.  Maybe I

 2     have the wrong reference.  Actually, we can look at the top.

 3             JUDGE KWON:  But as a matter of fact, if it is already in the

 4     transcript, you don't have to reconfirm it with the witness, because it

 5     is already in the evidence.  Let's proceed, Mr. Karadzic.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Yes.  Then I'm not going to discuss at any length what you

 9     already said in your testimony that has been admitted as a whole.  I'd

10     like to ask about this second meeting.  You discuss that in the Ivankovic

11     et al case; that is, 65 ter number 22155, on pages 20 and 21.  The

12     Prosecutor, Ms. Terzic, asked you -- actually, you said that the task had

13     not been accomplished and then you were asked to come back to this

14     meeting that was attended by Branko Buhovac as a crime scene officer, and

15     at that meeting what was discussed was whether an on-site investigation

16     had been carried out at all, and you said, I'm going to read this out --

17             THE INTERPRETER:  Interpreter's note:  The speaker will have to

18     slow down.

19             MR. KARADZIC: [Interpretation]

20        Q.   "[No interpretation]... no specific tasks.  However, he was the

21     most professional among us, and he said that before any relocation is

22     carried out the person has to be identified.  Quite literally all

23     persons.  And after that the persons should be buried."

24             That question has to be resolved; right?

25        A.   Yes.

Page 20866

 1        Q.   Thank you.  On page 21, the Prosecutor asked you whether

 2     Mr. Subotic, at the time minister of defence and colonel -- right?  He

 3     was a colonel and minister of defence at the time, wasn't he?

 4        A.   He was minister of defence.  That's 100 per cent sure.  But I

 5     think he was a general.

 6        Q.   Thank you.  Perhaps he became a general later.

 7             So the prosecutor asked you -- Prosecutor Terzic asked you

 8     whether he had any proposals regarding the bodies, and you said that he

 9     chaired the meeting and that he seriously intended for that meeting to be

10     fruitful to yield certain results, and to adopt conclusions that have to

11     be carried out.  Now, you say the people from Prijedor were a minority

12     with regard to this particular position, to hide things as if nothing had

13     happened.  That was no longer the case?

14        A.   Yes.

15        Q.   Thank you.  At that point in time, did it become clear to you

16     that they were afraid of being held potentially responsible for what

17     their policemen had done and that they feared the reaction of the

18     authorities, the top leadership of the republic as represented there by

19     Subotic?

20        A.   Yes.

21        Q.   Thank you.  Let us see what you said about that on page 28 in the

22     Ivankovic case.  Bazdarevic Defence counsel, asked you to explain the

23     behaviour of the late Drljaca and his behaviour at that other meeting

24     where he was no longer in favour of that other option, and you said that

25     you have a certain assumption that he was more peaceful at the other

Page 20867

 1     meeting because the meeting opened by General Subotic by starting to

 2     question Simo Drljaca as to who had issued orders to him to have the

 3     civilian population moved out of Prijedor.  He started it like a serious

 4     investigation.  You say that this was the second time in your life that

 5     you saw Simo Drljaca.  You knew that he was always courageous, loud, a

 6     show-off, but all of a sudden he calmed down and he was answering the

 7     questions almost in a whisper; right?

 8        A.   Yes.

 9        Q.   Is it correct that Subotic himself spoke less about getting the

10     bodies.  He spoke more about the relocation of the population.  That is

11     on this same page 28.

12        A.   Sorry, could you repeat that question?

13        Q.   Perhaps this is how I'm going to phrase it.  Actually, I'll read

14     it.  You say that he spoke in a whisper and answered questions as if he

15     were confused when he was answering General Subotic's questions.  So

16     maybe that was the reason.  The way in which the meeting was opened

17     resembled an investigation regarding the relocation of the population,

18     then a meeting which was called in order to resolve the problem of how to

19     get the bodies out.  So your impression was that Subotic first wanted to

20     see how come this population transfer occurred; right?

21        A.   Yes.  It's not that that was my impression.  That's the way it

22     was.  During the first part of this meeting, as I said in this transcript

23     that you've been reading from, the meeting was devoted to these issues

24     related to the transfer of the population, a serious investigation in

25     that regard.

Page 20868

 1        Q.   Thank you.  When Drljaca tried to say that someone from the

 2     authorities would have to know about that, Mr. Subotic was present, and

 3     he withdrew, and he could not prove that someone had known about that,

 4     but the regional level that was represented by Zupljanin and the

 5     republican level that was represented by Subotic unequivocally ruled out

 6     any possibility of hushing things up in any way.  They said that

 7     everything had to be done in accordance with the law; right?

 8        A.   I'm sorry.  It's as if you had put two questions.  Could you

 9     please separate the first part from the second part.

10        Q.   Thank you.  You're right, and I'm in such a hurry.  So as for the

11     first questions put by Minister Subotic in terms of how come that

12     happened, he tried to say that someone from the top leadership of the

13     republic knew about that, but then he calmed down because he realized

14     that Subotic was from the top leadership of the republic; right?

15        A.   Perhaps you could put it that way.  During my previous

16     testimonies, I never said, because no one asked me, what the response was

17     of Minister Subotic.  Minister Subotic responded to Simo Drljaca that it

18     was possible -- I mean, when Simo Drljaca said that the top leadership

19     knew about that, Minister Subotic said that it is possible that orders --

20     some kind of orders or instructions came regarding the freedom of

21     movement, primarily the non-Serb population in the territory of the

22     municipality of Prijedor and throughout Republika Srpska; whereas, Simo

23     and the other top people from Prijedor abused that.  They understood it

24     in their own way.  And this population transfer that they carried out was

25     in contravention of the efforts made by the leadership of the republic.

Page 20869

 1     That is what Minister Subotic said briefly, and then Simo Drljaca had no

 2     comment or answer.

 3        Q.   Thank you.  Now, the second part of the question.  They calmed

 4     down, and they accepted that there had to be an investigation, as well as

 5     prosecution and trials, because Zupljanin and Subotic unequivocally said

 6     that they rule out any possibility of hushing things up; right?

 7        A.   Yes, that's right.  Let me just say this once again.  Zupljanin

 8     at the first meeting and Subotic at the second meeting, because the two

 9     of them did not attend meetings at the same time.

10        Q.   Thank you.  Now I'd like to show you some documents that have to

11     do with the investigation, because that is your profession and you were

12     in the area.  65 ter 18438.  Can we have a look at that, please.

13             Let us please have a look at the English version as well, because

14     the telegram is barely legible in Serbian, but the English version will

15     be all right.  So I'd like to read it out to you in English.

16             "[In English] Serbian Republic MUP dispatch number so-and-so 31st

17     of August, 1992.  Banja Luka security service centre, to the chief.

18             "Order.

19             "I hereby order you, in accordance with some regulations to

20     conduct a full investigation regarding the deaths -- deaths of 150

21     Muslims in the territory of municipality Vakuf, Koricanske Stijene.

22             "Inform this ministry of the results of the investigation, and in

23     the event," something illegible, "the said allegations against the

24     perpetrators, initiate legal accountability.

25             "Minister, Mico Stanisic."

Page 20870

 1             [Interpretation] Have you heard or known that Stanisic had

 2     ordered an investigation as well down his own chain in the ministry?

 3        A.   No.  No.  And the reason is the following:  On the 1st of

 4     September, 1992, I was transferred to another job and left Knezevo, went

 5     to Banja Luka, and I see that that was written on the 31st of August.

 6     So, in fact, that was the day when I was no longer chief of the public

 7     security station of Knezevo.

 8        Q.   Thank you.  But you did know that an investigation continued;

 9     right?

10        A.   At my new job I didn't do anything that was related to this

11     particular incident.  However, as an inhabitant of Knezevo, because my

12     wife and child had stayed on in Knezevo, so I came there and like anybody

13     else who lived there I heard certain stories, certain details that may or

14     may not be true.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can it be admitted?

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Exhibit D1881, Your Honours.

19             THE ACCUSED: [Interpretation] Can we take a look at 65 ter 12589.

20     12589.

21             JUDGE KWON:  I'm told that it hasn't been released yet.

22             THE ACCUSED: [Interpretation] Can we then have a look at 5780.

23     That would be the 65 ter number.

24             MR. KARADZIC: [Interpretation]

25        Q.   Do you agree that this is the usual way in which things are done.

Page 20871

 1     Mr. Zupljanin as chief of centre in his telegram quotes the entire order

 2     of Minister Stanisic, and then he adds his own order related to this

 3     order.  It says that you should take written statements about the events

 4     that took place from the policemen that escorted the convoy on the

 5     21st of August and that they should be delivered personally.

 6             Is this the usual way things are done within an investigation?

 7        A.   Yes.  That's the standard way of communicating, and in some other

 8     situations Chief Zupljanin communicated with me in the same way.

 9             In a previous answer when I said I knew nothing about this, I

10     meant that my line of work had nothing to do with it, but to be

11     completely unequivocal, I believe these are authentic documents, and I

12     have no reason to doubt that it all happened as described here.  It's

13     just that I had nothing to do with it in my work.

14             THE ACCUSED: [Interpretation] Can this be admitted, please?

15             JUDGE KWON:  Exhibit D1882.

16             THE REGISTRAR:  It's Exhibit P3763, Your Honours.

17             THE ACCUSED: [Interpretation] Thank you.  Could we now look at --

18     thank you.  Could we look at 65 ter 20522.

19             Was this already exhibited by the Prosecution?  No.

20             MR. KARADZIC: [Interpretation]

21        Q.   In this document, Mr. Drljaca is replying to the chief of centre

22     in Banja Luka regarding the dispatch he had received, and he said he's

23     unable to conduct an investigation because those who were accompanied the

24     convoy are currently on the front line in Han Pijesak.  That's the

25     eastern part of Republika Srpska; right?

Page 20872

 1        A.   Yes.  It's in the eastern part of Republika Srpska.  What is your

 2     question about the dispatch of SJB Prijedor.

 3        Q.   I will.  He's just saying here that he can't provide a list

 4     because the public security station did not organise the convoys.  It

 5     only provided a certain number of policemen as guards at the request of

 6     the army and the Red Cross.  Do you agree with this, or do you think that

 7     they were still afraid of Zupljanin and Subotic?

 8        A.   In this first part of the dispatch, and this is only my opinion,

 9     of course, we see obvious obstruction on the part of Simo Drljaca.  He's

10     pretending these people are on a different planet and completely

11     unavailable to be investigated.  And in this second paragraph, it's

12     obvious that he wants -- and again this is only my opinion because I

13     don't know who organised the convoys.  My job had nothing to do with

14     this.  But I did have occasion to get to know Simo Drljaca better in 1995

15     and 1996 when he worked in the centre in Banja Luka.  This to me is

16     vintage Simo Drljaca, his attempts to distance himself from the whole

17     thing.

18             THE ACCUSED: [Interpretation] Can this be admitted, please?

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1882, Your Honours.

21             MR. KARADZIC: [Interpretation]

22        Q.   In this Ivankovic case, 65 ter 22155, responding to a question by

23     Madam Prosecutor, Mrs. Terzic, when she asked you about the position of

24     Prijedor at this second meeting, you said they were cooperative about the

25     proposal that things should be done properly, and the prosecutor asks

Page 20873

 1     whether you noticed this spirit of co-operation only at the second

 2     meeting that was chaired by General Subotic; is that right?

 3        A.   Yes.

 4        Q.   You confirmed that at the next page, page 23, namely that the

 5     defence minister was very serious in leading the whole operation to make

 6     sure that things be done thoroughly and properly.

 7        A.   Yes.

 8        Q.   Thank you.  You've already mentioned this autonomy of the

 9     municipalities.  Do you agree that more or less all the municipalities

10     liked to behave as if they were a state within a state, not only

11     Prijedor?

12        A.   Yes.  You put it very well, a state within a state.  And you can

13     see the same thing today in peacetime.

14        Q.   In the Stanisic case, on page 14067, I'll read your answer in

15     English, line 15:

16             "[In English] Some of the public security stations, and I mean in

17     particular Prijedor and Simo Drljaca, were disobedient, to put it mildly.

18     Undisciplined.  They did what they wanted in performing their everyday

19     law enforcement tasks."

20             [Interpretation] It's consistent with your knowledge about our

21     typical lack of discipline.

22        A.   Earlier today I have said that Prijedor was amongst the worst in

23     this respect.

24        Q.   Until they broke up with Banja Luka indefinitely and started

25     acting independently.

Page 20874

 1        A.   Yes.  When I say "Prijedor," I mean the public security station

 2     of Prijedor.

 3        Q.   Do you agree that during your tenure and even after you moved to

 4     Banja Luka you did not know the names of the perpetrators, and you spoke

 5     about that in the Ivankovic case 65 ter 22155 on page 27.  You were

 6     asked:

 7              "While you occupied that post there and later in Banja Luka, did

 8     you ever find out the identities of the perpetrators?"

 9             And you answered:

10              "No."

11        A.   Let me say this once again.  The site of the crime did not fall

12     under the purview of the public security station of Knezevo where I was

13     chief.  I was therefore in no way involved in the investigation, and even

14     if the names of the perpetrators had been found, I would not have learnt

15     about them.  When I moved to Banja Luka, I became involved in totally

16     different affairs and did not know anything about this.  So with all due

17     respect to the victims and the families of the victims and the survivors

18     and everyone in any way connected with the Koricanske Stijene incident, I

19     do not know to this day who these people were, regardless of the fact

20     that I testified in the Ivankovic and Zecevic cases, and I wasn't

21     interested, in fact.

22        Q.   Is it a good tradition in law enforcement agencies that people do

23     not display any interest in things that are not directly part of their

24     job?

25        A.   From my point of view, yes, it is, like in any other kind of

Page 20875

 1     work.  My current job has to do with sapping and removing mines in

 2     Sarajevo, and I am not at all interested in the department that deals

 3     with IDs and passports, what numbers they're going to put on papers and

 4     what forms they're going to use.  That is not my job, and that's the same

 5     attitude as I had earlier.

 6             THE ACCUSED: [Interpretation] Can we see 65 ter 16231, please.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Please look at this.  Is this the security services centre?  In

 9     fact, it is written to the security services centre by the public

10     prosecutor's office.  They say they received a criminal report, and now

11     they request that the necessary information be collected on identify --

12     unidentified perpetrators.  It says "NN perpetrators," which in our

13     language means unidentified; right?

14        A.   Yes.

15        Q.   The Prosecutor has already gotten involved here but through the

16     Ministry of the Interior, and he's giving instructions to the MUP as to

17     what the police should do; correct?

18        A.   Yes.

19        Q.   Thank you.

20             THE ACCUSED: [Interpretation] Can this be admitted, please?

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit D1883, Your Honours.

23             THE ACCUSED: [Interpretation] Could we please look at

24     65 ter 18440.

25             MR. KARADZIC: [Interpretation]

Page 20876

 1        Q.   This is the correspondence between the chief of centre in

 2     Banja Luka and the chief of the public security station in Prijedor.

 3     This is a request to provide a detailed written report on the incident at

 4     Koricanske Stijene near Knezevo, and the request specifies what

 5     information is needed, which policemen escorted the convoy, what their

 6     assignment was, to include all the active-duty and reserve policemen

 7     escorting the convoy.  They ask if there was anyone else in the escort

 8     apart from policemen and what the policemen -- what the policemen wrote

 9     in their individual reports.

10             Do you see that Mr. Zupljanin put four very serious tasks before

11     the public security station in Prijedor?  Do you believe that this is

12     perfectly regular?  He does not desist in his demands from Prijedor, and

13     he insists that it's their obligation.

14        A.   Yes, I agree it was completely regular.  He is not giving up.

15     And I see this last line where he says:

16             "I hereby request again that you act on and reply to our

17     dispatches ..."

18             To me it sounds like a warning to the chief in Prijedor.  He

19     makes it plain that the chief in Prijedor had not fulfilled his previous

20     task, and he requests an answer to this dispatch.

21             THE ACCUSED: [Interpretation] Can this be admitted, please.

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  Exhibit D1884; Your Honours.

24             THE ACCUSED: [Interpretation] Can we please look at 65 ter 5783.

25             MR. KARADZIC: [Interpretation]

Page 20877

 1        Q.   This is Drljaca's reply to Chief Zupljanin.  He says he has

 2     already provided an answer, and he refers to some people who are

 3     currently on the front line and have nothing to do with the incident at

 4     Koricanske Stijene.  So something is being done but not much, really.

 5        A.   As far as I can see, he's being evasive.  Only in the first

 6     sentence does he mention the people who perpetrated the crime, and he

 7     confirms that they are near Han Pijesak, on the front line.  The rest of

 8     the dispatch is about people who are not guilty, who had nothing to do

 9     with the convoy.  So he's avoiding the demands made in the previous

10     dispatches.

11             THE ACCUSED: [Interpretation] Can this be admitted, please?

12             JUDGE KWON:  Yes.

13             THE REGISTRAR:  Exhibit D1885, Your Honours.

14             THE ACCUSED: [Interpretation] Could we briefly look at 1D4533,

15     please.

16             MR. KARADZIC: [Interpretation]

17        Q.   Vlado Mandic, one of the deputies to the public prosecutor, is

18     returning the documents accompanying the criminal report so that they

19     could meet the demands made on 21 September 1999, to complete the

20     proceedings.

21        A.   Yes.

22             THE ACCUSED: [Interpretation] Can this be admitted, please?

23             JUDGE KWON:  Yes.

24             THE REGISTRAR:  Exhibit D1886, Your Honours.

25             MR. KARADZIC: [Interpretation]

Page 20878

 1        Q.   Thank you.  Do you agree -- or, rather, did you find out that

 2     those people were tried pursuant to the first batch of investigative

 3     documents dating back to 1992?

 4        A.   I apologise.  I didn't understand your question.  Could you

 5     please repeat it.

 6        Q.   You testified in at least two cases here, one was Ivankovic and

 7     the other was Zecevic.

 8             Do you agree -- or, rather, did you learn that the first or the

 9     initial results of investigation were grounds for criminal prosecution?

10        A.   I can't remember.  I can't answer your question.

11        Q.   Thank you.  Your position was that what had happened was a

12     terrible crime, and you were particularly sensitive to the incident

13     because it happened near Knezevo, although it was not in your

14     municipality.  That's why in the Stanisic case, on page 14046, you said,

15     amongst other things, that -- I will read from line 8:

16             "[In English] I shared with him everything, and I had learned in

17     the field and I also told him what the position was taken by the key

18     people in the Knezevo municipality, the people in the leadership."

19             And then they asked you what position that was:

20             "[In English] And in fact, the whole population, the members of

21     the police force, of the army in the municipality of Knezevo condemned

22     vigorously the attack, and they were appalled by what had happened,

23     particularly because in our municipality there had been no war crimes nor

24     mass or multiple murders and the public saw this indictment -- incident

25     as something that is going to besmirch our municipality."

Page 20879

 1             [Interpretation] That was your position, and you also spoke about

 2     that -- or, rather, is this the case?

 3        A.   Yes, with the correction that we made at the beginning.  I

 4     discussed that with the Prosecutor.  I said that from this answer you may

 5     gain the impression that I believe that that was in our municipality, but

 6     it wasn't.  It was not in Knezevo municipality.  And as for your

 7     question, I can easily answer that with yes.

 8        Q.   In Zecevic case -- on page 1 -- this is document 14547, page 15,

 9     you said that say you can say with certainty that nothing was ever taken

10     over from any organ of the municipality of Knezevo that would facilitate

11     the concealing of the bodies or any such thing.  Is that the case?

12        A.   I said that not only did we not take over anything to facilitate

13     the concealing of the body, but just the contrary was true.  The

14     leadership of the municipality and I as chief of the police station, as

15     well as the general public in the municipality, was shocked, was appalled

16     by that grave crime, and we were among those factors that put pressure on

17     everybody to do things as quickly as possible and to remove the bodies as

18     soon as possible and bury them in a dignified manner.

19        Q.   Thank you.  You said in the Stanisic/Zupljanin case on page 14076

20     that it was a very inaccessible area and that it was very difficult to

21     get to those bodies, that a whole set of equipment was necessary in order

22     to access the site and the bodies; is that correct?

23        A.   Yes.

24        Q.   In that case, you were shown photos.  I don't have the time to

25     show them to you again.  And in those photos, you marked the positions of

Page 20880

 1     the bodies; right?

 2        A.   Yes.

 3        Q.   Can we now look at a photo, P3767.  It wasn't shown, but it was

 4     admitted.  And while we're waiting for it to appear on e-court, I'm going

 5     to remind you what you said on page 14100 in that case when you were

 6     asked to mark, you said:

 7             "Q. [In English] But it's very steep.  Isn't it extreme?

 8             "A. Extremely.

 9             "Q. So we could say that these bodies below marked with the line

10     and number 3 were 50 metres down roughly.  Does that sound right?

11             "A. From the road, yes."

12             [Interpretation] Is this the site of the incident?  Is this the

13     slope which represented a problem when it came to removing the bodies,

14     especially in view of the circumstances?

15        A.   Yes.  The shape of the terrain was certainly one of the

16     restricting factors when it came to taking the bodies out of the gorge.

17     And another limiting factor was this road which is very narrow.  It looks

18     as if it was carved in the rock, which actually is the case.  And this is

19     the only road that connected the Vlasic plateau with Knezevo, and

20     according to my free estimate, in that plateau there were about 10.000

21     people, including civilians and troops.  I heard that when the -- the

22     action was launched to remove the bodies that they had to interrupt their

23     work very often to allow passage for the wounded, the army.  So those

24     were two restricting factors in the effort to remove the bodies from the

25     gorge.

Page 20881

 1        Q.   Thank you.  When you testified in the Ivankovic case, which is

 2     22155 --

 3             JUDGE KWON:  Just -- I was hesitant, but if you are really short

 4     of time for your cross-examination, the previous part, I can say, was

 5     unnecessary, because already they are in evidence, and you can rely on it

 6     at any time at a later stage for your submission, unless you are minded

 7     to supplement the witness's evidence in addition to what is already in

 8     our evidence.

 9             Please bear that in mind in the future, Mr. Karadzic.

10             THE ACCUSED: [Interpretation] Thank you, Excellency.  I simply

11     wanted everybody to see how things looked like in this trial as well, but

12     I will take your words into account.

13             MR. KARADZIC: [Interpretation]

14        Q.   Let's move on.  Is it true that in the Stanisic proofing note,

15     which is 1D4546, you confirm that the Skender Vakuf or Knezevo public

16     security station did not have anything to do with the republican MUP in

17     Pale after the 4th of -- the 4th of April, and that the communication

18     lines were down up until the time when you left for Banja Luka on the 1st

19     of September?

20        A.   Yes.  Let me just explain the term "communications."  That's

21     direct communications.

22        Q.   Thank you.  As for Banja Luka, you could go there?  You could

23     establish telephone communication?

24        A.   We could go there, we could make telephone calls, or we could

25     receive dispatches as well as the indirect dispatches from Sarajevo

Page 20882

 1     through Banja Luka and then to Knezevo.

 2             JUDGE KWON:  Are we talking about the year of 1992?

 3             THE ACCUSED: [Interpretation] It says here from the 4th or 5th

 4     April to the 1st September.  I read that from the proofing note.  The

 5     1st September was the moment when he left to Banja Luka.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   And you probably don't know what happened later, whether Knezevo

 8     had communication lines, direct communication lines, with Pale.  When you

 9     were in Knezevo that was not the case; right?

10        A.   Yes, your interpretation is quite good.

11        Q.   Later on, on page 14028, in the Zupljanin/Stanisic case, you

12     confirm that in 1992 you were not an SDS member.  Although you were among

13     its founders, you said that because of your profession you stopped being

14     a party member of any party for that matter, not only of the SDS; right?

15        A.   Yes.  When I was selected as chief of the public security station

16     in Knezevo, I stopped being an MP in the municipality of Knezevo, a

17     member of the Municipal Board of SDS of Knezevo, and an MP in the

18     Assembly of the autonomous province of Banja Luka.  I froze my

19     membership -- or, rather, I abandoned my membership in the SDS.  I don't

20     know if there were any other parties in existence at the time, and this

21     is still my status.

22        Q.   Thank you.  On page 14097, you said that you had MPs from the SDA

23     and the SDS that -- that you reached certain agreements before the

24     conflict and that you had agreed -- or, rather, you favoured the option

25     of Croats setting up their own municipality in their territory; right?

Page 20883

 1        A.   Yes.  I said that at the beginning of this trial.  We did not

 2     have any sticking points with the Croats, no arguments with the Croats.

 3     The leadership of the HDZ and the leadership of the SDS had very good

 4     relations, and there was also a good relationship between the leadership

 5     of the SDA and the SDS.  For example, my school friend was the president

 6     of the SDA.  Before the beginning of war, we had very good relations, and

 7     we co-operate -- co-operated very well.

 8        Q.   Thank you.  Do you agree that in our midst every newly set up

 9     municipality tries to speed up development and tries to improve the

10     conditions of life?  Wasn't that always a motive for all people to have

11     their place proclaimed a municipality?

12        A.   Yes, that's absolutely correct.  Let me just say in favour of

13     that statement that the municipality of Knezevo was set up sometime in

14     the 1960s, and there was a legal limit for a municipality to have a

15     certain number of inhabitants.  Since that condition was not met, the

16     part with the Croatian population was taken from Jajce although it did

17     not belong to Knezevo, and Croats actually did not benefit from that

18     situation, and if they had become independent, I'm sure they would have

19     moved forward much faster.

20        Q.   Thank you.  In the Ivankovic case, which is

21     65 ter 2215 [as interpreted] on page 6, you spoke about the existence of

22     the Council for National Defence, which was sometimes also referred to as

23     the Crisis Staff, but you also confirmed that the counsel for national

24     defence was a permanent body whose members -- were its members ex

25     officio; is that correct?

Page 20884

 1        A.   Yes.  The Council for National Defence before the war was

 2     provided for by the law.  Every municipality in the former SFRY had it.

 3     At the same time there was a committee on civilian protection and

 4     self-defence which was under the dominant influence of the League

 5     Communists and social and political organisations.

 6             After the first multi-elections in Bosnia-Herzegovina, including

 7     Knezevo, that committee lost its influence and importance and it was

 8     abolished, and what we mind was the Council for National Defence which

 9     continued to function.  Since in Knezevo we did not experience any crisis

10     or inter-ethnic conflicts there, there was no power struggle.

11             When the war broke out, as far as I knew we did not have an

12     officially established Crisis Staff.  I don't know if people called the

13     Council for National Defence a Crisis Staff.  Maybe it was fashionable

14     because that's what happened in other -- in other areas.

15             In my view, it was the Council for National Defence that

16     continued to work throughout the war.

17        Q.   Do you agree that in your municipality there was no reason for

18     fear or concern among the Muslim population; however, the vicinity of the

19     front line, the events in Travnik, Vecici, and Jajce, and in the

20     neighbouring municipalities did cause some concern, that they

21     communicated with us, and that they asked you to allow them to leave?

22        A.   I would put it this way:  Fear, concern were present among

23     everybody in Bosnia-Herzegovina, including the population of Knezevo, and

24     certainly there was fear and concern among the Muslim population, and you

25     put it very well the reason for all fear and concern was not just one.

Page 20885

 1     There were several reasons for fear and concern.  One of them was the

 2     general situation.  A war broke out in the neighbouring municipality

 3     of -- of Jajce and Kotor Varos and along the border between the

 4     municipalities of Knezevo and Travnik.  Muslims were a minority, a huge

 5     minority, and from my point of view I would say that they subjectively

 6     feelled -- felt fear and concern.  How justified that was and whether

 7     that fear and concern were justified, I'm sure that they could not think

 8     that the official authorities in Knezevo municipality would do them harm.

 9     It was just the matter of war and war-related developments that must have

10     caused fear and concern among the Muslim population.

11        Q.   Thank you.  The passing of soldiers, their return from the front

12     line, was that also an element that was feared by both Serbs and Muslims?

13     I'm talking about transit of armed people through your town.

14        A.   Yes.  That was one of the elements, and as well as the arrival of

15     various paramilitary units and both Serbs and Muslims feared them.

16     Muslims more than the rest of the population, certainly.  And, you know,

17     war is an illness in society according to a definition.  There were a lot

18     of renegade -- renegades, looters, some old debts surfaced, and all of

19     that resulted in fear and concern among the people.

20        Q.   Thank you.  In the Stanisic and Zupljanin case, on pages 14128 to

21     14130, you stated that in the course of 1992, one killing happened in

22     late 1991, and there were five or six killings or murders in 1992.  Of

23     the victims, five were Muslims, one was Croat, and one was a Serb.  Is

24     that correct?

25        A.   Yes.

Page 20886

 1        Q.   Thank you.  Is it correct that you had a lot of problems because

 2     you had very few policemen?  And let me add that sometimes you had to

 3     place your policemen under the command of units in the area when there

 4     were attacks.

 5        A.   Yes.

 6        Q.   Thank you.  Is it correct that in your public security station

 7     there were Muslim employees as well?

 8        A.   Yes.  Yes.  Up until some date in April 1992, Muslims and Croats

 9     worked there.  They refused to sign that solemn declaration that was sent

10     to us from the security centre in Banja Luka.

11             Croats withdrew to their own territory.  They did not come to

12     work on the following day, whereas the Muslim employees quite fairly and

13     correctly asked me to leave and go to Travnik properly; that is to say,

14     with weapons, vehicles, et cetera, to see that if it suits them, they

15     could join the police in Travnik, and if not, they'd go back.  I allowed

16     them to do that.

17             They returned on the next day.  They were all beaten up.  Their

18     clothes were torn.  They told me that members of the HVO had attacked

19     them, disarmed them, beaten them up, and then they asked me whether they

20     could go to Jajce the same way with these vehicles, weapons, et cetera.

21     I allowed them to do that, and they went to Jajce and did not return.

22     One lady who's an ethnic Muslim stayed on at the public security station.

23        Q.   Thank you.  Did the Croats set up their own station in that

24     concentration that has now become their municipality?  Did they go there,

25     or did they go to Jajce?

Page 20887

 1        A.   That I don't know.  Both are plausible.

 2             THE ACCUSED: [Interpretation] 1D4543.  Could we have that,

 3     please.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   So this is your report.  This was in February.  This is a report

 6     about the work, who worked for you, and members of the reserve force, and

 7     you report that they worked 27 days that month.  This is your telegram,

 8     isn't it?

 9        A.   Yes.

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

11             MR. KARADZIC: [Interpretation]

12        Q.   Can you help us with this:  Number 4, is that Nedzad Krkic?  Is

13     he a Muslim?

14        A.   Yes.

15        Q.   Thank you.  I don't have time now for us to see what the ethnic

16     backgrounds of the others is.

17             THE ACCUSED: [Interpretation] Can this be admitted?  Actually,

18     can we have the last page.

19             MR. KARADZIC: [Interpretation]

20        Q.   You had a total of 23 policemen, didn't you?

21        A.   Approximately, active-duty policemen, and in addition to that

22     there was the reserve force.

23        Q.   Thank you.

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

25             JUDGE KWON:  Yes.

Page 20888

 1             THE REGISTRAR:  Exhibit D1887, Your Honours.

 2             THE ACCUSED: [Interpretation] 1D4544.  Could we have a look at

 3     that, please.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Can we see here that an order was given to have payments made to

 6     these four persons, and is the fourth person on this list Nihada Topal,

 7     and is that person of Muslim ethnicity?

 8        A.   Yes.

 9             THE ACCUSED: [Interpretation] I don't know whether this has been

10     uploaded, this part, 12589, 65 ter 12589.

11        Q.   While we're having this checked, let me ask you is it correct --

12     I saw the oath or rather solemn declarations that were signed by Serbs,

13     too.  Is it correct that after the Krajina -- MUP and Krajina were

14     established, the Serbs were also duty-bound to sign a solemn declaration

15     stating that they would act in accordance with the laws and regulations

16     of the ARK Krajina?  So it wasn't only the Muslims and Croats.

17        A.   Absolutely correct.  A solemn declaration would be signed, an

18     oath, and I think that also the emblems were changed.  Until then there

19     was a five-pointed star, and then that was replaced by a flag which is in

20     force to this day in our part of the world in Republika Srpska.  Also,

21     they were different uniforms.  Everything was the same for all, and I

22     claim with full responsibility that I signed such an oath as did all the

23     Serbs who worked in my public security station.

24        Q.   Thank you.  Do you agree that in our effort to bring about a

25     reconciliation between the Partisans and Chetniks we opted for a flag

Page 20889

 1     rather than a cockade or a five-pointed star or other ideological

 2     emblems?

 3        A.   I agree.  I think that you are the most deserving person in that

 4     respect with all the efforts you made to overcome this rift between the

 5     Partisans and Chetniks among the Serb people, and I think that you were

 6     quite successful in that.

 7        Q.   Thank you.  Did you attend any meetings that I attended?  I did

 8     go to Knezevo -- actually, anywhere.  Did you attend any such meetings

 9     where I was too?

10        A.   Not in Knezevo.  Two or three times I was in the area of Pale.

11     That was towards the end of 1990.  And once in Banja Luka in the

12     beginning of 1991; that is to say, while I was in these political

13     structures of the SDS.

14        Q.   May I ask you to say whether you could notice anything extremist

15     in my views or anything that would lead to future conflicts?

16        A.   Absolutely nothing.  As such, you were a target, if I can put it

17     that way, of the verbal attacks of these extremist representatives of

18     both the Partisans and Chetniks.  That is to say neither of them were

19     satisfied with you.  There was this ultra-left extremism and ultra-right

20     extremism, if I can put it that way.

21        Q.   Thank you.  Do you agree that my position was to take a soft

22     stance vis-a-vis the other ethnic communities and that nothing should be

23     done that would make then apprehensive in any way?

24        A.   While I was a member of these structures and while I attended

25     these meetings, it's not only that you insisted on this soft stance, as

Page 20890

 1     you called it, but you also asked us to have full co-operation with the

 2     representatives of the other peoples before the first multi-party

 3     elections in Bosnia-Herzegovina, and you also insisted on that after the

 4     multi-party elections when the power-sharing agreements were being worked

 5     out.  You said that we should not keep all power in our hands where we

 6     were a majority.  You said that we should involve the minorities as well,

 7     because it was stated that according to this purported agreement with the

 8     other two national parties - I never saw this agreement - they would also

 9     give Serbs the same kind of opportunities where the Serbs were a

10     minority.

11        Q.   Thank you.

12        A.   Sorry, may I just ask you to put once again the other part of

13     your question because I seem to have forgotten it.

14        Q.   Did I do anything that would encourage any kind of future

15     conflicts?

16        A.   No.  It was the other way around.  Again, I want to say that I'm

17     speaking about the time when I attended various meetings.  People were

18     asking you specifically to have Serbs armed because the Croats and the

19     Muslim were is doing that as well.  Primarily the Croats were doing that.

20     Then also in Banja Luka there were calls for the Banja Luka Krajina to

21     proclaim some kind of union with the Serb Krajina or those autonomous

22     regions in Croatia.  You were absolutely opposed to that, saying that the

23     Socialist Federal Republic of Yugoslavia is the best framework for the

24     Serb people, that there is a state there already, that there is the JNA

25     which is the guarantor for the Serb people so that they could live in one

Page 20891

 1     state.

 2             If we Serbs do anything wrong, we would be the first to be

 3     blamed, so you insisted that we should be tolerant, that there was no

 4     need for arming, and that that simply could not be done.

 5        Q.   Let me end on this note:  Do you agree that it wasn't only that

 6     Prijedor tried to get out of Banja Luka's sphere of influence, but also

 7     has there not been this rivalry between Banja Luka and Sarajevo for

 8     decades regardless of who was in power?  Did Banja Luka always want to be

 9     independent from Sarajevo just like Prijedor always wanted to be

10     independent from Banja Luka?

11        A.   I'm sorry, you mentioned Sarajevo, Banja Luka, Prijedor.  Now,

12     what did you actually mean?

13        Q.   Let me try to put it simply.  Even way back from the times of

14     socialism, is there -- is there this strong rivalry between Sarajevo and

15     Banja Luka regardless of who's in power, Communists, Serbs, Muslims,

16     whoever?  Was there always this tendency in Banja Luka to be more

17     independent from Sarajevo?

18        A.   Yes.  That was there during the times of the socialist system,

19     and also it happened when the government had their seat in Sarajevo.  And

20     I know that full will that that is the case to this day because I work in

21     Sarajevo and so I know.

22        Q.   Thank you.

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

24             JUDGE KWON:  Yes.

25             THE REGISTRAR:  Exhibit D1888, Your Honours.

Page 20892

 1             THE ACCUSED: [Interpretation] I thank you, Mr. Krejic, not only

 2     for your testimony, but I would also like to thank you for having carried

 3     out your duty in a way that can only be to your credit and to the credit

 4     of Republika Srpska.  Thank you.

 5             THE WITNESS: [Interpretation] Thank you for having stated that.

 6             THE ACCUSED: [Interpretation] Excellencies, I have finished.

 7             JUDGE KWON:  Thank you.

 8             Yes, Ms. Sutherland.  How long will your re-examination take?

 9             MS. SUTHERLAND:  Hopefully not more than 10 minutes.

10             JUDGE KWON:  Then we'll do that now.  Please proceed.

11                           Re-examination by Ms. Sutherland:

12        Q.   Mr. Krejic, earlier today at pages 25 and 26, Mr. Karadzic asked

13     you a question about --

14             "It seems to follow that the residents of Prijedor were rather

15     independent even from Banja Luka, which was no more than 50 kilometres

16     away."

17             And you answered that you --

18             "Indeed, when we had meetings before the war and during the war,

19     Chief Zupljanin held these meetings at the collegium attended by all the

20     chiefs of the SJBs in the area of Banja Luka.  And that at these meetings

21     we gained a very clear impression.  In fact, it was perfectly clear that

22     he had next to no influence at all on the leading people from the

23     SJB Prijedor --"

24             THE INTERPRETER:  Please slow down while reading.  Thank you.

25             MS. SUTHERLAND:

Page 20893

 1        Q.   "... and I mean first and foremost Simo Drljaca."

 2             Do you recall that?

 3             JUDGE KWON:  I'm not sure your question was fully translated.

 4             Do you remember that part, Mr. Krejic?

 5             MS. SUTHERLAND:

 6        Q.   Do you remember the question and the answer that I just read to

 7     you, that -- that occurred earlier in today's proceeding?

 8        A.   I do remember.  However, I don't think that it has been presented

 9     to me 100 per cent accurately.  You said something like the residents of

10     Prijedor being independent from Banja Luka.  And I also don't think that

11     I said -- I also did not say that Chief Zupljanin didn't have any

12     influence whatsoever in Prijedor.  I'm sure.  You have confused me now,

13     actually.

14        Q.   Okay.  I will read again very slowly the question and the answer.

15     The question was:

16             "It seems to follow from that that the residents of Prijedor were

17     rather independent even from Banja Luka, which was no more than 50

18     kilometres away."

19             Your answer was:

20             "I will limit my answer only to my line of work, that is to say

21     public security.  Indeed, when we had meetings before the war and during

22     the war, Chief Zupljanin held these meetings at the collegium, attended

23     by chiefs the public security centres in the area of Banja Luka and at

24     these meetings we gained a very clear impression.  In fact, it was

25     perfectly clear that he had no next to no influence at all on the leading

Page 20894

 1     people from the public security station of Prijedor, and I mean, first

 2     and foremost, Simo Drljaca."

 3             And then you go on to say:

 4             "And other public security stations, Novi Grad and

 5     Bosanska Dubica."

 6             THE ACCUSED: [Interpretation] May I be of assistance?  The

 7     interpretation said "residents of Prijedor," whereas I meant "policemen

 8     from Prijedor."  It's probably my fault.  I did not mean Prijedorcani,

 9     people of Prijedor in general terms.  I meant Prijedorcani as in

10     policemen from Prijedor.  However, Mr. Krejic already corrected that

11     through his answer because he restricted his answer to public security

12     only.

13             MS. SUTHERLAND:  Exactly.

14        Q.   Now, you were then further -- you recall that question and

15     answer?

16        A.   I do recall that, and now you're question was more specific.  Not

17     only what Mr. Karadzic explained just now but also the first time I was

18     told that I had said that the public security centre of Banja Luka and

19     Chief Zupljanin did not have any influence whatsoever over the public

20     security station in Prijedor; whereas, the second time you said it

21     correctly, that they had a small influence only, and there is a

22     distinction between the two.

23        Q.   So, you -- or Mr. Karadzic then took you to an answer that you

24     had given in the Ivankovic trial when he was referring to asking you

25     questions about the second meeting with -- on the 30th of August, the one

Page 20895

 1     that General Subotic attended.  And there in the transcript it says --

 2     when he was quoting the transcript that you testified that:

 3             "That was the second time in my life that I saw Simo Drljaca.

 4     The first time I saw him was at that first meeting.  But later I came to

 5     know him a little better."

 6             But how do you reconcile that with the answer here that you gave

 7     here that you -- indeed, when there were meetings before the war and

 8     during the war Zupljanin held these meetings at the collegium with all

 9     the SJBs, and then you go on to say that he had no influence over

10     Prijedor, in particular, Drljaca?  Or little -- next to no influence.

11        A.   Well, precisely.  Just having meetings held does not mean that

12     someone has influence over someone else.  The fact that Chief Zupljanin

13     held meetings does not mean that he held all the strings in his own

14     hands, namely that the people from the public security station in

15     Prijedor and primarily Chief Simo Drljaca listened to him and did his

16     work in accordance with the law on regulations as one should.

17        Q.   You said at transcript page 36 today that you only got to know

18     Drljaca better in 1995/1996, and given that the first time you saw

19     Drljaca was in late August 1992, therefore you had not met him before,

20     during the earlier months, let's say between April and beginning of

21     August, 1992.  I just wanted to know how we are to reconcile the fact

22     that you now say that Zupljanin had no influence over Drljaca.

23        A.   I would like to correct a mistake here, a mistake of my own.  To

24     err is human, so I should admit my own mistakes.  During Ivankovic case,

25     I think, or another case, I made a mistake.  The lawyers put that

Page 20896

 1     question to me and I think that I made a mistake when I said that I first

 2     saw Simo at that first meeting in August, because it is a fact that I saw

 3     him before that as well, not many times.  Perhaps two or three times.

 4     Not more than that.  They drew my attention to that there and over there

 5     I did correct that.

 6             Now, before Simo Drljaca became chief, that is to say before the

 7     war, more frequent meeting were held, and at that time Simo Drljaca was

 8     not the chief in Prijedor.  It was another man, a Muslim.  I remember his

 9     first name was Hasan.  I cannot remember his last name.  That is to say

10     that I admit that it was my mistake, but it is totally unintentional.

11     When I said that I first met Simo on that first meeting on the 23rd in

12     Banja Luka, it is possible --

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

14     witnesses.  Could all microphones please be switched off.  Thank you.

15             JUDGE KWON:  Mr. Krejic, the interpreters were not able to catch

16     the last part of your answer when you said "it is possible."

17             THE WITNESS: [Interpretation] It is quite possible that I met

18     Simo Drljaca some other time as well, not only during that first meeting

19     that had to do with what had happened in Koricanske Stijene.  That is my

20     mistake, an unintentional mistake.  That was indicated at the hearing in

21     the court in Sarajevo, and I admitted that mistake there.

22             MS. SUTHERLAND:

23        Q.   Well, what other time did you meet with Simo Drljaca between

24     April and early August 1992?

25        A.   Up until the beginning of the war, the chief of the security

Page 20897

 1     services centre held meetings very often, joint meetings, with all the

 2     chiefs of the public security stations from the region.  All the

 3     chiefs -- or, rather, out of the 16 of us, 14 were Serbs and two were

 4     Muslims, one from Prijedor and the other one from Jajce.  When the war

 5     started, Simo Drljaca was appointed chief of the public security station

 6     in Prijedor, replacing this man whose first name was Hasan and whose last

 7     name I do not remember.

 8             When the war started, these meetings were held less frequently

 9     because of the crisis, because of the state of war.  It is possible that

10     from May until August I saw Simo Drljaca perhaps once or twice or three

11     times maximum.

12        Q.   I want to take you now to another point.

13             THE ACCUSED: [Interpretation] May I assist with the last name of

14     this man Hasan?  I can just ask if it's the same Hasan.

15             JUDGE KWON:  I'm not sure whether it's necessary.  Let's proceed.

16             MS. SUTHERLAND:

17        Q.   At page 32 of today's transcript, when we were discussing -- when

18     you were discussing the second meeting on the 30th of August, 1992, where

19     Minister Subotic attended, and -- and Mr. Karadzic put to you, and I'll

20     read the question:

21             "Thank you.  You're right, and I'm in such a hurry.  So as for

22     the first questions put by Minister Subotic in terms of how come that

23     happened, he tried to say that someone from the top leadership of the

24     republic knew about that, and then he calmed down because he realized

25     that Subotic was from the top leadership of the republic; right?"

Page 20898

 1             This was in relation to the earlier question put when

 2     Mr. Karadzic asked you when someone from the authorities -- when Drljaca

 3     tried to say that someone from the authorities would have to know about

 4     that.  And in your -- your answer to Mr. Karadzic's question that I just

 5     put to you was:

 6             "Perhaps you could put it in that way.  During my previous

 7     testimonies I never said, because no one asked me, what the response

 8     of -- was of Minister Subotic.  Minister Subotic responded to

 9     Simo Drljaca that it was possible.  I mean, when -- when Simo Drljaca

10     said that the top leadership knew about that, Minister Subotic said that

11     it was possible that orders, some kind of orders or instructions came

12     regarding the freedom of movement, primarily the non-Serb population in

13     the territory of the municipality of Prijedor and throughout Republika

14     Srpska; whereas, Simo and the other top people from Prijedor abused that.

15     They understood it in their own way.  And this population transfer that

16     they carried out was in contravention of the efforts made by the

17     leadership of the republic.  That is what Minister Subotic said briefly,

18     and then Simo Drljaca had no comment or answer."

19             Do you remember that question and answer from earlier today?

20        A.   Your question is too long.  I've lost the thread, and I'm not

21     even sure when you are quoting me and when you are putting a question or

22     making a suggestion.  If you want me to answer properly, could you

23     simplify the question.

24        Q.   Mr. Krejic, I read you word or word your answer.  Do you

25     recall -- and I'll read it again.  This is what you said:

Page 20899

 1              "During my previous testimonies, I never said, because no one

 2     asked me, what the response was of Minister Subotic.  Minister Subotic

 3     responded to Simo Drljaca that it was possible, I mean, when -- when

 4     Simo Drljaca said that the top leadership knew about that,

 5     Minister Subotic said that it -- it is possible that orders, some kind of

 6     orders or instructions came regarding the freedom of movement, primarily

 7     the non-Serb population in the territory of the municipality of Prijedor

 8     and throughout Republika Srpska; whereas, Simo and the other top people

 9     from Prijedor abused that."

10             Do you recall saying that answer earlier today?

11        A.   That is better phrased now.  I recall that.

12             MS. SUTHERLAND:  Could I have -- I'm not sure of the 65 ter

13     number.  It's the Zecevic transcript in Mr. Krejic's testimony in the

14     Zecevic case in Bosnia.

15             JUDGE KWON:  1D4547.

16             MS. SUTHERLAND:  Thank you, Your Honour.

17             JUDGE KWON:  If you have more than five minutes, we would better

18     have a break.

19             MS. SUTHERLAND:  No, Your Honour.  I don't wish to take more than

20     five minutes.  If we could go to page 17 in the English, and it's page 20

21     in the B/C/S.

22             JUDGE KWON:  I was told that there's no English for this.

23             MS. SUTHERLAND:  Oh.  Your Honour, it -- I have -- I have an

24     English translation here, so we do have it.  I wonder if Mr. Reid --

25             JUDGE KWON:  Shall we put it on the ELMO?

Page 20900

 1             MS. SUTHERLAND:  I'm afraid I've marked my copy.

 2             JUDGE KWON:  If it is a short passage --

 3             MS. SUTHERLAND:  It's a short passage.

 4             JUDGE KWON:  Then we can proceed --

 5             MS. SUTHERLAND:  I can possibly --

 6             JUDGE KWON:  -- because the interpreter can see the B/C/S

 7     version.  Yes.

 8             MS. SUTHERLAND:

 9        Q.   Mr. Subotic -- Mr. Subotic.  Mr. Krejic, do you recall saying

10     this in the Zecevic case when you were asked by the Prosecutor about --

11     about this meeting, and then you said:

12              "Well, Mr. Subotic went further than that.  He first addressed

13     Simo Drljaca directly by asking something to the effect of who allowed

14     them to move the population from Prijedor at all, and that question was

15     posed in a very stern form.  I didn't know Simo very well but got to know

16     him better later.  This was the first time I saw him answer mildly.  He

17     was confused and didn't really have a proper answer, and finally Simo

18     said, 'Why are you asking me this when you know better than I do who made

19     the deal and how it was made?'  Minister Subotic ignored that and asked

20     for information."

21             And your answer goes on.  Do you recall stating that in the

22     Zecevic trial?

23        A.   Yes, I remember I stated that, but I added something that nobody

24     had asked me, namely the answer of Minister Subotic, who said a few words

25     precisely about that freedom of movement for the civilians.

Page 20901

 1        Q.   You mentioned that today, that -- you said that nobody had asked

 2     you previously about what Mr. Subotic said after Simo Drljaca said, "Why

 3     are you asking me this when you know better than I do who made the deal

 4     and how it was made?"  And today you said, "Well, nobody asked me before.

 5     Now I'm telling you what Mr. Subotic said, and he talked about the

 6     freedom of movement."  I just read you a paragraph from the Zecevic trial

 7     where after exactly Simo said that, you testified under oath that

 8     Minister Subotic ignored that, and I'm just wondering how we reconcile

 9     those answers.

10        A.   He did not ask any further questions about the organisation of

11     the movement of the population and convoys, et cetera.  He only briefly

12     mentioned some orders that the top leadership of Republika Srpska sent

13     down to municipal authorities and lower-level authorities about the

14     freedom of movement.  It was not very articulate, but he did speak about

15     that, and he didn't say much.  He continued to talk mostly about

16     Koricanske Stijene.

17        Q.   And finally, you were taken to a number of documents involving

18     the investigation and even documents showing involvement of the

19     prosecutor in -- in the event which occurred at Koricanske Stijene on the

20     21st of August, 1992.  Was anyone prosecuted for this crime to your

21     knowledge between 1992 and 1995, the end of 1995, or at all before the

22     year 2000?

23        A.   The answer to your question is already contained in one of the

24     answers I have given to Mr. Karadzic earlier, namely that as of 1st

25     September, I worked in a job that had nothing, but absolutely nothing to

Page 20902

 1     do with this case and cases like this, and I wasn't interested.  I had a

 2     different kind of work.  I was engaged in different assignments.  And of

 3     course I heard a few things like any other resident of Banja Luka or

 4     Knezevo could at the time, but my job did nothing --

 5        Q.   Mr. Krejic, I'm sorry to interrupt you, but your answer is either

 6     you know or you don't know whether anyone's been prosecuted?

 7             JUDGE MORRISON:  Well, Ms. Sutherland, I don't think you can put

 8     that observation in re-examination.  You're trying to lead the witness

 9     into a limitation.

10             MS. SUTHERLAND:  Very well, Your Honour.  I was simply asking if

11     he knew to his knowledge whether anyone had been prosecuted, but I

12     will -- I will leave it.

13             I have no further questions for the witness.

14             JUDGE KWON:  Thank you, Ms. Sutherland.

15             Thank you, Mr. Krejic.  That concludes your evidence.  On behalf

16     of my colleagues and the Tribunal I would like to thank you for coming to

17     The Hague.  Now you're free to go, but we'll rise all together.

18             We'll take a break for half an hour and resume at 1.00.

19             Did you have anything, Mr. Tieger?

20             MR. TIEGER:  No, Mr. President.  Thank you.

21                           [The witness withdrew]

22                           --- Recess taken at 12.28 p.m.

23                           --- On resuming at 1.01 p.m.

24             JUDGE KWON:  Before we proceed to hear the next witness,

25     witness's evidence, there's an administrative matter to deal with in

Page 20903

 1     private session briefly.  Shall the Chamber move into private session.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 20904

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11  Page 20904 redacted. Private session.

12

13

14

15

16

17

18

19

20

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22

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25

Page 20905

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7                           [Open session]

 8             JUDGE KWON:  Yes, while we are bringing in the witness -- yes

 9     Mr. Robinson.

10             MR. ROBINSON:  Yes, Mr. President.  We received information that

11     the Chamber would be sitting tomorrow morning to complete the testimony

12     of this witness and --

13             JUDGE KWON:  To accommodate the witness's request.

14             MR. ROBINSON:  Yes, and we don't have any problem with that, but

15     I just wanted to let you know that I, myself, will not be available

16     because of having to travel to Croatia and Bosnia, and I apologise for

17     that but we'll be ready to proceed.

18             JUDGE KWON:  Thank you for your understanding and co-operation.

19             In principle we will be sitting in Courtroom III tomorrow, but if

20     there is a change, i.e., that there is not sitting for Haradinaj

21     tomorrow, then we'll be sitting in Courtroom I.

22             MR. ROBINSON:  And what time are we starting?

23             JUDGE KWON:  9.00.  And I very much appreciate Mr. Harvey's

24     understanding.

25                           [The witness entered court]

Page 20906

 1             JUDGE KWON:  Would the witness kindly make the solemn

 2     declaration, please.

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

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

 5                           WITNESS:  MILAN KOMLJENOVIC

 6                           [Witness answered through interpreter]

 7             JUDGE KWON:  Thank you, Mr. Komljenovic.  Would you make yourself

 8     comfortable.

 9             Yes, Ms. Sutherland.

10                           Examination by Ms. Sutherland:

11        Q.   Sir, could you please state your full name?

12        A.   Milan Komljenovic.

13        Q.   As we discussed, part of your evidence in this case will be

14     submitted in writing.  We first need to deal with the formalities in

15     relation to that submission.  You provided a statement to representatives

16     of the Office of the Prosecutor of the ICTY on the 7th of December, 2009,

17     and you also testified before the Bosnia and Herzegovina state court in

18     the Prosecutor v. Ivankovic et al. Case on the 31st of March, 2009; is

19     that right?

20        A.   Yes.

21        Q.   A statement has been prepared which contains portions of your

22     ICTY statement and your BiH testimony.

23             MS. SUTHERLAND:  If 65 ter number 90291 could be brought on the

24     screen, please.

25        Q.   You recently had an opportunity to review this statement with the

Page 20907

 1     assistance of an interpreter; is that correct?

 2        A.   Yes.

 3        Q.   And during that review, paragraphs were -- we'll wait for the --

 4     is -- in front of you on the computer screen is this the amalgamated

 5     witness statement - if we could scroll down the page - that you reviewed

 6     on Friday?

 7        A.   Yes.

 8        Q.   And if we could turn to page 1.  The next page.  Paragraphs 1 to

 9     5 were read to you in a language you understood; correct?  Because

10     these -- if I -- if I may continue, because these paragraphs were taken

11     from your ICTY statement from the 7th of December, 2009, and they were in

12     the English language; is that right?

13        A.   Yes.

14        Q.   If we could turn to the next page, please.  Page 3 of the

15     statement.  And then, Mr. Komljenovic, with respect to paragraphs 6 to

16     24, that is the remainder of the statement, you reviewed these paragraphs

17     by going through the B/C/S version, what is commonly referred to as B/C/S

18     version, that is the -- the Serbian version of your BiH testimony; is

19     that correct?

20        A.   Yes.

21        Q.   In relation to the first five paragraphs which were read back to

22     you, you wished to make two clarifications and two corrections in

23     paragraph 4.  The two clarifications are contained in footnote 6 and 7,

24     and that was in relation to meetings and also in relation to a dispatch,

25     and then the two corrections that you wish to make, also in paragraph 4,

Page 20908

 1     related to --

 2             JUDGE KWON:  The previous page.

 3             MS. SUTHERLAND:  No, Your Honour.  Well, the two corrections are

 4     on this page, Your Honour, page 3.

 5             JUDGE KWON:  Yes.

 6             MS. SUTHERLAND:

 7        Q.   The two corrections that you wish to make related to the word

 8     "conclusion" and also in relation to "make accessible," which was in

 9     relation to the bodies from the massacre; is that correct?  And -- and

10     that is contained in footnotes 7 and 8, the two corrections.

11        A.   Yes.  The correction refers to the term "remove."  I had an

12     objection, because the term was not used at the meeting.  It was about

13     allowing access to the bodies of the dead persons.  That's one thing, and

14     we agree that term should be changed and also that the term "order"

15     should be replaced by "conclusions," because it was more conclusions than

16     an order by Mr. Subotic.

17        Q.   Then also during the review, there were two matters which were

18     found to be incorrect in the English translation, and that was in

19     relation to paragraph 7.  The word as it stands now -- it's the fifth

20     line from the bottom of paragraph 7, which is on page 5 of the statement.

21     The sentence reads:

22             "So it is possible that --"

23             It currently reads in this version in front of you:

24             "So it is possible that the local chief knew, had the

25     information, but I did not have the information."

Page 20909

 1             And the word "police" should be inserted between "local" and

 2     "chief"; is that right?  So it's the "local police chief"?

 3        A.   Yes.

 4        Q.   And then in paragraph 9, the fifth line, the word "mobilised" was

 5     to be corrected, and this is simply -- I'll read the -- the -- the answer

 6     that you gave in the -- the state court:

 7             "Yes, of course.  I found out about the event that took place on

 8     the 21st, that was simply an event which had its impact and we were all

 9     mobilised when that happened."

10             And the word "mobilised" should be "got up on our feet."  Do you

11     agree with that?

12        A.   Well, it was not really an adequate term.  I -- I believe that

13     your version "to get up on our feet" was better.  We were all in a state

14     of shock, but we were not mobilised.

15        Q.   That's correct.  And the interpreter that was reviewing this

16     statement with you went back to the B/C/S version of your transcript and

17     found that, in fact, you had said "got up on our feet."  Do you recall

18     that?

19        A.   I don't remember the interpretation in such great detail, but,

20     yes, that could be an adequate expression.

21        Q.   Now, I just wanted to take you to paragraph 12.  It's on page 9,

22     and it was dealing with -- paragraph 12 was dealing with whose area of

23     responsibility it was, who -- and -- and you said it was the area of

24     responsibility of the 22nd Brigade.  And then you mention a colonel, and

25     in the -- in the B/C/S transcript, the Bosnian transcript.  And this is

Page 20910

 1     65 ter number 22145.  At page 66 of that transcript, it actually spells

 2     Mr. Peulic's name Peuvic, P-e-u-v-i-c in the transcript, but in fact -

 3     correct me if I am wrong - you're actually referring to Colonel Peulic

 4     there at that point.

 5        A.   Yes.  Yes.

 6        Q.   And in paragraph 13, this is on page 10 of your amalgamated

 7     statement, when you were talking about the meeting on the 13th of August,

 8     and this is the fifth line down, you were mentioning some names of people

 9     who were there, and in the Bosnian transcript it actually says

10     "Djuro Gulic," and again correct me if I am wrong, it's supposed -- it

11     was supposed to read "Djuro Bulic"?

12        A.   Djuro Bulic is the name, Djuro Bulic.

13        Q.   Now, Mr. Komljenovic, you then signed the amalgamated statement.

14     Can you confirm to the Court today that the amalgamated statement with

15     your clarifications and corrections accurately reflects your evidence?

16        A.   Yes, certainly, in -- in one way or another.

17        Q.   If you were asked today about the matters contained in your

18     amalgamated statement, would you provide the same information to the

19     Trial Chamber?

20        A.   I wouldn't change anything.  More or less this is all I have to

21     say.

22        Q.   That's -- if you couldn't formulate everything in exactly the

23     same words, what you're saying is the essence would be the same.

24        A.   Obviously things could be worded differently.  Things could be

25     interpreted differently, but in essence, my statement would still remain

Page 20911

 1     the same.

 2             MS. SUTHERLAND:  Your Honour, I tender 65 ter number 90291.

 3             JUDGE KWON:  Yes.  That will be admitted.

 4             THE REGISTRAR:  As Exhibit P3768, Your Honours.

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

 6     summary of the witness's written evidence.

 7             Mr. Komljenovic is of Serb ethnicity.  In 1992, he was the

 8     president of the Skender Vakuf Municipal Assembly and president of the

 9     Skender Vakuf Crisis Staff.  The Skender Vakuf municipality changed its

10     name to the Knezevo municipality.

11             The witness described convoys of non-Serb inhabitants from

12     municipalities within the Autonomous Region of Krajina, including

13     Sanski Most, Kljuc, and Prijedor, being transported through the

14     Skender Vakuf/Knezevo municipality towards Travnik in the summer of 1992.

15     He testified -- he describes the aftermath of the Koricanske Stijene

16     massacre on the 21st of August, 1992, which is Schedule B, 15.6.

17             On the 22nd of August, 1992, the witness learned of the massacre

18     at Koricanske Stijene and immediately went to the site.  He described

19     what he saw as a "picture of horror."  The witness looked down into the

20     abyss and saw bunches of people, one over the other, hanging from the

21     branches and rocks.  The witness estimated that the number of bodies

22     could be around 200.  He returned to Skender Vakuf/Knezevo and attempted

23     to contact Stojan Zupljanin to report the massacre.  He was unable to

24     reach Stojan Zupljanin on the phone or in person in Banja Luka.

25             Mr. Komljenovic then travelled to Prijedor to see Milomir Stakic.

Page 20912

 1     The witness demanded that Stakic and the Prijedor authorities remove the

 2     bodies -- or make the bodies accessible, I should say better, because

 3     Prijedor police had committed the crime.  The witness testified that it

 4     was a common knowledge that the victims of the massacre were Muslims from

 5     Prijedor and that the massacre was committed by people from Prijedor who

 6     escorted the convoy.

 7             Shortly thereafter the witness travelled to Banja Luka with

 8     Nenad Krejic and Vladimir Glamocic for a meeting with Stojan Zupljanin,

 9     Milomir Stakic, and Simo Drljaca from Prijedor, and others also, in

10     relation to the recovery of the bodies of the massacre.  The witness

11     states that Stojan Zupljanin discussed with him a dispatch from

12     Radovan Karadzic.  The witness stated that possibly after the first

13     meeting, the civilian protection unit from Skender Vakuf/Knezevo removed

14     four bodies and buried them above the road.  In addition, the witness

15     provides evidence in relation to a meeting held in Banja Luka on the 30th

16     of August, 1992, which was chaired by Republika Srpska minister of

17     defence, Bogdan Subotic.  The meeting was attended by RS MUP personnel

18     and civilian authorities from Banja Luka, Prijedor, and

19     Skender Vakuf/Knezevo.

20             The witness and Vlado Glamocic made notes on the conclusions from

21     this meeting.  One of the conclusions was that the Prijedor authorities

22     were to clear the terrain and make the bodies from the ravine accessible

23     in order to allow for further processing of the case.  The witness states

24     that after the Prijedor authorities were tasked with the removal of the

25     bodies from the massacre, the Skender Vakuf/Knezevo representatives were

Page 20913

 1     excluded from participation in the further developments and received no

 2     official information.  Unofficially, the witness received information

 3     that people from Prijedor had a crane and brought some equipment from

 4     Prijedor mines but that the crane broke down and they could not complete

 5     the job.  The witness stated that there were rumours that the bodies, the

 6     remaining bodies, were -- were burnt or explosives were put into the

 7     abyss.

 8             The witness also stated that three or four months prior to

 9     December 2009, Vlado Glamocic admitted to him that on the night of the

10     massacre, Glamocic received an enraged telephone call from

11     Radovan Karadzic demanding answers about the massacre and who was

12     responsible for it.

13             Your Honour, that completes the summary of the witness's

14     evidence.

15        Q.   Mr. Komljenovic, I have a few questions for you.  You have stated

16     in your amalgamated statement that you tried to contact Stojan Zupljanin

17     and went to Banja Luka but couldn't find him, and then you went to

18     Prijedor to see Milomir Stakic.  What did Stakic say to you when you --

19     when you confronted him about this event that had happened in

20     Koricanske Stijene?

21        A.   Obviously we had a problem after this event.  Things came to a

22     head between us and Prijedor.  Knezevo as a local commune could not take

23     all the necessary measures, primarily works within the competence of the

24     civilian protection.  We wanted the municipality of Prijedor to get

25     involved, because those were their fellow citizens.  The relations came

Page 20914

 1     to a head during the first meeting, and then during the second meeting I

 2     asked Stakic to help us get the bodies out of the gorge, that they should

 3     be made accessible to investigating bodies and for the bodies to be

 4     returned to Prijedor and buried there because they were citizens of

 5     Prijedor.

 6             I didn't -- he didn't really appreciate what I'd said, and the

 7     problem came to a head at the meeting on the 3rd -- 30th of August.  The

 8     citizens of Prijedor refused to get involved and refused to lend a hand

 9     in removing the bodies and helping the other bodies to do their work.

10     And you will find that in the minutes of the records -- of the meetings

11     where it says that the bodies should be approached, they should be taken

12     out from that place, they should be made available to the investigating

13     bodies who should then do their job.

14        Q.   Mr. Witness, we will get --

15             THE INTERPRETER:  Could the witness kindly sit closer to the

16     microphones, thank you.

17             MS. SUTHERLAND:

18        Q.   You're being asked if you can come closer to the microphones.

19     The interpreters are having difficulty hearing you.  Or if you can speak

20     up a little.

21             We'll get to the 30th of August meeting in one moment, but do you

22     recall going to a meeting with Mr. Krejic and Mr. Glamocic with -- with

23     Mr. Zupljanin in Banja Luka before you have the meeting with -- that's --

24     with Mr. Subotic on the 30th of August?

25        A.   Yes, yes.

Page 20915

 1        Q.   You mentioned that in your amalgamated statement that a dispatch

 2     from Mr. Karadzic was discussed informally between Mr. Zupljanin and

 3     yourself.  What -- what was discussed between you at that informal

 4     meeting?

 5        A.   Mr. Zupljanin mentioned some dispatch in the sense that both

 6     municipalities should take necessary measures to do the work that should

 7     be done after a massacre had been committed.  Of course, I did not see

 8     the dispatch myself but Mr. Zupljanin told me what the dispatch said.

 9     The essence was that the two municipalities stop quarreling and that at

10     that moment they try to recover the bodies so the appropriate organs

11     could do their own work.

12        Q.   Moving on to the 30th of August meeting.

13             MS. SUTHERLAND:  If we could have 65 ter number 13299 on the

14     screen, please.

15        Q.   Mr. Komljenovic, do you recognise what's on the screen?

16        A.   Yes.

17        Q.   And what is it?

18        A.   It is my diary.

19        Q.   If we could turn to page 19 of the B/C/S and page 13 of the

20     English.  Sorry, page 20 of the B/C/S.  It's actually page 19 in the

21     version that I have in -- in front of me.

22             MS. SUTHERLAND:  Mr. Usher, can you take that to Mr. Registrar.

23             JUDGE KWON:  Do you have the ERN number?

24             MS. SUTHERLAND:  Oh, yes.  0637783.  Thank you very much, Your

25     Honour.  And if we could just go to the previous page in English.  Thank

Page 20916

 1     you very much.

 2        Q.   Mr. Komljenovic, do we see on the -- in front of us the page of

 3     your diary which has the notes of the meeting that was held in Banja Luka

 4     on the 30th of August, 1992?

 5        A.   [No interpretation]

 6             THE INTERPRETER:  We could not hear the witness.

 7             MS. SUTHERLAND:

 8        Q.   Can you repeat your answer.  The interpreters didn't hear.

 9        A.   Yes.  Yes.

10        Q.   Now, you said this is your notebook.  Is this your handwriting

11     here?

12        A.   Not on the first page but on the second one on the right-hand

13     side, yes.

14        Q.   Whose handwriting is this?

15        A.   Since I and the president of the Executive Board sat next to each

16     other, he wrote this note.  He kept the minutes.  This is the very clear

17     handwriting in the Latin script, whereas this totally illegible scroll on

18     the right-hand side is my own handwriting.

19        Q.   And if we can go to the next page of the B/C/S.  That's -- and

20     this is ERN 06397784.  Is that a continuation of the meeting and that is

21     your notes; is that right?

22        A.   Yes.  These are my notes.  I would say the left-hand side of this

23     side, if I can put it that way.  I'm not sure about what it says here on

24     the right, "Judge Maric, president of the court Maric," because we had

25     not recorded him as attending the meeting, so I'm not sure.

Page 20917

 1             JUDGE KWON:  Next page for English.

 2             MS. SUTHERLAND:

 3        Q.   Okay.  Now, if we can go back to the next page in both.  You

 4     mentioned earlier that -- that in the meeting it was -- it was explained.

 5     One of the conclusions was that the bodies had to be made accessible for

 6     further -- for further things to -- to be done in relation to the bodies.

 7             Who was involved?  What -- sorry, I'll start again.

 8             What involvement did the Skender Vakuf/Knezevo people -- what

 9     role do they have in doing this?

10        A.   I would like to go back to the first meeting with regard to a few

11     details only.  Basically the first meeting failed, and that is why this

12     other meeting that we're talking about now took place.  It failed because

13     the people of Prijedor did not want to take part.  They did not want to

14     help work on the bodies.  Mr. Zupljanin tried to persuade them, and in

15     fact he was between a rock and a hard place, between us and them.  They

16     were trying to get out of this, and it was probably Colonel Subotic who

17     called this meeting in order to influence the Prijedor men to take part

18     of the responsibility to get the bodies out, because nobody was doing

19     anything.  And the civilian protection of Knezevo, in view of the men who

20     were there, they were old, weak, ill-equipped, and they were simply not

21     in a position to do it, also in view of the landscape involved.

22             So this meeting is a result of the failure of the previous

23     meeting, and the essence of this meeting was that the Prijedor men should

24     take part in this, as they had refused to do beforehand, that they should

25     take it upon themselves to get the bodies out so that the organs would be

Page 20918

 1     in a position to identify the bodies, or, rather, to do all the work that

 2     was required in such situations in accordance with the law.  So that is

 3     the essence; one, for Prijedor to take this responsibility because we

 4     were not in a position to do so; and the second point is that the work

 5     should be done as the diary says.  It says quite clearly here that the

 6     operation would be led by Simo Drljaca and that our duty was this

 7     scribbling of mine shows that, that we provide them with food and a place

 8     to sleep, although that did not happen either.  We didn't participate

 9     even from that point of view.  And also that they should come with men

10     and equipment, including firefighters so that this could be done

11     properly.

12        Q.   If we go back to -- and that's -- you've referred to that as

13     being on the left-hand side of that text, on the left-hand side of your

14     illegible -- with your illegible handwriting.

15             If we go back to the page before where it has the participants of

16     the meeting, and then we see on the right-hand side page there it says:

17             "Identification at the site," how many corpses are to be

18     identified, and then "CZ," which is the civilian protection of the

19     municipality where it happened.

20             And then I think you've also written in your handwriting, "Engage

21     the CZ," the civilian protection.  What was that in relation to?

22        A.   Yes.  These are the conclusions.  Most of them are on the

23     left-hand side as written by Glamocic, and they say to provide for

24     identification on the scene itself, and the second one is actually a

25     question:  "How many corpses are to be identified?"  That is what was

Page 20919

 1     discussed, since access to the bodies was a major problem.  So the

 2     question was how many corpses could be retrieved in the first place

 3     during the course of one day.  And then involve the civilian protection.

 4     We had already involved the civilian protection.  We tried to get a few

 5     bodies out.  You mentioned that already, that the civilian protection of

 6     Knezevo retrieved four bodies and buried them above the road.  Later on

 7     they were exhumed, and I don't know what happened then.

 8             And then, of course, pathologists, pathologists should get

 9     involved too.  That's what it says at the end.  The essence of these

10     conclusions was that everything should be done as should invariably be

11     done in such cases so that the appropriate authorities could deal with

12     that, and I repeat once again so that what is in accordance with the law

13     could be carried out.

14        Q.   Who was the head of the civilian protection in

15     Skender Vakuf/Knezevo municipality?

16        A.   At the time we had a Council for National Defence, or, rather, we

17     had a Secretariat of National Defence that was still functioning.  The

18     secretary of the secretariat was, in fact, the head of the civilian

19     protection, and they had a company of their own, and the commander of

20     this company was Cedo Vukovic, and the secretary of the secretariat was

21     Ostoja Barisic.

22        Q.   Was Cedo Vukovic about the place or did he have to be brought

23     back from somewhere?

24        A.   We intervened through the military to have Cedo returned because

25     he was in a military unit.  We asked for him to be returned and to take

Page 20920

 1     over the civilian protection unit, and that is indeed what happened.

 2        Q.   So he was part of a military unit at the front?

 3        A.   Yes.

 4             MS. SUTHERLAND:  Now, Your Honour --

 5             JUDGE KWON:  I see the time.  Do you have more?

 6             MS. SUTHERLAND:  No, Your Honour.  I was about to say thank you,

 7     Mr. Komljenovic.  That's all the questions that I have.

 8             JUDGE KWON:  We should have risen a minute ago, but I have to

 9     continue a bit --

10             MS. SUTHERLAND:  [Microphone not activated]

11             JUDGE KWON:  Are you tendering only those two pages?

12             MS. SUTHERLAND:  Yes, Your Honour.

13             JUDGE KWON:  They will be admitted.

14             THE REGISTRAR:  Exhibit P3769, Your Honours.

15             JUDGE KWON:  Mr. Karadzic, we have decided to sit tomorrow in

16     order to accommodate the witness's request.  We are always trying to --

17     to accommodate them, but I'm very reluctant to ask you, but whether you

18     can finish your cross-examination in less than two hours' time tomorrow.

19     The maximum amount of time that we can sit for tomorrow is two hours

20     with -- i.e., two one-hour session with a 15-minute break.  Otherwise,

21     we'll just cancel tomorrow's sitting and we'll continue next week.

22             THE ACCUSED: [Interpretation] Your Excellency, it all depends on

23     the witness, on Mr. Komljenovic.  If he really has to be brought back

24     next week, then I will do my best tomorrow to finish on time, because it

25     would be a pity, though.  Mr. Komljenovic is also a political figure, he

Page 20921

 1     is familiar with the process of the creation of the community of

 2     municipalities.  He took part in political life, so it would be useful

 3     for the Trial Chamber to hear from him about all of this.

 4             JUDGE KWON:  But -- yes.  Mr. Komljenovic, my understanding is

 5     that if required and if necessary, you can stay till next week.  Is my

 6     understanding correct, Mr. Komljenovic?

 7             THE WITNESS: [Interpretation] Well, I am ready to accommodate

 8     Mr. Karadzic and stay, if necessary.

 9             JUDGE KWON:  That being the case, I don't see the point of

10     sitting tomorrow at the sacrifice of having the benefit of presence of

11     Judge Lattanzi as well as Mr. Robinson.  So we will adjourn for this

12     week, and I will resume next week on Tuesday at 9.00.

13             MS. SUTHERLAND:  Your Honour.

14             JUDGE KWON:  Yes, Ms. Sutherland.

15             MS. SUTHERLAND:  Is Your Honour going to warn Mr. Komljenovic

16     that he can't discuss his evidence.

17             JUDGE KWON:  Oh, yes.

18             Probably you will be aware already that you are not supposed to

19     discuss about your evidence with anybody else outside the courtroom.  Do

20     you understand that, sir?

21             THE WITNESS: [Interpretation] Yes.

22             JUDGE KWON:  I appreciate very much your kind understanding.

23     Please have a nice weekend.

24             The hearing is now adjourned.

25             THE ACCUSED: [Interpretation] The Defence is also grateful.  The

Page 20922

 1     Defence is also grateful to the witness for the effort he has made.

 2                           --- Whereupon the hearing adjourned at 1.50 p.m.

 3                           to be reconvened on Tuesday, the 8th day

 4                           of November, 2011, at 9.00 a.m.

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