Page 24462

 1                           Friday, 10 February 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.02 a.m.

 6             JUDGE KWON:  Good morning, everyone.  Judge Morrison is

 7     indisposed today, so we'll be sitting pursuant to Rule 15 bis.  I hope he

 8     can join us as soon as possible.

 9             Yes, Ms. West.  Please continue.

10             MS. WEST:  Good morning, Mr. President.  Good morning,

11     Your Honours.

12                           WITNESS:  MILENKO KATANIC [Resumed]

13                           [Witness answered through interpreter]

14                           Examination by Ms. West:  [Continued]

15        Q.   Good morning, Mr. Katanic.

16             JUDGE KWON:  Excuse me, Ms. West.

17             Yes, Mr. Harvey.

18             MR. HARVEY:  Good morning, Mr. President.  Good morning

19     Your Honours.  I'm pleased to introduce Andjela Vuckovic, who is a native

20     of Montenegro who has joined our team in the last few weeks.  Thank you.

21             JUDGE KWON:  Thank you.

22             Yes, Ms. West.

23             MS. WEST:

24        Q.   Sir, when we broke off yesterday, you were talking about your

25     long-standing relationship with Miroslav Deronjic.  At this point, I want

Page 24463

 1     to turn your attention to the events in 1995 in Bratunac, and

 2     specifically in July of 1995.

 3             Now, during July and the months before, were you working for the

 4     SDS?

 5        A.   That is correct.  I worked for the SDS as their technical

 6     secretary.

 7        Q.   And what was Miroslav Deronjic's position with the SDS at that

 8     time?

 9        A.   Miroslav Deronjic was the president of the party, and at the same

10     time, he held other positions with the authorities.  I think he was the

11     mayor.

12        Q.   Now, on 11th July 1995, what appointment did Mr. Deronjic receive

13     from President Karadzic?

14        A.   Miroslav Deronjic was appointed by President Karadzic to the

15     position of civilian commissioner for Srebrenica.

16        Q.   And how did you find out about that?

17        A.   At the time, I was placed in the 2nd Battalion as a private.

18     When the Serb forces entered Srebrenica, Miroslav Deronjic summoned me

19     and told me that he needed me in his office since he had been appointed

20     civilian commissioner for Srebrenica.  It was on the 11th of July.

21        Q.   Did he give you a specific task?

22        A.   When we saw each other, he told me to set up a meeting in the

23     evening with the representatives of the Srebrenica municipality authorities

24     as well as a certain number of people whom he wanted to appoint to

25     positions of company managers, of both public institutions and companies.

Page 24464

 1        Q.   And where was the meeting to be held?

 2        A.   The meeting was scheduled to take place in the large meeting hall

 3     of the SDS which could take in some 50 people.

 4             THE ACCUSED: [Interpretation] A small intervention for the

 5     transcript.  I understand the interpreters may have a peculiar economical

 6     system.  They were not strictly private companies.  They were public

 7     companies and socially or state-owned companies.  They used to be called

 8     socially owned, whereas, as a matter of fact, it was -- they were owned

 9     by the state.  It was line 2 -- line 25, page 2.  Perhaps the witness

10     could clarify.

11             THE WITNESS: [Interpretation] That is correct.

12             MS. WEST:  Mr. President --

13             JUDGE KWON:  That is an area you can clarify during your

14     cross-examination.  As translate -- not -- it says "... appoint to

15     positions of company managers, some socially and some privately owned."

16             THE ACCUSED: [Interpretation] It's an error in the transcript,

17     because that's not what the witness said.  In my cross-examination, I

18     will try to clarify with the witness the things he said, but I don't need

19     to deal with transcript errors per se.

20             In our system, there were public companies or public utility

21     companies, and there -- then there were socially or state-owned

22     companies.

23             JUDGE KWON:  Very well.  I would like the CLSS to look into

24     the -- that part and clarify, come up with clarification later on.

25             Yes, Ms. West.  Please continue.

Page 24465

 1             MS. WEST:  Thank you.

 2        Q.   Sir, about how many people attended this meeting?

 3        A.   I'm not sure.  I don't know exactly.  More than 20, I think.

 4        Q.   And who chaired the meeting?

 5        A.   The meeting was chaired by Mr. Miroslav Deronjic.

 6        Q.   At some point in the meeting did Deronjic leave the room?

 7        A.   At the meeting, Miroslav Deronjic informed those present that he

 8     had been appointed civilian commissioner for the municipality of

 9     Srebrenica.  During the meeting, the party secretary, Ms. Nikolic,

10     arrived in the large meeting room and told Deronjic that

11     President Karadzic was on the line.  Miroslav Deronjic left to take the

12     call, and after some time the secretary returned and invited us all to

13     the room where the phone was.  It was a small office, so we couldn't all

14     fit in.  We left the door open, and some people were out in the hallway.

15             Then Miroslav Deronjic said that Mr. Karadzic wanted to say

16     something that all of us should hear.  Mr. Karadzic addressed all those

17     present by saying that Miroslav Deronjic was responsible to him for all

18     civilian affairs in the municipality of Srebrenica and that he is to

19     guarantee for that with his life and that the other people were

20     responsible to Miroslav Deronjic for their respective areas of work.

21        Q.   Had you ever heard President Karadzic's voice before?

22        A.   Yes, a number of times.  I heard President Karadzic's voice,

23     although we never spoke on the phone directly.  However, I could hear him

24     speaking live.  I heard him speak at some rallies through the

25     loudspeakers or in the media.

Page 24466

 1        Q.   As a result of that phone call, what did you understand to be the

 2     professional relationship between Deronjic and Karadzic?

 3        A.   When Mr. Karadzic addressed us on the phone, my conclusion was

 4     that the relationship was quite professional.

 5        Q.   Who did you understand Deronjic's superior to be?  From whom

 6     would he at that point take orders?

 7             THE ACCUSED: [Interpretation] Leading question.  It implies that

 8     he received orders.  He was appointed rather than received orders.  Where

 9     did the witness say that he received any orders?

10             JUDGE KWON:  Who did you understand Deronjic's superior to be?

11     From whom would he at that point take orders?

12             No.  We don't agree with it.

13             Can you answer the question, Mr. Katanic?

14             THE ACCUSED: [Interpretation] I'm sorry, Your Excellency.

15             JUDGE KWON:  No, Mr. Karadzic.  The Chamber ruled it's not

16     leading.

17             Can you answer the question, Mr. Katanic?

18             THE WITNESS: [Interpretation] Miroslav Deronjic was appointed by

19     President Karadzic.  It was by wave of -- way of a written decision.  By

20     the fact of appointment, President Karadzic was his superior.

21             JUDGE KWON:  Thank you.

22             Ms. West, please continue.

23             MS. WEST:  Thank you.

24        Q.   When we interviewed you, you drew a diagram of the SDS office,

25     and we're going to talk about that in a moment, but I'd like you to draw

Page 24467

 1     another diagram on the screen in front of you.

 2             MS. WEST:  If I can have the assistance of the usher, please.

 3             JUDGE KWON:  Before doing that, Ms. West, could you ask the

 4     witness what an a technical secretary was and what he did in that

 5     capacity.

 6             MS. WEST:  Thank you very much, Mr. President.

 7        Q.   Mr. Katanic, you heard the President's question which regarded

 8     your job.  Can you tell us what you did in your role as a technical

 9     secretary?

10        A.   Before Miroslav Deronjic was chosen to act as civilian

11     commissioner for Srebrenica, I held the job of technical secretary.  My

12     job had to do with preparing meetings, setting them up, receiving people

13     when President Deronjic was away from his office, and dealing with

14     technical issues.  It also included dealing with requests by people who

15     came to the office, if they were founded.

16        Q.   And when you say "technical issues," can you tell us a little bit

17     more about that?  What were technical issues?

18        A.   As I said, it included the preparation of meetings which took

19     place at party premises.  Also, co-ordinating the work of the party

20     itself with its local branches, as well as assisting them in their work.

21        Q.   And when were you first -- when did you first start that job?

22        A.   I no longer recall the date, but I think it was in 1993.

23        Q.   And was that a paid position?

24        A.   I was placed in that position by a decision of the ministry as a

25     work obligation.

Page 24468

 1        Q.   When did you finish that position?

 2        A.   I stopped working in that position when the war was over, but in

 3     1993, shortly after being appointed to that position, I was sent by the

 4     military command of the municipality of Bratunac to another front line

 5     where I spent some two months as a soldier.

 6        Q.   Now, in July of 1995, when you were working as a technical

 7     secretary at the SDS office, can you tell us how often you were present

 8     in the SDS office itself?

 9        A.   In July 1995, before Mladic's arrival in Bratunac, I spent the

10     regular working hours in the office, that is to say from 7.00 to

11     3.00 p.m.  When Miroslav Deronjic was appointed civilian commissioner for

12     Srebrenica, there were no longer any working hours.  I was in the office

13     all the time.

14        Q.   Okay.  So let's talk about the office itself.  When we spoke to

15     you, you made a diagram in the office, but at this point on the screen in

16     front of you I'd like you to draw a diagram of the office, but I want you

17     to include the conference room where you said you had the meeting on

18     July 11th.  If you can include that as well, that would be helpful.

19             JUDGE KWON:  Did you indicate the 65 ter number?

20             MS. WEST:

21        Q.   The 65 ter number of the previous office diagram you did was

22     23555.  It now has a Prosecution exhibit number.  This diagram,

23     Mr. Katanic, I hope will be a little bit different.  It will be a bit

24     broader.

25             JUDGE KWON:  No, I'm asking because we don't have a diagram

Page 24469

 1     before us.

 2             MS. WEST:  And I'm asking the witness if he will draw us one.

 3             JUDGE KWON:  On a blank page.

 4             MS. WEST:  On a blank page or on the screen.

 5             JUDGE KWON:  That should be possible.  Yes.  Very well.

 6             MS. WEST:  Thank you.

 7        Q.   So, Mr. Katanic, on the screen in front of you, you can take the

 8     pen and you can actually draw a diagram of the SDS, but in this diagram

 9     I'd like you to include the conference room.

10        A.   Very well.

11        Q.   Okay, sir.  Thank you.

12        A.   Is this enough?

13        Q.   Yes.  Thank you very much.  We'll go through it together.

14             Now, on the top right-hand side of the drawing you have some

15     words, and they are pointed to the room in the top-hand side of the

16     drawing.  What are -- what does at that say?

17        A.   "Secretary's office."

18        Q.   Okay.  And the office --

19             JUDGE KWON:  Just a second.  Can you change the colour of the pen

20     into blue.  Could you put the number 1 on that so we don't need the

21     translation right now.

22             In the meantime I noted that 65 ter 23555, the diagram which

23     witness drew earlier on, we need translation.

24             MS. WEST:  Thank you, Mr. President.

25             JUDGE KWON:  Yes.  Yes.  Could you put number 1 on secretary room

Page 24470

 1     above the B/C/S writing.

 2             THE WITNESS: [Marks]

 3             JUDGE KWON:  Yes.  Please continue, Ms. West.

 4             MS. WEST:

 5        Q.   And the office below the secretary's office that we see on the

 6     screen, whose office was that?

 7        A.   It was President Deronjic's office.

 8        Q.   And can you put a number 2 above the writing that is indicating

 9     Deronjic's office.

10        A.   [Marks]

11             JUDGE KWON:  Could you read out what you wrote there.

12             THE WITNESS: [Interpretation] "Deronjic's office."

13             JUDGE KWON:  Thank you.  Yes.

14             MS. WEST:

15        Q.   Now, if we go outside number 1, the secretary's office, is that a

16     hallway?

17        A.   Yes.

18        Q.   And you've put some writing in that area as well.  Can you tell

19     us what that -- what the writing says.

20        A.   I wrote "Hallway."

21        Q.   Thank you.  If you can put a 3 above that.

22        A.   [Marks]

23        Q.   Now, there's another room on the left hand of the screen, to the

24     extreme left.  Can you tell us what room that is?

25        A.   It is the large meeting or conference room of the SDS party.

Page 24471

 1        Q.   And you have some writing in that room as well, and can you tell

 2     us exactly what the writing says.

 3        A.   I also wrote "The large meeting room of the SDS."

 4        Q.   Put a -- please put a 4 on top of that writing.

 5        A.   [Marks]

 6             MS. WEST:  May we change the colour of the pen one more time, if

 7     possible.

 8        Q.   Mr. Katanic, we talked about this meeting on July 11th that

 9     Mr. Deronjic asked you to organise, and you said that it was in the SDS

10     office.  The meeting that took place with the 20-plus people, which room

11     was that in?

12        A.   It was in room number 4.

13        Q.   And you testified that at some point you left that room to listen

14     to a telephone call.  Where did you go to listen to that telephone call?

15        A.   I didn't leave the room.  Mr. Deronjic did, because he was called

16     by the secretary.

17        Q.   Thank you.  At any point -- well, you testified that you heard

18     Mr. Karadzic on the telephone.  In which room was that telephone?

19        A.   The telephone was in office number 1.

20        Q.   So at some point did all the people in office number 4 go to

21     office number 1?

22        A.   Precisely.

23        Q.   And can you describe for us - you mentioned it was a

24     number - where all these people were located in and around office number

25     1.  You can do it with your pen.

Page 24472

 1        A.   Excuse me.  Some people entered office number 1 and others

 2     remained in the hallway.

 3             JUDGE KWON:  Just a second.  Just a second.  Could you write the

 4     date of today, which is 10th of February, 2012, and your initial on the

 5     right bottom.

 6             THE WITNESS:  [Marks].

 7             JUDGE KWON:  Let's save this first.  We'll admit it as the next P

 8     exhibit.

 9             THE REGISTRAR:  Exhibit P4380, Your Honours.

10             JUDGE KWON:  And after saving it, we upload it and zoom it on

11     room number 1.

12             MS. WEST:  Thank you.

13             JUDGE KWON:  Yes.  Let's zoom it in further on room number 1.

14     That's a bit too much.  Is it okay?  Ms. West, I leave it in your hands.

15             MS. WEST:  Thank you, Mr. President.

16        Q.   We are now looking at room number 1 where you indicated - right

17     there's perfect.  Thank you - was located the phone where you heard

18     Karadzic's voice, and I asked you about the people who came into that

19     room.  Can you indicate on this -- you can still write on this.  Can you

20     indicate --

21             JUDGE KWON:  Can you wait until assisted by the usher.  The usher

22     needs to sets up the pen.  Probably in black.

23             MS. WEST:  Mm-hmm.

24             JUDGE KWON:  Yes.

25             MS. WEST:

Page 24473

 1        Q.   And now I'd like you to tell us, show us, where in and about this

 2     office all the participants of the conference you had called were located

 3     during the telephone call.

 4        A.   Can I mark it?

 5        Q.   Please.

 6        A.   This area marked green would roughly be the area where the

 7     attendees of the meeting were, those who listened to Mr. Karadzic's

 8     conversation.

 9        Q.   And can you put an X where the telephone was located.

10        A.   [Marks]

11             MS. WEST:  Mr. President, may this be the next exhibit.

12             JUDGE KWON:  Could you initial and date this drawing,

13     Mr. Katanic.  This will be Exhibit P4381.

14             THE WITNESS: [Interpretation] Should I mark that little cross --

15     actually, should I write down that that denotes the telephone?

16             JUDGE KWON:  No, that's fine.  Could you put your initial and

17     date somewhere between the two numbers 1 and 2.

18             THE WITNESS: [Marks]

19             MS. WEST:  Thank you.

20             JUDGE KWON:  This will be saved.

21             Yes, Ms. West.

22             MS. WEST:

23        Q.   Mr. Katanic, you had testified that you and Mr. Deronjic spoke to

24     each other frequently in the evenings.  Can you tell us again in the

25     month of July -- or in that period of time, in the month of June and

Page 24474

 1     July, where these conversations would take place?

 2        A.   In view of the situation that prevailed in Bratunac at the time,

 3     I saw Miroslav Deronjic quite seldom during our free time, because I

 4     didn't have much free time and he had even less.  All of our

 5     conversations took place in passing at SDS offices.  However, before

 6     these events, during our free time, often, almost every day, I would see

 7     Miroslav Deronjic at the Caesar cafe that I owned, and in the evening, we

 8     would tell each other about what happened during that day.

 9        Q.   Sir, in paragraph 72 of your statement, you noted that you became

10     aware of the July 13th killings at Kravica warehouse on that same night,

11     July 13th.  How did you become aware of them?

12        A.   That is correct.  I heard about that from Miroslav Deronjic at

13     the SDS office.  He told me about that, although he was not aware of any

14     details either.  He had just heard that that happened.

15             Judging by the way he said this to me, my conclusion was that

16     this was something that had worried him.

17             MS. WEST:  I'd now like to go to 65 ter 40246A.  This is a video.

18     We will play it, but there's also an accompanying transcript.

19        Q.   Mr. Katanic, this is a video you've seen before.  It's dated

20     July 14th, 1995.  It's a newscast.  We're just going to walk -- we're

21     going to go through it, and then I'll ask you some questions about it.

22                           [Video-clip played]

23             MS. WEST:

24        Q.   Sir, we're going to go through this.  I just want you to ID some

25     people, and if you'll bear with me, we'll play it again.

Page 24475

 1                           [Video-clip played]

 2             MS. WEST:  Now, I just stopped at -- I've just stopped at

 3     1 minute and 1 second.

 4        Q.   Now, this is on July 14th, and the announcer has just noted that

 5     Serbian refugees who had left the area more than two years ago are coming

 6     back too.  Were you aware that Serbians refugees were returning to

 7     Srebrenica after its take-over?

 8        A.   On the 14th of July, there was no organised return to Srebrenica.

 9     However, there were inhabitants of Srebrenica who lived in Bratunac, and

10     they, that is correct, went to their houses to see what they were like,

11     and on the following days, they went to Srebrenica again and they cleaned

12     their own houses, because it was impossible to enter Srebrenica and go on

13     living in Srebrenica.  Srebrenica had to be brought into order, if you

14     will, because it was in very bad shape.  The living conditions there were

15     basically non-existent.

16        Q.   Thank you.  We're going to --

17             JUDGE KWON:  Mr. Katanic, do you know SRT television?

18             THE WITNESS: [Interpretation] Yes.  Serb Radio Television that

19     was broadcast from Pale.

20             JUDGE KWON:  And the title on the right side, how does it read?

21     Could you read it.

22             THE WITNESS: [Interpretation] "News, Serb Television."

23             JUDGE KWON:  Thank you.

24             MS. WEST:

25        Q.   And this particular Serb Radio Television that was broadcasted,

Page 24476

 1     this programme, had you ever seen this programme before?

 2        A.   No.

 3        Q.   And let me clarify my question.  I don't specifically mean this

 4     programme but this newscast.  Were you familiar with this newscast or

 5     this station?

 6        A.   I knew of that TV station.  That is Serb Radio Television, and it

 7     was very popular among the Serb people.  People watched this programme,

 8     the news, in particular.

 9        Q.   Okay.  We will continue.

10                           [Video-clip played]

11             MS. WEST:  Now, we've stopped at 1 minute and 27 seconds.

12        Q.   Can you identify the people in this frame?

13        A.   The first person on the left is Mr. Miroslav Deronjic.  Next to

14     him, in the middle, is Dane Katanic.  He was a member of the

15     Municipal Board of the Serb Democratic Party, and I think that he was the

16     president Executive Board for the municipality of Srebrenica.

17        Q.   Is he related to you?

18        A.   Yes.  He's a relative of mine.  The third person, with a beard, I

19     think his name is Milenko, and his last name is Canic, and I think that

20     he was president of the Municipal Assembly of Srebrenica.

21             MS. WEST:  Okay.  We'll continue.

22                           [Video-clip played]

23             MS. WEST:  We're at 1 minute and 40 seconds.

24        Q.   Do you recognise this gentleman?

25        A.   Yes, that is Momcilo Krajisnik.  He was president of the

Page 24477

 1     Assembly, the people's Assembly of Republika Srpska.

 2        Q.   And earlier in this video, and I'm going to try to avoid going

 3     back, there was a person who was sitting to the left of Mr. Karadzic.  Do

 4     you recognise that person?  He was at the same table as Mr. Karadzic.

 5        A.   I cannot remember now.  Was it also Mr. Momcilo Krajisnik?  I'm

 6     not sure.  If it could be shown again, I could identify that person.

 7        Q.   Thank you, and I'll do that?

 8                           [Video-clip played]

 9             MS. WEST:  We started at 1:20 and we've stopped at 1:21.

10        Q.   The person on the right, do you recognise him?

11        A.   The person on right is Momcilo Cvjetinovic.  He was president of

12     the party in Srebrenica, the president of the Serb Democratic Party in

13     Srebrenica.

14        Q.   Thank you.  I'll continue.

15                           [Video-clip played]

16             MS. WEST:  We're at 2 minutes and 25 seconds, and this is an

17     interview with Deronjic, and he's talking about the state of the town of

18     Srebrenica.

19        Q.   Now, right after the attack on Srebrenica, or at least in the

20     month of July, did you have an opportunity to go to Srebrenica itself?

21        A.   I went to Srebrenica only seven days after it had been liberated.

22     At the time, Srebrenica was in very poor shape.  It was in such a bad

23     condition that, believe me, I didn't even leave the car.

24             People who had already been to Srebrenica were warning us not to

25     get out in order to avoid getting some kind of a disease.  It was

Page 24478

 1     extremely dirty and there were lice in town, so I just drove around in my

 2     car and went back to Bratunac.

 3        Q.   So we're -- here Mr. Deronjic says the town was quite ruined,

 4     destroyed, and plundered.  Is that consistent with your memory as well?

 5        A.   The town was quite destroyed, that is correct.  Also, there had

 6     been cases of looting, and the task of the civilian commissioner

 7     was - and I helped him in carrying out this task - to prevent this

 8     looting in the following way:  Directors of public institutions and

 9     public utilities were appointed, and they made inventories of the

10     property there.  They also introduced guard duty in various companies,

11     and they started cleaning the buildings that these companies were in, and

12     the public utilities started cleaning the town itself.

13             MS. WEST:  Thank you.  We'll play till the end.

14                           [Video-clip played]

15             MS. WEST:  Mr. President, I'd like to tender the video.

16             JUDGE KWON:  Yes.  Just for record, we did have subtitles, but

17     also we have transcript which is attached to the e-court; is that

18     correct.

19             MS. WEST:  Yes, that is correct.  Thank you.

20             JUDGE KWON:  Thank you.  That will be admitted as the next

21     P exhibit.

22             THE REGISTRAR:  Exhibit P4382, Your Honours.

23             JUDGE KWON:  Yes, Mr. Robinson.

24             MR. ROBINSON:  Mr. President, I was just becoming a little bit

25     concerned about the time.  I know you've allocated three and a half hours

Page 24479

 1     to Dr. Karadzic for his cross-examination, and if it were to begin

 2     immediately we would end at 3.00 with that three and a half hours, so --

 3             JUDGE KWON:  By the way, do we have to finish this witness's

 4     evidence by today?

 5             MR. ROBINSON:  I don't know what his situation is.

 6             MS. WEST:  Your Honour, we'd have to inquire.  I'm not --

 7             JUDGE KWON:  I'm just asking what prompted your concerns,

 8     Mr. Robinson?

 9             MR. ROBINSON:  Well, normally we try to complete the testimony of

10     a witness before the weekend, so I was just concerned that if he wasn't

11     able to stay over the weekend Dr. Karadzic doesn't lose his allotted time

12     for cross-examination.

13             JUDGE KWON:  Very well.  I'll ask the witness.

14             Mr. Katanic, is it your case that you need to return before the

15     weekend, or more directly, whether you can stay over the weekend till

16     Monday next week.

17             THE WITNESS: [Interpretation] Well, the court is my first

18     priority, but I would appreciate it very much if I could go back on

19     Sunday, because it's my daughter's birthday.

20             JUDGE KWON:  Thank you for your understanding.

21             THE WITNESS: [Interpretation] My daughter --

22             JUDGE KWON:  Yes, please continue.

23             THE WITNESS: [Interpretation] My daughter is young.  She's only

24     12 years old.

25             JUDGE KWON:  No doubt she will miss you.  We'll see how it

Page 24480

 1     evolves, but let's carry on.

 2             Yes, Ms. West.

 3             MS. WEST:  Thank you, Mr. President.  May we have 65 ter 23556,

 4     please.

 5        Q.   Mr. Katanic, you've seen these before.  It's a few pages long.

 6     It's five or six pages long, and these are bills from the Hotel Fontana.

 7     And looking at the first page with the stamp on it, what -- what can you

 8     tell us about this piece of paper?  Is this familiar to you?

 9        A.   This is an invoice issued by the state-owned hotel company

10     Podrinje in Bratunac.  It was issued to the Municipal Assembly of

11     Bratunac for the services rendered.  I saw this invoice for the first

12     time when the Prosecution showed it to me.

13        Q.   And do you know anything about how these -- how invoices to the

14     Municipal Assembly of Bratunac were paid?  Do you know anything about

15     that process?

16             THE ACCUSED: [Interpretation] I have to object.  Let

17     Madam Prosecutor establish with this witness whether the invoice was

18     paid.  It was issued, but we don't know if it was paid and how.

19             JUDGE KWON:  Mr. Karadzic, I read the question again:

20              "Do you know anything about how these -- how invoices to the

21     Municipal Assembly of Bratunac were paid?  Do you know anything about

22     that process?"

23             I don't see anything that you should be concerned about.  If

24     witness knows, he can answer the question.

25             But before that, was the name of that state-owned hotel company

Page 24481

 1     Podrinje in Bratunac Hotel Fontana?

 2             THE WITNESS: [Interpretation] The Fontana Hotel was part of this

 3     company.

 4             JUDGE KWON:  Thank you.  And now, Mr. Katanic, can you answer the

 5     question from Ms. West.

 6             MS. WEST:

 7        Q.   And the question was:  Do you know anything about invoices to the

 8     Municipal Assembly of Bratunac were paid?  Do you know anything about

 9     that process?

10        A.   The municipality of Bratunac had its functioning account.  It was

11     customary that the president of the Executive Council paid such invoices.

12     At the time, I did not work at the municipality.  As I said, I saw this

13     invoice for the first time when shown it by the Prosecution.  Therefore,

14     there's nothing else I can say about it.

15        Q.   Thank you, Mr. Katanic.

16             MS. WEST:  Mr. President, I have no further questions.

17             JUDGE KWON:  Thank you.

18                           [Trial Chamber and Registrar confer]

19             MS. WEST:  I'm not tendering it.

20             JUDGE KWON:  Yes, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you.  Good morning,

22     Your Excellencies, good morning to everyone.

23                           Cross-examination by Mr. Karadzic:

24        Q.   [Interpretation] Good morning, Mr. Katanic.

25        A.   Good morning.

Page 24482

 1        Q.   I'd like to ask you to help me shed some light on some parts

 2     which drew my attention in the transcript.  First of all, you mentioned

 3     work obligation.  That is when someone is ordered to do something

 4     irrespective of whether they're employed somewhere or not.  And was this

 5     service to be performed instead of a compulsory military service?

 6        A.   Yes, absolutely.  It was a military assignment.

 7        Q.   It applies to everyone, including yourself and SDS officials?

 8        A.   Yes.

 9        Q.   We need to wait for the interpreters.

10             THE ACCUSED: [Interpretation] Your Excellencies, I would propose

11     that it be translated as it was in the past, "compulsory work" rather

12     than "work obligation."  It occurred in the testimony of some Muslim

13     witnesses, and the impression was that it only applied to them.  In such

14     cases, it was translated as "compulsory work," whereas today we have

15     "work obligation."  It was on page 6, lines 23 and 24.  I suggest that

16     the other option be used.

17             JUDGE KWON:  It's for the CLSS, but I will ask them to take a

18     look into that as well.

19             THE ACCUSED: [Interpretation] Thank you.

20             MR. KARADZIC: [Interpretation]

21        Q.   Let us begin with the footage as one of the last things we dealt

22     with.  Do you agree that at 02, Mr. Deronjic said that he also came to

23     ask for help?  Do you agree that material assistance could only be

24     provided by the Assembly and that the president of the government -- of

25     the republic had no such powers?  Did they not come asking for help from

Page 24483

 1     the government?

 2        A.   Is that a question for me?

 3        Q.   Yes.

 4        A.   I agree.

 5        Q.   Do you agree that at 02 -- sorry, 2:25 onwards, Mr. Deronjic

 6     invited all former residents to return?  He didn't only invite the Serbs

 7     to return.  If you wish, we can go back to the footage.

 8        A.   No need.  I observed his statement, and it is true that he

 9     invited all former residents of Srebrenica to return.

10        Q.   Thank you.  After the war was over, did some Muslims and Serbs

11     return, and is it true that not all Muslims or Serbs returned?

12        A.   When the fighting stopped, no one returned to stay in Srebrenica.

13     They returned for a while to clean their homes, because in the town

14     itself, there was no water or electricity.  They simply came to prepare

15     their homes to be able to live there.  Only when all the conditions were

16     finally met, that is when organised return started.

17        Q.   Who returned?

18        A.   The Serbs returned to their homes.  There were also some refugees

19     from Central Bosnia, mostly from Ilijas and other places.  They were

20     placed in the empty apartments and houses.  During that period of time, I

21     know of no Muslim returns.  They began returning only later.

22        Q.   Is it correct that the Muslims began returning when the peace

23     agreement was signed and that before there were no conditions in place

24     for them to return?

25        A.   It is correct that they only started returning after the peace

Page 24484

 1     agreement was signed, but not immediately.

 2        Q.   Thank you.  Did it depend on the Serb authorities or their own

 3     feeling of safety?

 4        A.   It depended exclusively on their own feeling of safety.

 5        Q.   Thank you.  From the moment when the peace agreement was signed

 6     until today, is it not the case that some of the most prominent

 7     position -- positions in the Srebrenica authorities are held by Muslims?

 8        A.   That is correct.  The president -- or, rather, head of

 9     municipality of Srebrenica is a Muslim.  In terms of political structure,

10     the head of municipality, one may say, holds the greatest executive

11     powers.

12        Q.   Does it differ from the previous system where the President of

13     the Municipal Assembly held the highest authority and the head of

14     municipality, as is nowadays called mayor, was the person number two?

15        A.   That is correct.

16        Q.   We heard Mr. Deronjic mention, informing the President about the

17     military situation.  Do you recall that after their visit, I declared a

18     state of war on the 14th of July in Birac and some other municipalities?

19        A.   That is correct.  I remember that.

20        Q.   Thank you.  Were Mr. Deronjic and his delegation right in saying

21     to me that things were not over and that in the forests there were

22     enormous numbers of Muslim soldiers and that they would be able to

23     capture any settlement they could and that a state of war needs to be

24     proclaimed so as to safeguard the population and institutions?

25        A.   In terms of territory, Srebrenica is one of the largest

Page 24485

 1     municipalities of the former Bosnia-Herzegovina.  It covers an enormous

 2     area.  As for any groups of Muslims who did not want to surrender or go

 3     to Tuzla together with the group which did remained hidden for quite some

 4     time in the area of the municipality of Srebrenica.

 5        Q.   Thank you.  Do you agree that I was told that there was still no

 6     victory there, although they entered Srebrenica on the 11th?  I was also

 7     told that a state of war should be proclaimed.  Is it correct that in

 8     Bratunac itself people were afraid because there were no Serb soldiers in

 9     Bratunac?

10             MS. WEST:  Mr. President, there are three questions in there.  If

11     I could just ask that this be more simple.

12             JUDGE KWON:  Could you break down your question.

13             THE ACCUSED: [Interpretation] I just wanted for Mr. Katanic to be

14     on time for his daughter's birthday.

15             MR. KARADZIC: [Interpretation]

16        Q.   Mr. Katanic, I will try to put questions which will largely --

17     which could largely be answered with a yes or no, and of course you're

18     free to expand if you want to.

19             Is it correct that Muslims could enter any Serb town in the area?

20        A.   I'm not quite sure that I understand your question.  What time do

21     you have in mind when you say that they could walk into any town?  Do you

22     mean the period before the 12th of July or after the 12th of July?

23        Q.   I am referring to the Muslim forces that were scattered

24     throughout the woods.  Is it correct that in Bratunac, and you talked

25     about this in paragraph 79, you say that they were scattered all around,

Page 24486

 1     while in town there were only teenagers and people over 70 years old,

 2     whereas the Bratunac Brigade moved on towards Zepa.  So is it correct

 3     that Bratunac was defenseless at that point in time?

 4        A.   It is correct that Bratunac had very few able-bodied persons at

 5     the time, and it is true that I expressed my fear, but that related to

 6     something quite different.  That was a reference to the time when the

 7     prisoners were in the town, when they were in different streets.  They

 8     were all over town on streets, and they presented a threat to the town.

 9             As for your question, the groups that remained scattered

10     throughout the territory of Srebrenica municipality that did not want to

11     surrender or join the convoys on route to Tuzla, they could pose a threat

12     in that they could commit an atrocity or a crime somewhere.  They could

13     loot a house or two, but these were not homogeneous large groups that

14     could pose a threat to the town itself.

15        Q.   Could we now take a look at a document showing what the DB stated

16     about that.  Could we see 65 ter 1959.

17             THE ACCUSED: [Interpretation] I think that we've disclosed this

18     to the Prosecution or notified the Prosecution that we'd be using this

19     document.  If not, my apologies.

20             MR. KARADZIC: [Interpretation]

21        Q.   Could you please read this portion which says that Pobudje and

22     Bratunac municipalities, there's still present, a large group around 500

23     armed men, and allegedly in the course of the next evening they were

24     planning a breakthrough of the Milici-Konjevic Polje-Drinjaca road, and

25     so on.  So do you agree that this is a report sent to the Ministry of the

Page 24487

 1     Interior of Sarajevo by the state security department?  We see that it's

 2     a document signed by the head of the state security.  Do you agree?

 3        A.   Yes, I can agree with that.  This report referred to the group

 4     that was moving towards Tuzla.  That was a group that was being observed,

 5     but what I referred to a moment ago were smaller groups that were not

 6     organised and that remained even after the signing of the agreement

 7     remained in the territory of Srebrenica scattered.

 8             Now, this is a reference to a group that was moving from

 9     Srebrenica towards Tuzla.  These were able-bodied men, armed men, and a

10     group of civilians also joined them, civilians who refused to go to

11     Potocari.

12        Q.   Thank you.

13             THE ACCUSED: [Interpretation] I'd like to tender this, please.

14             JUDGE KWON:  That will be admitted.

15             THE REGISTRAR:  As Exhibit D2058, Your Honours.

16             MR. KARADZIC: [Interpretation]

17        Q.   When you were asked about the television is it correct that this

18     was about the state television and that there was a window from the

19     Sarajevo studio, whereas the other window or frame was from the

20     Banja Luka studio?  We saw at the very beginning that there were two

21     windows.

22        A.   That's correct.  I -- this is probably correct.  I did watch the

23     Serbian TV occasionally, because we had -- we could not receive other TVs

24     at Bratunac, and I knew that it was broadcast from Pale.

25        Q.   Thank you.  Now, this was the latest thing that you saw.  So

Page 24488

 1     probably on the 11th you could have heard my voice?

 2             Now, do you know that there was a conversation between me and

 3     Mr. Deronjic on this day, but because the lines were down the

 4     conversation was actually conducted via a mediator, a third party?  Did

 5     you -- were you present during that conversation?

 6        A.   No, I did not, but I did know that there was such a possibility,

 7     that Deronjic and you would communicate.

 8        Q.   Thank you.  Now, during this conversation that you listened in on

 9     or listened to, did Deronjic receive any instructions or was he

10     encouraged in any way to do anything that would be against the law in his

11     function as the civilian commissioner?

12        A.   Deronjic, as the civilian commissioner, had a strict obligation

13     to take care of civilians, of their property, and also to handle civilian

14     affairs in Srebrenica.  Other than that, he had no powers.

15        Q.   Thank you.  Do you agree that an alternative to the civilian

16     commissioner in a town that is without an organised government, the only

17     alternative would have been military control and that this would be a

18     normal way of establishing authority in a newly captured territory, and

19     that by appointing Deronjic, I, in fact, sidestepped or tried to avoid

20     the military role?

21        A.   I agree.

22        Q.   Thank you.  Madam West implied today that in one of her questions

23     she asked you about who was Deronjic's superior and whom he received

24     orders from.  Did you ever learn who Deronjic received orders from, and

25     did he receive records from anyone or did he just act as the situation

Page 24489

 1     demanded?

 2        A.   By -- when he was appointed civilian commissioner, Deronjic had

 3     the powers and the authority to take action within that ambit.  Other

 4     than that, I am not aware that there was any pressure put on him.

 5        Q.   Thank you.  Do you know whether he received any orders on a daily

 6     or a weekly basis which would be outside of the legal framework within

 7     which he could work together with the authorities of Srebrenica?

 8        A.   I'm not familiar with that.

 9        Q.   Thank you.

10             THE ACCUSED: [Interpretation] Excellencies, I see what time it

11     is.  Do we need to go on break now?

12             JUDGE KWON:  Yes.  We will break for half an hour and resume at

13     11.00.

14                           [The witness stands down]

15                           --- Recess taken at 10.30 a.m.

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

17             JUDGE KWON:  Yes, Mr. West.

18             MS. WEST:  Thank you, Mr. President.  Mr. President, I'm just

19     asking for a clarification of the record.  Shortly before we broke,

20     there -- in the record Mr. Karadzic was asking the witness about a

21     conversation, and I think we can see that on the screen now.  Yeah.

22     Exactly.  This would be page 26, and this starts -- will begin on 18.

23     The witness was talking about the video, the television video, and then

24     at 21 Mr. Karadzic said:

25             "Now, this was the latest thing that you saw," and that would be

Page 24490

 1     the 14th, "so probably on the 11th you could have heard my voice."

 2             And then he says:

 3             Now do you know that there was a conversation between me and

 4     Mr. Deronjic on this day, but because the lines were down, it was via a

 5     mediator.

 6             So the clarification I'm looking for is what Mr. Karadzic meant

 7     "on this day," and the reason this is an issue is because he's talking

 8     about a conversation between a mediator and I assume he must mean a

 9     conversation on the 13th, because there is evidence that Mr. Karadzic had

10     a conversation with Mr. Deronjic through a mediator on the 13th.  And

11     just two days ago Mr. Karadzic asked (redacted) some questions about this

12     as well, and this is two days ago transcript 24257, talking about the

13     conversation on the 11th.  (redacted) gives an answer.  But then at line 14

14     Mr. Karadzic says:

15             "We do have evidence that it was through an intermediary."

16             So the result of all of this is today when Mr. Karadzic said

17     "this day."  I just need a clarification, and I assume it must be the

18     13th if he means the 13th.

19             JUDGE KWON:  What was it?  What's the date of all the people

20     hearing Mr. Karadzic's voice as to the appointment of Mr. Deronjic?

21             MS. WEST:  That is on the 11th.

22             JUDGE KWON:  The 11th.

23             MS. WEST:  Yeah.

24             JUDGE KWON:  Before speaking about my understanding, can I hear

25     from you, Mr. Karadzic on this?

Page 24491

 1             THE ACCUSED: [Interpretation] Certainly.  I believe that what I

 2     said was not recorded in the transcript.  Did you also hear the

 3     conversation that I had on the 13th via a mediator?  And I said, You

 4     probably heard my voice on the 11th, but were you present during the

 5     conversation that I had through an intermediary on the 13th?  So it is

 6     indubitable that the conversation was on the 13th.  I believe that on the

 7     14th Deronjic was -- came to see me, and there was no occasion to talk to

 8     him because he left Bratunac early to -- to come and see me in my office.

 9             Now -- so there is a portion missing here where it says, You

10     probably heard my voice on the 11th, but do you remember that there was

11     also a conversation through an intermediary because the lines were down

12     on the 13th?

13             JUDGE KWON:  Thank you.

14             Are you satisfied, Ms. West?

15             MS. WEST:  I am.  Thank you.

16             JUDGE KWON:  Let's bring in the witness.

17                           [The witness takes the stand]

18             JUDGE KWON:  Thank you, Mr. Katanic.  Please make yourself

19     comfortable.

20             Please continue, Mr. Karadzic.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   So we talked about the conversation that you heard and listened

24     to.  Did you understand that Deronjic wanted you to hear that he was

25     appointed to this post which would then vest him the -- in the authority

Page 24492

 1     that he needed in order to carry out that function?

 2        A.   Well, you could interpret it that way.  Could you say it's how it

 3     was.

 4        Q.   Thank you.  Now, you prepared that meeting; correct?

 5        A.   Correct.

 6        Q.   And you invited all former members, Serb officials, and in this

 7     joint Assembly as well as Serb officials in the Serbian municipality of

 8     Srebrenica that existed for a while; correct?  In other words, people who

 9     were in the local government in the past and then fled.

10        A.   That's correct.  So people -- also people who were managers of

11     companies and officials and state institutions.

12        Q.   Thank you.  So Deronjic's task was to ensure continuity of the

13     government.  In other words, to ensure that there was a local government

14     in the Serbian municipality of Srebrenica; is that correct?

15        A.   Yes, that's correct.

16        Q.   Is it correct that at that point in time on the 11th in the

17     evening we did not know that all Muslims would leave?  But before that,

18     my question:  Do you agree that it could be expected that those people

19     who were not from Srebrenica, who were not locals, would -- it would be

20     normal to expect them to leave Srebrenica, people from Cerska and other

21     places?

22        A.   Well, at that time in Srebrenica, the population had swelled

23     because people came from other municipalities to Srebrenica.  We could

24     not assume with any certainty that the entire population of Srebrenica

25     would leave Srebrenica.

Page 24493

 1        Q.   Do you agree that that became evident only on the 12th of July

 2     after a series of meetings with UNPROFOR, with Mladic, and with Muslims'

 3     representatives?

 4        A.   That was a decision that the Muslim people took, and they

 5     expressed this decision through their representatives who attended the

 6     meeting at the Hotel Fontana.

 7        Q.   Thank you.  We will get back to this later.  Now, let me ask you

 8     this:  Was there any dilemma that Deronjic was in charge and trusted with

 9     establishing civilian authorities in Srebrenica and that none of those

10     applied to Srebrenica?  In other words, that he did not have any

11     authority in Srebrenica.

12        A.   Deronjic was appointed civilian commissioner of the municipality

13     of Srebrenica and that applied to Srebrenica alone.

14        Q.   Thank you.  So in Bratunac, the legal authorities continued in

15     their work, and Deronjic did not have any authority over them; correct?

16        A.   Well, by being appointed civilian commissioner in Srebrenica

17     municipality, he did not get any special powers for the Bratunac

18     municipality.

19        Q.   Thank you.  Now, you were asked, but you also said in

20     paragraph 71 of your amalgamated statement, and I don't know if you have

21     that translated into Serbian, you were asked about various options,

22     whether Deronjic could have talked to me from some other place, and you

23     said that such a possibility did exist, but then there was something

24     else.  You were asked whether you knew whether Deronjic had informed me

25     of the Kravica incident on the 13th of July when he came to see me on the

Page 24494

 1     14th of July.  You said that you didn't know anything about that, but

 2     that as far as you knew him, that would be possible because some of those

 3     people were civilians and others were combatants.

 4             So now let me ask you this:  Before he left for Pale early in the

 5     morning on the 14th, was there any other matter that Deronjic could need

 6     to inform me about?  Were there any other dramatic incidents, murders, or

 7     anything like that?

 8        A.   I'm not aware of any.

 9        Q.   Thank you.  You learned on the 14th, after you arrived at work or

10     in the course of that day, of the bodies found in the school building;

11     correct?

12        A.   Yes.  I learned that from my family and that because my school

13     was in the vicinity of -- my house was in the vicinity of the school

14     building, and that's how we learned that some people had been killed

15     there.

16        Q.   Thank you.  In paragraph 72 and onwards, you talk about -- for

17     instance, in 82, and I will read the entire paragraph in English:

18             [In English] "The next day, the Muslim prisoners were taken away

19     from Bratunac.  I did not see them leave.  I heard from the public media

20     that most of the prisoners were taken to Zvornik municipality.  Probably

21     some were taken to other places.  I don't think there is anyone from

22     Bratunac who could help them.  Miroslav Deronjic tried to keep the honour

23     of Bratunac to avoid them being imprisoned here."

24             MS. WEST:  For the record, that's paragraph 83.

25             THE ACCUSED: [Interpretation] Yes.  Thank you.

Page 24495

 1             MR. KARADZIC: [Interpretation]

 2        Q.   So you saw for yourself that Deronjic did not want them to be

 3     kept there, and at that point in time no one had any idea about the

 4     killings; is that correct?

 5        A.   If you allow me, I would like to refer to the summary of my

 6     statement that was read out by the Prosecutor where she said something to

 7     the effect that those people were murdered.  However, in all my

 8     statements so far, I have said that in this particular case the issue was

 9     the imprisonment of these prisoners of war in Bratunac, because all these

10     prisoners were arrested in different municipalities and then were brought

11     to Bratunac and only to Bratunac.  I said that I thought that

12     Mr. Karadzic helped Deronjic because these prisoners were not detained in

13     Bratunac, or they shouldn't be detained in Bratunac, but, rather, be

14     distributed throughout various municipalities and that -- because this

15     would be a great burden for the Bratunac municipality, which was already

16     encumbered with a lot of financial difficulties.

17        Q.   Thank you.  In the next paragraph that's what you mention.  Now,

18     do you remember that Mr. Deronjic was angry with Mr. Dukic because the

19     prisoners who were arrested in his municipality were being sent to

20     Bratunac?  In paragraph 94, you say talk about that, but you don't

21     mention Dukic, but rather Milici.  Do you remember that that was the

22     reason why he was angry, why they weren't kept in his own municipality

23     but rather sent to Bratunac?

24        A.   Well, that's precisely what I was trying to describe a moment

25     ago.

Page 24496

 1        Q.   Thank you.  Did you know by any chance that an order had been

 2     sent -- or, rather, a message that a thousand people should be received

 3     at Batkovic and that in Rogatica also there should be facilities prepared

 4     for the reception of prisoners?

 5        A.   I don't know anything about that.  However, Miroslav Deronjic

 6     told me that he had major problems with Lieutenant-Colonel Beara.  He

 7     didn't want them detained on the territory of Bratunac municipality, and

 8     when they were bused out of Bratunac, I said that I thought that

 9     Mr. Karadzic had helped him in persuading Beara to send them to a

10     different location.

11        Q.   Did Deronjic tell you that as part of that argument he told him

12     he would go to Pale the next day and speak to the president about it all

13     and that that is what finally persuaded Beara to give up on accommodating

14     the prisoners in the brickworks factory or at another location?

15        A.   Yes, more or less.

16        Q.   Thank you.  Do you agree that Batkovic was the only well-known

17     POW camp after Manjaca and that people were exchanged from there?

18        A.   I'm not familiar with that.

19        Q.   We touched upon this topic during the previous session.  You said

20     that the people in Bratunac were upset because of the presence of so many

21     prisoners.  They were restless.  Is it correct that only those who were

22     not fit for military service guarded those prisoners so as to protect

23     them from anyone who would want to take revenge on them, and by the same

24     token, they were there to safeguard the town from the prisoners

25     themselves?

Page 24497

 1        A.   That is correct.  I was in the office when concerned citizens

 2     came in.  They were concerned for their safety, because there were a

 3     great many prisoners in the town, on the buses and trucks, which were not

 4     guarded appropriately.  I informed the police station about that, and

 5     then they took upon themselves to provide additional security, because

 6     the army had gone on to Zepa.

 7        Q.   Is it true that there was a small number of people who guarded

 8     the prisoners?  And I'm looking for a specific paragraph.  Somewhere you

 9     said that if they had known how poorly Bratunac was secured, they could

10     have rioted.

11        A.   That is correct.  Some additional guards were provided by the

12     so-called third wave of draftees who were otherwise people who were

13     not -- deemed not fit for military service and were usually not called

14     up.

15        Q.   Could you notice that the civilian protection of Bratunac

16     undertook some measures to take care of those people, civilians, in

17     Potocari as well as providing water to the prisoners who were on the

18     buses?  Do you have anything to say about that?

19        A.   The municipal authorities took measures through their services so

20     that the prisoners were provided with the basic necessities, including

21     those who were on the buses as well as in Potocari.  In other words, they

22     brought food and water for them.

23        Q.   Can I ask you this:  When did you realise that something would be

24     going on around Srebrenica?  Is it correct that you only realised that

25     once you saw the army coming in great numbers?

Page 24498

 1        A.   I did not realise that there would be anything done around

 2     Srebrenica for quite some time.  I believe the operation was well

 3     underway by the time one could conclude that it was aimed at Srebrenica.

 4             A few days before the entry into Srebrenica, Miroslav Deronjic

 5     left without notifying anyone in the party.  He went to the forward

 6     command post called Pribicevac.  He spent three days there without

 7     returning to Bratunac.  Only once he returned did he tell me that there

 8     was an operation around Srebrenica underway.

 9             At around that time, General Mladic arrived in Bratunac as well.

10     All able-bodied men who were included in work obligations reported to

11     their war assignment locations.  I, too, went to the 2nd Battalion,

12     because General Mladic was well known for his dislike of men fit for

13     military service walking around town.

14             When General Mladic arrived in Bratunac, it dawned on me only

15     then that Srebrenica will be tackled.

16             JUDGE KWON:  Just a second.  Yes, Ms. West.

17             MS. WEST:  My apologies for interrupting.  But page 29 today,

18     lines 5 and 7, my earlier comments.  Can we have a redaction for lines 5

19     and 7 before it's --

20             JUDGE KWON:  Uh-huh.  It's your submission.  Yes.  Thank you.

21             Shall we continue from there?  You can take up, Mr. Karadzic.

22             THE ACCUSED: [Interpretation] Yes.  I wasn't able to identify

23     what this is about, but I do not object to a redaction if it's necessary.

24             MR. KARADZIC: [Interpretation]

25        Q.   I wanted to draw your attention to paragraph 93.  I'll read it

Page 24499

 1     out in English:

 2             [In English] "Deronjic stated that at that moment Beara was

 3     searching for a location, probably to kill the prisoners, right in

 4     Bratunac.  And I think Deronjic was assisted by Karadzic so that these

 5     prisoners were relocated from Bratunac and were not killed in Bratunac.

 6     I think that because on one side there was a military leadership in

 7     Bratunac represented by Mladic and his high-level officer Beara, and on

 8     the other side there were civilian representative Deronjic, and I think

 9     he, by himself, could not defend himself and impose his will on a

10     Main Staff colonel of VRS."

11             [Interpretation] I would like to clarify something.  Is this the

12     way you formulated this sentence because you subsequently learned of the

13     killings, or did you at that moment know that it was Beara's request that

14     they be either killed or imprisoned there?

15        A.   Are you asking me?

16        Q.   Yes.

17        A.   I referred to the summary of my statement presented by

18     Madam Prosecutor.  What I said is that I had not stated it previously.

19     It only appeared in the abbreviated version.  I always state -- I have

20     always stated that the issue at hand was imprisonment.  At the time, it

21     was not known that they would be killed.

22             JUDGE KWON:  Why don't we upload his amalgamated statement.

23     Page 18 in hard copy, para 93.

24             THE ACCUSED: [Interpretation] Ninety-one, 92, 93.

25             JUDGE KWON:  Let me -- just a second.

Page 24500

 1             In para 92, the first sentence reads like this, Mr. Katanic:

 2             "Deronjic said that Beara sent people to search for places where

 3     they could imprison Muslim prisoners in the brick factory and Sase

 4     mines."

 5             But 93 reads -- para 93 reads like this, I'll read it for you:

 6             "Deronjic stated that at that moment, Beara was searching for a

 7     location, probably to kill the prisoners, right in Bratunac.  And I think

 8     that Deronjic was assisted by Karadzic so that these prisoners were

 9     relocated from Bratunac and were not killed in Bratunac."

10             Karadzic -- Mr. Karadzic asked question about this para 93.

11             Mr. Karadzic, could you ask the witness again.

12             THE ACCUSED: [Interpretation] Thank you.

13             MR. KARADZIC: [Interpretation]

14        Q.   In paragraph 93 and 92, you say that at that point in time the

15     civilian authorities were asked to provide a place where the people would

16     be imprisoned, and all of a sudden in paragraph 93 we have this reference

17     to a place that would be used to probably kill the prisoners.

18             Was it clear at that time that they would be killed, or did this

19     find its way in the -- into the paragraph because of something you

20     learned subsequently, that there were killings?

21        A.   I don't remember having stated this in paragraph 93.  I did sign

22     the document, the statement, but I need to say that I signed the document

23     without having a Serbian version.

24             JUDGE KWON:  Mr. Katanic, this --

25             THE WITNESS: [Interpretation] Yes?

Page 24501

 1             JUDGE KWON:  -- which refers to killing, probably killing, has a

 2     citation which refers to your interview.  Would you like to see them, or

 3     do we have an audiotape?

 4             MS. WEST:  Yes, Your Honour.  This is directly from an interview.

 5     I believe we have it in B/C/S, but these -- these footnotes are direct

 6     quotes from the interview itself.

 7             JUDGE KWON:  Yes.  So I'm asking Mr. Katanic whether he's

 8     interested in seeing the interview you had -- you had with the

 9     Prosecutor.  Is it correct, interview with the Prosecution?

10             MS. WEST:  Yes.

11             THE WITNESS: [Interpretation] Your Honour, I don't think there is

12     any need.  I trust this.  But perhaps the question was put in such a

13     leading way that my answer came out as it did without thinking about the

14     weight of what I said, and now I realise its full weight.

15             It is a fact that it happened.  The killings ensued.  But at that

16     time, as we can see from the previous paragraph, I was not discussing any

17     killings, because I did not have this idea or expectation that the

18     prisoners would be killed.

19             JUDGE KWON:  I wanted to reserve my question at the end, but I

20     have to intervene now.

21             Could you -- could we take a look at para 43 -- I'm sorry, 83

22     again, the previous page.  At the end of this paragraph you said,

23     Mr. Katanic:

24             "Miroslav Deronjic tried to keep the honour of Bratunac to avoid

25     them being imprisoned here."

Page 24502

 1             My question for you, Mr. Katanic, is this:  Why would Bratunac be

 2     dishonoured if it was to keep -- if it was to imprison the prisoners?  I

 3     would understand if the prisoners were to be killed in Bratunac it may

 4     dishonour Bratunac, or I can understand it would be a burden for Bratunac

 5     to imprison them, but it's a bit difficult to understand why Bratunac

 6     would be dishonoured by imprisoning those prisoners.

 7             THE WITNESS: [Interpretation] Well, you see, Your Honour, the

 8     prisoners were those who had surrendered voluntarily because the police

 9     went around with loudspeakers calling out to the masses that were moving

10     from Srebrenica to Tuzla, asking them to surrender, saying that their

11     safety and security would be guaranteed and that the Serb army guaranteed

12     that they would be safe, that nothing would happen to them.

13             In these columns of people who were surrendering, there were

14     quite a few civilians, probably people who did not -- who do not deserve

15     this treatment of being prisoners of war.  Probably that had to do with

16     that.  That was the honour involved.

17             It is possible that when this interview was conducted, it was

18     well known what had happened, all of it, and it's been almost 20 years --

19     or, rather, this happened almost 20 years after these events.  When it

20     was known that these prisoners were being killed, perhaps the statement

21     was made in that context.

22             JUDGE KWON:  Thank you, Mr. Katanic.

23             Yes, Mr. Karadzic, please continue.

24             MR. KARADZIC: [Interpretation]

25        Q.   While we're on the subject, let me ask you this as well:  Did

Page 24503

 1     Bratunac have an appropriate infrastructure for properly, in accordance

 2     with the law, put up such large number of prisoners?

 3        A.   Bratunac did have an infrastructure, but not for putting them up

 4     properly.  This would not have satisfied even the most minimal criteria.

 5        Q.   Thank you.  You mentioned that perhaps the question was a leading

 6     one.  I want to ask you the following:  How were your answers formulated?

 7     Were they transcripted from the -- transcribed from the tape directly, or

 8     did someone help you in the formulation of the answers you gave during

 9     this interview?

10        A.   My interview was audio recorded, and it was typed up on a

11     typewriter.  One of the investigators typed it up in English.  After the

12     interview, I was given that to sign.

13        Q.   Thank you.  Do you speak the English language?

14        A.   You could say no, because I know a few words only.  It's not even

15     sufficient for getting by in a hotel.

16        Q.   Thank you.  In paragraph -- actually, on page -- actually,

17     paragraphs 83 and 4 and onwards.  And you assume that my authority

18     helped, because you believe that Deronjic could not oppose a member of

19     the Main Staff on his own.  You also confirm that Deronjic had not

20     informed you about this but that he managed to prevent this from

21     happening in Bratunac, the detention, I mean, and you assumed that that

22     happened because he invoked my name; right?

23        A.   I assume that he had your assistance in that.

24        Q.   Oh, thank you.  So that is paragraph 93 that refers to that;

25     right?

Page 24504

 1             [In English] "Deronjic did not tell me that he received support

 2     from Karadzic in having prisoners moved out of Bratunac.  Deronjic never

 3     told me about any conversation he may have had with Karadzic about the

 4     fate of the Muslim prisoners in Bratunac or about Deronjic speaking with

 5     Beara.  I do not know if Deronjic did or did not discuss these topics

 6     with Karadzic.  If Karadzic told Deronjic that all the Muslims should be

 7     killed, as I read in the newspaper, I find it strange that he would not

 8     have told me about it.

 9             [Interpretation] Are you convinced of this, that you had said

10     that if I had told Deronjic that they should be killed, Deronjic would

11     have certainly told you about it?

12        A.   Well, it's a bit strange considering the kind of person Deronjic

13     was who liked to say, I was with Karadzic today, or, Today I talked to

14     Mr. Karadzic, because this gave him importance too.  After all, not

15     everybody could talk to Mr. Karadzic.  And when he says, I talked to

16     Mr. Karadzic, then that gives him a certain wait.  That is why I stated

17     that he, as a person who liked to say something that he talked about with

18     Karadzic, he never said that to me, and he never said that to anyone in

19     town.

20        Q.   Thank you.  I'm sorry, had I known that we would have been

21     discussing this subject, I would have brought something.

22             Did you know that the late Professor Koljevic, actually, that his

23     diary was published after his death, "The Creation of Republika Srpska,"

24     two volumes?

25        A.   I'm not aware of that.

Page 24505

 1        Q.   Thank you.  If I were to tell you that Koljevic also wrote that

 2     he met up with our civilian commissioner a month or a month and a half

 3     later and asked him what it was that really happened in Srebrenica, he

 4     says that Deronjic said to him, Professor, nothing.  Do you find that

 5     understandable?  Is this in accordance with what you said in terms of

 6     what he would say and what he would not say?

 7        A.   As for this conversation with Mr. Koljevic, I hadn't heard about

 8     that, and it doesn't really mean much to me.

 9        Q.   Would you expect Deronjic to say that?  Is that in accordance

10     with what you know in terms of what Deronjic was saying?

11             MS. WEST:  Objection.  He's answered the question.

12             JUDGE KWON:  Yes.  Let's move on.

13             THE ACCUSED: [Interpretation] All right.  Then I'm going to

14     tender that diary at some point.

15             MR. KARADZIC: [Interpretation]

16        Q.   In one of these paragraphs you say that these buses with the

17     prisoners were leaving, and no one knew what their fate would be; right?

18     That's paragraph 91.  You say that even Miroslav did not know what would

19     happen to them.

20        A.   I think that the citizens of Bratunac and those who took part in

21     escorting the buses to their destination did not know what the fate of

22     the prisoners would be.

23        Q.   Thank you.  Do you agree that it was natural for them to head

24     towards Zvornik and Bijeljina because Batkovic is near Bijeljina?

25        A.   At that point in time, I didn't know what their destination was.

Page 24506

 1        Q.   Thank you.  I don't know whether you've dealt with this.  How did

 2     you find out -- or, rather, did you find out what caused that killing at

 3     the co-operative in Kravica on the 13th of July, 1995?  Did you hear how

 4     that happened?  Had that been prepared and planned or did something

 5     happen?

 6        A.   As for what happened in Kravica, I heard about that from Deronjic

 7     the same evening, but only by way of conveying information, because he

 8     was not aware of any details either.  Later on, I found out that the

 9     cause of this was an incident that occurred roughly as follows:  One of

10     the prisoners seized an automatic rifle from a guard and killed another

11     guard.  That is why things happened the way they did.

12             Now, whether that could have been prevented or kept under

13     control, I don't know.

14        Q.   Thank you.  Did you have any knowledge as to how many guards were

15     guarding these people in Kravica at the co-operative there when this man

16     dared seize a rifle and shoot?

17        A.   I did not have any knowledge before or after; as to the number of

18     guards, that is.

19        Q.   Did you have any knowledge of this being people who had been

20     taken prisoner in the area of Sandici during the course of the day, or

21     did anyone give you a reliable number as to how many persons were there?

22        A.   I did not have any knowledge to that effect.

23        Q.   Thank you.  Did you find out -- actually, was it the duty of the

24     civilian protection to bury the bodies, and did you hear of these killed

25     persons being buried as well?

Page 24507

 1        A.   The civilian protection was duty-bound to carry out the

 2     sanitisation of the terrain.  I don't know if they were buried and, if

 3     so, at which location.

 4             THE ACCUSED: [Interpretation] 1D4098.  Can we have a look at

 5     that, please, in e-court.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Is it correct that in 1992, the president of the municipal

 8     government -- or, rather, the Executive Committee of the municipality was

 9     Mr. Rodoljub Djukanovic?

10        A.   Yes, that's correct.

11        Q.   Please take a look at this document.  Would you agree that this

12     was an order issued on the 25th of June, 1992, and it talks about the

13     description of the locations where people who were killed in Bratunac and

14     its surroundings, in other words, on the territory of the municipality,

15     should be buried?

16        A.   Yes, that's correct.

17        Q.   And do you agree that it says here that after the bodies are

18     identified, they should be buried either in accordance with the will of

19     the families or -- would you like to read it?  Should I give you some

20     time to read through this?

21        A.   Well, I've read it.  This order is an order saying that the

22     bodies of people of Muslim ethnicities should be buried in the

23     cemetery -- Muslim cemeteries; whereas people of the Orthodox faith, the

24     Serb people, should be buried in Orthodox cemeteries.

25        Q.   I see.  However, there were so many casualties that it was

Page 24508

 1     impossible to comply with this order; correct?

 2        A.   Yes, that's correct.  It was impossible.

 3        Q.   Thank you.

 4             THE ACCUSED:  Can we see the next page, please.  Thank you.

 5             JUDGE KWON:  [Overlapping speakers] English, yes.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   This is a standard document of a municipal government; correct?

 8        A.   Yes.

 9             THE ACCUSED: [Interpretation] I'd like to tender this, please.

10             JUDGE KWON:  What's the relevance, Mr. Karadzic?  How is it

11     relevant?

12             THE ACCUSED: [Interpretation] Well, it is obvious that the

13     municipal authorities in Bratunac took care, when they realised that

14     there would be a war, took care of the matter of dealing with the burial

15     of people who get killed.  So this shows what the authorities did and

16     what their responsibilities were.

17             JUDGE KWON:  This is admitted.

18             THE REGISTRAR:  As Exhibit D2059, Your Honours.

19             MR. KARADZIC: [Interpretation]

20        Q.   Thank you.  We will get back to the events of 1995 after the

21     break.  For now, I would just like to go back to the beginning of the

22     crisis and the events between 1990 and 1992, and I'd like to ask you

23     this:  Is it --

24             JUDGE KWON:  Mr. Karadzic, for planning purpose, today we'll have

25     a second break only for 50 minutes.  I appreciate the understanding and

Page 24509

 1     indulgence of the staff.  So we'll go till 12.40 to have a break, just to

 2     let you know.

 3             THE ACCUSED: [Interpretation] And do we then go on to 3.00?

 4             JUDGE KWON:  After the break.  But I would like you to come back

 5     to 1995 as soon as possible.

 6             Yes, Mr. Robinson.

 7             MR. ROBINSON:  Yes, Mr. President.  I was actually commending

 8     Dr. Karadzic for taking my advice this time.  I told him to go to the

 9     most important things first, so I think we've used -- most of 1995 is

10     completed.

11             JUDGE KWON:  Thank you, Mr. Robinson.

12             Please continue.

13             THE ACCUSED: [Interpretation] Thank you.  If there's anything

14     else left over from 1995, I'll get back to that after the break, but now

15     I'd like to touch upon these other subjects, and the witness is kind

16     enough to answer concisely and briefly.

17             MR. KARADZIC: [Interpretation]

18        Q.   Now, do you agree, Mr. Katanic, that in the previous system there

19     was a one-party system in which Serbs and Muslims in Bratunac shared in

20     the local government?

21             THE INTERPRETER:  The interpreter did not understand the last

22     part of the question.

23             THE WITNESS: [Interpretation] That's correct.

24             JUDGE KWON:  The interpreters didn't catch the last part of your

25     question.

Page 24510

 1             THE ACCUSED: [Interpretation] Well, they shared in the local

 2     government under the auspices of the League of Communists, which was the

 3     only party in existence at the time, and the witness said yes, that that

 4     was correct.

 5             JUDGE KWON:  Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Is it correct that the Party of Democratic Action was established

 8     first at the republic level and then in the Bratunac municipality

 9     followed by the establishment of the Serbian Democratic Party?

10        A.   That's correct.

11        Q.   Is it correct, and you mentioned this in one of the paragraphs,

12     that the people who had been for many years dissidents or in the

13     opposition, or in any case, anti-Communists, were the ones who actually

14     signed up to become members of the Serbian Democratic Party?

15        A.   I can say that Miroslav Deronjic and I were people who had not

16     been politically active before the establishment of the Serbian

17     Democratic Party.  I can also state that in the beginning, many people

18     joined the Serbian Democratic Party from among the ranks of politically

19     disengaged people, not active, up until then.

20        Q.   Thank you.  Now, is it correct that Mr. Deronjic had a reputation

21     even before the establishment of these new parties, that he had a certain

22     reputation in Bratunac?

23        A.   Miroslav Deronjic was a teacher.  He was a teacher of literature

24     in Srebrenica municipality, and he worked in the school library.  He was

25     a very respectable citizen and had a very good reputation in Bratunac

Page 24511

 1     municipality.

 2        Q.   Thank you.  Is it correct that before the establishment of these

 3     parties, he had a public appearance - this was while the League of

 4     Communists was still there - which actually created or established his

 5     reputation, because he opposed and he pointed out all the different

 6     machinations and the things that Communists were trying to do in order to

 7     maintain power?

 8        A.   I wouldn't put it exactly that way.

 9        Q.   Well, would you please say it in your own words?

10        A.   The League of Communists, before the first multi-party

11     parliamentary elections, organised a public debate, the topic of which I

12     cannot recall, I'm not aware of it any more, but I know that

13     Miroslav Deronjic and I were both present.  This public debate had as its

14     speakers some people from Sarajevo who toed the party line and who spoke

15     for about two hours, which irritated Miroslav Deronjic, who then took the

16     floor, and in three sentences he said far more than all the other

17     speakers combined for the previous two hours.

18             That left a deep impression on me, because I didn't know that

19     face of Miroslav Deronjic.  He probably left the same impression on all

20     the other people who attended this public debate.

21        Q.   Thank you.  Was that decisive in Deronjic's profiling as the

22     future leader, local leader, and is it correct, as you state in

23     paragraph 11, that Karadzic even knew about -- or of Deronjic at the

24     time?

25        A.   I don't know that Mr. -- that Mr. Karadzic knew of Mr. Deronjic

Page 24512

 1     at the time, but at that time, the SDA and HDZ parties had already been

 2     established at the republic level.  It was rumoured in the town that the

 3     Serb people, too, should organise themselves politically.  So there were

 4     various gatherings organised where people talked about establishing an

 5     initiating board which would then organise the Serbian Democratic Party

 6     in Bratunac.

 7             One day when we were playing cards on the Drina, on the banks of

 8     the Drina, at a motel, after I heard about one such gathering I told

 9     Miroslav that perhaps we, too, should go and see what it was all about.

10     He agreed, and from that point onward his fate was closely tied to that

11     of the Serbian Democratic Party.

12        Q.   Thank you.  Now I would like to put my questions in such a way

13     that would allow you to answer with a yes or no.  Is it correct that the

14     initiative to establish the Serbian Democratic Party arose because there

15     was a -- because there was a sense that the Serbs, too, needed to do

16     something that the Croats and Muslim had already done and that it was not

17     imposed from above but, rather, from grassroots?

18        A.   In Bratunac that was the case.

19        Q.   Thank you.  Is it correct that they did not manage to ensure my

20     presence for the Assembly that actually put -- established the party and

21     that I did not attend?

22        A.   Yes.  And I was very sorry about that.

23        Q.   Is it true that no one from the republic level interfered in the

24     election of members of the Municipal Board and the municipal officials or

25     the president of the party at the -- at the municipal level?  Is it

Page 24513

 1     correct that no one interfered in that?

 2        A.   That's correct.  We self-organised without any assistance from

 3     the republic level.

 4        Q.   Thank you.  In paragraph 12, you talk about how there was

 5     insufficient understanding for you at the republic level.  Would it be

 6     more precise to say that there -- the presence and assistance from the

 7     federal and republic level was not sufficient and was not sufficiently

 8     present in -- in your local circumstances?

 9        A.   Other than the assistance that we got from Mr. Micevic - I

10     believe that was his name - which consisted of some propaganda, flags,

11     buttons and similar, there was no other assistance or support from the

12     republic level.

13        Q.   Thank you.  So you could say you established the party

14     single-handedly, and that you won in the election single-handedly;

15     correct?

16        A.   Yes.

17        Q.   Do you agree that at first, as you put it yourself, the powers

18     were also shared between Serbs and Muslims but without the patronage

19     of -- without the patronage of the League of Communists?

20        A.   After the elections, the Serbian Democratic Party and the SDA, as

21     the parties who one in the elections, shared in the local government.

22     You could say that we were coalition partners and everything was normal.

23     We both had, as our ideological opponent, the League of Communists, or as

24     it was later known, the SDP.

25        Q.   Thank you.  Is it correct that power was shared in accordance

Page 24514

 1     with good customs?  If the president of the municipality was a Muslim,

 2     then the president of the Executive Board would be a Serb.  If the chief

 3     of police station is a Muslim, then the police commander is a Serb.  And

 4     was that done at all levels where officials are elected and appointed?

 5        A.   Well, the power sharing took place according to the following

 6     principle:  All the different positions, offices, were listed, and then

 7     one side would choose a particular office, and then the other side had

 8     the right to choose another one.  And it all went on that way until all

 9     of the offices were distributed, all the positions.

10        Q.   Thank you.  And is it correct that all of this functioned

11     properly, more or less, until the cessation of Slovenia and Croatia --

12     or, rather, until they held their referendums and when these tensions

13     broke out in the western part of the country?

14        A.   That would be it roughly.  The reason was that there were

15     organised departures of Muslims from Bratunac.  The SDA organised their

16     trips to Croatia where they joined the ZNG and fought against the Serb

17     people.  Not a single case was recorded of a Muslim representative of the

18     people going and fighting on the side of the Serbs.

19        Q.   Or on the side of Yugoslavia.

20        A.   Or on the side of Yugoslavia.  You can put it that way as well.

21     That disrupted the relationship between the two coalition partners.

22        Q.   Thank you.

23             THE ACCUSED: [Interpretation] Could we please show the witness

24     D387.

25             MR. KARADZIC: [Interpretation]

Page 24515

 1        Q.   Do you remember that the chief of police in Bratunac was

 2     Senad Hodzic on behalf of the SDA?  He was a Muslim who was there on

 3     behalf of the SDA.

 4        A.   I know that Senad Hodzic was chief.

 5        Q.   I'd like to ask you to take a look at this document, and the

 6     second paragraph reads as follows:

 7             "In keeping with that, in a letter to the Bratunac

 8     Municipal Secretariat of National Defence, we requested a list of the

 9     free military conscripts according to local communes, respecting the

10     ethnic structure."

11             So in the first paragraph, a 100 per cent increase in the police

12     force was ordered.  Did you hear about that?  And this caused some degree

13     of suspicion among the Serbs?

14        A.   I don't remember that.

15        Q.   Thank you.  So in the second paragraph it says that they asked

16     the military department to say who was free out of the military

17     conscripts, and then it says:

18             "After we received the requested list and started making the

19     necessary checks, we obtained information that the list included a

20     certain number of Muslim military conscripts who have spent time in

21     Croatia on a part of the training within the MUP of Croatia.  We do not

22     know on whose orders or recommendation, but it is believed that Serb

23     citizens do not have enough trust in such future members of the reserve

24     police force," and so on and so forth.

25             Do you agree that this Muslim, the chief of the public security

Page 24516

 1     station, acted professionally, that he did not send these people because

 2     he knew and believed that that would have been detrimental for relations

 3     in Bratunac?

 4        A.   At that time it was still believed that co-existence could

 5     continue in Bratunac in harmony.  I understand the chief of the public

 6     security station when he made this assessment.

 7        Q.   Thank you.  Is it correct that in the town of Bratunac itself

 8     relations were is rather civilised and proper, whereas in villages

 9     extremism started to flourish and there was less of that in town?

10        A.   Well, that is a fact.  And I think that I could safely say that

11     that went both for the Serbs and the Muslims.  In town that was certainly

12     not the case, or, if so, to a very small degree.  People who had radical

13     views, groups that had radical views, ethnically speaking, all came from

14     rural areas.  There were even cases when they tried to impose these ideas

15     within the town itself in a violent manner.

16             One such situation was when a group of extremists, extreme

17     nationalists from Voljavica, entered town chanting, This is Bosnia.  They

18     were firing their guns into the air intimidating both Serbs and Muslims.

19        Q.   Thank you.  Is Voljavica a Muslim village?

20        A.   Voljavica is a Muslim village exclusively.

21        Q.   Thank you.  Is it correct that already at the end of August or

22     September, the 1st of September, a crisis broke out when the JNA wanted

23     to take its documentation from the military department in the

24     municipality, and about 10.000 Muslims assembled there and made that

25     impossible?

Page 24517

 1        A.   I would put it this way:  That that was one of the key moments

 2     that disrupted the coalition government of the SDS and the SDA, and at

 3     the same time it disrupted relations between the two ethnic groups.

 4        Q.   Thank you.  By then, were tensions felt in Bratunac, tensions

 5     that stemmed from what was happening on the political scene, primarily

 6     the efforts made by the SDA and other Muslim parties to have Bosnia

 7     secede from Yugoslavia?

 8        A.   At the time, there were other options that were there, and it was

 9     believed that Bosnia would remain within Yugoslavia.

10        Q.   Thank you.  Do you remember that throughout July and August there

11     were debates in the public that were well known and that there was this

12     agreement between the Muslims and Serbs that was reached?  It was

13     Adil Zulfikarpasic and Muhamed Filipovic that spoke on behalf of the

14     Muslims, and this was an historic Serb-Muslim agreement.  Is that what

15     you meant, because that envisaged that Bosnia would remain within

16     Yugoslavia?

17        A.   That's precisely what I meant, because I know of this agreement

18     and I believed it.  I believed that we would remain in a single state

19     after all.

20        Q.   Is it correct that we relented and allowed for the possibility of

21     Bosnia to secede on the condition that we are not out-voted, and that

22     what was envisaged within that context was the establishment of two

23     municipalities in Bratunac?

24        A.   That is correct, too.  I know that in the municipality of

25     Bratunac, with the agreement of the SDA and the SDS, there was a

Page 24518

 1     commission that worked on the division of the territory of the

 2     municipality of Bratunac to see where the Muslim majority was and where

 3     the Serb majority was.  In our area villages were either majority Muslim

 4     or majority Serb; whereas the town itself was split half and half,

 5     roughly.

 6        Q.   Is it correct that negotiations progressed very well and that in

 7     the Serb part of town, in the Serb villages, the Serbs would have their

 8     own authorities, and in the Muslim villages, in the Muslim part of town,

 9     the Muslims would have their own authorities?

10        A.   In my view, that was the kind of division that exist nowadays.

11     In some towns there are several different municipalities.

12        Q.   Thank you.  So a large part of the town infrastructure would

13     remain shared, and things would function like in a town with several

14     municipalities; right?

15        A.   Yes.

16             THE ACCUSED: [Interpretation] 1D1405.  Could we have that,

17     please, along with my apologies for the delay in the translation.

18             MS. WEST:  Mr. President, this is already admitted as D297 with

19     the translation.

20             JUDGE KWON:  Thank you.

21             THE ACCUSED: [Interpretation] Thank you from the Defence as well.

22             MR. KARADZIC: [Interpretation]

23        Q.   You have the Serbian version in Cyrillic.  It's handwritten.

24     Actually, could you please scroll up so that we see the bottom of the

25     page, because there's a stamp there, the Serbian version.

Page 24519

 1             Do you agree that what it says here is the Serb Republic of

 2     Bosnia-Herzegovina, the Serb municipality of Bratunac?

 3        A.   Yes.

 4        Q.   Do you agree that whenever a municipality had the prefix "Serb,"

 5     it meant that in that town there was also a Muslim municipality and

 6     perhaps even a Croat municipality, too, that this does not mean that all

 7     of Bratunac is a Serb municipality; rather, it is only part of Bratunac

 8     that is the Serb municipality; right?

 9        A.   I cannot answer that question with any degree of certainty.  This

10     is the stamp of the Serb municipality of Bratunac from the time when it

11     was expected that there would be a division of town in administrative

12     terms into two municipality, because we had two ethnic groups, two

13     peoples in Bratunac.

14        Q.   Thank you.  Can we have the next page to see what kind of

15     conclusions were reached then?

16             JUDGE KWON:  This is the last page.  Let's see page 1.  In B/C/S

17     as well.

18             MR. KARADZIC: [Interpretation]

19        Q.   Does it say here in paragraph 1 that representatives of both

20     peoples accept as a reality that the division process is a reality and

21     inevitable and agreed that it can be realised in a peaceful and

22     democratic way?

23        A.   Yes.

24        Q.   Thank you.  Further on, it says that the establishment of a Serb

25     public security station in Bratunac and the division of the existing

Page 24520

 1     public security station is the first step in that direction.

 2             Is it correct that the Muslim police remained in the existing

 3     building, whereas the Serb police selected another building as their

 4     temporary base?

 5        A.   That's right.

 6        Q.   I don't need to read out all of this, but you please take a look.

 7     Everything should be done in a democratic way, schools should start

 8     working again and all inhabitants return.  Does that mean that before the

 9     conflict broke out the population left, people belonging to both faiths?

10        A.   That's correct.

11        Q.   Did anyone expel them or were they fearful of the way things were

12     developing?

13        A.   They were leaving town for security reasons, because the security

14     situation had deteriorated.

15        Q.   Thank you.

16             THE ACCUSED: [Interpretation] Can we have the next page now in

17     Serbian.  I believe -- yes, yes.  Paragraph 11.  In English we should

18     also look at the next page.  Eleven.

19             MR. KARADZIC: [Interpretation]

20        Q.   It says:

21             "Equal numbers of Serb and Muslim policemen should be engaged."

22             Was that a measure to deal with the tension and suspicions?

23        A.   Yes.  To establish parity, so that no one would feel threatened.

24     Say if there were two times more policemen belonging to one ethnic group

25     or the other.

Page 24521

 1        Q.   Further on it says in 13 that the plans and tasks should be

 2     co-ordinated by both chiefs and that joint on-site investigations should

 3     be conducted, and so on and so forth.

 4             And the last paragraph says that disputes and problems should be

 5     resolved in a peaceful and democratic way; right?

 6        A.   That's right.

 7        Q.   Tell me, was the Serb side enthusiastic about the establishment

 8     of two municipalities?

 9        A.   The Serb side was primarily interested in avoiding conflicts and

10     in having problems resolved in a peaceful manner.  One of the ways in

11     which these problems could be resolved was what we saw, namely, the split

12     into two administrative entities.

13        Q.   Thank you.  Was it envisaged, was there any idea and would it be

14     possible to realise it that Muslims should be expelled from Bratunac?

15        A.   No.  That wouldn't work.  That couldn't be done.

16        Q.   They would get the same things that the Serbs did.  They would

17     have their own policemen, their administration, and so on and so forth;

18     correct?

19        A.   Yes, that's correct.

20             THE ACCUSED: [Interpretation] Your Honours, I see the time.

21             JUDGE KWON:  Yes.  We'll take a break for 50 minutes and resume

22     at 1.35.

23                           --- Luncheon recess taken at 12.42 p.m.

24                           --- On resuming at 1.37 p.m.

25             JUDGE KWON:  Yes, Mr. Karadzic.

Page 24522

 1             THE ACCUSED:  Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Mr. Katanic, I'll try to go through this as fast as possible, the

 4     things that happened in 1991 and the beginning of 1992.

 5             In paragraphs 11 -- or, rather, 13 through 16, you spoke about

 6     Crisis Staffs, even in 8 as well, the Crisis Staff of the party.  Do you

 7     agree that there is a distinction between a Crisis Staff of the party

 8     that can only provide information and the Crisis Staff of the

 9     municipality that consists of people from the authorities?

10        A.   Absolutely correct.

11        Q.   In paragraph 16, you say that you did not know what the criteria

12     were, but it was formed as stated in the instructions:

13             "Some people became members of the Crisis Staff based on the

14     duties they already performed."

15             That's paper A and B, those instructions, we'll get to that

16     later?

17             Let me ask you another thing:  In our country, in our culture, if

18     you will, that before and after situation like this, for example, the

19     snow that fell now, when there's a crisis, the -- all the potentials of

20     the state are mobilised and called a Crisis Staff, say when there's a

21     flood or when there's a lack of electricity, any kind of crisis.  Do the

22     authorities focus then and start functioning as a Crisis Staff?

23        A.   That is correct.  Whenever a state of emergency is imposed.  And

24     I came to testify now from that kind of a situation, when a state of

25     emergency was imposed because of the snowfall.  Crisis Staffs are

Page 24523

 1     established, and they operate for as long as the state of emergency is in

 2     place.

 3        Q.   Thank you.  Now, do you agree that for 20 years, until 2011, you

 4     were convinced that the meeting of the Municipal Board of the SDS on the

 5     23rd of December, 1991, was convened because of something that was the

 6     result of some agreement with Izetbegovic or a result of the conference,

 7     and then someone offered you the possibility that this meeting had been

 8     convened because of paper A and B; right?

 9        A.   My answer to this question would be I do not remember, because I

10     got a document that was authentic from the session of the

11     Municipal Board, that is.  The document is actually the minutes of that

12     meeting.  It includes the agenda, and basically I confirmed the

13     authenticity of that document which shows what it was that was discussed

14     at that meeting.

15        Q.   Thank you.  As a person who organised and technically prepared

16     meetings, would you agree that usually the reason for convening a meeting

17     is stated in the first item on the agenda and then the other items

18     follow?  So it would be compulsory to have this in item one, and the rest

19     is optional; right?

20        A.   Yes, that's right.  And the last item is miscellaneous.

21        Q.   Thank you.  Now, let us cast a glance at the agenda in this

22     document.

23             THE ACCUSED: [Interpretation] Can we call it up?  Can the

24     Prosecution assist us with this?  It's a document of theirs.  It's been

25     admitted as a P document, the meeting of the 23rd of December, 1991.

Page 24524

 1             JUDGE KWON:  Is it P2598, appearing in para 15?

 2             THE ACCUSED: [Interpretation] I'm trying to find it.  Sorry about

 3     that.  P2598.  Yes, that would be it.

 4             JUDGE KWON:  We have 15, para 15, in front of us, minutes of

 5     23rd of December, P2598.

 6             THE ACCUSED: [Interpretation] Yes, yes.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   In this paragraph, you say -- I'm going to read it out in English

 9     because they'll interpret it better that way:

10             [In English] "I was shown minutes of 23rd of December, 1991, and

11     asked what I remember about the meeting and the instructions presented to

12     the board.  These minutes are accurate, as far as I can recall.  I was

13     also shown a document entitled 'Instructions for the Organisation and

14     Activity of Organs of the Serbian People in Bosnia-Herzegovina in a State

15     of Emergency,' dated 19th of December, 1991."

16             [Interpretation] So a bit further down you say:

17             [In English] [As read] "when I was first asked about these

18     instructions at my interview in May 2011, I first thought they related to

19     agreement between Karadzic and Izetbegovic.  Having reviewed them and

20     refreshed my memory, it is clear that the instructions were not based on

21     any agreement with Izetbegovic.  Rather, those were instructions from the

22     SDS party leadership on what to do and how to react in 20 -- in a certain

23     conditions and -- at that time."

24             [Interpretation] Let us now take a look at D86, 00086, that is,

25     and see -- actually, we can see it here as well.  Item 1 on the agenda,

Page 24525

 1     yes.

 2             A decision was made to establish a Serbian B and H.  Yes, that's

 3     it.  So the first item says that a decision was made to establish a

 4     Serbian B and H; right?

 5        A.   Yes, that's right.

 6        Q.   Do you agree that this decision was not made at a party meeting

 7     held on the 19th of December but rather at the Assembly of the Serb

 8     people on the 21st of December?

 9        A.   I do not remember the date, but the decision to establish a Serb

10     BH was established -- was made at the Assembly.

11        Q.   Thank you.

12             THE ACCUSED: [Interpretation] Can we now have a look at D00086.

13     In Serbian, it's page 28.  Maybe -- maybe 28.  Actually, let's see.  152

14     are the last three digits of the ERN number.  And in English it's 14.

15     One page further up in Serbian, please.  And in English it's page 14.

16             MR. KARADZIC: [Interpretation]

17        Q.   Actually, sorry, on the first page, it says:

18             "The 4th session of the Assembly of the Serb people in

19     Bosnia-Herzegovina, the 21st of December, 1991."

20             Is that right?

21        A.   That's right.

22        Q.   Can we have the next page in Serbian and in English page 14.

23     Yes.  Please.  Take a look at the bottom of the page.  Could we see the

24     bottom of the English version and this one.  It says here:

25             "Proceeding from the constitutional right of peoples to

Page 24526

 1     self-determination, the Serb -- the Assembly of the Serb people in

 2     Bosnia-Herzegovina, at the session held on the 21st of December, 1991, is

 3     adopting a decision to establish a Serb Republic of Bosnia and

 4     Herzegovina."

 5             And we see that in English as well.

 6             Is it clearer to you now that this meeting on the 23rd was

 7     convened in relation to this, not in relation to what had happened on the

 8     19th?  Does it look more logical to you now that this was the reason, not

 9     what happened on the 19th?

10        A.   I personally do not remember, but it's possible that this was it,

11     bearing in mind the item on the agenda and this event that had to do with

12     the establishment of the Serb Republic of Bosnia and Herzegovina.

13        Q.   Thank you.  Is it likely that during that meeting Variants A or B

14     were discussed?  Did you see a registration number, a signature, or a

15     stamp on Variant A or B?

16        A.   I do not remember that.  I remember the instructions, and I

17     remember -- I remember that there were variants where the Serb people

18     were a minority, and then there were others where the Serb people were a

19     majority.  We were in a situation that meant that we were in a minority,

20     because the Serb population in the territory of the municipality of

21     Bratunac was a minority then.  That is to say that the second variant

22     applied in our case.

23        Q.   Thank you.  Do you agree that the Crisis Staff and the party was

24     formed a bit earlier in 1992 and in the municipality perhaps only on the

25     2nd or the 3rd of April when it was obvious that there would be a war?

Page 24527

 1        A.   It is correct that the Crisis Staff of the municipality of

 2     Bratunac was established after the Crisis Staff of the party was

 3     established.

 4        Q.   Thank you.  Now that we're dealing with these paragraphs,

 5     paragraph 18 refers to a meeting held in the party on the

 6     24th of February, 1992, and I'm going to read it out in English so that

 7     it's interpreted better:

 8             [In English] [As read] "At first I could not recall this meeting

 9     [indiscernible], but now that I read the document, those events from that

10     time have started to come back to me.  The outcome of this meeting and

11     the measures discussed at that meeting, that is the implementation of the

12     measures of the second level of the instructions were not something that

13     was typical just for Bratunac, rather, this meeting and the outcome

14     something that was -- was essentially the result of the overall situation

15     in Bosnia and Herzegovina just transposed to Bratunac."

16             [Interpretation] Now, that's the document that they showed you,

17     but do you remember somehow things developed, and do you remember that

18     the SDA was negotiating but also preparing for war and that this solution

19     was indispensable as a measure aimed at protection against a Muslim

20     attack?

21        A.   As far as I can remember, the first measure that we introduced

22     was duty service and providing information to local boards about the

23     situation in general and the security situation in the municipality.

24     When the situation worsened, then President Deronjic scheduled this

25     meeting, and then another measure was introduced that had to do with the

Page 24528

 1     security situation at the time, the situation that had deteriorated.

 2             In order to overcome that, guards -- or guard duty was

 3     introduced, and the suggestion made was for the population to obtain food

 4     supplies.

 5        Q.   Thank you.  Is it true that Serbs and Muslims guarded their

 6     apartment buildings together, whereas in villages they all had their own

 7     guards?

 8        A.   That is correct.  That's how it was at the beginning.

 9        Q.   Thank you.  Do you know that this phase two was introduced into

10     various municipalities at different times based on their own local

11     assessments?  Do you recall that there was any instruction to the effect,

12     Now you are to implement this and now you should implement that?

13        A.   [No interpretation]

14        Q.   [No interpretation]

15             JUDGE KWON:  I'm sorry.  My apologies.  We didn't have the

16     interpretation.  Could you repeat your question, Mr. Karadzic -- or we

17     didn't hear the interpretation of the previous answer from Mr. Katanic.

18             Could you repeat your answer kindly, Mr. Katanic, to the

19     question:

20             "Do you recall that there was any instruction to the effect, Now

21     you are to implement this and now you should implement that?"

22             THE WITNESS: [Interpretation] There was just that one instruction

23     that we implemented.  As for any subsequent instructions or monitoring of

24     how those instructions were being implemented, there was no such thing.

25             MR. KARADZIC: [Interpretation]

Page 24529

 1        Q.   Thank you.  Now, as I'm moving through these paragraphs, would

 2     you please look at paragraph 19.  You were shown minutes from a meeting

 3     of February 1st, 1993 - that's 65 ter 00593 - and then it goes on to say

 4     what was said at that meeting.

 5             Is it correct that because of the police failure to maintain law

 6     and order and fight looting, a request came from me -- or, rather, from

 7     us to actually vote on confidence in the authorities?  So to take a vote

 8     of confidence in the Assembly.

 9        A.   I don't recall that there was any request for a vote of

10     confidence on the then-government, but I do remember the meeting.  I

11     organised it, and we also had guests who were invited to attend that

12     meeting or the Assembly session.  And the reason was that one of the

13     items on the agenda was this vote of confidence, a vote of confidence in

14     the Municipal Board and the authorities in Bratunac municipality.

15        Q.   Thank you.  So the party was trying to check whether those people

16     who were in authority, whether they were doing their job properly and

17     whether they still enjoyed trust?

18        A.   That's correct.

19        Q.   Well, at this meeting, which could be interpreted to be in the

20     function of the pre-election period, was that used in order to actually

21     bring into question those people who were in -- in power at the time?

22        A.   The introductory remarks by Mr. Deronjic could be interpreted as

23     bragging, which was not unusual -- which was not unusual in situations of

24     a vote of confidence.

25        Q.   Well, when this vote of confidence was taken, did some people

Page 24530

 1     actually gain -- retain their positions and some people had to resign?

 2        A.   Well, everybody was voted in except for the chief of police,

 3     Mr. Luka, who was voted out because in the preceding period, it was found

 4     that there had been a lot of crime and that they -- the crimes could have

 5     been prevented had more effort been put into it.

 6        Q.   Thank you.  And then subsequent to this, he resigned; correct?

 7        A.   He was replaced by Ljubisa Borovcanin.  And as for him, I don't

 8     know if he resigned or whether he was just fired.

 9        Q.   Thank you.  Now, is it correct that you had occasion to

10     experience the situation where the Muslim formations, the

11     Patriotic League and the Green Berets, created an atmosphere of

12     insecurity, because there were a lot of incidents on the eve of the war

13     which contributed to the exacerbation of the crisis.  There were several

14     incidents, some people were killed.  Do you remember that?

15        A.   Well, I've already mentioned the case where a group of Muslims

16     from Voljavica came into town and intimidated the population.

17        Q.   Thank you.  Do you remember as of 21st of March that there were

18     several attacks, and all this is from the Muslim sources on the

19     24th March in Buljim; 25th of March, Orahovac and Bukova Glava; and 25th

20     of March in Zeleni Jadar where allegedly ten Chetniks were killed.  Do

21     you remember that in Zeleni Jadar, before the month of April, some

22     workers, some forestry workers were killed?

23        A.   I don't recall that.

24        Q.   Thank you.  Do you remember that until April 15th -- or before

25     April 15th there was an offensive on Konjevic Polje?  Do you remember

Page 24531

 1     that on the 3rd of April a JNA depot was blown up, a JNA depot in

 2     Nova Kasaba?

 3             Was this a crisis situation, and before the 17th of April, did

 4     they have an initiative?

 5             JUDGE KWON:  Yes.

 6             MS. WEST:  Sorry to interrupt, but there are, I think, four or

 7     five questions in that.  I don't know how the witness can keep up.  I

 8     certainly cannot.

 9             JUDGE KWON:  Yes.

10             MR. KARADZIC: [Interpretation]

11        Q.   All right.  I don't need an answer to these individual incidents.

12             Now, do you agree with me that at that time the

13     Party of Democratic Action was the one who actually created this crisis,

14     critical situation with all these incidents?

15        A.   Well, I do recall some situations where some radical Muslim

16     elements intimidated the Serb population.

17        Q.   Thank you.  On the 17th of April, is it correct that some

18     saviours all of a sudden appeared, some members of paramilitary groups,

19     that they took control of Bratunac, they suspended the Assembly and took

20     over?

21        A.   The date is correct.

22        Q.   Thank you.  Did they appear -- did they make the first appearance

23     as volunteers and then they became renegades from the JNA, and they were

24     in villages and towns, but they were not anywhere in the woods?

25        A.   When they first came to town, they presented themselves as

Page 24532

 1     volunteers of the Serbian people, and they came to help.  They came

 2     armed, and any group that had arms was an armed force and wanted to take

 3     power, which created major difficulties for the municipal authorities.

 4        Q.   Thank you.  You confirmed, and you mentioned this in your

 5     statement, but also in the interview you confirmed that the authorities

 6     immediately tried to get rid of these volunteers and that people became

 7     anxious and upset, especially the women, who -- because the men had

 8     already joined the army, because they felt that they would be threatened

 9     because of these volunteers, by Muslim extremists; is that correct?

10        A.   That's correct.  They even organised a protest rally in front of

11     the municipal building, these women, and they physically attacked the

12     president of the Executive Committee, Radoljub Djukanovic.

13        Q.   He was a member of the SDS, and he was opposed to these

14     paramilitary groups; correct?

15        A.   Yes.  The decision was taken at the Crisis Staff meeting, a

16     decision that these volunteers were no longer welcome.

17        Q.   Thank you.  During your interview, you said that the authorities

18     would have gotten rid of them and opposed them had they had the strength

19     and the power, and that in Bratunac five to ten armed men already

20     represented an armed force for the authorities the way they were.

21        A.   Yes, that's correct.

22        Q.   Thank you.

23             THE INTERPRETER:  Microphone, please.  The interpreters cannot

24     hear the speaker clearly.

25             JUDGE KWON:  Could you repeat.

Page 24533

 1             MR. KARADZIC: [Interpretation]

 2        Q.   I will read this out in English, because we're not happy with the

 3     interpretation of what the witness said:

 4             [In English] "Yes, the decision was taken at the Crisis Staff

 5     meeting, a decision that these volunteers were no longer welcome."

 6             [Interpretation] Were they ever welcome?

 7        A.   In the beginning, they were welcomed, because the Serb people had

 8     already been scared because of the Muslim extremists who made their

 9     appearance from time to time from the rural areas.

10        Q.   Am I correct if I say that they were welcome when they said that

11     they were JNA volunteers but that the welcome was withdrawn when they

12     stopped being JNA volunteers, when they reneged and become an independent

13     armed force?

14        A.   We considered every volunteer to be welcome if they were at the

15     disposal of the JNA at the time when it was in Bratunac or if they joined

16     the Bratunac Brigade, which was later established.  All those who came on

17     their own and acted in their own interest, they were not welcome.

18        Q.   Thank you.  In paragraph 24, there's talk about disarming, and it

19     is described that this was done by the Yugoslav People's Army.  Can we

20     agree that the Yugoslav People's Army was a legitimate force all the way

21     until the 19th of May, 1992, whereas in this paragraph the date mentioned

22     is the 19th of April, 1992?

23        A.   I don't recall by what time the Yugoslav People's Army was

24     considered a legitimate force in Bosnia-Herzegovina, but it's documented,

25     and, as such, it is a fact.

Page 24534

 1        Q.   Thank you.  Now, in this paragraph you talk about parts of the

 2     Novi Sad Corps that were stationed there on their way -- on their way

 3     back from Bosnia and Herzegovina and that the commander was

 4     Captain Reljic, and that this unit collected weapons that were held by

 5     civilians.

 6             Now, do we agree that in our system, according to the Tito

 7     doctrine, an armed populous, the doctrine -- the doctrine of an armed

 8     populous meant that any worker, any factory, had arms and could be armed?

 9        A.   That's correct.  The doctrine was that the entire population was

10     the army.  That was the doctrine from the previous Yugoslavia.

11        Q.   Thank you.  Now, in this paragraph you say that the weapons were

12     collected in local communities, and then in the last sentence it says:

13             [In English] "In practice, only the Muslims were being disarmed."

14             [Interpretation] Now, I would like to ask you this, and I would

15     like you to tell us what your position is:  Was the crucial question here

16     their -- or was the determining factor their faith or the fact that they

17     refused to respond to the mobilisation call-up?

18        A.   Religious affiliation had nothing to do with it.  In 1991, the

19     SDA organised an attempt to prevent the JNA to collect the military

20     booklets of all conscripts in the municipality of Bratunac.

21        Q.   It was a sign to the JNA that the people in Bratunac did not

22     gather spontaneously but that they were organised.

23        A.   Precisely.  They were organised.  The SDA invited the Muslim

24     people not to respond to JNA call-ups.

25        Q.   Am I correct in saying that the Crisis Staff in Bratunac also had

Page 24535

 1     a negative position on the formation and arming of paramilitary

 2     formations irrespective of religious affiliation or ethnicity.

 3             To that end, I would like to call up 1D4094, a document of the

 4     Crisis Staff.

 5             So no distinction was made in terms of ethnicity or religion.

 6     Whoever was part of a TO, JNA unit, was part of the legitimate armed

 7     force, whereas the rest were not.  1D4094, 1D4094.

 8             Am I right in saying that?

 9        A.   Yes, you are.

10        Q.   This is the cover page.  It reads:

11             "Order forbidding all paramilitary formations to be active in the

12     territory of Bratunac municipality."

13             I think the second page is empty.  Perhaps we can move to the

14     third page immediately.

15             THE ACCUSED: [Interpretation] Can we zoom it in, please, in both

16     versions.

17             MR. KARADZIC: [Interpretation]

18        Q.   Is it correct that as early as the 1st of May, the Crisis Staff

19     used a Cyrillic typewriter?  That is to say, the Serb municipality

20     forbade the existence and activity of all paramilitary formations in the

21     municipality of Bratunac.  Is that the gist of the document?

22        A.   Yes.  And not only paramilitary formations but individuals as

23     well; that is to say people who possessed weapons illegally and were --

24     and were active on their own.

25             THE ACCUSED: [Interpretation] Thank you.  I seek to tender this

Page 24536

 1     document.

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  Exhibit D2060, Your Honours.

 4             THE ACCUSED:  2060.  [Interpretation] Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Is it correct that on the 3rd or 4th of May in Hranca a JNA

 7     convoy was stopped withdrawing towards Yugoslavia?  It was attacked and

 8     several young soldiers were killed?  Is Hranca in the outskirts of

 9     Bratunac?

10        A.   Hranca is 2 kilometres away from Bratunac.  There was an incident

11     at that time, but I no longer remember details.

12        Q.   Thank you.  Is it correct that Judge Zekic was killed on the

13     8th of May?  And as you have described him, he had been a prominent

14     person.  As you say in paragraph 27, he was a judge and an Assembly

15     deputy.  He was killed on the 8th of May.

16        A.   That is correct.  Goran Zekic enjoyed the trust of the Serb

17     people not only in Srebrenica, because he hailed from Srebrenica, but he

18     enjoyed the trust of the people of the whole region.  As you probably

19     know, he was a people's deputy in the B and H Assembly.

20        Q.   You had -- you informed us that you had an objection to

21     paragraph 26 and the way operation Glogova was described, where it was

22     called an attack.  You said you believed it to be -- to have been

23     directed at disarming the people who caused a number of incidents we

24     referred to previously.

25        A.   I'll have to expand on this so as not to say yes or no only.

Page 24537

 1        Q.   Feel free.

 2        A.   I took part in that operation as a TO member.

 3     Mr. Miroslav Deronjic was with me in the same capacity, in civilian

 4     clothes.  We were told that it was our task to guard a perimeter towards

 5     Glogova on the Srebrenica side in case someone tried to flee with weapons

 6     to Srebrenica.  It was the last thing on my mind that it was supposed to

 7     be an attack on Glogova, because any attack would have to commence with

 8     artillery fire followed by the infantry.  We were not ready or trained

 9     for that.  Simply, our task was to guard the line so that no one could

10     flee with weapons.

11             The JNA, which was trusted by the Serb people, entered Glogova on

12     a -- on a paved road.  They arrived in the centre of Glogova with the aim

13     of disarming the people who had not handed in their weapons.  It was

14     assessed that there were a lot of weapons in Glogova.

15        Q.   Thank you.  You didn't know then that there were going to be some

16     killings, and even after the fact you were still unaware of it for a

17     while?

18        A.   The only thing that I can say to that is it is correct.

19        Q.   You discussed that in paragraphs 37 and 38, as well as 39.  In

20     paragraph 38 you say:

21             [In English] "I have been told that what Deronjic stated and pled

22     guilty to is that the purpose of the Glogova operation was to remove the

23     Muslim population of Glogova from Bratunac municipality.  That is the

24     conclusion I, myself, made after the operation, but that is not something

25     I knew during the operation."

Page 24538

 1             [Interpretation] Paragraph 37, the last sentence is:

 2             "[In English] My assumption at the time was that the purpose of

 3     the operation was to gather people and not to expel them."

 4             [Interpretation] In your opinion, what Mr. Deronjic pleaded

 5     guilty to, does it stray from everything you knew at the time?

 6        A.   I didn't know that the aim was to expel the Muslim population

 7     from Glogova, which is something Mr. Deronjic pleaded guilty to.

 8        Q.   Did he confess that to you before he did to the Court or did you

 9     only learn of the fact of his plea following the fact here?

10        A.   I have only learned of it once he pleaded guilty to it before the

11     Tribunal.

12        Q.   Thank you.  Later on there was another group -- well, Makedonac

13     was part of the first group at the beginning of the war; correct?

14        A.   Yes.

15        Q.   So they beat up people, slapped people around, tied up prominent

16     citizens and paraded them through town; correct?

17        A.   No.  It wasn't Makedonac's group that did that.  It was done by

18     the group where Mijovic was later on.

19        Q.   Oh, so it's the second group.  They also terrorised; correct?

20        A.   Yes.

21        Q.   Is it true that you escorted Mr. Deronjic at a meeting where he

22     sought my support and the support of others to have the group driven out

23     of Bratunac?

24        A.   That is correct.  That was after they began detaining people in

25     their premises.  And the people they detained were not only ordinary

Page 24539

 1     citizens but also members of the both civilian and military authorities.

 2     They detained them and physically mistreated them.  Even Mr. Deronjic was

 3     detained, and physically mistreated, as well as I.

 4        Q.   In paragraph 53, you say that they even put a gun to your head

 5     and that they mistreated you and that your life was in danger; is that

 6     correct?

 7        A.   This does not pertain to the group commanded by Mijovic.  He

 8     threatened to kill Mr. Deronjic, even took him to the Drina River to kill

 9     him there, but it turned out to be intimidation only, to put pressure on

10     him.  I was threatened with a gun by the group where Makedonac was when I

11     tried to have several Muslim families evacuated from Bratunac.  One of

12     the Muslims involved was my best man, Edhem Grahovac.

13        Q.   Is it correct that the Serbs at the time, the Serbs from

14     Bratunac, were trying to protect the Bratunac Muslims from these people

15     and that it was very dangerous to attempt that?

16        A.   It is correct that it was dangerous.  Despite that, many Serbs

17     decided to help their co-citizens.

18        Q.   And you managed, or, one of your relatives managed to save

19     several people; correct?

20        A.   Well, it would be quite a list of such examples.  I'll only

21     mention one.  The Defence commander in Kravica smuggled out a person by

22     the name of Ahmic in the trunk of his car.  His nickname was Siledzija.

23     He took him to Kravica.

24        Q.   Which was a Serb village.

25        A.   Yes.  And the next day, he safely escorted him to the territory

Page 24540

 1     controlled by the Muslim forces.

 2        Q.   In paragraph 41, you say that you were asked whether Muslims were

 3     forced to leave Bratunac municipality, and you said that they had no

 4     choice, because if they had stayed, they probably would have been

 5     mistreated and even killed.

 6             Can we agree that they were driven away by fear and the events

 7     themselves, or were they driven out by the authorities who knocked on

 8     their doors and said, Pack up?

 9        A.   Perhaps the best answer to that question would be if I said that

10     if I were Muslim, I, too, would have left Bratunac most likely, as it was

11     unsafe to be Muslim in the town, and the authorities had no means to

12     protect them.

13        Q.   Thank you.  You said something similar about Srebrenica 1995, and

14     I will find where exactly, where you say that no one told them that they

15     should leave, that they had the option to remain.  So were they told that

16     they could not be protected or did they reach that conclusion themselves?

17        A.   That was the decision taken by representatives of the Muslim

18     people.  They probably consulted with their own people and decided to

19     leave Srebrenica, although they also had the option to remain.

20        Q.   Thank you.  Can we take a look at 1D4104.  This is a review of

21     the various important decisions and orders issued by the War Presidency

22     and the Crisis Staff of Bratunac municipality.  It was published -- 4104.

23     1D4104.  This is not the document.

24             Can we now see the next page, and I'd like to see whether you

25     remember that these were the decisions by the municipal authorities and

Page 24541

 1     that this was their position.  The English is okay.  No, we need the

 2     B/C/S, the Serbian page.

 3             For instance, the third from the top:  "Decision to disarm

 4     civilians who possess weapons in Bratunac municipality," and this really

 5     applied to Serbs more than to Muslims in September 1992; is that correct?

 6        A.   Yes, that's correct.

 7        Q.   Could we now see the next page, please.  Here it says:  "Decision

 8     for all paramilitary formations to leave Bratunac municipality," and this

 9     was on the 6th of May, two days before the killing of Goran Zekic;

10     correct?

11        A.   That's correct.

12        Q.   And then let's skip the next one, and then we see the one after

13     that is a decision to accommodate refugees from Srebrenica and other

14     municipalities, and here already we see that we're on the 8th of May.

15             Could you tell us what the flow of refugees looked like in

16     Bratunac, and how did that affect the safety and security of both Muslims

17     and Serbs?

18        A.   Before the refugees began arriving, there were -- or, actually,

19     the influx of refugees came in waves.  They did not all arrive at the

20     same time.

21        Q.   Thank you.  Is it correct that it says here that they will be

22     accommodated in abandoned houses temporarily while they're engaged by

23     Bratunac TO.  They must maintain and secure the houses where they're

24     accommodated with all the property found there.  In other words, they

25     were not given that property.  They were just allowed to use it

Page 24542

 1     temporarily.

 2        A.   That's correct.  The abandoned houses had been registered by the

 3     municipal authorities and sealed off.  Later on, they were used to

 4     accommodate refugees pursuant to this decision on the proviso that they

 5     should maintain and secure all the -- the house and the property there.

 6        Q.   Thank you.  Can we see the next page, please.  Here toward the

 7     bottom in Serbian we see there's an order to prohibit the operation of

 8     all paramilitary units in the municipality.  That is a decision of

 9     May 1st, 1992, that we've already seen.

10             Can we see the next page, please.  During this period, is it

11     correct that it was impossible to get from Bratunac to Pale?  The only

12     way out, the only open route, was to Serbia.

13        A.   Well, it was possible to get to Pale, but it was dangerous.

14        Q.   Thank you.  Now, let's take a look at this, an order prohibiting

15     the serving and use of alcohol in Bratunac municipality; order

16     prohibiting looting, smuggling and corruption; order on temporarily

17     accommodating refugees and uncared-for individuals in abandoned houses

18     and buildings; and then at the bottom, order prohibiting bringing alcohol

19     to the territory.  So were all these measures and decisions taken in

20     order to improve the security and safety of citizens?

21        A.   That's correct.  As I've already said, I was a member -- I was

22     the owner of the Caesar cafe, and at the time, it was prohibited to serve

23     hard liquor.

24             THE ACCUSED: [Interpretation] Thank you.  Would I like to tend

25     this document.

Page 24543

 1             JUDGE KWON:  Yes.  We'll admit it as Exhibit D2061.  In the

 2     meantime, Mr. Karadzic, for the planning purpose, can I ask how much

 3     longer you need.

 4             THE ACCUSED: [Interpretation] I hope that I can complete by ten

 5     minutes past 3.00, but perhaps I'll be able to do it even sooner.

 6             JUDGE KWON:  I take it you have re-examination, Ms. West.

 7             MS. WEST:  I do, Your Honour.  I have up to ten minutes and it

 8     might be shortened as well.

 9             MR. TIEGER:  And, Mr. President, sorry, I just need literally one

10     minute at the end of the session to address a matter in private session.

11             JUDGE KWON:  Just a second.  Could the Registrar approach the

12     Bench.

13                           [The Trial Chamber and Registrar confer]

14             JUDGE KWON:  Yes, we'll sort out a way to deal with it, but in

15     the meantime please continue, Mr. Karadzic.

16             THE ACCUSED: [Interpretation] Thank you.

17             MR. KARADZIC: [Interpretation]

18        Q.   In paragraph 77, you talk about -- and I will read it out for

19     better interpretation, the third line:

20             [In English] "I am convinced that there would have been a will by

21     the police bodies to protect the Muslim population who would have stayed

22     in Srebrenica, but despite this will, I do not believe that police would

23     have been in a position to offer a guarantee that the Muslim population

24     would have been safe and secure."

25             [Interpretation] But they weren't told, Stay, but we can't

Page 24544

 1     guarantee your safety.  Rather, your conclusion was that the police was

 2     not very strong; is that correct?

 3        A.   That's correct.  The police was strong and powerful, but the

 4     situation was such that I don't believe that they would have been able to

 5     prevent possible acts of vengeance.

 6        Q.   Thank you.  You speak about possible acts of vengeance because of

 7     what had been happening the previous three years; correct?

 8        A.   Yes.

 9        Q.   Were the Muslims themselves afraid that this might happen even to

10     those people who had not committed any crimes or atrocities?

11        A.   Well, I assume that -- I believe that that was one of the main

12     reasons when people assessed this decision and when they made this

13     decision to leave Srebrenica.  I believe that was the strongest reason.

14        Q.   Thank you.

15             JUDGE KWON:  Mr. Karadzic, we'll continue until 3.00, and if

16     necessary, we'll have another 15 minutes after having a 15-minute break.

17             THE ACCUSED: [Interpretation] I hope so.  I will do my best to

18     complete by 3.00.

19             JUDGE KWON:  Thank you.

20             MR. KARADZIC: [Interpretation]

21        Q.   Now I would like to ask you about an incident of 1995, or,

22     rather, the events in the school.  It was shown here, and I want to check

23     whether you knew anything about it, it was said here that on the 14th,

24     after the prisoners were evacuated from the school, bodies were found in

25     every of the -- every one of the 16 classrooms.  There would be one or

Page 24545

 1     two or up to three bodies, which would mean that there would be up to 60

 2     people -- 60 dead bodies there.  Do you know whether they had been killed

 3     after the evacuation of most of the prisoners or were they killed during

 4     the incarceration and detention?

 5        A.   Well, I heard of the events in the school.  I heard about that

 6     later on from my family or relatives, because we live in the vicinity of

 7     that building, very close to it.  I did not know the scale of the

 8     incident and the crime there that occurred at the school, but I asked

 9     around.  I asked the people who knew about it, and I learnt that there

10     were about 30 dead.

11        Q.   Did you hear of any information whether they were killed while

12     they were detained, or were they brought in the course of the night and

13     then killed one, two, or three per classroom, because I'm a bit confused.

14     If they were killed, why would that be done in multiple classrooms if

15     they were brought to one place?

16        A.   I wouldn't know.  All I heard was that there had been an

17     incident, that a group had tried to escape.

18        Q.   Thank you.  Is it possible that they were killed in their attempt

19     to escape and then their bodies brought -- taken back to the classrooms?

20        A.   That's possible.

21        Q.   In paragraph 56, you recall that I visited Srebrenica on the

22     4th of August, 1995.  Do you remember whether this was a religious event

23     and that I did not come to the municipal building, nor did I go anyplace

24     else?

25        A.   I do remember that event.  Mr. Deronjic asked me to clear up an

Page 24546

 1     office at the cultural centre where we could receive you, where you could

 2     visit.

 3        Q.   Thank you.  You say that we walked to the church together.  Now,

 4     what was the -- what was the condition, the state of this church in

 5     Srebrenica when we got there?

 6        A.   I did not accompany you to the church, and I don't know what kind

 7     of condition it was in.  I know that it had been devastated, but I don't

 8     know to what extent.  I remained -- I returned to Bratunac while you

 9     attended -- there was some kind of ritual, I don't know what to call it,

10     because there was a very religious woman there who had a vision of some

11     sort, and she said that there should be a cross put up in the Old Town,

12     and the cross should face some other town, I don't know exactly which

13     one, which would then protect this area and the Serbian people.

14        Q.   Thank you.  So was this the lifting of the cross a tradition that

15     dates all the way back to Emperor Constantine and his mother, the

16     Empress Helena?

17        A.   I don't know anything about that, but I do know that this

18     happened as I described it.

19        Q.   Thank you.  Now, in paragraph 98, you talk about reburials, and

20     you say that you were asked in October -- in September and October

21     1995 -- or, rather, whether in September or October 1995 you issued some

22     quantities of fuels meant for some reburials.  I will read it out in

23     English:

24             [In English] "I did not, but as a citizen and as many other

25     citizens, I could notice that these bodies were relocated from Glogova."

Page 24547

 1             [Interpretation] So am I correct if I say that somewhere in

 2     Glogova, and you don't know the exact location, people who had been

 3     killed in Glogova were buried in May 1992, and that in July 1995, at

 4     least everyone who died then, who was killed then, was buried in Glogova

 5     as well as the victims from Kravica?

 6        A.   Well, it can be assumed that there were victims in Glogova from

 7     both 1992 and 1995.

 8        Q.   Do you agree that the civilian protection had the duty to

 9     sanitise the terrain throughout the war and that after every battle the

10     civilian protection would have to bury both our and enemy soldiers?

11     Well, not in the woods but in towns.

12        A.   Well, that was their responsibility.

13        Q.   Did you get the impression that the perpetrators of these crimes

14     openly bragged about these things, or was it your impression that they

15     were trying to conceal this from the authorities, that they made an

16     effort to conceal it from the authorities?

17        A.   The incident discussed there, the relocation of the bodies, that

18     is something that I did not see.  I did not see the bodies on the trucks,

19     but I did see the trucks, and I heard comments of my fellow citizens that

20     bodies were being relocated from Glogova.

21        Q.   Well, I meant in general terms, any crimes.  Did the perpetrators

22     move around freely and bragged about them, or did they try to conceal it

23     from the authorities?

24        A.   Well, no one would want to brag about crimes they committed.

25        Q.   So the authorities, the police, and the military command, they

Page 24548

 1     were unaware because this was concealed from them; is that correct?

 2        A.   If one committed a crime, I know that they could not publicly

 3     brag about having committed that crime.

 4        Q.   Thank you, Mr. Katanic.  I'm trying my best to return before your

 5     daughter's birthday.  I'd like to thank you for your testimony, and give

 6     my regards to Bratunac town.

 7        A.   Thank you, I will.

 8             JUDGE KWON:  Yes, Ms. West.

 9             MS. WEST:  Thank you, Mr. President.

10                           Re-examination by Ms. West:

11        Q.   Sir, you were just asked about this visit of Mr. Karadzic's to

12     Srebrenica on August 4th.  You remember that; correct?

13        A.   Yes.

14        Q.   Was General Krstic in Srebrenica on that visit as well?

15        A.   I don't think so.  I didn't see him.

16        Q.   Okay.  The other issue that I wanted to address, Mr. President,

17     is -- regards the transcript today, at page 39 and 40, when we were

18     discussing the witness's paragraphs 92 and 93, and there was a discussion

19     as to whether it was a leading question from the interview or not.  You

20     were part of that discussion.

21             I have those two pages from the transcript, from those two pages

22     in order to admit them, which is what I would like to do.  I will have to

23     play the audio which is about seven minutes.  If the Defence does not

24     object to the admission of those two pages then I don't have to play the

25     audio and I'm done.

Page 24549

 1             JUDGE KWON:  Mr. Robinson.

 2             MR. ROBINSON:  Yes, actually, we don't object.  We think it would

 3     be useful for the Chamber to have that.

 4             JUDGE KWON:  Yes.

 5             MS. WEST:  Thank you.  And that is 65 ter 23612, and it's page --

 6     it's just two pages.  Yeah.  So it's two pages.  Thank you, I have no

 7     further questions.

 8             JUDGE KWON:  We'll admit that.

 9             THE REGISTRAR:  As Exhibit P4384, Your Honours.

10                           Questioned by the Court:

11             JUDGE KWON:  Mr. Katanic, you talked about the brick factory.

12     Mr. Beara and Mr. Deronjic went together to the place and there was

13     debate whether prisoners could be imprisoned there or not.  Have you been

14     to the place ever?

15        A.   Yes, Your Honour.

16             JUDGE KWON:  Could you explain to us -- to us how it looks like,

17     what -- how big it is?

18        A.   In terms of an area, it is quite large.  As for the buildings

19     themselves, it doesn't have any specific structures that would have a

20     roof.  There's only the administrative building and the workshop itself.

21             JUDGE KWON:  Could you tell us how big is the administrative

22     building and workshop.  How many employees are working there, or how many

23     rooms or offices does it have?

24        A.   In the administrative building?

25             JUDGE KWON:  Yes.  You said that's the only building that has a

Page 24550

 1     roof.

 2        A.   Yes.  It's a small building.  In terms of size, I believe it can

 3     accommodate up to ten office workers.

 4             JUDGE KWON:  Thank you.  Have you ever been to Sase mine?

 5        A.   Yes, I have, but I wasn't at the brickworks during the war or in

 6     the Sase mine during the war.  I only visited the locations before and

 7     after the war.

 8             JUDGE KWON:  Thank you.  Could you explain to me as well about

 9     the Sase mine in terms of building or size.

10        A.   The Sase mine had buildings that were much larger than the ones

11     at the brickworks in Bratunac, although I can't tell you with any

12     certainty what the size was.

13             JUDGE KWON:  You told me just now that you believed that the

14     building at brick factory could accommodate up to ten office workers.

15     How about the office building in Sase mine?

16        A.   It's much bigger.

17             THE ACCUSED: [Interpretation] May I be of assistance?  The

18     witness meant to say ten offices rather than ten workers per se, because

19     ten workers can be placed in a single office if needed.

20             THE WITNESS: [Interpretation] If I may.  I put it well.  The

21     administrative building in the brick factory is small, and in normal

22     conditions it cannot accommodate more than ten office employees.  It has

23     only three or four rooms.

24             JUDGE KWON:  Thank you very much.

25             Yes.  Unless my colleagues have questions for you, that concludes

Page 24551

 1     your evidence, Mr. Katanic.  On behalf of this Trial Chamber and the

 2     Tribunal, I would like to thank you for your coming to The Hague to give

 3     it.  Now you are free to go.

 4             THE WITNESS: [Interpretation] Thank you.

 5             JUDGE KWON:  By the way, we will rise all together.

 6             MR. TIEGER:  Mr. President.

 7             JUDGE KWON:  Oh, yes.

 8             If you could excuse yourself.

 9                           [The witness withdrew]

10             JUDGE KWON:  Yes, Mr. Tieger.  Should we go into private session

11     briefly?

12             MR. TIEGER:  Yes.  Thank you very much.

13                           [Private session]

14   (redacted)

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Page 24552

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14                           [Open session]

15             THE REGISTRAR:  We're back in open session, Your Honours.

16             JUDGE KWON:  Thank you.  The hearing is now adjourned.  We will

17     resume on Monday at 9.00.

18                           --- Whereupon the hearing adjourned at 3.07 p.m.,

19                           to be reconvened on Monday, the 13th day

20                           of February, 2012, at 9.00 a.m.

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