Tribunal Criminal Tribunal for the Former Yugoslavia

Page 37144

 1                           Monday, 15 April 2013

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.04 a.m.

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

 7     solemn declaration, please.

 8             MS. EDGERTON:  If I may, Your Honours.

 9             JUDGE KWON:  Yes, Ms. Edgerton.

10             MS. EDGERTON:  I had communicated with the parties by e-mail

11     yesterday afternoon indicating the Prosecution wished to make submissions

12     with respect to the late disclosure of the proofing note and additional

13     documents we received on Saturday afternoon prior to the witness

14     beginning his testimony.  I wonder if I may be permitted to do that at

15     this time.

16             JUDGE KWON:  Is this something that would prohibit the witness

17     from making solemn declaration itself?

18             MS. EDGERTON:  No, Your Honours.  I had just thought it might be

19     preferable to do it before the witness took the declaration.

20             JUDGE KWON:  So is the thing that you wanted to make that

21     submission in the absence of the witness.

22             MS. EDGERTON:  It doesn't matter at all, Your Honour, in that

23     regard.

24             JUDGE KWON:  Then we'll have the witness make his solemn

25     declaration, please.

Page 37145

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

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

 3             JUDGE KWON:  Thank you, General.  Please be seated and make

 4     yourself comfortable.

 5                           WITNESS:  STANISLAV GALIC

 6                           [Witness answered through interpreter]

 7             JUDGE KWON:  And would the counsel representing the witness

 8     introduce himself to the Chamber.  Thank you.

 9             MR. PILETTA-ZANIN: [Interpretation] Good morning, Your Honours.

10     I am Stephane Piletta-Zanin, I represent or, rather, I will assist

11     Mr. Galic during his testimony.  Would you like me to add anything?

12             Let me precise [as interpreted] that I will be speaking French,

13     as usual, in this courtroom, and I hope that you will bear with me.

14             JUDGE KWON: [Interpretation] Thank you, Mr. Piletta-Zanin.

15             [In English] I take it, Mr. Galic, that Mr. Piletta-Zanin

16     explained this to you.  However, before you commence your evidence, I

17     must draw your attention -- do you hear me in your language, General?

18             THE WITNESS: [Interpretation] I heard you, but it was not in a

19     language that I understand because I speak Serbian.  Now I can hear

20     interpretation into Serbian and it will be all right.

21             JUDGE KWON:  Thank you.  Before you commence your evidence,

22     General Galic, I must draw your attention to a certain Rule of procedure

23     and evidence that we have here at the International Tribunal, that is

24     Rule 90(E).  Under this Rule, you may object to answering any question

25     from Mr. Karadzic, from the Prosecution, or even from the Judges if you

Page 37146

 1     believe that your answer might incriminate you in a criminal offence.  In

 2     this context, "incriminate" means saying something that might amount to

 3     an admission of guilt in a -- for a criminal offence or saying something

 4     that might provide evidence that you might have committed a criminal

 5     offence.  However, should you think that your answer will incriminate you

 6     and as a consequence you refuse to answer the question, I must let you

 7     know that the Tribunal has the power to compel you to answer the

 8     question.  But in such situation, the Tribunal would ensure that your

 9     testimony compelled under such circumstances would not be used in any

10     case that might be laid against you save and except for -- except the

11     offence of giving false testimony.

12             Do you understand what I have just told you, General Galic?

13             THE WITNESS: [Interpretation] Yes, Your Honour.

14             JUDGE KWON:  Thank you, Mr. Galic.

15             Now the Chamber will hear you, Ms. Edgerton.

16             MS. EDGERTON:  Thank you, Your Honours.  I'd just like to put

17     some observations on the record, and it's with, as I indicated

18     previously, with respect -- this is a notice issue, and this is with

19     respect to the late notice of the material which is a 15-page very

20     detailed proofing note and 12 additional untranslated documents, three

21     maps, only one of which was already exhibited, which were delivered or

22     e-mailed at 5.27 p.m. on Saturday night.  And, Your Honours, that's well

23     less than 48 hours before General Galic was expected to testify, and in

24     that regard I would say in specific contravention of the guidelines

25     Your Honours set in place for the procedures for the conduct of this

Page 37147

 1     trial.

 2             And this set of documents, Your Honours, that we received on

 3     Saturday was actually the third set identified that might be used in the

 4     course of the examination-in-chief of General Galic.  The first, about

 5     65 in number, we received on the 27th of March, the second, 107, we

 6     received on the 9th of April, and of course we welcome in advance the

 7     documents because even though they don't tell us what General Galic might

 8     say in his testimony in chief, we've been working with them to try and

 9     identify themes that might be the subject of his testimony, and we do

10     that because without an adequate summary of specific facts on which the

11     General is expected to testify, that's all we have.  The General's

12     summary, his 65 ter summary for two years of command of the

13     Sarajevo-Romanija Corps was 11 lines long.  And -- but looking at those

14     documents, Your Honour, with rare exception, the documents that we

15     received before Saturday only seemed to relate largely to one paragraph

16     on page 7 of this summary, in fact the second full paragraph on page 7,

17     which relates to Muslim attacks.

18             Now, when you look at those -- the greater number of those

19     documents against the summary, it looks like the Prosecution actually has

20     been wasting their time in preparation for this examination-in-chief,

21     wasting our time out of court and not saving it, and it's put us in

22     effectively the worst of all possible scenarios because we're coming into

23     an examination on some areas of evidence in that summary cold.  And just

24     looking at the summary that we received on Saturday, I also note that

25     there's areas on here that weren't even close to being identified in the

Page 37148

 1     65 ter summary as filed.  There was no notice that General Galic would

 2     speak about the SRK before he arrived.  There was no notice that he would

 3     speak about its place in the VRS.  There was no notice that he would

 4     speak about UNPROFOR and the UNMOs.  There was no notice he would speak

 5     about the relationship with civilian authorities, no notice that they

 6     would speak about the media, no mention that they would speak about

 7     proportionality and selectivity of fire.

 8             Your Honours, of course the Prosecution's been able to guess or

 9     anticipate that some of those might be the subject of testimony, but not

10     a word of that has been mentioned in the summary, and the documents have

11     actually -- I would go as far as to say sometimes led us down some rabbit

12     holes when we could have been directing our preparations on or into the

13     actual information that the General might testify to.  The way this has

14     gone actually undermines our ability to effectively cross-examine

15     General Galic.

16             But now keeping in mind that it appears as though there's going

17     to be some breaks during the course of the examination-in-chief this

18     week, and of course with the undertaking that we're going to do our

19     utmost best not to waste the Court's time, I hope we will be prepared to

20     cross-examine on all areas, but given the lateness of this notice,

21     Your Honours, when the time comes, I feel I may be addressing you with

22     respect to certain areas of the evidence mentioned during the

23     examination-in-chief in that we might require additional time to prepare

24     on those areas.

25             JUDGE KWON:  Mr. Robinson.

Page 37149

 1             MR. ROBINSON:  Yes, Mr. President, very briefly.  We thought of

 2     all these things last year when we asked the Chamber to bring the

 3     witnesses who were serving their sentences in other locations to

 4     The Hague earlier because the Registry wouldn't appoint them counsel, so

 5     we couldn't have any proofings until they got here and the Prosecution

 6     opposed that request and persuaded the Chamber that it was only necessary

 7     for the witness to be here one week before they commenced their

 8     testimony.  As a result of that, we didn't have a chance to obtain any

 9     information from General Galic until he arrived here last week.  Since

10     then, we've done our best to provide the Prosecution with, as they say, a

11     detailed proofing note, which I wonder if they prefer we didn't give them

12     such a detailed proofing note, but in any event, we've done our best to

13     inform them of the substance of General Galic's testimony as soon as we

14     became aware of it.

15             If they need more time to prepare for their cross-examination

16     when the time comes, which probably will not be until the beginning of

17     next week, we certainly wouldn't have any objection to that, but I think

18     this is a little bit of the boy crying wolf.  Ms. Edgerton prosecuted

19     General Galic, worked on his case for three or four years.

20             MS. EDGERTON:  No, I did not.

21             MR. ROBINSON:  Well, she attended the trial, let's put it that

22     way, or participated in the trial.

23             MS. EDGERTON:  No, I did not.

24             MR. ROBINSON:  Okay.  Well, then I'm mistaken about that.

25             JUDGE KWON:  Please do not overlap.

Page 37150

 1             MR. ROBINSON:  I apologise [overlapping speakers] --

 2             JUDGE KWON:  Just a second.  Now you realise at which pace we

 3     should proceed.  Please continue, Mr. Robinson.

 4             MR. ROBINSON:  Thank you, Mr. President.  I apologise if that's

 5     not correct, but nevertheless, the Prosecution prosecuted General Galic,

 6     thousands of documents were dealt with in his case, and they had a full

 7     range of information about his conduct.  So to claim at this stage that

 8     they're not prepared to cross-examine him is a little overblown in our

 9     estimate, but nevertheless, we remain committed to assist the Prosecution

10     in not having to commence its cross-examination until it's reasonably

11     prepared.  Thank you.

12             JUDGE KWON:  Just a second.  Yes.  Does the Prosecution have

13     anything to add?

14             Mr. Tieger.

15             MR. TIEGER:  Thank you, Mr. President.  Only to clarify, if it's

16     necessary to do so, that the suggestion, perhaps inadvertent, that the

17     Prosecution brought this problem on itself, that is not at all the case.

18     The Prosecution's position in respect of the first time the issue of the

19     arrival of previously convicted witnesses arose was consistent with the

20     Trial Chamber, and that was based on the idea that members of the trial

21     team could go to where the witness was well in advance and prepare that

22     witness.

23             Now, apparently that normally expected procedure foundered on the

24     issue of appointment of counsel, at least in the previous case.  When

25     that happened, I met with Mr. Robinson and indicated to him that in light

Page 37151

 1     of that problem, the Prosecution would fully support any remedial steps

 2     that would address the problem that had arisen.  So -- and nothing in the

 3     interim that took place to prevent the situation we find ourselves in now

 4     notwithstanding our positions of support for anything that would do so.

 5             So I'm only addressing at this moment the suggestion that somehow

 6     we brought this on ourselves.  We did not.  This is a very significant

 7     problem, as one can imagine, and the -- the emphasis on the volume of

 8     material available that Mr. Robinson just made is precisely the problem.

 9     The preparation could go in many, many, many different directions and

10     expend -- and require the expenditure of enormous resources, which is

11     precisely why the rules provide for detailed factual summaries, proofing

12     notes and other forms of guidance to narrow the area of preparation

13     required by the opposing party, and that's the nature of the problem.

14     And as Ms. Edgerton indicated, notwithstanding enormous efforts by

15     Ms. Edgerton and other persons assisting her in an effort to prepare, we

16     suddenly find ourselves confronting issues that were not notified and for

17     which adequate preparation was not undertaken.

18             JUDGE KWON:  Thank you.  Well, would you like to add anything,

19     Mr. Robinson?

20             MR. ROBINSON:  No, thank you, Mr. President.

21             JUDGE KWON:  While I note that all these problems originally

22     originate from the insufficient summary of the witness, the Defence

23     65 ter list, I appreciate the Prosecution's commitment to do its utmost

24     not to waste the court time.  So if necessary, the Chamber may consider

25     deferring the cross-examination of the witness about certain issues.

Page 37152

 1     Thank you.

 2             Then, Mr. Karadzic, please proceed.

 3             THE ACCUSED: [Interpretation] Good morning, Excellencies.  Good

 4     morning to everybody.

 5                           Examination by Mr. Karadzic:

 6        Q.   [Interpretation] Good morning, General Galic.

 7        A.   Good morning, Mr. President.

 8        Q.   General, I must ask you and remind myself that we should speak at

 9     a moderate pace and make a break between question and answer so that

10     everything may be recorded.

11             General, could you briefly say your full first and last name and

12     your father's name.

13        A.   My name is Stanislav Galic, lieutenant-general of the Army of

14     Republika Srpska, and my father's name is Dusan.  I have been retired

15     since --

16        Q.   We'll get there.  Tell us, please, your date and place of birth.

17        A.   The 12th of March, 1943, at Golesa in the Banja Luka

18     municipality.

19        Q.   Thank you.  What is your current occupation?

20        A.   I'm a prisoner now in Freiburg, and that's my occupation as it

21     were.  It's not a profession, but it's an occupation.  It's what I do

22     now, and I must do my time.

23        Q.   You mentioned that you were a retired lieutenant-general; right?

24        A.   Yes.  I'm a retired lieutenant-general of the Army of Republika

25     Srpska, and a major-general of the Army of Serbia.  It may be illogical,

Page 37153

 1     but I'm sure you understand.

 2        Q.   Thank you.  Please list briefly the stages of your education.

 3        A.   I graduated from primary school in Banja Luka.  Then I continued

 4     my education in the military system, which began in 1950, and that took

 5     longer than ten years in different time periods.  I graduated from the

 6     non-commissioned officers' school in Sarajevo.  Then I graduated from the

 7     military academy in Belgrade and the Command Staff Academy in Belgrade as

 8     well as the school of All People's Defence in Belgrade.  That would be my

 9     education in a nutshell.

10        Q.   Are these all the schools or courses that you need to finish to

11     become a general?

12        A.   Well, yes.  Well, these were the schools, but to become a general

13     you need much more.  You must get good assessments.  You must work well

14     in your position, and there were other criteria to become a general in

15     the Socialist Federative Republic of Yugoslavia.  Until you become

16     colonel, you will be promoted in the regular fashion, but after that

17     there were ethnic quotas.  There were quotas to consider the ethnic

18     composition of Yugoslavia for becoming a general.

19        Q.   Thank you.  Could you explain to the Chamber from what that

20     originates and what the result of that quota was?

21        A.   Well, there were various results.  One of the results was that

22     all the ethnicities in Yugoslavia were represented, and that's positive,

23     of course.  But at a certain point in time, due to that quota, some

24     people would become generals who were maybe not best prepared.  Since the

25     Serbs were the -- were the most numerous ethnicity in Yugoslavia, most

Page 37154

 1     generals were also Serbs.

 2        Q.   Thank you.  Could you tell us which positions you were in until

 3     you arrived at the Sarajevo-Romanija Corps.

 4        A.   To put it briefly, I was in every position from platoon commander

 5     to corps commander, company commander, battalion commander, regiment or

 6     brigade commander, division commander, and finally corps commander.  I

 7     retired as corps commander.

 8        Q.   Thank you.  During your career were you commended, decorated, or

 9     rewarded?

10        A.   You couldn't become general if you weren't commended, rewarded,

11     and decorated.  So I received some of these during the war.

12        Q.   Thank you, General.  Can you tell us where you were, in which

13     position, before you joined the Sarajevo-Romanija Corps.

14        A.   Before joining the SRK, I was commander of the 30th Infantry

15     Division at Mrkonjic Grad, which is in Republika Srpska.

16        Q.   What was its zone of responsibility?

17        A.   Well, the zone changed depending on the certain period of time.

18     Initially it encompassed the area of Drvar and so on, all the way up to

19     Glamoc, and in depth up to Kljuc and Petrovac.  Later on, when the

20     2nd Corps arrived, it took over this zone and the division remained

21     deployed in the area towards Kupres, and then later on that part was also

22     excluded from the division area such as Mrkonjic Grad and Jajce and

23     Knezevo.

24        Q.   Thank you.  When were you appointed or, rather, when did you join

25     the SRK and which post did you have?

Page 37155

 1        A.   I joined the SRK on the 10th of September, 1992, and I took up

 2     the position of the corps commander.  I have to add, though, you know

 3     that posts are taken voluntarily with the consent of the general.  In

 4     this situation, however, lots of things were not clear sufficiently, but

 5     I nevertheless accepted this post.

 6        Q.   Thank you.  Your predecessor, the previous commander of the SRK,

 7     when did he leave his post, and what was the situation in the corps upon

 8     your arrival and the situation in the theatre of war?

 9        A.   I don't know exactly when General Sipcic left the position of the

10     commander, but I think that was more or less a month before my arrival.

11     I don't know exactly.  At that time there was a directive issued by the

12     Federal Secretariat of National Defence of Yugoslavia before the

13     formation of the VRS that all those who were not born in

14     Bosnia-Herzegovina or had no specific orders to that effect were not

15     required to remain where they were.  They were able to be transferred to

16     other areas, for example, to Montenegro.  Since I was born in

17     Bosnia-Herzegovina, of course I remained there.

18             As for Sipcic, I assume when he acquired the rank of the general

19     decided to go to Belgrade, and as far as I know, he never came back and I

20     think he retired there.

21             Now, what did I find as far as the situation was concerned.  I

22     found a corps without the commander and without the Chief of Staff of the

23     corps.  You remember when you met me at Jahorina when I was taking over

24     my duty, you would recall that the situation in the corps was quite

25     complex, and I don't know whether we should go into details regarding the

Page 37156

 1     complexity of the situation.

 2        Q.   Hopefully we shall come to that.  A minute ago you said -- but

 3     can you tell us whether a corps commander is higher than the division

 4     commander?

 5        A.   Well, the corps commander is a higher position than the division

 6     commander, although they are approximately the same with regard to the

 7     authority.  Division has less authority, and therefore the commander can

 8     be either a colonel or a general.  So that would be the difference.  And

 9     the strength is lesser, and I'm talking about the division, of course.

10        Q.   So if one was transferred from a division to the level of a

11     corps, would that be considered as a promotion?

12        A.   Well, yes, definitely.

13        Q.   You just said that people accepted this voluntarily but that in

14     your case it seems as if you didn't go there voluntarily.  Can you give

15     us the reasons why the position of the SRK commander was not so desirable

16     to you?

17        A.   Well, there were several reasons, but the main one was the

18     complexity of the very theatre of war of Sarajevo, because that was one

19     of the most difficult one within the whole theatre of Bosnia-Herzegovina.

20     There is a witness who said many times that waging war in Sarajevo,

21     equally for commander or a soldier or a civilian, was simply a nightmare,

22     and I think that it speaks for itself.  I think that we shall deal with

23     other characteristics at later stage regarding this particular theatre of

24     war.

25        Q.   Thank you.  What was the composition of the SRK, and how many

Page 37157

 1     lower-level units were included in it?

 2        A.   Well, mainly when I arrived we had nine light brigades.  We had a

 3     mixed anti-armour regiment, a mixed armour artillery regiment.  We had a

 4     light artillery regiment.  We had a battalion, communications battalion,

 5     medical battalion, and transport battalion, and communications battalion

 6     if I omitted to mention that.  So those were more or less the units that

 7     made up the Sarajevo-Romanija Corps.

 8             That was the situation prevailing until the 1st of November,

 9     1992.  After that, two brigades left the corps so that the corps was sort

10     of downsized at that time.  That would be in brief the strength and the

11     composition of the corps.

12        Q.   What was the occasion and which specific brigades had left the

13     SRK, and where were they transferred?

14        A.   The two brigades that left were the 1st Romanija and the other

15     one, and they joined the Drina Corps that was established at that time.

16     The other one was the Rogatica Brigade.  One part of armoured and

17     mechanised units also went away because this was a newly established unit

18     that was formed on the 1st of November, 1992, and it became operational

19     at that time.

20        Q.   Thank you.  Were there any changes in the area of responsibility

21     as a result?

22        A.   Well, it affected the zone of responsibility, because practically

23     the zones of responsibility of these brigades went as far as the Drina,

24     the Drina River, and towards Kladanj and Olovo, but now the zone was

25     slightly changed, but we expanded it in another direction.  So after

Page 37158

 1     these two brigades left, we gained the Nisic plateau direction and the

 2     part that was held by the 2nd Romanija Brigade.  The rest remained within

 3     the zone of responsibility of the corps, the one within Sarajevo itself,

 4     then the area towards Jahorina and Igman mountains, and other directions

 5     and axes which I can name if you wish me to do so.

 6        Q.   Now, did we understand you correctly when you said that after the

 7     departure of these two brigades they did not change the area of

 8     responsibility, only these two zones were excluded from your area?

 9        A.   Yes.

10             THE INTERPRETER:  Could the speakers please pause between

11     questions and answers and speak more slowly.  Thank you very much.

12             JUDGE KWON:  It's very difficult for the interpreters to catch up

13     with your speed unless you put a pause between the question and answers

14     and speak very slowly.

15             Mr. Galic, could you repeat your answer.

16             THE WITNESS: [Interpretation] With regard to the zones of

17     responsibilities of those two brigades, if a unit leaves and they left

18     the SRK, they became part of the Drina Corps, and, of course, their

19     respective zones of responsibility were not under the SRK jurisdiction

20     any longer but they were transferred under the jurisdiction of the

21     Drina Corps.  That would be my answer, if I repeated it properly.

22             MR. KARADZIC: [Interpretation]

23        Q.   Thank you.  You made -- mentioned the Rogatica Brigade called

24     after its municipality.  Can you tell the Chamber the brigades that

25     remained within the SRK, what kind of formations were they?  What were

Page 37159

 1     their zones of responsibility, and in what way were they connected with

 2     their respective defence areas?

 3        A.   The remaining part of the brigade or the remaining part of the

 4     corps, everything was based on the territorial principle.  Initially, the

 5     municipality took care of those brigades themselves because that was a

 6     form of self-organisation by the people themselves.  Until the

 7     19th of May, all of that was part of the JNA.  We know that the Serbian

 8     people advocated the option of remaining within Yugoslavia, that the task

 9     of the Yugoslav People's Army was to defend the sovereignty and integrity

10     of Yugoslavia, and as a result, they were more linked to the JNA.  It

11     didn't pay much attention to other things which left them not

12     sufficiently prepared for the new situation that emerged

13     post-19th of May.

14             Now we have the Ilidza Brigade which was mostly deployed in the

15     area of Ilidza and was holding positions towards Stupska junction in

16     Nedzarici, towards Dobrinja, Alipasino Polje, and of course this area is

17     facing the airport as well.

18             Now, the next part of the front line was towards the Mount Igman,

19     Stojicevac and other places, but the Igman mountain itself was held by

20     the BH Army.  It is interesting to say that the area of this brigade,

21     particularly the area of Nedzarici, were constantly surrounded or

22     semi-surrounded as it were.  So for a person to be a commander there was

23     an extremely difficult task.  I had to go there on several occasions.

24        Q.   Can I please ask you to show us that on the map?

25             THE ACCUSED: [Interpretation] Can we now have 65 ter 24947.

Page 37160

 1             MR. KARADZIC: [Interpretation]

 2        Q.   You can also use the map that is on the screen, but I believe

 3     that we and the other parties concerned will have --

 4        A.   Mr. President, yeah -- now I have a very small map on my screen.

 5        Q.   If it would be more convenient and easier for you, can someone

 6     give you a pointer --

 7             JUDGE KWON:  Yes, Ms. Edgerton.

 8             MS. EDGERTON:  Just to note that this was one of the potential

 9     exhibits that was notified on Saturday night.

10             JUDGE KWON:  I don't follow the point.  This is --

11             MS. EDGERTON:  Notified late.

12             THE ACCUSED: [Interpretation] Thursday or Friday shouldn't be

13     considered as belated notice.  We sent this to them on those two days and

14     we asked them to scan the document.

15             JUDGE KWON:  Specifically what problem do you have with using

16     this map, Ms. Edgerton?  It's difficult to follow what kind of problem it

17     may cause.

18             MS. EDGERTON:  At the moment, none for the Prosecution,

19     Your Honour, just to make a note when we come to the time of

20     cross-examination.

21             JUDGE KWON:  Let's proceed.  If necessary we can zoom in, but I

22     don't know how far we can zoom in, but I leave it to you, Mr. Karadzic,

23     how to proceed with the witness.

24             THE ACCUSED: [Interpretation] Thank you.  I trust that we can

25     enlarge the central part, because there's a lot of empty space on the

Page 37161

 1     sides of the map.  So we can zoom in.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   General, if it is easier for you to use the map behind you and to

 4     make a presentation for the benefit of the Chamber so that they can

 5     follow both.

 6             You were talking about the Ilidza Brigade, so could you please be

 7     kind to tell us where its zone was, where its neighbouring units were,

 8     and where the positions of the enemy in front of it were.

 9        A.   When I was discussing -- microphone.  How -- you'll hear me.

10             When I was discussing the positions of the Ilidza Brigade, these

11     are the positions, and they are marked in colour blue, and this is the

12     area of Nedzarici, Nedzarici, Alipasino Polje, the settlement,

13     Aerodromsko settlement, Dobrinja.  So this was the area where Nedzarici

14     itself was.  These red lines indicate the position of the Army of BH.

15     Blue lines indicate the positions of the Sarajevo-Romanija Corps.

16     Usually we always indicate our own forces with colour red.  So if we

17     were -- if this had been --

18             THE INTERPRETER:  Could Mr. Karadzic please wait for the

19     interpretation to be finished.

20             THE ACCUSED: [Interpretation] Would it be easier for the General,

21     Your Honours, to use a pen to indicate the positions on the screen?

22             THE WITNESS: [Interpretation] Well, I don't think it will be easy

23     for me because this map is not clear.  I can't see almost anything.

24             JUDGE KWON:  I find it a bit difficult to follow the way in which

25     the witness is indicating on the map, because it's difficult to recap his

Page 37162

 1     evidence.

 2             If you'd zoom in part and part, and if necessary he can mark it.

 3     We can admit it in several pieces if necessary.  Think about the matter.

 4     Or the General can explain the map as it is described on the map with the

 5     zoomed-in map.  Shall we try that?

 6             THE ACCUSED: [Interpretation] Thank you, Your Excellency.  I

 7     think that's the best solution.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   General, can you please go back to the desk, and then we shall

10     ask the Registry to zoom in the bottom left part of the map grid.

11             THE ACCUSED: [Interpretation] Can we zoom in further, please.

12     There is quite a bit of the outlying area that we don't need.  Can we

13     enlarge it a bit further.

14             MR. KARADZIC: [Interpretation]

15        Q.   General, sir, is this an appropriate view now?

16        A.   Yes.  I will now indicate exactly where the Ilidza Brigade had

17     its positions.

18             It manned the positions of Aerodromsko settlement.  We can see

19     how the blue line stretches.  Nedzarici.

20        Q.   Thank you.  Can you place the letter A with your electronic pen

21     to indicate the airport settlement, Aerodromsko settlement?

22        A.   This is just one portion of it here.  It's not working really

23     well, is it.

24        Q.   You can erase this, perhaps, and just put an ordinary A.  Or you

25     can put numbers if you prefer.

Page 37163

 1        A.   Yes, numbers would be better.

 2        Q.   Then 1 for Aerodromsko settlement.

 3        A.   There, it's done.

 4        Q.   And to the north of Aerodromsko settlement?

 5        A.   Yes, Nedzarici.  We can place number 2.

 6        Q.   Please go on and introduce to us the area of responsibility of

 7     that brigade.

 8        A.   In this area of Nedzarici and Aerodromsko settlement there was

 9     only one battalion of the Ilidza Brigade.  The other battalion manned

10     Stup and the Stup junction here.  So that's the area around here.  That

11     would be number 3.

12        Q.   Yes, number 3 is fine.

13        A.   It also mans the positions around Energoinvest.  So this is the

14     Stup area.  And this bit is interesting, as we come to the area of Otes.

15     That area was, until the 10th of December, 1992 -- and that would be

16     number 4; right?

17        Q.   Yes, yes.  Number 4.

18        A.   I can't read the lettering at all, so I'm just placing this from

19     my memory, and if I make a mistake, please take this into consideration.

20             So this area was, up until the 10th of December, 1992, under the

21     control of the BH Army.  Subsequently, it was under the control of the

22     SRK forces, that's to say of the Ilidza Brigade, through to the

23     Dobrinja River.  We can see the river here.  It's the Dobrinja, which

24     stretches along almost the entire front.

25        Q.   Can you draw a line to indicate the flowing of the Dobrinja?

Page 37164

 1        A.   Well, all right.  I think you can see it anyway.

 2        Q.   Thank you.  General, sir, can you tell the Chamber who was

 3     opposite the brigade in the various stretches of the line?

 4        A.   Let me first round off just the area of the brigade,

 5     Mr. President.

 6        Q.   Fine.

 7        A.   This brigade also had positions opposite Stojicevac.  We'll mark

 8     it with number 5.  We can see that all the way down in the south, it's

 9     the 4th Motorised Brigade that held its positions.  That's Stojicevac,

10     across from the airport.  It also manned the positions in the direction

11     of Mount Igman all the way to Golo Brdo, Golo hill, which you can't see

12     in the map, but it's opposite Otes.  This was an area of 800 metres only.

13     The entire brigade was, in fact, in an encirclement or semi-encirclement

14     during that period of time.  That was why it was necessary to go out into

15     this area in the direction of Otes to round this up and to prevent Golo

16     hill from being captured.

17        Q.   All right.  Then in the direction of the Mount Igman can you just

18     place an arrow and say that it indicates the direction of Golo hill and

19     place number 6.

20        A.   Well, Golo Brdo is basically one of the hills of Mount Igman.  Is

21     this all right?

22        Q.   Yes.  Number 6 and an arrow.

23        A.   All right.

24        Q.   Thank you.

25        A.   I am not really good at handling this pen, I'm afraid.

Page 37165

 1        Q.   Can you tell us, starting from Otes and then further on eastward,

 2     who is the enemy really there?

 3        A.   It changed in this area.  This map reflects the situation as it

 4     was at the time I took up my positions.  That's the Motorised Brigade.

 5     And we held this area of Alipasino Polje, which we could mark with

 6     number 7.  That's the Alipasino Polje neighbourhood.  Is that right?  Is

 7     number 7 all right?

 8        Q.   Yes.

 9        A.   This area was held by the 101st Mountain Motorised Brigade, and

10     in the direction of Dobrinja, it was the 5th Mountain Brigade.

11        Q.   Number 8, please.

12        A.   Number 8.

13        Q.   General, can you tell us first --

14             JUDGE KWON:  Shall we stop here.  Shall we ask the witness to

15     date and put his initials onto this map.  Today is 15th of April, 2013.

16     Probably top right, at the top right part of the map, could you date and

17     initial.

18             Yes, Ms. Edgerton.

19             MS. EDGERTON:  I wonder if I could ask one further thing,

20     Your Honour.  Perhaps we could have for the record the date of the map --

21             JUDGE KWON:  That's why I'm going --

22             MS. EDGERTON:  I'm sorry.

23             JUDGE KWON:  -- I'm asking the witness to save this at the

24     moment.

25             MS. EDGERTON:  Apologies.

Page 37166

 1             JUDGE KWON:  If I were to introduce a map, I would introduce the

 2     provenance and the date of the map it was produced.  While after we kept

 3     this into the record, why don't you put those questions to the witness,

 4     Mr. Karadzic.

 5             Could you put the date, Mr. Galic, on the map, at the top right

 6     part.

 7             THE WITNESS: [Interpretation] Today's date?

 8             JUDGE KWON:  Yes.  15th of April.  And your initials, please, or

 9     signature.

10             THE ACCUSED: [Interpretation] Thank you --

11             JUDGE KWON:  Just a second.  We keep this as --

12             THE ACCUSED: [Interpretation] There is one other thing I would

13     like the witness to mark, please, so I'd like to have something marked

14     before we admit it.

15             JUDGE KWON:  Yes.

16             MR. KARADZIC: [Interpretation]

17        Q.   General, tell us what were the features that were held by this

18     Motorised Brigade?  What was the population?

19        A.   In the area of responsibility of the 3rd Motorised Brigade in

20     relation to Ilidza and the area of Stup junction, there was this one

21     specific feature which was a silo next to the Stup junction, and it was

22     out of there that most of the activity aimed at Ilidza came from.  The

23     rest were mostly high-rise buildings and that especially applies to the

24     area in the direction of the Nedzarici, the students' centre,

25     Alipasino Polje, Dobrinja, because Nedzarici is mostly single housing,

Page 37167

 1     family houses, whereas around Nedzarici you had high-rise buildings,

 2     skyscrapers.

 3             Across the Miljacka, there is the area under the 2nd Motorised

 4     Brigade.  That's the Brijesce Brdo, Brijesce hill, and you can see the

 5     area under the control of the Ilidza Brigade from the vantage point of

 6     Brijesce hill.

 7        Q.   Can you place number 9 to indicate Brijesce hill.  Yes, it's

 8     right.  It's been interpreted well.  Can you place number 9 on Brijesce

 9     hill.

10        A.   I don't see where it is written on this map so I'm just going to

11     place it from my memory.  I think this would roughly be where Brijesce

12     hill is located.

13        Q.   Can you also identify where Mojmilo is and how it is related to

14     and in what position does it stand in relation to the other

15     neighbourhoods.

16        A.   Mojmilo is east of the 5th Mountain Motorised Brigade, and it is

17     under the control of the 101st Brigade.  This is where Mojmilo is

18     situated roughly.

19        Q.   Number 10, please.

20        A.   Thereabouts.  Dobrinja is up there, and then Mojmilo would be

21     over here.

22        Q.   And finally, General, this portion of the map that we will now

23     admit, which map does it belong to, and who drew the map?

24        A.   This portion of the map was taken from, I think --

25        Q.   You can look behind your shoulder.

Page 37168

 1        A.   It's taken from --

 2             JUDGE KWON:  Just a second.  We'll keep it as a temporary next

 3     Defence exhibit.  We'll keep it, and let's zoom in on the top left corner

 4     of the map.  Shall we designate as an MFI -- temporarily mark it for

 5     identification.  What's the number?

 6             THE REGISTRAR:  As MFI 3381, Your Honours.

 7             THE ACCUSED: [Interpretation] The upper left-hand corner is what

 8     we need to identify the provenance of the map.  It will be on your screen

 9     shortly.  Can we zoom in on the upper left-hand corner.

10             THE WITNESS: [Interpretation] I don't have it, not yet.

11             JUDGE KWON:  Upper-left corner of the map, same map.

12             THE WITNESS: [Interpretation] Further to the left.  Yes, now I

13     have it.

14             JUDGE KWON:  We do not need the witness to mark the map at the

15     moment.  Yes.  Please go ahead.  We can zoom in a bit further.

16             MR. KARADZIC: [Interpretation]

17        Q.   General, can you tell the Chamber what is the stamp that has been

18     affixed here?

19        A.   Yes.  It's the stamp of the 1st Corps of the Army of

20     Bosnia-Herzegovina.

21             THE ACCUSED: [Interpretation] Your Excellencies, would you like

22     this zoom to be admitted as well?  And the General can place his

23     signature on it, we will know that the previous portion comes from this

24     map.

25             JUDGE KWON:  No, it's not necessary.  We can zoom in at any

Page 37169

 1     moment.

 2             I would ask the witness to read out this portion in its entirety.

 3             THE WITNESS: [Interpretation] Thank you.  "Operational map of the

 4     staff of the 1st Corps.  Beginning --" or, rather, first I should say

 5     that there's a stamp beneath it of the command of the 1st Corps.  And

 6     then it reads:  "Beginning:  1 December 1992.  End:  4 April 1993."

 7     That's all that we can read here.

 8             JUDGE KWON:  And bottom left part.  Scroll down.

 9             THE WITNESS: [Interpretation] Here we have the legend or the key

10     indicating the situation as it was in different periods of time, and we

11     will see that they differ slightly from the situation as it was at the

12     beginning and at the end.  And the first one is the 1st of December,

13     1992.  The next line is the 4th of December, 1992.  Then the

14     9th of December, 1992.  Next, the 11th of December, 1992; 14th December

15     1992; 15th December 1992 --

16             JUDGE KWON:  I think it's now sufficient.  When did you see this

17     map for the first time, General?

18             THE WITNESS: [Interpretation] I saw this map for the first time

19     at my trial.  I think that it was being shown repeatedly by the

20     Prosecutor until we started putting certain questions about it.

21             JUDGE KWON:  Do you have any objection to the admission of this

22     map, Ms. Edgerton?

23             MS. EDGERTON:  No.  We're just looking to see if it was actually

24     used in the Galic trial.

25             JUDGE KWON:  Do we need a translation for this map or not?

Page 37170

 1             MS. EDGERTON:  I don't think so.  It's been read into the record,

 2     Your Honours.

 3             JUDGE KWON:  Yes, Mr. Piletta-Zanin.  Do you have any observation

 4     to make?

 5             MR. PILETTA-ZANIN: [Interpretation] I consider myself as the

 6     owner of this map that I have brought here in order to facilitate things.

 7     I'm still working on this map, and there is a problem because I would

 8     like to have the original of the map.  I think that people have been

 9     informed about this, so there shouldn't be any problem.

10             JUDGE KWON:  What does a BBR mean, Mr. Galic, in the Army of

11     Bosnia and Herzegovina?

12             THE WITNESS: [Interpretation] BBR, Mountain Brigade.  MTBR stands

13     for Motorised Brigade.  If you're interested, I can tell you what it all

14     means.  MBR stands for Mechanised Brigade.

15             JUDGE KWON:  Yes.  I think we have a proper basis to admit this.

16             MS. EDGERTON:  And it was P467 in the Galic trial.

17             JUDGE KWON:  Thank you.  We'll admit the entire map into a new

18     Defence exhibit.

19             THE REGISTRAR:  Exhibit D3382, Your Honours.

20             JUDGE KWON:  And the previous one we admitted as marked for

21     identification, Exhibit D3381, will be admitted in full.

22             Please proceed, Mr. Karadzic.

23             THE ACCUSED: [Interpretation] Thank you.  Can we have D3381 again

24     so that the General can speak about the strength and structure of the

25     enemy based on that map.  D3381.

Page 37171

 1             MR. KARADZIC: [Interpretation]

 2        Q.   While we're waiting, General, can you tell us what were the

 3     reasons, military or otherwise, for you to capture Otes?

 4        A.   The taking of Otes had a typically military reason.  I explained

 5     that Otes and Golo hill, which were both held by the BH Army, were

 6     blocking the Ilidza Brigade from exiting from that zone.  It is important

 7     to add that we failed to mention an important feature, and that's the

 8     airport, which at the time was controlled by UNPROFOR.  Probably there

 9     will be questions about this so that we'll probably get back to this.

10             This had a military reason, and I can elaborate, if you want,

11     about Otes.  It's very interesting that when I arrived when -- we

12     immediately established contact with the people on the opposite side.

13     The Ilidza Brigade informed all civilians that it would try to take Otes,

14     and some civilians who wanted to move out of that area, and they were

15     mostly Croats, and I'm not sure of the ethnic composition of those who

16     were transported to Kiseljak, but it was several dozen.  They -- there

17     were a number buses who took them there.

18             Then the fighting for Otes began.  This was a new housing

19     development made of reinforced concrete, and many people were killed,

20     even the brigade commander, I mean the Ilidza Brigade, Zoran Borovina.

21        Q.   Thank you.  Please explain to the Chamber what forces the enemy

22     had opposing the Ilidza Brigade, that is, the 3rd Motorised Brigade?

23     What kind of forces did they have, and what kind of equipment?

24        A.   Basically their brigades numbered about 2.000 men.  Here in this

25     area they had mortars, infantry weapons, and they had support from Igman

Page 37172

 1     and other parts of town.  If they needed it, they could get support from

 2     the howitzers at Igman and even by a 130-millimetre gun that was there.

 3     But as far as I know, the BH Army did not target this area with their

 4     artillery, but they used all the other weapons they had.  And the mortars

 5     moved a lot.  They also had many rifle brigades --

 6             THE INTERPRETER:  Interpreter's correction:  Rifle grenades.

 7             THE WITNESS: [Interpretation] They had a lot of those, because

 8     they manufactured them.

 9             And here in this area there were also snipers, in all these

10     high-rise residential buildings.  From Alipasino Polje through the

11     students' settlement, all the way to the Stup junction, all the

12     building -- in all the buildings there were snipers.

13             In Sarajevo, as far as we knew, there were some 500 snipers in

14     all, that is, sniping rifles.  Whether they got any more, I don't know,

15     but the number was thereabouts.  In the area of this brigade we can only

16     make an assessment of their numbers because they changed.  And then they

17     engaged the special units like the Swallows or the Larks and others that

18     have been mentioned here before this court.  If necessary, I can go

19     into -- I can elaborate more on these units.

20             Furthermore, they were occasionally supported by a tank, but I

21     wasn't -- I didn't get any information about that in the reports I

22     received.

23             There was a howitzer battalion somewhere around Humsko hill, and

24     the armoured battalion, that's what they called it, was somewhere around

25     the brickworks and the railway station, and they went up to Zuc -- Zuca

Page 37173

 1     or toward the threatened directions.  They manoeuvred with their forces.

 2     Wherever there was a threat, they would manoeuvre with their forces and

 3     engage their forces fast and efficiently.

 4             There was strong fire from Igman on the Ilidza Brigade.  They

 5     even used barrels filled with explosives and nails or what have you.  Of

 6     course, when that explodes, it had a devastating effect.  I don't know if

 7     I elaborated sufficiently.

 8        Q.   Thank you, General.

 9             JUDGE KWON:  Yes, Ms. Edgerton.

10             MS. EDGERTON:  I'm sorry, I don't quite understand because of the

11     length of the answer.  I was wondering if we're still talking about the

12     3rd Motorised Brigade or if we've gone on to talk about other units.  I'm

13     unclear.  Because the question was about the 3rd Motorised Brigade.

14             THE ACCUSED: [Interpretation] If I can explain.  I asked the

15     General to explain who the opponents of the Ilidza Brigade were.

16             JUDGE KWON:  Mr. Karadzic, ask the witness to clarify what he

17     said instead of you giving testimony.

18             THE ACCUSED: [Interpretation] Thank you.

19             MR. KARADZIC: [Interpretation]

20        Q.   General, we're speaking about only the 3rd Motorised Brigade or

21     about all brigades, including the 101st and the 5th, opposing the

22     Ilidza Brigade?

23        A.   In principle I spoke about all brigades in Sarajevo, and I

24     described their composition.  I also described the composition of the

25     3rd Motorised Brigade and what significant things there were.  Just like

Page 37174

 1     the other units that opposed the Ilidza Brigade, because we cannot look

 2     at one brigade and its actions in isolation, because it never acts in an

 3     isolated manner.  It's part of a corps that is a system so that the

 4     3rd Brigade and the 101st and the 5th, just as the 4th and the

 5     8th Brigades from Igman and so on, act in a synchronised fashion toward

 6     Ilidza.  So we cannot look at only one brigade.  But I've outlined the

 7     specific features of the others too.

 8        Q.   So those were the brigades opposing the Ilidza Brigade, the 8th

 9     from Igman, the 3rd, the 101st, the 5th, and the 4th.  The 5th from

10     Dobrinja and the 4th from Hrasnica; right?

11        A.   Yes.  They opposed the Ilidza Brigade.

12        Q.   Can you tell us now what kind of weapons they had at Hrasnica,

13     for example, or what did the 101st have to face the Ilidza Brigade toward

14     Lukavica?

15        A.   Their weapons.  Well, I said that they had all kinds of infantry

16     weapons.  I especially stressed the fact that they had many sniping

17     rifles from which -- which they had deployed on high buildings and all

18     high features, such as hills, around the Ilidza Brigade.  Then there were

19     mortars.  And at Mojmilo, and I watched it personally, there were also

20     some recoilless guns belonging to the 101st at the time and the 5th --

21     all right.  Well, there was some overlap there, but there was a

22     recoilless gun there.  And they also fired -- fired rifle grenades.

23             And when I went to Nedzarici, I was only able to go there at

24     night.  You couldn't go there in daytime because they would target you

25     with all sorts of weapons.  When I went there, I saw that the situation

Page 37175

 1     was really very difficult, and even today we must praise those fighters

 2     as heroes.

 3        Q.   Where were those fighters at Nedzarici for [as interpreted]?

 4        A.   All the fighters at the Sarajevo-Romanija Corps were local

 5     soldiers.  Those are people from Nedzarici, Ilidza, or some people from

 6     the other parts of Sarajevo.  That was the composition mostly of those

 7     forces at the Sarajevo-Romanija Corps, including Nedzarici.

 8        Q.   To what extent did commanding such a unit differ from commanding

 9     a professional military unit?

10        A.   Well, there are many differences.  I was a professional soldier,

11     but basically the goal is always the same.  The differences, however, are

12     the following:  That personnel was insufficiently trained for

13     house-to-house fighting.  Not only were those soldiers poorly trained for

14     such combat, but the rest of us, even the professionals, were poorly

15     trained for this kind of fighting.

16        Q.   We'll get there yet.  Can you tell us what kind of weapons the

17     4th Brigade at Hrasnica had, I mean the BH Army?  I don't mean the

18     artillery at Igman but at Hrasnica itself.  Did they target you and with

19     what kind of weapons?

20        A.   There was fire by the Ilidza Brigade from Hrasnica, to be more

21     precise, from Stojicevac.  They fired from all sorts of infantry weapons

22     and then there were mortars.  They also had also had some other weapons

23     including sniping rifles, quite a few, and this brigade didn't differ

24     much from -- from the other brigades.

25        Q.   You mentioned manoeuvre.  Which forces of theirs manoeuvred?

Page 37176

 1     What kind of assistance did come to this area?  Which units intervened?

 2        A.   It was mostly those free forces, to call them that, and by that I

 3     mean special forces.  Then there were these special brigades who for a

 4     while were at the disposal of the corps, and then there were groups that

 5     were established from Vikic's group to the Swallows, to the Larks.  And

 6     that reinforcement was such that it was very difficult to fight them off.

 7     And often they would use parts of one -- some units from one brigade to

 8     transfer to another brigade if there was a threat there.

 9        Q.   Thank you.  And on page 28, you said "mobile mortars," and it was

10     interpreted as mortars that moved.  What exactly did you mean?

11        A.   In Sarajevo, the parts held by the BH Army, it was characteristic

12     that they had mortars mounted to trucks, and they took them from one spot

13     to another.  They would stop, fire, and move on.  That's why it was very

14     difficult to locate the place from where the shell had been fired.  And

15     they weren't selective about these spots, whether there were civilians

16     nearby or not.  And that fire was sudden.  You can't expect such fire,

17     because when there is a spot from -- where there's a recoilless gun or

18     some other weapon, you expect it to fire from there, but when you don't

19     know where they are, then you can't expect the fire, and of course the

20     result is surprise which can lead to success.

21        Q.   Thank you.

22             THE ACCUSED: [Interpretation] Your Excellencies, I note the time.

23     Perhaps we should make a break now, because the pace was quite fast, or

24     should we continue for five more minutes?  Because I want to deal with

25     another brigade and other zones of responsibility and another portion of

Page 37177

 1     the map, but we can continue if you so wish.

 2             JUDGE KWON:  If it is convenient, we'll take a break for half an

 3     hour and resume at 5 to 11.00.

 4                           --- Recess taken at 10.26 a.m.

 5                           --- On resuming at 10.59 a.m.

 6             JUDGE KWON:  Yes, Mr. Galic, do you have any problem with the

 7     monitor?

 8             THE WITNESS: [Interpretation] No.  It's rather good now, but I

 9     asked why I cannot see a Serbian transcript.  I can only see an English

10     transcript.  Or possibly German.  I learned some German, but my English

11     is very poor.

12             JUDGE KWON:  Yes.  We have only English transcript during the

13     hearing.

14             THE WITNESS: [Interpretation] Thank you very much.

15             JUDGE KWON:  Mr. Mladic, please continue.

16             MR. KARADZIC: [Interpretation]

17        Q.   General, while we're at this map, on the example of this

18     Ilidza Brigade, can you tell us what the goals of the Ilidza Brigade were

19     and what were the goals of the BH Army brigades opposing it?

20        A.   The goals of all brigades of the VRS in the zone were the defence

21     of the territory with Serbian majority and the defence of the people

22     living there, not only Serbs but everybody.  To what extent that was

23     possible we'll discuss later.  And the goals of the forces of the BH Army

24     in the area -- and I must say that in the area of Ilidza, the goal of the

25     Ilidza Brigade of the SRK was to keep the area, which is extremely

Page 37178

 1     important because that's where Energoinvest is and water wells, and apart

 2     from that, the population there was by majority Serbian.  And before

 3     June 1992, while we were holding the airport, it connected Ilidza with

 4     the other territories controlled by the SRK.  That is the airport and

 5     further towards Lukavica.  And that's why it was important to preserve

 6     control over these areas, and through these, you could go north-west and

 7     link up with the other forces.  That's what the goal of the

 8     Ilidza Brigade in the area was.

 9             The BH Army, we see that they had strong forces grouped opposing

10     Ilidza.  There was a 3rd Motorised Brigade.  Later the 101st, then the

11     101st, and the 5th, 4th, 8th, 9th, and so on.  Their goal was to exert

12     pressure on the forces of the Ilidza Brigade in this area which was very

13     small, and advance in the -- along the axis Dobrinja-Alipasino Polje and

14     to link up with the 4th Brigade through the airport.  That is, the area

15     toward Igman had to be linked with the other territories controlled by

16     them.  That was their goal.

17             We were also under strong pressure for a while from Stup junction

18     toward Ilidza, that is, towards Stojicevac, and further on toward Stup

19     junction.  Why?  There were some schools there and faculties.  So the

20     goal was to take these buildings and drive out the Serbs from these

21     areas.

22        Q.   Thank you.  Let us now move away from this map and perhaps you

23     could tell us where which brigade was and what the goals, intentions, and

24     tasks of the units belonging to SRK was as opposed to those of the

25     BH Army.

Page 37179

 1        A.   I think it would be better to use the other map because the

 2     Chamber would be able to follow more easily, but if not, I can use this

 3     map.

 4        Q.   I believe that we don't need the exact demarcation lines between

 5     the brigades.  Who was on the one side and who was on the opposite side,

 6     and which forces were on each side?  And please indicate the dominant

 7     points.  If possible, please speak slowly and indicate the areas where

 8     the brigades were deployed, and if we can enlarge the picture.

 9        A.   We said that the Ilidza Brigade was up to the river Dobrinja,

10     then up to the river Miljacka, this area.

11             JUDGE KWON:  While witness is indicating on the map, could we

12     upload that map on our e-court so that we can follow separately.

13             MR. KARADZIC: [Interpretation]

14        Q.   General, it's not necessary for you to tell us the boundaries.

15     Just indicate the areas occupied by each brigade.

16        A.   The next neighbour to the Ilidza Brigade was the Igman Brigade.

17     The Igman Brigade held the area of Hadzici and Blazuj, to the area of

18     Ormanje and towards Kiseljak, and this is this area here.

19             The next brigade of ours was the Rajlovac Brigade.  The

20     Rajlovac Brigade held the area between Rajlovac and Zabrdje, and to the

21     river Miljacka.

22             This external area, I don't know if we have to address that at

23     all or should we concentrate only in the direction of Sarajevo.

24        Q.   Only towards Sarajevo, but can you tell us something about the

25     population of the Igman and Rajlovac brigades.  Who populated those

Page 37180

 1     areas?

 2        A.   The area of the Igman Brigade was actually the area of Blazuj and

 3     Hadzici and that was predominantly a Serb-populated area.  As for

 4     Rajlovac, it was also populated by Serbs.  Opposite the Rajlovac Brigade,

 5     and you said that I can start also speaking about the positions of the

 6     BH Army, this was held by the 2nd Motorised Brigade, and it was dominant

 7     in the areas of Sokolj and Brijesce Brdo, all the way up to Zuc.  We can

 8     see here how much effort this brigade made with the 1st Motorised to

 9     penetrate into the Serb area.  You can see clearly from the map because

10     this map shows the movement of Muslim positions vis-a-vis the Serb

11     position.  In the legend we saw that we had ten positions --

12             JUDGE KWON:  Just a second.  Yes, Ms. Edgerton.

13             MS. EDGERTON:  I'm very sorry, Your Honour, but can the General

14     be encouraged to speak a little bit more slowly and Dr. Karadzic also to

15     pause before he speaks.

16             JUDGE KWON:  Now, Mr. Karadzic and Galic must have understood

17     your intervention.  By the way, this is a question for Mr. Robinson or

18     Ms. Edgerton:  Do we not have our evidence -- map depicting the

19     various -- the brigades of Sarajevo-Romanija Corps' zone of -- area of

20     responsibility?

21             THE ACCUSED:  I think so, yeah.  There are some already admitted.

22             MS. EDGERTON:  Throughout the Sarajevo-specific court binder map

23     book we find these maps.

24             JUDGE KWON:  Depicting the areas of responsibility of various

25     brigades of the Sarajevo-Romanija Corps.

Page 37181

 1             MS. EDGERTON:  Yes, Your Honour.  Going from the rear, map number

 2     32, which dates from 1995.

 3             JUDGE KWON:  Have we admitted them all?

 4             MS. EDGERTON:  I'll just check with Mr. Reid, but I actually

 5     think so, Your Honour.

 6             JUDGE KWON:  Very well.  I'll leave it at that.  Please continue,

 7     Mr. Karadzic -- just a second.  Yes --

 8             THE ACCUSED:  The only --

 9             JUDGE KWON:  Just a second.

10             MR. PILETTA-ZANIN: [Interpretation] Somewhere at line number

11     16 -- no, no, no.  I'm sorry.  No, no, no.  Everything is in order.

12             JUDGE KWON:  Yes, Mr. Karadzic.

13             THE ACCUSED:  The only value of this map is that this is from

14     1992, when General Galic started to command, and that's showing changes

15     of the line.

16             JUDGE KWON:  Yes.  I understood, but I was wondering whether we

17     have separate map admitted depicting the areas of responsibility of the

18     Sarajevo-Romanija Corps.  Let's continue.

19             MR. KARADZIC: [Interpretation]

20        Q.   General, can you please speak slowly and just tell us roughly

21     where the positions of the brigades were in your time?

22        A.   Both the brigades?

23        Q.   Yes.

24        A.   The 3rd Brigade of the --

25             THE INTERPRETER:  Interpreter's note:  We are having problems

Page 37182

 1     hearing the witness since he's so far away from the microphone.

 2             JUDGE KWON:  Mr. Galic, since you are far away from the

 3     microphone, the interpreters are having difficulty to follow you.  So

 4     could you speak a bit louder and more slowly, please.

 5             THE WITNESS: [Interpretation] Thank you very much.  I'll do my

 6     best.

 7             The next brigade of the SRK was the Vogosca Brigade, which was

 8     later merged with the Rajlovac Brigade and the Centar Brigade, and that

 9     constituted the 3rd Sarajevo Brigade.  It is important to note here that

10     in Vogosca there were huge industrial and commercial potentials that the

11     brigade was supposed to protect.  And in Rajlovac we had a repair and

12     maintenance depot called Oro.  This --

13             THE INTERPRETER:  We didn't hear the witness saying the name of

14     the brigade.

15             JUDGE KWON:  Just -- can we get a wireless microphone?  If

16     necessary, we can take a short break.

17             In the meantime, we'll continue.

18             General, could you repeat your evidence from where you referred

19     to some several names of a place.

20             THE WITNESS: [Interpretation] This refers to the disposition of

21     the SRK brigades.  In the Vogosca area, we had a large number of

22     industrial and military production facilities, and that was Pretis and

23     Tas.  Then in Rajlovac we had a repair and maintenance depot called Oro.

24     Then I said that the Vogosca Brigade and the Rajlovac Brigade and the

25     Centar Brigade were later merged into one single brigade which was named

Page 37183

 1     the 3rd Sarajevo Brigade.

 2             Let me say something about the BH Army area.  We can see here

 3     that with respect to this disposition, there is the 1st Mechanised

 4     Brigade holding the area towards Zuc up here.  I think this is this part

 5     here.  It's a feature that is overlooking the whole area, and it covers

 6     Vogosca, Rajlovac, and the valley of the entire river Bosna.  They were

 7     holding Orlic, the Vogosca Brigade.  I know that there was mention of

 8     other brigades such as 112th and other BH Army brigades, but basically

 9     this was the area held by [indiscernible] brigades, Bugarsko [phoen],

10     Orlic, and other places.  What is interesting here, in view of the

11     disposition of the BH Army, we can see that their zones go all the way to

12     the centre.  That's how they're marked.  There was no indication of what

13     is the civilian zone and what is the military zone because the brigade

14     zone went all to centre and then we had the area of the next brigade.

15             Now, there's another brigade there, the SRK brigade, and that was

16     the 1st Romanija Brigade.  Together with the mixed anti-armour regiment,

17     they were holding the area of Hresa and the general area around it.  It

18     was rather difficult terrain in depth, and we can see that there are

19     no -- almost no roads there.

20             When we handed over the airport, I had a very serious problem

21     with the access to this area and our brigades because they were all up

22     there, and the access was only possible from Sumlovac [phoen], Hresa,

23     towards Vogosca, but since there were no roads there we had to build one

24     throughout the whole war and that was a major project.

25             Facing this brigade was the 7th Mountain Brigade.  It mainly held

Page 37184

 1     Grdonj.  The 3rd Mountain Brigade held Pasino Brdo.  The 2nd Mountain

 2     Brigade held positions between Kozja Cuprija and Pasino Brdo.  The 1st

 3     Mountain Brigade held position between Velika and Mala Colina Kapa all

 4     the way down to Kozja Cuprija.

 5             The next one is the 10th Mountain Brigade holding the positions

 6     mainly at Debelo Brdo, including Brijesce and the rest of the settlement.

 7             One very interesting thing is that the features in this area held

 8     by the BH Army between Grdonj, Pasino Brdo and then Velika and Mala Kapa,

 9     and then to Debelo Brdo, they separated this area toward Trebevic and

10     Hresa which means that Sarajevo could hardly been seen from the positions

11     of the VRS or it could only be seen from certain positions.

12             The next brigade, first we had the 1st Romanija Brigade holding

13     everything, including Grbavica for a period of time.  Later on it was

14     redeployed beyond Grbavica and it held the positions of the SRK.  We can

15     see that opposite this brigade in the area of Grbavica was the

16     1st Motorised Brigade and later on, due to some rearrangement,

17     105th Brigade came and, according to the information I have, it had a

18     different name as well, and it replaced the Mechanised Brigade.

19             The 6th -- now we have the positions of Sarajevo-Romanija Corps

20     as well.  These are the positions held by the 1st Sarajevo Mechanised

21     Brigade including the positions between Mravac [phoen] towards Dobrinja,

22     part of Dobrinja, and now depending on -- on the stage of war it held

23     different positions.  Initially it held positions until July 1993 towards

24     Jahorina, because that's where the front line was, and later on it

25     focused on this area here which is Grbavica and Lukavica and Dobrinja.

Page 37185

 1             JUDGE KWON:  Just a second.  Mr. Karadzic, would you like the

 2     General to continue to explain on the map?

 3             THE ACCUSED: [Interpretation] No, Your Excellency.  I would just

 4     like to ask while he's still standing there, General --

 5             JUDGE KWON:  I was informed that it is possible to install a

 6     microphone with wire so that General can speak while standing.

 7             THE ACCUSED: [Interpretation] We won't be needing it.  We have

 8     finish.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Can you just tell us about this internal front line around

11     Sarajevo.  How long was it, the one that held by the SRK?

12        A.   Well, it varied, but generally speaking, it was around

13     65 kilometres.  And the entire length of the front line of the corps was

14     between 240 and 320 kilometres.

15        Q.   Thank you.  Within this front line of 65 kilometres --

16             JUDGE KWON:  So that now the General can return to his seat.

17             THE ACCUSED: [Interpretation] Yes, he can return to his seat.

18     Are we going to admit the whole map?  Yes.  It's been admitted.  Now the

19     General can go back to his seat.

20             JUDGE KWON:  Yes, Ms. Edgerton.

21             MS. EDGERTON:  And, Your Honours, you'd inquired about whether or

22     not there were other maps which tended to show the brigade's area of

23     responsibility.  We've identified from 1994, P1021, D718; from 1995, D311

24     and P842; from July 1992, P1494; and from 1994 again, D2788.

25             JUDGE KWON:  I just looked at the Exhibit D718, but since the

Page 37186

 1     translation is missing, we have difficulty identifying the name of the

 2     brigades.  But I'll check with the other exhibits and I'll come back to

 3     this issue.

 4             MS. EDGERTON:  Thank you.

 5             THE ACCUSED: [Interpretation] Can we now call up another map.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   A minute ago you said that the area of responsibility stretched

 8     towards the centre.

 9             THE ACCUSED: [Interpretation] So can we please have 1D10502.

10             THE WITNESS: [Interpretation] The zone of responsibility of the

11     BH Army brigades?

12             MR. KARADZIC: [Interpretation]

13        Q.   Yes.  1D10502, can we just look at the legend, and the date is

14     the 19th of December, 1992; is that correct?  In the left corner you can

15     see the dates.  Thank you.

16             Can we now see the whole map.

17             Can you read whose map this is?  What does it depict?

18        A.   This is the layout of disposition of units of the 1st Corps and

19     the -- the staff of the defence of Sarajevo.

20             THE INTERPRETER:  Interpreter's correction:  District Staff.

21             JUDGE KWON:  Please put a pause on your part as well,

22     Mr. Karadzic.

23             THE ACCUSED: [Interpretation] Thank you.  Can we please zoom in.

24             MR. KARADZIC: [Interpretation]

25        Q.   General, can you please tell us, these coloured portions between

Page 37187

 1     the confrontation line and the city, what do they signify, and what is

 2     the importance of these portions, and what did the brigades have in those

 3     areas with regard to their infrastructure?

 4             MS. EDGERTON:  If I may?

 5             JUDGE KWON:  Yes, Ms. Edgerton.

 6             MS. EDGERTON:  There's a legend on the bottom right of this map

 7     that says what those portions -- those coloured portions might signify.

 8             JUDGE KWON:  Could you ask the witness to read out the legend

 9     part.

10             MR. KARADZIC: [Interpretation]

11        Q.   General, please, would you read this legend out for us.

12             THE WITNESS: [Interpretation] "Area of responsibility of the

13     brigades.  Two, area of responsibility of the district defence staff of

14     Sarajevo."

15             You see what the symbols are.  There where the symbols are

16     similar the colours differ, if you agree with me, although perhaps it's

17     hard to discern.

18             Next it's corps units and this refers to the BH Army units.  They

19     have been assigned a yellowish colour.  If it's a battalion, then you

20     have two companies at the front end and two companies at the rear end.

21             Next is the unit of the district defence staff of Sarajevo.  They

22     were -- these units were also plotted into the map but in the colour

23     green.  It's going to be difficult to discern those since the map itself

24     is prevalently green.  And that's all that the legend says.

25        Q.   Thank you.

Page 37188

 1             THE ACCUSED: [Interpretation] Can we look at the central part

 2     again, please.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   General, does this correspond to your knowledge of the way in

 5     which the units covered the town?  Is this town accurate -- is this map

 6     accurate in your experience?

 7        A.   Well, based on what I've just said in reference to that other

 8     map, it does fit into this situation generally.  We see that we have the

 9     District Staff of Vogosca.  That's the staff that I referred to.  We see

10     the line facing Jezersko.  We said that it was the 7th Brigade -- well,

11     all right.  It's the Territorial Defence, as it says here.  And we said

12     that there was the 10th Brigade from Debelo hill to Colina Kapa.  On the

13     other bank of the Miljacka, in the direction of Grbavica, we have the

14     green marking.  It should stand for the Territorial Unit but we know that

15     it was the 10th Battalion.  Perhaps at the time it was still recorded as

16     such.  So it does generally correspond to the situation as I knew it and

17     as I portrayed it on that map.

18        Q.   Thank you.

19        A.   Did you have any other questions?  Should I continue with my

20     answer?

21        Q.   Yes.  What did they have in their area of responsibility from the

22     front end to the rear?

23        A.   We can see -- let's start from the brigades.  This was something

24     that I knew at the time.  In this area, including the 4th Brigade, there

25     were the total of 14 brigades of theirs.  Every brigade had three

Page 37189

 1     battalions on its strength.  If we count the command posts themselves, we

 2     will see how many there were.  So the first brigade times three to get

 3     the battalion posts, and then to get the company post that will be

 4     multiplied by three again.  Based on the disposition of their units, you

 5     can see that they drew battalions and then each of these lines should

 6     represent the positions of companies.

 7             This isn't a disposition with a layout into a line where you

 8     would have all the forces in one line and nothing at the rear.  Here you

 9     can see that every battalion has its depth and the brigades are the ones

10     that constitute the depth of the corps.

11             This part of the map which depicts the deployment of our forces

12     facing theirs is pretty accurate, pretty accurate.  I can't make it out

13     that well, though, on this map, so perhaps my statements can be verified.

14        Q.   General, when you look at this map, can you tell us what were the

15     positions from which fire was opened on your forces, from infantry fire,

16     mortar fire, artillery fire?  What was there at the front end and -- the

17     forward end, and what was there in the depth?

18        A.   Well, as for the forward line, when it comes to features they

19     held almost all the higher ground.  In the first line they would be using

20     infantry weapons.  Let's define what infantry weapons are.  It includes

21     everything up to and including 120-millimetre calibre.  If you take a

22     120-millimetre mortar, that wouldn't be qualified as infantry weapons

23     anymore.  That would already be artillery.  So they used all these

24     various weapons, including all systems of fire.

25             What were the axes along which they were the most active?  Well,

Page 37190

 1     those in the direction of Nedzarici and Dobrinja.  There the fire was

 2     practically nonstop and I'm talking about the fire coming from the

 3     BH Army.  Then, as for the Grbavica area, from the position of the

 4     skyscrapers on the right bank of the Miljacka because they had a

 5     commanding view of the area.  They were also active from Debelo and

 6     Humsko hills.  All of these weapons acted in a synchronised manner.  If

 7     we speak about infantry weapons, we would point out snipers, rifle --

 8     rifles that could fire shells, et cetera.

 9             Another area from which there was intensive fire against our

10     positions was Zuc and Vogosca, that was the axis, the northern part.  As

11     well as the Zuc-Rajlovac axis.  We were able to see on that other map

12     that these were indeed the areas where they were most successful in

13     capturing our territory.

14             One of the important areas that was constantly under attack from

15     them was the axis from Sedrenik to Zlastiste.  That's the area under the

16     10th Mountain Brigade.  There were constant incursions and raids and

17     active fire.  The same applied to Hresa.  There was constant movement of

18     forces.

19        Q.   Take it slowly, General.

20             JUDGE KWON:  Just a moment.  Yes, Ms. Edgerton.

21             MS. EDGERTON:  Your Honour, I don't see the relevance of this

22     line of questioning and the General's evidence to Dr. Karadzic's

23     individual criminal responsibility for any aspect of the Sarajevo

24     component, for example.  What's -- what's the relevance of this?

25             JUDGE KWON:  Mr. Robinson.

Page 37191

 1             MR. ROBINSON:  Yes, Mr. President.  I think we sat through so

 2     much of the Prosecution's case in which they were trying to show that

 3     fire that was opened on Sarajevo was indiscriminate and disproportionate

 4     and was fired at civilian targets with no military reason, and so

 5     General Galic's testimony is trying to lay the basis to show what the

 6     military reasons were for the fire that was directed into Sarajevo.

 7             JUDGE KWON:  Would you like to add anything, Ms. Edgerton?

 8             MS. EDGERTON:  I'll leave it for the moment, but I see the

 9     testimony as talking not about fire directed into Sarajevo but nothing

10     other than fire directed at Serb forces.

11             JUDGE KWON:  The Chamber will allow the accused to continue the

12     line of questioning.

13             Please go ahead.

14             THE ACCUSED: [Interpretation] Thank you.

15             MR. KARADZIC: [Interpretation]

16        Q.   Thank you.  General, you started telling us about the weapons

17     that they used to fire upon you from their depth.  Can you continue?

18        A.   As for their depth, they used artillery weapons that were

19     positioned at the foot of Hum, thereabouts.  Those were 105-millimetre

20     howitzers.  They also fired from tanks in part.  There was mortar fire,

21     and, as I've already said, other infantry weapons.

22        Q.   Thank you.  What was your response when fire was opened at you

23     from one of those positions?  What would be the positions you would be

24     responding from and to what extent?

25        A.   When it comes to our response to their fire, it largely depended

Page 37192

 1     on the forces that they used to fire upon us.  If they used sniper units,

 2     because they did have sniper units, whereas the SRK did not, we had some

 3     sniper rifles but not sniper units, we tried to return adequate fire.

 4     What does it mean, adequate fire?  To return fire with the same assets

 5     that we had been fired upon if we had those assets.  If they opened fire

 6     on us from snipers, then we'd use snipers as well or other infantry

 7     weapons if we didn't have enough snipers.  If they fired upon us from

 8     mortars, then although one could return fire from other weapons, the best

 9     way to return fire is from mortars.

10             The problem was, of course, to distinguish the various assets and

11     the issue of proportionality.  Now, why?  If you look at the map and, of

12     course, in reality this would be easier to see, the BH Army units were

13     commingled with civilians, and this applied to the situation regardless

14     of whether we're talking about the more proximate or more distant front.

15     So we applied all those principles when returning fire, especially when

16     we were dealing with an urban area.  Primarily we wanted to neutralise as

17     our target the source of fire.  So we would open fire at that particular

18     source of fire or pursuant to orders.  Everybody had to have orders to

19     act upon.

20             Mr. President, I have to stress here what the steps were that we

21     took in order that we may achieve the adherence to the principles that

22     I've just mentioned.  First of all, within the corps, we took a number of

23     measures and activities that would ensure that our return fire was indeed

24     the way it should be.  And if you will allow me to, I will list the

25     various steps that the corps had to take.

Page 37193

 1        Q.   Can you please tell us --

 2             JUDGE KWON:  Mr. Karadzic, repeat your question.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   General, tell us who would it be who would issue orders and what

 5     sort of orders did you receive?  And in what way did you make sure that

 6     there was efficiency and proportionality?  What was your view of their

 7     civilians and casualties?  First of all, tell us who could issue orders,

 8     what sort of orders did you receive, and what sort of orders did you in

 9     turn issued?

10        A.   Let me take it in this order:  I will first speak about the

11     orders that we received and what they contained.  So first of all, from

12     the superior command and from you we received orders that all the 1949

13     Geneva Conventions be adhered to, complete with Protocols I and II.  I

14     would then in turn issue such instructions further down the corps, and I

15     think that everyone was aware of this.  Of course, one has to bear in

16     mind the fact that we were at war.  It is really hard to reach every

17     soldier and to train him, but we did do our best to reach every soldier

18     down the line and convey that order to him.

19             The next order that I would issue would be that the civilians

20     should not be the target of the attack.  And the same applied to civilian

21     features, civilian buildings and those that enjoyed protection.

22             Now, given the situation in Sarajevo, how far was it possible to

23     distinguish between soldiers and civilians?  We did alert UNPROFOR and

24     others during the war that it was very difficult to distinguish soldiers

25     from civilians because, first of all, not all of the soldiers wore

Page 37194

 1     uniforms.  Secondly, not all of them carried weapons.  Some of them would

 2     carry weapons only when they were headed to the front, to the

 3     confrontation line.

 4             We had information to the effect that they had been using

 5     UNPROFOR uniforms, especially those belonging to the French UNPROFOR

 6     forces.  When we alerted them to this, they said they didn't know.  And

 7     we said, "Why don't you investigate the information that we have that the

 8     other side was doing this?"  We also had information that they were using

 9     VRS uniforms.

10             Under those circumstances, to be able to distinguish at some

11     distance who a civilian or who a soldier was and to demand from soldiers

12     manning positions to be absolutely certain as to who was a civilian or

13     who was a soldier was quite difficult.  Nevertheless, that was the order.

14     I issued such an order, and quite a few UNPROFOR members did concede when

15     they came here that, during the war, if I received information that there

16     were civilian casualties, I ordered that the attack be stopped.

17             We also took steps to protect our civilians as well as theirs by

18     alerting them to the fact that the facilities such as hospitals, schools,

19     daycare centres, education institutions, that they not be used by the

20     BH Army.  And we did protest with UNPROFOR, and I believe that UNPROFOR

21     themselves protested with the BH Army against the use of such facilities,

22     because there the problem would arise of how to return fire against such

23     features.

24             One prominent problem was that of the Kosevo Hospital, when

25     mortar fire was opened from that building.  On a number of occasions we

Page 37195

 1     protested against this practice, this was our duty, but to not much

 2     avail.  Likewise, UNPROFOR features were used to mask their activities.

 3     We lodged our protest on that score as well, but it seemed to fall on

 4     deaf ears among those in the BH Army.

 5             Furthermore, as soon as I took up my position, I issued an order

 6     detailing the use of -- the permitted use of artillery.  I always asked

 7     that a report on the use of artillery be submitted to the -- to one level

 8     up the chain of command.  For instance, every brigade had its artillery,

 9     as did the corps.  So a regiment commander could not issue a task to the

10     artillery to open fire on Sarajevo unless he had been given that order

11     from his superior command.

12             Now, was this always adhered to?  Well, it depended on the area.

13     It depended on the forces that were firing upon the SRK.  As I've already

14     said, the problem lay in the manoeuvres and movement about the town.  It

15     was difficult to discern whether we were returning fire against a

16     military target or whether it was no longer there, because if the asset

17     that had fired upon us was mobile, then it would no longer be on the spot

18     from which it fired.

19             Furthermore, we took measures to spread information about it.  We

20     lodged protests with UNPROFOR.  In addition to all the intelligence we

21     had from people deserting their ranks and from reconnaissance, they were

22     the ones that were the best source of information for us as to what was

23     going on in the territory of the BH Army, and I think that we will be

24     talking about these protests later.

25             So these were the main measures and activities that we took in

Page 37196

 1     order to ensure that the attacks were legitimate.

 2        Q.   Thank you.

 3             JUDGE KWON:  Just a second.  Yes, please continue.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   How did you know where their weapons were deployed and what the

 6     source of fire on you was?  How did you know that, and how did you

 7     control your response?

 8        A.   The information about their positions, their units, their weapons

 9     came mostly from our intelligence work and from our reconnaissance.  We

10     got reports from our reconnaissance what had been spotted where and so

11     on.

12             A good way was to get information from people crossing the lines,

13     crossing over from the part of Sarajevo controlled by the BH Army.  We

14     would have some 15 to 20 such persons per day coming from the parts of

15     Sarajevo controlled by the BH Army.  We, of course, checked the

16     information obtained from them against other information, but mostly it

17     would be accurate.

18             At the time, we were unable to conduct other reconnaissance.

19     There was a little bit of electronic reconnaissance by tapping their

20     communications, and this way we knew from where they were shooting, but

21     there was always a risk involved, because it's impossible to check the

22     reliability of information so obtained, because they may have wanted to

23     trick us, speaking about these things over the radio.  So when they say,

24     "Open fire from mortar from position so-and-so," that may be accurate,

25     but it may also be a ruse, and we were unable to tell.

Page 37197

 1        Q.   When did you reconnoiter and how?

 2        A.   Well, you mean in what depth.  That would be a better question.

 3     According to the deployment of forces, both our and enemy forces, our

 4     reconnaissance was limited because the configuration of terrain was bad.

 5     There were high buildings blocking our view, and it was difficult to

 6     reconnoiter in depth.

 7             When the forces were near each other, there were stretches where

 8     there was only a war [as interpreted] between our forces and theirs, and

 9     then of course it was not a problem to know from where they were

10     shooting.  Or if I take Dobrinja as an example, it was easy to tell, but

11     it was always a problem to reconnoiter the depth of their territory.

12     Whether their command post was in one house or another or in a different

13     building altogether, that was difficult to prove because we know it

14     changes always.

15             JUDGE KWON:  Just a second.

16             Yes, Ms. Edgerton.

17             MS. EDGERTON:  Please, again, if the General can be reminded to

18     speak a bit more slowly.  And with a transcript correction at page 52,

19     line 13.  It should be "wall" rather than "war," and I think that mistake

20     is because of the speed at which the General speaks.

21             THE WITNESS: [Interpretation] Yes, that's my problem.  I speak

22     fast and it's difficult to solve it at this trial, but I will try to

23     adapt to your needs.  Thank you.

24             MR. KARADZIC: [Interpretation]

25        Q.   General, I believe that it's also a matter of interpretation.  We

Page 37198

 1     see that reconnaissance is mentioned.  Do you mean -- really mean

 2     reconnaissance or observation?

 3        A.   Well, I mean both.  Yes, you have to be in a favourable position

 4     to reconnoiter, but of course you can also observe all the time.

 5             JUDGE KWON:  We are still hearing the interpretation of your

 6     first answer, which was not completed.  Could you repeat whether it was a

 7     reconnaissance or observation?  Could you repeat from there?

 8             THE WITNESS: [Interpretation] Mr. President, it was both

 9     reconnaissance and observation.  These are two different things.  You can

10     reconnoiter by moving, or you can -- forcefully.  And observation, that's

11     when you have a position somewhere and you observe what's happening in

12     front of you.  But we had both, reconnaissance and observation.

13             Is that a sufficient answer?

14             MR. KARADZIC: [Interpretation]

15        Q.   Thank you.  I hope it is.

16             Please explain to the Chamber, while you were observing, where

17     did you respond?  Was there retaliation?  If they shot at your staff, did

18     you shoot at their staff or how did you respond?  What was the direction

19     of your fire?

20        A.   The question is clear.  I believe it's a pertinent question too.

21     Why?  Because the selection of a target in Sarajevo was always a

22     difficult task.  We opened fire not on their staff to retaliate, although

23     my staff at Lukavica, where I was on the upper floor, sometimes there

24     would be 20 shells falling over my head, but I never ordered to return

25     fire on the staff of the 1st Corps or the staff of the Supreme Command.

Page 37199

 1     I mostly protested to UNPROFOR to stop fire.  If that wasn't done, then

 2     we would target the source of their fire.

 3        Q.   Did you always respond, and what was important for your decision

 4     when to respond and when not?

 5        A.   There were a number of factors I took into consideration.  There

 6     were few decisions of mine to open fire at a certain target.  Basically

 7     what influenced my decision when and how to respond was the source of

 8     their fire.  If it was rifle fire, then we responded with rifle fire.

 9     But then a problem arose that was difficult to control.  For example, in

10     the evening, rifle fire would commence at a section of the front, and

11     then the whole front line would start firing although there was no reason

12     for that.  It is very difficult to control from both sides.  Now, if that

13     is a response or not is open to discussion because you would hear replies

14     such as:  "We say hello this way to each other to show that we're still

15     alive and to celebrate."  But it was a problem on both sides.

16             However, mostly we responded in kind.  If there was mortar fire,

17     we respond with mortar fire.  But there was no incriminate -- there were

18     no incriminated artillery attacks in those annexes 1 and 2.  There was

19     only -- there were only mortar attacks that were incriminated, except for

20     one incident but the prosecutor very soon gave up on that.

21        Q.   Did you respond to every provocation, to every instance when fire

22     was open at you?

23        A.   I must say to the Trial Chamber that it was difficult, but we

24     were pretty much successful not to respond to fire during cease-fires,

25     because if somebody's killing your people and somebody orders you to bear

Page 37200

 1     it without returning fire, it is very difficult, but we were successful

 2     to some extent.

 3        Q.   Were orders about bearing such things issued?

 4        A.   Yes.  I believe that there were even similar orders from you,

 5     especially in a situation when there were cease-fire agreements.  Then

 6     orders were issued from the highest levels not to open fire.

 7             JUDGE KWON:  Mr. Galic, just a minute ago you stated that, I

 8     quote:  "We were successful to some extent."  What did you mean by "to

 9     some extent"?  Could you clarify?

10             THE WITNESS: [Interpretation] You mean refraining from opening

11     fire.

12             JUDGE KWON:  Yes.

13             THE WITNESS: [Interpretation] Thank you.  I want to tell you the

14     truth.  We were not always fully successful to stop these attacks or,

15     rather, fire in response to enemy fire, but essentially we were

16     successful and sometimes even fully successful in following such an

17     order.  That's what I meant.  I'm not sure if I was clear enough.

18             For example, if I can continue to clarify some more, after the

19     TEZ agreement there was a cease-fire, and there is no information either

20     from UNPROFOR or from other sources that we opened artillery fire at that

21     time except for some sniping.  We were unable to fully control that.

22             JUDGE KWON:  I'll leave it at that.

23             Yes, please continue, Mr. Karadzic.

24             MR. KARADZIC: [Interpretation]

25        Q.   Under whose control is the opening of fire from greater calibres,

Page 37201

 1     and under whose control the opening of fire from light weapons?  And how

 2     can you stop an attacked unit from returning fire?

 3        A.   The control of fire from light weapons was at the level of

 4     companies and platoons, and the fire from mortars and artillery was at

 5     level -- at battalion level and up, whereas heavy artillery was under the

 6     corps.

 7             Speaking about sniping, and I've gotten used to the expression,

 8     but --

 9        Q.   But I'm saying from the trenches.  When there is infantry fire,

10     who controls that, and how can you achieve that the attacked unit does

11     not return fire?

12        A.   Well, at that time I couldn't influence that because once I get

13     the information about such a thing, it was too late already.  The platoon

14     commander and the company commander can directly influence it, but not

15     always the battalion commander.

16        Q.   Before we tender this map, can you tell us, from the southern

17     slopes to the northern slopes, what could be used to open fire from the

18     slopes of Trebevic from Serbian positions at the Muslim positions at Hum

19     and the other way around?

20        A.   Yes, I understand.  If we take the zone of defence of the

21     1st Corps of the BH Army in Sarajevo, we'll see that the size of the area

22     is 20 by 10 kilometres.  If I remember well.  And then we can see what

23     can be used to fire through that area.  If we're talking about rifle

24     fire, when it comes from rifles then it's most times qualified as

25     sniping, but I as a military professional, I don't agree with that

Page 37202

 1     terminology because a sniper is a defined term.

 2             Rifle fire is successful up to a distance of 400 metres.  You can

 3     use hand-held rocket launchers --

 4             THE INTERPRETER:  Could the General please repeat these

 5     distances.

 6             JUDGE KWON:  Just a second.  Could you repeat from the distances.

 7             THE WITNESS: [Interpretation] I gave the general ranges.  So a

 8     sniper with an optical sight that we had and that the BH Army had as

 9     well, maybe theirs were more modern, one could be successful up to

10     400 metres.  And you can also be successful up to 800 metres.  An

11     ordinary rifle up to 400 metres.  A automatic rifle has an even smaller

12     range.

13             Now, mortars have the range depending on the calibre, 62, 82 and

14     182 millimetres, which means the range between 3 and 8 kilometres.

15     Hand-held launchers, I said about 200 metres.  Rifle grenades, between

16     150 and 200 metres.  Recoilless guns, as the ones they had, approximately

17     800 metres, between 4- and 800 metres.  The ones they had and we also had

18     of were of the 82-millimetre calibre.

19             THE ACCUSED: [Interpretation] Thank you.  Can this map be

20     admitted into evidence?

21             JUDGE KWON:  Mr. Karadzic, please bear in mind the giving --

22     having some pause after the witness's answer.  Please pay attention to

23     the transcript on your part, please.  Probably we need a translation.

24     It's better to have translation of the title and the legend separately,

25     although the witness read them out in the courtroom.

Page 37203

 1             Do you have any objection, Ms. Edgerton?

 2             MS. EDGERTON:  No.

 3             JUDGE KWON:  We'll mark it for identification pending translation

 4     of those parts.

 5             THE REGISTRAR:  As MFI D3383, Your Honours.

 6             JUDGE KWON:  Before we move away this map, what does a BB mean,

 7     Mr. Galic?

 8             THE WITNESS: [Interpretation] BB?  Look, there are lots of

 9     acronyms that we use.  Now I cannot remember what it stands for.  I

10     cannot translate it for you because there were too many of these

11     abbreviations.  Can you please tell me where you found it?  It could have

12     been BR?

13             JUDGE KWON:  There are many BBs here.  If we zoom in at any part

14     of the map.

15             THE WITNESS: [Interpretation] No.  I suppose it's LR.

16             THE ACCUSED: [Interpretation] Can we look all the way to the

17     eastern portion, and we can find BB there.

18             MR. KARADZIC: [Interpretation]

19        Q.   Maybe it's a Mountain Brigade?

20        A.   A Mountain Brigade abbreviation is BBR.

21        Q.   How about lesser units?

22        A.   A Mountain Battalion, that would be a BB.

23             JUDGE KWON:  That sounds plausible.

24             THE WITNESS: [Interpretation] Yes, it's possible that the BB was

25     that, but if you have an R -- it must be an R there because it would

Page 37204

 1     indicate that it's a Mountain Battalion.

 2             JUDGE KWON:  Do you see a BBR on the map and below which with the

 3     colour you see BB.  So I take it your explanation that it should be a

 4     Mountain Battalion sounds --

 5             THE WITNESS: [Interpretation] This means -- I'm sorry.  That's

 6     their designation.  That's how they did it, and that's how they

 7     designated a Mountain Battalion.  Well, all right.  A Mountain Battalion.

 8     Because all these units were later abolished, and this term was not in

 9     use very much.

10             JUDGE KWON:  And MB on this map would mean a Motorised Battalion.

11             THE WITNESS: [Interpretation] MB could be a Mechanised Battalion,

12     but if it is motorised, then it would be MTB, which will differentiate it

13     from the other one.

14             JUDGE KWON:  Yes.

15             THE WITNESS: [Interpretation] I hope I gave you an understandable

16     explanation.  If I haven't, please ask me.

17             JUDGE KWON:  Thank you.  We see both MTB and MB, so thank you.

18     Let's proceed.

19             MR. KARADZIC: [Interpretation]

20        Q.   Sir, speaking about responses, but let me first ask you this:

21     Apart from responses, did you have any artillery preparations or

22     artillery fire targeting the city, and what would be the purpose of

23     those?

24        A.   Apart from responding to enemy fire, as far as I know, there were

25     no other artillery activities or otherwise targeting the city.  Whenever

Page 37205

 1     something happened, I always inquired about it and the answer I got was

 2     always that that was the response to the enemy action.

 3             JUDGE KWON:  Could the Chamber move into private session, please.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             JUDGE KWON:  Yes, please continue, Mr. Karadzic.

14             MR. KARADZIC: [Interpretation]

15        Q.   Did they make any artillery preparations, and what is the

16     difference between their artillery fire and your artillery fire?  And I

17     mean the SRK artillery fire.

18        A.   Their fire, unlike our fire, if they had selected a specific

19     target, they would fire at it several times without any discrimination

20     with regard to whether it was a military or a civilian target.  I believe

21     that they wanted to target a military facility but that was not always

22     the case.  According to the information and intelligence that we had and

23     on the basis of the orders that we issued, the point was that only

24     military facilities can be a target and that civilian targets are

25     prohibited from being fired at.

Page 37206

 1        Q.   How many infantry attacks you had with the aim of penetrating

 2     into the city that involved artillery preparations, and how many of those

 3     attacks did they have?

 4        A.   We saw it on the map.  There is this big area heading towards the

 5     city, and that was the area of Otes, and this is where we made

 6     preparations.  If we look at this map here, we can see that they shifted

 7     their positions 11 times within one year, and for shifting the positions

 8     they had to open fire, and that is why they had more preparation work

 9     than we did.  And the more active operations with regard to Sarajevo were

10     in the area of Zuc after December 1992, and the improvement of the

11     positions that I indicated in the map that were disturbed sometime in

12     1993 -- as for the other activities mainly involved fending off their

13     penetrating the areas that I indicated earlier.

14        Q.   Was Zuc an urban part of the city?

15        A.   No, it wasn't.  Orlic, Zuc, and other features were under our

16     control for a time, and I went there.  There were not too many houses

17     there, at least not close to one another, and Zuc itself was not an urban

18     area, and the next feature was Orlic, which was rather an elevated one,

19     but not many people know of Orlic.

20             THE ACCUSED: [Interpretation] We can remove the map.

21             MR. KARADZIC: [Interpretation]

22        Q.   When you responded to their fire, did you take into account the

23     possible collateral damage in terms of injuries and losses incurred by

24     civilians, and how did you treat this issue, the issue of their civilians

25     and possible civilian casualties with regard to targeting a specific

Page 37207

 1     military facility that had to be destroyed?

 2        A.   Earlier I said that on a regular basis, whenever we responded to

 3     fire coming from the city and the BH Army, we responded to mainly

 4     military facilities that fire came from and that posed a threat to us.

 5     Now, in a situation where you have a city, how can one calculate, and

 6     what right the commander has with regard to proportionality?  It is not

 7     specified anywhere.  Nobody says what proportional response is required.

 8     It depended on the objective.  If we wanted to destroy or neutralise a

 9     target, it was possible to have the civilian casualties as a by-product

10     of such an action.

11        Q.   Thank you.  Did you undertake any precautionary measures with a

12     view to avoiding, or how did you treat this issue and what measures did

13     you undertake in that regard?

14             JUDGE KWON:  Just a second.

15             Yes, Ms. Edgerton.

16             MS. EDGERTON:  I'm sorry, Your Honour, to keep repeating this,

17     but I've spent the morning listening to the French translation just to

18     try and ensure and see how things are keeping up, and there is difficulty

19     because of the speed at which Dr. Karadzic and the General are speaking

20     with one another, and it seems like the only way I can address that is to

21     keep reminding or asking for reminders to be issued.

22             JUDGE KWON:  Yes, Mr. Piletta-Zanin.

23             THE INTERPRETER:  Microphone, please.

24             MR. PILETTA-ZANIN: [Interpretation] I've been following the three

25     discussions, the original language, the French translation, and the third

Page 37208

 1     language, and I must say that the French booth is doing an extraordinary

 2     work.  They are even following the discussions live from the courtroom,

 3     and I would like to congratulate them for that.

 4             JUDGE KWON:  You will understand under what circumstances our

 5     colleague Judge Lattanzi is working.  Please put a sufficient pause.

 6             Yes, please continue.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   According to what you know, during the time while you were the

 9     SRK commander, did civilian losses occur and did they exceed the

10     justification of military purposes?  And to what extent did the civilians

11     suffer as a result of our responses to their fire?

12        A.   Civilian casualties in Sarajevo, to the extent that I was aware

13     of that and according to the reports that I was receiving at the time and

14     whether this information was correct, all of these casualties were

15     proportionate to the targets that were fired upon.  There was some

16     indication that there was sometimes an excessive use of artillery, and

17     that was something that was not entirely possible to control by officers.

18             The losses incurred in Sarajevo, the problem is always who caused

19     these losses.  Everybody was saying that these major losses, for example,

20     in the case of Markale, the initial information was this had been done by

21     the Muslim forces.  I believe that General Rose said that when he

22     testified here.

23        Q.   We'll come back to Markale because that deserves special

24     attention.

25        A.   You asked me about mass losses, and I think that that was one of

Page 37209

 1     the examples of major losses that I can give you an answer about.

 2        Q.   Thank you.  Did you have observers, international observers,

 3     posted next to our weaponry, and how many posts were there, if any?

 4        A.   I was always asking for this contingent of UNPROFOR, that is to

 5     say, UNMOs who came over to our side, that they receive the best possible

 6     treatment and protection.

 7        Q.   How many of them were there?

 8        A.   We'll come to that.  Yes, there were exactly 11 observation

 9     posts, and I think that there were eight of them on the Muslim side.

10     Practically every piece of heavy weaponry had one UNMO next to it, and

11     they constantly observed when fire was opened and what was happening.

12             I can tell you that I went to see those UNMOs, and it is

13     interesting that I was receiving protests from UNPROFOR, from the Muslim

14     side, whereas the UNMOs on our side never informed me that our weaponry

15     was used not according to plan and without proper purpose.

16             THE ACCUSED: [Interpretation] That's P2 -- that's P01431.  That's

17     the map of observation posts.

18             MR. KARADZIC: [Interpretation]

19        Q.   Could these 11 observation posts have covered the artillery and

20     mortar pieces of the brigades and corps, and could there have been fire

21     without them noticing it?

22        A.   Well, there could have been.  They covered all the positions of

23     the various brigade groups, and since they were deployed to the areas of

24     the brigades, they covered the positions of other artillery groups as

25     well.  So at least the way they presented it to me, there could not have

Page 37210

 1     been such fire without them noticing it.

 2             There would be the various sector commanders in Sarajevo, as well

 3     as the entire military observers' contingents, and those military

 4     observers who were on our side, they were all reliable sources of

 5     information, unlike all the others.  They were the only ones we could

 6     rely upon for information.

 7        Q.   From the observers who were on the Serbian side, did you receive

 8     the sort of formal or informal protests of the sort that they gave to the

 9     other side?

10        A.   Well, I spoke to all of them.  I was the sort of person who would

11     receive everyone to the extent I could, and as far as I remember, they

12     never alerted me to the fact that the artillery forces of the SRK were

13     acting in a way that would not have been legitimate.  I didn't receive

14     ever information to that effect.

15             As for the SRK on the other side -- or, rather, as for the other

16     side, they would receive information from UNPROFOR and would then lodge

17     protests to UNPROFOR.

18        Q.   If you received information from the observers who were deployed

19     on the Bosnian side, what would your response be then to that sort of

20     information that the SRK had opened fire, to these allegations?

21        A.   Well, I can tell you that we took very seriously all such

22     allegations that came our way and treated them responsibly.  Each and

23     every protest or allegation was checked upon.  I made sure that all the

24     allegations behind each and every protest coming from UNPROFOR was

25     checked.

Page 37211

 1        Q.   And to what extent or to what degree were the allegations behind

 2     these protests proved to be true or not?

 3        A.   Well, the degrees of accuracy or inaccuracy in war are very

 4     difficult to establish, but I can tell you that in the majority of the

 5     cases whenever I tried to double-check these allegations, the response

 6     was that they were returning the fire because they had been previously

 7     fired upon by the enemy or that they had not been opening fire in that

 8     period of time at all.  That would be your typical two responses that

 9     would come up from our units.

10             In that context I believe that UNPROFOR found it hard as well,

11     especially in view of the fact that they only had a handful of

12     observation posts on the side of the BH Army.  It was very difficult for

13     them to establish whether indeed a military target was fired upon and

14     whether artillery was involved and what sort of forces had been involved

15     on the side of the BH Army.  And there were a great many things that they

16     were doing at that period of time.

17        Q.   They who?

18        A.   I'm talking about the BH Army.  I'm talking about the various

19     problems that were encountered with some commanders, paramilitary groups.

20     There may have been some blood feuds among them.  Among their forces

21     there were some settlings of scores where civilian casualties were

22     involved.  This was the situation we were confronted with in the war.

23     And I recall clearly that on the 26th of October, 1993, Dusan Topalovic,

24     Caco, was killed.  That day was a dangerous day for everyone in Sarajevo,

25     and a sickening one.

Page 37212

 1             THE ACCUSED: [Interpretation] Thank you.  Your Excellencies, is

 2     it time for the break?

 3             JUDGE KWON:  Yes.  We'll have a break for 45 minutes and resume

 4     at 17 past 1.00.

 5                           --- Recess taken at 12.31 p.m.

 6                           --- On resuming at 1.20 p.m.

 7             JUDGE KWON:  Yes, Ms. Edgerton.

 8             MS. EDGERTON:  Your Honour, just to follow up on D718 that we

 9     were discussing earlier on today, Mr. Reid has helpfully advised me that

10     the translations we were referring to can be found at P5067, 5057, and

11     5055, and are on maps -- so-called maps 26, 27, and 28 in the map book.

12     So they're on the immediately following pages in the map book.

13             JUDGE KWON:  No.  We have translation of the legends, but I --

14     shall we upload P1021, which is the original D718.  It's difficult to

15     read Cyrillic, the name of the several brigades, et cetera.

16             MS. EDGERTON:  Indeed.  I see now, Your Honour, and I apologise

17     for misunderstanding you.

18             JUDGE KWON:  So since we are talking about that issue, I wonder

19     whether in co-operation between the parties, whether Prosecution is

20     capable of producing a map with English translation or the -- I can

21     notice SRK, but the others are a challenge, really.

22             MS. EDGERTON:  Of course.  I'm sure we can arrange something,

23     Your Honours.

24             JUDGE KWON:  Otherwise we will have to ask the witness to write

25     down in Latin, but if the parties are capable of producing another

Page 37213

 1     English version of this map, I'm -- that would be much convenient.  Thank

 2     you.

 3             We can get rid of this map now.

 4             Yes, please continue, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   General, can we now address this issue, how the issues that you

 8     testified about in the previous two sessions concerning documents played

 9     out in reality.  Let's especially focus on the fire into town.

10             THE ACCUSED: [Interpretation] Can we have 1D01146.

11             MR. KARADZIC: [Interpretation]

12        Q.   Let's especially focus on the fire coming into town.

13             This is a document issued by your command, dated the

14     13th of September, 1992.  You speak of the fire that was opened in

15     paragraph 1.  And in paragraph 2, you say that you spoke to Grey and that

16     what was discussed was the opening of a new position for the control of

17     heavy weapons in Nedzarici, and then it was said that Grey talked with

18     the Muslim side who sought to have our weapons placed under control, and

19     then they talk about the control of their own.  At the same time, they

20     emphasised that considering the losses they have suffered, war is more

21     important to them than weapons controlling humanitarian aid.

22             Do you recall this conversation?

23        A.   Well, it's been 20 years, and it's difficult to remember each and

24     every other document, but I do recall the conversation with Grey, and I

25     do recall the questions he put to me, and I agree that this is the way it

Page 37214

 1     happened.

 2        Q.   Very well.

 3             JUDGE KWON:  Put a pause, please.  Could you start over again.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Below -- or, rather, the latter part of paragraph 2 you say:

 6             "We believe that contact UNPROFOR is necessary and helpful."

 7             What sort of contacts did you have with UNPROFOR?

 8        A.   I can speak about my personal relationship with them.  I can say

 9     that our relationship was sincere and respectful.  I believed them to be

10     representatives of their countries which were political and military

11     representatives of their countries and respective armies in our region.

12     I believe that they too were in a difficult position.  That's why I tried

13     to help them in anyway I could.  And it is accurately represented here

14     what I said.  I found their contacts very helpful and, especially, if

15     you'll recall when I said that there were quite a few very important

16     pieces of information on the whole that I would receive from them.

17        Q.   Thank you.

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

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D3384, Your Honours.

21             THE ACCUSED: [Interpretation] Excellencies, the map that depicted

22     the areas of responsibility in different colours was, I believe,

23     admitted?  That was 1D --

24             JUDGE KWON:  Yes.  I think we marked it for identification as

25     D3383.

Page 37215

 1             THE ACCUSED: [Interpretation] Can we now call up 1D01150.

 2             THE WITNESS: [Interpretation] Can the text be enlarged a bit.

 3     It's hard for me to read it.  I apologise.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   For the sake of our colleagues in the courtroom, they could have

 6     the English version for themselves, and we could place this one here.

 7             This is another document from your command, dated the 17th of

 8     September, where you say that there was provocative fire and intense

 9     fire.  And then you say the enemy mounted a strong infantry attack from

10     the direction of Pere Kosorica Square with the support of mortars,

11     anti-aircraft machine-guns from the Viktor Bubanj barracks and Velesici.

12     The fire was directed at Grbavica.  You say that the enemy attack was

13     successfully repelled, that one soldier was wounded in combat.  And is

14     this indeed the weapons that opened fire from the direction of

15     Viktor Bubanj barracks in Velesici?

16        A.   Well, this attack on Grbavica, because it's an attack on

17     Grbavica, would happen quite frequently with the support of heavy

18     weaponry.  This was especially the case where sources of fire were from

19     the Viktor Bubanj barracks in Velesici, and I can certainly confirm that

20     this is one of the axes of fire intended for the Sarajevo-Romanija Corps.

21             THE ACCUSED: [Interpretation] Thank you.  Can this be admitted?

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  Exhibit D3385, Your Honours.

24             THE ACCUSED: [Interpretation] Can we have 1D06307.  Thank you.

25     Can the English version be placed at the disposal of other participants

Page 37216

 1     in the courtroom.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   This is again a document from your command dated the

 4     26th of October, 1992.  It says it was sent out at 1400 hours.

 5             How often were there reports for the Main Staff?

 6        A.   Well, there was an operational report that would normally come

 7     out in the evening, and then this supplementary one which would come out

 8     at around 1400 hours.  Although this might be an interim report, because

 9     it's the 26th.  The date that I mentioned previously when there was that

10     problem -- no, no.  Yes, yes.  That's it.  You go ahead with your

11     questions.

12        Q.   It says here that a build-up of forces of unknown strength has

13     been observed in the area of Hrasnica and that four tanks were coming

14     down the Igman slope, and this meant that they were coming down into

15     Hrasnica; right?

16        A.   Yes.  They had a couple of tanks up at Igman.  I don't know if

17     there were four or -- I don't know about the numbers.  We were observing

18     this from the area up from Igman down to Hrasnica and this would

19     particularly have applied to the area that is called Osmice, because that

20     would be the area of Hrasnica, not on the side of the airport.

21        Q.   Just to make this clear, when you say Osmice, is that a different

22     place from Osmice at Trebevic?

23        A.   Yes, Stijena Baba.  When you go in the direction of Pale, that's

24     the place I'm talking about, Osmice.  Whereas the other Osmice is when

25     you head from the area of Hrasnica in the direction of Mount Igman.  But

Page 37217

 1     that's not the main road that goes from Krupac up towards Bjelasnica, no.

 2     This is one of the side roads, not the Krupac-Bjelasnica road, and you

 3     know it better than me.

 4        Q.   Thank you.  There were wounded and killed at Hrasnica.  You say

 5     six dead, 33 wounded, and 70 per cent were civilians.  Was this indeed

 6     the case?

 7        A.   The reports that we sent out to the Main Staff could not be

 8     doctored in any way or in any way whitewashed, and that's why I'm saying

 9     that what is stated here must be the truth.  These are heavy losses to

10     have six people killed and 33 wounded in a day.

11        Q.   And that -- all of that before 1400 hours.

12        A.   Yes.

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

14             JUDGE KWON:  Yes.

15             THE REGISTRAR:  Exhibit D3386, Your Honours.

16             THE ACCUSED: [Interpretation] Can we have 1D06317, please.

17             MR. KARADZIC: [Interpretation]

18        Q.   It's a document issued by your command on the 10th of November,

19     1992.  It's the regular combat report sent out at 1400 hours to the

20     Main Staff.  You say that the enemy shelled the centre of Hadzici and

21     that it targeted Famos from Igman with recoilless guns and ZiSes, and

22     they were targeting the barracks from Mojmilo Hill.

23             JUDGE KWON:  Yes, Ms. Edgerton.

24             MS. EDGERTON:  Your Honour, I haven't risen for about four

25     documents now but I thought it might be timely to make the point I've

Page 37218

 1     raised before you before -- previously, that perhaps Dr. Karadzic could

 2     avoid reading the content of the document to the witness before asking

 3     him the question.

 4             THE ACCUSED: [Interpretation] If I may answer?

 5             JUDGE KWON:  Yes.

 6             THE ACCUSED: [Interpretation] During the previous two sessions I

 7     laid a foundation for all these documents.  Now I want to ask whether

 8     they put up with such fire and why, because here it says that they didn't

 9     shoot back and I want to ask him why.  I must introduce the document,

10     among others for the public too.

11             JUDGE KWON:  I'm not sure the foundation you laid was one that

12     could be considered sufficient.  I will consult my colleagues.

13                           [Trial Chamber confers]

14             JUDGE KWON:  Would you like to add anything, Mr. Robinson?

15             MR. ROBINSON:  Yes, Mr. President.  I think that Dr. Karadzic has

16     done what you've been asking him to do but he didn't do it immediately

17     prior to admitting -- to showing the document, but I don't see why that

18     would necessarily be a requirement.  I think he has laid the foundation.

19     If it's necessary, he can ask were there documents which corroborated or

20     which documented the things that you've discussed in the first two

21     sessions and then show him one by one.  But if he puts a document like

22     this before him and asks him what's this about, I don't see how he's

23     leading the witness given the previous testimony that the witness has

24     already given.

25             JUDGE KWON:  Given that the foundational question he put in the

Page 37219

 1     earlier sessions was such a -- of such a general nature, so the Chamber

 2     would be better off if Mr. Karadzic could put some more specific

 3     foundational questions as we go by, but we'll see.  Let us continue.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   General, you say here under item 2:

 7             "Our units are at the lines we reached and around Sarajevo we are

 8     not opening fire."

 9             Why didn't you open fire around Sarajevo?

10        A.   I must first be reminded if there was a cease-fire at the time,

11     whether there was such an order issued, but we see a problem here in the

12     area of Hadzici, because they were known to open fire at that area often

13     from Igman and other positions.  And these recoilless guns -- gun which

14     also fired, the question is whether it is always necessary to respond to

15     such fire, because if in the meantime there was a cessation of

16     hostilities, it is certain that they had to abide by it.

17             But on the whole and in essence, our forces for the most part,

18     irrespective of the existence of an order to cease fire, as we will see

19     later, mostly refrained from firing.  Why?  I will tell you very openly.

20     Why was it like that?  Whenever we responded, whenever we did anything,

21     there was a general outcry.  The Serbs are doing this or that.  They're

22     killing civilians, et cetera.  Although we certainly only targeted only

23     their military targets.  That's why we refrained from such activity all

24     the time.  I don't know if this was clear enough.

25        Q.   Thank you.

Page 37220

 1             THE ACCUSED: [Interpretation] I seek to tender this document.

 2             JUDGE KWON:  Yes.  We'll receive it.

 3             THE REGISTRAR:  As Exhibit D3387, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   You mentioned cease-fire agreements a minute ago.  How did you

 6     implement them, and what did you do with respect to your subordinate

 7     units in such cases?

 8        A.   There were many cease-fire agreements in and around Sarajevo

 9     which you know better than I.  As far as I remember, there were about

10     10 cease-fire agreements or so and other agreements during those

11     two years.  Those agreements and orders I mostly got from the Main Staff

12     but very rarely from the Supreme Command.  Those orders mostly went

13     through the Main Staff of the VRS and less often they came from the

14     Supreme Command, but occasionally they cited the directive of the

15     Supreme Command.

16        Q.   Thank you.  Did you abide by those, and did you forward these

17     orders to your subordinate units?

18        A.   Before everything else I must say something else.  Each agreement

19     had been prepared politically, morally [as interpreted], and so on, in

20     order to implement it.  Only then could we start ceasing fire, stopping

21     offensive operations, and so on.  I regularly sent out these orders to my

22     subordinate units, and they sent it down the line, down to the last

23     soldier.

24             THE ACCUSED: [Interpretation] 1D06311, please.

25             MS. EDGERTON:  May I just say something for the transcript.

Page 37221

 1             JUDGE KWON:  Yes.

 2             MS. EDGERTON:  Page 75, line 4, should be politically, military,

 3     and so on, rather than "politically, morally, and so on."

 4             JUDGE KWON:  Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   What kind of preparations did you mention for the cease-fire

 7     agreements?

 8        A.   Political and military.

 9        Q.   Please take a look at the preamble of this document.  You refer

10     to the authority of the Presidency of the republic and you order a

11     cease-fire.  Look at the first sentence.  Through the line of

12     subordination and command make sure there is a complete cease-fire with

13     the HVO forces and the Muslim forces in your areas of responsibility.

14             Was it your practice to issue such orders?

15             JUDGE KWON:  Yes, Ms. Edgerton.

16             MS. EDGERTON:  I'm sorry, but is there no translation of this

17     document?

18             JUDGE KWON:  In order for the witness to be able to see the

19     document more easily, we just collapsed the English translation.

20             MS. EDGERTON:  Apologies.

21             THE ACCUSED: [Interpretation] Can we get page 2, please.

22             THE WITNESS: [Interpretation] I would like to stay on page 1.

23             MR. KARADZIC: [Interpretation]

24        Q.   Please go ahead.

25        A.   What I said refers to the preamble of my order.  It is clear

Page 37222

 1     where the order had originated from and it's the Supreme Command.  And it

 2     says down here based on the agreement signed by, et cetera, and by the

 3     authority of the President of Republika Srpska, which means you.

 4             THE ACCUSED: [Interpretation] Thank you.  Can we see the next

 5     page, please.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Here, the fifth bullet point from the top warns individuals that

 8     they may be targeted by snipers with silencers.  But what I'm interested

 9     in the following:  You hold the commanders of brigades and regiments

10     personally responsible for the implementation of this order.  It says

11     commanders will be most strictly punished for any violation because the

12     cease-fire has international significance.

13             Was this strictness of yours usual?  Were you usually so strict?

14        A.   I don't know if I was strict, but I'm sure I was consistent,

15     because when I got an order from my superior command or the Supreme

16     Command, I had to act upon it and appeal to my subordinate officers to

17     act responsibly.  That's what I did always.  Here I warned them they

18     would be responsible in various ways in case of noncompliance.  This also

19     applied to the non-implementation of other orders.  I would like to

20     remind you of all sorts of instructions I gave with regard to opening

21     fire.  This was my position.

22        Q.   Thank you.

23             THE ACCUSED: [Interpretation] I seek to tender this document.

24             JUDGE KWON:  Yes, we'll admit it.

25             THE REGISTRAR:  As Exhibit D3388, Your Honours.

Page 37223

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Thank you.  You mentioned that there were a number of agreements.

 3     Did you send out an order to subordinate commands for each agreement or

 4     was there a general order for all agreements?

 5        A.   We had to send out orders for each agreement and we got orders

 6     for each agreement, because I wasn't involved in negotiating these

 7     agreements so I was not in a position to know whether there was one.

 8     Only when I got an order from the Main Staff or from you I could react.

 9     I wasn't involved in any other way and based on the orders received, I

10     issued such orders.  For each agreement there was a separate order and

11     some were even limited in duration.

12             THE ACCUSED: [Interpretation] Could we please see 1D06319.

13             MR. KARADZIC: [Interpretation]

14        Q.   Please explain to us this sentence:  All your units holding

15     positions toward the city of Sarajevo are duty-bound to abide by the

16     absolute cease-fire and so on.  Where else were there positions to which

17     the cease-fire did not apply?

18        A.   We only discussed the positions of the corps around Sarajevo,

19     that is, toward the 1st Corps of the BH Army in Sarajevo.  However, I

20     said that the front line was 65 kilometres long, and the remainder of the

21     front line was towards Konjic, Visoko, Vares, Olovo, and in the Praca

22     valley.  For a while toward Jahorina, too, but that went on until the --

23     until July 1993.  After the Lukavac operation that front line was

24     abolished.

25        Q.   Thank you.  Does that mean some cease-fires were valid only for

Page 37224

 1     some regions not for the whole of Bosnia-Herzegovina?

 2        A.   Yes, certainly.  Given the fact that I phrased this order this

 3     way, it is clear that it only applied to Sarajevo but not to other areas.

 4     There have been sufficient definitions of these agreements but let me not

 5     go into that now.  Maybe later there will be an opportunity to discuss

 6     that.  I mean, the question how either side abided by the agreement.

 7        Q.   So what remains is only the Ilijas Brigade which did not have

 8     positions facing the city of Sarajevo?

 9        A.   Yes.  All other -- the Romanija Brigade and others were there

10     too, but only the Ilijas Brigade had its positions toward -- had its

11     position elsewhere toward Visoko and Vares.

12             THE ACCUSED: [Interpretation] Thank you.  I seek to tender this

13     document.

14             JUDGE KWON:  Yes.

15             THE REGISTRAR:  Exhibit D3389, Your Honours.

16             MR. KARADZIC: [Interpretation]

17        Q.   Please tell us about the protests.  You have already mentioned

18     that there were protests by UNPROFOR.  How seriously did you take that

19     and did you respond to them?

20        A.   I said from which level the protests came to me.  They mostly

21     went through the commander of the Sarajevo Sector, but there were also

22     protests through the military observers.  Each of these protests,

23     irrespective of which UN representative submitted it to me or to my

24     subordinate units, had to be seriously considered, and it had to be

25     considered what could be done.

Page 37225

 1             THE ACCUSED: [Interpretation] 1D01864, please.  1D01864.  For the

 2     other participants please show the English version and do blow this up

 3     for General Galic.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   On the 28th of November, you reply to Colonel Davout [Realtime

 6     transcript read in error "Dvor"], and you say that upon reception of

 7     their information, you started investigating in detail.  And you say

 8     since at Colina Kapa there are no enemy forces, therefore we had no

 9     reason to shoot at that position from an anti-aircraft machine-gun.

10             And there's something else I'm interested in.  Item 3.  Currently

11     we have no aspirations toward Vojnic field and the Olympic housing

12     development, and the positions of the opposing side are such that an

13     infantry attack would have been unsuccessful.  And under item 4 you say

14     that the positions of our tanks are such that we cannot shoot at Hrasno

15     hill from there.  Fifth, we are strictly abiding by the order of the

16     commander of the Main Staff.

17             What was the content of the protest to which you replied like

18     this?

19        A.   In their protest they enumerated all the problems that they

20     perceived, and I replied to that letter of theirs.  But now concerning

21     Vojnicko Polje and item 5 and Olimpijsko Naselje that you asked me about,

22     I said that we had no aspirations towards those areas, and in the

23     introductory part I said in which locations we conducted offensive

24     operations in the area of the 1st Corps in Sarajevo.  As for the

25     remaining areas, we were never engaged in any operations, nor did we have

Page 37226

 1     any aspirations to have these areas attached to the area of

 2     responsibility of the SRK.  So I think this made it quite clear, and I

 3     don't know why there is any mention of an infantry attack of Vojnicko --

 4     on Vojnicko Polje.  If you head towards Alipasino Polje and

 5     Vojnicko Polje and if you mount an infantry attack on those areas equals

 6     a disaster, and that is why we never wanted to attack this area.

 7             Now, concerning this part relating to Hrasno Brdo, it -- it is

 8     true that it was impossible to fire from our tanks and the positions

 9     where they were located.

10             THE ACCUSED: [Interpretation] Thank you.  Can we have page 2.

11             MR. KARADZIC: [Interpretation]

12        Q.   On page 2, you apologise and you say that you were under the

13     impression that this information had been presented to them by the Muslim

14     side and that it was a falsehood, and that they had received order to

15     open fire only in self-defence.  Do you recall this?

16        A.   I believe that I drafted this letter myself.  So it is truly how

17     I wrote it, and it is an example of a document reflecting how I treated

18     the protests coming from UNPROFOR.  Now, I also wanted to warn them not

19     to take for granted everything that the BH Army or representatives of the

20     Muslims in Sarajevo were telling them.  Therefore, after this letter,

21     these commanders came to see me, and I think that we continued our

22     cooperation to the extent that it was required and possible.

23             THE ACCUSED: [Interpretation] Thank you.  Can this be tendered

24     into evidence.

25             JUDGE KWON:  Yes.

Page 37227

 1             THE REGISTRAR:  Exhibit D3390, Your Honours.

 2             JUDGE KWON:  Yes, Ms. Edgerton.

 3             MS. EDGERTON:  Just another transcript notation.  Page 79, line

 4     8, it should be Colonel D-a-v-o-u, and it's misspelled in the document it

 5     should have a t at the end, rather than "Dvor."

 6             JUDGE KWON:  Thank you.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Were you able to notify UNPROFOR, and if so, did you inform them

10     about the violations of cease-fire, and did you inform them about your

11     duty to fire back?  Can you tell us briefly how this worked, if there was

12     a violation of cease-fire, what kind of reports did you send back to

13     UNPROFOR?

14        A.   Concerning this process of reporting and co-operating with

15     UNPROFOR regarding the monitoring of cease-fire agreement took place

16     under various circumstances.  For a time we had a commission that after

17     the 5th of February, 1994, worked only on establishing the incidents of

18     cease-fire violations.

19        Q.   We are still in 1992.

20        A.   Oh, we are still in 1992.  Very well.  Whenever we were informed

21     about violations of cease-fire, and pursuant to your orders and the

22     orders from the Main Staff, we sent reports about these violations.  I

23     don't know to what extent these reports were acknowledged and accepted,

24     but partially they were.  On many occasions I intervened, in 1992,

25     because they were opening fire from the area of the Holiday Inn where the

Page 37228

 1     command of UNPROFOR was, and they were using that as a cover for mortars,

 2     and I sent protests about -- to this effect on many occasions.  So that

 3     was something that amounted to the abuse of that area, but I cannot say

 4     that we received replies exactly on every occasion.

 5             THE ACCUSED: [Interpretation] Can we please have 1D01181.

 6     1D01181.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   You see here that on the 6th of December, 1992, you say that in

 9     excess of 200 shells fell on Ilidza and Hadzici and caused extensive

10     damage, particularly at Ilidza.  And under item 5 you say that you

11     informed UNPROFOR about the violation of the cease-fire and that you

12     responded by firing at firing positions on Mount Igman.

13        A.   One could have expected such operations from time to time.  I

14     don't know if it was in 1992, but I remember that on one day, 18 to

15     20 mortars shells fell on one single area.  And particularly in the area

16     of Igman there were lots and lots of operations and fire coming from

17     weapons deployed in Vojkovici and other places.

18             Now when I look at this and when I recall everything that had

19     been told to me, this seems incredible, but there were reports confirming

20     that they had enough ammunition for a longer war.

21        Q.   Thank you.  This was at 1600 [as interpreted] hours on the 6th of

22     December, 1992?

23        A.   Yes.

24             THE ACCUSED: [Interpretation] Could this be admitted.  I said

25     1400 hours.

Page 37229

 1             THE WITNESS: [Interpretation] Yes.  That's what it says in the

 2     letter.

 3             THE ACCUSED: [Interpretation] Can this be admitted into evidence.

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  That will be Exhibit D3391, Your Honours.

 6             THE ACCUSED: [Interpretation] Now, can we have 1D01180.  It's the

 7     same date only at 1800 hours.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   This is your report in which you say that over 300 shells were

10     fired, which means 100 more, and that the damage was huge.  You say that

11     you were -- had a shortage of ammunition of this calibre.  You said that

12     two soldiers were killed, that nine were wounded, and that 15 women and

13     children were wounded in Ilidza.

14             Did anyone pay attention to this plight of the Serbs?  Was this

15     given any kind of publicity?

16        A.   It is difficult to answer such a question after this long time,

17     whether this was widely publicised.  This is just a document confirming

18     what happened.  I don't know whether this was this particular incident

19     when the bus-stop was targeted at Ilidza which resulted in great loss of

20     civilian life, but I remember that this was not broadcast, either on the

21     CNN or any other media outlet, saying that Serbs were killed at the

22     bus-stop.  However, if a similar occurrence took place on the opposite

23     side, it would have been covered by all the media, although I was not

24     able to follow all the reports due to the lack of electricity and other

25     hindrances.

Page 37230

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Could we have this admitted into

 3     evidence?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  Exhibit D3392, Your Honours.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Did you inform the Main Staff about these reports and about how

 8     you were monitoring the conduct of our army?

 9        A.   The Main Staff was being informed.  Are you referring to the

10     protests?  I informed them almost regularly about that, because you can

11     see that these reports are addressed to the Main Staff.  Whatever you see

12     here is intended for the Main Staff, and they knew what -- everything

13     that was done in the Sarajevo-Romanija Corps.

14             THE ACCUSED: [Interpretation] Can we now please have 1D01189.

15             MR. KARADZIC: [Interpretation]

16        Q.   Were you ever expecting their attacks, and were you aware of

17     their plans?

18        A.   I still don't have the document in front of me, but I can give

19     you a general answer to that question.  During that time, we received a

20     lot of intelligence about the commencement of various kinds of attacks.

21     Some of them involved shelling, although I'm hesitant to use that term,

22     and I explained to you in what way were we able to obtain this kind of

23     information.

24             Now, concerning their plans for future operations, we had a lot

25     of information from people who managed to escape.  Whether they were

Page 37231

 1     members of their army or were close to the disposition locations of their

 2     troops and once they came across to our side they were able to tell us

 3     what was in the offing.

 4             Now, this also involved, as I said, reconnaissance, electronic

 5     reconnaissance, and other means of obtaining information about possible

 6     attacks.

 7        Q.   Thank you.  Here, under item 1, it is said that the planned

 8     attack has not yet been carried out, which led me to believe that you had

 9     some advance information, but you are informing the Main Staff here that

10     the Muslim forces fired at the Croatian forces in the area of Kiseljak

11     and that you think that their intention was to blame us for that attack.

12     You notified the UNPROFOR, and in spite of that, you conducted some

13     checks with our units and you established that they hadn't opened mortar

14     fire at UNPROFOR buildings and the delegates club in Sarajevo.

15        A.   Well, this is a rather major issue to give you a short answer.  I

16     must go item by item.

17        Q.   Let me help you.  Were there any instances in which they were

18     playing games by attacking Croats and then accusing us?  Did you fight

19     the Croats in Central Bosnia in the area of Kiseljak?

20        A.   I understood the question properly, but I have to give you a

21     lengthy answer, and I don't like that.

22             Now, concerning Croats, during my time, I said that we managed to

23     establish good relationships with them, and we were never at war with

24     Kiseljak, as far as I'm aware of.  We only had some kind of screen

25     vis-a-vis that area, because we were sure that the HVO would not attack

Page 37232

 1     us from this area which was about 18 kilometres towards Kiseljak.

 2     However, one of their brigades which was deployed at Stupska Petlja, a

 3     Croatian brigade, until a conflict broke out in 1993 between the BH Army

 4     and the HVO, they demonstrated tolerance as much as they were able to.  I

 5     even conducted some so-called internal negotiations to win them over all

 6     to our side but that failed.

 7        Q.   Thank you.  Were there any instances when they were shooting at

 8     their own troops or at Croats with the intention of attributing this to

 9     Serbs?

10        A.   That was not only one occasion.  It happened on many occasions

11     that they fired at their own troops and at the Croats in Kiseljak.  I can

12     say that the Croatian forces that were in Sarajevo were part of the

13     BH Army, but later on this brigade was transformed.  That is why I'm

14     talking only about the area of Kiseljak.

15             So there were provocations coming from the Muslim side in order

16     to portray these attacks as being carried out by us against Croats.  They

17     even sometimes attacked their own forces, and we had plenty information

18     about that, sometimes even we had too much information about their firing

19     both at their own troops and their own civilians.

20             If you were to read a book by Lucarevic entitled "Condemned to

21     Victory," you would get an idea about what they were doing, and this was

22     according to his own admission.

23        Q.   Did you receive this information at the time or did you learn

24     that from the book?

25        A.   Yes.  I knew about that at the time, and I explained to you how

Page 37233

 1     we acquired this intelligence.  But as I said, there was too much

 2     information stating that they were firing at their own forces and their

 3     own civilians.

 4             Now, the question was whether that was really probable and

 5     possible, and I'm just telling you how I thought about that at the time.

 6        Q.   Is what you meant to say that this sounded incredible?

 7        A.   Yes, that's right.

 8        Q.   Thank you.

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

10             JUDGE KWON:  Yes, we'll receive it.

11             THE REGISTRAR:  As Exhibit D3393, Your Honours.

12             THE ACCUSED: [Interpretation] Thank you.

13             MR. KARADZIC: [Interpretation]

14        Q.   You mentioned the targeting of the bus-stop and the targeting of

15     civilians somewhere in Blazuj, and yet you did not return fire.

16             THE ACCUSED: [Interpretation] Can we look at 1D01190?

17             MR. KARADZIC: [Interpretation]

18        Q.   Was the bus-stop easily visible?  Was it targeted deliberately or

19     inadvertently?

20        A.   We don't have it yet.  Can it be enlarged a bit?  Can we zoom in

21     on the document to see what it's about?

22        Q.   No.  This isn't in Blazuj.  This is in Hadzici.  It's a different

23     incident, isn't it?

24        A.   Yes.  This is another incident involving a bus-stop just before

25     the New Year's Eve.  This bus-stop was easily visible, just as was the

Page 37234

 1     case with the one in Hadzici.  I think that almost all the members of the

 2     BH Army were familiar with this area, because they were mostly reinforced

 3     and manned by people who were locals.  They knew where the bus-stops were

 4     and the movement of civilians in general.

 5             In this instance 16 civilians were injured.  I can tell you that

 6     Hadzici was a frequent target of attack, as was the local church.

 7        Q.   Thank you.  We can see that one soldier was killed, a woman

 8     civilian was killed, and you also say that the enemy has been provoking

 9     continually and firing from all weapons during the visit by

10     Boutros-Ghali.

11             What is your experience in this context?

12        A.   Well, when it came to visits by prominent figures to Sarajevo,

13     they would normally go to the area of responsibility of the 1st Corps of

14     the BH Army.  That's where the Presidency was, with Alija, and all these

15     public figures, from Mitterrand to others.  There would always be

16     provocations, and that applied to the visit by Boutros-Ghali.  And the

17     attempt was attribute these attacks to the SRK, to send the message of,

18     "Well, you see how we're faring at their hands here."  And this was the

19     case every time an important delegation came to visit.

20             THE INTERPRETER:  Can the witness repeat the last sentence he

21     said.

22             JUDGE KWON:  Mr. Karadzic.  The interpreters did not hear your

23     last sentence.

24             MR. KARADZIC: [Interpretation]

25        Q.   Of your answer.  Can you repeat?  You said that whenever there

Page 37235

 1     were high-ranking figures visiting, what happened?

 2        A.   Whenever there were important delegations or senior

 3     representatives of politicians or military staff, they would always go to

 4     the BH Army-controlled part of Sarajevo.  So what they did was to try and

 5     attribute fire to us, to portray us as -- us being the SRK, as the ones

 6     causing trouble in Sarajevo.  At that time, we would warn units that they

 7     should refrain from any response to any sort of provocative fire, because

 8     we expected that there would be some forthcoming.

 9        Q.   Thank you.  Can you explain why it was that you ordered that

10     there be no fire, because under 2, it says here that all the SRK units

11     have been ordered that in the course of at that day they should be most

12     strictly forbidden from opening fire.  Why was this the case?

13        A.   Well, whenever there were visits of high-ranking officials, I had

14     to issue orders of this sort.  If it came to a conflict along the

15     confrontation line, if there was provocation, no one knew how far this

16     incident could escalate and what the consequences might be and whether

17     they would ultimately be helpful for the side of the SRK and the VRS in

18     general, because we didn't have any -- any aspirations to move towards

19     the town.

20             JUDGE KWON:  Yes.  Please continue.

21             THE ACCUSED: [Interpretation] Thank you.

22             MR. KARADZIC: [Interpretation]

23        Q.   What is missing from the transcript in my question is that there

24     was refraining from fire despite the fact that there were civilian

25     casualties.

Page 37236

 1        A.   Yes.  In fact, I did underline this.  I didn't simply have the

 2     time to read what this document states, but I know that I said that

 3     despite these victims, we should refrain from opening fire.  And you must

 4     know that I did not issue these orders lightly.  It was not an easy

 5     thing.  It was a difficult situation and with serious consequences for

 6     the SRK forces as well as the civilians who were within the AOR of the

 7     SRK.

 8        Q.   And why was that difficult?

 9        A.   Well, for the simple reason that you had to achieve your plan.

10     You had to achieve your goal, and the goal was clear that the Serbian

11     territories in that region be safeguarded.  I don't know if this was

12     something that they referred to in the same way in their documents, but

13     in our documents we referred to such actions as step-by-step toward an

14     intervention.  What did this mean?  This meant that the purpose was to

15     provoke our forces, and since NATO was present there with its aviation

16     flying over the area of responsibility of the SRK on a daily basis and

17     since we knew what the political situation was at the time, especially in

18     terms of the VRS and Republika Srpska, only a small incident was needed

19     in order for NATO aviation to get involved, or we knew that we were

20     sustaining losses, but nevertheless we will refrain from responding to

21     provocations so that we may preserve the territory.  Otherwise, who could

22     have guaranteed the Serbs and the SRK in the area the ability to defend

23     themselves from NATO in case they intervened or from combined NATO and

24     BH Army forces if it should come to that?

25        Q.   Thank you.  And what was the response on the part of civilians

Page 37237

 1     and fighters in general to the fact that you had to refrain from fire?

 2        A.   Well, of course they weren't happy about it, but they knew that

 3     these -- the sacrifice through these victims, if there should be any,

 4     would be necessary.  The civilians themselves knew full well why there

 5     was no response in such situations.  They knew that it would come to

 6     peace ultimately.

 7             Throughout my time as commander in Sarajevo, I expected that

 8     there would be peace in Sarajevo, that there would be demilitarisation.

 9     The talks were held, and the negotiations were proceeding at such a pace

10     that we were aware of the fact that peace could be achieved any day.

11        Q.   Thank you.

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

13             MS. EDGERTON:  If I may, Your Honours.

14             JUDGE KWON:  Yes, Ms. Edgerton.

15             MS. EDGERTON:  I believe there's something missing from the

16     transcript at page 91, the first four lines.  I believe that

17     General Galic referred to territorial exchanges and that Sarajevo should

18     be divided.  And perhaps he can confirm that because I don't see it in

19     the transcript.

20             MR. KARADZIC: [Interpretation]

21        Q.   There was no division mentioned.  The Drina valley was mentioned.

22        A.   The exchanged [as interpreted].

23             THE ACCUSED: [Interpretation] It can be checked.

24             MS. EDGERTON:  I heard it in the French translation.

25             MR. ROBINSON:  I didn't hear it in the English, actually, so

Page 37238

 1     maybe there's been something missed.

 2             JUDGE KWON:  Why don't we ask the witness to repeat his answer,

 3     or could you put your question again, exactly.  Shall I put it for you?

 4             The question was, Mr. Galic:

 5             "What was the response on the part of civilians and fighters in

 6     general to the fact that he had to refrain from fire?"

 7             Could you kindly repeat your answer.

 8             THE WITNESS: [Interpretation] Thank you.  The response on the

 9     part of the civilians and soldiers to the fact that there was no response

10     to the provocations on the part of the BH Army despite there being

11     casualties was such that they were aware of the reasons why we should

12     refrain from firing, and these were the reasons that we explained to

13     them.  All of us in the Sarajevo-Romanija Corps, as well as the civilians

14     in the area, knew that ultimately peace would be achieved in Sarajevo,

15     because there were talks held about Sarajevo at all times and that it

16     should be demilitarised.  You will remember that I emphasised that.

17             There was discussion of protected areas, and there were

18     discussions about the exchanges of territory.  The VRS held part of

19     Sarajevo for an area in the Drina valley.  There were also talks held

20     with a view to reaching peace agreements.  We believed that the

21     Cutileiro Plan would be the one.  Unfortunately, it never was

22     implemented.

23             So despite all of this, we agreed that this -- that there was not

24     going to be any response on our part in order to reach that goal.

25             THE ACCUSED: [Interpretation] Is that clear now?  Can the

Page 37239

 1     document be admitted?

 2             JUDGE KWON:  Yes, we'll admit it.

 3             THE REGISTRAR:  As Exhibit D3394, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   General, you mentioned several times today that the SRK returned

 6     fire on firing positions.  Can you tell us where most of these firing

 7     positions were and where did this huge number of projectiles land?  And

 8     as I said, where were most of these firing positions located?

 9        A.   Do you mean the SRK fire?

10        Q.   Yes, the SRK fire and the fire on their firing positions.

11        A.   Well, we were able to see on the various maps including the

12     operational maps what the disposition of the forces of the BH Army in

13     Sarajevo was.  We can see that right at the confrontation line there were

14     forces some 1 to 3 kilometres -- at least 1 to 3 kilometres deep within

15     their territory.  There were battalion forces, company forces, and forces

16     of lower-level units.

17             So these were the forces that fire was opened upon, and that only

18     happened if there was outgoing fire from those positions targeting the

19     SRK forces.  In other words, this happened at the confrontation line or

20     not that far deep into the territory.  The approximate depth.  What would

21     the approximate depth be in urban terms?  Well, up to 500 metres.  Over

22     500 metres we're talking about the sorts of depth where, because of the

23     disposition of streets and high-rise buildings, you're not able to

24     control the situation.

25             As for other positions, we said that they had the positions where

Page 37240

 1     they held recoilless guns.  They had APC positions, tank positions, and

 2     they would open fire from these positions on occasion, although they

 3     frequently shifted these positions.  We saw what sort of mortar fire

 4     there was.  Some of the mortars, those that provided support to the

 5     brigades along their axes, were stationary mortars.  Their positions

 6     would mostly in the same area where the other forces were, and they also

 7     had mobile mortars.

 8             Next, when we were opening fire on their artillery, this could

 9     have happened in the area where they were deployed.  That would be in the

10     area of Hum or in the area of Igman.  It was but rarely that we would

11     respond to their artillery fire down there.  It would mostly have

12     happened in the direction of Igman.

13        Q.   Thank you.

14             THE ACCUSED: [Interpretation] Can we have 1D01443.

15             MR. KARADZIC: [Interpretation]

16        Q.   Thank you for this extensive answer.  I would now like to show

17     you a number of documents relating to precisely what you've been telling

18     us now.

19             Yes, it's the 11th of January, 1993.  The document reads that

20     they fired on Milinkladska and Ozrenska streets.  These are city streets

21     populated by the Serbs; right?

22        A.   Yes.

23        Q.   One hundred and ten shells from Mojmilo, and they were even a

24     multi -- multiple-rocket launchers.  But you say, under 2, upon clearance

25     from the SRK, the unit opened fire on enemy artillery in the area of

Page 37241

 1     Mojmilo and Hrasnica.  Is this, then, what you referred to when you said

 2     that -- you said responded to artillery attacks?  And we can see that

 3     under 4 we have casualties which are not negligible.  There were wounded.

 4        A.   Yes.  That's certainly how it was.  We see here from this area

 5     from where we were being fired at, we responded by targeting those

 6     positions.  It isn't easy to tell now whether that was a pinpoint target

 7     or a large target.  That's why we had to choose the right weapon for our

 8     response in order not to hit anything but the area targeted.

 9             THE ACCUSED: [Interpretation] I seek to tender this document.

10             JUDGE KWON:  Yes, we'll receive it.

11             THE REGISTRAR:  As Exhibit D3395, Your Honours.

12             THE ACCUSED: [Interpretation] Thank you.  Could we please see

13     1D01448.

14             MR. KARADZIC: [Interpretation]

15        Q.   This is dated the 15th of January, 1993, and it says that one

16     civilian was killed and 13 wounded by artillery fire at Ilidza.  And

17     under item 2, it says that the corps units are ready to respond but

18     during the day did not engage in significant combat activity.  And then

19     you say under item 3 that there are instances of population leaving the

20     area due to frequent shelling.  You also say further down that the

21     soldiers are uneasy about the Serbian delegation agreeing to accept the

22     constitutional principles.

23             THE INTERPRETER:  Could the accused please repeat his last

24     sentence.

25             JUDGE KWON:  Just a second.  Could you repeat your last sentence,

Page 37242

 1     Mr. Karadzic.

 2             THE ACCUSED: [Interpretation] I apologise.  I hurry and then, as

 3     a result, lose more time.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   My question is:  Did the soldiers follow the developments at

 6     conferences, and how did they react?  This is my question to you.

 7        A.   Thank you.  I'm waiting for a sign to start replying.

 8             I said in my first answer that living and waging war in Sarajevo

 9     was hell for everybody involved.  We followed all these conferences, all

10     the soldiers, all the civilians, and we wanted them to be successful so

11     that peace is reached in Bosnia-Herzegovina, and especially in Sarajevo.

12     It was equally difficult for both sides.  That's why I say that the

13     soldiers followed the developments and the agreements reached.

14        Q.   In spite of all the damage and casualties at Ilidza, you say that

15     you are ready to respond to possible attacks, but you did not respond

16     after all.  Why not?

17        A.   At that time it wouldn't have served a useful purpose.  I mean,

18     shooting back at the origin of enemy fire.  If we see what was hit, these

19     were daily targets of attacks.  It wasn't anything new.  Both the

20     soldiers and the civilians in the area controlled by the SRK had already

21     gotten used to taking care of themselves, to protect themselves against

22     enemy attacks.  There had already been quite a few casualties on our

23     sides -- on our side.

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

25             JUDGE KWON:  Yes.

Page 37243

 1             THE REGISTRAR:  Exhibit D3396, Your Honours.

 2             THE ACCUSED: [Interpretation] Can we see 1D25061?

 3             MR. KARADZIC: [Interpretation]

 4        Q.   This is dated the 24th of January.  And your deputy says here

 5     that the enemy fired six shells at Ilidza, that there was constant

 6     sniping, and under item 2 it says pursuant to the approval of the chief

 7     of artillery, the latter fired at enemy positions in the Nabozici area.

 8     Other units did not engage in any more significant combat activity.  What

 9     is this place, Nabozici?  Is that some -- is this a downtown area or

10     what?

11        A.   We can see where they fired from, from Mojmilo, Hrasnica and

12     other places, whereas we only responded by firing at Nabozici, which is a

13     road.  How do I explain that to you without a map?  I can draw it.

14     Nabozici is along the road from Ilijas to Vogosca, and from Vogosca to

15     the Niksic plain -- or the plateau, actually.  And this is a mountainous

16     area known as Nabozici.  So it's above Vogosca and on to Cemerska --

17     Mount Cemerska.  I hope I was able to describe it.

18        Q.   In other words, Nabozici is --

19        A.   Outside of Sarajevo.

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

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit D3397, Your Honours.

23             MR. ROBINSON:  Excuse me, Mr. President, before we adjourn or

24     have the rush to adjourn, I just wanted to advise the Chamber, which is

25     something you already know and also we've already informed General Galic,

Page 37244

 1     that it's going to be necessary to interrupt his testimony tomorrow

 2     morning to hear the evidence of Ljubisav Simic, and that we anticipated

 3     General Galic returning to the Chamber around 11.30 tomorrow morning.

 4             JUDGE KWON:  It may depend.  Possibly that may be postponed till

 5     the third session.

 6             Do you understand that, Mr. Galic and Mr. Piletta-Zanin?

 7             THE WITNESS: [Interpretation] Mr. President, sir, I understand

 8     that, and I've already grown used to today's pace.  Nothing new.  It's

 9     normal at such trials.  And thank you for this information.

10             JUDGE KWON:  Yes, Mr. Piletta-Zanin.

11             MR. PILETTA-ZANIN: [Interpretation] Your Honour, I just have a

12     tiny question.  I don't really want to be difficult, but I would like to

13     know the following:  Will I be able to see General Galic during the

14     breaks?  And of course I will not talk about the substance of his

15     testimony.  I understand that the Prosecution has already said something

16     about my conduct, but I would like to know whether I would be able to

17     talk to him during the breaks.  I know the Tribunal, the Tribunal knows

18     how I behave, but will I be entitled to see General Galic during the

19     breaks without touching upon the substance of his testimony?

20             JUDGE KWON:  Do you have any observation, Ms. Edgerton?

21             MS. EDGERTON:  Just by way of clarification, I would assume that

22     Mr. Piletta-Zanin means he's not going to discuss his testimony at all

23     rather than the substance of his testimony.  He is not to discuss his

24     testimony with the General.

25             JUDGE KWON:  That is my understanding.  Mr. Piletta-Zanin, could

Page 37245

 1     you confirm that?

 2             MR. PILETTA-ZANIN: [Interpretation] Your Honours, I thought that

 3     I was clear, and if you have understood what I said, I'm absolutely

 4     delighted.  Thank you.

 5                           [Trial Chamber confers]

 6             JUDGE KWON:  As long as Mr. Piletta-Zanin does not discuss about

 7     Mr. Galic's testimony, the Chamber sees no difficulty with it.

 8             The hearing is adjourned.

 9                           --- Whereupon the hearing adjourned at 2.47 p.m.,

10                           to be reconvened on Tuesday, the 16th day

11                           of April, 2013, at 9.00 a.m.