Tribunal Criminal Tribunal for the Former Yugoslavia

Page 24916

 1                           Thursday, 28 August 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.32 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good morning, Your Honours.  This is the case

 8     number IT-09-92-T, the Prosecutor versus Ratko Mladic.

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             Nothing in the court agenda.  No preliminaries have been

11     announced.  Therefore, we wait for the witness to be escorted into the

12     courtroom.

13                           [The witness takes the stand]

14             JUDGE ORIE:  Good morning, Mr. Dunjic.

15             THE WITNESS: [Interpretation] Good morning.

16             JUDGE ORIE:  Before we continue, I'd like to remind you that

17     you're still bound by the solemn declaration you have given yesterday at

18     the beginning of your testimony.  Mr. Jeremy will now continue his

19     cross-examination.

20             MR. JEREMY:  Thank you.  Good morning, Your Honours.

21                           WITNESS: VELIMIR DUNJIC

22                           [Witness answered through interpretation]

23                           Cross-examination by Mr. Jeremy: [Continued]

24        Q.   Good morning, Mr. Dunjic.

25        A.   Good morning.

Page 24917

 1             MR. JEREMY:  Could we please start by returning to the notebook

 2     entry that we left off with yesterday.  That's 65 -- that's Exhibit P356.

 3     And if we could go to page 165.

 4        Q.   Mr. Dunjic, while that's being brought up, you'll recall that we

 5     were discussing a tour of the Igman Brigade by your commander.  I think

 6     you said it was -- it was safe to assume that while you didn't recall

 7     that, that it would have been a tour by General Galic.  Do you recall the

 8     purpose of that particular tour or tours such as this, even if you don't

 9     remember that exact tour?

10        A.   General Stanislav Galic toured my brigade on several occasions.

11     Among other things, yesterday there was a question about who it was from

12     the superior command because it was also General Mladic who toured my

13     unit.

14             Regarding what I was shown here, I can assume what it's all

15     about; namely, the technical maintenance facility was one of the vital

16     institutions and a key factor for the survival of the Serbian people in

17     that territory.  In a study by the director of the facility, I think it

18     was Mr. Radivojsa, that was his last name, the facility was supposed to

19     be transferred out of that area.  My experience tells me, and I think

20     that my action was correct, we prevented it from being transferred out

21     because in combat it would take months and would affect the defensive

22     capabilities of my unit and other units of the Sarajevo Romanija Corps.

23        Q.   Mr. Dunjic, I think we're jumping slightly ahead and we'll get to

24     this point.  In fact, if I introduce it, we see halfway down that page

25     there is a reference to a discussion with this person whom you have

Page 24918

 1     referred to, this Colonel Radivojsa, and let's focus on that.  We see

 2     that it says it's regarding the incident at the Hadzici TRZ, the

 3     maintenance and repairs depot.

 4             Now we see that there is a note stating Colonel Radivojsa's name

 5     and a reference to:  "All disagreements began the moment the decision was

 6     taken to transfer part of the depot equipment to a new location in

 7     Banja Luka."

 8             MR. JEREMY:  Could we go to the next page in the -- in both

 9     languages, please.

10        Q.   Next to the first star, we read:

11             "On the morning of 31 October 1992, Radic walked in together with

12     Major Dunjic, they arrested us pointing Heckler pistols at us."

13             Now, this reference to Radic, that's President Radic who you

14     referred to yesterday, the president of the municipality of Hadzici;

15     correct?

16        A.   Yes, that's correct.

17        Q.   The entry goes on to say:

18             "Major Dunjic always came to the TRZ with Radic and he was always

19     insolent and rude.

20             "Major Dunjic treated the logistics people disparagingly,

21     particularly General Djukic."

22             Did you arrest Colonel Radivojsa on your own initiative?

23        A.   Radivojsa, let me correct you.  Radivojsa.  I didn't arrest him

24     but I forbade any kind of relocation for the reasons that I mentioned.

25        Q.   And you say you forbade any relocation.  Did you forbid this on

Page 24919

 1     your own initiative?

 2        A.   In agreement with the political leadership.  The relocation was

 3     not justified, for objective reasons.  The relocation -- the depot was

 4     supposed to be relocated to Banja Luka.  There was no reason for me to

 5     prevent the relocation other than the fact that I wanted to save the

 6     people in that area, and what confirmed that my decision was correct was

 7     the fact that in 1995, the people from Hadzici, when the depot was

 8     relocated, left that area.  And that was one of the reasons why they left

 9     the area.

10        Q.   Referring to the people from Hadzici, we see further down in the

11     same entry another reference, presumably there again Colonel Radivojsa's

12     words.  They say:

13             "Everything that could be pillaged in Hadzici was pillaged by the

14     Serbs and various militia."

15             Now, Hadzici was in your zone of responsibility; correct?

16        A.   Hadzici was in my area of responsibility and the people who

17     worked in the depot were from Hadzici and they worked in the depot before

18     the war.  There were no military formations in the depot at all.

19        Q.   And as brigade commander, you were aware of this pillage in

20     Hadzici; correct?

21        A.   What pillage?

22        Q.   The pillage that we see referred to in this notebook entry of

23     Mr. Mladic.

24        A.   What pillage?  Could you please tell me what pillage?  What was

25     pillaged?

Page 24920

 1        Q.   So --

 2             JUDGE ORIE:  Mr. Mladic, no laughter.  No spoken or unspoken

 3     comments on questions or answers.  You know the consequences if you

 4     continue.

 5             Please proceed, Mr. Jeremy.

 6             Well, Witness, Mr. Jeremy just read it, that the report says that

 7     everything that could be pillaged was pillaged.  That is what Mr. Jeremy

 8     is referring to, whether you were aware of that.

 9             THE WITNESS: [Interpretation] This is just a general assessment.

10     Everything that was pillaged -- there was pillaged.  This is not correct.

11     Mrs. Plavsic later and the minister of defence, Mr. Subotic, toured the

12     depot after these events, and the defence minister and she ascertained

13     themselves that the depot was working to its full capacity according to

14     all the regulations which satisfied all the criteria.

15             JUDGE ORIE:  So just to understand your answer, you were not

16     aware of any wide-scale pillaging in or outside that depot in the Hadzici

17     area?

18             THE WITNESS: [Interpretation] That's correct, no.

19             JUDGE ORIE:  Please proceed, Mr. Jeremy.

20             MR. JEREMY:

21        Q.   Mr. Dunjic, you say that Mrs. Plavsic and the Minister of

22     Defence, Mr. Subotic, later toured this depot.  When did that -- when

23     exactly did that tour occur?

24        A.   This was in late November.  I don't recall the exact date, but

25     what I say is correct.

Page 24921

 1        Q.   Let's take a look at another entry in this notebook.  This time

 2     from the 14th of November.

 3             MR. JEREMY:  Could we go to e-court page 175 in the English and

 4     the B/C/S, please.

 5        Q.   Now, we see this is an entry for Saturday the 14th of November

 6     1992.  We see the subheading: "Reporting by the Organs of the GS/Main

 7     Staff/ of the Army of RS/Republika Srpska."

 8             MR. JEREMY:  If we could go to page 177, please.  Two pages

 9     forward.  Focusing in on number 4 that we see at the top of the page and

10     the last starred asterisk.

11        Q.   We see:

12             "Order

13             "Consider the possibility of appointing

14     Lieutenant-Colonel Zeljaja commander of the Igman brigade."

15             Mr. Dunjic, were you told by the Main Staff that in the middle of

16     November 1992 they were considering replacing you as commander of the

17     Igman Brigade?

18        A.   Well, I wouldn't understand it like that.  In November, I don't

19     know the exact date, I wrote a request to the Main Staff that they should

20     find another commander and that they should relieve me of duty because I

21     disagreed with the way in which the defence of the Serbian people was

22     organised in that section.  I received an answer literally stating -- I

23     received the answer from General Mladic: "Mr. Dunjic, kindly remain as

24     commander of the Igman Brigade because the fighters believe in you, the

25     Serbian people, and I myself also believe in you."

Page 24922

 1             After that, Mr. Galic came and asked me if I was going to stay.

 2     He probably later reported back that I would remain at that post, but at

 3     the time that's what happened regarding that.  Otherwise, Mr. Mladic, I

 4     listened to him, because we have similar characteristics.  We are

 5     officers.  We are educated and trained.  We do not tolerate injustice and

 6     unfit command, and above all we love the Serbian people, and we did

 7     everything to save the Serbian people in that area because it was easier

 8     to sacrifice an unfit colonel than lose tens of thousands of soldiers and

 9     civilians in that area.

10        Q.   Mr. Dunjic, when you refer to the sacrifice of an unfit colonel,

11     do I take it you're referring to Colonel Radivojsa?

12        A.   Among others, yes.  Him too.

13        Q.   And am I correct that you draw no connection to the arrest --

14     your arrest of Colonel Radivojsa that is noted in Mr. Mladic's diary and

15     the discussion two days later about your replacement by Colonel Zeljaja?

16        A.   The translation is bad.

17        Q.   I'll -- it's -- I'll phrase my question more clearly.  Am I

18     correct in thinking that when, on the 12th of November, we have an entry

19     in Mr. Mladic's notebook referring to your arrest of Colonel Radivojsa,

20     and then we see two days later a discussion about your replacement as

21     commander of the Igman Brigade, am I correct in thinking that you draw no

22     connection between those two events?

23        A.   I didn't even know about it.  I'm seeing for the first time that

24     Mr. Zeljaja was supposed to take over the duty of commander.  I wasn't

25     informed of this.

Page 24923

 1        Q.   And seeing this now, seeing this entry now, do you think it is

 2     connected to your decision, your decision that you took with the

 3     political authorities to arrest Colonel Radivojsa?

 4        A.   It's possible.  It's possible.

 5        Q.   All right.  Let's move on from here.  Now, a few days after the

 6     events noted in these notebook entries we've looked at, do you recall

 7     attending a large meeting of political and military figures who were

 8     operating in the area of the SRK?  The meeting was held at the Lukavica

 9     barracks.

10        A.   Yes, yes.

11        Q.   I'd like to take a look at the minutes of those meetings and ask

12     you a few questions in relation to those.

13             JUDGE ORIE:  Before we do so, I'm slightly confused, Mr. Dunjic.

14     Earlier you said you didn't arrest Mr. Radivojsa, and later now you were

15     asked -- you explained that by saying that you just prevented any

16     relocation.  Did you mean relocation of the depot or did you mean

17     relocation of anything else?

18             THE WITNESS: [Interpretation] I meant the relocation of the

19     maintenance and repair depot, and I didn't arrest Colonel Radivojsa.  I

20     just expelled him.  Got him out of there.

21             JUDGE ORIE:  What do you mean by "expelled him"?  In factual

22     terms, what did you do?

23             THE WITNESS: [Interpretation] I ordered him to leave the area of

24     responsibility of my brigade and that area included the maintenance and

25     repairs depot.

Page 24924

 1             JUDGE ORIE:  Yes.  And did he follow your order?

 2             THE WITNESS: [Interpretation] He did, yes.

 3             JUDGE ORIE:  Please proceed, Mr. Jeremy.

 4             My confusion, by the way, was caused by -- later on whether the

 5     arrest was connected with or was not connected, linked with the other

 6     matter.  And if there was no arrest, it's difficult for someone to tell

 7     us whether there is any link between something that didn't happen and

 8     something that is referred to at a later entry in the notebook.  Just for

 9     you to know what caused my confusion.

10             Please proceed.

11             MR. JEREMY:  Thank you, Your Honour.

12             Could we please see P1967.

13        Q.   Those are the minutes of the meeting that I just asked you about,

14     Mr. Dunjic.  As this is being brought up, I can tell you that these are

15     the minutes of the SRK corps command from a meeting of commanders and

16     presidents operating in the political and military situation in the SRK

17     zone, dated 15 November 1992.

18             So on the first page we see the date is 15 November 1992, and so

19     that's a day after the notebook entry that indicated consideration was

20     being given to replacing you as commander of the Igman Brigade.  We see a

21     list of persons present at the start of the minutes.

22             MR. JEREMY:  Could we go to page 2 in the English and 3 in the

23     B/C/S, please.  Now, number 29 we see a reference to Velimir Dunjic,

24     Igman Light Infantry Brigade.

25        Q.   So that's a reference to you; correct?

Page 24925

 1        A.   Yes, yes.  That's me.

 2             MR. JEREMY:  On the next page in the English, same page in the

 3     B/C/S.

 4        Q.   We read:

 5             "On behalf of the Main Staff of the Republika Srpska Army, the

 6     following were present:

 7             "- Commander, Colonel General Ratko Mladic and

 8             "- Colonel Tolimir."

 9             MR. JEREMY:  Now, could we go to page 5 in the English and the

10     B/C/S, please.

11        Q.   Now looking at the top of the page in the B/C/S and halfway down

12     the page in the English, we see that an introductory report is submitted

13     by Lieutenant-Colonel Marko Lugonja.  Mr. Dunjic, he was the commander --

14     the assistant commander of intel and security in the SRK; correct?

15        A.   That's correct.

16        Q.   I'd like to look at some of the aspects of the report that he

17     provides to the meeting.

18             MR. JEREMY:  If we can go to e-court page 7 in the English and 6

19     in the B/C/S.

20        Q.   And looking at the subheading on that page, we see that he is

21     giving a report on basic security issues in SRK units.

22             MR. JEREMY:  Now, if we could go to page 8 in the English and 7

23     in the B/C/S, please.

24        Q.   Now, at the bottom of the page in the English, I think at the top

25     of the page in the B/C/S, we see a reference to:

Page 24926

 1             "Creation of formal and informal groups and organisations

 2     gathering around an already prominent and credible individual.  They

 3     exercise a status in units by threats, extortion, and other violent

 4     methods."

 5             MR. JEREMY:  Could we go to the next page in the English, please.

 6        Q.   Mr. Lugonja's report continues, and he references:

 7             "Extremely widespread theft, robbery, violence and other crimes."

 8             He goes on to describe various things being stolen.  And in the

 9     next hyphen point we see he states:

10             "The understanding and practice of individuals and groups that

11     they are masters of life and death to every individual of different

12     ethnicity, resulting in cases of unnecessary mistreatment and killing of

13     members of other ethnicities, especially Muslims.  Such people see the

14     Geneva and other conventions as obsolete and unnecessary in this war."

15             Now, Mr. Dunjic, I put it to you that one of the groups that

16     Lieutenant-Colonel Lugonja is referring to here is Branislav Gavrilovic's

17     unit which was under your command.

18        A.   I assert that that is not correct.  You need to give me evidence

19     that the group committed any crimes during the time that I was commander.

20     And the group that you are speaking of, you showed me a document

21     yesterday in which my successor, Spasoje Cojic, confirmed to -- issued a

22     certificate, proof to Branislav Gavrilovic, that he was a member of the

23     Army of Republika Srpska or a member of the Army of Republika Srpska.

24     I'm saying that he was in the army and my successor confirmed that in

25     writing.  Not that he was a member of the paramilitary units but a member

Page 24927

 1     of the Army of Republika Srpska.  You showed me that document.

 2        Q.   So, Mr. Dunjic, from your answer, I understand your evidence to

 3     be that you were not aware of any crimes committed by Gavrilovic's unit

 4     during the time that you were commander of the Igman Brigade; is that

 5     correct?

 6        A.   In my statement, I stated that as far as I know,

 7     Branislav Gavrilovic's unit, while I was in command, did not commit any

 8     crimes, did not do anything that would contravene the provisions of the

 9     Geneva Conventions.  And now whether there were any minor disciplinary

10     breaches, whether there were fights or things like that, I don't know.  I

11     didn't really care that much because that unit accounted for 2.5 per cent

12     of the complement of my brigade, so I focused in my work on the others.

13     Like any other commander of any other unit in the world, I didn't focus

14     on just a 2.5 per cent -- a complement of my unit.

15        Q.   Let's take a look at another document in connection with this.

16             MR. JEREMY:  Could we please see P04595.

17             JUDGE ORIE:  Before we do so.

18             You were present at that meeting, it was, apparently -- you said

19     it was the Gavrilovic unit did not commit any crimes.  What was the --

20     what was hinted at when there was talk about widespread theft, killing?

21     Did you understand what they were talking about or was it totally unknown

22     to you?

23             THE WITNESS: [Interpretation] This report does not relate to my

24     brigade.

25             JUDGE ORIE:  [Overlapping speakers].

Page 24928

 1             THE WITNESS: [Interpretation] Mr. Lugonja was the chief of

 2     security in the corps, so this refers to corps units.  I was the one who

 3     prevented plunder, looting, and things like that.

 4             JUDGE ORIE:  So this happened by corps units.  Could you explain

 5     to us what exactly then which units committed -- which corps units

 6     committed those crimes?

 7             THE WITNESS: [Interpretation] No, I don't know that.  This is

 8     just a sweeping generalisation.  There are no facts as to what happened

 9     and if it did, where it happened.  I don't know if you understand me.

10             JUDGE ORIE:  I take it that if there are made such sweeping

11     statements not specifically referring to corps units but in very general

12     terms and insisting on measures to be taken, that you at least asked

13     where this happened and by whom this happened?

14             THE WITNESS: [Interpretation] I was not the one who was supposed

15     to ask those questions.

16             JUDGE ORIE:  That was -- you were not -- your units were not

17     excluded from the sweeping statements, were they?

18             THE WITNESS: [Interpretation] I thought that that had nothing to

19     do with my unit.

20             JUDGE ORIE:  For what reason did you think that?

21             THE WITNESS: [Interpretation] Because I tried to keep everything

22     under control in my unit.

23             JUDGE ORIE:  Did you have the impression that any of your

24     colleagues did not try to do the same?

25             THE WITNESS: [Interpretation] Yes.  That was my impression.  And

Page 24929

 1     subsequent events would prove that.

 2             JUDGE ORIE:  Okay.  Which colleagues then were not doing the

 3     same; that is, trying to prevent these type of crimes to be committed?

 4             THE WITNESS: [Interpretation] Not only the perpetrators of crimes

 5     but also they proved to be incapable of organise combat, especially the

 6     Rajlovac and -- Rajlovac and Vogosca Brigade were of that kind.

 7             JUDGE ORIE:  I'm not interested in combat.  You said it was your

 8     impression that the others did not do the same as you did, that is, to

 9     prevent crimes.  My question was whom of your colleagues, in your

10     impression, did not try to prevent crimes to be committed?  Crimes as

11     theft, large-scale theft, and killing of other ethnicities.

12             THE WITNESS: [Interpretation] As for the killing of members of

13     other ethnicities, I knew nothing about that.  And if you're talking

14     about theft and plunder, we're not talking about the robbing of Muslims

15     and Croats.  Those were internal problems in the territory under the

16     control of the Army of Republika Srpska.

17             JUDGE ORIE:  Well, that's not what the report describes.  You

18     told us that you did not feel that you were addressed by the sweeping

19     statements because you tried to prevent these type of crimes - that is,

20     large-scale theft, killing of people of other ethnicity - that others did

21     not try to prevent that.  You did, and therefore it didn't address you.

22             I'm asking you whom of your colleagues did not prevent the type

23     of crimes as described in this report?  And now you are moving to combat.

24     I didn't ask about combat.  You're moving to internal little problems.

25     I'm not talking about that.  I'm talking about the type of crimes as

Page 24930

 1     described in what Mr. Lugonja reported.  Whom of your colleagues did not

 2     prevent those crimes?

 3             THE WITNESS: [Interpretation] That question - i.e., who did not

 4     prevent crimes - should be put to the author of this information.  Not

 5     me.

 6             JUDGE ORIE:  [Overlapping speakers].

 7             THE WITNESS: [Interpretation] And I'm telling you that according

 8     to what I know --

 9             JUDGE ORIE:  You said that it was my impression that my

10     colleagues did not do what I did; that is, to prevent these type of

11     crimes.  My question is:  Whom did you have in mind when you said that

12     you had the impression that the others did not do the same and, as you

13     said, which later turned out to be really the truth?  Who of your

14     colleagues?

15             THE WITNESS: [Interpretation] The commands of the Rajlovac and

16     Vogosca Brigades.

17             JUDGE ORIE:  [Overlapping speakers].

18             THE WITNESS: [Interpretation] I don't remember their names.

19     Perhaps Mr. -- I apologise, it was 22 years ago.  In any case, the

20     commanders of those units.  I'm sure you have the names of those persons

21     who were in command during that period of time.

22             JUDGE ORIE:  Now, how did it become apparent from later events

23     that they did not try to prevent these crimes to be committed?  What did

24     you have in mind when you told us that this turned out to be the truth?

25             THE WITNESS: [Interpretation] There was an operation during which

Page 24931

 1     they were arrested, and they were arrested primarily - and that was the

 2     foremost reason - due to their incapability to organise combat.  They

 3     were very --

 4             JUDGE ORIE:  I'm not -- I'm not talking about combat.  You told

 5     us that following events showed that they did not sincerely try to

 6     prevent these crimes to be committed.  I ask you, what are these events

 7     that happened later on that demonstrated that your colleague commanders

 8     did not do their utmost best to prevent these crimes, large-scale theft,

 9     killings of other ethnicities, were committed?  What happened?

10             THE WITNESS: [Interpretation] I repeat --

11             JUDGE ORIE:  No.

12             THE WITNESS: [Interpretation] -- once again --

13             JUDGE ORIE:  Don't repeat anything you said before.  Please

14     answer my question.

15             THE WITNESS: [Interpretation] I didn't know that people committed

16     crimes any of the brigades.  I didn't know that.  Why don't you put that

17     question to Mr. Lugonja?  I'm sure that he will be able to tell you

18     exactly who he meant.  I'm not the best suited person for that question.

19             JUDGE ORIE:  I'm asking you.  You said, "It was not me who was

20     addressed by it because I did everything to prevent these type of

21     crimes."  I then asked you was that different for your colleagues?  You

22     said, "Yes, I had the impression that the others did not sincerely try to

23     prevent that which was shown by later events."  That's what you told us,

24     not what Mr. Lugonja told us.  And I'm asking you a clarification, and I

25     unfortunately have to establish that you're evasive in your answers in

Page 24932

 1     this respect.

 2             Mr. Jeremy, you may proceed.

 3             MR. JEREMY:  Your Honour --

 4             JUDGE ORIE:  But if you still want to answer my last question,

 5     then you have an opportunity to do so; that is, what events demonstrated

 6     that your colleagues did not sincerely try to prevent these crimes?

 7             THE WITNESS: [Interpretation] This information that we can see

 8     here does not relate only to killings and theft.  There are other things

 9     here.  There are other missions in the work of those people as described

10     here.  If you allow me --

11             JUDGE ORIE:  No.

12             THE WITNESS:  Okay.

13             JUDGE ORIE:  I'm asking you to clarify some of your previous

14     answers, and you're moving away from my questions again and again.  I

15     gave you an opportunity to answer my last question.  You didn't do so.

16     Mr. Jeremy will now continue his cross-examination.

17             Mr. Jeremy.

18             MR. JEREMY:  Thank you, Your Honour.

19             Can we please see P04595.

20        Q.   And, Mr. Dunjic, while this is being brought to the screen, I can

21     tell you it's a report from SRK commander General Galic to the Main

22     Staff, dated 18 November 1992; therefore, a few days after the meeting

23     we've just been discussing.  In point --

24             MR. JEREMY:  Could we go to the last page, please.

25        Q.   Just to show you, Mr. Dunjic, that it's signed by General Galic.

Page 24933

 1             MR. JEREMY:  And we can go back to the first page now.  Thank

 2     you.

 3        Q.   In point number 1, we see a reference to enemy operations and

 4     some description.  In point number 2, we see a reference to "operation by

 5     our forces."  I'd like to focus your attention, Mr. Dunjic, on point

 6     number 3, where we read the following:

 7             "The situation in the territory without significant changes.

 8     However, a paramilitary formation consisting of about 25 men commanded by

 9     Branislav Gavrilovic, aka Brne, is active in the Rakovica sector.  This

10     is a group of criminals whose behaviour is damaging the reputation of the

11     Republika Srpska Army in the eyes of the population in this territory."

12             Now, Mr. Dunjic, you agree that the Branislav Gavrilovic being

13     referred to here is a reference to the same Commander Gavrilovic who was

14     under your command at this time; correct?

15        A.   Yes, that's correct.

16        Q.   And on the basis of the answers that you've given me saying that

17     you knew of no crimes that Gavrilovic committed during the time that you

18     were commander of the Igman Brigade, how is it that the -- the commander

19     of the SRK, who you have told us yesterday commanded up to 25.000 troops,

20     is aware of crimes being committed by Gavrilovic and his men but that you

21     were not.  How can that be the case?

22        A.   First of all, this is another general assessment, and that

23     includes the number of men in the units.  This seems to me like an

24     assessment of the artistic impression in skating.  There is no evidence

25     whatsoever.  It just says, "This is a group of criminals."  This is a

Page 24934

 1     sweeping description.  As a commander, I was not interested in who was

 2     what before the war, or after the war for that matter.

 3        Q.   Mr. Dunjic, we see that Mr. Galic is specific in terms of the

 4     unit he refers to.  It's Gavrilovic's unit.  We see he is specific in

 5     terms of the area in which that unit is committing crimes.  So it's not a

 6     general assessment.  In fact, it's actually quite specific.  So how is it

 7     that General Galic had this specific information despite the fact that he

 8     was responsible for eight times as many soldiers as you were but it's

 9     your evidence that you did not have information about crimes being

10     committed by Mr. Gavrilovic's unit?

11        A.   Obviously you don't understand certain things in here.

12     Gavrilovic's unit was deployed in Rakovica in the orchard.

13             JUDGE ORIE:  Could you please focus on the question.  The

14     question is:  Why was General Galic reporting about misbehaviour of

15     Gavrilovic's unit, where you, being -- commanding the brigade say you had

16     no knowledge of it?  That's the question.

17             THE WITNESS: [Interpretation] I did not know anything about that.

18     If I had known, I would have taken measures.  I did not.  I did not

19     report on things like that in my reports.  Now, as to how he received

20     that information, by what parallel channels of information, I don't know.

21             MR. JEREMY:

22        Q.   So, Mr. Dunjic, it's your evidence that while we see Mr. Galic

23     reporting to the Main Staff his concerns about crimes being committed by

24     a unit under your command, you're saying that Mr. Galic's concerns were

25     never brought to your attention in your capacity as commander of the

Page 24935

 1     Igman Brigade.  Is that how I should understand your evidence?

 2        A.   No, no, no.  Don't say that.  What crimes are mentioned in this

 3     report?  The only thing that is mentioned is that they are a group of

 4     criminals whose behaviour among the population, I suppose that the

 5     reference is made to the Serbian population, tarnishes the reputation of

 6     the army of Republika Srpska.  This is what I am reading.  So the

 7     operative word is "behaviour" or "conduct."

 8        Q.   Mr. Dunjic, there is a clear reference to Gavrilovic's unit being

 9     "a group of criminals."  Is it your evidence that you -- that

10     General Galic never brought to your attention that he considered this

11     unit under your brigade to be a group of criminals.  Is that your

12     evidence?

13        A.   It's a very serious qualification when somebody says of other

14     people that they are a group of criminals.  I don't remember that --

15     Galic ever told me any such thing.  I am not an investigating judge.  I

16     did not ask for my soldiers' criminal records.  I never investigated

17     whether any of them had been convicted of crimes before the war.  That

18     was never my intention or my task.

19             JUDGE ORIE:  Witness, the report - and you are consistently

20     ignoring certain aspects of it - is not only about being a bunch of

21     criminals but also about problematic behaviour linked in the text of this

22     report directly to it being a group of criminals with problematic

23     behaviour.

24             Were you never informed about the problematic behaviour of this

25     group described by General Galic as a group of criminals when they were

Page 24936

 1     under your command?

 2             THE WITNESS: [Interpretation] I don't remember.  I have already

 3     told you that I don't remember that he ever informed about that.

 4             Second of all, whether people behaved in this way or another way

 5     was less important than the organisation of combat.  It was really not

 6     important whether somebody had beaten somebody else in a restaurant.

 7     That was not what I concerned myself with in my work.

 8             JUDGE ORIE:  Then you did not link this information you may have

 9     received and you said you were not interested in, you did not link that

10     to the observations made during that consultation meeting about

11     widespread theft and murder?  You did not think is the one perhaps

12     related to the other?

13             THE WITNESS: [Interpretation] There were no murders in my

14     brigade.  I did not receive this information.  It was sent to the

15     superior command.

16             JUDGE ORIE:  That's not the same.  You say there were no murders

17     or do you say I don't know of murders?

18             THE WITNESS: [Interpretation] I'm saying that there were none.

19     None committed by the unit or individuals in it.  I didn't know.  I think

20     that there weren't in.  I'm even sure that there weren't any while I was

21     the commander of the Igman Brigade.  If I'd known of a murder, I'm

22     certain that such a case would have been prosecuted without any second

23     thoughts about it.

24             JUDGE ORIE:  Just now to summarise:  You attended a meeting where

25     Lugonja stated that widespread theft and killing on an ethnical basis

Page 24937

 1     happened, and you thought, well, he's addressing someone else.  Asked who

 2     else he may have addressed, you're evasive in your answers.

 3             We now see that General Galic is reporting to the Main Staff that

 4     a group of criminals is showing behaviour which is, to say the least,

 5     problematic, and you still say, well, what may have happened, I was more

 6     interested in combat and I did not directly receive a report, so I assume

 7     that no such crimes under my command happened.

 8             That seems to be the gist of your testimony.  Is that well

 9     understood?

10             THE WITNESS: [Interpretation] You understood me well.

11             JUDGE ORIE:  Thank you.

12             THE WITNESS: [Interpretation] It says in this report that there

13     were murders --

14             JUDGE ORIE:  It's not you who are asking the questions.  I didn't

15     say that in this report it was said that murders were committed, so don't

16     put that question to me.

17             Mr. Stojanovic, yes.

18             MR. STOJANOVIC: [Interpretation] Your Honours, with all due

19     respect, in order to avoid confusion, we were listening to the

20     interpretation and you were interpreted as saying that Mr. Lugonja

21     reported that all those crimes were ethnically based.  In the text showed

22     to the witness by the Prosecutor, that part - and I'm referring the

23     ethnically based crimes - are actually not what Mr. Lugonja said.

24             JUDGE ORIE:  Well, I think -- but we could check that.  I think

25     that he referred to feeling that someone is the master of another's life

Page 24938

 1     and the ethnicity is clearly mentioned there, Mr. Stojanovic, isn't it,

 2     in the portion we saw earlier?  Especially the Muslims were mentioned

 3     specifically in this meeting where Mr. Lugonja spoke.  If you say it

 4     doesn't appear there, then please take me back to that part of the report

 5     of this meeting where Lugonja is speaking and indicate to me that no

 6     reference so ethnicity was made and I'll be glad to agree with you.

 7             MR. STOJANOVIC: [Interpretation] Your Honour, we are -- we saw

 8     document P1967.

 9             JUDGE ORIE:  Mr. Stojanovic.

10             MR. STOJANOVIC: [Interpretation] Page 6.

11             JUDGE ORIE:  Mr. Stojanovic, we are close to the break.  If you

12     would perhaps briefly meet with Mr. Jeremy during the break and find

13     where I misstated the evidence in this respect, and please then put that

14     to me in detail before the witness enters the courtroom, and I'll be glad

15     to look at it and to listen to it.

16             Judge Moloto has one question before we take the break --

17     Judge Fluegge, I'm sorry.

18             JUDGE FLUEGGE:  Mr. Dunjic, earlier today you said Mr. Gavrilovic

19     was a member of the Army of Republika Srpska; correct?

20             THE WITNESS: [Interpretation] Yes.

21             JUDGE FLUEGGE:  In this document we have still on the screen, the

22     report, the regular combat report of your superior commander, it is said:

23             "The situation in the territory without significant changes.

24     However, a paramilitary formation consisting of about 25 men commanded by

25     Branislav Gavrilovic ...," and so on.

Page 24939

 1             He is addressed here as a commander of a paramilitary formation.

 2     Can you explain that?

 3             THE WITNESS: [Interpretation] I can't.  It says here that their

 4     behaviour is inappropriate.

 5             JUDGE FLUEGGE:  [Overlapping speakers].

 6             THE WITNESS: [Interpretation] In his information, Lugonja even

 7     characterises their behaviour as criminal behaviour.

 8             JUDGE FLUEGGE:  Stop.  I asked you something else.  Was he

 9     commander of a paramilitary formation or was he a member of the Army of

10     Republika Srpska?

11             THE WITNESS: [Interpretation] No.  He was not a member of a

12     paramilitary formation.  To prove that, you saw a document yesterday

13     where Mr. Cojic confirms in writing that he was a member of the Army of

14     Republika Srpska in the relevant period.

15             JUDGE FLUEGGE:  Are you saying that your commander was wrong in

16     writing that, that he made a mistake or he was misleading or he was

17     lying?  Are you saying that?

18             THE WITNESS: [Interpretation] There was a problem.  At the

19     beginning of the war, there was a problem.

20             JUDGE FLUEGGE:  I'm not talking about --

21             THE WITNESS: [Interpretation] If somebody's name was Savo

22     Derikonja he was immediately considered a paramilitary or if he was a

23     member of party, he was considered to be a --

24             JUDGE FLUEGGE:  Stop.

25             THE WITNESS: [Interpretation] -- paramilitary.

Page 24940

 1             JUDGE FLUEGGE:  Stop.

 2             THE WITNESS: [Interpretation] It was done automatically and it

 3     was not correct.

 4             JUDGE FLUEGGE:  18th of November 1992.  Your commander addressed

 5     Gavrilovic as a commander of a paramilitary unit.  Was that correct or

 6     incorrect?

 7             THE WITNESS: [Interpretation] It is correct that that's what he

 8     called him, but the -- that was not correct.  You saw a payroll and you

 9     saw that that unit was on the strength of the brigade.

10             JUDGE FLUEGGE:  Are you still saying that your commander made a

11     mistake or was misleading the Main Staff?

12             THE WITNESS: [Interpretation] I believe that he made a mistake.

13             JUDGE FLUEGGE:  Thank you.

14             JUDGE ORIE:  Mr. Dunjic, you may follow the usher.  We take a

15     break of 20 minutes.

16             We resume at five minutes to 11.00.

17                           [The witness stands down]

18                           --- Recess taken at 10.33 a.m.

19                           --- On resuming at 10.57 a.m.

20             JUDGE ORIE:  Before we continue with the witness.

21             Mr. Stojanovic, the Chamber received half an hour ago the message

22     that Mr. Bukva would not be ready to come and testify because proofing or

23     preparation is not completed yet.  The Chamber does not understand why a

24     witness, who was interviewed last time on the 27th of June, who signed

25     his statement on the 18th of July of this year, who arrived in The Hague,

Page 24941

 1     and where there was an opportunity yesterday to continue to prepare him,

 2     where there was more time this morning to continue to prepare him, could

 3     not be available once we've done with this witness.  And therefore, the

 4     Chamber is seriously considering, if Mr. Lukic doesn't appear and if the

 5     witness doesn't appear at the end of the testimony of the present

 6     witness, that we'll consider whether this is time lost for the Defence.

 7             It's totally unclear why you need more than five or six hours.

 8     In these circumstances, Mr. Lukic himself having been present during the

 9     interviews, as we read that, why we couldn't just continue.

10             Another reason might be that it was at the request of Mr. Lukic

11     yesterday that we postponed the evidence of the previous witness, and the

12     Chamber is aware that the Defence blames the Chamber for the inability to

13     hear the testimony of that witness but does not necessarily agree with

14     that point of view, and considers that at least there is a serious part

15     of responsibility for the Defence as well.

16             But apart from all that, five or six hours, under the present

17     circumstances, should be enough to call this witness and to examine him.

18             Would you please pass this message to Mr. Lukic, inclusive that

19     the Chamber will consider whether this time not used will be deducted

20     from the time available for the Defence.

21             Can the witness be escorted into the courtroom.

22             MR. STOJANOVIC: [Interpretation] Thank you, Your Honour.

23                           [The witness takes the stand]

24             JUDGE ORIE:  Could I further inquire, not to pursue the matter at

25     this very moment, but whether Mr. Stojanovic and Mr. Jeremy you sat

Page 24942

 1     together and have established that there was no reference to ethnicity,

 2     or if you have any observations in this respect then I'd like to hear

 3     later from you, perhaps at the end of this session.

 4             MR. JEREMY:  Yes, Your Honour.

 5             JUDGE ORIE:  Yes.

 6             Please proceed, Mr. Jeremy.

 7             MR. JEREMY:

 8        Q.   Mr. Dunjic, I have a final question on the topic that we were

 9     discussing at the time end of the last session, and it is this:  It is

10     correct, is it not, that you never took any disciplinary action against

11     Branislav Gavrilovic or any of the men in his unit?

12        A.   I think that is correct.  Yes.

13        Q.   Thank you.  I'd like to move on and take a look at your -- the

14     statement that you provided for this particular case.  The additional

15     statement.

16             MR. JEREMY:  And that's D599.  If we could have that on our

17     screens, please.  If we could go to the -- to the next page in each of

18     the English and the B/C/S.

19        Q.   And, Mr. Dunjic, I'm particularly interested in paragraph 4 in

20     the statement.  It's now up on the screen.  And there you refer to the

21     fact that in early December 1992 you state:

22             "I was designated pursuant to an order of the Sarajevo Romanija

23     Corps (SRK) Command, signed by the Chief of Staff Colonel Dragan Marcetic

24     to co-ordinate the command and control of the Rajlovac and Ilidza

25     Brigades in addition to my duties as the Commander of the Igman Brigade."

Page 24943

 1             Mr. Dunjic, you recall this particular assignment you refer to in

 2     paragraph 4?

 3        A.   Yes, I do remember.  I received a written order on that.

 4        Q.   Now, I'd like to show you a document in connection with that

 5     assignment and I'll ask you a few questions on that document.

 6             MR. JEREMY:  Could we please see 65 ter 09808.

 7        Q.   Mr. Dunjic, while this is being brought to our screens, I'll tell

 8     you it's an SRK report to the Main Staff of the VRS.  It's dated 16

 9     December 1992.

10             MR. JEREMY:  If we could go to the last page, please, in the

11     English and the B/C/S.

12        Q.   And we see it's type signed by Ljubljana Kosovac.

13             MR. JEREMY:  Could we go to the first page in English and B/C/S,

14     please.

15             JUDGE ORIE:  While waiting for that, in your quote, Mr. Jeremy,

16     the Rajlovac Brigade is mentioned but not the Ilidza Brigade.  Rajlovac

17     and Ilidza Brigade in addition to.

18             MR. JEREMY:  Thank you, Your Honour.

19             JUDGE ORIE:  Please proceed.

20             MR. JEREMY:

21        Q.   Mr. Dunjic, in paragraph 3 on page 1 of this report, we read:

22             "At the moment, the most critical situation is in the area of the

23     municipality of Rajlovac and Vogosca."

24             MR. JEREMY:  If we go to the next page in the English, please.

25        Q.   And we read in the second paragraph:

Page 24944

 1             "In the areas of the municipalities of Hadzici, Ilidza, Rajlovac,

 2     and Vogosca, the chief organiser of the paramilitary formations is

 3     Major Dunjic, the commander of the Blazuj Brigade."

 4             Now, Mr. Dunjic, the command post of your Igman Brigade was in

 5     Blazuj; is that correct?

 6        A.   Correct.

 7        Q.   And the Major Dunjic being referred to here is you; correct?

 8        A.   Correct.

 9        Q.   Now, the report goes on to say:

10             "He is discharging the duties of brigade commander in form only.

11     He fails to show up at the brigade for three days at a time.  He has

12     unified under his command paramilitary formations and some special forces

13     units; he is supplying them with weapons and ammunition; he has taken out

14     all the combat equipment from the repair and maintenance depot and placed

15     it at the disposal of these formations.  It is clear now why he had

16     expelled the Depot management."

17             And that expelling of the depot management is a reference to the

18     entry in General Mladic's notebook we saw earlier; is that correct?

19        A.   Correct.  Yes, correct.

20        Q.   Now if we go to the next paragraph, we read:

21             "Noting all the seriousness of such a situation, the Corps

22     Command sent Colonel Kosovac, Assistant Commander for Morale, and

23     Lieutenant-Colonel Maljkovic" --

24             MR. JEREMY:  I think we need to go to the next page in the B/C/S,

25     thank you.

Page 24945

 1             THE WITNESS: [Interpretation] Lieutenant-Colonel.

 2             MR. JEREMY:

 3        Q.   Thank you.  "Lieutenant-Colonel Maljkovic to Rajlovac on 8

 4     December 1992 to assist in consolidating the situation ..."

 5             Did that in fact happen?

 6        A.   Yes, the corps commands did send them.

 7        Q.   Thank you.

 8        A.   And then after that I was appointed co-ordinator.

 9        Q.   Thank you.  Let's take a look at the next paragraph.  It states:

10             "Dissatisfied with the general situation and with the endangered

11     state of this part of the front, supposedly with the approval of the

12     Presidency, various municipal leaders take the decision to have the

13     commands of the Rajlovac and Vogosca Brigade arrested; the one executing

14     this was Major Dunjic and his people.  In addition ... the commands of

15     the brigades, Colonel Kosovac" -- excuse me.  "In addition to the

16     commands of the brigades, Colonel Kosovac and

17     Lieutenant-Colonel Maljkovic were arrested, also."

18             Mr. Dunjic, you don't deny that in September 1992 you were in

19     Rajlovac and you arrested Colonel Kosovac and

20     Lieutenant-Colonel Maljkovic; correct?  Excuse me, in December 1992.

21        A.   I don't deny.  No.

22        Q.   And you, in making these arrests, men from Branislav Gavrilovic's

23     unit, acted together with you; correct?

24        A.   No, that is not correct.

25        Q.   Do you recall testifying in the Karadzic case?

Page 24946

 1        A.   I do, yes.

 2        Q.   All right.  I'd like to show you an excerpt of your testimony in

 3     that case where a similar question was put to you, and I'd like to show

 4     you the answer that you provided.

 5             MR. JEREMY:  Can we please see 65 ter 31115.  And I would like to

 6     go to page 37.

 7        Q.   Now focusing on line 17, you were asked a question -- or I'll

 8     read it to you and it will be translated.  So the question was, and this

 9     was by -- this was during the cross-examination, so by Prosection

10     counsel.  The question was:

11             "Now, sir, you don't deny in September 1992 you were in the Zuc

12     area and you made some arrests; correct?"

13             And you state:

14             "Well, I denied that I was at Zuc.  I mean, I was below Zuc.  Let

15     us be precise.  I was in Rajlovac.  And it is correct that I arrested

16     Colonel Kosovac and Lieutenant-Colonel Maljkovic, and it is correct that

17     I arrested almost the entire municipality of Rajlovac.  And I think that

18     that was a brilliant move in order to save tens of thousands of Serb

19     people.

20                  "Q.  Let's speak specifically about who went along with you.

21     This" --

22             MR. JEREMY:  If we could go to the next page, please.

23             JUDGE ORIE:  Is that the next page or is it?

24             MR. JEREMY:  It's not the next page.  Is that the next page in

25     e-court?  It should be 30509.  Could we go to the next page, please.

Page 24947

 1             JUDGE ORIE:  Mr. Jeremy --

 2             MR. JEREMY:  Yeah, that's the correct page.  And if we could go

 3     to one page back so I can regain the continuity of the question.

 4             JUDGE FLUEGGE:  No, the -- it's difficult to go back again.  You

 5     will lose it.

 6             JUDGE ORIE:  Now it's 511 --

 7             JUDGE FLUEGGE:  [Overlapping speakers].

 8             MR. JEREMY:  Okay.  So the question, 30511, last line.

 9        Q.   "Q.  Let us speak specifically about who went along with you."

10             MR. JEREMY:  If we could just go one page forward, please.

11        Q.   "This talks about your men.  Were these men from Brne's unit who

12     were with you?

13                  "A.  Part of them, yes."

14             So, Mr. Dunjic, in your Karadzic testimony, you state that

15     Gavrilovic's men, Brne's men, were with you when you made these arrests.

16     Now you stated that they were not with you.  So which is correct?

17        A.   Let me explain.  May I?  The unit and other units from the

18     brigade were at Zuc in view of the fact that those positions were

19     falling.  The unit was at the following position, the position named

20     Smetliste.  That was Gavrilovic's unit.  It was there in order to prevent

21     the enemy from breaking through, but it was not only at Rajlovac when

22     Kosovac and Maljkovic were arrested from the Rajlovac municipality.  And

23     that is the correct answer.

24        Q.   Mr. Dunjic, I'm a little confused.  Were Brne's men with you or

25     were they not with you when you made those arrests?

Page 24948

 1        A.   They were not with me during that arrest.  They were at the

 2     Smetliste facility and they were arresting a lieutenant there who was

 3     running away from the line.  We are talking about two different arrests

 4     here.

 5        Q.   And so when in the Karadzic case you talk about making these

 6     arrests, you talk about it being a brilliant move, you were asked who

 7     went along with you and you said -- and you were asked were men from

 8     Brne's unit with you, and you said yes.  You're now saying that in fact

 9     you were not referring to the particular arrest but a separate operation.

10     Is that how I understand your testimony?

11        A.   They were with me in Rajlovac in the area of responsibility of

12     the brigade, but they were not with me at the brigade command when that

13     arrest was carried out.  They were at positions.

14             JUDGE ORIE:  Could I try to find out.  You're talking about a

15     series of arrests including the arrest of Kosovac and Maljkovic, and you

16     considered them together as one brilliant action.  In that brilliant

17     action, arresting several people, were Brne's men assisting you, were

18     they involved in those arrest?

19             THE WITNESS: [Interpretation] They did not take part in those

20     arrests because they were at positions in the area of responsibility of

21     the Rajlovac Brigade.

22             JUDGE ORIE:  Well, the Karadzic testimony suggests otherwise.

23     Not that they were at combat positions but part of the unit, that's a

24     very specific answer.  Part of the unit was with you when arrests were

25     made.  Which part of the unit was with you?

Page 24949

 1             THE WITNESS: [Interpretation] The special police units from

 2     Ilidza.

 3             JUDGE ORIE:  Now but not from Brne?  Gavrilovic.

 4             THE WITNESS: [Interpretation] No, not Brne.  People from Brne's

 5     unit were not with me at the Rajlovac command.  You're asking me for very

 6     much detail.  They did not ask for so many details in the previous trial.

 7     If they had, I would have explained.  That's why I said partly, partly

 8     because they were in a different position.  They were deployed elsewhere

 9     in the area of responsibility of the brigade.

10             JUDGE ORIE:  I specifically asked about the arrests in the

11     Karadzic case, and it was read to you a minute ago, who were with you.

12     This talk about your men.  Were these men from Brne's unit who was with

13     you?  And you were talking about the arrests.  You said:

14             "Part of them, yes."

15             My question is which part of Brne's men did you refer to at that

16     point in time?

17             THE WITNESS: [Interpretation] The troops that were deployed in

18     that position.  I took several units to Rajlovac in order to prevent the

19     fall of those positions.  Those units were from the Igman Brigade.

20             JUDGE ORIE:  Mr. Dunjic, this answer was given in direct

21     connection with you involving -- being involved in arrests.  To say that

22     they were somewhere on their positions is inconsistent with your

23     testimony given in the Karadzic case.  Do you have any explanation for

24     that?

25             THE WITNESS: [Interpretation] They were in Rajlovac.  There is

Page 24950

 1     nothing in dispute about that.

 2             JUDGE ORIE:  I didn't --

 3             THE WITNESS: [Interpretation] But they were not with me during

 4     the arrests.  That's what I'm saying.

 5             JUDGE ORIE:  I heard you saying that and I put it to you that

 6     it's inconsistent with what you said in the Karadzic case and I asked for

 7     an explanation, not for you to repeat what you said already several

 8     times.  Do you have an explanation for this inconsistency?

 9             THE WITNESS: [Interpretation] Yes.  My possible explanation would

10     be that the Prosecutor didn't ask for so much detail.  If I said they

11     were in Rajlovac, he thought that they were with me.  They were in

12     Rajlovac but not with me during the arrest.

13             JUDGE ORIE:  The Chamber will carefully read the testimony in the

14     Karadzic case and see whether your explanation assists us.

15             Please proceed, Mr. Jeremy.

16             MR. JEREMY:  Thank you, Your Honours.

17        Q.   Mr. Dunjic, you gave the order to make these arrests; correct?

18        A.   Yes.

19        Q.   And you gave this order without first consulting your superior

20     officers; correct?

21        A.   Correct.

22        Q.   All right.  I'd like to go back and take a look at this same

23     report that we were looking at a moment ago.

24             MR. JEREMY:  Could we again look at 65 ter 09808.  Can we go to

25     the second page in the B/C/S, please, and second page in the English

Page 24951

 1     please.

 2        Q.   Mr. Dunjic, five or so paragraphs from the end, we read:

 3             "There was" --

 4             At the bottom of the page in the English, we read:

 5             "There was no excuse for the arrests of complete commands of the

 6     brigades ..."

 7             MR. JEREMY:  And if we go to the next page in the English,

 8     please.

 9        Q.   In the next sentence, we read:

10             "The Brigades were thereby left completely leaderless at the

11     moment of the strongest enemy offensive.  The next day, Colonel Marcetic,

12     the Corps Chief of Staff, was also the target of abuse."

13             Mr. Dunjic, this Colonel Marcetic is the person you refer to in

14     paragraph 4 of your statement, the person that actually appointed you to

15     oversee these brigades; correct?

16        A.   Yes, it's the same Colonel Marcetic, the chief of the corps

17     staff.  He was not ill-treated.  He was not in Rajlovac.  As far as I

18     know, he was in a Vogosca.

19        Q.   We read continuing on:

20             "During the execution of these operations, there was theft and

21     looting of military property."

22             Witness, in this document it says that various municipal leaders

23     take the decision to have the commands of the Rajlovac and

24     Vogosca Brigade arrested.  Was there any involvement of municipal leaders

25     in the decision to arrest those brigade commands?

Page 24952

 1             Now you don't deny that there was theft and looting of military

 2     property, do you?

 3        A.   I deny the looting of property.  I did this to prevent the fall

 4     of the entire defence line and prevent any possible cases of looting.

 5             MR. JEREMY:  Your Honours, I'd like to tender that document as

 6     the next Prosecution exhibit.

 7             JUDGE ORIE:  Madam Registrar.

 8             THE REGISTRAR:  Document 09808 receives number P6705, Your

 9     Honours.

10             JUDGE ORIE:  And is admitted into evidence.

11             MR. JEREMY:  Actually, forgive me.  Could we take a final look at

12     P6705.  The document we were just looking at.  I've got a question on the

13     final paragraph of that document.  It's still on the screen.

14        Q.   So, Mr. Dunjic, the last paragraph in this document reads as

15     follows:

16             "Also, we propose that Major Dunjic be immediately relieved of

17     his duties, arrested, and that criminal proceedings be instituted for

18     exceeding his authority and refusing to obey Corps Command orders."

19             So, Mr. Dunjic, again we see in December there is another

20     suggestion that you should be replaced as brigade commander; correct?

21        A.   Please, this report was drafted by a colonel whom I arrested, the

22     same man from Kos was arrested and he drafted this report only two days

23     later.  You should have checked that.  I still believe that that was an

24     excellent move.

25             JUDGE ORIE:  Witness, the question was whether here, whomever did

Page 24953

 1     it, suggested you to be replaced as a brigade commander; is that correct?

 2             THE WITNESS: [Interpretation] I didn't receive this document.  It

 3     was not addressed at me.  I was not aware of it at all.  I was appointed

 4     as co-ordinator, and I was not removed from my position.

 5             JUDGE ORIE:  Mr. Jeremy, the Chamber is able to read what this

 6     document says.  The witness says he has no knowledge of it.

 7             Please proceed.

 8             MR. JEREMY:

 9        Q.   Mr. Dunjic, despite the fact that you didn't see this document at

10     the time, did it come to your attention in December 1992 that again your

11     replacement was being discussed and, in this case, suggested?

12        A.   No, no.  I was appointed as a co-ordinator.

13        Q.   And after appointed being -- after being appointed co-ordinator

14     and making these arrests, it was never brought to your attention that

15     because of the way you executed your duties, your replacement was being

16     represented to the Main Staff.  You're saying that never came to your

17     attention?

18        A.   I don't remember that anybody said anything.  However, the result

19     of that operation was this:  We prevented the fall of those

20     municipalities, we reinforced our defence, and we saved the Serbian

21     population in that area.  In view of the fact that any municipality or

22     the sector of any the brigades west of Sarajevo would cause a domino

23     effect.  It would have a ripple effect on the entire territory and the

24     entire territory would have been lost.

25        Q.   All right.  So nobody told you in December that they were

Page 24954

 1     planning or suggesting that you be replaced as Igman Brigade commander;

 2     correct?

 3        A.   That's correct, yes.

 4        Q.   Now in January 1993 in the next month --

 5             JUDGE ORIE:  Mr. Jeremy, before you continue, I have a few

 6     questions still related to December and this document for the witness.

 7             Witness, in this document it says that various municipal leaders

 8     take the decision to have the commands of the Rajlovac and

 9     Vogosca Brigade arrested.  Was there any involvement of municipal leaders

10     in the decision to arrest those brigade commands?

11             THE WITNESS: [Interpretation] I'm not aware of that decision.

12     No, I don't know.  I made it myself for Rajlovac.

13             JUDGE ORIE:  Yes.  Now it's also said in this document that this

14     decision was supposedly taken with the approval of the presidency.  Did

15     you have any contact with the presidency in relation to this action,

16     arresting the brigade commands?

17             THE WITNESS: [Interpretation] I did not have any contacts.  The

18     brigade -- okay.

19             JUDGE ORIE:  So you acted purely on your own without any orders

20     from the corps level?

21             THE WITNESS: [Interpretation] Yes.  It was a matter of minutes

22     whether the positions would fall or not.

23             JUDGE ORIE:  Mr. Jeremy, please proceed.

24             MR. JEREMY:  Thank you, Your Honours.

25        Q.   Mr. Dunjic, you -- I asked you about the reference to

Page 24955

 1     Colonel Marcetic in that document and you said that no harm came to

 2     Colonel Marcetic.

 3        A.   This is not what I said.  I said that he was not in Rajlovac.  I

 4     think that he was in Vogosca, but I don't know what transpired there.  I

 5     didn't say that he -- no harm had come to him.  I only said that he was

 6     not in Rajlovac but that he was in Vogosca as far as I know.

 7        Q.   So you said that he was not ill-treated.  He was not in Rajlovac.

 8     So is it your testimony he was not ill-treated in Rajlovac but it may be

 9     he was ill-treated elsewhere, you just don't know about that?

10        A.   Yes, I don't know about that because he was not in Rajlovac.  I

11     don't know what happened in Vogosca.

12        Q.   All right.  We'll move on.

13             MR. JEREMY:  Could we please see -- excuse me.

14        Q.   Mr. Dunjic, you were replaced in January 1993; correct?

15        A.   Yes, on the order of the corps command.  I don't know whether the

16     corps was relevant or not.  However, I was removed, I obeyed the order,

17     and I left the area of the Sarajevo Romanija Corps.  Until the very end

18     of the war, I had no further contacts with the corps.

19        Q.   Now it's correct, isn't it, that on hearing about the decision,

20     on being told a decision had been made to replace you, you had an

21     altercation with General Galic; that's correct, isn't it?

22        A.   That's not correct.  The decision on my dismissal followed the

23     incident involving General Galic.

24        Q.   All right.  I'd like to show you a document in connection with

25     the incident with General Galic and I'd ask you some questions on that.

Page 24956

 1             MR. JEREMY:  Could we please see 65 ter 31126.

 2        Q.   And this is an Official Note from the RS MUP.  Now, Mr. Dunjic,

 3     referring to this document, we see it reads in the -- on the third line:

 4             "On 14 January 1993 in the afternoon, General Galic came to

 5     Hadzici to visit the commander of Igman Brigade, Major Velimir Dunjic.

 6     The two met in the Dunjic's flat in the presence of some company

 7     commanders and fighters who had also been invited.  The meeting lasted

 8     until late.  Alcohol was consumed.  Some were already under the

 9     influence.  At about midnight that day, General Galic and Major Dunjic

10     started disagreeing.  At one point Major Dunjic jumped up and rip off the

11     general's ranks from his camouflage uniform and dipped them into some

12     gravy sauce" --

13             JUDGE ORIE:  Where are we exactly in the text?  Could you guide

14     us, Mr. Jeremy.

15             MR. JEREMY:  Forgive me, Your Honours.  I've have been reading

16     from a related but different document.

17             JUDGE ORIE:  Yes, but we'd like to follow the document you showed

18     to us on the screen.

19             MR. JEREMY:  I understand.  Can we please see 65 ter 31125.

20        Q.   Mr. Dunjic, I've read to you the second and third paragraphs of

21     the document on the screen before you.  I continue from where I left off:

22             "General Galic didn't react.  After some heavy arguing and

23     alcohol consumption, a physical confrontation between Galic and Dunjic

24     broke out."

25             So it's correct, Mr. Dunjic, that in January 1993 you actually

Page 24957

 1     got into a physical confrontation with your corps commander,

 2     General Galic; correct?

 3        A.   Correct.

 4        Q.   And it was as a consequence of this confrontation that you were

 5     removed from your role as commander of the Igman Brigade; correct?

 6        A.   Yes.  I suppose that that was the reason.

 7        Q.   And do you dispute the events described in this MUP document we

 8     see on the screen before us?

 9        A.   I deny that in the part where it says that I was under the

10     influence.  I'm talking about myself.  Second of all, I dispute that

11     Brne's men were involved.  While I was the brigade commander, Brne never

12     entered the command post where I was in command, where I was in charge.

13             JUDGE MOLOTO:  I'm sorry.  I'm lost now.  I don't see anything

14     about Brne in this document and I don't know what the witness is talking

15     about at this stage.

16             MR. JEREMY:  Your Honours, I --

17             JUDGE MOLOTO:  And secondly, he just -- you just agreed,

18     Mr. Dunjic, a few minutes ago that as a consequence of the incidents

19     described here, you were dismissed.  Now suddenly you deny them.  Can you

20     please explain yourself?

21             THE WITNESS: [Interpretation] No, I did not deny the fact that I

22     was dismissed after that.

23             JUDGE MOLOTO:  But you are denying the incidents described in

24     this document after you have admitted that it was a consequence of these

25     incidents that caused your dismissal.  Listen to my question.  Do you

Page 24958

 1     have an answer?

 2             THE WITNESS: [Interpretation] And the question was?

 3             JUDGE MOLOTO:  The question was you'd just admitted a few minutes

 4     ago that as a consequence of the events that are described in this

 5     document, you were dismissed.  Now, on a subsequent question, you are now

 6     saying you deny that the incidents described in this document took place.

 7     And then you want to bring -- you want to say you were not under the

 8     influence.  There is no mention of you being under the influence here and

 9     that is not Mr. Jeremy's question.  Only said here about alcohol is that

10     it was consumed, by who we don't know.

11             THE WITNESS: [Interpretation] I'm not saying that I was not

12     dismissed after the incident and that that --

13             JUDGE MOLOTO:  That's not my --

14             THE WITNESS: [Interpretation] -- that may have been the reason.

15             JUDGE MOLOTO:  Stop.

16             THE WITNESS: [Interpretation] I'm not denying that.

17             JUDGE MOLOTO:  Stop.  That was not the question.  You did admit

18     that you were dismissed but you also did admit that the reason you were

19     dismissed was because of the incidents described in this document.  Now,

20     how do you then come to say, and I want you to explain this

21     inconsistency, that you deny the events that took place in this document?

22             THE WITNESS: [Interpretation] I'm not denying that the incident

23     took place, but I'm --

24             JUDGE MOLOTO:  [Overlapping speakers].

25             THE WITNESS: [Interpretation] -- disputing the entire description

Page 24959

 1     of the event.

 2             JUDGE MOLOTO:  That was my question.  That was my question.

 3             JUDGE ORIE:  Yes, I have, perhaps, then a few questions.

 4             Apparently you say an incident happened but not in the way

 5     described here.  You referred to Brne's men.  We've talked about them

 6     quite a bit.  Were any of those of Gavrilovic's unit present?

 7             THE WITNESS: [Interpretation] No, nobody.

 8             JUDGE ORIE:  Were there any fighters present other than

 9     Gavrilovic's men?

10             THE WITNESS: [Interpretation] Yes, my security detail, which

11     secured the command post, and General Galic's escorts.

12             JUDGE ORIE:  They were in the flat where the incident happened?

13             THE WITNESS: [Interpretation] Yes, in the flat.

14             JUDGE ORIE:  Did any of your security detail ever belonged to a

15     unit which was commanded by Gavrilovic?

16             THE WITNESS: [Interpretation] Not at that time or before that.

17     As a matter of fact, I don't know.  While I was in command none of the

18     people who were at the command post -- no, no, no, nobody was there.

19             JUDGE ORIE:  I asked you whether any of your security detail had

20     been a member of Gavrilovic's unit at whatever point in time.

21             THE WITNESS: [Interpretation] No, no.  Not before that.

22             JUDGE ORIE:  The other document shown from which Mr. Jeremy was

23     not quoting specifically mentions the presence of Brne's Chetniks during

24     this party, and you say that's just invented.  It's not true.  Is that --

25             THE WITNESS: [Interpretation] That's correct, yes.

Page 24960

 1             JUDGE ORIE:  Any company commanders present?

 2             THE WITNESS: [Interpretation] I don't remember.  I don't know.  I

 3     don't think so.

 4             JUDGE ORIE:  Well, if you say you don't remember, apparently you

 5     do not remember the exact composition of the company that was present in

 6     the flat.

 7             THE WITNESS: [Interpretation] I have to remember that because it

 8     was the permanent security detail that provided security for the command

 9     post.

10             JUDGE ORIE:  When I asked you about company commanders, you said

11     I don't remember.  So apparently you're not fully acquainted anymore with

12     who were and who were not present.

13             THE WITNESS: [Interpretation] I said that members of my security

14     detail were there as well as members of Galic's security detail.

15             JUDGE ORIE:  I asked you whether any company commanders were

16     present.  Your response was:  "I don't remember.  I don't know.  I don't

17     think so."  This led me to my question that you may not remember the

18     presence -- remember all those who were present or were not present.  Is

19     that well understood?

20             THE WITNESS: [Interpretation] Yes, that was well understood.

21     Yes.

22             JUDGE ORIE:  Please proceed, Mr. Jeremy.

23             MR. JEREMY:  Thank you, Your Honours.

24        Q.   Mr. Dunjic, do you dispute that you ripped off General Galic's

25     ranks from his camouflage uniform or is that part of the report correct?

Page 24961

 1        A.   I remember.

 2        Q.   That did in fact happen; correct?

 3        A.   Yes.  It did happen.  When General Galic ordered members of his

 4     security detail to shoot at me, I ripped off his ranks because he already

 5     invoked his authority as a general.  He said he could do whatever.  And

 6     that's when he ordered his security detail to shoot at me, then I ripped

 7     off his ranks, and I told him, "Now we can talk as two human beings

 8     without any ranks."

 9        Q.   And what prompted General Galic to order members of his security

10     detail to shoot at you?

11        A.   We were at a meeting in Ilidza.  Mr. Morillon was there as well

12     as Mr. Galic and myself.  We discussed a celebration of rank awarding to

13     Mr. Galic and to Mr. Morillon.  After the official part of the meeting,

14     there was a cocktail party which I left, that was the unofficial part,

15     and I left and went to my command post in Hadzici.

16             In the evening, Galic and his security detail arrived there.  He

17     was angry with me for having left the cocktail party where alcohol had

18     been consumed, and he was also angry that I had arrested people in

19     Rajlovac including Colonels Kosovac and Maljkovic. 

20             MR. JEREMY:  Your Honours, I would like to tender that document

21     as the next Prosecution exhibit, 31125.

22             JUDGE ORIE:  Madam Registrar.

23             THE REGISTRAR:  Document 31125 receives number P6706, Your

24     Honours.

25             JUDGE ORIE:  And is admitted into evidence.

Page 24962

 1             MR. JEREMY:  Could we just have another look at 31126.  It was on

 2     our screens before this document.

 3        Q.   Mr. Dunjic, I'm calling up a document you've already had an

 4     opportunity to look at.  It's an RS report dated the 18th of January,

 5     1993.  It relates to the same incident.  You've actually described a

 6     number of the events described in this particular document.  We see in

 7     the first paragraph that there is a reference to Brne's men being present

 8     in the apartment.  I understand that your evidence is that that was not

 9     the case; correct?

10        A.   This is not correct.  That's why I said that Brne's men were not

11     there, because I already saw this document before it was shown to me and

12     I reacted immediately.

13        Q.   Now just before we leave this document, I'd like to direct your

14     attention to the final paragraph where we read:

15             "We have information that within the military circles in the area

16     of Hadzici, Ilidza, and Butila, there is talk that on that occasion the

17     general was arrested, and as a reason for that, his sacking of

18     Major Dunjic from the Sarajevo Romanija Corps is cited."

19             Is it correct that the reason you assaulted General Galic was

20     because you, and the reason that he asked his men to shoot at you, is

21     because you tried to arrest him; is that correct?

22        A.   No, that is not correct.  You would have had the exact data on

23     that even now, 22 years after the fact, had he actually been arrested.

24     Mr. Galic did not see me nor did he sack me.  The procedure is quite

25     different in the army.

Page 24963

 1        Q.   Did you attempt --

 2             JUDGE ORIE:  That's not the question.  The question was whether

 3     you were shot at because you'd tried to arrest General Galic.  I think

 4     your answer is that's not correct.

 5             THE WITNESS: [Interpretation] Yes.

 6             JUDGE ORIE:  Please proceed.

 7             MR. JEREMY:

 8        Q.   Mr. Dunjic, you've mentioned your security detail.  Could you

 9     tell me the name of the person who was in charge of that?

10        A.   I think that it was Dragan Kecanovic, Dragan Kecanovic.  He was a

11     member of the special units of the Bosnia-Herzegovina MUP before the war.

12     And Krstic, Krstic, Krstic -- I don't know his first name.

13             MR. JEREMY:  Your Honours, I'd tender that document as the next

14     Prosecution exhibit.

15             JUDGE ORIE:  Madam Registrar.

16             THE REGISTRAR:  Document 31126 receives number P6707, Your

17     Honours.

18             JUDGE ORIE:  And is admitted into evidence.

19             MR. JEREMY:  Your Honours, I think we're at break time and I

20     expect to conclude my cross-examination shortly after the break.

21             JUDGE ORIE:  Yes, thank you.

22             And, Mr. Stojanovic, we'd like to hear from the plans as far as

23     the next witness is concerned.  Not necessarily now.

24             But, first of all, could the witness be escorted out of the

25     courtroom.

Page 24964

 1                           [The witness stands down]

 2             JUDGE ORIE:  I was not expecting that you had already

 3     communicated with Mr. Lukic, but I take it that you certainly will do so

 4     during the break.  But you may have done it already.  If there is

 5     anything to report, please let us know.

 6             Second, there was the other issue about you and Mr. Jeremy

 7     meeting during the break to find out whether I misstated that portion of

 8     the evidence where reference was made to crimes committed in relation to

 9     ethnicity of the victims.  Anything to further report on that, either

10     from you or from you, Mr. Jeremy?

11             MR. JEREMY:  Your Honours, my understanding of the conversation

12     is that the -- the translation of the relevant paragraphs is not

13     disputed, and I also understand that it -- that we do not believe that

14     you mischaracterised the paragraph in -- in any way.

15             JUDGE ORIE:  Yes.  Thank you for having resolved that matter for

16     me.

17             Mr. Stojanovic, you agree with Mr. Jeremy?

18             MR. STOJANOVIC: [Interpretation] That is right, Your Honours.

19     That is how matters stand.  We just had a problem regarding the

20     translation.

21             JUDGE ORIE:  Okay.  I'm glad that that matter is resolved.  We

22     take a break and will resume at 20 minutes past 12.00.

23                           --- Recess taken at 11.57 a.m.

24                           --- On resuming at 12.21 p.m.

25             JUDGE ORIE:  While the witness will be brought in, any further

Page 24965

 1     reports from the Defence on the next witness?

 2             MR. STOJANOVIC: [Interpretation] Your Honours I would just like

 3     to inform you that during the break I contacted my colleague, Mr. Lukic.

 4     He is at the office right now and he is working with the next witness.

 5                           [The witness takes the stand]

 6             MR. STOJANOVIC: [Interpretation] And I was asked to let you know

 7     and to ask for your understanding for the reasons why we were closer to

 8     the opinion that we had not -- we have not completed the proofing of the

 9     witness; namely, the witness testified in the Galic case, he does not

10     speak English, and they are just going through the transcript of his

11     testimony in the Galic case in order to complete the proofing.

12             Last night when I was at the office together with my colleague,

13     Mr. Lukic, and with the witness, we saw or I saw that there was a

14     technical problem to open the map marked by the witness in the Galic

15     case, which is a relevant piece of evidence because the data that he had

16     when he was working at his duties in the Sarajevo Romanija Corps command,

17     he marked the targets of the B and H army in Sarajevo itself.  And so

18     this morning they had to open it with the help of the technical service

19     in order to go through that with the witness.

20             Then once they searched the EDS, they did get a lot of documents

21     which in the opinion of my colleague Mr. Lukic they need to go through in

22     order to prepare the witness properly for his testimony because we

23     believe that this is a very relevant witness.  We did not have enough

24     time last night or yesterday afternoon after court to complete this.

25             This morning, they began again at 8.30 at the office, and as you

Page 24966

 1     could see I was in the courtroom by myself today with my colleague

 2     Mr. Saljic.  So once again, we would kindly ask you to accept the reasons

 3     why we are not going to be able to bring the witness out today to begin

 4     his testimony.

 5             JUDGE ORIE:  The Chamber appreciates that you have explained the

 6     situation, Mr. Stojanovic.

 7             Mr. Jeremy, if you're ready, please proceed.

 8             MR. JEREMY:  Thank you, Your Honours.

 9        Q.   Now, Mr. Dunjic, we -- we ended the last session discussing in

10     some detail this incident between General Galic and yourself.  Now,

11     during his testimony in the Karadzic case, General Galic made a few

12     comments about you, and I'd like to discuss those comments with you.

13             MR. JEREMY:  Could we please see on our screens 65 ter 31117.

14     And this is the transcript of the testimony of Stanislav Galic in the

15     Karadzic case.  It's dated the 8th of May 2013.  I would like to go to

16     e-court page 14, please.

17        Q.   Mr. Dunjic, as I mentioned, you were discussed by General Galic

18     at various points during his testimony and -- actually, during his

19     cross-examination, in particular, in the Karadzic case.  Now, I'm going

20     to read you an excerpt of that cross-examination.

21             MR. JEREMY:  Before I read the excerpt, I can make a

22     representation to the Court that while General Galic in the quote I'll

23     read out to you refers --

24        Q.   -- to you only as Dunjic, elsewhere in his testimony in the

25     Karadzic case, he refers to you as "commander of the Igman Brigade,

Page 24967

 1     Dunjic," and that's at transcript page 37811, lines 6 to 7 in the

 2     Karadzic case.

 3             So I'll read the quotation and it's 22 lines of text, Mr. Dunjic,

 4     so please bear with me.

 5                  "Q.  Perhaps you could tell us whether Dunjic or Grkovic

 6     were removed" --

 7             MR. JEREMY:  If we could go to the next page, please.

 8        Q.   "... for use of SRK artillery against Bosnian-held Sarajevo in a

 9     disproportionate fashion?"

10                  "A.  The last assertion is correct about the two of them,

11     and that's the words that I used, disproportionate use of firing assets,

12     including artillery.  I am an artilleryman.  That's -- I meant artillery.

13     And I said about Dunjic that he did lack discipline.  And it's only

14     normal when a war goes on.  He was engaged.  He had his own views as to

15     how to deal with certain problems.  I did not consider whether he was

16     right or wrong in his theoretical considerations, but I had a lot of

17     objections to the practical side of his use of assets.  That's why I

18     thought that he would -- should be removed and not to have to deal with

19     the problem that existed in his area of responsibility, and also because

20     he used artillery and firing assets in a disproportionate way.

21             "When it comes to Grkovic, I don't know what Dunjic said here and

22     I don't really care, to be honest.  Let's be clear on that.  I don't care

23     what Dunjic said here.  I know why a proposal was tabled for his removal.

24     What he said is his problem.  Everybody has the right to think for

25     himself and to say whatever they want to say.  That's the way he saw the

Page 24968

 1     problem, but I was the commander at the time.  I had the right to make

 2     decision, and I proposed that he should be removed.  I'm not hiding that.

 3     That is nothing new."

 4             Mr. Dunjic, do you have any comments on the fact that the reason

 5     why General Galic said that you were removed from your command was

 6     because you used artillery and firing assets in a disproportionate way?

 7        A.   I am just now for the first time finding out that I used

 8     artillery disproportionately, and on the basis of documents you can see

 9     that while I was carrying out the duty as brigade commander I was never

10     even once warned about unselective or disproportionate use of artillery.

11             If Galic is an artilleryman, I'm a tank-man, and in the case of

12     attack, the corps command was 100 kilometres away from my command.  Lines

13     were frequently cut.  And in the event of an attack, I would use all

14     available assets to destroy the enemy.  That is correct.  But I don't see

15     what is disproportionate there.  We were not playing chess.  We were

16     waging war.

17             And Galic has the right to his opinion just as I have the right

18     to mine.  I didn't know that that was the reason.  This is the first time

19     that I'm hearing of it.  I believe that the reason is actually the

20     incident.

21        Q.   When you say "the incident," which incident -- can you be clear

22     which incident you mean?

23        A.   Of the 14th of January.

24        Q.   This was the incident in your apartment where you and

25     General Galic had the altercation; correct?

Page 24969

 1        A.   At my forward command post in Hadzici.  Yes, yes.  Where we had

 2     the altercation, that's right, on the 14th of January 1993.

 3        Q.   And do I understand your testimony correctly, which is that you

 4     were never -- General Galic never said to you that you were using

 5     artillery and firing assets in a disproportionate way; is that correct?

 6        A.   Right.  Not to me.  Because he mentions me by name as the person

 7     who's using fire disproportionately.

 8        Q.   So it's correct then that you dispute the truth about what

 9     General Galic is saying in his testimony in the Karadzic case; yes?

10        A.   I don't know.  First of all, I don't know what "disproportionate"

11     means.  I am a military man but I don't know what that means.  I would

12     like somebody to explain that to me.

13        Q.   Mr. Dunjic, it seems to be the case that regardless of how we

14     define "disproportionate," it seems clear from General Galic's testimony

15     that he had real concerns about the way that you were using artillery and

16     firing assets.  Did he ever bring those concerns to your attention?

17        A.   Not to me personally, no.  Some orders did arrive concerning all

18     corps brigades and that was when there was a cease-fire that was agreed

19     on not to use heavy weaponry.  I do recall some orders about that.  But

20     nobody issued an order to me personally, neither orally or in writing.

21        Q.   So from your answer, Mr. Dunjic, I interpret your answer as

22     saying that when General Galic says that you were removed because you

23     used artillery and firing assets in a disproportionate way, I understand

24     your answer to be that, no, that is not in fact correct, that instead you

25     were removed because of the event that happened on the 14th of January

Page 24970

 1     1993; correct?

 2             JUDGE ORIE:  Well, I think, Mr. Jeremy, you are -- what the

 3     witness said is that he has no knowledge of any such reason for being

 4     removed and that he lives in the belief that the incident caused him to

 5     be removed and not anything else.  That is.

 6             So what happened or not is not necessarily exactly the same of

 7     what the witness tells us of his awareness of the reasons for the

 8     removal.  We should clearly distinguish the two.

 9             Please proceed.

10             MR. JEREMY:  Thank you, Your Honour.

11        Q.   Mr. Dunjic, just to finally clarify my understanding:

12     General Galic himself never personally drew to your attention concerns

13     that he had regarding the use of artillery and firing assets regarding

14     the way you were using them; is that correct?

15        A.   Correct.

16        Q.   Thank you.

17             MR. JEREMY:  Your Honours, that concludes my cross-examination.

18        Q.   Thank you, Mr. Dunjic.

19             JUDGE ORIE:  Thank you, Mr. Jeremy.

20             Mr. Stojanovic, have you any questions in re-examination for the

21     witness?

22             MR. STOJANOVIC: [Interpretation] I do have a few questions, Your

23     Honour.

24             JUDGE ORIE:  Please proceed.

25                           Re-examination by Mr. Stojanovic:

Page 24971

 1        Q.   [Interpretation] Mr. Dunjic, I'm asking you as a soldier:  In the

 2     command and control system, who appoints and who relieves a commander of

 3     the brigade of duty?

 4        A.   The Main Staff.

 5        Q.   In the specific instance, you were replaced in late January 1993.

 6     Who specifically relieved you of duty?

 7        A.   The corps commander.

 8        Q.   And did you receive any written decision about this?

 9        A.   Yes, I did.

10        Q.   And who signed the decision on your dismissal from duty as

11     commander of the Igman Brigade?

12        A.   I think it was either Marcetic or Galic.  I don't recall the

13     signature.

14        Q.   Do you know whether at any point General Mladic was directly

15     informed about the incident of the 14th of January 1993?

16        A.   No, I don't know that.

17             MR. STOJANOVIC: [Interpretation] Could we please look at document

18     65 ter 31126 in e-court, please.

19             JUDGE FLUEGGE:  This is now P6707.

20             MR. STOJANOVIC: [Interpretation] Thank you, Your Honour.  I

21     didn't manage to write in the number.  So please P6707.

22        Q.   This is a document that you had the opportunity to see a while

23     ago during the cross-examination.  I'm just going to ask you to tell me

24     whose document is this, judging by the heading?

25        A.   This is a document of the Ministry of the Interior.

Page 24972

 1             MR. STOJANOVIC: [Interpretation] Could we look at the last page,

 2     please.

 3        Q.   The document is signed by somebody who signed for the chief of

 4     the sector of the National Security Service, Predrag Ceranic?

 5        A.   Yes.

 6        Q.   Are you aware that documents like this of the National Security

 7     Service were given to the Army of Republika Srpska?

 8        A.   No, I don't know if they were or were not.

 9        Q.   Thank you.  And according to you, at any point in time because of

10     events that occurred in Rajlovac and due to the arrest of two officers of

11     the corps, were any disciplinary or criminal proceedings taken against

12     you in relation to this?

13        A.   No, never.

14        Q.   You answered a question of the Prosecutor by saying that although

15     it was a long time ago, it was, in your opinion, a brilliant decision.

16     Would you please tell us why you still think that is so after so many

17     years?

18        A.   The positions of the Rajlovac Brigade were about to fall.  The

19     command in that brigade was completely in disarray.  There was no

20     commander of the brigade there.  The chief of staff of the brigade was

21     not there.  They had abandoned their positions.

22             Colonel Kosovac and Lieutenant-Colonel Maljkovic arrived in front

23     of the corps command, or on behalf of the corps command, to deal with the

24     situation.

25             I came to Rajlovac, Colonel Kosovac was reporting to

Page 24973

 1     General Galic.  He said, "General, sir, Dunjic arrived.  The situation

 2     here has been resolved.  Should Maljkovic and I now return to the corps?"

 3             The report of Colonel Kosovac to General Galic was false.  The

 4     soldiers were abandoning their positions.  They were throwing their

 5     weapons away.

 6             I made the decision on the spot to arrest those responsible for

 7     this situation, and the municipal leadership, following the logic that a

 8     soldier would say, "This man is arresting these guys.  I wonder what will

 9     happen to us."  I returned the units to their positions and saved the

10     population.

11        Q.   And was this the period when a dominant feature, Zuc hill, was

12     captured by the Army of Bosnia and Herzegovina during their assault?

13        A.   Yes, it was during that period.  We're not just talking about Zuc

14     but the line of separation.  Let me explain to the Trial Chamber.  The

15     line of separation between the Rajlovac Brigade and the BiH Army forces

16     was just 50 metres apart.  With the fall of these dominant features, the

17     whole municipality of Rajlovac would have fallen as well as the

18     municipality of Vogosca.  And the only road for thousands of civilians

19     and members of six brigades -- actually, five brigades, not the

20     Koseva Brigade, would be closed through Rajlovac, Vogosca, for Semizovac.

21             All those units, together with the civilian populations, would

22     have found themselves in an encirclement.  These were positions where --

23     were such that if any brigade were to fall there would be a domino effect

24     and all the other brigades would fall.

25        Q.   And let me finish by asking you whether you know that at that

Page 24974

 1     time people were arrested elsewhere including officers who were deemed to

 2     be responsible for everything what was happening to the positions of the

 3     Army Republika Srpska?

 4        A.   If you mean the Sarajevo Romanija Corps, yes.  I knew that

 5     Colonel Josipovic in Vogosca arrested the command of the Vogosca Brigade

 6     due to their inability to organise combat.  And the two of us did not do

 7     it in agreement.  Both of us were taken by the military instinct to react

 8     immediately.

 9        Q.   Thank you.

10             MR. STOJANOVIC: [Interpretation] I would like to call up P1967.

11     Page 6 in B/C/S and I believe it's the end of page 6 and the beginning of

12     page 7 in English.

13        Q.   Mr. Dunjic, these are the minutes of the meeting which was held

14     at the command of the Sarajevo Romanija Corps which you attended, and

15     Marko Lugonja has been recorded in this part addressing the gathering.

16             MR. STOJANOVIC: [Interpretation] Page 6 in B/C/S and the

17     following page in the English version of the same document.

18        Q.   While we're waiting for --

19             MR. STOJANOVIC: [Interpretation] The following page in B/C/S,

20     page 6 and page 7 in English.  Thank you.  I believe that we have the

21     correct pages.

22        Q.   I would like to ask you:  Before I direct your attention to one

23     part of this document, do you know -- did you know at the time about the

24     Golf affair and the theft of cars from the TAS factory in Vogosca?

25        A.   I was aware of that, but let me explain that I became the brigade

Page 24975

 1     commander after the affair, when the whole thing was over.  But I did

 2     know that there was a major theft in Vogosca, several thousand of cars

 3     had been stolen.

 4        Q.   According to you, would that have been a major theft, a grand

 5     theft?

 6        A.   Yes, absolutely.

 7        Q.   Was that before Marko Lugonja's introductory address?  Did that

 8     theft precede that address?

 9        A.   Yes.

10        Q.   Do you know that before you joined the unit and while you were

11     there in Hadzici, Rajlovac, Vogosca, there were cases of illegal conduct,

12     that the crime rate went up, that there was a lot of theft of property?

13        A.   Yes, I knew that that started happening before I arrived.

14        Q.   As a matter of fact, who would have been in charge to prosecute

15     such crimes that went on behind the brigades' lines?

16        A.   In my statement, I said that I filed dozens of criminal reports

17     against my own soldiers for ammunition smuggling, for desertion, and

18     other nonmilitary matters.  Those criminal reports were sent to the

19     judiciary bodies.  The brigade commander is not in charge of actually

20     processing such matters but only to file reports on learning that a crime

21     had been committed.

22        Q.   Now let's look at one paragraph together.

23             JUDGE FLUEGGE:  Mr. Stojanovic.

24             MR. STOJANOVIC: [Interpretation]

25        Q.   In that paragraph you --

Page 24976

 1             JUDGE FLUEGGE:  Mr. Stojanovic, obviously you have not the

 2     corresponding pages on the screen.

 3             MR. STOJANOVIC: [Interpretation] Your Honours, I believe that the

 4     B/C/S page is correct.  As for the English version, we need to go back to

 5     the previous page and that would be the correct page in English.  Thank

 6     you for your assistance.

 7             JUDGE FLUEGGE:  No, this is not correct.  This is not correct.

 8             JUDGE ORIE:  No, but I --

 9             MR. JEREMY:  [Overlapping speakers].

10             JUDGE ORIE:  I think we moved twice.  So if we -- well, I --

11             MR. JEREMY:  I think we go forward one more page.

12             JUDGE FLUEGGE:  This I can't be the right page.

13             JUDGE ORIE:  No.  It -- we just had an English version where it

14     was indicated the start of pages 6.  Whenever it's on the screen, it

15     disappears immediately.  I don't know why.  But let's try to get back.

16     That's where in the English we see a 6 and that seems to correspond

17     with ...

18             Now, what part of page, and if I say "6," I mean 6 in the hard

19     copy, would you like to draw our attention to, Mr. Stojanovic?

20             MR. STOJANOVIC: [Interpretation] In B/C/S we have the right page,

21     paragraph starting with the wide phenomena of plunder and looting, and I

22     believe it's on the following page in English.

23             MR. JEREMY:  Your Honours, I think it's page 9 in e-court for the

24     English.

25             JUDGE ORIE:  Okay.  Yes.  Perhaps at the top of that page.

Page 24977

 1             Please, Mr. Stojanovic.

 2             MR. STOJANOVIC: [Interpretation] I believe that we are now on the

 3     right page, Your Honours.

 4        Q.   Mr. Dunjic, I would like to direct your attention to just one

 5     paragraph.

 6             MR. STOJANOVIC: [Interpretation] And I would like to thank

 7     Mr. Jeremy for his help.

 8        Q.   Here, amongst others things, Mr. Lugonja says:

 9             "Extremely widespread theft, robbery, violence and other crimes.

10     Everything is being stolen starting from cars, household appliances to

11     clothing, et cetera.  It is worth emphasising that many individuals feel

12     that theft and robbery is their right and that it is the only way to be

13     reimbursed for what they have lost or compensate for their participation

14     in war."

15             You participated in the events and you listened to this address.

16     Did there come a time at any moment when this was happening only against

17     non-Serbs or was this a widespread phenomenon involving everybody?

18        A.   It involves everybody, but I did not find myself in Mr. Lugonja's

19     address.  I didn't find parts of my unit in that address.  And Mr. Galic

20     also confirmed that in his report to the corps.  He mentioned theft,

21     robbery, and other things, whereas Mr. Galic in his report said that

22     members behaved inappropriately, and he was referring to members of

23     Brne's unit.

24             If I do not say good morning to the Trial Chamber, I will not be

25     behaving appropriately but this will not constitute a crime.  So this

Page 24978

 1     wording "inappropriate behaviour" or "inappropriate conduct" may imply

 2     that he did not give the seat to an elderly woman a bus, but that doesn't

 3     imply crime, murders, killings, and any other forms of criminal

 4     behaviour.

 5        Q.   Did you learn personally that in the area of responsibility of

 6     your brigade there were crimes which were committed by members of your

 7     unit against non-Serbian population?

 8        A.   No.  None of the units from my brigade.  Including the members of

 9     the unit that is being referred to in this paragraph.

10        Q.   Thank you, Mr. Dunjic.

11             JUDGE ORIE:  Could I just try to.

12             Mr. Stojanovic, did I understand you well that the extremely

13     widespread theft, robbery, violence and other crimes, that you consider

14     that to be crimes committed not specifically by the military but as a

15     general feature of the time or did I misunderstand you?  Was that the

16     gist of your questions, that it was theft, robbery, everywhere, and not

17     necessarily part of misbehaviour of the members of the

18     Republika Srpska Army?

19             MR. STOJANOVIC: [Interpretation] Your Honour, when I read the

20     document carefully while I was preparing to lead the witness, after

21     having received it from the Prosecutor, I see that this refers to members

22     of the Sarajevo Romanija Corps because this is how his address started,

23     and that's why I asked Mr. Dunjic whether such occurrences were noticed

24     in the area of responsibility of his unit behind his lines.  And I meant

25     not only soldiers but civilians as well.

Page 24979

 1             JUDGE ORIE:  Yes.  Just for me to properly understand, is it the

 2     position of the Defence that this document, and specifically this

 3     paragraph you took us to, also deals with crimes - that is, theft,

 4     robbery, violence, and other crimes - committed by others than the

 5     members of the SRK units?  Is that your position or is it your position

 6     that this paragraph deals with criminal behaviour or at least

 7     misbehaviour of members of the SRK?

 8             MR. STOJANOVIC: [Interpretation] This refers to members of the

 9     SRK.  The position of the Defence is that there were such occurrences

10     among the civilian structure as well.

11             THE WITNESS: [Interpretation] May I be allowed to explain

12     something?  This was the first such meeting from the moment combat

13     activities started and it comprised all of the events that had taken

14     place up to that day.

15             JUDGE ORIE:  Then perhaps for you, Mr. Dunjic, this part of this

16     report, do you understand this to deal primarily, and I would even say

17     exclusively, with misbehaviour of members of the SRK, or do you consider

18     that this goes broader and also deals with crimes, et cetera, committed

19     by others; civilians, nonmembers of the SRK?

20             THE WITNESS: [Interpretation] Yes, I believe that this is the

21     case.  The others were prosecuted by the Ministry of the Interior or

22     whatever was in charge.  In any case, it wasn't the military.

23             JUDGE ORIE:  But in this report --

24             THE INTERPRETER:  Microphone for the Judge.

25             JUDGE ORIE:  But in this report, does that cover the -- well,

Page 24980

 1     let's say, the misbehaviour of members of the SRK or does, it in your

 2     view, go beyond that and does it cover crime in general, irrelevant

 3     whether it was committed by members of the SRK or any other person?

 4             THE WITNESS: [Interpretation] I believe that this is a report

 5     from the field and involves other people who were not members of the

 6     Sarajevo Romanija Corps; i.e., civilians who were not engaged in any of

 7     the corps units.

 8             JUDGE ORIE:  Yes.

 9             THE WITNESS: [Interpretation] This is just my opinion.

10             JUDGE ORIE:  Yes.  Almost every paragraph of -- almost every item

11     in this paragraph specifically deals with military so therefore I'm a bit

12     surprised by your explanation of this document, because every bullet

13     point specifically refers to a military situation; ill-discipline for

14     nonmilitary members.  Discipline seems to be irrelevant.  Nonrecognition

15     of army hierarchy is not a matter which is primarily relevant for those

16     who are not members of the armed forces.

17             In third bullet point, they talk about units, which is also

18     typically military language.  And the fourth bullet point, where the

19     theft, robbery, violence, and other crimes are mentioned.  That's the

20     only one -- well, it mentions that this is the -- that they consider it

21     the only way to refund what they have lost or to compensate their

22     participation in the war, which seems to be a rather military expression.

23             The bullet point after that, whether they feel the Geneva and

24     other conventions as obsolete and unnecessary is also usually what

25     civilians would usually consider.

Page 24981

 1             The next bullet point deals with military police organs, which

 2     also is -- seems not to be very relevant for civilians.

 3             So in every bullet point, I find references to misbehaviour in a

 4     military situation.  So therefore that surprises me that you say that

 5     this is a report which goes broader and also covers civilian abuse and

 6     civilian misbehaviour.  If you have any comment on it, please give it.

 7     If not, then --

 8             THE WITNESS: [Interpretation] Yes.  I told you just a while ago

 9     that this was the first meeting of this kind which covered the period

10     from the moment the conflict broke out in that territory to that meeting.

11     It was not the military who stole cars from Vogosca and that's why I

12     thought that this description refers to a wider range of people, not just

13     members of the military.

14             JUDGE ORIE:  In this paragraph, Vogosca is not even mentioned.

15     Thank you.

16             Any further questions, Mr. Stojanovic?

17             MR. STOJANOVIC: [Interpretation] Just one more topic.

18        Q.   Mr. Dunjic, will you tell the Trial Chamber whether, when you

19     discharged duties as the brigade commander, did you receive any

20     instructions with regard to the treatment of humanitarian convoys on

21     route to Sarajevo?

22        A.   Yes.  At another meeting, I received conclusions from a meeting,

23     actually.

24        Q.   Can you tell the Trial Chamber something about those conclusions?

25        A.   Those conclusions were as follows:  As far as I can remember,

Page 24982

 1     those convoys had to be led through.  They had to be checked.  And

 2     members of UNPROFOR were supposed to be treated correctly.

 3             In keeping with that order, I issued my own order and dispatched

 4     it to my subordinate units.  I quoted the conclusions from that

 5     instruction that I received from my superior command; i.e., they were to

 6     treat UNPROFOR members fairly and correctly without any demonstration of

 7     hostility.

 8             MR. STOJANOVIC: [Interpretation] Now I would like to call up

 9     65 ter 14744.  14744.

10        Q.   I would kindly ask you, Mr. Dunjic, to look at the document.  It

11     is dated 29 November 1992 in Blazuj.  You can see that your name is

12     printed and that the document was signed on your behalf by somebody whose

13     signature is illegible.

14        A.   I can't read it either.

15        Q.   And it says here that you, as the brigade commander, order the

16     implementation of conclusions and tasks reached at the meeting on the

17     17th November 1992 regarding the military situation and military

18     behaviour.  I am asking you whether you had in mind this document when

19     you answered your previous question.

20        A.   Yes.

21        Q.   Further on, you say that the behaviour of members of your units -

22     i.e., your subordinates - vis-à-vis UNPROFOR should be regulated

23     according to the documents which is referred to herein.  And you say

24     under 4 that disciplinary measures should be taken including criminal

25     responsibility for all mistreatment of UNPROFOR.  And if they show

Page 24983

 1     ill-treatment towards our members of the military, that should be

 2     reported to our command.  Did you have such situations?

 3        A.   Yes.

 4        Q.   And is this order of yours precisely the result of the

 5     conclusions of the advisory meeting?

 6        A.   Yes.

 7        Q.   And I'm going to end with this question:  At the advisory

 8     meeting, was anybody present from the Main Staff of the Army of Republika

 9     Srpska who would talk about it?

10        A.   It was General Mladic and General Tolimir.  They were there.

11     General Mladic particularly drew attention, if I remember correctly, to

12     this attitude or position towards members of UNPROFOR.

13        Q.   Could you please tell the Court according to your best

14     recollection what exactly General Mladic said?

15        A.   Well, the conclusions were precisely to behave professionally and

16     in a fair way towards UNPROFOR members, not to permit the passage of

17     weapons and ammunition in the area of responsibility of the units, but

18     humanitarian aid, food and everything else had to be allowed to pass

19     through without any problems regardless of whether it was in -- whether

20     this was to Sarajevo.  And as I mentioned, there was over 10.000

21     civilians who went through my area of responsibility from Sarajevo to

22     Kiseljak.  There were both citizens of Muslim and Croat ethnicity.  So we

23     did heed the orders of our general and we acted accordingly.

24        Q.   Thank you, Mr. Dunjic.

25             MR. STOJANOVIC: [Interpretation] Your Honours, I would like to

Page 24984

 1     tender this document also.  This is 65 ter document 14744.

 2             MR. JEREMY:  No objection, Your Honours.

 3             JUDGE ORIE:  Madam Registrar, the number would be.

 4             THE REGISTRAR:  Document 14744 receives number D607, Your

 5     Honours.

 6             JUDGE ORIE:  And is admitted into evidence.

 7             MR. STOJANOVIC: [Interpretation] Your Honours, that would be

 8     everything that I had for this witness.

 9        Q.   Mr. Dunjic, thank you very much.

10             JUDGE ORIE:  Yes.

11             Mr. Stojanovic, this document refers to a document dated the

12     17th of November, and this document also refers to a -- what seems to be

13     the conclusions of a consultive meeting.  Now, I think we have had a look

14     at the minutes of a meeting which took place on the 15th of November.  Is

15     the 17th of November document, is that available to any party?  Because

16     it would create -- if it is about the same meeting, it would create a

17     link between a meeting on the 15th, conclusions apparently put on paper

18     on the 17th, and now the issuance of orders on the 29th but related to

19     the conclusions reached or put on paper on the 17th of November.  Is that

20     document anywhere available?

21             MR. JEREMY:  Your Honours, I will check that and I'll report back

22     to the Trial Chamber.

23             JUDGE ORIE:  Yes.  We are about to be at the conclusion of the

24     testimony of this witness.  Could an urgent search been done immediately?

25             Or, Mr. Stojanovic, you've used this document.  Perhaps you are

Page 24985

 1     aware of the document of the 17th of November.

 2             Meanwhile, while you're working on it I would have one question

 3     to the witness.

 4             Witness, what was the misbehaviour or the shortcomings in the

 5     attitude of -- towards UNPROFOR members?  Could you tell us what had

 6     happened which triggered you to remind them that they should behave

 7     properly?

 8             THE WITNESS: [Interpretation] At one time, we are talking about

 9     the Movtas Koras [phoen] facility that links Ilidza with Hadzici, at one

10     of the check-points there, which was held by the public security service

11     - I'm thinking about the Ministry of the Interior - two soldiers came

12     from some special unit from Ilijas.  They stopped the convoy.  It was a

13     mixed convoy -- actually, it was a French convoy that was entering

14     Sarajevo.  They were drunk, armed, and they verbally abused those who

15     were in the convoy.

16             Immediately upon finding out, I came to the location and with a

17     special police unit, I -- maybe I made a mistake when I said they were

18     from Vogosca.  They were from Ilijas.  So we took those two members of

19     the army from that place and then immediately after that in light of the

20     advisory meeting and the conclusions I drafted this document.

21             JUDGE ORIE:  Of what unit were these two members?

22             THE WITNESS: [Interpretation] They were from the Ilijas Brigade.

23             JUDGE ORIE:  Now, the Savo Derikonja 1st Volunteer Detachment was

24     a unit of what brigade?

25             THE WITNESS: [Interpretation] It belonged to the Igman Brigade.

Page 24986

 1             JUDGE ORIE:  Because this order is directly addressed to this

 2     volunteer detachment, not to any unit of the Ilijas Brigade, so I have

 3     some difficulties in reconciling the reason why you said you issued this

 4     order, something that happened in the Ilijas Brigade, but you address a

 5     specific detachment - a volunteer detachment - in the Igman Brigade.  Do

 6     you have any explanation for that?

 7             THE WITNESS: [Interpretation] I do.  Yes, I do.  These orders,

 8     you can see in the right-hand corner it says: "To the command 1st

 9     volunteer detachment Savo Derikonja," that was the name of the unit.  The

10     order was sent to all of my units.  I don't know why the other orders are

11     not mentioned there, to the Rajlovac command, to the Rakovac Battalion

12     command, to the command of the Blazuj Battalion, and the command of the

13     Hadzici Battalion.  So this order was not sent just to them but to all

14     the units in my brigade in order to prevent what happened from happening

15     again.

16             JUDGE ORIE:  Yes, if I look at the left bottom of this document,

17     it is listed to whom this order was sent, isn't it?

18             THE WITNESS: [Interpretation] Yes.

19             JUDGE ORIE:  Are these all the units in your brigade?

20             THE WITNESS: [Interpretation] This is the battalion command, 1 to

21     4, SSJB Ilidza, Hadzici, correct.  Not to my brigade but they were at the

22     check-points where the convoys passed, to the military police to my

23     brigade, the Savo Derikonja Volunteer Detachment from my brigade, and the

24     command of the military police.

25             JUDGE ORIE:  Yes.  Now the volunteer detachment is specifically

Page 24987

 1     mentioned.  Did they have a special position within your brigade?

 2     Because they are not just subordinated to one of the battalion commands

 3     or any of the other units mentioned here.

 4             THE WITNESS: [Interpretation] The brigade, by establishment,

 5     consists of battalions.

 6             THE INTERPRETER:  Could the witness please repeat what he's

 7     saying?

 8             JUDGE ORIE:  Could you please repeat what you said.  You started

 9     by saying that a brigade consists of battalions.  Could you tell us what

10     you then said.

11             THE WITNESS: [Interpretation] By establishment that was in force

12     at the time, a brigade can also encompass detachments which are smaller

13     than battalions but are of equal rank as the battalion.  They are also

14     subordinated to the brigade command and not to the command of a

15     battalion.

16             JUDGE ORIE:  Yes.  So this order to the -- this volunteer

17     detachment has got nothing to do with what was discussed at the

18     15th of November and was not the subject of the 17th of November

19     conclusions that were sent to you.  Is that how I have to understand it?

20             THE WITNESS: [Interpretation] Yes.

21             JUDGE ORIE:  Has any of the parties been able to identify and

22     locate the 17th of November decision -- or conclusions, perhaps I should

23     say.

24             MR. WEBER:  Your Honours, it appears that we are able to identify

25     it.  I do not see it currently uploaded in the e-court system.  It does

Page 24988

 1     appear that we do have a translation for it, too, under ERN 05289502 to

 2     059289505.

 3             JUDGE ORIE:  Could we have a look at it?  Is that a possibility.

 4             MR. JEREMY:  Yes, Your Honours, we can show the English

 5     translation on Sanction now.

 6             JUDGE ORIE:  If we could do so, please, if we could have a look

 7     at it, especially item 5.

 8             Yes.  Could we go to the previous parts of it so that we have an

 9     opportunity to scan through it.  First page, please.  Could we further

10     scroll down.  It apparently is related to the 15th of November

11     consultation meeting.  Could we scroll further down, if my colleagues

12     are -- could we scroll further down.  Could we scroll further down.

13     Could we scroll further down.  Could we scroll further down.  Could we

14     scroll further down.  Perhaps just a bit up at the beginning of

15     paragraph 3.  Could we scroll further down.  Could we scroll further

16     down.  And the last page, please.  And further down.

17             This apparently is a document which is in between the meeting and

18     preceding the further instructions given by this witness.

19             We have seen this one document in which you complement the

20     instruction given under number 5, that is to be kind to UNPROFOR.  Did

21     you give any further instructions on the basis of this document such as

22     action to be taken against thefts or looting or criminal behavior?  Did

23     you issue any orders in that respect?

24             THE WITNESS: [Interpretation] I issued the order in accordance

25     with the conclusions of the advisory meeting regarding members of

Page 24989

 1     UNPROFOR.  I did not issue orders regarding the looting, because it was

 2     not necessary.  In the AOR of my brigade there were no such cases.

 3             JUDGE ORIE:  Yes.  But if I understood you well, there were no

 4     such cases of unpleasant behaviour towards UNPROFOR within your brigade

 5     either, because you said it was triggered by something that happened in

 6     the Ilijas Brigade not the Igman Brigade.

 7             THE WITNESS: [Interpretation] You misunderstood me.  This was

 8     committed by members of the Ilijas Brigade in the area of responsibility

 9     of my brigade.  Two of them did it.  They were at the Mostar crossroads,

10     which is in the area of responsibility of my brigade.

11             JUDGE ORIE:  Yes, but they were not members of your brigade.

12             I leave it to the parties whether they want to further deal with

13     this document, yes or no.

14             No further questions, Mr. Jeremy?

15             MR. JEREMY:  Your Honours, could we tender that document that's

16     now been uploaded, 65 ter 31172 -- oh, it will be.  It will have that

17     number.  It's actually not in e-court yet.  I think for the context of

18     these discussions it makes sense to tender it.

19             JUDGE ORIE:  Any objection to the tendering of this document?

20             MR. STOJANOVIC: [Interpretation] We have no objection that it be

21     tendered at presently for identification only until we receive the

22     official translation.

23             JUDGE ORIE:  Yes.  Madam Registrar, could you already reserve a

24     number for this document.

25             THE REGISTRAR:  Document that will be uploaded as 65 ter 31172

Page 24990

 1     receives reserved number P6708, Your Honours.

 2             JUDGE ORIE:  Yes.  And once it's uploaded, it will be marked for

 3     identification so that the Defence has a further opportunity to look at

 4     the original.

 5             No further questions?

 6             MR. JEREMY:  No further questions, Your Honour.

 7             JUDGE ORIE:  No further questions.  No further questions from the

 8     Bench, either.

 9             Mr. Dunjic, this concludes your testimony in this Court.  I would

10     like to thank you very much for coming to The Hague, it's a long way, and

11     for having answered the many questions that were put to you by the

12     parties and by the Bench and I wish you a safe return home again.  You

13     may --                          

14             THE WITNESS: [Interpretation] I would like to thank the Trial

15     Chamber for having allowed me to testify on behalf of the Defence of the

16     great Serbian hero --

17             JUDGE ORIE:  No, no.

18             THE WITNESS: [Interpretation] -- General Ratko Mladic.  Thank you

19     very much.

20             JUDGE ORIE:  No propaganda here.  We have -- you are a witness.

21     Mr. Mladic is in the courtroom and appears as an accused in this case.

22     That is the situation at present.  And your last expression of your

23     feelings about the accused is part of the record of this trial and will

24     be considered as every other word of your testimony by this Chamber.

25             You may follow the usher.

Page 24991

 1                           [The witness withdrew]

 2             JUDGE ORIE:  Mr. Jeremy.

 3             MR. JEREMY:  Your Honours, just to confirm that 65 ter 31172 is

 4     now in e-court, so I'd invite Mr. Stojanovic to check the translation and

 5     report back --

 6             JUDGE ORIE:  Yes.

 7             MR. JEREMY:  -- to the Chamber.

 8             JUDGE ORIE:  Therefore it's marked for identification under

 9     number P6708.

10             MR. JEREMY:  Yeah.  Thank you.

11             JUDGE ORIE:  We -- since there is no other witness at this

12     moment, we --

13                           [Trial Chamber confers]

14             JUDGE ORIE:  At least, Mr. Stojanovic, that's how we understood

15     your explanation for the present situation, that the Defence is not in a

16     position at this moment to call its next witness.  For that reason, we'll

17     adjourn for the day and we will resume on Monday the 1st of September

18     2014, 9.30 in the morning, hopefully in Courtroom I, but if not in a

19     courtroom to be further announced.  We stand adjourned.

20                 --- Whereupon the hearing adjourned at 1.33 p.m.,

21                  to be reconvened on Monday, the 1st day

22                  of September, 2014, at 9.30 a.m.