Tribunal Criminal Tribunal for the Former Yugoslavia

Page 25249

 1                           Thursday, 4 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.29 a.m.

 5             JUDGE ORIE:  Good morning to everyone in and around this

 6     courtroom.

 7             Madam Registrar, would you please call the case.

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

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

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             No preliminaries.  Could the witness be escorted into the

12     courtroom.

13                           [The witness entered court]

14             JUDGE ORIE:  Good morning, Mr. Glogovac.  Before you give

15     evidence, the Rules require you to make a solemn declaration.  May I

16     invite you to make that declaration, of which the text is now handed out

17     to you.

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

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

20                           WITNESS: RADOVAN GLOGOVAC

21                           [Witness answered through interpretation]

22             JUDGE ORIE:  Thank you.  Please be seated.

23             You'll first be examined by Mr. Stojanovic.  You'll find him to

24     your left.  Mr. Stojanovic is counsel for Mr. Mladic.

25             You may proceed, Mr. Stojanovic.

Page 25250

 1             MR. STOJANOVIC: [Interpretation] Good morning, Your Honours.

 2                           Examination by Mr. Stojanovic:

 3        Q.   [Interpretation] Witness, good morning.

 4        A.   Good morning.

 5        Q.   I would like to ask you to speak your name as slowly as possible

 6     for the transcript.

 7        A.   My name is Radovan Glogovac.

 8        Q.   Mr. Glogovac, at any point in time did you provide a statement to

 9     the Defence of General Mladic, a written statement?

10        A.   Yes, I did.

11             MR. STOJANOVIC: [Interpretation] Your Honours, could we please

12     look at document 1D01687 in e-court, please.

13        Q.   Mr. Glogovac, this is the first time you're appearing before this

14     Tribunal; is that correct?

15        A.   Yes.

16        Q.   We will go more slowly.  Could you please look at the screen in

17     front of you and there you see your statement.  And my question will be:

18     Is this your information, are these your particulars, and is that your

19     signature on this page?

20        A.   Yes, it is my signature and the data is correct.

21        Q.   Thank you.

22             MR. STOJANOVIC: [Interpretation] Could we now look at the last

23     page of the document, please.

24        Q.   Mr. Glogovac, is this your signature on this page and is the date

25     that is written there written by your hand?

Page 25251

 1        A.   Yes, the signature and the date are in my handwriting.

 2        Q.   Thank you.  When we were preparing for you to appear before the

 3     Tribunal today, did you point out three errors in the information in this

 4     statement?

 5        A.   Yes, that is correct.

 6             MR. STOJANOVIC: [Interpretation] Your Honours, with your leave I

 7     would just like us to look at paragraph 1 of the statement, line 2.

 8        Q.   Where it states:

 9             "At the faculty of economics in Subotica ..."

10             Does it not -- is what is omitted here that "studied" -- the word

11     "studied at the faculty of economics in Subotica"?

12        A.   Yes, that is correct.

13             MR. STOJANOVIC: [Interpretation] Could we now look at paragraph

14     21 of the statement, please.

15        Q.   In paragraph 21, line 2, you indicated the following words:

16     "Dr. Stamenkovic was killed in Zepca."  Should the person's last name be

17     different?

18        A.   Yes, it should be Dr. Vaskovic, Dr. Djordje Vaskovic.  It was my

19     error.

20             MR. STOJANOVIC: [Interpretation] Your Honours, for the transcript

21     I see line 17, page 3, where it says -- ah, it's been corrected.  All

22     right.  Thank you so much.  Dr. Djordje Vaskovic.

23        Q.   In lines 5 and 6 of paragraph 21 of the statement in the B/C/S

24     version, there is the words:  "Fire was opened on a vehicle of a Serb,

25     Obrenovic, a Heckler weapon," and then it says:  "That was when Milojevic

Page 25252

 1     was wounded."  Could you please tell us whether the last name of this

 2     person is Milovic or Milojevic?

 3        A.   His last name was Milovic.  Actually I'm related to him on my

 4     mother's side and I knew him quite well.

 5        Q.   Thank you.  And now today when you made these three corrections

 6     in your statement, if I -- after you made the corrections, now, if I were

 7     to put the same questions to you that I put to you in the statement,

 8     would your answers be identical to the ones you gave in your written

 9     statement?

10        A.   Yes, except there is a mistake.  I had said that the number of

11     Serbs in Zenica was 27.000 but actually the exact number is 22.433.

12     That's the exact number.  It was an error during some talks that we had,

13     so we -- we included others who did not declare themselves as Serbs,

14     about 5.000 of them, so this is what the error was about.

15             MR. STOJANOVIC: [Interpretation] Your Honours, could we now

16     please look at paragraph 5 of the witness statement.  Paragraph 6.

17     Paragraph 6 of the witness statement.

18        Q.   Mr. Glogovac, you said here that about 27.000 Serbs lived there

19     before the war.  Today you're making a correction and you're saying that

20     the number is -- could you please repeat it for the transcript?

21        A.   The official information according to the consensus was 22.433

22     Serbs.  This is the actual figure.  When I was dealing with those figures

23     in negotiations, we included about 15.000 Yugoslavs all together, so we

24     split that figure giving 5.000 to Serbs, 5.000 to Croats, and 5.000 to

25     Muslims, and this is what this mistake is.

Page 25253

 1        Q.   Thank you.  Now that you have clarified this, I'm putting the

 2     question to you again:  Taking into account the three corrections, today,

 3     after you have given the solemn declaration, would you stand by the

 4     answers that you provided in your written statement?

 5        A.   Yes, I would.

 6        Q.   Thank you.

 7             MR. STOJANOVIC: [Interpretation] Your Honours, I would like to

 8     tender the witness statement of Witness Radovan Glogovac, and that would

 9     be number 1D01687.

10             MR. TRALDI:  No objection, Mr. President.  I don't object in this

11     case.  But just to lay down a marker, corrections like that, that are

12     made beforehand, we would normally expect to receive some notice of and I

13     haven't in this instance.  In this case we don't consider ourselves

14     prejudiced and so we don't object.

15             JUDGE ORIE:  Thank you.

16             Madam Registrar.

17             THE REGISTRAR:  Document 1D1687 receives number D619, Your

18     Honours.

19             JUDGE ORIE:  And is admitted into evidence.

20             MR. STOJANOVIC: [Interpretation] By your leave, Your Honours, I

21     would like to read the summary of Mr. Radovan Glogovac's statement now.

22             JUDGE ORIE:  Please do so.

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

24             Witness Radovan Glogovac, together with his family, in 1992 lived

25     and worked in Zenica where he was also politically engaged in duties of

Page 25254

 1     the vice-president of the local SDS party.  He took part in numerous

 2     negotiations between the political leadership of the Muslims, Serbs, and

 3     Croats with the objective of calming political and interethnic tensions

 4     in that area already after the war broke out in Croatia.

 5             He will testify about the attitude towards Serb cadres in the

 6     municipality, about deterioration of interethnic relations, and the Serbs

 7     escaping from this region.  Some left on their own; others were expelled,

 8     arrested, and held captured in the correctional facility of Zenica, some

 9     4- to 500 of them, or some were killed.  He will speak about the

10     blockades and attacks on JNA barracks, about pulling out the men and

11     equipment from Zenica, and about the departure of the Serb civilian

12     population from this area after the JNA left Zenica on the 18th of May

13     1992.

14             During that time-period several attacks on Serb villages occurred

15     starting from the 11th of May 1992.  There was an attack on the village

16     of Svice.  There were a number of killings of Serbs in the Zenica area.

17     The Mujahedin came to these areas which caused even more insecurity among

18     the Serb population.

19             After leaving Zenica on the 7th of June 1992, he got a job at the

20     government of Republika Srpska as an associate, and he worked on

21     population exchanges as member of the commission for the exchange of

22     persons in the territory of central Bosnia.  He participated in several

23     negotiations with the opposing sides about organising exchanges, and is a

24     direct participant of a number of implemented exchanges.

25             He will talk specifically about his role and the assignments

Page 25255

 1     which he was given from Minister Ostojic in the process of bringing out

 2     the Croatian population over Mount Vlasic towards Croatia.  They were

 3     instructed to receive the population and take care of them in a

 4     professional manner.  He was in contact with the local commander, Janko

 5     Trivic, about the implementation of this assignment, and he had the

 6     opportunity to see a dispatch by the VRS Main Staff on the arrival of

 7     Croats from Central Bosnia.

 8             HVO soldiers that came to RS territory with the civilian

 9     population handed over their weapons, and when they left the area the

10     weapons were returned to them and the civilian population continued on

11     their way towards Gradiska and Okucani.

12             This is a short summary of the witness's statement.  And by your

13     leave, Your Honours, I would just like to put a few questions to the

14     witness now.

15             JUDGE ORIE:  Please proceed as you suggested.

16             MR. STOJANOVIC: [Interpretation] Could we please look at

17     paragraph 7 of the statement, which now has the number -- actually, I

18     didn't manage to write down the exact -- the correct number, but --

19             JUDGE FLUEGGE:  D -- it is --

20             MR. STOJANOVIC: [Interpretation] -- for the transcript --

21             JUDGE FLUEGGE:  It is D619.

22             MR. STOJANOVIC: [Interpretation] D619.  Thank you very much, Your

23     Honour.  So let's look at D619, paragraph 7, please.

24        Q.   Mr. Glogovac, when you described your role in these difficult

25     times - we're talking about paragraph 7 now - you spoke about specific

Page 25256

 1     assignments that you had in negotiations with the Muslim side.  Since you

 2     were the vice-president of the SDS, how did it come about for you to find

 3     yourself in the middle of all of these negotiations about the exchanges?

 4        A.   During the elections in the Serbian Democratic Party in Zenica,

 5     Dr. Slobodanka Hrvacanin was elected president, and I was elected

 6     vice-president.  As the tensions grew in Zenica, we were informed that

 7     they were preparing to liquidate her.  The information came from very

 8     high-up figures in the police.  They said that she could not be

 9     protected.  She left Zenica and went to Banja Luka with her family.  I

10     confirm this.  And then after she tried to move her things out from her

11     flat in Zenica, a truck came and then there was a conflict between our

12     workers that we had sent to load her things and some local strongmen.

13             This was one of the first interethnic conflicts, actually.  You

14     could say that.  So she had to leave Zenica because we could not provide

15     security for her.  According to the statute, I took over all of her

16     duties.

17             MR. STOJANOVIC: [Interpretation] Could we look at paragraph 13

18     now, please.

19        Q.   This is your statement, D619.  This is where you say that the

20     Muslim authorities did not allow the Serbs to leave Zenica.  So I am

21     asking you why did the authorities in Zenica act in this way?

22        A.   Well, I believe that the first reason was because they wanted to

23     present the situation in Zenica as being a multiethnic one.  Even though

24     a lot of Serbs had left Zenica, they put up blockades on the road from

25     Zenica towards Doboj so that buses were not able to leave.  I thought

Page 25257

 1     about what the second reason could be, and that was that we were some

 2     sort of human shields.  So the propaganda in Zenica was such that they

 3     were saying that Serbs were expected to enter the town of Zenica from all

 4     sides and so on and so forth.

 5        Q.   Thank you.

 6             MR. STOJANOVIC: [Interpretation] Can we look at paragraphs 20 --

 7     paragraph 25 of your statement.

 8        Q.   There you describe negotiations on one occasion with the

 9     authorities in Zenica, in Bosnia and Herzegovina, and you talk about how

10     they offered you that you should surrender the area of Zenica to the VRS

11     so that armed hostilities would cease.  Could you please tell the Court

12     what happened?  How did this come about?

13        A.   There was a meeting in Turbe, near Travnik, and to my surprise,

14     for the first time we managed to speak with the representatives from

15     Zenica in a normal way.  We managed to exchange a number of civilians,

16     arrange humanitarian aid, and that was where they presented to me an

17     old-fashioned instrument, gusla, and that made me feel that they

18     appreciated my work.

19             After searching my apartment, they brought that from my apartment

20     and they gave me that musical instrument.  They allowed 1500 Serbs to

21     leave Zenica.  So --

22             THE INTERPRETER:  Could the witness please be asked to slow down.

23             JUDGE ORIE:  Witness, could you please slow down.  Perhaps you

24     resume.  You said:

25             "After searching my apartment, they brought that from my

Page 25258

 1     apartment and they gave me that musical instrument."

 2             Could you resume from there?  You said, "They allowed ..."  and

 3     then continue from there.

 4             THE WITNESS: [Interpretation] I apologise, Your Honours, but I

 5     don't have much experience in testifying like this.  I will try to speak

 6     as slowly as possible.

 7             So they did give me the instrument.  They allowed people to

 8     leave.  They decided to permit 1500 Serbs from leaving Zenica.  They

 9     proposed that the part that they were controlling, that they would lay

10     down their weapons in that area, that there would be no war.  They didn't

11     mean that forces of Republika Srpska should enter that part and control

12     Zenica.  They just meant that there would be a suspension of combat and

13     that we could arrange through the bar port to ship large quantities of

14     aid from the United States which would meet everybody's needs.

15             So I was really very satisfied.  And there was a Professor Dokic

16     who was also participating in the negotiations, replied from our side

17     that we gladly accept that.  And if they were able to guarantee that

18     there would be no fighting and that the extremist groups in that area,

19     the Mujahedin and so on, would surrender their weapons, and that this

20     whole area would become a peaceful area.

21             MR. STOJANOVIC: [Interpretation]

22        Q.   I would appreciate it if you would answer briefly.  I see your

23     answer to this next question in this paragraph, but what, according to

24     you, is the reason why the Muslims changed their position in December

25     1993?

Page 25259

 1        A.   They had fierce clashes with Croats in western Bosnia at that

 2     time.  They claimed they were receiving aid through Luka and Ploce, et

 3     cetera, and they claim that the Croats skimmed 50 per cent off that

 4     because those were Croat ports.  And that's why they wanted to restore

 5     some peace with the Serbs, not to wage war anymore.  I asked them how

 6     they meant to do this in view of their government in Sarajevo.  They

 7     said, "We don't care.  We just don't want to be at war anymore."

 8        Q.   Thank you.  Could we look at paragraph 36 of your statement,

 9     please.  In this paragraph you described your participation in the

10     process of dislocating the Croat civilians and military.  Could you just

11     tell the Court, very briefly, what your role and tasks were in this

12     process?

13        A.   At that time I was working at the office of Minister

14     Velibor Ostojic, who was then a minister without portfolio, and deputy

15     vice -- deputy prime minister, and he told me to urgently report to

16     military authorities in Banja Luka and in Vlasic to see how they would

17     receive a large number of Croat refugees in the area of Vlasic and partly

18     in Donji Vakuf and via Kupres.  My task was to report on a daily basis

19     what is needed - fuel, buses, et cetera.

20             I went to the command of the 1st Krajina Corps and they told me

21     to go see the commander at Mount Vlasic.  I believe it was the 22nd

22     Brigade.  I had to see Lieutenant-Colonel Janko Trivic, whom I didn't

23     know.  Trivic received me, showed me an order of the Main Staff, and I

24     saw that the orders were made to supply [Realtime transcript ready in

25     error "shares"] chairs for Croat officers, everything according to Geneva

Page 25260

 1     Conventions.

 2             I was present several times when groups departed.  Buses were

 3     waiting for civilians to take them to Gradiska, to Novska.  The

 4     able-bodied military-aged men were, of course, routed differently and

 5     taken away in different directions.

 6        Q.   Did you, as representative of the civilian authorities of

 7     Republika Srpska, or Mr. Trivic as the representative of military

 8     authorities, at any point have any instructions for unlawful treatment of

 9     this population?  Did you have instructions to hinder their passage

10     through Republika Srpska or anything like that?

11        A.   No.  Emphatically no.  Neither Mr. Trivic nor I had any such

12     instructions.  On the contrary, with all the problems that I had to deal

13     with, I had to report to the Deputy Prime Minister, Velibor Ostojic, if

14     anything was not going well.  I had instructions that if I encountered

15     any problems, I had to report to Ostojic.

16        Q.   Thank you.

17             MR. STOJANOVIC: [Interpretation] Your Honours, I would only like

18     to tender one accompanying exhibit, 1D03712, one associated exhibit.  And

19     that would be the conclusion of my direct examination.

20             JUDGE ORIE:  Thank you, Mr. Stojanovic.

21             Any objections?  No objections.

22             Madam Registrar.

23             THE REGISTRAR:  Document 1D3712 receives number D620, Your

24     Honours.

25             JUDGE ORIE:  And is admitted into evidence.

Page 25261

 1             Before I invite the Prosecution to cross-examine the witness, I

 2     would have two questions.

 3             You said you saw orders.  "The orders were made to supply shares

 4     for Croat officers."  What did you mean exactly with "to supply shares"?

 5     Was it chairs?  Yes.  Yes, then perhaps it -- on the transcript we read

 6     "shares," but "supplying chairs in line with the Geneva Conventions," is

 7     that -- I was just wondering what exactly you meant by that or to what

 8     extent that is covered by any legal instrument.

 9             THE WITNESS: [Interpretation] No, Your Honours, that's not

10     exactly what I said.  I said I had seen the order of General Mladic on

11     how to receive the refugees from Central Bosnia, and I wanted to clarify

12     that I saw Mr. Trivic, the commander, take all the measures to make sure

13     that everything was in keeping with Geneva Conventions.  And before me,

14     he gave orders to his subordinate officers on how to receive Croat

15     officers, to provide them with so many chairs and so much furniture in

16     the rooms where they would be accommodated.

17             JUDGE ORIE:  Yes.  Now does --

18             JUDGE MOLOTO:  That's not what the statement says.

19             JUDGE ORIE:  Let's have a look at the statement, then.  I was

20     looking at the transcript, as a matter of fact, but ...

21             Well, the statement in this respect leaves it open whether

22     specifically the chairs were mentioned in the order or whether the order

23     just said that they should be received in the humane and professional

24     manner.  I have no -- I don't want to further explore this.

25             There was another matter which I would like to ask you about,

Page 25262

 1     which is the following:  You said -- one second, please.  You said you

 2     were present several times when groups departed.  You're talking about

 3     buses waiting for civilians and where they were taken.  And then you

 4     said:  "The able-bodied military-aged men were, of course, routed

 5     differently and taken away in different directions."  Could you tell me

 6     why, of course, able-bodied military-aged men were routed differently?

 7             THE WITNESS: [Interpretation] Well, as far as I know there was an

 8     agreement with the Croatian side.  And when we were negotiating about

 9     those people with whom there were no problems, civilians, et cetera, they

10     could immediately depart via Gradiska and Novska, whereas the others, as

11     agreed with the Croatian side, would be allowed to depart after we ran

12     certain checks because we had information that there were among them war

13     criminals.  Especially in the area of Jajce there had been heinous war

14     crimes.  And after these checks, they were allowed to depart after only a

15     brief delay.

16             JUDGE ORIE:  Did you find any war criminals during those checks?

17             THE WITNESS: [Interpretation] As far as I know, we did not and

18     nobody was kept.  Nobody was held back.

19             JUDGE ORIE:  Thank you for those answers.

20             You'll now be cross-examined by Mr. Traldi.  You'll find

21     Mr. Traldi to your right.  Mr. Traldi is counsel for the Prosecution.

22             Mr. Traldi, you may proceed.

23             MR. TRALDI:  Thank you, Mr. President.  And good morning.

24                           Cross-examination by Mr. Traldi:

25        Q.   Good morning, sir.

Page 25263

 1        A.   Good morning.

 2        Q.   And to pick up where the Presiding Judge just left off, do you

 3     know where those checks for war criminals were conducted?

 4        A.   I cannot say with any certainty at which location, but as far as

 5     I know -- I mean, I don't really know where the checks were carried out.

 6     I know that some military-aged men were kept at Manjaca for a short time

 7     and after that they were sent off to the so-called Herceg Bosna as it was

 8     known at the time.

 9        Q.   I'll leave that topic now and I want to turn back to 1992 --

10             JUDGE ORIE:  Mr. Traldi, I nevertheless would have one question.

11             If you said they were kept at Manjaca for a short time, what do

12     you mean by "a short time"?  One or two days, one or two weeks, or one or

13     two months, or six months?  What is "a short time" for you?

14             THE WITNESS: [Interpretation] Up to six days.  That's what I mean

15     by "short time."

16             JUDGE ORIE:  And how do you know that, that they were released

17     after six days?

18             THE WITNESS: [Interpretation] I made inquiries through some

19     commanders and they answered whenever I asked that one group had left,

20     then another group had left, and later on I found out that there was

21     nobody left at Manjaca.  In fact, Herceg Bosna and their representatives

22     were in constant contact with us on this matter and they took over their

23     own people -- I mean, they were constantly in touch with our military

24     authorities.

25             JUDGE ORIE:  This Chamber has received quite some evidence about

Page 25264

 1     what happened in Manjaca.  I just think it's fair that the overall

 2     impression was not people arrived there and could leave within a couple

 3     of days.  The overall impression was quite different from that, just for

 4     you to know and to give you an opportunity to comment on that.

 5             THE WITNESS: [Interpretation] Your Honours, I know about Manjaca,

 6     but these men did not receive that kind of treatment.  Their treatment

 7     was completely different because we could find no other place in

 8     Banja Luka where such a number of men could be placed.  We couldn't find

 9     such premises within the city.

10             JUDGE ORIE:  When do you --

11             THE WITNESS: [Interpretation] And if I may add --

12             JUDGE ORIE:  Well, when you say these men did not receive that

13     kind of treatment, what do you mean by "that kind of treatment"?

14             THE WITNESS: [Interpretation] I mean they were not treated as

15     prisoners of war.  They were treated as civilians.

16             JUDGE ORIE:  You mean to say that those that were kept in Manjaca

17     were treated as civilians?

18             THE WITNESS: [Interpretation] Yes, yes.  I mean, specifically

19     these men.

20             JUDGE ORIE:  Please proceed.

21             MR. TRALDI:

22        Q.   Sir, a couple of brief questions to follow up on that.  First,

23     when you distinguish between this group and those that received what you

24     call "that kind of treatment," are you speaking in the latter category of

25     persons who were held at Manjaca in 1992 before it was first closed?

Page 25265

 1        A.   Could you please repeat that question?

 2        Q.   Sure.  You said:

 3             "I know about Manjaca, but these men did not receive that kind of

 4     treatment.  Their treatment was completely different."

 5             You mean their treatment was completely different than other

 6     persons who had at some point been held at Manjaca; right?

 7        A.   I know about Manjaca, what I read in the papers, and I know these

 8     men were not treated as prisoners of war.  So they had the freedom to go

 9     out and move around within certain limits, and they departed, left the

10     area completely after a short while.

11             Now, what the treatment at Manjaca really was, I don't know

12     because when I came there the Manjaca camp had already been closed down.

13     And I protested, I remember, before President Karadzic that Manjaca had

14     been closed, whereas the Serbs were still being held at Zenica.  That's

15     all I know, actually.  All I know about it is from media reports and

16     certain meetings with the opposite side at negotiations.

17        Q.   What you'd read and heard from the opposite side at negotiations

18     was that before it closed the people there were abused and some were

19     killed; right?

20        A.   I cannot maintain that with any certainty.

21        Q.   Sir, I --

22        A.   I -- I heard some witness testimony here --

23        Q.   I'm not asking you about whether you personally know whether it

24     happened, and I think that's what you're answering.  I'm asking you what

25     you read and what you heard, is it that people there were abused --

Page 25266

 1     people who were detained there were abused, and some were killed, whether

 2     or not you have any personal knowledge?

 3        A.   It's true that happened and I cannot deny any of that.  It's a

 4     fact that these things have happened.

 5        Q.   Do you remember the first time, roughly, what month, what year,

 6     that you read or heard of those allegations?

 7        A.   I cannot remember the exact month, but it was certainly 1992 at

 8     my first meetings with these people.  At that time I didn't believe these

 9     stories until some evidence began to be led before courts, because I

10     didn't really believe stories.  I knew that reports were manipulated, et

11     cetera, but I do believe what the court has established.

12             I cannot say when exactly the first time was that I heard of

13     Manjaca, but I was in Banja Luka beginning with September 1992.  I don't

14     know exactly when Mr. Karadzic disbanded that camp, but at that time a

15     large number of Serbs were still held at Zenica, and I protested and

16     others protested very vocally, very strenuously, that Manjaca had been

17     closed down while Serbs were still being held at Zenica because I was

18     aware of what was going on there.

19        Q.   With that, sir, I will turn back to early 1992.  Now, you

20     mentioned on direct examination that Slobodanka Hrvacanin was the

21     president of the SDS in Zenica.  She was also a member of the SDS Main

22     Board; correct?

23        A.   Yes, correct.

24        Q.   And among her functions, she would relay information from the SDS

25     at the republic level to you and the other members of the SDS in Zenica;

Page 25267

 1     correct?

 2        A.   Correct, while she was in Zenica.

 3        Q.   You mentioned during direct examination that she left and you

 4     became president of the SDS in Zenica.  When did that happen?

 5        A.   It was the beginning of 1992.  I can't remember the date.  I

 6     didn't become president.  I still held the elected post of

 7     vice-president, but I actually had the responsibilities of the president.

 8     But I was never officially elected president of the SDS.

 9        Q.   I appreciate your precision in explaining that, sir.  To achieve

10     a similar precision about your own career, I'm going to ask you about a

11     couple of the dates that you held the positions you mentioned on direct

12     examination.  You mentioned that you were an associate of

13     Minister Ostojic.  When did you begin working with Minister Ostojic, what

14     month and what year?

15        A.   I was appointed to the office of Minister Velibor Ostojic in the

16     beginning of 1993.

17        Q.   How long did you remain one of his associates?

18        A.   As long as Mr. Velibor Ostojic was deputy prime minister, which

19     was some time in 1994.

20        Q.   And when did you become president of the agency for the exchange

21     of property?

22        A.   In 1994.

23        Q.   That was a state agency; correct?

24        A.   The government established that agency, yes.

25        Q.   And to whom did you report about the work of that agency?

Page 25268

 1        A.   There was all sorts of monitoring and vetting by the state

 2     security, the police.  We wrote reports nonstop, sent them to the

 3     government, et cetera.

 4        Q.   Do you recall which ministry of the government you sent your

 5     reports to?

 6        A.   I think it was the ministry of Mr. Brdjanin while he was in

 7     power, and after that I sent my reports to the government.  Mr. Momir

 8     Jugic would come to see me as my contact.  He was working on a project of

 9     free movement of civilians.  He was a representative of the government,

10     and he came to me regularly.  So they were informed on a regular basis.

11     In practice you couldn't do anything much with these property swaps

12     because people dealt with it privately.  They would find each other,

13     agree on something, and then ...

14        Q.   You also mentioned you were appointed to the exchange commission.

15     When were you appointed to that commission?

16        A.   Right after becoming an associate of Minister Ostojic.  He and

17     President Karadzic addressed a letter to the commission - that is to say,

18     to Mr. Bokic - suggesting that I should be appointed to help out with

19     these exchanges of civilians and taking care of the accommodation for

20     refugees.  That was my main job while I was working for Minister Ostojic.

21     That position still exists.

22        Q.   Now --

23        A.   That [Realtime transcript read in error "fact"] fax still exists.

24        Q.   Now, there was a central exchange commission as well as regional

25     and municipal commissions; right?

Page 25269

 1        A.   Correct.

 2        Q.   Were you affiliated with the central commission or one of the

 3     regional or municipal commissions?

 4        A.   I had a connection with the central commission through

 5     Professor Janko Dokic, who was a member of that commission, and I worked

 6     exclusively with him.

 7             THE INTERPRETER:  Interpreter's note:  In line 21 on page 20, the

 8     word should be "fax," like "facsimile," not "fact."

 9             MR. TRALDI:

10        Q.   Now, the way the commission worked was that municipal commissions

11     had to submit lists of persons to be exchanged for approval from higher

12     level commissions; correct?

13        A.   In my case I was working on the commission concerning civilian

14     persons, and I can show the Court the document including from the

15     Croatian side.  I dealt only with civilians.  I didn't have to make any

16     lists except for the moment when they were crossing the separation line.

17     Then I would submit a list to the command of the regiment or the corps so

18     that they know that such and such a number of civilians would be crossing

19     the boundary from our side, and from the other side another number of

20     civilians would also be crossing the same line.  And then with

21     Professor Dokic, we would agree on a certain exchange.  But civilians, in

22     any case, whether the other side had kept their word or not, I always

23     released civilians to go wherever they wanted.

24        Q.   And you mention the different geographic areas and military

25     units - this is in paragraph 33 of your statement - had their own

Page 25270

 1     exchange commissions.  Your commission would co-operate with those

 2     military commissions; right?

 3        A.   We co-operated with the military commission in so far as we had

 4     to meet at the separation line.  They were always looking for prisoners

 5     of war.  Of course we co-operated.  We couldn't do without co-operation.

 6     We had many cases when the opposite side was looking for civilians, and

 7     through these commissions I was looking for those people -- looking for

 8     people who were willing to leave, et cetera.  It's just that I couldn't

 9     go myself to see all these people, visit all these people, to tell them,

10     "You know, your family from the other side is looking for you.  Do you

11     want to go or not?"  I had to do it through them.

12        Q.   Sir, I think you've gone a little bit beyond the scope of my

13     question, but I understand that your commission did in fact co-operate

14     with the military commissions; correct?

15        A.   Absolutely.  And I needed their co-operation.

16        Q.   You also mention that the Red Cross would be involved in the

17     exchanges.  This was the Republika Srpska Red Cross; right?

18        A.   Yes.  The ICRC would be informed as well as the UNHCR.  They had

19     exact information as to when, how many people were crossing over to the

20     other side, in order that food and accommodation be provided, et cetera.

21        Q.   Just to repeat my question:  This was the Republika Srpska branch

22     of the Red Cross; right?

23        A.   Yes, yes.

24        Q.   The --

25        A.   But we had certain co-operation also with the International Red

Page 25271

 1     Cross.

 2        Q.   Do you know whether the Republika Srpska Red Cross was recognised

 3     by the International Red Cross at that time?  Just if you know or not.

 4        A.   I don't know.

 5        Q.   And beginning in 1993, the president of the Republika Srpska

 6     Red Cross was Ljiljana Karadzic; right?

 7        A.   Yes.

 8        Q.   That was Radovan Karadzic's wife?

 9        A.   Yes.

10             MR. TRALDI:  Your Honours, I see we're at the time for the break.

11     I'm about to turn to a new topic.

12             JUDGE ORIE:  We are.

13             Witness, we would have a break of 20 minutes.  We'd like to see

14     you back after the break.  You may now follow the usher.

15             THE WITNESS: [Interpretation] Thank you, Your Honours.

16                           [The witness stands down]

17             JUDGE ORIE:  We resume at 10 minutes to 11.00.

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

19                           --- On resuming at 10.55 a.m.

20             JUDGE ORIE:  We're waiting for the witness to be escorted into

21     the courtroom.

22             For scheduling purposes, we'll not sit tomorrow.  We might finish

23     the -- conclude the testimony of this witness today, perhaps even easily.

24             MR. TRALDI:  I anticipate being done in the next session.

25             JUDGE ORIE:  Yes.

Page 25272

 1             JUDGE FLUEGGE:  This session.

 2             MR. TRALDI:  Not this -- the next, the one after this.

 3             JUDGE ORIE:  Okay.  And then we have still some time for the next

 4     witness that may perhaps not yet be available or is available, Mr. Lukic?

 5             MR. LUKIC:  Your Honours, our next witness is coming tomorrow

 6     night.

 7             JUDGE ORIE:  Okay.  Fine.  That's understood.  And in view of the

 8     developments this week, it's fully understood that the witness is not yet

 9     on standby for later this day, and then we'll hear his testimony starting

10     on Monday.

11                           [The witness takes the stands]

12             JUDGE ORIE:  You may proceed, Mr. Traldi.

13             MR. TRALDI:  Thank you, Mr. President.

14             Could we have 65 ter 1D02455.  And this will be the publication

15     in the Official Gazette of a decision appointing members of the exchange

16     commission in May 1993.

17        Q.   While it comes up - and I see we already have the B/C/S - this is

18     during your time as Minister Ostojic's associate; right?

19        A.   Yes, 6th of April.

20             MR. TRALDI:  And I think in the B/C/S we actually need the --

21     yeah, and a little bit higher in the right column.

22        Q.   So these are the members of the exchange commission that you

23     collaborated with, the names that we see here; right?

24        A.   Yes.

25             MR. TRALDI:  And, Your Honours, the Prosecution tenders 1D02455.

Page 25273

 1             JUDGE ORIE:  Madam Registrar.

 2             THE REGISTRAR:  Document 1D2455 receives number P6718, Your

 3     Honours.

 4             JUDGE ORIE:  And is admitted into evidence.

 5             MR. TRALDI:

 6        Q.   Turning to a different topic --

 7             MR. TRALDI:  And I'm done with this document, now.

 8        Q.   -- and taking you back to before the war in your role in the SDS,

 9     sir, did you know Jovan Tintor?

10        A.   Yes.

11        Q.   And he was, among other things, a leading member of the SDS in

12     the Sarajevo area; right?

13        A.   Yes.

14        Q.   And you spoke to Mr. Tintor on occasion in 1991; correct?

15        A.   Yes, in 1991, 1992.  Whenever we would meet, we talked.

16        Q.   Now, the Chamber has received evidence that Mr. Tintor --

17             MR. TRALDI:  And I'm referring to P4583.

18        Q.   -- in his own words, that he told the RS Assembly:

19             "I went from municipality to municipality and created military

20     formations on order from my president."

21             And that he said:

22             "We created brigade commanders down to platoon commanders.  All

23     this was done by the SDS."

24             Now, Mr. Tintor, in 1991, was involved in arming Serbs in

25     Bosnia-Herzegovina, wasn't he?

Page 25274

 1        A.   I don't have this information.  I think that this is Mr. Tintor

 2     boasting.  I don't believe that he was forming platoons and brigades.

 3     Absolutely not.  People self-organised, mostly.  I think that this is

 4     just propaganda.  My experience with him was quite different.  He likes

 5     to boast a lot, but in the end it all comes to nothing.

 6        Q.   So your evidence is you don't know whether -- you don't have

 7     personal knowledge whether or not Mr. Tintor was involved in arming; is

 8     that right?

 9        A.   I just have information about his empty words.  Really, just

10     empty words.  Just talk, empty talk.  But actually what happened was

11     quite different.

12        Q.   Now, the Chamber has received evidence that in a number of

13     municipalities Serbs received arms from the SDS and the JNA, and one of

14     those was Zenica; that's correct, isn't it?

15        A.   They definitely did not receive weapons from the SDS.  That is

16     incorrect.  I don't know.  Perhaps it's possible that they stole

17     something from the JNA barracks when they went in there.  That is

18     possible.  I had that kind of information.

19        Q.   So your information is that Serbs in Zenica went into the JNA

20     barracks and stole things that you believe to include arms?

21        A.   I had information that individuals and criminals did that and

22     that even that they sold these weapons to Muslims.  I can give you two

23     specific names, if necessary.

24        Q.   And the Defence can inquire about that later if they choose, sir,

25     but the Chamber has also received evidence that more than 1.700 Serbs in

Page 25275

 1     Zenica have received arms.

 2             MR. TRALDI:  And we've seen the document a number of times but

 3     it's P3030.

 4        Q.   Now, that's a report from the 2nd Military District from the JNA.

 5     That's more than a couple of criminals; right?

 6        A.   I don't know.  I would need to look at the document.  But I think

 7     that's quite a high number, 1.700.  It's a whole brigade.  It's not

 8     possible that that many Serbs had weapons in Zenica, but I would like to

 9     look at the document.

10             MR. TRALDI:  If we could have Exhibit P3030 for the witness.

11        Q.   Now, this is the cover page.  You can see this is a report from

12     the 2nd Military District, from General Kukanjac, dated 20th of March

13     1992; right?

14        A.   Yes.

15             MR. TRALDI:  And if we could turn to I believe it's page 11 in

16     the English and 16 in the B/C/S, and if we zoom in on point 33.

17        Q.   You can see there on the left side of the screen:  "Zenica,

18     1.761"; right?  For the moment I'm just asking if you see the number.

19        A.   Yes.  I see it, yes.

20             MR. TRALDI:  Can we scroll up to the top of the page, please.

21        Q.   And the column heading:  "Opstina," or "municipality" is the one

22     we find Zenica in, and "Ljudi," or "man" is the one we find the number

23     in; correct?

24        A.   Yes.

25        Q.   Then I'd simply put to you that this JNA report is relaying

Page 25276

 1     reliable and accurate information about the arming of Serbs in Zenica at

 2     the time.

 3        A.   I'm very surprised by this information because I know that they

 4     were constantly saying what they would do, how they would manage.  Some

 5     of the men did enter the barracks, but I'm hearing for the first time now

 6     that it was a question of this many weapons.  Could you please clarify

 7     for me:  Do they only mean the municipality of Zenica or the region of

 8     Zenica?  I'm sorry, yes, I can see Zepa, Vitez, and so on.  Yes.

 9        Q.   And so having seen that, you understand it to be the

10     municipality; right?

11        A.   Yes, yes.  Right.  That's right.

12        Q.   Okay.  I'm going to leave this topic now and turn to your work

13     with Minister Ostojic.  You mentioned that you worked on refugee issues.

14     One of Mr. Ostojic --

15        A.   Yes.

16        Q.   One of the minister's responsibilities was that together with

17     Minister Brdjanin he was tasked to prepare a programme for the

18     accommodation of refugees; right?

19        A.   Correct, yes.

20        Q.   Now, the goal of this programme and of Minister Ostojic was to

21     build new demographic politics and establish the ethnical geographical

22     continuity of the Serb population; right?

23        A.   I wouldn't be able to say what their intention was.  I worked and

24     I was looking for any possible free space where I would be able to

25     accommodate those people who were asking for my help.  I don't know what

Page 25277

 1     the goals were that you referred to.

 2        Q.   Well --

 3        A.   I did bother both of them about accommodation for the refugees.

 4     Yes, definitely.

 5             MR. TRALDI:  Well, could the Prosecution have 65 ter 02382.  This

 6     is the transcript of the 34th Session of the Republika Srpska Assembly.

 7     And once it comes up, I'll be asking for the bottom of page 212 in the

 8     English and page 230 in the B/C/S.

 9             JUDGE MOLOTO:  After seeing the first page.

10             MR. TRALDI:  Yes, which we can see here.

11        Q.   And we can see Minister Ostojic begins speaking in the middle of

12     the page on the B/C/S and towards the bottom of the page in the English,

13     and he says in the fourth line down in the English:

14             "We were aiming to achieve our goal which was ethnical

15     geographical continuity of Serb population while accommodating the

16     refugees.  And actually, we were building new demographic politics for

17     the RS."

18             MR. TRALDI:  Then we turn the page.  If we could turn to 213 in

19     the English.

20        Q.   "With this aim, we had two tasks.  Those are to as soon as

21     possible shelter and accommodate displaced persons and to find them jobs

22     so that the economical consolidation and later on political integration

23     of their lives in the area would move on."

24             Now, do you see that language in the Serbian version?

25        A.   Yes, yes.

Page 25278

 1        Q.   So, Minister Ostojic's goal, as he presented it to the assembly,

 2     did involve the ethnical geographical continuity of the Serb population;

 3     right?

 4        A.   I don't know if that was his goal.  I mean, he did speak clearly

 5     here, but I cannot really comment on it now.

 6             MR. TRALDI:  Your Honours, a portion of this assembly session is

 7     admitted as Exhibit P2508.  This is not included in the admitted portion.

 8     I'd propose to speak with the Defence and agree on additional portions.

 9     I note the session has been tendered, I believe in its entirety, as an

10     associated exhibit to the testimony of a witness who will come next week.

11     So we'll just meet about additional portions in between, if that's all

12     right with the Bench.

13             JUDGE ORIE:  The Chamber is looking forward to any agreement the

14     parties may reach on extending the scope of the exhibit you just

15     mentioned.

16             Please proceed.

17             MR. TRALDI:  Thank you, Mr. President.

18             Could the Prosecution now have 65 ter 02391.  And this will be

19     the 39th Session of the Republika Srpska Assembly in March 1994.  And we

20     can see that on the first page.  So if we could now have page 168 in the

21     English and page 135 in the B/C/S.

22        Q.   Now here we see Minister Ostojic speaking again, and in the

23     middle of the page in English, towards the bottom in the B/C/S --

24             MR. TRALDI:  I'm looking in the English at the end of the first

25     paragraph.

Page 25279

 1        Q.   He says:

 2             "We have to deal with this problem first in order to establish

 3     the geographic continuity of the Serbian population in RS area."

 4             And then below the number 33 in the English, he says:

 5             "There are four areas that are extremely sensitive and which

 6     should be worked on.  The first one" --

 7             JUDGE ORIE:  Are we sure that this is still on the right B/C/S

 8     page?  I think we should move to page --

 9             MR. TRALDI:  You're quite right, Mr. President.

10             JUDGE ORIE:  -- 33.  Yes.

11             Could you please resume reading.  You said you -- you started?

12             MR. TRALDI:  "There are four areas ..."  There, Mr. President.

13             JUDGE ORIE:  Let me see.  Yes.  "There are four areas ..." which

14     is at the top of page 33, apparently.

15             MR. TRALDI:  Your Cyrillic exceeds mine.

16             JUDGE ORIE:  Well, "33" is the same in both languages,

17     Mr. Traldi.

18             MR. TRALDI:  That's true, too.

19             JUDGE ORIE:  You can follow what Mr. Traldi reads on the top of

20     page 33, Witness.

21             Please proceed.

22             MR. TRALDI:

23        Q.   So he's mentioned this problem that has to be dealt with in order

24     to establish geographic continuity.  And now he says:

25             "There are four areas that are extremely sensitive and which

Page 25280

 1     should be worked on.  The first one is old Herzegovina, in the area of

 2     Srbinje, Visegrad, Rogatica."

 3             Now, Srbinje is what had previously been called Foca; right?

 4        A.   Correct.

 5        Q.   And that area is on the Drina River; right?

 6        A.   Yes.

 7        Q.   So the second one is Birac in the area of Vlasenica, Bratunac,

 8     Zvornik.  That area, too, is on the Drina; right?

 9        A.   Correct.

10        Q.   The third one is Posavina in two directions, along the Sava river

11     and outskirts of Trebava, Vlasic, et cetera.  The fourth one is Sana Una

12     area, and the fifth is Vrbas area.  And he explains for a couple of lines

13     where those fall, and then says:

14             "We lack the population ..."

15             Do you see that text?

16        A.   Correct.

17        Q.   Now, what he's identifying here were areas where efforts were

18     being made to resettle Serbs; right?

19        A.   It's what it states here.  Yes.

20        Q.   And based on your experience as his associate, that's true, isn't

21     it?

22        A.   My experience is completely different.  I don't know what

23     Mr. Ostojic meant by this, but I am one of those people - and I can prove

24     that to this Tribunal - that at the beginning of the war in 1991 publicly

25     said over the media that we need to be careful not to destroy anything,

Page 25281

 1     because at the end of everything we will all come back to where we come

 2     from.

 3             I tried to speak with Mr. Ostojic a few times.  He would say,

 4     "Take people here or there," but it's very difficult for anybody to

 5     implement anything like this.  And he's dead, so it's not very nice to

 6     say anything like this about him, but it was impossible to direct people

 7     in that way.  People would go to a different area or abroad or something.

 8     I could never guide people to these areas that he refers to here.

 9             In any case, it was impossible.  That was already engulfed by

10     war.  There was destruction there.  So you would need to have a lot of

11     funds to be able to implement something like this.  It wasn't really

12     possible.  I was among those who believed - and I can prove that - that

13     everybody would return to where they originally came from.  What they

14     wanted was of a temporary nature.  So I can't comment on that.  I was

15     aware that what was being done was a temporary measure.

16        Q.   So, sir, you've answered several questions, but I'd like to

17     return to the one I asked, which is:  It's true, isn't it, that this is

18     an area where efforts were being made to resettle Serbs?

19        A.   What do you mean, "efforts made"?  Because it was not possible to

20     accommodate people there.  It was not possible.  It was not possible.  It

21     was destroyed.  I knew the area.  I toured the area and I knew the

22     situation very well.  It wasn't possible to do this without enormous

23     investments.  I mean, I wouldn't even mention it.  They could say

24     whatever they wanted at the government, but what was actually the

25     situation on the ground was completely different.  You had to see for

Page 25282

 1     yourself, know what was going on.

 2             The easiest thing is to talk sitting in your office.  I think you

 3     would agree with me about that.

 4        Q.   Let's turn to your own work, then.

 5             MR. TRALDI:  And, Your Honours, this, too, I believe has been

 6     tendered in its entirety as an associated exhibit to the evidence of a

 7     witness scheduled to testify next week, and I'd just propose that we deal

 8     with it at that time and I'll speak with the Defence in the interim.

 9             JUDGE ORIE:  Mr. Stojanovic agrees.

10             MR. TRALDI:  I appreciate that.

11        Q.   So turning to your work at the agency for exchange of property,

12     you assisted a number of Muslims in leaving Republika Srpska; correct?

13        A.   Assisted?  I don't know whether that was assisting, but when

14     people wanted to leave, they would report to us and then they would

15     leave.  And the same thing applied to the Serbs who were coming from the

16     other side.

17        Q.   I'll just ask a couple of questions about your procedures.  They

18     had to pay a fee to leave; correct?

19        A.   That depended on where they were going, in which direction.  They

20     had to pay for the bus and so on.  Yes, yes.  Sometimes there was a taxi.

21     Yes -- I mean, yes, it was correct.

22        Q.   Those fees for bus fare would be a hundred or more deutschmarks;

23     right?

24        A.   More or less, yes.

25        Q.   And sometimes even more.  Sometimes several hundred or more than

Page 25283

 1     a thousand?

 2        A.   It depended.  It depended on -- I mean, it's not correct if they

 3     were going to these areas.  Only if they were going to Hungary they had

 4     to pay quite high tax there, because I think they were giving to the

 5     Hungarians either 4- or 500 German marks and then the passport.  So they

 6     would pay the Hungarians about a thousand marks.

 7             If they were going somewhere within Bosnia-Herzegovina it was a

 8     hundred or 150, depending on the driver, how much he asked for and how

 9     much he had to pay for the trucks and the other transport.  But that was

10     about how much it ranged.  When you mentioned 1.000 marks, 600 of that

11     went to the Hungarians, for them to be able to enter Hungary.

12        Q.   And in many cases they also had to sign forms requesting

13     permission to leave; right?

14        A.   Permission to leave?  They didn't ask for permission to leave.  I

15     don't know how it was by municipality by municipality.  Did they have to

16     cancel their telephone, electricity.  They didn't ask for permission.

17     All I did was make lists and submit them to the authorised command that

18     on such and such a day we would be crossing the border.  That was the

19     gist.  I don't know if that was a permission or what it was, but that's

20     how it went.

21        Q.   I won't insist on the word "permission" for the moment, sir, but

22     I take it you would agree that they would sign forms requesting to leave;

23     right?

24        A.   A request?  A request is when they asked to leave.  However, all

25     I needed was the form that they filled in, general particulars, so that I

Page 25284

 1     would be able to announce to the command.  That's what the form was used

 2     for.  Nobody could forbid a civilian from going somewhere, whether they

 3     could go or not.  They had the right to go wherever they wanted.  That

 4     was the main thing.  The form contained their general particulars that I

 5     would record, then a list would be drafted which I submitted to the

 6     command, and then we would come to the line of separation.  The list

 7     would be checked.

 8             When they were going across the border to Hungary, the form was

 9     also filled in and it was checked.  There was no permission.  Civilians

10     were allowed to go without any problems.  I would like you to point to me

11     a single case when somebody was not permitted to leave.

12        Q.   Without looking at individual cases at the moment, sir, the forms

13     had to be given to the military command so that people could cross the

14     line of separation, didn't they?

15        A.   Of course.  All border crossings were controlled.  That is

16     logical -- sorry, not the border but the line of separation.  Excuse me.

17        Q.   All right.  I'm going to turn to the exchange commission now.

18             MR. TRALDI:  And could we have 65 ter 11889 brought to our

19     screens.

20        Q.   Now, we see here a document on the exchange of prisoners from the

21     central commission for the exchange of prisoners and civilians, and it

22     bears the stamp of the SRK, intelligence and security affairs organ.

23     Now, this says, among the addressees, that it's being sent to the

24     president of the RS Assembly, the security organ of the SRK, and the Novo

25     Sarajevo CSB; right?

Page 25285

 1        A.   Yes.

 2        Q.   So the exchange commission is informing political, military, and

 3     police institutions about the exchange it's conducting; right?

 4        A.   That is so here, but I'm really unable to comment on this

 5     document.  When I worked, I did not work in this way.  All I asked was

 6     security from the security services centre in Banja Luka.  So I would ask

 7     for an escort of two vehicles, I would announce when I would be going,

 8     and I would ask for an escort by the military police so that nothing

 9     would happen to us on the road.  And that is why I would notify them

10     about when we were going.

11        Q.   Okay.

12        A.   As for this thing, this is a matter for the political structure,

13     so I never had anything to do with that.  This is the first time that I'm

14     seeing this type of notification.  What does that mean, that the

15     president of the assembly is being informed about this?  I don't know

16     what the intention was when everybody was being informed.  All I -- the

17     only ones that I submitted notification to would be the command and the

18     time of the departure.  That was it.

19             JUDGE ORIE:  Witness, would you please focus your answer on the

20     question.  The question was just whether this was addressed to the

21     persons Mr. Traldi referred to.  He didn't ask you whether this is how

22     you did it or how someone else did it.  Could you please focus your

23     answer on the questions.

24             MR. TRALDI:  Your Honours, I'd tender this document.

25             THE WITNESS: [Interpretation] Thank you.

Page 25286

 1             JUDGE ORIE:  Mr. Stojanovic.

 2             THE WITNESS: [Interpretation] Thank you, Your Honour.

 3             MR. STOJANOVIC: [Interpretation] Just one objection:  I think

 4     that this document should not be tendered through this witness because he

 5     does not have any knowledge about this document and is unable to assist

 6     in any way.

 7             MR. TRALDI:  Your Honours --

 8             JUDGE ORIE:  Mr. Stojanovic, I think it was common practice

 9     developed over the last period of time that if a witness testifies about

10     a certain matter and if a document sheds light on the same issue - and

11     here, for example, the witness says that this is not how he did it - then

12     that becomes relevant in this context.  And therefore whether we call it

13     introduced through the witness or in relation to the witness's testimony,

14     but it's not a reason not to admit.

15             Mr. Traldi, I just set out the general -- not guidance but the

16     practice in this Chamber.  Would you like to add something before I give

17     a ruling?

18             MR. TRALDI:  Just very briefly to say that I'd understood the

19     witness's answer to confirm that he, too, would communicate with the

20     police and the military but not with the political branch, and that was

21     the only distinction between what we saw in the document and his answer.

22             JUDGE ORIE:  Madam Registrar.

23             THE REGISTRAR:  Document 11889 receives number P6719, Your

24     Honours.

25             JUDGE ORIE:  And is admitted into evidence.

Page 25287

 1             MR. TRALDI:

 2        Q.   Now, sir, discussing exchanges.  In paragraph 29 of your

 3     statement, you say:

 4             "There was no parity in the exchange..."

 5             And the Bosnian Serb side sought to exchange groups on an

 6     all-for-all basis; right?

 7             MR. TRALDI:  And the transcript, I think, through my own fault,

 8     recorded me a little bit imprecisely.  Let me ask the question again if I

 9     might --

10             JUDGE FLUEGGE:  It's now corrected.

11             MR. TRALDI:  Then I'll leave it as it stands.

12        Q.   So, Mr. Witness --

13             JUDGE ORIE:  Mr. Mladic is not supposed to speak aloud.

14     Mr. Lukic, if Mr. Mladic wants to consult you, he can do it at an

15     inaudible volume.

16             Please proceed.

17             MR. TRALDI:

18        Q.   Would it assist if I repeated the most pertinent part of the

19     question, sir?

20        A.   You can repeat it.  No problem.

21        Q.   The Bosnian Serb side sought to exchange groups on an all-for-all

22     basis; right?

23        A.   Yes, that's right.

24        Q.   So I just want to look at one example of a document setting out

25     that policy.

Page 25288

 1             MR. TRALDI:  Can 65 ter 19958 be brought to our screen.

 2             JUDGE MOLOTO:  Is it 199 or 119?

 3             MR. TRALDI:  199 --

 4             JUDGE MOLOTO:  Yes.

 5             MR. TRALDI:  -- and I apologise, my speed may have been off.

 6             JUDGE MOLOTO:  No, no.

 7             MR. TRALDI:  It's more likely to have been my mistake, Your

 8     Honour.  So I see we have it now.  My notes may be in error as to this

 9     document, so I'll come back after the break if I have any time remaining.

10     And now --

11             JUDGE ORIE:  It's on page 3 of your list --

12             MR. TRALDI:  I --

13             JUDGE ORIE:  -- of exhibits to be used.

14             MR. TRALDI:  I see it is, Mr. President.

15             JUDGE ORIE:  Okay.

16             MR. TRALDI:  But I've reversed the number of this one and another

17     in my outline, I'm afraid.

18             JUDGE ORIE:  Okay.  Let's move on.

19             MR. TRALDI:  Can 65 ter 31166 please be brought to our screens.

20        Q.   Now, this is going to deal with one of the exchanges that you

21     participated in.  This is a document coming from the Mrkonjic Grad

22     department of the Banja Luka CRDB.  And it notes that the military and

23     civilian commissions of Republika Srpska and the so-called BH Republic

24     met on 27 July 1994 in Ljubin Han on the line of demarcation between the

25     VRS and the so-called BH army.

Page 25289

 1             JUDGE ORIE:  Mr. Traldi, in order to avoid further confusion

 2     65 ter 3116?

 3             MR. TRALDI:  6.

 4             JUDGE ORIE:  6, yes.

 5             MR. TRALDI:  Mr. President.

 6             JUDGE ORIE:  It is not clear on the transcript.

 7             MR. TRALDI:  Looking --

 8             JUDGE ORIE:  Yes.  Again, it's 31116 in its totality.

 9             MR. TRALDI:  All right.  Not to further any confusion, but I

10     believe it's 31166.

11             JUDGE ORIE:  Oh, yes, I apologise.  It's --

12             MR. TRALDI:  As do I.

13             JUDGE ORIE:  The last number is definitive.

14             Please proceed.

15             MR. TRALDI:

16        Q.   So beginning with the document again, this is a document coming

17     from the Mrkonjic Grad department of the Banja Luka CRDB, and it notes in

18     the first paragraph that:

19             "The military and civilian commissions of Republika Srpska and

20     the so-called BH Republic met on 27 July 1994 in Ljubin Han; i.e., on the

21     line of demarcation between the VRS and the so-called BH army (halfway

22     between Borike and Turbe)."

23             And it notes -- I'll just summarize the next couple of paragraphs

24     for efficiency.  It notes that the BH army brought eight VRS POWs, it

25     notes that the VRS brought ten BH army soldiers, and the civilian

Page 25290

 1     commissions brought along four buses full of civilians, it says between

 2     170 and 217, most of whom were elderly people and women and children.

 3             Do you see that language?

 4        A.   Yes.

 5        Q.   And looking at paragraph 6, it says that when you headed to the

 6     scene, so this is an exchange that you participated in; right?

 7        A.   Yes.

 8        Q.   So what we're seeing here is, I'd put to you, an exchange which

 9     primarily consists of civilians leaving RS territory; that's right, isn't

10     it?

11        A.   Yes.

12             MR. TRALDI:  And, Your Honours, I'd tender this document.

13             JUDGE ORIE:  Madam Registrar.

14             THE REGISTRAR:  Document 31166 receives number P6720, Your

15     Honours.

16             JUDGE ORIE:  And is admitted into evidence.

17             MR. TRALDI:  And can 65 ter 19602 be brought to the screen.

18        Q.   And as this is brought up, I'd put to you that the Republika

19     Srpska exchange commissions would exchange non-Serb civilians for

20     captured VRS soldiers at times.  That's true, isn't it?

21        A.   I am not aware that these things happened, because I never had

22     such cases where civilians would be exchanged for soldiers.  I don't know

23     what was done in Goradze.  I see the document but I really did not have

24     such a case myself.

25        Q.   Well --

Page 25291

 1             JUDGE MOLOTO:  But, Witness, the previous document where you are

 2     mentioned to have participated mentioned civilians being brought in a

 3     bus, four buses.

 4             THE WITNESS: [Interpretation] Yes, Your Honour --

 5             JUDGE MOLOTO:  So you --

 6             THE WITNESS: [Interpretation] -- the civilians were brought.

 7             JUDGE MOLOTO:  -- did participate in an exchange of civilians on

 8     that occasion?

 9             THE WITNESS: [Interpretation] They were not exchanged.  They were

10     released to go.

11             JUDGE MOLOTO:  That's not what --

12             THE WITNESS: [Interpretation] I expected the Prosecutor to ask me

13     about that document, and I'm sorry that -- I know what was done.  It

14     doesn't have to be written here.  They were released to go free.

15             JUDGE MOLOTO:  Mr. Traldi.

16             MR. TRALDI:  Thank you, Your Honour.

17        Q.   That's reported, not to linger on the previous document, but the

18     Mrkonjic Grad department of the CRDB was reporting that that was part of

19     the exchange; right?  If it would be useful, we can call it back up.

20        A.   I think it would help, Your Honours.

21             MR. TRALDI:  Could we have P6720, again.

22        Q.   Okay.  Now, this was done, looking at the document, these

23     civilians were brought and taken across the confrontation lines in the

24     context of a meeting between the military and civilian exchange

25     commissions of Republika Srpska and the exchange commission of the

Page 25292

 1     BH Republic; right?

 2        A.   Correct.  May I further clarify this case?

 3        Q.   Go ahead.

 4        A.   This event remained etched in my mind.  What I see here about the

 5     elderly woman is not true, because while the military commissions were

 6     negotiating, I allowed our buses to cross over the line.  And I made a

 7     huge mistake.  I let them cross over with civilians to the other side,

 8     and suddenly the buses stopped coming back.

 9             I didn't know that military policemen had approached, took out a

10     very young man, a civilian, a man younger than myself - and I was then

11     40-something; that man was far younger - and he was an officer of the

12     former JNA.  I had put him on that bus because he had come with his

13     family and signed up, but one of those military policemen either knew him

14     from before or recognised him.  They took the man out.  They wanted him

15     to produce some additional permits in order to let him go.

16             I went back, made a phone call, and the whole thing was settled

17     very quickly.  He was put back on the bus together with his wife and

18     children.  This, I am emphatically maintaining, is not connected with an

19     exchange of civilians.  I was supposed to receive some civilians from

20     Bugojno, Travnik, et cetera.  The opposite side did not comply with our

21     agreement.  I learnt my lesson and I never did the same thing again.

22             So it's not true that an elderly person was concerned.  It was a

23     very young man, an officer of the JNA.  They left without any problem and

24     I got my buses back.

25        Q.   That's Azem Omerbasic as mentioned in the last paragraph?

Page 25293

 1        A.   I don't know.  I can't remember the name after so much time.  But

 2     we can check.  He was a JNA officer.

 3        Q.   Now, I want to direct your --

 4             MR. STOJANOVIC: [Interpretation] I apologise.  Just a moment.

 5     Could we look at the next part of the B/C/S version so the witness can

 6     follow your question.

 7             MR. TRALDI:  Of course.  If we could -- I think we could just

 8     scroll down.  No, up the next page.

 9             THE WITNESS: [Interpretation] Yes, yes.  I'm very happy we can

10     see this because I know I've been telling the truth to the Court.

11             MR. TRALDI:  Could we go back to the first page in the B/C/S.  I

12     want to look at the third and fourth paragraphs.

13        Q.   The third paragraph reads:

14             "Our civilian commission brought almost four buses full of

15     civilians (the exact number has not been ascertained, although there were

16     between 170 and 217), most of whom were elderly people and women with

17     children."

18             In the fourth paragraph the document continues:

19             "The exchange began at 1315 hours, when the first bus headed to

20     the place where the commissions were working ..."

21             So I'd put to you that the Mrkonjic Grad department of the CRDB

22     is reporting here that the exchange began when the first bus of civilians

23     headed to the place where the commissions were working; that's right,

24     isn't it?

25        A.   The first, second, bus, when it happened, really no.  But these

Page 25294

 1     arbitrary figures, four buses of 170 to 218, tells us how frivolous this

 2     is.  There was no elderly woman.  They were all much younger than myself.

 3     I did bring four buses.  I do not dispute that.  But there were all sorts

 4     of people of all age groups, even younger people.  Not only women and

 5     children.  This was done very unprofessionally and very sloppily.  I

 6     really have --

 7        Q.   Sir, I put it again --

 8        A.   I mean, 100 --

 9        Q.   I think again you're answering a different question than what

10     I've asked.  What I'm putting to you is simply that the Mrkonjic Grad

11     CRDB is reporting that the exchange began with the departure of the first

12     bus of civilians.  That's the literal text of the report; right?

13        A.   Correct.

14        Q.   And so I'd put to you that they are, in fact, treating those

15     civilians as part of the exchange.  That's right, isn't it?

16        A.   No, no.  It was not like part of the exchange.  I normally let

17     these people move from one bus to another and they moved their things,

18     too.  And the military commissions were exchanging prisoners of war.  I

19     was expecting to receive the civilians that were due to me and they

20     hadn't brought anyone, but I still let the civilians that I was keeping,

21     because I -- I let them go because I was told that I must not bring

22     anyone back.  These people were those who had requested to leave.  They

23     had visas for third countries, some of them.  They had expressly wanted

24     to leave.

25             MR. TRALDI:  Your Honours, I note it's close to time for the

Page 25295

 1     break.  I'm done with this document.

 2             JUDGE ORIE:  I would have one question for the witness.

 3             You said:

 4             "I was expecting to receive the civilians that were due to

 5     me ..."

 6             Why were they due to you if everyone was free to leave?  Yes,

 7     please explain.

 8             THE WITNESS: [Interpretation] Your Honours, they were due to me.

 9     I meant to say that I was claiming those civilians and I had an agreement

10     with them that these civilians would be brought to me, to Ljubin Han,

11     because this Sefer who is mentioned here is a man to whom I talked on the

12     radio twice a week.  We exchanged information about whether people on my

13     side or his side wanted to cross over.  We swapped information about that

14     and talked at least twice a week by radio.  Those were the people that I

15     was claiming.  Sefer even had told me that he had some people who wanted

16     to cross over to Republika Srpska.  We had that kind of communication.

17             JUDGE ORIE:  We will take a break.

18             We'd like to see you back in 20 minutes.

19                           [The witness stands down]

20             JUDGE ORIE:  We will resume at 10 minutes past 12.00.

21                           --- Recess taken at 11.50 a.m.

22                           --- On resuming at 12.13 p.m.

23             JUDGE ORIE:  Mr. Traldi.

24             MR. TRALDI:  Just to use the time efficiently and having

25     corrected my notes or had them corrected, I wonder if, as the witness is

Page 25296

 1     being brought in, we might already pull up 65 ter 19558.

 2                           [The witness takes the stand]

 3             THE REGISTRAR:  Your Honours, document 19588 -- is it 588 or 558?

 4             MR. TRALDI:  558.

 5             THE REGISTRAR:  558.

 6             MR. TRALDI:

 7        Q.   Now, if you recall, sir, last session we discussed the Bosnian

 8     Serbs advocacy of all-for-all exchanges, and in the second paragraph

 9     here, and this is a document bearing General Tolimir's name and dated the

10     4th of June, 1995, we read him say:

11             "We believe it is necessary to insist on observing the

12     'all-for-all' principle so that the exchange is carried out in one day in

13     arranged locations."

14             Now, I would just stop there and ask you:  It's correct, isn't

15     it, that your evidence is that's the principle that the Bosnian Serbs

16     advocated, this all-for-all exchange; right?

17        A.   I don't know what you mean, my principle.  This concerns

18     prisoners of war.  Civilians are an entirely different issue.  They were

19     not sent for an exchange.  They were just released to go free.  That was

20     our principle, to allow everybody freedom of movement.  All civilians, I

21     mean.

22        Q.   But, sir, if I could --

23        A.   I --

24        Q.   -- interrupt for a moment, and we'll get to that.  We'll get to

25     the civilians and prisoners of war.  But if I look at your evidence on

Page 25297

 1     temporary transcript page 39, I asked you at lines 18 and 19:

 2             "The Bosnian Serb side sought to exchange groups on an all-for

 3     all-basis; right?"

 4             And you said:

 5             "Yes, that's right."

 6             That was your evidence at that time; right?

 7        A.   Yes.

 8        Q.   And so what General Tolimir is advocating here is consistent with

 9     the Bosnian Serbs position as you described it a few transcript pages

10     ago; correct?

11        A.   If we're talking about POWs, I know that it was all-for-all, but

12     exchanges of civilians did not go along those lines.  They were allowed

13     to go wherever they wanted.

14             MR. TRALDI:  I'll tender this document.

15             JUDGE ORIE:  Madam Registrar.

16             THE REGISTRAR:  Document 19558 receives number P6721, Your

17     Honours.

18             JUDGE ORIE:  And admitted into evidence.

19             MR. TRALDI:  Now, if we could have Exhibit P4008.

20        Q.   Now, this is a document, an order, as it's identified, also

21     coming from General Tolimir.  And the first paragraph refers to an

22     agreement reached on the 1st of October 1994.  Do you see that?

23        A.   Yes.

24        Q.   And it refers to the exchange of a prisoner -- of prisoners held

25     in Gorazde and Konjic and Sarajevo in the first paragraph, and then in

Page 25298

 1     the second to the exchange of prisoners -- Muslim prisoners being held in

 2     Foca, Rudo, Visegrad, and some in Batkovic and Butmir.  Do you see that

 3     as well?

 4        A.   Yes.

 5        Q.   Where it refers to Butmir, that's another name used to refer to

 6     Kula prison; right?

 7        A.   I don't know that.  I really don't know.  I know about the Kula

 8     prison, but Butmir?  I was convinced that it was a prison on the Muslim

 9     side.

10        Q.   Well, looking at the long paragraph in the English that begins:

11     "The Sarajevo Romanija Corps ..." I'm going to call your attention to the

12     end of that paragraph.  There General Tolimir writes:

13             "It should be kept in mind that in the exchanges we received

14     captured soldiers of the Republika Srpska while we mostly give them

15     civilians."

16             So what General Tolimir is saying here is that the Republika

17     Srpska authorities were exchanging civilians, receiving back captured

18     soldiers; right?

19        A.   I would not agree with you because that's not the way we did

20     things.

21        Q.   Sorry.

22        A.   Whether it happened somewhere --

23             JUDGE ORIE:  Witness, that wasn't the question.  The question was

24     not whether it happened.  The question was whether you agree that that is

25     what General Tolimir is saying.

Page 25299

 1             THE WITNESS: [Interpretation] I apologise, Your Honour.  Then I

 2     didn't understand the question.  Yes, it is stated so here.

 3             MR. TRALDI:

 4        Q.   Now, you claim in paragraph 30 of your statement that the army

 5     didn't deal with the departure and exchange of civilians.  That's exactly

 6     what General Tolimir is referring to here; isn't it?

 7        A.   I continue to maintain that the military was not there, where I

 8     was moving.  But what General Tolimir says, it's probably true because we

 9     never stopped a military conscript from crossing over to the other side

10     as a civilian.

11             MR. TRALDI:  I'd ask that we call up 65 ter 19602.

12        Q.   And this is going to be a prisoner exchange report from the

13     Bosnian State Commission for Exchange dated 5th October 1994, about 12

14     days later.

15             MR. TRALDI:  If we could turn to page 2, and in the English it

16     will be the second paragraph.  In the B/C/S we are actually towards the

17     bottom of the first page.

18        Q.   Now, this paragraph starts:  "The aggressor ..." and that was

19     language that the Bosnians commonly used to refer to the Bosnian Serbs;

20     right?

21        A.   Yes.

22        Q.   "The aggressor took advantage of the exchange to expel 87

23     Bosniaks, Muslims, from ..." and then it lists a number of villages.

24     Those are villages in eastern Bosnia, including in Rogatica; right?

25        A.   I don't know, but I don't see that Rogatica is mentioned.

Page 25300

 1     Knezina, Kramerci, Kolina.  I don't know where you see Rogatica.

 2        Q.   I wasn't suggesting that it was mentioned.  What I was suggesting

 3     was that one or more of those are in Rogatica municipality; is that

 4     correct?

 5        A.   I could not confirm that because I really don't know these

 6     places.  I passed through Rogatica quite by chance a few times, but I

 7     don't know these places.

 8             MR. TRALDI:  If we could turn to page 3 in the English, and we'll

 9     be turning I believe to page 3 in the B/C/S as well, under the word

10     "Analysis."

11        Q.   So at the beginning of the analysis it gives a number of dates,

12     and then says:

13             "We managed to implement most of the 1 October 1994 agreement

14     relating to prisoner exchange."

15             Now, that's the same date for an agreement referred to in General

16     Tolimir's order that we just saw, right?

17        A.   Yes.

18        Q.   And it says:

19             "Karadzic's Bosnian Serbs freed a total of 247 prisoners from

20     various prisons in Foca, Rudo, Visegrad, Rogatica, Batkovic, as well as

21     Lukavica and Kula ..."

22             A number of those are the prisons that were listed in

23     General Tolimir's order; right?

24        A.   Yes.

25        Q.   Then it refers to the legal authorities of the Republic of

Page 25301

 1     Bosnia-Herzegovina freeing 135 members and associates of the enemy army

 2     and other categories of citizens detained on reasonable grounds of

 3     suspicion that they had committed conflict-related crimes.  And it goes

 4     into the structure of the freed persons.  And it says:

 5             "Karadzic's Serbs freed a total of 19 members of the Republic of

 6     Bosnia-Herzegovina armed forces, only three of whom were captured in

 7     combat."

 8             And it breaks it down.  It says:

 9             "20 of the freed persons were women, 3 were children under the

10     age of 10."  And below that it says:

11             "Four of the freed prisoners are older than 70.  One is older

12     than 84 and one older than 86."

13             Do you see that language?

14        A.   I see it, yes.

15        Q.   And so what I put to you is that this document reflects just what

16     General Tolimir said, that in the exchange the Bosnian Serbs were

17     receiving captured soldiers and were mostly giving civilians.  That's

18     true, isn't it?

19        A.   Again, I say this is what it states in the document, but I'm

20     absolutely unaware of this.  So if you're asking me is this what the

21     document says, it does.  As for whether this is correct or not, I cannot

22     say because this was happening in a completely different part of the

23     Bosnia-Herzegovina.

24             Again, I state before this Tribunal that this is not how I did

25     things.  I did not exchange civilians for prisoners.  If the civilians

Page 25302

 1     came, that was all very well.  If they wanted to leave, I would let them

 2     go.

 3             MR. TRALDI:  Your Honours, I'd tender this document.

 4             JUDGE ORIE:  Madam Registrar.

 5             THE REGISTRAR:  Document 19602 receives number P6722, Your

 6     Honours.

 7             JUDGE ORIE:  Admitted into evidence.

 8             MR. TRALDI:  Can 65 ter 19313 be brought to our screens?

 9        Q.   This is the last document I'll show you today.  It will be dated

10     5 April 1995 and reflect minutes from a session of the Bosnian Serb

11     Supreme Command.

12             MR. TRALDI:  I'm going to ask that we turn, now that we've seen

13     the cover page, to page 69 of the English and 62 in the B/C/S.

14        Q.   And General Tolimir is speaking.  And in the middle of the

15     paragraph that begins:  "Never mind that he is miscalculating ..."

16     looking at the third line, he says:

17             "If Mr. Glogovac is a socially-owned agency, then approval can be

18     requested, approval given for emigration in accordance with the Geneva

19     Convention that has been nicely proposed in our memorandum, according to

20     the Geneva Convention on War.  It was written privately for civilians --"

21             JUDGE FLUEGGE:  Show down.  Slow down.

22             MR. TRALDI:  I apologise, Your Honour.  I'll pick up at the word

23     "civilians."

24        Q.   "Every civilian has the right to choose his place of residence

25     and to go where he is safer, and we could draw up a form which this

Page 25303

 1     Glogovac will give Muslims to fill in.  It is precisely spelled out in

 2     the Geneva Conventions that they wish to move out while war conflicts are

 3     going on, and he voluntarily wishes to move out to the territory of a

 4     third country because he does not want to take part in the war conflicts.

 5     So the moment that he signs that he is leaving he has expressed and

 6     documented his will.  I did that while I was in Knin and not a single

 7     Croat ever returned, and we showed the papers to the UN and that is why

 8     the Croats cannot bring them back even by force."

 9             So what I'm going to put to you is that General Tolimir is

10     describing forms that are, in fact, the forms you described in the

11     previous session that Muslims would fill in when they were leaving the RS

12     and going to third countries or going to Bosnian-held territory.  That's

13     true, isn't it?

14        A.   I can see what is written here and it is clear to me.  However, I

15     categorically state that I never received any papers or forms from

16     anyone, including General Tolimir.  I don't know what they were thinking

17     when they were doing this.  Perhaps it's related to the agreement of the

18     late Professor Koljevic and the representative of the International Red

19     Cross, Mr. Sam Ruga, who signed an agreement about civilians, and that

20     they could do what is said here.  But I categorically state before this

21     Court that I never received any forms to this effect, so I really don't

22     know what they talked about, what they meant.

23        Q.   Just to conclude, I'd put to you you've confirmed you gave

24     departing Muslim civilians forms, you've confirmed that they filled them

25     out, you've confirmed that those documented they voluntarily wished to

Page 25304

 1     leave.  That's all true, isn't it?  A simple "yes" or "no."

 2        A.   No.  Categorically no.

 3             MR. TRALDI:  The witness's previous testimony on this matter

 4     speaks for itself and so I have no further questions.

 5             JUDGE ORIE:  Thank you, Mr. Traldi.

 6             MR. TRALDI:  Given the length of the document, I'd ask that it be

 7     marked for identification for the moment.

 8             JUDGE ORIE:  Madam Registrar.

 9             THE REGISTRAR:  Document 19313 receives number P6723, Your

10     Honours.

11             JUDGE ORIE:  P6723 is marked for identification.

12             Mr. Stojanovic, any questions in redirect?

13             MR. STOJANOVIC: [Interpretation] A few, Your Honours.

14             Perhaps it would be good to stay with this document for a moment

15     while we still have it in front of us.

16                           Re-examination by Mr. Stojanovic:

17        Q.   [Interpretation] Mr. Glogovac, perhaps it would be good if you

18     told the Trial Chamber according to your best recollection how this

19     process went in which you, as part of the agency, took part the process

20     of the population wishing to leave the territory of your area of their

21     own free will.

22        A.   I already -- I can say before this Tribunal that at one point

23     prosecutors came to Banja Luka.  They wanted to discuss this topic,

24     something that had to do with these forms.  I said that I could be a

25     potential witness for Krajisnik and Karadzic, and they did not force me

Page 25305

 1     to discuss this because I said that I needed to remain objective.  The

 2     process - this is the way it went from the Muslim and Croat side - they

 3     asked me to bring certain families that had remained behind because their

 4     families were looking for them.

 5             They would come to us.  It was just a plain form with your first

 6     name, last name, date of birth, address, and the person would state where

 7     they wanted to go.  There was nothing else on the form, whether they

 8     wanted to come back or not, what would happen to their property, nothing

 9     like that.  I'm sorry, I am going quite fast again.

10        Q.   Thank you.  And what did you use this form for in the continued

11     process of the transfer of those people?

12        A.   The form was used to make a list to report to the responsible

13     command where and when we would be crossing into the territory.  So that

14     was the only purpose of that form.  It could not be used for anything

15     else, for any other purpose.

16        Q.   Were there any situations when the citizens would voice their

17     desire to leave the territory of Bosnia-Herzegovina and where they wanted

18     to go to western Europe, for example?

19        A.   Yes, there were numerous such cases.  Mostly people wanted to go

20     to a different country.  Some of them even had visas.  And often they

21     would be quite persistent until we made it possible for them to leave

22     through Croatia or Hungary or another different area of

23     Bosnia-Herzegovina.

24             MR. STOJANOVIC: [Interpretation] Could we look at document

25     65 ter 31168 in e-court, please.  31168.

Page 25306

 1        Q.   Mr. Glogovac, this is a document where your name is mentioned.  I

 2     would like you to read it, and then I would like to ask you this:  The

 3     process of seeking permission for unhindered passage, is this document a

 4     response to such a request made by you?

 5        A.   Let me first read this aloud.

 6        Q.   No, you don't have to read it out loud.  Read it for yourself and

 7     then answer.

 8        A.   Yes, precisely.  We would announce to the military organs and to

 9     the police, and then the police would provide two or three vehicles as

10     security because I didn't want to allow anything unfortunate to happen on

11     the way.

12        Q.   And if people were prepared to go to Bosnia and Herzegovina that

13     was under the control of the army of Bosnia-Herzegovina, the line of

14     separation, the front line had to be crossed.  Whose permission would you

15     ask for then?

16        A.   I would then ask the corps command to allow us to pass freely,

17     and I would also ask for security to provide -- to be provided by the

18     civilian police, and I would also ask for a vehicle from the military

19     police just in case any of the soldiers were making any problems.  When

20     crossing I would always have both police and military escort.

21        Q.   When you answered Judge Orie's question about "the persons that

22     were due to me, that I was expecting," who were you specifically thinking

23     of?  Where were they supposed to be coming from?

24        A.   Well, if I remember correctly, these would be ethnic Serbs who

25     were living in the area of the then-Bosnia-Herzegovina.  It was Travnik,

Page 25307

 1     Novi Travnik, Bugojno, a part of Zenica.  That was the area that I meant.

 2     And so if anybody wanted to come, Sefer Samir would usually report to me

 3     how many such persons wished to cross to our side.  So I do have requests

 4     from the commission asking that these people cross to the territory of

 5     Republika Srpska.  I received them from Mr. Sefer.  These documents can

 6     always be presented to the Court.  They are still available.

 7             MR. STOJANOVIC: [Interpretation] Could we look again at P6720.

 8        Q.   It's a document you had an opportunity to see when you were

 9     cross-examined by the Prosecutor, and you also answered a question from

10     Judge Moloto on this document.  Could you please focus on paragraph 2 of

11     this document.  Can this paragraph refresh your memory to the effect that

12     it was precisely when you brought those civilians in four buses,

13     simultaneously there was an exchange of prisoners of war.

14        A.   That's right.  It happened not only here.  There were more cases

15     of that.  We can look at the exchange of prisoners between Herceg Bosna

16     and our side, on which occasion I accepted or received 201 civilians.  It

17     happened both with the Croat side and the Muslim side.

18        Q.   And I will conclude.  At any time while doing the job you

19     described, did you gain the impression or perhaps have specific knowledge

20     that there were open and deliberate takeovers of civilians who were made

21     to leave the area where they were living by force?

22        A.   No.  During my tenure, no.  Sometimes, I can tell the Court, they

23     would even sleep over at my own apartment before departure.  I would

24     never allow anything of the sort, nor did anyone ever complain that it

25     happened.  There were cases when people didn't want to go.  In response

Page 25308

 1     to a query from the family on the other side, they would write a letter

 2     sending their greetings and saying they want to stay where they were.

 3        Q.   What was the main reason why these people were departing?

 4        A.   Well, I can tell you about my own case.  I fled.  I left.

 5     Terrible things happened in our area.  We have terrible experiences from

 6     World War I and World War II.  Many times I made an appeal through TV

 7     Zenica:  "Please, do not all run away."  However, the fear was

 8     overwhelming, and there was also propaganda.

 9             There were combat operations in April 1992.  A large group of

10     refugees came from Derventa, and I couldn't imagine what had happened to

11     those people.  The media went wild.  I went to see these people together

12     with a neighbour of mine to ask these people what they had fled from,

13     what the Serbs had done to them.  They just said, "Serbs are surrounding

14     Derventa.  We are afraid of revenge.  We just fear for our lives.  We

15     wanted to leave."

16        Q.   Thank you.  Thank you very much for the answers you provided.

17             MR. STOJANOVIC: [Interpretation] We have nothing further.

18             JUDGE ORIE:  I have a few questions for you.

19                           Questioned by the Court:

20             JUDGE ORIE:  You told us about people who were going to Hungary.

21     Were they transported in buses or trucks or ...?

22        A.   Up to the Hungarian border, they went by bus.  From there on, I

23     don't know.  We had various reports.  But up to the Hungarian border --

24             JUDGE ORIE:  They travelled by bus.  How many people would a bus

25     take on average?

Page 25309

 1        A.   Well, as many as there were seats.  There were smaller and larger

 2     buses.  It depended on how many people had signed up.  But they were not

 3     overcrowded.  We always tried to leave some space free until the last

 4     moment in case somebody appeared at the last -- at the eleventh hour.  It

 5     was a long way to travel, so we didn't want them to be overcrowded.

 6             JUDGE ORIE:  How do I have to understand this, there to be then

 7     40 people on the bus approximately?  Or would there be 5 people on the

 8     bus or 70?

 9        A.   Your Honours, there were buses that had 35 to 40 seats.  There

10     were buses of 50-plus seats, up to 70.  There were all sorts of buses.

11     But there were enough seats.  I can confirm that.

12             JUDGE ORIE:  Yes.  Now to whom did those who were transferred

13     have to pay?

14        A.   Part of the fee they paid to the agency for the bus and the

15     passports, and part of the money they had to keep because they had to pay

16     it to the Hungarians at the border.

17             JUDGE ORIE:  Do you mean the agency -- were you involved in the

18     agency?

19        A.   Yes, yes.

20             JUDGE ORIE:  Now, you said that, in response to a question put to

21     you by Mr. Traldi, when you mentioned 1.000 deutschmarks, 600 of that

22     went to the Hungarians.  Do I understand that then 400 remained with the

23     agency?

24        A.   No.  Part was needed to arrange passports because they didn't

25     have passports, and the rest was to cover the cost of the buses because

Page 25310

 1     at that time the buses were very expensive because petrol was very

 2     expensive.  So it was a costly affair to get a bus.  There were also

 3     cases when people didn't have any money, and I have certificates for

 4     this, that we provided money to people who were indigent because they had

 5     been literally kicked out of their houses or -- well, because of other

 6     circumstances, they didn't have any money.

 7             JUDGE ORIE:  Is there written documentation about these financial

 8     arrangements for those who left?

 9        A.   I had them.  I believe they still exist.  But we had rigorous

10     controls, and I believe every day somebody checked exactly which monies

11     were paid into which account and how much.  But we don't have any

12     documentation of the money that was paid to the Hungarians.

13             JUDGE ORIE:  I'm asking this, and I'm also addressing the

14     Defence, because until now we've seen that the testimony of the witness

15     sometimes differs from what we see in documentation.  I do not know what

16     the basis of Mr. Traldi's questions were about the money being paid, 100,

17     150 deutschmarks.  But of course the Chamber would very -- be very much

18     assisted in assessing the weight to be given to the testimony by any

19     underlying documentation.

20             MR. STOJANOVIC: [Interpretation] Your Honours, we will certainly

21     endeavour to find this, but I would like to clarify one thing.

22             Witness, this is documentation you provided to the Brdjanin

23     Defence or is it still in the archive of the agency?

24             THE WITNESS: [Interpretation] That was provided to the Brdjanin

25     Defence team and that's why the OTP requested the same documents later.

Page 25311

 1             JUDGE ORIE:  Mr. Traldi, if you have any documentation about it.

 2     Of course, we are trying to -- to find as much -- well, not to find, but

 3     to seek that as much evidence are presented to the Chamber as possible so

 4     as to enable us to assess the probative value of the evidence.

 5             MR. TRALDI:  We'll consult our archives, Mr. President.  I can

 6     say that my basis was not official records but a number of statements

 7     from persons who'd been transported out, and explained that they had paid

 8     to leave under those circumstances.  So I haven't seen the exact

 9     documents that you're looking for, but we're happy to check our records.

10             JUDGE ORIE:  Yes.  If the parties would do so.

11             Have the questions in redirect triggered any need for further

12     questions?

13             MR. TRALDI:  No, Mr. President.

14             JUDGE ORIE:  Then, Witness, this concludes your testimony.  I'd

15     like to thank you very much for coming to The Hague and for having

16     answered all the questions that were put to you, questions put to you by

17     the parties, questions put to you by the Bench, and I wish you a safe

18     return home again.

19             You may follow the usher.

20             MR. TRALDI:  I'm reminded to inquire, Mr. President --

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

22             JUDGE ORIE:  Do we need the witness for --

23             MR. TRALDI:  No, Mr. President.

24             JUDGE ORIE:  Okay.  Then let's first allow the witness to leave

25     the courtroom.

Page 25312

 1                           [The witness withdrew]

 2             MR. TRALDI:  I'm reminded to inquire if Mr. Stojanovic intended

 3     to tender 65 ter 31168 which he used on redirect, and if he does we would

 4     have no objection.

 5             MR. STOJANOVIC: [Interpretation] Yes, Your Honour.  Let me just

 6     tender for the record the document 65 ter 31168.

 7             JUDGE ORIE:  Madam Registrar.

 8             THE REGISTRAR:  Document 31168 receives number D621, Your

 9     Honours.

10             JUDGE ORIE:  D621 is admitted into evidence.

11             Since there are no witnesses at this moment to be examined, we

12     adjourn for the day but also for the week, and we will resume on Monday,

13     9.30 in the morning - that is, Monday the 8th of September, if I'm not

14     mistaken.

15             Ms. Bibles, you're on your feet.

16             MS. BIBLES:  Your Honour, I could take five minutes to follow up

17     on a question from the Trial Chamber about one of the exhibits from

18     Witness Adzic's testimony, or I could do that later.  I'm in the Court's

19     hands.

20             JUDGE ORIE:  I think we have some spare time at this moment, so

21     perhaps we do it now.

22             MS. BIBLES:  Thank you, Mr. President.

23             Your Honours, Exhibit 3951 was used with Witness Adzic last week.

24     At transcript 24804, the Chamber noted that the document refers to a

25     Stevo, S-t-e-v-o, Drljaca, and asked the Prosecution to explain why we

Page 25313

 1     believe that this refers to Simo, S-i-m-o, Drljaca.  P3951 refers to a

 2     massacre committed by the Prijedor police under a "Stevo Drljaca."  The

 3     correct name of the Prijedor police chief is Simo Drljaca as noted by

 4     RM16 at transcript 17368 in relationship to this specific document.

 5             Drljaca is additionally identified as the chief of the Prijedor

 6     police in the trial record at T17838, T2589 and --

 7             JUDGE FLUEGGE:  Could you repeat the first transcript reference.

 8             MS. BIBLES:  Yes.  2589 -- oh, I'm sorry, the one before that was

 9     17838 and transcript reference 17926.

10             There are additionally a large number of exhibits which have been

11     admitted which also identify the chief of the Prijedor police as Simo

12     Drljaca.

13             For the responsibility of the Prijedor police under Chief Drljaca

14     for the massacre, we refer Your Honours to the evidence of RM60, RM96,

15     and RM97.  We have also searched our demographic records for any

16     reference to a Stevo Drljaca who might fit this description in this

17     time-period, and we have found no such individuals.

18             It is the Prosecution's position that 3951 report -- the report

19     reflects a mistake in the first name, that "Stevo" should be "Simo."

20             Thank you, Your Honours.

21             JUDGE ORIE:  Thank you, Ms. Bibles.

22             Any comments by the Defence in this respect?

23             MR. LUKIC:  Your Honour, I couldn't find in this document the

24     name, so I don't know the context; although, my learned friend told us

25     the context.  And I can confirm that in 1992 the head of Prijedor police

Page 25314

 1     was Simo Drljaca.  So it's --

 2             JUDGE ORIE:  Yes, it seems --

 3             MR. LUKIC:  -- there is no dispute.

 4             JUDGE ORIE:  -- there may not be any dispute about that.  But

 5     then 3951, Ms. Bibles, could you remind me where we find Stevo, in what

 6     context, so that we --

 7             MS. BIBLES:  I believe it was page 4 in both versions.

 8             JUDGE ORIE:  Let's have a look.  Perhaps we could have a look at

 9     it.

10             MS. BIBLES:  I'm operating from memory.

11             JUDGE ORIE:  I can't find it immediately on that page, but --

12             JUDGE FLUEGGE:  Can it be brought up on the screen.

13             MS. BIBLES:  It should -- at the top of the English section of

14     the page.

15             JUDGE ORIE:  Yes, let me see.

16             MS. BIBLES:  And the previous page in the English version

17     describes the massacre.  Oh, I'm sorry, Your Honour, it is actually in

18     this paragraph that describes the massacre.

19             MR. LUKIC:  It is obvious from the document that it is Simo

20     Drljaca.

21             JUDGE ORIE:  Then there is no dispute that the reference to Stevo

22     Drljaca should be understood as a reference to Simo Drljaca.  May I take

23     it because there is only one such massacre known where 150 people died on

24     the same route --

25             MR. LUKIC:  And only one head of Prijedor CSB at that time by the

Page 25315

 1     name of --

 2             JUDGE ORIE:  Yes.

 3             MR. LUKIC:  -- Simo Drljaca.  And also in connection with the

 4     Koricanske Stijene massacre in Kotor Varos.

 5             JUDGE ORIE:  Yes.  So the parties agree that this reference is

 6     about the Koricanske Stijene massacre and that the reference to Drljaca

 7     is -- should be read as "Simo Drljaca."

 8             Thank you, Ms. Bibles.

 9             Thank you, Mr. Lukic.

10             We then now really adjourn for the day and for the week and will

11     resume Monday, the 8th of September, 9.30 in the morning.  I do not know

12     yet whether it will be Courtroom II or whether Courtroom I will be fixed

13     by then.  It will be Courtroom I, Madam Registrar indicates to me.  We

14     stand adjourned.

15                           --- Whereupon the hearing adjourned at 1.02 p.m.,

16                           to be reconvened on Monday, the 8th day

17                           of September, 2014, at 9.30 a.m.