141104ED

Page 27761

1 identification. Has a -- has the B/C/S version been uploaded into

2 e-court?

3 MR. LUKIC: Give us one second. I don't know if it's -- if it's

4 in e-court. As you know, yesterday we had some problems.

5 JUDGE ORIE: Yes, I see that. But then there's one remaining

6 matter. If the witness would please be so kind to give the copy he

7 received this morning to the usher so that the Prosecution and the

8 Chamber also have an opportunity to verify whether what the witness

9 attested to is the same as what we'll then later find in e-court because

10 otherwise there is a missing link.

11 Could the witness -- yes, Mr. Usher, could you please receive the

12 copy from the -- and could it be put in the hands of the Registrar for

13 the time -- for the time being. So the parties ...

14 [Trial Chamber and Registrar confer]

15 JUDGE ORIE: Madam Registrar keeps a copy which we just received

16 from the witness so that the parties are in a position to verify whether

17 the witness attested to the same as what then later appears in e-court.

18 Having dealt with this matter, Mr. Weber, are you ready to

19 continue your cross-examination?

20 MR. WEBER: Yes, Your Honours.

21 JUDGE ORIE: Please proceed.

22 Cross-examination by Mr. Weber: [Continued]

23 Q. Good morning, Mr. Vlaski.

24 A. Good morning.

25 Q. Yesterday at transcript page 27739, the Defence asked you a

Page 27762

1 question about the documentation available to the State Security Service

2 in Sarajevo. The question was:

3 "Did it remain in Sarajevo or did you take it?"

4 In a following answer on that same page, you did acknowledge that

5 some of the documents were taken after military operations ensued.

6 My question: Did you take any documents, recordings, or other

7 material that belonged to the State Security Service in Sarajevo?

8 A. The documents that were at the Zlatiste facility included

9 documents from the previous period, and from what I know, a whole truck

10 of documents was taken out of that facility. Yes, yes, I didn't see

11 those documents.

12 Q. Sir, that wasn't my question. I'm directing it specifically to

13 you. Did you take any documents, recordings, or other material that

14 belonged to the State Security Service in Sarajevo?

15 A. I personally did not take any documents because they're official

16 documents.

17 Q. And you say that it would be a crime to remove documentation from

18 the State Security Service; correct?

19 A. That was a crime. Ever since the State Security Service began,

20 not only the State Security Service but also it applies to other services

21 as well.

22 Q. That's understood. My next question: The republican security

23 service in Bosnia worked on the principle of secrecy; correct?

24 THE INTERPRETER: Could the witness please repeat his answer.

25 JUDGE ORIE: Could you please repeat your answer, Witness.

Page 27763

1 THE WITNESS: [Interpretation] This is one of the principles of

2 operation of the state security service, the principle of secrecy.

3 JUDGE ORIE: Before we continue, you said that you personally did

4 not take any documents because they're official documents. Does that

5 also include that you never copied one and kept it for yourself and took

6 it?

7 THE WITNESS: [Interpretation] I did not know anything or have

8 access to the documents that the Prosecutor is referring to. I didn't

9 see it. I had no access to it. I didn't make any copies of these

10 documents that were taken from the Zlatiste facility.

11 JUDGE ORIE: Thank you.

12 Please proceed.

13 MR. WEBER:

14 Q. And just so you know, sir, my question was more broad than that.

15 It wasn't limited to the Zlatiste facility. Is what Judge Orie asked

16 you, would that apply for any documents or recordings? Not just the ones

17 taken from the Zlatiste facility.

18 A. This applies to all the documents of the State Security Service.

19 Q. Okay. Going back to the principle of secrecy which we do

20 understand is one of the bedrocks of your service. The application of

21 this principle meant that information about the methods and the

22 techniques used by a department of the service to obtain certain

23 intelligence was compartmentalised so that individuals would be only

24 aware of the information they were specifically authorised to have;

25 correct?

Page 27764

1 A. That is correct. The principle of secrecy and the way documents

2 are kept was different. The documents were not kept in facilities of the

3 RDB but in some other locations that were secret, some other institutions

4 and other places that had a sufficient system of protection.

5 Q. Okay. Thank you for those explanations. I just want to return

6 to your statement and my question from yesterday. I see do you have a

7 copy of the statement with you.

8 Can you confirm that the matters you discuss up to and including

9 paragraph 96 of your statement concern events that supposedly occurred

10 prior to April 1992?

11 A. I am speaking about those events because they had a crucial

12 effect on what happened after April. The war in Bosnia and Herzegovina

13 did not just break out suddenly.

14 Q. Sir --

15 JUDGE ORIE: Witness, that wasn't the question that was put to

16 you. The question was whether you can confirm that everything, every

17 event found in paragraphs 1 to 96, 96 included, are events which took

18 place before April 1992. That was the question.

19 THE WITNESS: [Interpretation] Yes, I confirm that except for

20 paragraphs 18 and 19, they all do refer to that period.

21 MR. WEBER:

22 Q. Okay, sir, thank you for that clarification. I'll look at those

23 during the next break, those paragraphs. We'll come back to your

24 statement in a little bit. But I want to focus on some other matters

25 with you.

Page 27765

1 MR. WEBER: Could the Prosecution please have 65 ter 31531 for

2 the witness.

3 Q. Sir, before you is a 10 October 1994 RS MUP request from

4 Nedeljko Kesic for an allocation of an apartment to you. In the second

5 paragraph, Mr. Kesic states that you were:

6 "Among the first people in the former State Security Service of

7 the former Bosnia and Herzegovina ... to organise the Serbian personnel

8 in order to oppose the Croatian-Muslim coalition."

9 Before we discuss a number of other materials today I would just

10 like you to answer openly: Could you tell us how you were one of the

11 first organisers of Serbian personnel to oppose the Croatian-Muslim

12 coalition?

13 A. Well, that's the way it's written but I wouldn't agree with that.

14 You know, when requests of this kind are written, then they are written

15 in affirmative way but I would not attach such importance to myself.

16 However, by the nature of my work I was nearby, and I believe that I was

17 part of this group of people who worked on the establishment of

18 Republika Srpska.

19 Q. When you say you were part of the group of people, who do you

20 consider to be part of that group? If you could tell us the names.

21 A. Well, in addition to myself in the State Security Service where I

22 worked, there were a few other colleagues who, in that stage, noticed on

23 time political, military and media preparations for war against the Serbs

24 and --

25 Q. Sorry to cut you off, but I do want to go through things in an

Page 27766

1 efficient manner. If could you just tell us the names of the people that

2 you consider to be part of the group.

3 A. In addition to myself in the State Security Service,

4 Mr. Dragan Devedlaka, Goran Radovic operated in this way as well. I

5 would mention the two of them because, as I've said, at that time they

6 were my two closest co-workers who held high positions. And in the

7 centres of state security there were other colleagues, however, that

8 would be a list that would be somewhat longer. Of course, if I need to

9 list all of them, I have the time to do that.

10 Q. We'll go through and discuss more names so it might be more

11 efficient to just identify them as we go.

12 In the next paragraph it says Mr. Kesic states that you greatly

13 contributed to the creation of the SNB of the RS MUP. Could you explain

14 how you did this?

15 A. Well, precisely this information that I referred to in my

16 statement are part of these activities. As I did my regular work, and as

17 I was in contact with colleagues who were engaged in operative work on

18 the ground, we viewed the overall situation and relations that affected

19 our personal safety and security and the level of imperilment for the

20 people that we represented. We had a professional challenge as well.

21 Not to allow --

22 Q. Sir, you're explaining the circumstances to me, but are there any

23 concrete, direct contributions that you made to the creation of the SNB

24 that you'd like to share with us right now?

25 A. I don't think I did anything important that would affect my

Page 27767

1 contribution in that direction. I just did not accept to be part of the

2 project that was envisaged by those who headed the State Security Service

3 on the Muslim and Croat sides. I didn't want to be an accomplice in that

4 part of the activities involved.

5 Q. All right. We will discuss what I'm going to ask you next a

6 little bit more later, but I see in the same paragraph that Mr. Kesic

7 indicates that you were directly engaged in the organisation of the

8 security detail for Radovan Karadzic. Is it correct that you organised

9 security for Mr. Karadzic and other Bosnian Serb officials throughout the

10 war?

11 A. That was just one stage of my involvement. In view of my job

12 description in the pre-war State Security Service, because I was chief of

13 the department for providing security for persons and buildings - that is

14 to say, persons coming from the Croat, Serb, and Muslim people - when the

15 war started, a number of operatives who were involved in providing

16 security were within my purview. So I dealt with that work directly

17 especially in relation to --

18 Q. If you could just pause there. Finish your sentence:

19 "Especially in relation to ..."

20 A. Radovan Karadzic. During his international political activities

21 and the contacts that he had.

22 Q. Sir, if you could please listen carefully to my questions and I

23 do have follow-up questions which will allow you to provide further

24 detail.

25 Do I understand from your previous answer that you organised

Page 27768

1 security details for Radovan Karadzic and other Bosnian Serb officials

2 prior to April 1992?

3 A. Before April 1992, there was a request to expand the list of

4 persons who were provided with security; namely, the presidents of

5 political parties and the heads of religious communities because their

6 security was being endangered increasingly. That was a decision taken by

7 the Assembly of the Socialist Republic of Bosnia-Herzegovina. It was on

8 that basis that Karadzic was supposed to have security as well.

9 Q. You're speaking in the -- in a certain tense. You say:

10 "Supposed to have security as well."

11 Did you organise, did you personally organise, security details

12 for Radovan Karadzic and other Bosnian Serb officials prior to 1992?

13 A. I personally did not take part in that.

14 Q. In the next -- returning to the document, in the next paragraph,

15 there's reference to your service-related changes of residence between

16 Pale, Belgrade, Bijeljina, and Banja Luka. Is it correct that these are

17 the locations where you were stationed throughout the war?

18 A. Correct.

19 MR. WEBER: The Prosecution tenders 65 ter 31531 into evidence.

20 JUDGE ORIE: Madam Registrar.

21 THE REGISTRAR: Document 31531 receives number P6881,

22 Your Honours.

23 JUDGE ORIE: P6881 is admitted.

24 MR. WEBER:

25 Q. Mr. Vlaski, when you were a witness in the Stanisic and Zupljanin

Page 27769

1 case, is it correct that you identified speakers in a number of

2 intercepted communications involving Radovan Karadzic; do you recall

3 that?

4 A. Of course I recall that.

5 MR. WEBER: Could the Prosecution please have 65 ter 31530 for

6 the witness.

7 Q. Coming up will be an 18 September 1991 conversation between

8 Radovan Karadzic and Trifko Komad which you previously authenticated

9 during a proofing session with the Prosecution on the 14th of February,

10 2010.

11 MR. WEBER: Could the Prosecution actually go to page 3 of the

12 English and page 4 of the B/C/S.

13 Q. Toward the top of the page before you, which is at the bottom of

14 the page in the English, Radovan Karadzic indicates he is meeting with

15 Alija at 2.15 again, and Trifko Komad asks if Rajko is needed there.

16 JUDGE MOLOTO: Can we scroll down the English please.

17 MR. WEBER: Yes, thank you, Your Honour.

18 Q. Do you see this portion?

19 A. I do.

20 MR. WEBER: Could the Prosecution please have the next page of

21 the English version.

22 Q. Radovan Karadzic goes on to state in this conversation:

23 "Yes, I need Rajko and I need some others to get in touch with

24 me. If you can, tell Brana to find them. I need Vlaski and

25 Momo Mandic ..."

Page 27770

1 There's then a discussion of --

2 JUDGE ORIE: Mr. -- you have not read the entirety of this

3 paragraph. And apart from that, what is filled it you just read it as --

4 if that would be the text, that is --

5 MR. WEBER: Okay.

6 JUDGE ORIE: -- "some others and tell," and you left out the last

7 three words.

8 MR. WEBER: "And tell Momo Mandic to call me."

9 Thank you, Your Honours, for bringing that to my attention.

10 Q. There's then a discussion and Devedlaka is also mentioned. Can

11 you please confirm that you are one of the individuals being discussed

12 during this conversation?

13 A. I can confirm on the basis of this transcript that I am being

14 mentioned too.

15 Q. At that time in September 1991, Dragan Devedlaka was one of your

16 subordinates in the 5th Administration of the DB; correct?

17 A. Before that, he was in my department as an inspector, in the

18 department for providing security for persons and buildings, before this

19 date, before September. It was until May.

20 JUDGE ORIE: Witness, the question was at that time in September.

21 So you're not asked to tell what Mr. Devedlaka did before or after that

22 but what he did in September. Was he one of your subordinates in the

23 5th Administration of the DB in September of 1991?

24 THE WITNESS: [Interpretation] He was not my subordinate and he

25 was not in the 5th Administration at this moment, in that period there.

Page 27771

1 JUDGE ORIE: Thank you. Could you tell us what he did in

2 September 1991?

3 THE WITNESS: [Interpretation] In that period, he was assistant

4 head of the State Security Service of Bosnia-Herzegovina.

5 JUDGE ORIE: Please proceed, Mr. Weber.

6 MR. WEBER: Thank you, Your Honour.

7 Q. How did Radovan Karadzic know who you were in September 1991?

8 A. In September 1991, I was proposed and nominated, appointed deputy

9 head of the State Security Service according to a decision made by

10 Minister Alija Delimustafic. Because on the basis of the agreement

11 reached among the political parties involved, this position was allocated

12 to the Serb people. So that is how Radovan Karadzic found out about the

13 personnel appointments and the equal representation of the peoples of

14 Bosnia-Herzegovina on the basis of the census. Especially for top

15 positions.

16 JUDGE MOLOTO: May I just get clarification.

17 MR. WEBER: Sure.

18 JUDGE MOLOTO: Sir, in this position of head of State Security

19 Services, are there two posts, one of assistant and one of deputy; and,

20 if so, what is the difference between the two?

21 THE WITNESS: [Interpretation] According to the rules on internal

22 organisation and job descriptions, there were the following positions:

23 The under-secretary, that is to say, the head of the State Security

24 Service, that was a position that was taken up by a Croat. Then the

25 position of his deputy, the deputy head of the State Security Service.

Page 27772

1 According to the agreement reached among the political parties as one of

2 the important positions, that was allocated to a representative of the

3 Serb people. Whereas within the leadership of the State Security

4 Service, there were two positions, namely, assistant heads of the

5 State Security Service. One was allocated to the Muslims and the other

6 one was allocated to the Serbs, and Mr. Devedlaka held this position at

7 this moment at the time when this transcript came into being.

8 JUDGE MOLOTO: Can we go back to my question. Were there two

9 different posts, a deputy head of State Security Service and an assistant

10 head of State Security; and, if so, what was the difference? Don't tell

11 me about other posts.

12 THE WITNESS: [Interpretation] The difference was because the

13 deputy head could stand in for the head whereas the assistant heads had

14 specific lines of work that they were in charge of. So in terms of work

15 organisation, one assistant head was in charge of operative, technical

16 matters, whereas the other one was in charge of operative work of other

17 departments. So they were co-ordinators.

18 JUDGE MOLOTO: So at the time that this Mr. Devedlaka was the

19 assistant head of state security, you were the deputy head of state

20 security, in September 1991.

21 THE WITNESS: [Interpretation] I was not the deputy but I did

22 receive a decision appointing me to that position. However, I was

23 prevented from assuming that position which is why this political problem

24 was created.

25 JUDGE MOLOTO: Okay. Yes, you were appointed in September 1991.

Page 27773

1 Whatever may have prevented you from taking the position. But at that

2 time you were being appointed as deputy, Devedlaka was the assistant --

3 was the assistant head of the state security.

4 THE WITNESS: [Interpretation] Correct. Correct.

5 JUDGE MOLOTO: Thank you so much.

6 [Microphone not activated]

7 MR. WEBER: Your Honours, I wasn't planning to go much into the

8 structure of the DB but just maybe just to clarify one thing.

9 Q. Sir, is it correct that there was an under-secretary of the

10 State Security Service at the republic level, a deputy for that person,

11 and then individual heads of each of the administrations within the

12 security service?

13 A. So what is the question?

14 Q. Is that correct? Is that how the State Security Service was

15 structured?

16 A. Well, a moment ago I explained that we had a head who was called

17 an under-secretary, that was an anachronism from the previous system.

18 And this head had a deputy head, two assistant heads, and there were the

19 chiefs of the administrations or departments. Yes, so that's correct.

20 Q. Thank you for that explanation. We're on the same page.

21 Going back to September 1991, up until that time, had you ever

22 had any contacts with Radovan Karadzic?

23 A. Well, I think I did not have any official contact or any private

24 contact in that period.

25 Q. I'm not asking you in that period. I'm asking you more

Page 27774

1 generally. Did you know him before September 1991?

2 JUDGE ORIE: If the witness says "that period," I understand him

3 to say the period you mentioned, that is, up until September 1991.

4 MR. WEBER: Right. Which means anytime prior --

5 JUDGE ORIE: So if you say: I'm not asking you in that period,

6 then it's ...

7 Did you have any official or private contact with Mr. Karadzic up

8 to September 1991?

9 THE WITNESS: [Interpretation] I did not have any contact with

10 Mr. Karadzic. Although, from 1975, I was familiar with his activity

11 because he was a subject of the work of the service that I worked for,

12 and I knew everything about him.

13 MR. WEBER: Thank you for the clarification, Your Honours.

14 Q. I just want to go back to this conversation. And a little bit

15 further down on the page, about -- Radovan Karadzic then continues to

16 state in this conversation:

17 "We will be deciding on the MUP today."

18 And then he goes on to say after Mr. Komad speaks:

19 "Yes, yes, we are working on the MUP today. Rajko should be told

20 this, and we are working on the MUP today."

21 Were you contacted regarding this work on the MUP?

22 A. I did not have any contact in view of this situation.

23 Q. Were you aware as to whether Radovan Karadzic wanted to work on

24 the MUP because he wanted to draw up a scheme according to the importance

25 and value of positions to the SDS?

Page 27775

1 A. I knew about that because I felt that problem on my very own

2 skin. As for this part of the schematic, it was part of an inter-party

3 agreement reached and Mr. Rajko Dukic was in charge of that on behalf of

4 the SDS. He was the person who co-ordinated these personnel affairs when

5 the parties that formed the government of Bosnia-Herzegovina had meetings

6 of their personnel commission.

7 MR. WEBER: The Prosecution tenders 65 ter 31530 into evidence.

8 JUDGE ORIE: Madam Registrar.

9 JUDGE MOLOTO: I was just going ask, before we do that, whether

10 the witness did go to Radovan Karadzic as stated here that he was

11 required either to call or to come personally.

12 Did you go as a result of this discussion? Did you either call

13 Mr. Karadzic or did you go to see him?

14 THE WITNESS: [Interpretation] I didn't go to see him. I did not

15 report there because I was aware of the fact that nothing would come out

16 of that. Radovan Karadzic had no influence over personnel policy in the

17 ministry and in the State Security Service. Even the SDS as such did not

18 have any influence there whatsoever.

19 JUDGE ORIE: You tell us that you didn't go there. Did the

20 request reach you to go there?

21 THE WITNESS: [Interpretation] I heard about the request from my

22 colleague Devedlaka.

23 JUDGE ORIE: Thank you.

24 Madam Registrar, the number.

25 THE REGISTRAR: Document 31530 receives number P6882,

Page 27776

1 Your Honours.

2 JUDGE ORIE: Admitted into evidence.

3 MR. WEBER: Could the Prosecution please have 65 ter 31529 for

4 the witness.

5 Q. Sir, coming up before you will be another intercepted

6 conversation from the afternoon of 18 September 1991. This conversation

7 is between Radovan Karadzic and Rajko Dukic.

8 On this first page, we see again that Mr. Karadzic is discussing

9 the 2.15 meeting and then he states:

10 "We have to complete the MUP first and when we are done we will

11 continue working and you can then go. But we have to find out exactly

12 which positions ... firstly, who appoints the staff and, secondly, the

13 arrangement ..."

14 Do you see that portion?

15 A. I do.

16 Q. Just to -- based on your experience in the service, it was

17 apparent by this time that an ethnic balance would have to be reached at

18 the managerial levels of the MUP; correct?

19 A. Ethnic balance was one of the most invaluable principles of the

20 previous communist socialist system of government and the stability of

21 Bosnia-Herzegovina was based on that. So this is just continuity,

22 namely, to honour the ethnic balance and equality of rights of the

23 peoples of Bosnia-Herzegovina everywhere, including this State Security

24 Service. This is a principle upon which Bosnia and Herzegovina was

25 based.

Page 27777

1 Q. With that being said, is it correct that at this time, by

2 September 1991, that the leaderships of the political parties took over

3 and a sort of deal-making or bartering started where the SDS fought for

4 areas of interest which were really not logical at all?

5 A. It is not logical that in September 1991 this question is being

6 raised at all because the government was established after the 1990

7 elections and this process was supposed to be completed very quickly

8 after the government was established. However, because of the unequal

9 position of the representatives of the Serb people, this problem

10 escalated in this period of time, especially in the State Security

11 Service. And when Mr. Karadzic said, as far as my very own case was

12 concerned, that this was the last drop, the straw that broke the camel's

13 back, and he would consider leaving all government posts in

14 Bosnia-Herzegovina and that the SDS would consider becoming the

15 government opposition in Bosnia-Herzegovina.

16 Q. We'll come back to that, I think, after the recess.

17 MR. WEBER: The Prosecution tenders 65 ter 31529 into evidence.

18 And, Your Honours, this is a good time for the Prosecution to break if

19 you like.

20 JUDGE ORIE: Madam Registrar.

21 THE REGISTRAR: Document 31529 receives number P6883,

22 Your Honours.

23 JUDGE ORIE: Admitted into evidence.

24 Witness, we'll take a break of 20 minutes and we'd like to see

25 you back after that.

Page 27778

1 [The witness stands down]

2 JUDGE ORIE: Mr. Lukic, before we take that break, there's some

3 confusion about the deadline you asked for to be extended. Now we

4 extended it, but could you again tell me exactly what the deadline was

5 about. Is it about the request for leave to reply?

6 MR. LUKIC: I think so.

7 JUDGE ORIE: Yes. Well, that deadline did not expire today but

8 it expired on the 30th of October. But it is extended anyhow --

9 MR. LUKIC: Okay, thanks. I calculated somehow that it should

10 expire today.

11 JUDGE ORIE: Yes. Well, at least Chambers' staff thinks that it

12 expired on the 30th of October. Let's not make a drama out of it.

13 There's no opposition from the Prosecution. We'll just --

14 MR. LUKIC: I apologise if I made a mistake.

15 JUDGE ORIE: It's extended as we decided before.

16 We'll take a break, and we'll resume at five minutes to 11.00.

17 --- Recess taken at 10.32 a.m.

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

19 JUDGE ORIE: Mr. Weber.

20 MR. WEBER: Your Honours, if I may, the Prosecution -- the next

21 document it's going to call up is 65 ter 20261.

22 [The witness takes the stand]

23 THE REGISTRAR: Your Honour, there is no translation available

24 for this document.

25 [Prosecution counsel confer]

Page 27779

1 THE REGISTRAR: It's available now.

2 JUDGE ORIE: Please proceed.

3 MR. WEBER: Your Honours, to follow your line, thank you to

4 everyone in and around the courtroom, including Ms. Stewart.

5 Q. Welcome back, Mr. Vlaski. Before you is another intercepted

6 conversation which you previously authenticated during a meeting with the

7 Prosecution on 3 June 2009. And I see you're nodding your head. It is a

8 conversation between Radovan Karadzic and Miodrag Simovic from

9 17 September 1991, a day before the last two conversations we looked at.

10 In this conversation, about halfway through the first long

11 answer, Radovan Karadzic states:

12 "Tonight at 8.00, I am going to break up with Izetbegovic. I am

13 withdrawing everything, Serbian Democratic Party into opposition. We are

14 doing [sic] dis to break apart and then we're going to establish our own

15 SUP separately with other men, without ... and we'll make the government

16 separately, we'll make everything separately."

17 My question: Was this what you were talking about before the

18 break, that the SDS would consider becoming the government opposition in

19 Bosnia-Herzegovina?

20 A. That is precisely something that reflects the social reality in

21 Bosnia and Herzegovina at that time, humiliation, over-voting, violating

22 the constitution in the assembly, the procedure. This was something that

23 was happening to such an extent in all the institutions prompting

24 Mr. Karadzic to have this reaction.

25 JUDGE ORIE: You were not asked what made Mr. Karadzic decide

Page 27780

1 this but you were asked whether this is the development you talked about

2 earlier. And I do understand that you confirm that.

3 THE WITNESS: [Interpretation] I confirmed that earlier. This was

4 just a comment to my previous statement.

5 JUDGE ORIE: Do not comment if no request for further comments

6 are put to you.

7 Please proceed, Mr. Weber.

8 MR. WEBER: Thank you, Your Honours.

9 Q. In this same discussion, right before the part that I read,

10 there's reference to "Vlaski was removed from his office and it is over."

11 Just so we have clarification, is it correct that that is a

12 reference to you?

13 A. Yes.

14 Q. Is it correct that you no longer performed your duties at the

15 republican MUP of Bosnia-Herzegovina between mid-September 1991 and the

16 beginning of 1992?

17 A. I was performing my duties. For a time, I was not deployed in

18 any specific position, but then I was working in the 1st SDB

19 Administration. This was in early 1992.

20 If I can explain, then I can just tell you what happened about

21 all of this.

22 Q. We're going to go and discuss early 1992. But just so I could

23 have clarification, between mid-September 1991 and you taking up your

24 position in the 1st SDB Administration in early 1992, is it correct that

25 you did not perform your duties in the Bosnian MUP between that time?

Page 27781

1 You didn't go to work during that time; right?

2 A. I went to work regularly. However, I didn't have any specific

3 tasks. The decision that I received remained in force, and I received my

4 salary on the basis of that decision. I spent my work hours in the

5 office of Mr. Devedlaka.

6 Q. Okay. Thank you for that clarification.

7 MR. WEBER: The Prosecution would tender this intercept into

8 evidence.

9 JUDGE ORIE: Madam Registrar.

10 THE REGISTRAR: Document 20261 receives number P6884,

11 Your Honours.

12 JUDGE ORIE: Admitted.

13 MR. WEBER:

14 Q. Mr. Vlaski, is it correct that you attended a meeting on

15 11 February 1992 in Banja Luka with Momcilo Mandic, Mico Stanisic,

16 Stojan Zupljanin, and Zoran Zugic, among others? I see you're nodding

17 your head but if could you please answer.

18 A. Goran Zugic. Yes, I was present at the meeting.

19 Q. This meeting was held at the Bosna hotel; correct?

20 A. Correct.

21 Q. Is it correct that the minutes of the meeting were taken by

22 Igor Velasevic, who was a lawyer at that time, a young lawyer

23 specifically?

24 A. Igor Velasevic was a member of our service. He was employed at

25 the MUP. I think that later he worked as a lawyer. I don't know what

Page 27782

1 happened afterwards.

2 Q. All right.

3 MR. WEBER: Could the --

4 MR. LUKIC: If I just --

5 JUDGE ORIE: One second --

6 MR. LUKIC: [Overlapping speakers] -- clear the confusion.

7 "Lawyer" in our language is only somebody who has private practice and

8 has bar exam. And we have different term for somebody who is working in

9 companies or -- or in MUP or somewhere else.

10 JUDGE ORIE: Yes, okay.

11 MR. WEBER: Okay.

12 JUDGE ORIE: Did you want to tell us that he was -- that

13 Igor Velasevic later acted as a lawyer in his own law firm?

14 THE WITNESS: [Interpretation] The Prosecutor said "lawyer," but

15 he was actually working on legal affairs in our service.

16 JUDGE ORIE: And later on, he went into private practice as a

17 lawyer?

18 THE WITNESS: [Interpretation] I don't know that.

19 JUDGE ORIE: Please proceed.

20 MR. WEBER: Could the Prosecution please have Exhibit P3208

21 [Realtime transcript read in error "P3028"] for the witness.

22 Q. Sir, coming up will be the minutes of the meeting in Banja Luka

23 on 11 February 1992. I know those minutes have been shown to you before.

24 I was wondering if you could just take a look at them and confirm that

25 these are the minutes of the meeting you attended?

Page 27783

1 JUDGE MOLOTO: Sorry, Mr. Weber, what is the P number?

2 MR. WEBER: It's P3208.

3 JUDGE MOLOTO: Thank you. At least it will be corrected now.

4 MR. WEBER: Thank you, Your Honour.

5 JUDGE ORIE: Can you confirm that these are the minutes of the

6 meeting you attended?

7 THE WITNESS: [Interpretation] Yes, these are the minutes.

8 MR. WEBER: Could the Prosecution please have page 5 of the B/C/S

9 original and page 3 of the English translation.

10 Q. On this page, we see that you spoke at this meeting, and you

11 started with the comment:

12 "We must work out how to carry out the decisions from this

13 meeting. The only way would be to organise the Serbian MUP and implement

14 all the decisions without questions -- without question."

15 Can you confirm that this is what you said during the meeting?

16 A. Yes, I did say that.

17 Q. Do I understand correctly from this statement that you were in

18 support of all the conclusions that were reached at this meeting?

19 A. I did support the conclusion in the domain of my service. As for

20 those that referred to the work of other participants, I did support them

21 in the political sense, but I did not go into any kind of detailed

22 analysis of that.

23 MR. WEBER: Could the Prosecution please have page 6 of the B/C/S

24 and page 4 of the English translation.

25 Q. I want to discuss further with you the conclusions that were

Page 27784

1 reached at this meeting.

2 Under conclusion 1 it is stated:

3 "A Serbian collegium is hereby established in the SRBH MUP,

4 consisting of Serbian personnel at executive positions in all the lines

5 of work within the SRBH MUP."

6 Were you one of these people that received an executive position

7 in the Serbian collegium?

8 A. We did not have any functions. We were the personnel of Serbian

9 ethnicity in the MUP of the Socialist Republic of Bosnia-Herzegovina who

10 were supposed to represent the interest of the Serbian people within a

11 joint MUP. The interests of the Serbian people that were under threat at

12 that time.

13 Q. My question --

14 A. So this was just the Serb collegium.

15 Q. Yes. My question was: Did you receive an executive position in

16 the Serb collegium?

17 A. No executive positions were given. We were just representatives

18 of the Serb collegium by nature of our ethnicity. We were

19 representatives of the Serbian people and we were working jointly in the

20 collegium as Serbs. We were supposed to form some kind of consultative

21 body made of up of ethnic Serbs but it did not have any kind of executive

22 function.

23 Q. Okay.

24 JUDGE ORIE: Mr. Weber, is there any chance that there's any

25 confusion about how the words "executive positions" are used here?

Page 27785

1 MR. WEBER: It's possible --

2 JUDGE ORIE: From your question --

3 MR. WEBER: It's possible.

4 JUDGE ORIE: From your question, I understand that you read it as

5 the members of the collegium being appointed at executive positions

6 within that collegium. Whereas another way of reading it would be that

7 those in executive positions and being Serbs would become members of the

8 collegium.

9 MR. WEBER: Your Honour, I think you're right. And I'm happy to

10 rephrase that way.

11 JUDGE ORIE: Yes. Well, I think the witness more or less in his

12 answer has --

13 MR. WEBER: If I misunderstood, yes --

14 JUDGE ORIE: -- but there's a chance that you read it in two

15 different ways. I do understand that you now take the position that it

16 should be understood as those who were in executive positions in the SRBH

17 MUP and were Serb, that they would become members of the Serbian

18 collegium.

19 MR. WEBER: I actually appreciate your clarifications.

20 JUDGE ORIE: Yes. Please proceed.

21 MR. WEBER:

22 Q. Under conclusions 2 and 3, the minutes indicate that

23 Momcilo Mandic will manage the Serbian collegium and all staffing

24 policies cannot be implemented without his approval.

25 This was agreed upon at the meeting; correct?

Page 27786

1 A. This was some sort of desperate need to protect the rights and

2 the interests of the Serbian personnel in the MUP in this way and to then

3 place that under the responsibility of some person in a leading position,

4 and Momcilo Mandic was thought to be such a person at that time.

5 Q. Sir, you're giving me explanations. That was what was agreed

6 upon at this meeting; correct?

7 A. Yes. You can see that on the basis of the conclusion, that this

8 is something that was agreed upon.

9 MR. WEBER: Could the Prosecution please have the next page in

10 the B/C/S and stay on the same page in the English.

11 Q. I just want to go quickly over some of the other items. Under

12 conclusion 13, there's reference to:

13 "Ensuring liaison and providing assistance to the Republic of

14 Serbian Krajina."

15 Did this collegium co-ordinate at all with Milan Martic, the RSK

16 minister of the interior?

17 A. I don't think that at that point in time there were any

18 indications of any sort of co-ordination, at least as far as this makeup

19 is concerned. I don't know if any of the people involved from the area

20 of Banja Luka had any contacts with him.

21 Q. Prior to this meeting, is it correct that you had gone to

22 Belgrade to seek the assistance of Radmilo Bogdanovic, the former head of

23 the Serbian MUP, and Jovica Stanisic, the chief of the Serbian DB?

24 A. My colleague Devedlaka and I did go to see Mr. Radmilo Bogdanovic

25 but we did not go to see Jovica Stanisic because at that time,

Page 27787

1 Mr. Zoran Janackovic was the one who was heading the RDB.

2 Q. Okay. So based on the timing that you've given, is it correct

3 that your visits to Radmilo Bogdanovic would have then been before he

4 left office in May of 1991?

5 A. Yes, yes.

6 Q. And Mr. Stanisic was a member of the Serbian DB, and did you go

7 see him after his official appointment after Mr. Janackovic left at the

8 outset of 1992?

9 A. I did not have any contacts with Mr. Stanisic.

10 Q. Under conclusion number 16 --

11 MR. WEBER: If we could go -- actually, we need the next page of

12 the English translation.

13 Q. Under conclusion 16, the minutes state:

14 "Work intensively to train and arm our police personnel."

15 Is it correct that this refers to arming Serb police personnel?

16 A. If I read the conclusion literally, this is talking about the

17 training and arming of our police personnel, meaning Serb police

18 personnel, because in the previous period, an imbalance was recorded,

19 both in the training and arming of the Serb contingent of personnel in

20 the Ministry of THE Interior.

21 Q. Sir, I'm -- if could you answer my questions and please listen

22 carefully. I do want to try to conclude you today.

23 I want to change topics and discuss the barricades with you in

24 Sarajevo in March. Can you confirm that you were aware of the setting up

25 of barricades in Sarajevo between the 1st and the 4th of March, 1992?

Page 27788

1 A. I did not have any information about the setting up of the

2 barricades until the actual moment that they were erected. It was a

3 Sunday that day, and I was skiing at Mount Bjelasnica.

4 Q. And just so we have a clear record of that, the Sunday that you

5 were skiing, was that the 1st of March?

6 A. Yes, it was the 1st of March.

7 Q. Is it correct that you learned of the barricades being erected in

8 Sarajevo from Djordje Kapor, one of your colleagues who was providing

9 security for Mr. Karadzic in Belgrade at the time?

10 A. Correct, he was the first person to inform me about it.

11 Q. Is it correct Mr. Kapor called you to inform you of this?

12 A. Yes. He called me from Belgrade. I was at my apartment.

13 Q. When Mr. Kapor called you, did he convey to you a message from

14 Radovan Karadzic?

15 A. Yes. He told me what the problem was in Sarajevo after the

16 killing of the Serbian best man in the wedding party.

17 Q. Were you informed that Mr. Karadzic wanted you to go down to the

18 Deputies Club?

19 A. Yes, that was the point of the whole conversation, and to

20 assemble.

21 Q. Who was Radovan Karadzic meeting with in Belgrade at the time?

22 A. I don't know who he was with in Belgrade. I was -- I myself was

23 in Sarajevo.

24 Q. Okay. After you received these instructions, is it correct that

25 you then went to the Deputies Club on Djuro Djakovic Street?

Page 27789

1 A. It's correct. There were other colleagues there besides me, so

2 based on that, you could call it the Serb collegium.

3 Q. Okay. Just so we have some date context, did you receive this

4 call and go to the Deputies Club on the 1st or 2nd of March, 1992?

5 A. I think that this was on the 1st of March. It was the same day,

6 after the killing of the person from the Serbian wedding party.

7 Q. The Deputies Club was the official premises used by the deputies

8 of the Serbian Democratic Party; correct?

9 A. Well, for the most part, all the clubs of national parties had

10 their own premises where they gathered. The club of the Serb deputies

11 was in this area.

12 Q. Okay. And that's where you went; correct?

13 A. I went then, but otherwise I did not go to that area.

14 Q. After you went to the Deputies Club, is it correct that you were

15 then told to go to the Holiday Inn?

16 A. It's not whether it was said. It's -- it was the conclusion that

17 it was not appropriate for taking measures that followed later. I mean

18 political measures.

19 Q. When you say "it was the conclusion," whose conclusion was this?

20 A. Well, joint conclusion. Most participants assessed that for

21 security reasons this area was not a place where one could stay longer.

22 Q. Okay. When you went to the Holiday Inn, did you meet there with

23 Rajko Dukic and Velibor Ostojic?

24 A. Precisely. On the premises that Mr. Dukic used as the office of

25 his company, that's where this meeting was held.

Page 27790

1 Q. And this was in the Holiday Inn?

2 A. Correct.

3 Q. Is it correct that Mico Stanisic, Dragan Kijac, Dragan Devedlaka,

4 and Momo Mandic were also at the Holiday Inn on this occasion?

5 A. All the mentioned persons were at the Holiday Inn. Along with

6 some other individuals.

7 MR. WEBER: Could the Prosecution please have Exhibit P6634 for

8 the witness. The Prosecution is looking for page 2 of the B/C/S original

9 and page 3 of the English translation.

10 Q. Sir, coming up before you is a Socialist Republic of BiH MUP

11 report on the -- on information about the setting up of barricades in

12 Sarajevo in early March 1992.

13 Under item 1, there's information that Momo Mandic was in command

14 at the barricade on the Vrbanja bridge and the deputy commander was

15 Dragisa Kujacic. Is it correct that Mr. Kujacic was also present at the

16 Holiday Inn when you went there?

17 A. I didn't know him personally, but I was aware of the fact that it

18 had to do with some criminal?

19 Q. I have -- it sounds like you ended your last answer with a

20 question. It's not clear what you meant by "some criminal"? Did you --

21 did you want to clarify anything?

22 A. Well, I cannot clarify because, I mean, I was not involved in

23 this kind of work in the MUP and also I am not familiar with these roles,

24 commander or deputy commander of barricades. I was not aware of the fact

25 that there was some kind of hierarchy even then.

Page 27791

1 Q. Okay.

2 MR. WEBER: Well, could we go to page 5 in both versions of this

3 document.

4 Q. On this page, the report lists five individuals who were engaged.

5 It indicates that Mico Stanisic and Momo Mandic were giving instructions

6 to people in the field. Did Stanisic and Mandic provide instructions or

7 reach any conclusions about the setting up of the barricades at the

8 Holiday Inn while you were present?

9 A. At that moment, as far as I know, agreements were not being

10 reached on the barricades. Rather, the point of this Crisis Staff was a

11 political message to the Presidency of Bosnia-Herzegovina. How to have

12 this situation overcome. The barricades were a spontaneous reaction on

13 the ground.

14 Q. Sir, did you yourself man barricades?

15 A. I was not at the barricades, and I didn't even visit. But I

16 passed through barricades.

17 Q. Okay. Is it correct that after the barricades were set up by the

18 Serbs, that the Bosnian Muslims then set up their own barricades?

19 A. That is correct. However, in this report, this information is

20 not contained.

21 Q. Okay. That's why I was asking it for -- from you, sir. Just so

22 there is no confusion here eventually with this report, it says that --

23 it appears to refer to you, that Nedjo Vlaski was wounded by fire-arms

24 and he was hospitalised. Is it correct that this was a self-inflicted

25 wound that did not occur at the barricades?

Page 27792

1 A. It wasn't at the barricades but it had to do with the barricades

2 because I passed through two Muslim barricades and I was armed. And in

3 the weapon, there was a bullet that, due to certain circumstances,

4 happened to hit me in the leg or foot.

5 Q. And that was a bullet from your own gun; correct?

6 A. Yes.

7 MR. WEBER: At this time, I'm actually going to move off this

8 document, and I'm going to ask Ms. Stewart to play 65 ter 31014 for the

9 witness. And if we could actually, maybe just for time efficiency, go to

10 the 35-second mark.

11 Q. Sir, this is a video dated 30 March 1992, and I'm now going to

12 play it. If you could please watch it.

13 MR. WEBER: If we could play if from the 35-second mark and pause

14 at 49 seconds. And there's no translation that is necessary for this

15 part of the clip.

16 JUDGE ORIE: So no audio.

17 MR. WEBER: There's no speaking.

18 JUDGE ORIE: No speaking. Okay. That's -- no spoken words.

19 Please proceed.

20 [Video-clip played]

21 MR. WEBER: And we're now paused at the 49-second mark.

22 Q. Sir, in this clip we saw that there was a gentleman in a grey

23 overcoat and tie. Is it correct that that person is Mico Stanisic?

24 A. Correct.

25 Q. Now in this clip, we saw that there were individuals in

Page 27793

1 camouflage uniforms and berets. Is it correct that those are members of

2 the Bosnian Serb MUP?

3 A. These were active members of the MUP of Bosnia-Herzegovina. This

4 is Mr. Zoran Cvijetic, as far as I can see in this footage.

5 Q. You've mentioned Mr. Zoran Cvijetic. Is he the person who is

6 currently partially obscured in the lighter colour overcoat in this video

7 or is he the man in the camouflage in the -- to the left of Mr. Stanisic?

8 A. The person in camouflage uniform, as far as I know, is

9 Mr. Cvijetic, although the face is not very clear here.

10 JUDGE ORIE: Mr. Weber --

11 MR. WEBER: Yes.

12 JUDGE ORIE: -- one of your previous questions has been answered

13 in an ambiguous way.

14 MR. WEBER: I defer to Your Honour.

15 JUDGE ORIE: You asked the witness whether these are members of

16 the Bosnian Serb MUP. Now the witness answered by saying:

17 "These were active members of the MUP of Bosnia and Herzegovina."

18 Were these all Serbs?

19 THE WITNESS: [Interpretation] I suppose. I don't know who was

20 lined up. I suppose they are Serbs.

21 JUDGE ORIE: Yes. And under the circumstances on the

22 30th of March, at such an occasion, you would only find active Serb

23 members of the MUP of Bosnia-Herzegovina to be lined up like this?

24 THE WITNESS: [Interpretation] Well, that was already the moment

25 when there was a division in the Ministry of the Interior.

Page 27794

1 JUDGE ORIE: Yes.

2 Please proceed.

3 MR. WEBER: If we could go to the 3 minute, 40 second mark in the

4 video-clip and pause the video at that point.

5 [Video-clip played]

6 MR. WEBER:

7 Q. I'm going play this for about four seconds, sir, so you can see

8 the images because I see it's a little bit blurry when we have it paused.

9 MR. WEBER: I'm go to ask Ms. Stewart to play to 3 minutes,

10 44 seconds.

11 [Video-clip played]

12 MR. WEBER: Okay.

13 Q. Sir, we see that there are individuals in a different type of

14 uniform, a blue uniform. Similar question as before: Were those Serb

15 members of the MUP?

16 A. I suppose. I don't have any reliable proof on the basis of which

17 I can claim that there were no other persons of different ethnicity

18 there, but this is what I assume.

19 Q. Okay. I'm now going to actually go to Mr. Stanisic's comments on

20 this occasion.

21 MR. WEBER: Your Honours, a lot of the other video is just the

22 procession of individuals back and forth and an oath being administered

23 by Mr. Cvijetic, so I'm going to skip ahead to Mr. Stanisic's comments at

24 4 minutes and 3 seconds.

25 JUDGE ORIE: But, nevertheless, do the parties agree on what kind

Page 27795

1 of an oath was it? To be loyal to the Serb or to the MUP or to the ...

2 is there any ...

3 MR. WEBER: There's the translation uploaded of it. I can read

4 the oath in. It does refer to the constitution of the Serbian Republic

5 of the Bosnia-Herzegovina and the Serbian Republic of Bosnia-Herzegovina

6 is again repeated.

7 JUDGE ORIE: If there's any dispute about that, we'd like to

8 hear.

9 Now, when you earlier said, "I don't know whether there were any

10 people of other ethnicities there," when you were asked about the blue

11 uniforms, but the uniforms themselves, they were of -- of the Serbian

12 MUP?

13 THE WITNESS: [Interpretation] The SUP -- the Serb MUP did not

14 have uniforms then. These were uniforms that were used by the active and

15 reserve policemen. I saw the uniforms there. Possibly Mr. Cvijetic had

16 some kind of insignia but it is rather blurred and I didn't see it very

17 clearly. Otherwise this is the first time I'm watching this.

18 JUDGE ORIE: Yes. But it is -- when you say "were used by active

19 and reserve policemen," you mean active and reserve policemen of Serbian

20 ethnicity, of the Serbian --

21 THE WITNESS: [Interpretation] Well, the joint police used the

22 same uniforms because up until this moment, the 30th of March, all of

23 these persons, who I assume were there for this lineup, were part of the

24 regular MUP, either active duty or reserve.

25 JUDGE ORIE: At the same time, you -- earlier when I put to you a

Page 27796

1 question focused very much on this matter, what you would expect people

2 to be lined up, you said: It was after the -- there was a division

3 already in the Ministry of Interior. So you then explained that what we

4 see is for that reason most likely Serbian, whereas now asked about these

5 uniforms on the same day, you see -- you say it could be the joint police

6 forces. That is -- there's some friction between the two.

7 Could you explain why you are having more reservations as far as

8 the uniforms you saw being worn by Serb police officers?

9 THE WITNESS: [Interpretation] Well, on the uniforms, it doesn't

10 say who is a Serb, who is a Bosniak, who is a Croat. Everybody wore the

11 same uniforms when they worked in the previous joint MUP, in the previous

12 joint institutions. There was a similar situation as far as uniforms are

13 concerned. Only insignia were changed on caps, on epaulettes and so on.

14 We did not have the resources, I mean, to change uniforms for the entire

15 force, for the sake of this kind of situation, when there would be a

16 lineup, a review or oath-taking.

17 JUDGE ORIE: But if I understand you well, you're saying the

18 setting is such that there should be no more doubt as whether those

19 wearing uniforms there were Serbs than compared to what you said earlier.

20 THE WITNESS: [Interpretation] Well, I assumed that they were

21 Serbs.

22 JUDGE ORIE: Please proceed.

23 MR. WEBER: Your Honour, I'm going to ask Ms. Stewart to play the

24 remainder of the clip. I believe transcripts have been disseminated to

25 the booths, and there is audio for this portion.

Page 27797

1 JUDGE ORIE: So we need to play it twice.

2 [Video-clip played]

3 MR. WEBER: And, Your Honours -- Your Honours, this time the

4 Prosecution is going to play it the second time

5 JUDGE ORIE: Please do as you suggest.

6 [Video-clip played]

7 THE INTERPRETER: [Voiceover] "As of today, the Serbian Republic

8 of Bosnia-Herzegovina has its own police force. The legality of our

9 existence is provided by the constitution of the Assembly of the Serbian

10 Republic of Bosnia-Herzegovina and the Law on Internal Affairs recently

11 adopted by the Assembly at its session. Moreover, the legality of our

12 existence is based on the result of negotiations of the three ethnic

13 communities under the auspices of the European community. As of today,

14 we will act as the police of the Serbian Republic of Bosnia-Herzegovina

15 which will carry out its tasks and assignments professionally and not

16 politically, as the MUP of the old Bosnia and Herzegovina has done so

17 far, in order to protect property, life, body, and overall security of

18 all citizens in the Serbian Republic of Bosnia-Herzegovina equally.

19 "Members of the police, we are not involved in politics. We must

20 carry out our tasks professionally. Therefore, long speeches do not

21 belong to us, but as of today, good luck, get to work, in the interest of

22 all who live in the territory of the Serbian Republic of

23 Bosnia-Herzegovina. Thank you."

24 MR. WEBER:

25 Q. Sir, I think you've alluded to this already, but can you confirm

Page 27798

1 that as of the 30th of March, 1992, that the Serbian Republic of

2 Bosnia-Herzegovina had its own police force?

3 A. Well, this was just a public manifestation of that act. Its

4 existence was defined in the constitution and the Law on Internal Affairs

5 as was stated at this gathering. The law and the constitution of the

6 Serb Republic of Bosnia-Herzegovina.

7 Q. And that constitution and law were passed on the 28th of

8 February, 1992; correct?

9 A. That is the sequence of events that preceded this.

10 Q. Aside from Mr. Cvijetic who you've previously mentioned, did you

11 recognise any of the other individuals who were present on the stage with

12 Mr. Stanisic?

13 A. I recognised Mr. Cicko Bjelica whom I do not know personally, but

14 I recognised him in this footage because he was a Member of Parliament

15 and some SDS functionary.

16 MR. WEBER: The Prosecution at this time tenders 65 ter 31014

17 into evidence.

18 [Trial Chamber and Registrar confer]

19 MR. WEBER: I believe Ms. Stewart does have CDs available.

20 JUDGE ORIE: Madam Registrar, now having received the CDs, what

21 number would be assigned?

22 THE REGISTRAR: Document 31014 receives number P6885,

23 Your Honours.

24 JUDGE ORIE: Admitted into evidence.

25 MR. WEBER: Could the Prosecution please have 65 ter 31533 for

Page 27799

1 the witness.

2 Q. Sir, coming up is an 30 April 1992 SRBiH MUP list of employees of

3 the Trnovo police station. You are the first person on this list which

4 indicates that you were the chief of the Trnovo police station. Is it

5 correct that you held this position in April and early May 1992?

6 A. I was never the chief. I don't know who compiled this list.

7 However, at that moment, due to that circumstance, the fact that I was

8 wounded, I was in the area because this is where I was born.

9 Q. Okay. Well, did you have any activities related to the Trnovo

10 police in April and May 1992?

11 A. I did not carry out any activities at the station, but I was

12 involved in the peace council that was established in the municipality of

13 Trnovo because I was a colleague of the head of that station at the time

14 of the joint service, I mean, the joint MUP of Bosnia-Herzegovina,

15 Mr. Godinjak. I worked with Edo Godinjak for many years. So I was

16 involved in that sense, in the area of this municipality.

17 Q. Okay. And, sir, I want to be fair to you and we had two

18 different lists that related to this police station so I do want to show

19 you the other one.

20 MR. WEBER: Could the Prosecution please have page 3 of the B/C/S

21 and page 4 of the English translation.

22 Q. This is an SRBiH MUP CSB Trnovo list of active police workers who

23 carried out duties during the month of April 1992. You are the first

24 person again on the list. And the document indicates that you were paid

25 out in the SNB. Is it correct that you were a member of the SNB as of

Page 27800

1 April 1992?

2 A. That is correct. However, due to the fact that I was wounded for

3 a while, I was in that area for 15, 20 days, and these colleagues from

4 the public security station of Trnovo put me there for the sake of

5 continuity so that I could get this compensation that our ministry was

6 paying anyway, of the Serb ministry. However, as is stated here, I was

7 paid through the SNB where I was assistant head.

8 Q. Are those your initials or signature on that first line to the

9 far right, under the fifth column? Are you able to see them?

10 A. This is the first time I see this document. I never signed

11 anything on this list.

12 Q. Okay. With respect to the --

13 JUDGE ORIE: Could -- could I -- you say you never signed. Does

14 this appear to be your signature or is your signature entirely different

15 from this one? It could be a forgery produced by someone else, but does

16 it resemble in any way your signature?

17 THE WITNESS: [Interpretation] My signature is not here. It is

18 noted that I was paid out in the SNB, meaning that the salary was paid

19 due to my affiliation with the service.

20 JUDGE ORIE: Yes. You have still not answered my question. That

21 is, whether what appears here in column 5, whether that resembles or does

22 not resemble your signature.

23 THE WITNESS: [Interpretation] No, I don't see my signature

24 anywhere here.

25 JUDGE ORIE: And nothing that looks like your signature either?

Page 27801

1 THE WITNESS: [Interpretation] No, nothing like that. I did not

2 sign anything on a document of this kind, ever.

3 JUDGE ORIE: You apparently are very insistent on answering your

4 own question rather than mine. But I take it that what appears on this

5 document is not similar to what is your signature.

6 Please proceed.

7 MR. WEBER:

8 Q. And, sir, you've acknowledged that you were paid out from the SNB

9 at this time. Is it correct that someone could have just simply signed

10 for you on your behalf?

11 A. From what I can see, there is no signature here. It's just a

12 colon.

13 MR. LUKIC: I have to intervene. It says, I will spell, i-s-p-l.

14 JUDGE ORIE: One second, please. One second.

15 Mr. Lukic, you intervened when the previous translation was still

16 continuing. Apparently you wanted to bring something to our attention.

17 MR. LUKIC: Yes. It says, I will spell, i-s-p-l, which is

18 shortened for "isplacen," paid, and it's not the signature.

19 MR. WEBER: Okay.

20 JUDGE ORIE: Yes, well, in the --

21 MR. LUKIC: In English translation it's --

22 JUDGE ORIE: Well, you -- at this moment you are giving evidence.

23 But if that what is means, then I take it that you could easily agree

24 with the Prosecution on that and then it's taken for a fact.

25 MR. WEBER: Okay.

Page 27802

1 Q. My next question, sir, is: On both these lists, Rade Ivanovic is

2 also mentioned. Could you please tell me what your relationship was like

3 with Rade Ivanovic in April and early May 1992?

4 A. Rade Ivanovic was the chief of the public security station. Due

5 to the circumstances of my wounding, I was in Trnovo at the time, so we

6 were in touch. I can also say that he was my teacher in elementary

7 school as well.

8 MR. WEBER: Your Honour, the Prosecution would tender the

9 document at this time. And I believe it's again time for a break.

10 JUDGE ORIE: Madam Registrar.

11 THE REGISTRAR: Document 31533 receives number P6886,

12 Your Honours.

13 JUDGE ORIE: And is admitted into evidence.

14 We take a break. Witness, would you please follow the usher.

15 [Trial Chamber confers]

16 [The witness stands down]

17 JUDGE ORIE: Mr. Weber, are you on track as far as time is

18 concerned?

19 MR. WEBER: I will verify during the break as to where I'm at,

20 but I believe so, yes.

21 JUDGE ORIE: Yes. So that we can also give an assessment as

22 whether the next witness would have to remain standby, yes or no.

23 Mr. Lukic, if you would also --

24 MR. LUKIC: Till now, I don't have much.

25 JUDGE ORIE: You don't have much.

Page 27804

1 JUDGE ORIE: Yes. In relation to matters still to be raised.

2 MR. WEBER: That I'm going to be discussing this session.

3 [The witness takes the stand]

4 JUDGE ORIE: Mr. Vlaski, the Prosecution has invited me to bring

5 a Rule to your attention, which I'll do now. That's Rule 90(E) of the

6 Rules of Procedure and Evidence. I'll read the Rule for you:

7 "A witness may object to making any statement which might tend to

8 incriminate the witness. The Chamber may, however, compel the witness to

9 answer the question. Testimony compelled in this way shall not be used

10 as evidence in a subsequent prosecution against the witness for any

11 offence other than false testimony."

12 Which means that you, as a witness, if you think that a truthful

13 answer to any question might tend to incriminate you, you can address me

14 and asked to be relieved from your obligation to answer that question,

15 and we'll then further consider that.

16 I don't know what questions Mr. Weber will put to you, but it's

17 good practice in this courtroom that at the request of one of the

18 parties, I inform the witness about this Rule, which I have done now.

19 Mr. Weber, please proceed.

20 MR. WEBER:

21 Q. Mr. Vlaski, is it correct that you and Mr. Rade Ivanovic attended

22 meetings of the Trnovo SDS Municipal Board Crisis Staff?

23 A. I attended perhaps one or two such meetings, but not as a member

24 of the staff but more as an observer and a guest, as a person who was

25 working on security issues.

Page 27805

1 Q. Is it correct that you do not mention your involvement with this

2 Crisis Staff at all in your statement?

3 A. I did not consider it important because there was nothing of

4 particular interest at the meetings.

5 MR. WEBER: Could the Prosecution please have 65 ter 31532 for

6 the witness.

7 Q. Sir, coming up before you will be a series of minutes from the

8 Trnovo Crisis Staff from late April to 11 May, 1992. The first minutes

9 appearing before you are from 29 April 1992, and they indicate that you

10 were present.

11 A. Yes, I was present at this meeting.

12 Q. Could you tell us where this meeting took place.

13 A. It was held at the Hotel Treskavica as far as I can recall.

14 Q. I'm going to skip down to the first part where Radivoje Draskovic

15 speaks and states:

16 "We need to make lists together with company commanders to see

17 who failed to respond and make a list together with the local boards, who

18 left the place and who arrived from elsewhere."

19 Is it correct that Mr. Draskovic was the president of the

20 Trnovo Crisis Staff?

21 A. He was the president of the SDS, and I don't know whether that

22 made him also the president of the Crisis Staff. I didn't pay attention

23 to that.

24 Q. Okay. Sir, I want you to be able to read along here.

25 MR. WEBER: If we could slide down, please, in the B/C/S version.

Page 27806

1 And in the English version we see that there's discussion about

2 Kalinovik, and then could we have the next page of the English

3 translation.

4 Q. On this next page, after there's discussion of Kalinovik,

5 Mr. Draskovic states:

6 "We have agreed about the supply of sighting mechanisms, firing

7 tables, and tires. We have agreed with representatives of the JNA, they

8 will be included in the ciscenje of the municipality. We need to secure

9 the field for the [sic] army personnel carriers and tanks. It's good

10 because of the psychological effect."

11 The reference to "ciscenje of the municipality," is this

12 referring to the municipality of Kalinovik?

13 A. Well, it's not all that clear to me from this. However,

14 everything that has to do with the JNA is in the context of military

15 activities, meaning mopping up military or paramilitary structures that

16 were already active in this area by the time.

17 Q. Sir, you've given an explanation. Do you recall, based on your

18 presence at this meeting, what municipality was being discussed?

19 A. If Draskovic was speaking, then it's possible that he was

20 speaking about the municipality of Trnovo, not the municipality of

21 Kalinovik. I don't see any connection with Kalinovik other than that JNA

22 units were stationed in that area.

23 MR. WEBER: We'll keep on coming to some more information here,

24 so could the Prosecution please have page 3 of both versions.

25 Q. Coming up will be the handwritten minutes for the 30th of April,

Page 27807

1 1992. Again, these minutes indicate that you were present.

2 At the bottom of the page before you and at the end of

3 Mr. Draskovic's comments, who's noted as Radivoje, he states:

4 "We have to create conditions for work and the division of

5 resources is one of the ways to do this, since there is no prospect of a

6 joint investment with them."

7 Who are the people that are being referred to as "them" by

8 Mr. Draskovic?

9 A. Already then it was clear that it's not possible to have a joint

10 rule in the municipality with the Muslim side that was doing everything

11 to prevent the activities of the Serbian authorities in the municipality

12 and in other institutions of power.

13 MR. WEBER: Could the Prosecution please have the next page of

14 the B/C/S original.

15 Q. According to these minutes, you state:

16 "The police should immediately go down to the building of

17 socio-political organisations."

18 What building were you discussing?

19 A. This was a building used by all the institutions in the small

20 municipality. The intent was --

21 Q. Sir, I'm sorry, I'm very tight on time. I'm going have to start

22 cutting you off a little bit more. If you could just please answer my

23 question: What building were you discussing?

24 A. It was a building in the centre of the Trnovo locality

25 settlement.

Page 27808

1 Q. A little bit further down in these minutes, Andjelko, who appears

2 to be Andjelko Milic, states:

3 "Today we will get Pero to observe the terrain so that the

4 locations are decided. From here you cannot shell Spile, but can you

5 shell all the other villages."

6 What villages could be shelled?

7 A. I wasn't an expert for military issues and I did not even enter

8 into any of these analyses of the basis of data on the movement of units

9 that we were monitoring over the communications media. Some places I

10 knew where these military or paramilitary formations were active, the

11 Muslim military and paramilitary formations.

12 JUDGE ORIE: Witness, what you are a doing at this moment, you're

13 saying, "I don't know about it," and then you start explaining that it

14 must be where the Muslim units were. Either you don't know, you have not

15 analysed it, fine, but then refrain from giving any further comment. Or

16 you do know and then you explain exactly what the basis of your knowledge

17 was.

18 Please proceed.

19 MR. WEBER: Could the Prosecution please have page 6 of the B/C/S

20 and page 5 of the English translation.

21 Q. These are the minutes from 3 May 1992 and they also indicate that

22 you were present. Is it correct that you, on this date, were at least

23 20 kilometres away from the city of Sarajevo in Trnovo, on this specific

24 day?

25 A. The 3rd of May. And this is 25 kilometres away from Sarajevo.

Page 27809

1 Q. Okay. According to these minutes, you state:

2 "Assign crews, conduct ... training, dig in and go to Kalinovik

3 for target practice."

4 MR. WEBER: Could the Prosecution -- just for time's sake, I'm

5 going move through to page 8 of the B/C/S and page 6 of the English

6 translation.

7 Q. Sir, I'm going to another comment you make. It's towards the

8 bottom of the English version and towards the top of the page before you.

9 And according to these minutes, you stated:

10 "We have achieved now what we dreamt of a year ago. Everything

11 that was done, it was done with one objective in mind."

12 What was the one objective that you were talking about at this

13 meeting?

14 A. The objective was to protect our interests that were under threat

15 for the previous year. The Muslim forces began to organise militarily in

16 January 1991, whereas our authorities did not begin to organise before

17 1992 as a result of the impossibility of reaching an agreement in the

18 functioning of our joint organs of power. And for some form of

19 independence in exercising power. That -- that was the objective.

20 Q. Okay. So I'm a little confused there. I understand how that

21 second part could have been accomplished by this time. Was the first

22 thing that you said accomplished by this date?

23 A. We didn't accomplish anything until the Assembly of the Serbian

24 People was formed and until the institutions were created that were

25 supposed to protect the interests of Serbs in Bosnia-Herzegovina.

Page 27810

1 Because we couldn't reach a mutual agreement.

2 MR. WEBER: Could the Prosecution now go to page 9 of the B/C/S

3 and page 8 of the English translation.

4 JUDGE ORIE: Before we do so, could the witness explain what it

5 means that Hamo Karic was attacked. What is that? Or Hamo. What was

6 attacked?

7 THE WITNESS: [Interpretation] What is meant here is a problem

8 that existed in the communication between Edhem Godinjak, the chief of

9 the police station, and this Mr. Karic here. They had a problem between

10 themselves. This was in the relationship between Muslims. I don't quite

11 recall what it was all about, but it seems that the information he had

12 acquired actually had to do with some problem in their relations that Edo

13 used as a pretext to attack this Mr. Karic, Hamo Karic. But I don't

14 remember exactly what it was about.

15 JUDGE ORIE: Nevertheless, it says that:

16 "We put him under pressure with our arguments and then he

17 attacked Hamo Karic."

18 So I'm a bit surprised that you do not know what it was about

19 where you apparently were involved in putting pressure upon -- and then

20 Mr. Karic being attacked.

21 THE WITNESS: [Interpretation] There was certain information about

22 organised attacks on Serbian villages. We got this information by

23 monitoring the radio communications. Specific military actions in

24 certain areas were carried out. These areas were populated by Serbs.

25 So, in that sense, we had this intelligence that we used to pressure

Page 27811

1 Mr. Godinjak, who was the chief of the Trnovo police station. These

2 problems manifested themselves in communications in the field where

3 Mr. Karic was active. So this is the context that I am familiar with.

4 As for data that Mr. Glisa Simanic had from before, that's

5 something that I am not familiar with because I didn't spend that much

6 time before this in that area, so I really wasn't very familiar with the

7 situation or the relationships among the protagonists.

8 JUDGE ORIE: Was Mr. Karic attacked?

9 THE WITNESS: [Interpretation] It was just verbal attacks. There

10 was no actual attack. These were just verbal attacks because of the

11 actions that he was carrying out at the time. The attack was verbal

12 attack by Mr. Godinjak, the police chief.

13 JUDGE ORIE: Nothing worse happened to him than to be verbally

14 attacked. Is that well understood?

15 THE WITNESS: [Interpretation] They are from the same ethnic

16 group, so I don't know how they resolved the problem amongst themselves

17 later, but this was just a verbal attack.

18 JUDGE ORIE: It's not an answer to my question, but please

19 proceed, Mr. Weber.

20 MR. WEBER: Could I just verify that the Prosecution has page 9

21 of the B/C/S and page 8 --

22 MR. LUKIC: I'm sorry, for the record, this is exactly the answer

23 to your question, Your Honour.

24 JUDGE ORIE: No, it's not.

25 MR. LUKIC: Can you direct the witness on which part of your

Page 27812

1 question he didn't answer, please.

2 JUDGE ORIE: No. I -- I said that it's not an answer to my

3 question, and ... I asked whether nothing worse happened to him than to

4 be verbally attacked. The answer was that they were from the same ethnic

5 group so that he doesn't know how they resolved the problem, but that it

6 was just a verbal attack. Focusing specifically on that one attack

7 whereas my question was broader, whether anything worse happened to him

8 than to be verbally attacked.

9 MR. LUKIC: And he said he does not know after that. At that

10 time, only verbal attack. He told you what he knows. Not that he didn't

11 answer the question.

12 JUDGE ORIE: He didn't say that he didn't know whether anything

13 else happened to him. He said he was verbally attacked at that moment.

14 Whether the witness has any knowledge about what happened later to him is

15 not clear from the answer. To that extent it does not answer my

16 question, only very partially, and starts with an explanation on matters

17 I have not asked for.

18 I leave it to that, Mr. Lukic. We're not in a debating club.

19 We'll continue --

20 MR. LUKIC: Please --

21 JUDGE ORIE: Mr. Lukic, you may make further submissions if you

22 want to do that later --

23 MR. LUKIC: Yes, I will.

24 JUDGE ORIE: -- and you may revisit the matter in re-examination

25 if you're not happy with the way in which the witness was able to explain

Page 27813

1 himself.

2 Please proceed, Mr. Weber.

3 MR. WEBER: The Prosecution would like to -- oh, I see it's

4 coming up. Page 9 of the B/C/S and page 8 of the English translation.

5 Q. Sir, these are the handwritten minutes of the 7th of May, 1992.

6 As we see in the past ones, there's references by first names and the

7 name Nedjo appears on these minutes also. What I'd like to focus on with

8 you is what Danilo says who appears from the previous minutes to be

9 Danilo Goljanin. He states:

10 "Today we should go to Kalinovik with gun crews."

11 Based on the references that we've seen in these minutes, is it

12 correct that you were involved in the planning of operations in the

13 municipality of Kalinovik?

14 A. I never went to Kalinovik municipality. I know nothing of these

15 operations. However, there was discussion at these meetings about

16 organising a defence of the Serbian villages.

17 Q. Okay, sir, I don't exactly accept your characterisation of these

18 things but I'm going to keep on progressing.

19 My next question for you is: Danilo Goljanin, was he the

20 commander of the Trnovo Territorial Defence?

21 A. I don't know about the hierarchy. I just spent a brief period of

22 time there, so I did not really deal with the organisational structure

23 there. But I did take part due to the reasons that I mentioned, because

24 I knew Mr. Godinjak, because I knew the security problems that we were

25 encountering there. So this is why I was attending the meeting. I was

Page 27814

1 not familiar with the individual posts.

2 Q. According to these minutes, an individual who is referred to in

3 the one before us as Glisa, Glisa Simanic appears to be this person.

4 Could you tell us briefly who he is? I believe he is a person you know.

5 A. I know he was an experienced senior policeman who by that time

6 was already retired.

7 MR. WEBER: The Prosecution tenders 65 ter 31532 into evidence.

8 JUDGE ORIE: Madam Registrar.

9 THE REGISTRAR: Document 31532 receives number P6887,

10 Your Honours.

11 JUDGE ORIE: Admitted into evidence.

12 MR. WEBER: Could the Prosecution please have 65 ter 31549.

13 Q. Sir, coming up before you will be a report on the operation and

14 activities of the TO command and the commanding personnel of the Trnovo

15 armed forces for the period of 15 to 30 May 1992. The report is from the

16 Trnovo DB.

17 MR. WEBER: Could the Prosecution please have the lower portion

18 of the last page in both versions.

19 Q. According to this report, on 29 May 1992:

20 "At a joint meeting of the Crisis Staff and the Trnovo SOS Main

21 Command, a decision was passed that the entire Serb population of Trnovo

22 from the territory of Sirokari, Dobro Polje, and Kalinovik be evacuated

23 by 30 May 1992, and that in a joint effort with the Kalinovik forces, the

24 entire Muslim and other population be killed or expelled in an armed

25 intervention to thus provide an ethnically clean Serb territory along the

Page 27815

1 entire line of Krupac-Foca."

2 Based on your involvement with the Trnovo Crisis Staff, is it

3 correct that you were involved in the planning and preparations to

4 ethnically cleanse areas of Bosnia, including Kalinovik?

5 A. This assertion was not possible. The municipality of Trnovo is

6 of such demographic composition that there was only 30 per cent of Serbs

7 in the overall population. A peaceful solution of the problem suited us

8 so we undertook activities in that regard, and I was included in that

9 sense in the actions. I was a member of the peace council. The events

10 that were referred to from the SDS Department of Trnovo are something

11 that I'm seeing for the first time because I had left the area already on

12 the 13th of May and I did not come back ever to this municipality so that

13 I do not know what happened after the 13th of May. So whatever the

14 events were there after the 13th of May, I am not aware of what happened.

15 Q. Sir --

16 MR. WEBER: Well, Your Honours, I was just putting it to the

17 witness. The Prosecution tenders 65 ter 31549 into evidence.

18 JUDGE ORIE: Madam Registrar.

19 THE REGISTRAR: Document 31549 receives number P6888,

20 Your Honours.

21 JUDGE ORIE: Admitted into evidence.

22 MR. WEBER:

23 Q. And, sir, since you just asserted that this was not possible, I'm

24 going to show you one more document.

25 MR. WEBER: Could the Prosecution please have 65 ter 10833 for

Page 27816

1 the witness.

2 JUDGE ORIE: Mr. Weber, could I ask one question.

3 In the previous document we looked at and where you said this is

4 all not possible, there is also a list of the names at the beginning of

5 that document. One of the persons by the same family name as you have,

6 Vlaski. First name Miroslav, or Miso. Are you in any way related to

7 that person?

8 THE WITNESS: [Interpretation] We are not closely related.

9 JUDGE ORIE: How closely are you related?

10 THE WITNESS: [Interpretation] Well, not at all. These are two

11 families that are no blood relations but that have the same surname.

12 There is this settlement --

13 JUDGE ORIE: Well, you've answered my question. Thank you.

14 Please proceed, Mr. Weber.

15 MR. WEBER:

16 Q. Sir, before you is a report of the Trnovo DB on the activities

17 and operation of the Trnovo SDS Municipal Board between 1 January and

18 31 May 1992.

19 We see that the first sentence indicates that the Crisis Staff

20 held 24 meetings during these six months. And the next sentence

21 indicates that the questions of preparing and organising the Serb people

22 for armed rebellion against the Muslim people were mainly discussed at

23 the meetings.

24 Sir, I put it to you that these --

25 JUDGE ORIE: Mr. --

Page 27817

1 MR. WEBER: Oh, I'm sorry.

2 JUDGE ORIE: -- Weber --

3 MR. WEBER: Am I going too fast?

4 JUDGE ORIE: -- it says "at this meeting," it says, whether

5 that's a translation error or not is a different matter.

6 MR. WEBER: Okay.

7 JUDGE ORIE: But it reads: "... were mainly discussed at this

8 meeting," which, by the way, doesn't make it very understandable --

9 MR. WEBER: Understandable, right.

10 JUDGE ORIE: -- because there are 24 meetings. So what is

11 referred to is unclear --

12 MR. WEBER: I don't know if Mr. Lukic can assist. I was --

13 JUDGE ORIE: If you would agree that the original reads in the

14 plural about meetings, then we could seek verification of that

15 understanding by CLSS.

16 MR. WEBER:

17 Q. Sir, based on this information at least for the time being, what

18 I'd like to put to you is that the purpose of the meetings that you

19 attended was to prepare and organise the Serb people for armed rebellion

20 against the Muslim people. Do you agree?

21 A. For defence.

22 Q. Okay.

23 MR. WEBER: Could the Prosecution then please have page 4 of the

24 B/C/S original and page 6 of the English translation.

25 JUDGE MOLOTO: While we do that, can I just ask a question, sir.

Page 27818

1 Are we to understand that in your -- in your understanding a

2 rebellion is a defence?

3 THE WITNESS: [Interpretation] It is logical that it is defence.

4 We were 30 per cent of the population. We did not have even a

5 theoretical chance of launching any attacks in that micro-location.

6 70 to 30 was the balance of power.

7 JUDGE MOLOTO: Let me stop you. Would you like to answer my

8 question? Is a rebellion a defence in your understanding? You can

9 either say "yes, it is," or you can say "no, it is not," or "I don't

10 know."

11 THE WITNESS: [Interpretation] Rebellion is not defence. It can

12 be passive resistance.

13 JUDGE MOLOTO: Thank you. Thank you so much. Rebellion is not

14 defence.

15 MR. WEBER:

16 Q. Sir, on this page I want to draw your attention towards the

17 information on the 29th of May, 1992.

18 MR. WEBER: This is in the lower portion of the English version.

19 I believe we have to scroll down.

20 Q. The report states:

21 "On 29 May 1992, the Serb Crisis Staff passed a decision that the

22 entire Serb population be moved in the direction of Sirokari and

23 Dobro Polje, explaining that" - thank you for the next page - "explaining

24 that they would be attacked by Muslim forces, while in fact it was the

25 preparation of an armed intervention into Trnovo."

Page 27819

1 "At 0830 hours on 31 May 1992, the attack on the Trnovo and the

2 neighbouring Muslim villages began."

3 Sir, I put it to you that it was possible and this attack did

4 occur on the Muslim villages.

5 A. I don't have any direct knowledge about this because at the time

6 I was not in the area.

7 JUDGE ORIE: Nevertheless you say that it was impossible. Is it

8 seriously your testimony that if there's a 30/70 balance in the

9 population, that the 30 per cent could not attack the 70 per cent?

10 THE WITNESS: [Interpretation] This probably has to do with

11 co-ordinated action with some other forces that had come from some other

12 areas. That is the only thing I can infer in this context.

13 JUDGE ORIE: Well, therefore, you say it is possible, only

14 certain conditions should be met. Is that how we have to understand what

15 you're telling us?

16 THE WITNESS: [Interpretation] Well, those who planned this know

17 under what -- under which circumstances they operated and with which

18 forces they could carry out this operation. But I am not aware of this.

19 JUDGE ORIE: That's fine that you're not aware. You said it's

20 impossible. You tell us that you have no knowledge about who prepared

21 it, what exactly was prepared. Nevertheless, you have a judgement about

22 the possibility or the impossibility.

23 Is that the type of conclusion-drawing that we find in your

24 evidence?

25 THE WITNESS: [Interpretation] That is what pertains to the period

Page 27820

1 when I was in that area and when I was involved. The assessment was that

2 was that was not possible at that time.

3 JUDGE ORIE: Do we then have to understand that wherever your

4 evidence is about places, locations, and times you were not present at a

5 certain moment, that you cannot finally draw conclusions on what

6 happened?

7 THE WITNESS: [Interpretation] Well, in this specific case, I

8 cannot draw a conclusion because I'm not familiar with the details of

9 planning these activities, these military activities, in that period.

10 JUDGE ORIE: But you agree with me that you did draw conclusions

11 when you said it was impossible.

12 THE WITNESS: [Interpretation] Well, logic guides one in that

13 direction, and that was my reasoning at the time, that that was not

14 possible or wise, that it's better to go for a compromise.

15 JUDGE ORIE: You told us today that it was impossible. You

16 didn't say: "At the time I considered it impossible, but it turned out

17 not to be impossible." Today you told us two times, without being

18 solicited to give such an opinion, that it had been impossible.

19 I just would like to draw your attention to that and to very much

20 stick to facts you know. For example, we see in this report, we've seen

21 now four minutes of meetings of the Crisis Staff where, at least if I

22 understand you well, you do not deny that when reported to be present,

23 that you do not deny that you were present. At the same time, earlier,

24 when asked about your presence in meetings of the Crisis Staff, you said,

25 one or two times. That has been grown to four by now, which means that

Page 27821

1 the previous answer was certainly not accurate. And you're supposed to

2 tell us whatever you know, and if you're not certain about the number of

3 meetings, then to clearly indicate that, and your uncertainty was limited

4 to one or two. You should have said: "I have been there a couple of

5 times. I don't remember exactly how much." You should not have said one

6 or two if you attended four meetings.

7 Please proceed, Mr. Weber.

8 MR. WEBER: The Prosecution tenders 65 ter 10833 into evidence.

9 JUDGE ORIE: Madam Registrar.

10 THE REGISTRAR: Document --

11 MR. LUKIC: I was not on my feet on time for the next document.

12 Do we know who composed this document? Because we will show

13 that these two -- last two documents were composed by Muslims. And if

14 the Prosecution has any --

15 JUDGE ORIE: One second.

16 Mr. Weber, if you let -- Mr. Lukic has asked a question --

17 MR. LUKIC: Yeah, who -- who -- [overlapping speakers] ...

18 JUDGE ORIE: -- who composed this document. I take it that you

19 want -- before you explain who did it, that you'd first ask this question

20 to Mr. Weber.

21 Mr. Weber, do you have any further information about who drafted

22 this document, who -- who composed this document and perhaps also where

23 it has been found.

24 MR. WEBER: The document is composed by the state security sector

25 in Trnovo, the documents, and they were recovered during the

Page 27822

1 reintegration process in the municipality of Trnovo by Aid Sarajevo and

2 then turned over to the Prosecutor. So that's the --

3 JUDGE ORIE: That's your information about --

4 MR. WEBER: Information --

5 JUDGE ORIE: -- the origin of the document.

6 MR. LUKIC: Still who composed? Since Trnovo was at one point of

7 time in Muslim hands and [overlapping speakers] ...

8 JUDGE ORIE: Okay --

9 MR. LUKIC: Do they have any information who composed the

10 document.

11 JUDGE ORIE: First of all, I do understand that you object to the

12 admissions.

13 MR. LUKIC: Yeah. And I was late but I -- it's admitted but the

14 previous one as well, and I do oppose the admission of the document.

15 JUDGE ORIE: Well, the previous one has been admitted but

16 we'll -- of course, if there are serious reasons to do so, the Chamber

17 will also reconsider whatever has --

18 MR. LUKIC: Maybe after -- after the [overlapping speakers] ...

19 JUDGE ORIE: -- has to be reconsidered. We'll first follow what

20 happens here. We do understand that there's an objection.

21 Madam Registrar, the ... let me see, the number was.

22 THE REGISTRAR: Document 10833, Your Honours.

23 JUDGE ORIE: Is marked for identification at this moment under

24 number.

25 THE REGISTRAR: P6889, Your Honours.

Page 27823

1 JUDGE ORIE: MFI'd.

2 Mr. Weber.

3 MR. WEBER: Your Honours, I don't want to seek -- I want to try

4 and finish the witness today and I don't want to seek a huge discussion,

5 but there are many other information and documents related to these

6 events that are also in evidence and it might be most practical if we

7 have submissions after the fact, after the witness, on this matter if

8 that's the case.

9 JUDGE ORIE: Well, of course, Mr. Lukic can deal with the matter

10 in re-examination.

11 MR. WEBER: Yes, of course.

12 JUDGE ORIE: And we would hear any submissions on the matter at a

13 later stage.

14 Please proceed.

15 MR. WEBER:

16 Q. Sir, I just want to quickly go through some other information.

17 As of June 1992, is it correct that you were in Belgrade?

18 A. Correct.

19 Q. Is it correct that you were stationed in Belgrade at the Villa

20 Bosanska?

21 A. Correct.

22 Q. You remained in Belgrade throughout the remainder of 1992 and

23 early 1993 until you were reassigned to the headquarters in Bijeljina;

24 correct?

25 A. That's right.

Page 27824

1 Q. You were then assigned to the -- I'm sorry, I'm going to

2 mispronounce this, Kikinda building in Pale at the end of 1993 and 1994;

3 correct?

4 A. That's right. Until the 1st of April, 1994.

5 Q. You were then reassigned to Banja Luka; correct?

6 A. That's right.

7 Q. Is that where you spent the remainder of the war?

8 A. Well, yes. Until the end of the war, I was in Banja Luka, and

9 then after the war too.

10 Q. Returning to 1992, what were your duties in Belgrade? If you

11 could give us a short explanation.

12 A. Within the activities that were carried out in relation to the

13 negotiations of the three ethnic communities under the auspices of the

14 international community, certain activities of the service that I was

15 part of pertained, in addition to providing physical security to the

16 persons that took part in these negotiations, to counter-intelligence and

17 certain activities of an operative nature, with foreign journalists, and

18 some activity that was propaganda and psychology related.

19 Q. Sir, I'm going try to finish quickly here. Is it correct that

20 Radovan Karadzic came to Belgrade on a weekly basis while you were

21 stationed there?

22 A. Well, I didn't keep a diary in terms of when he came, but he came

23 very often on different business.

24 Q. Is it correct that Radovan Karadzic would meet with

25 Jovica Stanisic when he came to Belgrade?

Page 27825

1 A. I did not cover such contacts, and I was not in charge of

2 arranging these meetings. Therefore, I am not aware of the details where

3 and when they met. He arranged that himself.

4 Q. Okay. So you were aware that Karadzic would meet with

5 Jovica Stanisic?

6 A. That I do know.

7 Q. Is it correct that you were aware that they would meet at

8 Jovica Stanisic's villa?

9 A. Well, probably on those premises as well. Because I was not

10 present and I did not have a role to play in arranging these contacts.

11 JUDGE MOLOTO: Mr. Weber, is it Ivica or Jovica?

12 MR. WEBER: It's Jovica with a J, Your Honour.

13 JUDGE MOLOTO: Thank you.

14 MR. WEBER:

15 Q. What locations were you aware of these two individuals meeting?

16 If you could just tell us the locations.

17 A. I cannot say because I was not in charge of that at all.

18 JUDGE ORIE: Mr. Lukic.

19 MR. LUKIC: Your Honour, the witness already said that he has no

20 any data about their meetings, where and when.

21 JUDGE ORIE: Yes. He even -- you said probably also at

22 Jovica Stanisic's villa, but you don't know, so any probability. Refrain

23 from that as well. Just say, Stanisic's villa, you don't know. Refrain

24 from probabilities and assessments of a situation where you just don't

25 know.

Page 27826

1 Please proceed.

2 MR. WEBER:

3 Q. Sir, I want to change topics and quickly discuss paragraph 111 of

4 your statement. You comment --

5 JUDGE MOLOTO: Before we do that, can we see the first page of

6 this document on the screen, please. The document that Mr. -- yeah.

7 Thank you.

8 MR. WEBER: I was just pausing, Your Honour, in case you had any

9 questions --

10 JUDGE MOLOTO: Thank you. No, no, I have just seen it.

11 MR. WEBER:

12 Q. Sir, I'd like to change topics and discuss quickly paragraph 111

13 of your statement. You comment upon a document from the Milos group.

14 Could you tell us the names of the five members of this group?

15 A. As far as I can remember, State Security Inspector

16 Predrag Radulovic was there. Goran Sainovic. Mladen Stjepanovic.

17 Mr. Susnica. I didn't know these people. I mean ...

18 MR. WEBER: I just want to quickly go to Exhibit P4275. I'm

19 sorry, I think this is the incorrect document. I'm sorry, it's P4234.

20 My fault.

21 Q. Sir, this is a 20 October 1993 proposal for the promotion and

22 decoration of Predrag Radulovic from Nedeljko Kesic. Directing your

23 attention to the second paragraph of the document, Mr. Kesic states:

24 "In July 1991, he," referring to Mr. Radulovic, "was appointed

25 before the Banja Luka SNB sector as a liaison officer for the contact

Page 27827

1 with the MUP Serbia. In that function, apart from collecting

2 intelligence and counter-intelligence information about the enemy's armed

3 formations and intelligence services, he assisted in the arming -- in

4 arming the Serb people in the broader region of the then-BH and Slavonia.

5 The co-operation with the MUP Serbia was professional and of mutual

6 interest at that time."

7 Sir, do you agree that these were the functions of Mr. Radulovic?

8 A. That is derived from this document.

9 MR. WEBER: Could the Prosecution please have the next page of

10 the B/C/S original.

11 Q. In the next paragraph toward the end, Mr. Kesic indicates that

12 Mr. Radulovic was engaged in a number of areas, including Teslic.

13 Were you aware that Mr. Radulovic and his group were engaged in

14 this area?

15 A. I did not know all the way up until 1994, until I arrived in

16 Banja Luka.

17 Q. Then I understand correctly that you were not aware of their

18 activities in Teslic in 1992.

19 A. I did not know.

20 Q. This is a broader question. Is it correct that members of

21 intelligence services used code-names and do not always include their

22 official title or organisation in documents being sent to others?

23 A. Well, there was a certain procedure in the service as to how

24 information is exchanged or how appropriate institutions are informed.

25 Some elements from the rules of service were observed, whereas elsewhere

Page 27828

1 there was improvisation in this period of time, as far as I could see.

2 Q. I accept your answer is that you allow for the possibility. Were

3 you aware when you commented on the Milos report in your statement that

4 the document had been recovered from the archives of the State Security

5 Service of the Republic of Serbia?

6 A. I have no way of knowing on the basis of the document that I saw

7 from which archive it came because there is nothing on the document

8 itself as to where it was drafted and where it was recorded.

9 MR. WEBER: Your Honour, the Prosecution's done with this

10 document. The questions related to 65 ter 26215 which it's my

11 understanding the Defence is tendering as an associated exhibit, we do

12 not object to the admission of this document.

13 MR. LUKIC: It's already Prosecution Exhibit.

14 MR. WEBER: It's not been admitted.

15 JUDGE ORIE: Wasn't it true that there was a huge discussion and

16 there was strong opposition by the Defence where it now appears --

17 MR. WEBER: Yes, and if I --

18 JUDGE ORIE: -- on its own list.

19 MR. WEBER: If I could complete, it was the part of past

20 submissions and the document was discussed by Mr. Radulovic in

21 paragraph 133 of his statement which the Chamber ordered the Prosecution

22 to redact. The Prosecution sought reconsideration which was denied by

23 the Chamber on 26 February 2014. Based on the evidence now led by the

24 Defence, the Prosecution further requests that paragraph 133 of

25 Mr. Radulovic's statement be admitted and the Prosecution be allowed