Tribunal Criminal Tribunal for the Former Yugoslavia

Page 27754

 1                           Tuesday, 4 November 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.35 a.m.

 5                           [Trial Chamber confers]

 6             JUDGE ORIE:  Good morning to everyone.

 7             Madam Registrar, would you please call the case.

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

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

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             As was announced yesterday, Judge Fluegge is, for urgent personal

12     reason, unable to continue to sit in this case for a short period.  We

13     expect that it will last only one day.  Judge Moloto and I have

14     considered whether it would be in the interests of justice to continue to

15     hear the case, and we are satisfied that it is.  That's the reason why we

16     are sitting 15 bis today.

17             There are a few preliminary matters which we'd like to deal with

18     before the witness enters the courtroom.  For the first one, I'd like to

19     move into private session.

20                           [Private session]

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 27755

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11   (redacted)

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16   (redacted)

17   (redacted)

18                           [Open session]

19             THE REGISTRAR:  We're in open session, Your Honours.

20             JUDGE ORIE:  Thank you, Madam Registrar.

21             The next item I'd like to briefly deal with is associated exhibit

22     with Witness Savo Bojanovic.  The Chamber notes that on the

23     8th of September, the Defence filed a motion to file 18 exhibits

24     associated with the Rule 92 ter statement of Witness Savo Bojanovic.  The

25     Chamber invites the Defence to consider reducing the number of associated

Page 27756

 1     exhibits by, for example, tendering some of these documents with the

 2     witness during examination-in-chief.

 3             The next matter I would like to briefly deal with are associated

 4     exhibits related to the statement of -- to the testimony -- the evidence

 5     given by Witness Kralj.  I do understand that we have six exhibits now

 6     left, associated exhibits, that are tendered.  Is the Prosecution ready

 7     to respond to ...

 8             MS. BIBLES:  Yes, Your Honour.  And good morning, Your Honours.

 9             Your Honours, I spoke with Mr. McCloskey, he does not object to

10     the admission of these six associated exhibits.

11             JUDGE ORIE:  The six remaining associated exhibits.  I will read

12     the numbers one by one and invite Madam Registrar to assign a number.

13             The first one, 65 ter 1D02206 receives number?

14             THE REGISTRAR:  D737, Your Honours.

15             JUDGE ORIE:  Admitted.

16             1D02207 receives number?

17             THE REGISTRAR:  D738 Your Honours.

18             JUDGE ORIE:  Admitted.

19             1D02304.

20             THE REGISTRAR:  Number D739, Your Honours.

21             JUDGE ORIE:  D739 is admitted.

22             1D02305.

23             THE REGISTRAR:  Number D740, Your Honours.

24             JUDGE ORIE:  D740 is admitted.

25             14687.

Page 27757

 1             THE REGISTRAR:  Receives number D741, Your Honours.

 2             JUDGE ORIE:  Admitted.

 3             24893.

 4             THE REGISTRAR:  Receives number D742, Your Honours.

 5             JUDGE ORIE:  Admitted into evidence.  Thank you, Madam Registrar.

 6             I think we've dealt with all of those.  Then I do understand,

 7     Mr. Lukic, that there was one matter related to Witness Sarenac --

 8             MR. LUKIC:  Yes, Your Honour.

 9             JUDGE ORIE:  -- which you would like to raise.

10             MR. LUKIC:  Your Honours, I didn't have time yesterday to work on

11     this issue at all.  As you know, I was fully engaged in translation and

12     preparing of cross -- documents for cross-examination of Witness Vlaski.

13     So we would kindly ask you to extend our deadline for Sarenac until

14     weekend.

15             JUDGE ORIE:  And the deadline was exactly about what --

16             MR. LUKIC:  Today, the deadline was today --

17             JUDGE ORIE:  Yes, I know, but deadline to do what --

18             MR. LUKIC:  To reply.

19             JUDGE ORIE:  To reply.

20             MR. LUKIC:  Yes.

21             JUDGE ORIE:  Does that cause any problem for the Prosecution?

22             MR. WEBER:  No, Your Honour.

23             JUDGE ORIE:  Then the deadline is extended until after the

24     weekend, Mr. Lukic.

25             MR. LUKIC:  Thank you, Your Honours.  And thanks --

Page 27758

 1             JUDGE ORIE:  Shall we say --

 2             MR. LUKIC:  -- to my colleague.

 3             JUDGE ORIE:  Yes.  Shall we say Monday, midday?

 4             MR. LUKIC:  Thank you, Your Honour.

 5             JUDGE ORIE:  Yes.  The deadline has been -- has been moved to

 6     Monday, the -- Monday is the 10th, midday.

 7             Then I do understand that the -- Mr. Vlaski's information report,

 8     that a translation was produced yesterday.  The Chamber gave permission

 9     to hand out a copy of the B/C/S version through VWS to the witness so

10     that at least an opening has been made to seek his attestation to that

11     portion of his statement, to see whether it will be evidence before this

12     Chamber.

13             MR. WEBER:  That's understood, Your Honour.  And the Prosecution

14     would not have any objection to the Defence re-opening its examination

15     for the purpose of laying that foundation.

16             JUDGE ORIE:  Yes.  Mr. Lukic, would you prefer to deal with that

17     matter before the Prosecution continues its cross-examination?

18             MR. LUKIC:  I'm in your hands, Your Honours.

19             JUDGE ORIE:  Yes.  I'm afraid that I have not switched off my

20     cell phone.  I'll do it immediately.

21             The witness can be escorted into the courtroom.

22             MS. BIBLES:  Your Honour.

23             JUDGE ORIE:  Yes, Ms. Bibles.

24             MS. BIBLES:  Just very briefly going back to the Kralj exhibits.

25     We have -- I've been advised that with respect to one of the exhibits

Page 27759

 1     used with the witness, P6864, which was a cover letter and a series of

 2     convoy approvals, there were apparently a few pages in that exhibit that

 3     were not translated.  We have submitted them and will advise both the

 4     Defence and the Chamber as soon as those are completed.

 5             JUDGE ORIE:  Thank you for that information.

 6                           [The witness takes the stand]

 7                           WITNESS:  NEDJO VLASKI [Resumed]

 8                           [Witness answered through interpreter]

 9             JUDGE ORIE:  Good morning, Mr. Vlaski.

10             THE WITNESS: [Interpretation] Good morning.

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

12     you're still bound by the solemn declaration you've given at the

13     beginning of your testimony.

14             Mr. Vlaski, we were informed that you have been provided with a

15     copy of the information report which contains, apart from a few other

16     matters, primarily and mainly further explanations to your statement.  Is

17     that true?  Have you received that in a language you understand?

18             THE WITNESS: [Interpretation] Yes, I did have -- receive the

19     report.

20             JUDGE ORIE:  Did you have an opportunity to read it?

21             THE WITNESS: [Interpretation] I did.

22             JUDGE ORIE:  Then Mr. Lukic will have an opportunity to put a few

23     further questions to you in relation to this information report.

24             Mr. Lukic.

25             MR. LUKIC:  Thank you, Your Honours.

Page 27760

 1                           Examination by Mr. Lukic: [Continued]

 2        Q.   [Interpretation] Good morning, Mr. Vlaski.

 3        A.   Good morning.

 4        Q.   Yesterday we talked about working on the information report, on

 5     Saturday and Sunday, and this morning you say that you had the

 6     opportunity to read it in B/C/S; is that right?

 7        A.   Yes.

 8        Q.   And did you find anything in the report that you did not tell me

 9     on Friday and Saturday?

10        A.   Everything that I said is reflected in the report.

11        Q.   If I were to put the same questions to you today as I put to you

12     on Friday and Saturday, would you give the same answers?

13        A.   Yes, I would give the same answers with perhaps more detailed

14     explanations for some questions because I have some additional evidence.

15        Q.   Is what you told me when we analysed your statement truthful and

16     accurate?

17        A.   Yes, it's all accurate and truthful.

18             MR. LUKIC:  Your Honours, if there is nothing else, we would

19     tender this information report into evidence.

20             JUDGE ORIE:  Mr. Weber.

21             MR. WEBER:  Your Honour, for some of the other reasons I already

22     said, we ask that D736 marked for identification remain marked for

23     identification.  We do acknowledge that counsel has laid a foundation

24     pursuant to Rule 92 ter at this time.

25             JUDGE ORIE:  Yes.  That is, then, D736 is now marked for

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 27803

 1             MR. LUKIC:  Couple of minutes.  Five minutes.

 2             JUDGE ORIE:  Couple of minutes.  And ...

 3             MR. WEBER:  I have to check the exact time but I do plan on using

 4     the next session.

 5             JUDGE ORIE:  Next session.  Which means that if Mr. Lukic only

 6     has a couple of minutes, then it still makes sense to have the next

 7     witness to remain standby.

 8                           [Trial Chamber and Registrar confer]

 9             JUDGE ORIE:  You have, as a matter of fact, 54 minutes left, so

10     you really have to finish within the next --

11             MR. WEBER:  That's -- I'm right on track, Your Honour.

12             JUDGE ORIE:  Yes.  Then apart from that, Mr. Lukic, I was

13     informed by CMSS that for clarity of the record, withdrawal of the filing

14     is what should be done, the double filing we discussed earlier, because

15     just mentioning it in the transcript is -- may still cause quite some

16     confusion.  So would you please formally withdraw, through a filing, the

17     second filing of the 92 ter motion.

18             MR. LUKIC:  Yes, Your Honour, I will do so.

19             JUDGE ORIE:  Yes.  We'll take a break and resume at 20 minutes

20     past 12.00.

21                           --- Recess taken at 12.01 p.m.

22                           --- On resuming at 12.22 p.m.

23             JUDGE ORIE:  Mr. Weber.

24             MR. WEBER:  Your Honours, to be on the safe side, the Prosecution

25     would request a Rule 90(E) admonishment of the witness at this time.

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

Page 27829

 1     re-tender an unredacted version of Mr. Radulovic's statement.  The

 2     Prosecution submits that it is in the interests of justice to have the

 3     first-hand information on this document from a member of the Milos group

 4     who describes the information as being from reliable sources and further

 5     details his knowledge.

 6             If allowed, the Prosecution will upload an unredacted version of

 7     P3207 and inform the Chamber accordingly, not seeking resolution at this

 8     time but believe it can be dealt with with the associated exhibits for

 9     this witness.

10             JUDGE ORIE:  Yes.  Of course, it comes as a bit of a surprise,

11     the Chamber noted this already, Mr. Lukic, that there is such a strong

12     objection against the admission of a document and then you produced it

13     yourself.  That is -- it looks as if there's no well thought-over line of

14     the Defence in this respect.

15             MR. LUKIC:  No co-ordination, actually, with the field,

16     obviously.  So we are not tendering this document into evidence.

17             JUDGE ORIE:  No.  But you put it on the list and you consider

18     it -- and I think we'll consider the requests and -- but we'll give you

19     an opportunity, Mr. Lukic, to say more about it than just that you're not

20     tendering it.

21             MR. WEBER:  It is associated to his statement, so the Prosecution

22     then, if he is -- if the Defence isn't tendering it, tenders 65 ter 26215

23     into evidence.

24             JUDGE ORIE:  Yes.  Because there's comment on it.

25             MR. WEBER:  Yes.  I'm happy -- [overlapping speakers] ...

Page 27830

 1             JUDGE ORIE:  Mr. Lukic, if you say in a statement a witness is

 2     commenting on a document which you so strongly object to to be admitted,

 3     then, of course, it's not very consistent.  And then to say "we do not

 4     tender it" is not an answer to the real issue.

 5             MR. LUKIC:  I agree, Your Honour.  Obviously it was not

 6     co-ordinated well among the team members.

 7             JUDGE ORIE:  Does that mean that -- well, we'll first wait for an

 8     unredacted version to be uploaded by the Prosecution.  But can we

 9     understand that the objection against admission of the Milos report is

10     withdrawn?

11             MR. LUKIC:  It's not withdrawn.

12             JUDGE ORIE:  You ask a witness to comment on it, you produce a

13     statement, and at the same time you say "we are objecting against" --

14             MR. LUKIC:  The problem with this is that the Prosecution offered

15     this document only after the -- Mr. Radulovic died so we cannot

16     cross-examine him on that document.

17             JUDGE ORIE:  No.  Neither could you after you have put it to this

18     witness and to comment on it.  Similar situation.

19             Let's -- apparently, Mr. Lukic, you are insufficiently prepared

20     to really go into depth.  The Prosecution can upload into e-court the

21     unredacted version.  We'll further receive your submissions on the

22     matter.

23             MR. LUKIC:  The problem this Defence has, that this Chamber's

24     decisions are often in e-mails and on the transcripts, so obviously we

25     cannot follow everything.  Having in mind that it has P number --

Page 27831

 1             JUDGE ORIE:  Mr. Lukic --

 2             MR. LUKIC:  -- obviously somebody thought it was already

 3     admitted.

 4             JUDGE ORIE:  Yes, Mr. Lukic, I gave you an opportunity to make

 5     further submissions --

 6             MR. LUKIC:  Thank you.

 7             JUDGE ORIE:  -- but instead you preferred to immediately accuse

 8     the Chamber of causing the problem rather than --

 9             MR. LUKIC:  No, I'm just explaining our position.  I'm not

10     accusing anybody.  It's very hard for us to follow and that's why this

11     happened.

12             JUDGE ORIE:  I'm -- I'm just looking at the consequences of what

13     you did in including in the statement of this witness a comment on that

14     report.

15             We'll check very carefully how we dealt with the matter, and if

16     you want us to always deliver a written decision if we deny admission of

17     a document, then I'm afraid that there's a fair chance that you'll be

18     disappointed.  I mean, that's part of what happens at trial.  A document

19     is tendered.  The other party objects to it.  Certain -- sometimes after

20     further discussions, the Chamber decides on the matter, and that decision

21     is put on the record.  And there's -- if you consider this to be

22     inappropriate practice, we'd like to receive thorough submissions on

23     that.

24             We leave it to that at the time.

25             Mr. Weber.

Page 27832

 1             MR. WEBER:  Just for clarity, I was talking about two different

 2     matters.  One, the Prosecution is -- would seek the admission of

 3     65 ter 26215 and the separate unredacted matter, just so it's clear on

 4     the matter, related to Mr. Radulovic's statement.  So the -- that was

 5     separate and apart from 65 ter 26215.  And I would just note because of

 6     the -- where the document came from, that it would have to be

 7     provisionally under seal and we're happy to undertake the notifications.

 8             JUDGE ORIE:  Yes.  We'll first take a break and we'll consider

 9     the matter after the break before I make any mistakes.  Or was this --

10     does this conclude your --

11             MR. WEBER:  No.  I just have a very short portion, but I'll

12     finish very quickly after the break.

13             JUDGE ORIE:  Yes.  And we'll deal with the matter after the

14     break.

15             Witness, we'll take a break of 20 minutes.  You may follow the

16     usher.

17                           [The witness stands down]

18                           [Trial Chamber confers]

19             JUDGE ORIE:  The time that would remain after we've concluded the

20     evidence of this witness, Mr. Weber, you still having a few questions,

21     Mr. Lukic having some questions perhaps, the time would be so short if we

22     resume at quarter to 2.00 that it might be wiser to release the witness

23     for the time being.  But if you --

24             MR. LUKIC:  The next one, you mean?

25             JUDGE ORIE:  The next one.

Page 27833

 1             MR. LUKIC:  Yeah, yeah, we can release him.

 2             JUDGE ORIE:  So, therefore, we'd like to see the next witness to

 3     appear tomorrow morning, and he doesn't have to make himself available

 4     any further today.

 5             We'll take a break, and we'll resume at quarter to 2.00.

 6                           --- Recess taken at 1.25 p.m.

 7                           --- On resuming at 1.51 p.m.

 8             JUDGE ORIE:  Before we ask the witness to be escorted in the

 9     courtroom again, I would like to briefly deal with the matters raised.

10             Mr. Lukic, upon objection by the Defence, the Chamber admitted

11     into evidence the statement of Mr. Radulovic only with redactions, and

12     the redactions specifically dealing with 65 ter 26215, Milos report.

13             There was a written decision about that.  Then the Prosecution

14     asked the Chamber to reconsider that, and upon strong objection by the

15     Defence, the Chamber denied that -- that motion.  We did not reconsider

16     it.  And it was argued in quite some detail, and that decision was put on

17     paper and filed on the 26th of February, 2014.

18             You now, in the last paragraph of the statement of the present

19     witness, you ask him to comment on the document you so strongly objected

20     to be admitted.  And now the Prosecution, where this last paragraph had

21     not been redacted and where the document was announced as an associated

22     exhibit because it is indispensable, now the Prosecution has

23     cross-examined the witness on it, asking for how the Milos group was

24     composed, et cetera.  And now, you suddenly object to admission of

25     65 ter 26215.  That is not what the Chamber intends to follow.

Page 27834

 1             MR. LUKIC:  I will -- I cannot object to admission to that

 2     document at this situation.

 3             JUDGE ORIE:  Okay.

 4             MR. LUKIC:  I'm aware of it.

 5             JUDGE ORIE:  Yes.  65 ter 26215, Madam Registrar, would receive

 6     number?

 7             THE REGISTRAR:  Document 26215 receives number P6890,

 8     Your Honours.

 9             JUDGE ORIE:  P -- yes, Mr. Weber.

10             MR. WEBER:  Could we have it provisionally under seal.

11             JUDGE ORIE:  Yes.  The matter whether -- yes, we will put it

12     provisionally under seal.  Although the matter how confidential all this

13     is was raised, I think, already in February or even in 2013.  45 days

14     were given to make further submissions and I do understand that nothing

15     followed then.  Under those circumstances -- I'm still willing to do that

16     for two days.

17             MR. WEBER:  Thank you, Your Honour, for checking that.  That's

18     exactly what I wanted to check, just to see if the notification had been

19     made.  If it has been made, then obviously --

20             JUDGE ORIE:  Yes, okay.  Then 26215, which has now received

21     P6890, is admitted provisionally under seal but we really now need an

22     answer within 48 hours.

23             MR. WEBER:  Thank you, Your Honours.  No problem.

24             JUDGE ORIE:  Then we'll wait for further action to be taken by

25     the Prosecution in relation to P3207, especially the redaction of

Page 27835

 1     paragraph 133, which you would like to be -- that we would admit the

 2     92 quater statement in its original version without this redaction.

 3             MR. WEBER:  That's correct, Your Honour.

 4             JUDGE ORIE:  Then we'll wait for you to upload it and to -- the

 5     application has been made once it has been uploaded.  Mr. Lukic, you will

 6     then have an opportunity to respond to that and the Chamber will then

 7     decide on admission.

 8             Then I -- one second.

 9             JUDGE MOLOTO:  Just to say to Mr. Lukic that these decisions were

10     not by e-mail.  These were formal decisions.

11             MR. LUKIC:  Yes, Your Honour, but I have to admit that we were

12     misled by the decision from February, the 11th, of this year, when this

13     document was -- actually declares the motion moot in relation to the

14     following documents so ...

15             JUDGE MOLOTO:  What I'm saying is -- you are saying the confusion

16     arises because of decisions being rendered by e-mail, and I'm saying

17     these are not e-mails --

18             MR. LUKIC:  This one was in written form, yes, Your Honour.

19             JUDGE ORIE:  Yes.  Okay.  We'll leave it to that for the time

20     being.

21             Could the witness be escorted in the courtroom.

22             MR. WEBER:  Your Honour, I don't know if it assists for timing,

23     but the Prosecution is going to go to 65 ter 31534.

24             JUDGE ORIE:  Yes.  And could the parties try to see whether it's

25     possible to conclude the evidence of the witness today.

Page 27836

 1             Mr. Lukic, you've caused a lot of loss of time by your objections

 2     and not being aware of everything that preceded.

 3                           [The witness takes the stand]

 4             JUDGE ORIE:  Bad preparation.  We'll consider --

 5             MR. LUKIC:  I need some time, Your Honour.  It's really --

 6     especially in the last portion of cross-examination many questions were

 7     opened.

 8             JUDGE ORIE:  Mr. Weber.

 9             MR. WEBER:

10        Q.   Welcome back, Mr. Vlaski.  I skipped a document during my

11     examination.  I just wanted to go back to it quickly with you and discuss

12     the structure of the SNB from May 1992 onward.  Thank you for your

13     patience.

14             Before you is an SRBiH MUP SNB salary list for May 1992.  I

15     believe you've seen this document before.  Directing your attention to

16     the first name on the list, is it correct that Slobodan Skipina was the

17     under-secretary of the SNB between April and August 1992?

18             Sir, I see you're nodding your head but you have to audibly say

19     something.

20        A.   Skipina.  Skipina was the head of the National Security Service

21     in May 1992.

22        Q.   Okay.  And he was the head between April and August 1992;

23     correct?

24        A.   Yes.

25        Q.   Directing your attention to number 8 on the list,

Page 27837

 1     Mr. Dragan Kijac.  In August 1992, Dragan Kijac replaced Mr. Skipina as

 2     the under-secretary of the SNB; correct?

 3        A.   The new executive officer, yes.

 4        Q.   Could you tell us what Mr. Kijac's official title was between

 5     April and August 1992?

 6        A.   April, August 1992?  I think that he was in charge of the

 7     Sarajevo sector of national security at the time.

 8        Q.   Directing your attention to numbers 2 and 3, is it correct that

 9     you and Goran Radovic were both assistant under-secretaries to

10     Mr. Skipina?

11        A.   Yes.

12        Q.   Dragan Devedlaka is not on this list.  Is it correct that he had

13     been assigned to the Bijeljina CSB in April of 1992 when Arkan's units

14     arrived there?

15        A.   Yes, it's correct, he did go to Bijeljina.  I don't know upon

16     whose orders.

17        Q.   Okay.  Is it correct that Mr. Devedlaka eventually wound up in

18     Belgrade with you in June 1992 after he received an offer to work at

19     Arkan's Belgrade headquarters near the Red Star football stadium?  Were

20     you aware of that?

21        A.   I do know something about that.  He told me that after he had

22     some problems in Bijeljina, he went back to Belgrade, and he was trying

23     to find a way to become active with Arkan.

24        Q.   I'm just going by -- based on the information you have previously

25     provided.  Did he tell that you he received an offer to work at Arkan's

Page 27838

 1     headquarters in Belgrade?

 2        A.   Yes, I was aware of the offer.

 3             MR. WEBER:  The Prosecution tenders the document into evidence,

 4     Your Honours.

 5             JUDGE ORIE:  Madam Registrar.

 6             THE REGISTRAR:  Document 31534 receives number P6891,

 7     Your Honours.

 8             JUDGE ORIE:  Admitted into evidence.

 9             MR. WEBER:  Could the Prosecution please have 65 ter 31545 for

10     the witness, page 109.

11        Q.   Sir, coming up before you will be part of your interview with the

12     Office of the Prosecutor on 3 June 2009.

13             MR. WEBER:  And if we could have the bottom of the page.

14        Q.   I'll read it to you since the translation's not available.

15             MR. WEBER:  If we could have the bottom of the page.

16        Q.   This is the part of the interview where you were discussing your

17     relationship with Radovan Karadzic.  During the interview,

18     Investigator Grady asked you:

19             "Do we need to take a break?

20             You responded:

21             "I once told him something and he -- it made him think, I have to

22     say.  Since we had actually run a security check on Karadzic before the

23     war, he knew it, we listened in on his phone calls" - could we please

24     have the next page - "we did everything that we would, you know,

25     ordinarily do.  He knew it.  He accepted it as part of his task.  And in

Page 27839

 1     1992, we were sitting down, and I told him, you know, some of your

 2     associates are actually writing your indictment."

 3             Do you stand by this statement?

 4        A.   In a certain sense, this didn't refer to what was happening

 5     before.  This was more in the context of him personally, the way he

 6     lightly accepted everything that reached him.  He wasn't selective.  He

 7     didn't check anything.  So this statement was made in that context, in

 8     the sense that there was a problem in his attitude, how he was

 9     experiencing his collocutors, his associates, and how he was uncritically

10     accepting certain things that were happening.

11        Q.   When in 1992 did you sit down with Radovan Karadzic and tell him:

12     "Some of your associates are actually writing your indictment"?  When did

13     this conversation actually take place?

14        A.   This was on occasion when we were travelling to Bijeljina from

15     Belgrade.  The trip takes about an hour or so.  There was nobody else in

16     the vehicle other than myself, him and his body-guard Kapor, so we had a

17     kind of more relaxed conversation.

18        Q.   What month in 1992 did this conversation take place?

19        A.   It could have been in late May or early June.  Really, I don't

20     remember the dates.

21        Q.   When you told him:  "Some of your associates are actually writing

22     your indictment," what associates were you referring to?  Could you

23     please tell us their names.

24        A.   Mostly those who tried to abuse his position of power, his power

25     and the influence he wielded.

Page 27840

 1             JUDGE ORIE:  Witness, names, please.

 2             THE WITNESS: [Interpretation] I didn't have specific names.  Just

 3     based on my experience.  I didn't mention anyone specifically in that

 4     context.  And I didn't have that approach either, to charge or accuse any

 5     of his associates, but just based on the basis of my experience and the

 6     work that I was doing, from the side as I was looking, I had the

 7     impression that many people wanted to misuse his authority and position

 8     of power.  And that is what they did.  But it mostly referred to abuses

 9     in the functioning of Crisis Staffs, in the procurement of equipment, and

10     certain things for which his approval had to be given, but he did not

11     really look closely into the legitimacy of these claims.

12             MR. WEBER:  I have nothing further, Your Honour.

13             JUDGE ORIE:  I have one other question.

14             Were you not referring in any way to any paramilitary leaders

15     which may have been in the position to jeopardize Mr. Karadzic?

16             THE WITNESS: [Interpretation] Well, the problem was not really

17     pronounced of paramilitary leaders in that context at that time.  This

18     was at the beginning of the war, when they were being sent.  I don't know

19     according to whose orders.  A lot of them were also self-organised, and

20     they were taking advantage of the war situation in order to profit out of

21     their own personal criminal objectives.

22             JUDGE ORIE:  But you did not exclude them when you were talking

23     about associates?

24             THE WITNESS: [Interpretation] I was speaking about the problem in

25     general terms.  Being aware of the times that we were living in, I was

Page 27841

 1     aware that one day the question of responsibility would be put.  Perhaps

 2     in criminal proceedings.  And so, in a way, I was just indicating to

 3     Karadzic that he would need to pay more attention to his own actions.

 4             JUDGE ORIE:  Yes.  Do I understand your answer well, when you

 5     say:  I did not exclude those, although using general terms and not

 6     specifically pointing at paramilitary leaders, but that you certainly

 7     also did not exclude them?

 8             THE WITNESS: [Interpretation] I did not exclude them.  Because in

 9     our professional line of work, if anyone out of any intention makes any

10     kind of arrangement with those structures, meaning criminal or

11     paramilitary ones, then they would have a problem then because those

12     monsters might one day start dealing with those who created them.  So in

13     that sense, you could always have a problem with structures that were

14     created outside of the system.  So I was basing it on my professional and

15     operative experience when I was expressing that position.

16             JUDGE ORIE:  Yes.  So that was part of what you had on your mind

17     when you told him that "associates are actually writing your indictment"?

18             THE WITNESS: [Interpretation] That's the context.  But I really

19     cannot recall all the details of that anymore.

20             JUDGE ORIE:  Thank you.

21             Mr. Lukic, how much time would you need?

22             MR. LUKIC:  Probably around half an hour.

23             JUDGE ORIE:  Okay.  We'll do that then tomorrow.  Could you

24     please keep in mind that by the badly organised matters today, such as

25     double filings and other matters, that this is part of the reason why we

Page 27842

 1     couldn't conclude the testimony of this witness today.  And if it were

 2     the first time, I would not have mentioned it.

 3             Mr. Vlaski, unfortunately, we're unable to conclude hearing your

 4     evidence today, and we'd like to see you back tomorrow morning at 9.30.

 5     And I again instruct you not to speak or communicate in whatever way with

 6     whomever about your testimony, whether already given or still to be

 7     given.

 8             We -- you may follow the usher.

 9                           [The witness stands down]

10             JUDGE ORIE:  We adjourn for the day, and we'll resume tomorrow,

11     Wednesday, the 5th of November, 9.30 in the morning, in this same

12     courtroom, I.

13                            --- Whereupon the hearing adjourned at 2.13 p.m.,

14                           to be reconvened on Wednesday, the 5th day of

15                           November, 2014, at 9.30 a.m.