Tribunal Criminal Tribunal for the Former Yugoslavia

Page 28434

 1                           Tuesday, 18 November 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.33 a.m.

 5             JUDGE MOLOTO:  Good morning to everybody in and around the

 6     courtroom.

 7             Madam Registrar, please call the case.

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

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

10             JUDGE MOLOTO:  Thank you very much.

11             As indicated yesterday by Judge Orie before we adjourned, he's

12     not able to be with us today for urgent personal reasons, and

13     Judge Fluegge and I have decided that it is in the interests of justice

14     to carry on with the trial in his absence.

15             In the absence of any preliminaries, can we call the witness.  No

16     preliminaries.

17             MR. JEREMY:  Your Honours, we have a short preliminary but I can

18     do it while the witness is being brought in.

19             JUDGE MOLOTO:  By all means.

20             MR. JEREMY:  So it's -- and good morning to you, I should say.

21             It's just a housekeeping matter from yesterday, video 65 ter

22     22399a was MFI'd as P6923 pending provision of the CD to the Court

23     Officer.  That has now been done and therefore we would request that

24     P6923 be admitted into evidence.

25             JUDGE MOLOTO:  Any objections from the Defence?

Page 28435

 1             MR. IVETIC:  None, Your Honour.

 2             JUDGE MOLOTO:  Madam Registrar.

 3             THE REGISTRAR:  Your Honour --

 4             JUDGE MOLOTO:  P6923 is admitted into evidence.  May it please be

 5     given an exhibit number -- or it is already given an exhibit number.

 6     Thank you so much.

 7                           [The witness takes the stand]

 8             JUDGE MOLOTO:  Good morning, Mr. Corokalo.

 9             THE WITNESS: [Interpretation] Good morning to you.

10             JUDGE MOLOTO:  I would just like to remind you that you are still

11     bound by the declaration that you made at the beginning of your testimony

12     to tell the truth, the whole truth, and nothing else but the truth.

13     Thank you.

14             Mr. Ivetic.

15             MR. IVETIC:  Thank you, Your Honour.

16                           WITNESS: DUSKO COROKALO [Resumed]

17                           [Witness answered via interpretation]

18                           Examination by Mr. Ivetic:  [Continued]

19        Q.   Good morning, sir.

20        A.   Good morning to you.

21        Q.   I would like to pick off where we left off.

22             MR. IVETIC:  If we could please call up D785 in e-court and if we

23     could turn to page 4 of that document.  Once we get to page 4, I'll be

24     asking that we focus on paragraph 15 of the same.

25        Q.   Sir, in this paragraph, you talk of armed fights that took place

Page 28436

 1     in the Mahala neighbourhood.  Can you tell me how those fights were

 2     initiated, how they came about?

 3        A.   The neighbourhood of Mahala is a broader area.  It should be

 4     noted here that one part is called Muhici Mahala but it's all known as

 5     Mahala.  By monitoring that area which is behind my house, near the Zdena

 6     river, it's on the right bank of Mahala, and on the left bank is my house

 7     and a number of Serb houses.  So for our own security, we organised

 8     observation and monitoring to be prepared, and we noticed the people in

 9     the night hours, because this area is unlit.  And even before these

10     events, it was dangerous to go through this area because it's almost

11     purely Muslim, 90 per cent Muslim.  And in earlier days they were

12     extreme, bent on fighting, et cetera.  And since I had contact with them

13     in football, it was a rare match that didn't end in a brawl.

14             Anyway, we were observing that area, and in the night hours we

15     noticed people who were going over there from our neighbourhood by night,

16     and it was suspicious.  And we noticed that people carrying hunting

17     weapons were showing up there doing something, and then we organised

18     ourselves and we realised something was going on there.

19             Later, after the appeal was made to turn over those hunting

20     rifles and other weapons that were registered with the police, they

21     completely ignored it.  Not only they but all the Muslims ignored it.

22     And then an action was organised to collect these weapons, and in this

23     effort there were incidents of shooting, skirmishes; not major fighting

24     just skirmishes.  So that was the reason for that conflict.

25        Q.   Okay.  You also mentioned two individuals here, Lola and Nail.

Page 28437

 1     Could you tell me please what the reputation these persons before the

 2     war.

 3        A.   When I told you earlier that we had noticed that part of the

 4     non-Serb population from my street -- and at the end of my street there

 5     is a turn towards Otoci from which you could reach Mahala, which could be

 6     accessed also from another side, but I was interested in my street.

 7     Anyway, we noticed that some people from my area were going over there in

 8     the night hours.  Nail and Lola did not have permanent residence there.

 9     Lola and Nail were the nicknames of people of whom I knew before the war.

10     They passed through and sometimes stopped at my bar.  Lola was in that

11     area called Pobrijezje which was 5, 6 kilometres towards Sanski Most, and

12     Nail lived in the centre of the town.  Nail, in fact, is the name.

13             And when we were gathering weapons, we found those people who

14     were collecting weapons.  I just ran into them because I didn't take

15     part.  We stayed over on our side of the river Zdena.  Some people later

16     told me that they found Nail and Lola in a house which was not theirs, in

17     the house of a singer, they were sitting around, drinking whisky, smoking

18     Marlboro cigarettes, and there were two guns on the table.

19             So even before the war, these people were problematic.  They

20     would go to Italy, Germany, commit robberies, then they would be deported

21     and so on.

22        Q.   Now I'd like to look at paragraph 16, which is on the next page

23     in both languages of your statement.  And here you are talking about

24     Hrustovo village and how it remained untouched until the time an elderly

25     Muslim man killed Soldier Brajic with a rifle.  Could you please tell us

Page 28438

 1     what do you mean by saying that it remained untouched until this time?

 2        A.   The same story that happened in Mahala was going on in all the

 3     areas of Sanski Most, Hrustovo, Vrhpolje, everywhere.  The drive to

 4     collect weapons that were requested was going on and what had been done

 5     until the afternoon went well.  The population had not been provoked in

 6     any way.  And when it was thought that it was all over, that we could

 7     relax, an incident occurred when a man, an elderly man, perhaps 70 or 80

 8     years old, that's what Brajic, the chief with whom I later worked, told

 9     me, was killed by the brother of that Captain Brajic, and the conflict

10     escalated after that killing.

11        Q.   Sir, could you clarify for us.  The transcript and the

12     translation record that:  The elderly man of 70 to 80 was killed by the

13     brother of Captain Brajic.  Is that what happened or something else?

14        A.   The elderly Muslim man killed the brother of Captain Brajic, who

15     was the commander of that unit.

16        Q.   Okay.  And then what happened?

17        A.   According to the information I have, later there occurred an

18     incident where some people ran out of control.  We heard that there were

19     casualties; I don't know how many.  I wasn't there.  That's the

20     information I got from Veljko Brajic because they were cousins.

21        Q.   Okay.

22             MR. IVETIC:  Now I'd like to look at paragraph 19, which is on

23     the same page in both languages.

24        Q.   Here you talk about Arkan's men.  I would like for you to tell

25     the Court how you first came to find out that Arkan's men were in

Page 28439

 1     Sanski Most.

 2        A.   These events happened between the 16th and the 19th September

 3     1995.  According to a decision of the Crisis Staff, I was sent to the

 4     Kljuc front line with about 380 men that had been gathered.  We called it

 5     the Worker's Battalion, all the people we could rally; teachers, even

 6     retired people, everybody was recruited.  And although we were against

 7     using such people as the last defence of Sanski Most, we were sent

 8     towards Krupa - that is, from Benakovac to Turska Jasenica to Jasenica.

 9     We set out around 1600 hours.  We got to Jasenica.  Some people didn't

10     even have weapons.  Rapid action forces joined us on the road, and we

11     managed as best we could.

12             After a few days we had to retreat, and it was around Benakovac.

13     So from the 16th to the 19th in those operations where we had 380 men, I

14     was a security officer, we lost a couple of dozen men.  We were not well

15     armed enough.

16             When I got back on the 19th in the evening, my wife told me that

17     Arkan's men had arrived at the hotel.  The hotel was well lit.  The men

18     were given food, as normal in a hotel.

19             On the 20th when we got to Privredna Banka, which were our place

20     to report, I found Arkan's men there.  They were controlling all vital

21     facilities.  The man was not saying a word, and we had difficulty

22     reaching the command because he had captured some people, tied them to

23     trees, shaved their heads, et cetera.  Anyway, they had come somehow

24     between the 18th and the 19th.  On whose orders, I don't know.

25        Q.   Those people -- those people that were -- those people that were

Page 28440

 1     tied to trees and with their heads shaven, did you know who they were?

 2        A.   I didn't see them.  I didn't have the chance because I wasn't

 3     there physically.  But later during that month that we stayed there, we

 4     found the hotel manager, whose head was shaved.  I asked him how it

 5     happened, and he explained that one of Arkan's commanders who got angry

 6     because they had to go somewhere on duty, do a stint, and come back by

 7     bus in the evening, and they would get angry because their meals were not

 8     hot, the food was not ready, et cetera.

 9        Q.   What was the --

10             JUDGE MOLOTO:  Can I just get some clarification --

11             MR. IVETIC:  Yes.

12             JUDGE MOLOTO:  -- here.

13             Mr. Corokalo, if you look at page 6, starting from line 19,

14     you're telling us about the 20th when people -- when you got

15     Privredna Banka, and you say you found Arkan's men there.  They were

16     controlling all vital facilities.  Then you said:

17             "The man was not saying a word, and we had difficulty reaching

18     the command because he had captured some people."

19             Which man is this?  Who is this man?

20             THE WITNESS: [Interpretation] The man who was the security guard

21     outside that building.  We had our command in that bank.  It was a man of

22     Arkan's who was outside the bank with whom we were in contact.

23             JUDGE MOLOTO:  You were responsible for security in your unit?

24             THE WITNESS: [Interpretation] Yes.

25             JUDGE MOLOTO:  Thank you.

Page 28441

 1             Thank you, Mr. Ivetic.

 2             MR. IVETIC:

 3        Q.   Sir, how would you describe the attitude of the brigade as to or

 4     towards Arkan's men?

 5        A.   I cannot say for sure because during that month before I fled

 6     Sanski Most, I was unable to find out how they had arrived, at whose

 7     invitation.  I know that my entire section of the brigade was engaged in

 8     the Sanski Most-Kljuc front.  None of us were there.  Between the 16th

 9     and the 19th, there were some police officers left in town.  But since

10     all the men from the brigade were in position and he was in the hotel, I

11     couldn't know.

12             JUDGE MOLOTO:  But how was the interaction between you and then

13     Arkan's men on the 20th when you met them at Privredna Banka?

14             THE WITNESS: [Interpretation] We had a major problem explaining

15     that we had just come back the previous night, that our forces were

16     crushed, that we had no idea where most of our men were.  But they were

17     arrogant and we gave them a wide berth.  We feared them.

18             JUDGE MOLOTO:  Did they shave your heads like they had done to

19     the other people?

20             THE WITNESS: [Interpretation] No.  We kept telling them that we

21     had just arrived that night and that we were supposed to see the

22     commander to see what we were going to do, how to find our men, and it

23     was difficult to convince them.

24             MR. IVETIC:

25        Q.   Now, sir, you speak here of Muslims and Croats, 1.000 inhabitants

Page 28442

 1     in various neighbourhoods that were -- that were mis -- that had harm

 2     done to them by these Arkan's forces.

 3             First I want to ask you:  The territory that these Croats and

 4     Muslims lived upon, was it controlled by the VRS or by the ABiH?

 5        A.   No.  At that time we had the whole town under our control, but

 6     those people had just decided to stay.  The entire neighbourhood known as

 7     Aganovici on the right bank of the Sana River, which means from the hotel

 8     and the municipality building, up to the part called Poljaci, populated

 9     mainly by Croats.  So there were about a thousand Muslims and Croats who

10     just stayed, to live there.

11        Q.   And had those Muslims and Croats that stayed there caused any

12     trouble or fought against the VRS during the prior four years?

13        A.   No, no.  I know some of those people personally.  One of them

14     played football with me.  No.

15        Q.   Okay.  And you say that Arkan -- that all harm was done to them

16     by Arkan and his men.  What do you mean by that, if you have any details?

17        A.   No, I didn't have a chance to get any information about that

18     because I didn't spend any of that time in town.  The whole period until

19     I left Sanski Most, I was near the Novsko front line.  I was touring our

20     units to tell men that some of our people were missing, and if somebody

21     shows up they shouldn't shoot.  They should treat them carefully.  We had

22     lost 98 men.  I know that four or five had got out, a few were found and

23     identified.  For the rest, I don't know to this day where they ended up.

24        Q.   Sir, on behalf of General Mladic and the rest of my team, I thank

25     you for answering my questions?

Page 28443

 1             MR. IVETIC:  Your Honours, that completes the direct examination.

 2             JUDGE MOLOTO:  Thank you, Mr. Ivetic.

 3             Mr. Jeremy --

 4             JUDGE FLUEGGE:  May I put one question to the witness before --

 5             JUDGE MOLOTO:  Yes, by all means.

 6             JUDGE FLUEGGE:  -- the floor is for the Prosecution.

 7             Mr. Corokalo, I would like to clarify one matter.  It's me

 8     speaking at the moment.

 9             You described where and under which circumstances you met the two

10     men with the two men with the nicknames Lola and Nail in a private house

11     drinking whisky and smoking cigarettes.  In your statement, you told us

12     they were known as commanders of paramilitary units.  You didn't mention

13     that in your answers to Mr. Ivetic.

14             Could you explain that a little bit more, what kind of units and

15     what is the basis of your knowledge?

16             THE WITNESS: [Interpretation] I didn't say that I saw those men.

17     When the operation ended, I inquired from my men - I had to for security

18     reasons - and they told me they had found those men in that house.  We

19     knew they didn't live there.  What were they doing there if they weren't

20     part of some organisation?  Those were our conclusions.

21             JUDGE FLUEGGE:  Yes.  Thank you for this clarification that you

22     personally didn't meet them in the house.

23             Second, you say in paragraph 15 - perhaps we can get that back on

24     the screen; it's the previous page - they were known as commanders of

25     paramilitary units.  Not as members but commanders.  That is in your

Page 28444

 1     statement.  What does that mean?

 2             THE WITNESS: [Interpretation] Look, the word "komandir" or

 3     "leader," that's questionable.  From our information, these men had

 4     contacts in Italy, in Germany.  We knew that they were of suspicious

 5     background.  We knew they had been involved in smuggling before and they

 6     had been deported.  And then by inquiring, we found out that these men

 7     had a say in these things.

 8             JUDGE FLUEGGE:  In which things?

 9             THE WITNESS: [Interpretation] Arming, distribution of weapons to

10     Muslims.

11             JUDGE FLUEGGE:  That is your understanding of the term

12     "commander"?

13             THE WITNESS: [Interpretation] Yes, yes.

14             JUDGE FLUEGGE:  Thank you.

15             JUDGE MOLOTO:  Just a follow-up.  But even doing what you say

16     they did does not necessarily make them members of any paramilitary unit.

17     They could have just been armed traffickers.  What makes you think that

18     they belonged to a paramilitary unit?

19             THE WITNESS: [Interpretation] At the conclusion as to whether

20     they were members of paramilitary units or were just helping in the

21     arming, for me that's one and the same thing.

22             JUDGE MOLOTO:  I see.  So you actually have no basis for

23     concluding that they belonged to a paramilitary unit except for thinking

24     that:  If you arm people, therefore you do belong to a paramilitary unit.

25     That's the only basis?  Thank you so much.

Page 28445

 1             Mr. Jeremy.

 2             MR. JEREMY:  Thank you, Your Honours.

 3                           Cross-examination by Mr. Jeremy:

 4        Q.   And good morning, Mr. Corokalo.

 5        A.   Good morning to you, too.

 6        Q.   Now I'd like to begin by just taking a few minutes to clarify

 7     where you were and when during the war period.

 8             So in paragraph 4 of your statement, we read that in September

 9     1991 you were deployed to the Jasenovac theater; and later, in 1992, you

10     returned to Lusci Palanka, Sanski Most.  Now, this return was in early

11     April 1992; is that correct?

12        A.   Yes, thereabouts.

13        Q.   And were you also in Sanski Most in March 1992?

14        A.   Yes, yes, it's possible that I was there.  I could have been.

15        Q.   So you -- you returned a month before the return of your units in

16     April.  You came become in a personal capacity; is that correct?

17        A.   When the unit returned to Lusci Palanka, we went around, liaison

18     officers, as it were, some of us, who kept contact with the population in

19     Sanski Most.  We would go back to Sanski Most to keep in touch, so we

20     didn't have to be there all the time.

21        Q.   But according to your recollection, you returned back to

22     Sanski Most for a period of [sic] March 1992; is that correct?

23        A.   Well, yes.  At about that time.  Sometime in the spring, yes.

24        Q.   All right.  In paragraph 4, we read that on your return to

25     Sanski Most, which I read as the return of your unit, you were sent home

Page 28446

 1     where you stayed until May 1992.  Now, when in May 1992 did you return to

 2     active duty?

 3        A.   We weren't returned to active duty in the brigade immediately.

 4     We remained as liaison officers, a certain number of men, we remained

 5     there to work with the TO with some of our men who were trying to

 6     self-organise, to establish local parts of the town, to organise them.

 7     And because I was involved in sports and all these activities before the

 8     war, we felt that this was --

 9             THE INTERPRETER:  The interpreter did not hear the last portion

10     of the witness's answer.

11             MR. JEREMY:

12        Q.   Sir, could you -- we only heard a part of your answer.  So we

13     heard that you were "involved in sports and all these activities before

14     the war, we felt that this was ..." and then we didn't hear the end of

15     your answer.  Could you repeat, please.

16        A.   We decided that I and several other men who were men of

17     significance because we were involved with sports and those activities,

18     we decided that we should return to the town and organise people and

19     return people to activities that were ongoing then and that were the

20     result of all the developments there.

21        Q.   And this period during which you were working as a liaison

22     officer with the -- working with the TO, was that in May 1992?

23        A.   Yes, this went on for a while.

24        Q.   All right.  Now you became -- we read in your statement that you

25     were a -- that you were a security officer at the brigade command.

Page 28447

 1        A.   Very well.

 2        Q.   Now, your superior was Reserve Captain First Class

 3     Pero Milicevic, yes?

 4        A.   That's correct.

 5        Q.   And his superior in the 1st Krajina Corps, the chief of the organ

 6     for intel and security in May and June, was Colonel Milan Stevilovic,

 7     yes?

 8        A.   I don't know about that part.  Pero was in charge of us, the

 9     reservists, but I didn't know about the chain of command going upwards.

10     I wasn't in a position to know at that time.

11        Q.   All right.  And if I tell you that Colonel Stevilovic was

12     replaced by Colonel Stevan Bogajevic in early 1992, do you know about

13     that or is that also up the chain of command to a level that you're not

14     aware of?

15        A.   No, certainly no.

16        Q.   Okay.  In your statement and during your testimony yesterday and

17     today, you talked about questioning persons from Hrustovo and Vrhpolje.

18     Now, this questioning was carried out during early June 1992, yes?

19        A.   Well, those were the events.

20        Q.   Yes.  And was this questioning carried out in early June 1992?

21        A.   I can't tell you.  This was sometime in May or June, but I can't

22     really be specific about this period.  There were a lot of developments,

23     but I know that that period was approximately the way you put it, but I

24     can't recall every detail.

25        Q.   And you carried out this questioning in your capacity as a

Page 28448

 1     security officer in the brigade; correct?

 2        A.   That's correct.

 3        Q.   Now, we'll come back to those events, but for now I want to

 4     continue with the chronology of your war history.

 5             Now, at various points in your statement, you discussed your

 6     involvement in Operation Corridor, including at Modrica, Odzak, and

 7     Gradac.  Now, it's not always clear to me when you're referring to the

 8     involvement of your brigade in these operations and when you're referring

 9     to your own personal involvement so that's something that I want to

10     clarify.

11             Now, you say that you went along with the 3rd Battalion to

12     Operation Corridor where you relieved the 1st Battalion of your brigade.

13     Now, that 1st Battalion was also known as the Crni Djordje Battalion;

14     correct?

15        A.   No, you're not correct.  I didn't say that I was with the

16     1st Battalion.  I was with the 3rd.  The 1st Battalion preceded us.  We

17     relieved them.  So I came to relieve the 1st Battalion in early June.

18     The corridor was breached on the 28th of June.  So I came as a relief for

19     the 1st Battalion.  It was never called the 1st Battalion.  It was never

20     called the Crni Djordje.  The 1st was called the 1st, the 2nd was called

21     the 2nd, and the 3rd was the 3rd.  And me, as a member of the 3rd

22     Battalion, I came to relieve the 1st Battalion.  And then later we went

23     to Modrica and Odzak.

24        Q.   Okay.  The 1st Battalion, was that commanded by Captain

25     Milovan Lazic?

Page 28449

 1        A.   No, Miroslav Radakovic.

 2        Q.   Okay.  I'd like to show you a document in connection with these

 3     answers.

 4             MR. JEREMY:  And could we please see P2419.  And this is a report

 5     from the command of the 6th Partizan Brigade, and specifically the

 6     10th Partizan Battalion to the 6th Partizan Brigade forward command post.

 7     And it's dated the 15th of July, 1992.

 8        Q.   Now, sir, if you take a look at the document on the left side of

 9     your screen, in the first paragraph we read that:

10             "Based on the Order of the 6th Partizan Brigade Command," and we

11     see the strictly confidential number, "of the 13th of July, 1992, the

12     10th Partizan Battalion Command has replaced the Crni Djordje

13     Battalion" --

14             JUDGE MOLOTO:  "Replenished."

15             MR. JEREMY:

16        Q.   Excuse me, "replenished the Crni Djordje battalion with the

17     following VO," which earlier in the document we read is an abbreviation

18     for military conscripts.

19             MR. JEREMY:  Now, could we please go to page 4 in the English

20     and 3 in the B/C/S.

21        Q.   Now, sir, we see a list of 94 names, and number 92 is

22     Dusko Corokalo, security officer.  That's you; correct?

23        A.   Yes.

24        Q.   Now, this -- this order is dated the 15th of July, 1992.  This is

25     the order that pursuant to which you were first sent to the corridor

Page 28450

 1     operation; correct?

 2        A.   No -- well, actually, I've never seen this order before.  I

 3     wasn't with the 1st Battalion.  I relieved them.  Perhaps it was planned

 4     for me to be there, but I never received this kind of order.  What

 5     happened was Pero Malicevic came.  It was probably planned that I should

 6     be with the 1st Battalion for I don't know what reasons, and I actually

 7     went there as a replacement of the 1st Battalion.

 8             MR. JEREMY:  Could we go back to the first page, please, of this

 9     document.

10        Q.   And, sir, the way that I read this list is that the -- the list

11     of names are those persons who are replenishing or, to put it another

12     way, replacing the Crni Djordje Battalion.  And, therefore, on that

13     basis, my reading of this document is that, pursuant to this order,

14     you -- you were sent to the corridor as a replacement for persons in the

15     Crni Djordje Battalion.

16        A.   Well, I state with full responsibility that this is the first

17     time that I ever have seen this document.  I never had it in my hands,

18     and I see that it was signed by Milovan Lazic.

19             Now, whether there was a plan for me to be there, I really don't

20     know anything about that.  But what I do know is that the 1st Battalion

21     of the 6th Sana Brigade was never referred to as Crni Djordje.  There was

22     a group from Palanka that was called Crni Djordje.

23             As for the 1st Battalion, as I said, this is the first time that

24     I lay my eyes on this document.

25        Q.   Okay.  And it's -- I understand that you haven't seen the

Page 28451

 1     document before and that's -- that's not important.  My purpose of

 2     showing you this document was an attempt to date the time that you went

 3     to the corridor operation.

 4             Now, you've said that you were involved in operations in

 5     Sanski Most in early June 1992.  So can you give us a date when you were

 6     first sent from Sanski Most to the corridor operation?

 7        A.   The 1st Battalion was already at the corridor, and I went there

 8     as a replacement.  Now, the -- on the 28th of June, the corridor was

 9     broken through, so I was there in -- at the beginnings.  I can't recall

10     the date, but I was there when it was broken through, and I remained

11     there till mid-August; some 40 days or so.  About 40 days, that's for

12     sure.

13        Q.   So you were there from -- so you left in mid-August and you

14     arrived 40 days before that.  Can we agree on that?

15        A.   Well, yes.  In mid-August, I had already returned to Sanski Most

16     but with the 3rd Battalion.  The commander was Ranko or

17     Branko Predojevic.

18        Q.   Now after you returned to Sanski Most, I understand you were

19     there for a period of time before being sent to Gradacac.  How long were

20     you in Sanski Most from mid-August?

21        A.   After I returned from the corridor, some 10 to 15 days at most, I

22     was off duty.  We called it a rest period.  Because there weren't many of

23     us security officers, we couldn't spend a lot time resting.  So I was

24     then re-engaged as needed.  So it couldn't have been more than 15 days,

25     that's for sure.

Page 28452

 1        Q.   Okay.  So can we agree that you were in Sanski Most from early

 2     April to late June/early July, at which point you were sent to the

 3     corridor operation.  You then returned in mid-August and you remained in

 4     Sanski Most for 10 to 15 days.  And then, after that, I understand you

 5     were -- you left Sanski Most and you were in other war theatres and you

 6     didn't return until 1995, the autumn of 1995; is that correct?

 7        A.   Yes, approximately.  Yeah.

 8        Q.   Okay.  Now I'd like to move on, and I'd like to discuss the

 9     Mahala which you mention in your statement and which you have discussed

10     with Mr. Ivetic this morning.

11             Now, when you refer to Mahala in paragraph 17 of your statement,

12     you're referring to events on the 25th of May, 1992; is that correct?

13        A.   Well, I can't really tell you with certainty about the date,

14     whether it's exact, but all the events happened at that time,

15     approximately.  All the events in that territory.  But I would also just

16     like to tell you that Mahala is just a neighbourhood.  It starts near my

17     house on the right-hand side.  The problem was with Otoke, as far as the

18     defence of my part of the town was concerned.  So the neighbourhood Otoke

19     on the right hand of the Sana River, Otoke, Muhici, and Mahala.  So it

20     wasn't just Mahala.  It was these neighbourhoods, the three:  Mahala,

21     Otoke, and Muhici.  Now my house was on the left-hand side, on the left

22     bank of the Sana, and we were, in fact, on the forward lines of the front

23     line, the line of separation with them.

24        Q.   Now, were you actually personally involved in what you described

25     as the -- in your -- in paragraph 17 of your statement as the "armed

Page 28453

 1     fights" in Mahala, or were you at the command post in Lusci Palanka at

 2     the time?

 3        A.   No, no.  I was in Sanski Most as I've already said.  I was in my

 4     cafe bar.  We self-organised, as I already mentioned.  We had some kind

 5     of staff there of ours.  I was there.  Now, the unit that was then

 6     brought by Radak, that was the first time I saw that man, I believe he

 7     was a captain.  Now, I was responsible to show them the line where it

 8     begins towards Otoke, Mahala, and Muhici.  They are all one whole.  So I

 9     actually introduced them to the area.  I led them to the area because my

10     house was right there.  So then I had to go back home to my home because

11     we didn't know how the whole thing was going further to develop.

12        Q.   And how close is your cafe bar to Mahala?

13        A.   Well, from Otoke, that's where it was connected.  But from

14     Mahala, it was about 2 kilometres further up.  But from Otoke itself, it

15     was about 200 metres.  That's where my house was.

16        Q.   Now, were you -- were you among the Serb forces that entered

17     Mahala on the 25th of May, 1992?

18        A.   Only at the beginning, at the Otoke end.  So you have to bear

19     that in mind.  I was there at the Otoke end.  I led the units there.  I

20     didn't go through Muhic or Mahala, I was just the intro for Radak into

21     Otoke and then I went back to my position, to my house, my coffee bar.

22        Q.   Now, in paragraph 15 of your statement, you refer to Serb forces

23     finding a large quantity of automatic weapons and a 60-millimetre mortar

24     in Mahala.

25             Now, this morning you've testified that you noticed people

Page 28454

 1     carrying hunting weapons at night going from your area in the direction

 2     of Mahala.  Were you involved in counting the weapons found by Serb

 3     forces in Mahala?

 4        A.   No, no, definitely not.  But I was telling you about the

 5     beginning.  At the start people with hunting weapons were seen, but I

 6     couldn't go in depth.  That was not allowed.  You couldn't get to Mahala

 7     or Otoke.  Even before the war it wasn't easy to walk there at night

 8     safely.

 9             Now, this part and -- including Mahala, where there were a lot of

10     people of Muslim ethnicity, about 90 per cent of the people there were

11     Muslim, they were of low levels of education.  They were problematic

12     people.  They would cause trouble.  And you would have a problem if you

13     decided to go there, because these people were as they were, they would

14     start brawls and street fights and ...

15        Q.   So I think you -- you answered my question in the first sentence

16     of your answer with, "no, no, definitely not."  So you weren't involved

17     in counting of the weapons collected in Mahala.

18             Now in paragraph 15, you say that Serb forces found a large

19     quantity of automatic weapons and a 60-millimetre mortar.  Now, what is

20     the basis of your knowledge for this claim in your statement?

21        A.   Well, I got that bit of information from the men who had been

22     there.  We were interested to learn what had happened there, so I was

23     told by these men when they returned that they had found weapons there.

24        Q.   Were these men members of your unit?

25             THE INTERPRETER:  Automatic weapons, interpreter's addition.

Page 28455

 1             THE WITNESS: [Interpretation] Members of the 6th Sana Brigade,

 2     yes.  But the members -- my unit of the Territorial Defence did not.

 3     This part of the street.  No.

 4             MR. JEREMY:

 5        Q.   And did they give you an indication of the number of automatic

 6     weapons that they had found?

 7        A.   No.  No one mentioned in that sense the number of weapons.  But,

 8     as I said, there was a large quantity or largish quantity of weapons,

 9     including that 60-millimetre mortar.  But the exact number, no.

10        Q.   So no one mentioned a number to you but you, nevertheless,

11     believed that there was a large quantity of weapons there -- found there?

12        A.   Well, "large," that term, in this general story, yes.  We -- the

13     information from the people we learned -- we learned from the people who

14     were returning was that there was a large quantity, but what exactly the

15     number was I really wouldn't know.  But that was the term they used.

16        Q.   Sir, I'd like to put it to you that the reality is that there

17     wasn't a large quantity of weapons found in Mahala.  In fact, no

18     significant amounts of weapons were found.

19             MR. IVETIC:  Object.  Your Honours, can we have a bases for this

20     then?

21             MR. JEREMY:  Could we please see P2889.

22        Q.   And, sir, coming up on our screens is a report from the SJB chief

23     Mirko Vrucinic to the Banja Luka security services centre, and -- so it's

24     from the Banja Luka security services centre, and it's dated the 15th of

25     June, 1992.

Page 28456

 1             And, sir, did you -- so you knew who Mirko Vrucinic was at this

 2     time, yes?

 3        A.   There was no Marko Vrucinic but there was Mirko Vrucinic.

 4        Q.   Thank you.  And in paragraph 3 of this document, we read:

 5             "On the 25th of May 1992, this 'disarming' was followed by a

 6     military action (attack) against the downtown neighbourhood of Mahala,

 7     which resulted in the capture of 2.000 civilians but no significant

 8     amounts of weapons have been found because they had been concealed

 9     earlier."

10             And, sir, that's the reality, isn't it, that no significant

11     amounts of weapons were found?

12             MR. IVETIC:  Your Honours, for context I would ask that the next

13     paragraph be also presented which provides more information about "the

14     Muslim population had been relatively well armed predominantly with

15     infantry weapons, mines, and explosives."

16             JUDGE MOLOTO:  I guess you can do that in re-examination,

17     Mr. Ivetic.

18             Carry on, Mr. Jeremy.

19             MR. JEREMY:  Thank you, Your Honours.  And I would just like the

20     witness to answer my question.

21        Q.   Which is that the reality is that no significance -- no

22     significant amounts of weapons were found in Mahala?

23        A.   I don't agree with you.  You are contesting the -- in the sense

24     that you are denying the information that I received.  Now what is a

25     significant quantity, I -- you know, it's hard to determine, but this was

Page 28457

 1     done in a report by the police, and that's different.  Now, if you ask

 2     the men who had actually been there and they tell you, then that's a

 3     different issue.

 4             Now it's a difference in terminology.  They use this term there

 5     in this report, but whether a significant quantity is five or ten or --

 6     what that means to an ordinary man, that's a debatable issue, but weapons

 7     were there.  There were weapons found according to this document that I

 8     see before me.

 9        Q.   Okay.  We'll leave that there.

10             MR. JEREMY:  I know we are at break time, Your Honours.

11             JUDGE MOLOTO:  We take a break.

12             Before we do so, sir, may you please -- we're going to take a

13     break for 20 minutes and please get back in 20 minutes.  You may follow

14     the usher.

15                           [The witness stands down]

16             JUDGE MOLOTO:  We take a break and come back at 5 to 11.00.

17     Court adjourned.

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

19                           --- On resuming at 10.58 a.m.

20             JUDGE MOLOTO:  The witness may be escorted into the courtroom.

21                           [The witness takes the stand]

22             JUDGE MOLOTO:  Mr. Jeremy.

23             MR. JEREMY:  Thank you, Your Honours.

24        Q.   Now, sir, I'd like to resume by discussing events in Hrustovo and

25     Vrhpolje in late May, early June 1992.  So in your statement in paragraph

Page 28458

 1      17, you state that:

 2             "After the armed fights in Mahala, I went to the Gradacac war

 3     theater and I stayed there until the end of the war."

 4             Now, from the -- the questions and answers today, I think that

 5     this is correct, that we've established that you actually went to the

 6     corridor in late June, early July; therefore, not immediately after the

 7     events in Mahala.  And therefore, I'd like to ask you about these events

 8     that happened in Hrustovo and Vrhpolje in early June period.

 9             Now, were you personally involved in the disarming operations in

10     Hrustovo and Vrhpolje in late May, early June 1992?

11        A.   No.

12        Q.   Okay.  And in -- so in paragraph 16, and I think you've mentioned

13     this also today, when you -- when you say that you emphasize that the

14     Hrustovo village remained untouched until an elderly Muslim man killed

15     Soldier Brajic with a rifle, that's something that you heard from others;

16     correct?

17        A.   Correct.

18        Q.   Now, even though you were not involved in the disarming

19     operations, you were nevertheless involved in questioning persons

20     captured during those operations; that's correct, yes?

21        A.   Yes.  I mean that you are not putting certain things right.  What

22     happened in Hrustovo with the killing of Brajic's brother has nothing to

23     do with the action I took later, when that group from Golaja was

24     exchanged.  Then we went through a process of screening, looking for

25     people who were aiders and abettors, people we had information about.

Page 28459

 1     One action was the murder of Brajic's brother, and one other action - a

 2     completely different action - was when we were screening people looking

 3     for helpers.  We had operative information and we wanted to identify

 4     people who were helpers to those from Golaja.

 5        Q.   So do I understand it correctly that you were -- you were not

 6     involved in questioning persons captured during the late May, early June

 7     disarming operations in Vrhpolje and Hrustovo.  Instead, you were

 8     involved in questioning persons captured in Golaja woods; is that

 9     correct?

10        A.   I told you, the action of capturing people when Brajic's brother

11     was killed, I didn't participate, but later in Golaja I participated in

12     the screening operation, looking for helpers.  I was not present when

13     Brajic's brother was killed and I did not take part in that action.

14        Q.   But my question is whether you asked questions of persons

15     captured during the disarming operations in Hrustovo and Vrhpolje in late

16     May and early June.

17        A.   I was part of that operation, but you have to separate the

18     killing of that Brajic from that operation.  The two have nothing in

19     common.

20        Q.   Now while you were questioning these persons captured during the

21     disarming operations in Hrustovo and Vrhpolje, I'd like to ask you about

22     what information you were able to obtain, and I'd like to ask you about

23     two particular incidents.

24             Now, this Trial Chamber has received evidence that on the 31st of

25     May, 1992 Serb soldiers killed 27 unarmed civilians who were sheltering

Page 28460

 1     in a garage in Hrustovo.  During your interview of persons from this

 2     area, did you learn any information about this particular event?

 3        A.   No, I never heard anything about the killing of people in a

 4     garage.  I was not in charge of operative work on the ground.  We had a

 5     classroom in a school house, and we were looking for certain people.  I

 6     remember one nickname, Zeka, we were looking for him.  Unfortunately, we

 7     didn't find him.  I didn't leave that room for two days and one night.  I

 8     never heard about the killing of those people.

 9        Q.   And, sir, did you subsequently hear about this event or you'd

10     never heard about it before?

11        A.   Never.  Never heard.  Because the people who did the operative

12     work, I don't even know them.  Because the geographic area of Hrustovo

13     and Vrhpolje is very large.  I didn't even have a chance to meet them.  I

14     don't know the area at all except for the Hrustovo cave, where I went on

15     a school trip as a child.

16        Q.   But you were questioning persons captured in this area during

17     late May, early June, yes?

18        A.   That's right.  Brajo Grman [phoen].

19        Q.   Sir, the second instant I was to ask you about was an event on

20     Vrhpolje bridge also on the 31st of May, 1992.

21             Now, this Trial Chamber has received evidence that their soldiers

22     rounded up the inhabitants of Begejci near Vrhpolje, took the men to

23     Vrhpolje bridge, beat them, forced them to jump off, and shot them with

24     automatic weapons as they did.  Did you learn about this incident during

25     your interview of captured persons from Vrhpolje?

Page 28461

 1        A.   That incident again is not related to what I was doing, but I

 2     know about that incident.  I heard about it.

 3        Q.   And did you hear about it during the interviews that you were

 4     carrying out?

 5        A.   No.  When I returned to town, I heard about that incident.

 6        Q.   So you heard about it contemporaneously?  You heard about it in

 7     early June 1992; correct?

 8        A.   Right after, during those few days.

 9        Q.   And did you learn that the perpetrators of this incident were

10     members of the VRS?

11        A.   I don't know from which units they were.  This did not leak to

12     the public, but people were talking around town and I checked it.  But as

13     to what units were involved, I did not inquire.

14        Q.   Now, in paragraph 13 of your statement, we read that the

15     interviews that you were involved in were conducted at the elementary

16     school in Vrhpolje, and you've mentioned that a few times during your

17     direct testimony.  What was the name of that school, if you recall?

18        A.   I can't remember.  Look, the Vrhpolje area is large, unfamiliar

19     to me.  There was one old school and one new school.  I really don't

20     know.

21        Q.   Okay.  Now, in that same paragraph --

22             JUDGE FLUEGGE:  Sorry, have you been in the old school or in the

23     new school?

24             THE WITNESS: [Interpretation] The old one.

25             JUDGE FLUEGGE:  Mr. Jeremy.

Page 28462

 1             MR. JEREMY:  Thank you, Your Honour.

 2        Q.   Now, sir, in that same paragraph 13, you emphasize that the

 3     individuals that you spoke to were not detained either during or after

 4     the interview.  Now, during your testimony yesterday at transcript page

 5     28430, lines 10 to 14, referring to your screening of individuals at this

 6     school, you said, and I quote:

 7             "I participated in the screening or the questioning of people

 8     because the logistics wanted to have certain number of people.  I and

 9     another two co-workers of mine worked on that.  We never left the room

10     and therefore I don't know what happened to them afterwards, where they

11     went and so on."

12             So just to clarify, which of those two accounts is correct?  Do

13     you know that the individuals you spoke to were not detained after the

14     interview, or do you not know about what happened to them after the

15     interview?

16        A.   I don't know.  I don't have that information.  I didn't get a

17     chance to find out.

18        Q.   All right.  Now leaving aside those persons that you interviewed

19     who you don't know whether or not they were detained, you nevertheless

20     know that other individuals captured during the operations in Mahala,

21     Vrhpolje, and Hrustovo were detained in various locations in Sanski Most,

22     including the sports hall, Betonirka, and later the Krings factory hall.

23     You know that; right?

24        A.   I knew about that.

25        Q.   And were you also personally present at those facilities between

Page 28463

 1     May and July 1992?

 2        A.   I never was at Betonirka.  I was present by the sports hall

 3     because it's close to my house.  The sports hall is near the bank of the

 4     Zdena river.  And I was at Krings as well because I had heard that some

 5     elderly people were being held there because in the Second World War they

 6     had displayed solidarity.  I just went to check that information.

 7        Q.   Now, you're also aware that many persons held at the locations

 8     that I've mentioned and that you've also added to were taken to Manjaca

 9     camp, yes?

10        A.   I heard about the Manjaca camp when that operation began.  The

11     news spread around town.  But, of course, I didn't know in advance whom

12     they would be taking way.  We couldn't learn that from our sources.  When

13     I heard that it was happening, and it was about 500 metres from my coffee

14     bar where we had our headquarters, I went there to see what's going on.

15     I spent about an hour there but only as an observer.

16        Q.   So, sir, just to clarify, when you say "I heard that it was

17     happening," here you're referring to the transport of captured persons to

18     Manjaca; correct?

19        A.   Precisely.

20        Q.   And do you -- you seem to be referring to a particular incident.

21     Do you refer to the -- do you recall the date of that, date of that

22     transportation?

23        A.   No, no.  I don't remember dates because all these things happened

24     in a short period.  I can't remember.

25        Q.   And were you involved in securing this particular convoy?  Were

Page 28464

 1     colleagues of yours involved in securing this particular convoy?

 2        A.   No, I was not.  And none of my colleagues from my street

 3     participated either.

 4        Q.   How about the colleagues who weren't from your street?  Did you

 5     recognise any persons who were involved in securing the convoys?

 6        A.   I did not.  I was standing near the main entrance and they were

 7     on the flank of the sports hall.  We were not allowed to go around.  You

 8     could not go anywhere close to them.  We were standing on the plateau

 9     outside the secondary school centre.  It was a couple of hundred metres

10     away that we were standing.  There were lots of people around.

11        Q.   I'd like to move now to the --

12             JUDGE FLUEGGE:  Before you move to another topic, I have a

13     question to one point.

14             You told us about your questioning of people in the school.

15     Mr. Jeremy quoted from the transcript of yesterday, and there I read:

16             "I participated in the screening of the questioning of people

17     because the logistics wanted to have certain number of people."

18             Who is "the logistics"?

19             THE WITNESS: [Interpretation] The men from our Crisis Staff, our

20     defence.  We had a certain list of names that we were looking for.  I

21     remember one nickname, Zeka.  Of course, there were more people on the

22     list that we were supposed to find.

23             JUDGE FLUEGGE:  And what does it mean:  "They wanted to have

24     certain number of people"?

25             Just a number of people or what do you mean by that?

Page 28465

 1             THE WITNESS: [Interpretation] We had a list of names, a certain

 2     number of names of people whom we were supposed to find to determine

 3     whether they were still in the area or not.

 4             JUDGE FLUEGGE:  But I understood your testimony that you were

 5     responsible for questioning the people.  They were brought to you.  How

 6     can you work on finding people if you're not out in the field in the town

 7     or wherever?

 8             THE WITNESS: [Interpretation] The three of us, we had a list of

 9     people.  The people who did the operative work on the ground were looking

10     and bringing people to us, and then we would look on -- at the list and

11     see if the person was on the list or not.

12             JUDGE FLUEGGE:  And for that purpose, just to identify them, they

13     were brought to the school where you were working together with two

14     co-workers; is that correct?

15             THE WITNESS: [Interpretation] Correct.

16             JUDGE FLUEGGE:  I have another question.  A little bit earlier

17     you were asked about the incident at the Vrhpolje bridge, and you said

18     you heard about this event during those few days.  You say you heard that

19     "by people talking around town and I checked it."

20             I really don't understand.  Can you explain that a little bit

21     further.  From whom did you hear that and what did you check?

22             THE WITNESS: [Interpretation] The events that I mentioned in

23     those few days, all of this transpired in a couple of days, Golaja,

24     Mahala, these were linked events, and of course I wasn't always present

25     in all those locations.

Page 28466

 1             Now, I heard of these things when I returned to the town, and

 2     then I would hear about an incident.  There were a number of people that

 3     I trusted, and then when I got information from them, whether something

 4     had actually happened or not and what had transpired, I would -- I

 5     received the information from those men and confirmed that that had

 6     happened.

 7             JUDGE FLUEGGE:  And you knew these men from before, these people

 8     from whom you received this information?

 9             THE WITNESS: [Interpretation] Well, yes.  These were people from

10     Territorial Defence who worked with me on gathering intelligence.  They

11     were credible people.  They weren't people who would spread rumours.

12             JUDGE FLUEGGE:  Can you give me the names?

13             THE WITNESS: [Interpretation] I couldn't specifically mention any

14     names for any specific events because these -- all these events were

15     linked and I couldn't really remember.

16             JUDGE FLUEGGE:  You said you knew these people from before and

17     you trusted them, and now you say you don't know who it was who told you

18     about this specific event at the bridge.

19             THE WITNESS: [Interpretation] I said that I knew those people,

20     all those people, all of us who were there together who worked with me.

21     I trusted them and I received some information -- this information from

22     them.  We received information, approximately all of us, we would receive

23     the same type of information in those couple of days.  Now, I cannot

24     remember as I sit here specifically who told me about this particular

25     event.

Page 28467

 1             JUDGE FLUEGGE:  Thank you.

 2             MR. JEREMY:  Thank you, Your Honours.

 3        Q.   Witness, just before we -- we move away from this issue of the

 4     transportation of persons from the sports hall to Manjaca, you've said

 5     that you and those persons on your street were not involved in securing

 6     that particular convoy.  It's correct, though, that other members of the

 7     VRS provided security for that convoy, yes?

 8        A.   Correct.

 9        Q.   Now, I'd like to move to another topic, the departure of

10     non-Serbs from Sanski Most.  Now, in paragraph 19 of your statement, you

11     say that:

12             "Until the arrival of Arkan in 1995, there were several

13     neighbourhoods with more than a thousand inhabitants of Muslim and Croat

14     ethnicities in Sanski Most."

15             Now, you've said today that Arkan arrived in Sanski Most in

16     September 1995, yes?  Now -- so -- I see that you're shaking your head,

17     if you could just verbalise a response, just "yes" or "no."

18        A.   Well, on the 16th, I left and he wasn't this.  He appeared

19     sometime between the 16th and the 19th.

20        Q.   Okay.

21        A.   Or thereabouts.

22        Q.   Thank you.  Now, you -- you're aware that before Arkan arrived in

23     the period between 1991 and February 1995, tens of thousands of Muslims

24     and Croats, numbering the overwhelming majority of these ethnic groups,

25     had left Sanski Most; you are aware of that, correct?

Page 28468

 1        A.   Absolutely.

 2        Q.   And the security organ in your brigade was also aware that during

 3     1992 Muslim and Croat populations were -- were moving out of Sanski Most

 4     on a massive scale, yes?

 5        A.   That's correct.

 6        Q.   Now in connection with this answer, I'd like to show you a

 7     document.

 8             MR. JEREMY:  Could we please see 65 ter 31603.

 9        Q.   Sir, coming up now on the screen before you is a report dated the

10     3rd of August, 1992 to the Prijedor operations and tactical group

11     security chief, and it's --

12             MR. JEREMY:  If we go down to the bottom of the page in English.

13        Q.   We see that it's from the security chief, Captain First Class

14     Pero Malicevic.  He was your boss, yes?

15        A.   In the beginning, yes.

16        Q.   Now, I'd like you to focus on paragraph 1 of this document, a

17     "Situation in the Territory," and we read:

18             "Constant control of the territory in the brigade's area of

19     responsibility has been established.  There isn't any new intelligence

20     about the enemy's activities.  The Muslim and Croatian populations are

21     moving out on a massive scale.  This, in our opinion, should be done

22     selectively, in accordance with set criteria.  There is a potential

23     threat coming from those who are combat ready and likely to join the

24     enemy's ranks."

25             Sir, you're aware that in August 1992 the civilian and military

Page 28469

 1     organs of Sanski Most launched an initiative whereby Muslims and Croats

 2     who wanted to stay in Sanski Most were required to make a written request

 3     to stay and to provide a declaration of loyalty.  You're aware of that,

 4     yes?

 5        A.   Yes, I am.

 6        Q.   And this was the procedure that was followed -- that had been

 7     followed by those Muslims and Croats who were still in Sanski Most in the

 8     autumn of 1995 when Arkan was present, yes?

 9        A.   I suppose that's how it was.  I don't really know for certain.  I

10     had a colleague who worked at the bank and who, until the very end

11     almost, was with me and he played football with me.

12        Q.   Just to clarify your answer, that was a Muslim colleague, I take

13     it?

14        A.   Yes.  He, Rufad, these were the men who remained until very late.

15     Now whether they had signed loyalty, I never asked because it wouldn't

16     do.  Probably they did something in keeping with the law because -- and

17     that's how they acted, but -- and -- but they were there.

18             MR. JEREMY:  Your Honours, I'd like to tender this document as

19     the next Prosecution exhibit.

20             MR. IVETIC:  No objection.

21             JUDGE MOLOTO:  The document is admitted into evidence.  May it

22     please be given an exhibit number.

23             THE REGISTRAR:  Document 31603 receives number P6924, Your

24     Honours.

25             JUDGE MOLOTO:  Thank you.

Page 28470

 1             Yes, Mr. Jeremy.

 2             MR. JEREMY:  Thank you, Your Honours.

 3        Q.   Now, sir, I'd like to finish today by discussing your evidence in

 4     relation to Arkan, which you refer to in paragraph 19 of your statement

 5     and you've mentioned him a few times today.  Now, referring to those

 6     Muslims and Croats in Sanski Most in 1995, in paragraph 19 of your

 7     statement, you say that all the harm that was done to those Muslims and

 8     Croats was done by Arkan and his men.

 9             Now, here you're referring to the arresting and abusing of

10     non-Serbs in Sanski Most by Arkan and his men, yes?

11        A.   I have to correct you.  You said 1991 but this was in 1995.

12        Q.   Thank you for that correction.  If that's what I said, that was

13     my mistake.  I mean 1995.

14             But just to ask you to answer my question, this -- this arresting

15     and abusing of non-Serbs is what Arkan was doing in Sanski Most in 1995,

16     yes?

17        A.   Yes, absolutely.  Because those men who were there, there was no

18     reason whatsoever.  I mean, had we wanted to do anything, we could have

19     done it a long time ago.  But when they arrived there, Arkan's men, then

20     they handled these people.  And I was busy at the time, but I know that

21     there were some ten or so people that I knew that I didn't see there

22     anymore.

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

24     with Arkan's presence in Sanski Most in September 1995.

25             MR. JEREMY:  Could we please see P3095.

Page 28471

 1        Q.   Now, sir, this -- this document is a dispatch from the RS MUP

 2     forwarding to the deputy minister and the public security department a

 3     proposal of General Mladic to the RS MUP and the president of the

 4     Republika Srpska.  And it's dated the 23rd of September, 1995.  I'd like

 5     to look at that actual proposal.

 6             MR. JEREMY:  Which is on the second page of this document in each

 7     language.

 8        Q.   So we see that this letter is dated the 23rd of September, 1995,

 9     and we see it is to the president of RS and the RS Ministry of the

10     Interior.

11             MR. JEREMY:  And if we could just go to page 3, please, in each

12     language, just to see the signature.

13        Q.   And we see it's type-signed by Colonel General Ratko Mladic.

14             MR. JEREMY:  Could we go back to page 2, please.  Thank you,

15     Mr. Usher.  And so page 1 in the B/C/S.

16        Q.   Now, sir, we read in the first sentence that the formations of

17     the SDG, Serbian Volunteer Guard, known as Tigrovi, under the command of

18     Zeljko Raznjatovic, aka Arkan, are in the zone of the 1st Battalion of

19     the 1st Brigade of the 2 KK.

20             Now, in the second paragraph, we see details about what Arkan has

21     been doing.  We read that he's being bullying VRS officers, and at the

22     end of the first sentence in the second paragraph, halfway down, we see

23     that he's been arresting and abusing non-Serbs.

24             Now if we go to the fourth paragraph --

25             MR. JEREMY:  And we'll need to go to the next page in the B/C/S,

Page 28472

 1     please.

 2        Q.   We read that:

 3             "The presence of Arkan's paramilitary units precipitated armed

 4     clashes and incidents with individuals and some VRS units, and upset the

 5     population at large after word got out that he arrested all the Muslims

 6     in Sanski Most and liquidated a certain number of loyal Muslim citizens,

 7     including family members of some VRS servicemen, justifying it publicly

 8     as liquidation of an infiltrated sabotage group in Grdanovci village."

 9             Sir, this is the sort of behaviour that you made reference to in

10     your statement and during your testimony; correct?

11        A.   Well, as for this one part, that's how it was.  This was about

12     the men that I knew were there and this would be it.

13        Q.   Now, at the end of the paragraph that we've just been looking at,

14     we see that General Mladic makes some requests and proposals.

15             MR. JEREMY:  If we can go to the next page in the English,

16     please.  Sorry, actually could we go back one -- one page in the English.

17     But just go to the bottom of that page.

18        Q.   So we see that the first request is that:

19             "The President of the RS should revoke his decision that gave

20     Zeljko Raznjatovic the power to make arrests, mistreat, disarm and take

21     away VRS members and civilians ..."

22             Now, sir, were you aware that Arkan was making these arrests and

23     mistreating civilians in Sanski Most pursuant to a decision by

24     President Karadzic?

25        A.   No.

Page 28473

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

 2        Q.   And before we leave this document, sir, I'd just like to focus on

 3     the final point, 4, where we read:

 4             "If the competent state organs who engaged Zeljko Raznjatovic to

 5     carry out unlawful activities fail to take steps within their

 6     jurisdiction, then VRS units shall carry out the order of the

 7     President of RS on disarming paramilitary organisations that are not

 8     under the specific command of the VRS GS."

 9             Now, sir, in the week that followed the writing of this letter,

10     General Mladic's military notebook --

11             MR. JEREMY:  And that's P364, pages 72 to -3.

12        Q.   -- indicates that he first met with President Karadzic and

13     discussed Arkan, and then a day later, he met the chief of the General

14     Staff of the Yugoslav army, Momcilo Perisic, and the head of the Serbian

15     state security, Jovica Stanisic, and again discussed Arkan and

16     specifically his presence in Sanski Most.

17             Now, were you aware of these meetings through your role in the

18     security organ or otherwise?

19        A.   I don't have any knowledge of this meeting, and I didn't have any

20     occasion to know.  Because in my post it wasn't possible for me to obtain

21     this information, this type of information.

22        Q.   Okay.  Well, we won't dwell on those entries.

23             Now, following the conduct of Arkan and his men in Sanski Most,

24     as described by you and by General Mladic in this letter to Radovan

25     Karadzic that we've just looked at, rather than arrest Arkan or kick him

Page 28474

 1     out of the VRS's area of responsibility, the VRS started co-ordinating

 2     with Arkan in Prijedor.  Were you aware of that?

 3        A.   No, absolutely not.  And I couldn't know this.

 4             And secondly, the operations where I was at the Novsko theater, I

 5     was there with my men and couldn't know this or was this possible.

 6             MR. JEREMY:  Could we please see P3094 on our screens.

 7             And, Your Honours, as this document is being brought up, I'll

 8     mention that a revised translation of P3094 has been uploaded into

 9     e-court under doc ID P0046440/A/ET.  And as we'll see when we look at the

10     document, it is a -- the English translation of Milovanovic is --

11     currently reads as "Milanovic," and so we would request that the revised

12     translation replace the one currently in e-court.  And obviously

13     Mr. Ivetic will take a look at that first.

14        Q.   Now, sir, this is an order dated the 11th of October, 1995.  It's

15     from the RS MUP Minister Tomislav Kovac to the chief of the Prijedor CJB.

16     We see that it is copied to, among others, the VRS General Staff.  Now,

17     below this list of persons the document was sent to, we read:

18             "Pursuant to the agreement between the MUP Minister and the Chief

19     of the VRS GS, Manojlo Milovanovic," in the B/C/S, "I hereby order ..."

20             And we see that the order requires the chief of the Prijedor CJB,

21     Zeljko Raznjatovic, and the commander of the Janja Detachment, to start

22     arresting deserters in Prijedor.  And in the final sentence we read that:

23             "This task should be carried out together with unit commands if

24     they are in the area, and if they are not, further command should be

25     agreed with the main staff."

Page 28475

 1             Now, sir, following the co-ordination described in this document,

 2     were you aware that Arkan would go on to commit the same crimes in

 3     Prijedor that he'd just committed in Sanski Most?

 4             JUDGE MOLOTO:  Mr. Ivetic.

 5             MR. IVETIC:  Objection, Your Honour.  Can we have a basis for how

 6     the witness would know about this?  He's asking him to speculate.  If the

 7     witness has said, previously at page 40, line 9, that he couldn't know

 8     anything about this from 9 to 11.

 9             JUDGE MOLOTO:  Mr. Jeremy.

10             MR. JEREMY:  Your Honours, the witness has talked extensively

11     about Arkan.  Mr. Ivetic spent five or so transcript pages discussing

12     Arkan with the witness.  The witness is in this area at the time, and I

13     would suggest it's a perfectly reasonable question for me to ask him if

14     he is aware of what Arkan was doing in Prijedor during the exact same

15     time-period the witness has already discussed.

16             JUDGE MOLOTO:  Object overruled.

17             MR. IVETIC:  Put, Your Honours, the witness has already said he

18     doesn't know.  So how can he ask him again now were you aware?

19             JUDGE MOLOTO:  He can tell us if he knows or doesn't know about

20     this one.  He didn't know what happened earlier.  Now it's about

21     something different, and if he doesn't know, he can tell us.

22             MR. JEREMY:

23        Q.   So, sir, I'll repeat my question about whether you were aware

24     that Arkan would go on to commit the same crimes in Prijedor that he had

25     just committed in Sanski Most.

Page 28476

 1        A.   No, I couldn't possibly have known that.

 2        Q.   Now to finish my questions and to finish this chapter, I'd like

 3     to show you a document where these events were reported in the press, and

 4     I'll ask you if you had an opportunity to see those in the press even

 5     though you may not have been in Prijedor at the time.

 6             MR. JEREMY:  Your Honours, could we please see 65 ter 31619.

 7        Q.   Now, sir, on the screen before you is an article that appeared in

 8     the Serbian publication Vreme International on the 16th of October, 1995.

 9     So that's five days after the order that we just looked at.  The

10     dead-line is -- sorry, the head line is a "A job fit for the Tigers."

11     Now, in the first sentence of the first paragraph, we read that:

12             "According to field reports, after the launch of the offensive on

13     Western Bosnia, Arkan's men mounted earlier last month a huge campaign of

14     enforcing order in a manner" --

15             JUDGE FLUEGGE:  Could the left part of the -- the first paragraph

16     on the left column be enlarged.  Thank you.

17             MR. JEREMY:  Thank you, Your Honour.

18        Q.   And I read on:  "... in a manner already seen in Eastern

19     Slavonia:  By forcibly recruiting people, shaving their heads, and

20     beating them (if necessary)."

21             And I'll skip to the third paragraph and the sentence beginning

22     with the word "nevertheless."

23             "Nevertheless, the Tigers have undoubtedly encountered resistance

24     from the VRS."

25             And I'd like now to look at the last paragraph of -- sorry, the

Page 28477

 1     last sentence of paragraph 2.

 2             MR. JEREMY:  If we could just go down a little bit in the English

 3     and the B/C/S.

 4        Q.   Now, in the last sentence of paragraph 2, we read that:

 5             "General Mladic quickly recognised the danger and, in a recent

 6     interview, commented on 'groups and paramilitaries who gather mostly

 7     around goldsmiths' and banks but have never liberated one little hill.'"

 8             MR. JEREMY:  If we can go to the next page in the English,

 9     please.

10        Q.   Now continuing on, we read:

11             "Nevertheless, it seems that for now Zeljko Raznjatovic works

12     more for the benefit than to the detriment of the Republika Srpska

13     authorities.  One of the reasons why the misunderstandings have been so

14     quickly ironed out might be the unequivocal success of the operation

15     launch in late September in which the area around Prijedor was cleansed

16     of Muslims and Croats.  According to UNHCR reports, members of the

17     Serbian ..."

18             MR. JEREMY:  And could we go down in the B/C/S, please.

19        Q.   "... members of the Serbian Volunteer Guard expelled about 5.000

20     people to the territory under the control ..."

21             JUDGE FLUEGGE:  We should have that part in B/C/S on the screen.

22     I don't know where it is on that page, but on the right side or --

23             MR. JEREMY:  It's at the bottom of the page in B/C/S.

24             JUDGE FLUEGGE:  Yes, I did see that.  But the end of the sentence

25     is not visible.

Page 28478

 1             MR. JEREMY:  Yeah, could we go across and up, please.

 2             Thank you, Your Honour.

 3        Q.   Continuing on.  I'll read the sentence again.

 4             "According to UNHCR reports, members of the Serbian Volunteer

 5     Guard expelled about 5.000 people to the territory under the control of

 6     the BH Government within only a few days.  Kris Janowsky, the UNHCR

 7     porte-parole in Sarajevo, says that this was done in 'a rather ghastly

 8     way.'  According to the same reports, worn-out people were forced to swim

 9     across the river and many drowned during the attempt.  Others died of

10     exhaustion and beatings.  All them were thoroughly looted.  The

11     testimonies are by women, children and the elderly men:  The men were

12     made to board the buses with Vukovar licence plates and were taken to an

13     unknown location."

14             Sir, would you agree that, according to this report, Arkan and

15     his men continued in Prijedor what they had started in Sanski Most?

16             MR. IVETIC:  Objection, Your Honour.  Again, he's asking the same

17     question that the witness now has two times said he doesn't know what was

18     going on in Sanski -- pardon me, in Prijedor at that time.  So, again, if

19     we're getting to reading things to a witness and asking is this what is

20     written in the document, I don't think we're getting to any reliable

21     evidence that is of relevance to this Chamber.

22             JUDGE MOLOTO:  Mr. Jeremy.

23             MR. JEREMY:  Your Honours, I haven't asked the witness to confirm

24     if -- if I've read a section accurately.  I've asked the witness if,

25     according to his knowledge of events in Sanski Most, whether the actions

Page 28479

 1     described by Arkan in this article are a continuation of those events.

 2             JUDGE MOLOTO:  Your question was:

 3             "Sir, would you agree that, according to this report, Arkan and

 4     his men continued in Prijedor what they had started in Sanski Most?"

 5             MR. JEREMY:  And --

 6             JUDGE MOLOTO:  And that's according to this report.  In fact,

 7     whether he agrees with that report or doesn't agree with the report, the

 8     report says so anyway.  You're really not getting much mileage by asking

 9     that kind of question to the witness.

10             MR. JEREMY:  Well, Your Honour, I would only add that the report

11     doesn't say what Arkan had been doing in Sanski Most, and that's

12     knowledge that the witness has.  Although I won't insist on the question,

13     but I would like to tender the document either through this particular

14     witness or from the bar table.

15             MR. IVETIC:  We would object through the witness, as the witness

16     has not shown any knowledge to be able to authenticate the document or

17     give any reliability to it.

18             As for the bar table, I think we've stated multiple times before.

19     Your Honours have issued a guidance when bar table submissions by the

20     Prosecution were due.  That time has long past, and the Prosecution still

21     insists on amending its case and adding to its case with documents that

22     were not presented during the original time-period but they've not shown

23     due diligence why they did not seek them at that time and are now trying

24     to adduce evidence positive for their case after their case is closed.

25     And we believe that is not only a violation of Your Honours' guidance is

Page 28480

 1     also wholly improper, according to the rules of evidence.

 2             JUDGE MOLOTO:  Do you have any response?

 3             MR. JEREMY:  Yes, Your Honours.

 4             The Defence have submitted a statement from this witness with a

 5     paragraph that deals with Arkan's activities in Sanski Most in September

 6     1995.  This document -- this report is contemporaneous in respect to

 7     Arkan's activities, and it is the practice in this Trial Chamber that's

 8     been clarified a number of times, and I refer to the guidance we received

 9     on the 29th of October, 2012, that if the content of a document is

10     sufficiently linked to the content of a witness's testimony, then it is

11     admissible.  And this document is very clearly relevant.  It relates to

12     forcible transfer of non-Serbs from Serb-claimed territory, and it is a

13     part of our indictment.

14                           [Trial Chamber confers]

15             JUDGE MOLOTO:  You can MFI it.

16             MR. IVETIC:  Your Honour, if I may just add one additional thing:

17     Mr. Jeremy has now conceded what I've been claiming all along, that these

18     documents are part of their indictment.  So, again, they're trying to

19     reopen their case without asking for the Chamber to reopen their case and

20     to adduce positive evidence in relation to the indictment which I

21     believe, again, is wholly improper under the Rules.

22             MR. JEREMY:  Your Honours, if I can respond.  I did not say or

23     certainly did not intend to say that this particular document is part of

24     our indictment.  What I meant to say is that Prijedor and the cleansing

25     of non-Serbs from Prijedor is a part of our indictment and the cleansing

Page 28481

 1     of non-Serbs from Prijedor in September and October is part of our

 2     indictment which runs until the 30th of November, 1995.

 3             JUDGE MOLOTO:  The Chamber will MFI the document and we will deal

 4     with it later.

 5             Madam.

 6             THE REGISTRAR:  Document 31619 receives number P6925, Your

 7     Honours.

 8             JUDGE MOLOTO:  MFI'd, marked for identification.

 9             While we are at this stage, Mr. Jeremy, you asked that P3094 have

10     uploaded translations, to substitute that.  Shall we do that now?

11             Madam Registrar, document P0046440/A/ET to replace the current

12     translation of P3094.  Is that correct?  Thank you.

13             MR. JEREMY:  Thank you, Your Honours.  That concludes my

14     cross-examination.

15        Q.   Thank you, Witness.

16             MR. JEREMY:  No further questions.

17             JUDGE MOLOTO:  Thank you, Mr. Jeremy.

18             Any re-examination, Mr. Ivetic?

19             MR. IVETIC:  There is, Your Honours.  I see that we are about

20     seven minutes beyond the time for a break, though.

21             JUDGE MOLOTO:  Thank you for that help.

22             We will take a break at this time and come back in 20 minutes

23     time again, Mr. Corokalo.  You may follow the usher.

24             We take a break and we will come back at 20 minutes past 12.00.

25     Court adjourned.

Page 28482

 1                           --- Recess taken at 11.59 a.m.

 2                           [The witness stands down]

 3                           --- On resuming at 12.24 p.m.

 4             JUDGE MOLOTO:  Mr. Ivetic.

 5             MR. IVETIC:  Yes, Your Honour.  I think we have to wait for the

 6     witness.

 7                           [The witness takes the stand]

 8             JUDGE MOLOTO:  Now I can say "Mr. Ivetic."

 9             MR. IVETIC:  Thank you, Your Honour.

10                           Re-examination by Mr. Ivetic:

11        Q.   Sir, I would like to go back to your testimony in relation to the

12     fighting and the operation to disarm the Mahala neighbourhood.

13             First of all, I'd like to ask you:  You mentioned in the

14     cross-examination a Captain Radak who came with the unit that actually

15     within into Mahala.  Can you tell us what entity or organisation did

16     Captain Radak and his unit belong to?

17        A.   Captain Radak was commander of the 4th Battalion at that stage,

18     the preparation stage.

19             JUDGE MOLOTO: [Microphone not activated].

20             MR. IVETIC:  Your microphone was not activated, Your Honour.

21             JUDGE MOLOTO:  4th Battalion of which army?

22             MR. IVETIC:  VRS.

23             JUDGE MOLOTO:  Thank you so much.

24             MR. IVETIC:  And if we can call up in e-court Exhibit P2889.

25        Q.   While we wait for the same, I can introduce that document that

Page 28483

 1     was used with you in cross-examination.  That is, a 15 June 1992 report

 2     of the Ministry of the Interior, that is the public security station, the

 3     police.  Mr. Jeremy focused on the third paragraph of the document.  I

 4     would like to first focus on the second paragraph, which reads as

 5     follows:

 6             "The action of peaceful disarming and surrendering of weapons was

 7     carried out in the period between 10 May and 25 May 1992.  During that

 8     period, the Muslim and Croatian population handed over only hunting

 9     weapons and other legally owned weapons, but illegally obtained military

10     weapons were not surrendered, and were concealed (buried) on instructions

11     from above."

12             I'd like to ask you, sir, is this paragraph consistent with the

13     information, operative and security information, that was available to

14     you prior to the 4th Battalion going in to the Mahala neighbourhood?

15        A.   Absolutely.

16             MR. IVETIC:  And if we can look at the fourth paragraph in this

17     document.

18        Q.   It talks about after the action, the military action against the

19     Mahala, and says:

20             "After these combat actions, military police and civilian police

21     arrested and brought in members of Muslim paramilitary formations, who

22     were processed to obtain information about weapons available to their

23     membership.  On the basis of data gathered so far, it was determined that

24     the Muslim population had been relatively well armed, predominantly with

25     Infantry weapons and mines and explosives.  This was followed by an

Page 28484

 1     action of seizing these weapons from persons who were determined during

 2     the investigation process to have weapons in their possession.  The

 3     action was jointly carried out by military police and civilian police.

 4     It is still going on, and it can be said that it has only just started."

 5             JUDGE MOLOTO:  Mr. Jeremy.

 6             MR. JEREMY:  Your Honours, just -- I don't want to interrupt

 7     Mr. Ivetic, but I'll just make an interjection before he asks his

 8     question.  Mr. Ivetic has said that paragraph 4 talks about the military

 9     action against Mahala, and just so the record is clear, it's actually

10     referring to military action -- paragraph 3 is referring to military

11     action is Mahala, Vrhpolje, and Hrustovo, and paragraph 4 is making a

12     reference to those military actions.  So just so that is clear for all of

13     us.

14             JUDGE MOLOTO:  Mr. Ivetic.

15             MR. IVETIC:  I agree and I think I actually said that it was

16     talking about after the action because that indeed is the paragraph.  And

17     I think at line 21 of page 49, I did say "after the action," so I think I

18     correctly identified that paragraph as talking about after the actions.

19             MR. JEREMY:  Yeah.  Just to be clear, you said:

20             "Paragraph 4 talks about after the action, the military action

21     against the Mahala."

22             So I just want to make it clear that we're talking about Mahala,

23     Hrustovo, and Vrhpolje.

24             MR. IVETIC:  Okay.

25             JUDGE MOLOTO: [Microphone not activated].

Page 28485

 1             MR. IVETIC:

 2        Q.   Sir, the paragraph I have just read out to you, is that

 3     consistent with the information that was reported back to you of how

 4     weapons were uncovered or discovered?

 5        A.   It's absolutely consistent.  I have to stress that a number of

 6     people whom we didn't find there were from Mahala, Otoke, Muhici, and

 7     other Muslim inhabitants.  They were in the armed formation.  From Mahala

 8     specifically is Fera.

 9        Q.   Okay.  And from the bottom of the page we see that there is a

10     table enclosed of quantities of weapons, although it says that "the army

11     data is not too precise because they don't have precise data."

12             MR. IVETIC:  If we can go to the next page.

13        Q.   And the first page that Mr. Jeremy just directed us to indicated

14     that 2.000 individuals, it says "civilians," were taken in or captured

15     during this operation.  The resulting weapons from those 2.000 civilians

16     from the three villages by my count is approximately 700 weapons.  Now I

17     know that you said that you did not know about quantities of weapons, but

18     looking at the types of weapons that are listed here, is that consistent

19     with the information that you were receiving subsequent to the operation

20     as to the type of weapons that were recovered?

21             JUDGE MOLOTO:  Mr. Jeremy.

22             MR. JEREMY:  Your Honours, just again so the record is clear,

23     where we see the reference in this document to 2.000 individuals, that is

24     in relation to Mahala.  It's not in relation to the three villages that

25     Mr. Ivetic just referred to.

Page 28486

 1             JUDGE MOLOTO:  Mr. Ivetic.

 2             MR. IVETIC:  Correct.  It's 2.000 and then 800 men.  In the

 3     next -- the next two lines down.

 4             JUDGE MOLOTO:  Yeah.  Except that what Mr. Jeremy is saying is

 5     that these weapons do not relate to Mahala but they relate to all three

 6     areas.

 7             MR. IVETIC:  And I think I said that they relate to all three

 8     areas in my question.

 9             JUDGE MOLOTO:  Thank you.

10             MR. IVETIC:

11        Q.   Is this, sir, consistent in terms of the type of weaponry that

12     was recovered and handed over both to the SJB and to the army as a result

13     of these operations?

14        A.   In terms of structure, yes, but numerically I can't answer.

15        Q.   And I appreciate that.  Thank you, sir.  Now --

16             JUDGE FLUEGGE:  Mr. Ivetic, just a clarification.  I think it's

17     not working at the moment.

18             MR. IVETIC:  I can hear you, Your Honour.  So it is working.

19             JUDGE FLUEGGE:  I'll try this one.  You can hear me directly, I

20     think.

21             You said the two -- you were referring to all the three villages,

22     but in your question you made a different connection, that the witness

23     indicate -- no, the document indicated that 2.000 individuals, it says

24     "civilians," were taken or captured during this operation.  And only in

25     the -- with which you said then:

Page 28487

 1             "2.000 villages from the three villages."

 2             I don't have the first page on my screen at the moment, but the

 3     2.000 captured civilians were only from one village, Mahala; is that

 4     correct?  Perhaps you can see the first --

 5             MR. IVETIC:  From the document that's what it says, but the

 6     weapons are from all three villages.

 7             JUDGE FLUEGGE:  Yes, but you said the 2.000 civilians from the

 8     three villages and that caused the --

 9             MR. IVETIC:  Ah.

10             JUDGE FLUEGGE:  -- complication, I think.

11             MR. IVETIC:  I think you're right, Your Honour.

12        Q.   Now -- that worked a little too well, the microphone.

13             Now in terms of the 800 individuals that are listed on the first

14     page --

15             MR. IVETIC:  If we can go pack to the first page.

16        Q.   -- that were broken up and militarily defeated in Vrhpolje and

17     Hrustovo, how did those individuals relate to the armed group in Golaja

18     that you talk about in paragraphs 13 and 14 of your statement, if you

19     know?

20        A.   I wouldn't know about that linking up.  I did not have such

21     information.  I don't know how they did it.

22        Q.   That's fair enough.

23             MR. IVETIC:  If we can have P6924 on our screens.

24        Q.   You will see, I think, this is another document that Mr. Jeremy

25     used with you in cross-examination.  In fact, he tendered it during

Page 28488

 1     cross-examination.  And you were asked to comment about item number 1.  I

 2     would like to look at item number 2 with you, where it lists a total of

 3     four military conscripts who have been detained on reasonable grounds of

 4     suspicion of plundering several houses in Skender Vakuf and mistreating

 5     the civilian population.  Is this behaviour of the authorities, detaining

 6     military conscripts for these actions, consistent with your knowledge of

 7     the situation that prevailed within your brigade of the VRS?

 8        A.   Wherever it was possible to establish something like that, I

 9     suppose that was the procedure.  I don't know about the cases where we

10     were not sure.  But when we knew about cases like that, then we did it

11     that way.  Yes.

12             MR. IVETIC:  And if we could then also --

13             JUDGE FLUEGGE:  May I just put an additional question.

14             MR. IVETIC:  Yes.

15             JUDGE FLUEGGE:  Sorry for interrupting, Mr. Ivetic.

16             MR. IVETIC:  No problem.

17             JUDGE FLUEGGE:  Here in the document we can see the suspicion of

18     plundering several houses in Skender Vakuf and mistreating the civilian

19     population.  Do you know anything about these events of plundering and

20     mistreating the civilians?

21             THE WITNESS: [Interpretation] No, I did not have any occasion to

22     find out.  It's pretty far away from me, but I know by the names of these

23     people.

24             JUDGE FLUEGGE:  Do you know which kind of civilian population

25     this is referring to?

Page 28489

 1             THE WITNESS: [Interpretation] I suppose that it was the Muslim

 2     population inhabiting that area.

 3             JUDGE FLUEGGE:  But you don't know for a fact?

 4             THE WITNESS: [Interpretation] I couldn't tell you.

 5             JUDGE FLUEGGE:  Thank you.

 6             MR. IVETIC:  If we could turn to P3095 in e-court.

 7        Q.   This is a document that was shown to you in relation to the

 8     discussion about Arkan that you had with Prosecution counsel.

 9             MR. IVETIC:  And if we can turn to page 2 of the same.

10        Q.   And in the last sentence of the first paragraph, it says:

11             "Since so far these formations have not taken part in combat

12     activities and are not a part of any formation unit and have not reported

13     to any command from the level of Battalion to the VRS GS to be given an

14     assignment, obviously they are paramilitary formations acting

15     independently of the VRS."

16             Is this consistent with the view of how Arkan's men were viewed

17     by yourself and other officers in the brigade?

18        A.   Absolutely.

19        Q.   And what were the standing orders or the position taken by the

20     VRS since the beginning of the war in relation to paramilitary

21     formations?

22        A.   The position was that the paramilitaries should be either

23     integrated or disarmed.

24        Q.   Thank you.

25        A.   I mean integrated into the VRS.

Page 28490

 1        Q.   Thank you.  And now in regards to the description of

 2     Mr. Raznjatovic's appearance -- activities, it says here:

 3             "Raznjatovic's appearances at the command posts in the ZO of some

 4     units have so far had as their purpose bullying, mistreatment, and

 5     physical abuse of officers, kidnapping and taking away members of units,

 6     disarming parts of units for the purpose of confiscating material and

 7     technical equipment, MTS, and combat hardware, unauthorised opening of

 8     gun-fire on members of the VRS, tearing up official and identification

 9     documents of VRS members."

10             In relation to the conduct of Arkan's men towards the VRS, are

11     the things listed in this document consistent with what you either saw or

12     heard from others that was happening in Sanski Most in 1995?

13        A.   I couldn't see it because I was relocated.  But I heard that such

14     things happened, people were stripped of rank, slapped, beaten.

15        Q.   And approximately how long did you remain in Sanski Most before

16     having to flee Sanski Most after this time-period?

17        A.   Beginning with the 21st -- the 21st September when I came back

18     from the front line from Jasenica and Benakovac until the 10th October

19     when I fled.  But my whole involvement was in touring Bosanski Novi to

20     see if any of our people would get out and to find those 98 missing.

21        Q.   And, sir, for those that may not know, why did you have to flee

22     Sanski Most on or about the 10th of October, 1995?

23        A.   Well, the reason is well known.  On the 10th of October, from

24     8.00 in the morning, because we were invited in a meeting, all of us who

25     meant something in Sanski Most, from business leaders, police officers,

Page 28491

 1     et cetera, were invited at a meeting at Rasula's office.  The shelling

 2     began.  Shells were falling around the secondary school centre, and it

 3     began in the morning and increased in intensity until the afternoon, by

 4     which time the people from that area, from Tomina and the left bank of

 5     the river, had clogged all the passages across the river, all the

 6     bridges.  The so-called machine bridge.

 7        Q.   Who was shelling?

 8        A.   As far as we were able to tell, those were rapid action forces.

 9     They were acting so destructively that it must have been them.

10        Q.   And when you say "rapid reaction forces," of what entity did they

11     belong?  What army or entity?

12        A.   I think it was part of NATO.  The Muslim forces were not capable

13     of anything like that.  Until the fall of Sanski Most.  After the fall of

14     Sanski Most, the Muslims joined in.

15        Q.   Okay.  Now my last topic I'd like to discuss with you are the

16     events at the bridge at Vrhpolje.

17             The first thing I want to ask you is Mr. Jeremy intimated to you

18     that members of the VRS may have been involved in that killing that

19     occurred in May of 1992.  I'd like to ask you about something that the

20     survivor of that incident said in court on transcript page 2189.  He

21     described the unit as follows:

22             "That unit which came to our village on the 25th of May, 1992 was

23     commanded by a commander with long black hair tied in a ponytail.  He

24     wore round dark glasses."

25             And then further on, it is said:

Page 28492

 1             "He wore black leather gloves which he never took off."

 2             Later, the same individual said:

 3             "The unit was commanded by the Chetnik whom I previously

 4     described as having a long ponytail."

 5             Sir, based upon that description of the perpetrators of that

 6     incident, do they sound like the appearance of VRS personnel from your

 7     brigade?

 8        A.   Well, that was the description, long hair, hip crowd.

 9     Conditionally speaking, we had no such men.  At least I didn't.

10        Q.   Okay.  And what type of information did you hear about this

11     incident as to what actually happened?  What caused this to happen, if

12     you know?

13        A.   I don't know.

14        Q.   Sir, again --

15             JUDGE FLUEGGE:  I didn't hear the answer.

16             MR. IVETIC:  Yeah, I didn't think so.

17             JUDGE FLUEGGE:  Could you please repeat your answer.

18             THE WITNESS: [Interpretation] No, certainly not.  I said I don't

19     know.  I don't know what could have happened, what could have been the

20     cause.

21             MR. IVETIC:

22        Q.   Sir, again on behalf of General Mladic and the rest of the

23     Defence team, I thank you for answering our questions.

24             MR. IVETIC:  Your Honours, that completes my redirect

25     examination.

Page 28493

 1             JUDGE MOLOTO:  Thank you very much, Mr. Ivetic.

 2             MR. JEREMY:  Your Honours, I do have one question.

 3             JUDGE MOLOTO:  One question.

 4                           Further Cross-examination by Mr. Jeremy:

 5        Q.   Sir, you were asked in re-examination about Arkan and you were

 6     asked about your own departure from Sanski Most in 1995.  Now, we looked

 7     at a newspaper article at the end of your cross-examination from Vreme

 8     International that I quoted from, and in that article, it referred to the

 9     departure of 5.000 people from Prijedor.  And I -- I wanted to know what

10     information -- I want to know if you are aware that in 1995, in October

11     1995, 5.000 non-Serbs left Prijedor?

12             MR. IVETIC:  Your Honours, I think that has been asked and

13     answered in cross, and it certainly does not arise out of my redirect

14     examination.

15             JUDGE MOLOTO:  Was it asked in cross?  Where was it asked?

16             MR. IVETIC:  Give me a moment, Your Honours.  I believe the

17     witness said -- I believe he indicated that he did not have any knowledge

18     of Prijedor.  That was at -- I have that once at transcript page 42,

19     line 6.  There is a discussion of --

20             MR. JEREMY:  That's about Arkan's crimes.

21             MR. IVETIC:  Yes.

22             JUDGE MOLOTO:  Around 5.000.

23             MR. IVETIC:  And then at -- at page 47, lines 1 through 5,

24     Mr. Jeremy introduced the idea of cleansing of non-Serbs from Prijedor

25     from October of 1995, and he did not ask the witness a question of it.

Page 28494

 1     So I think that, in that sense, he had the opportunity.  He was not --

 2     it's not an issue I raised again in redirect.  They can't have a second

 3     bite at the apple.

 4             JUDGE FLUEGGE:  And, Mr. Ivetic, you asked the witness - this can

 5     be found at page 56, the last three lines, and the answer then follows on

 6     page 57 - about the reasons why -- for fleeing Sanski Most in October

 7     1995.  I just state.

 8             MR. IVETIC:  Correct.  And the question that Mr. Jeremy is asking

 9     is related to Prijedor, not to Sanski Most.

10             JUDGE FLUEGGE:  Thank you.

11             JUDGE MOLOTO:  Mr. Jeremy.

12             MR. JEREMY:  Your Honours, Mr. Ivetic has gone back into this

13     question of Arkan in this region in 1995.  He's gone into the issue of

14     persons leaving these areas in October 1995.  My question is squarely

15     within the remit of that sphere, and I would submit that it's perfectly

16     appropriate for me to ask this witness this question.

17             JUDGE MOLOTO:  You may ask the question.

18             MR. JEREMY:

19        Q.   So, sir, very simply you are aware, are you not, that in October

20     1995 5.000 non-Serbs left Prijedor as described in the article that I

21     showed to you during cross-examination?

22        A.   I absolutely had no knowledge and I don't know how I could have

23     had it.  Now, I had to fight for my own life.  On the 10th of October, I

24     left Sanski Most at 7.30 at night.  I don't know where -- I didn't know

25     where my family was --

Page 28495

 1             JUDGE MOLOTO:  May I stop you.

 2             THE WITNESS: [Interpretation] So how could I have known?  I

 3     couldn't even get the papers --

 4             JUDGE MOLOTO:  You have answered the question.  You don't have to

 5     tell us about your personal situation.  Thank you very much.

 6             MR. JEREMY:  Your Honours, I have no further questions.  Although

 7     I would submit that, in respect to the tendering of this document that's

 8     been MFI'd, that's a further ground for tendering of that document in

 9     that it relates to the credibility of this witness, that he didn't know

10     about the departure of 5.000 persons from his neighbouring municipality.

11             JUDGE MOLOTO:  We've heard you.

12             MR. IVETIC:  And, for the record, then, could we also have the

13     Prosecution stipulate that Vreme is published in Serbia, not in Bosnia?

14     Can we get that stipulation, that Vreme is published and distributed in

15     Serbia, not in Bosnia.

16             MR. JEREMY:  Your Honours, that's something that I won't do right

17     now and I'll need to verify that, but my understanding is that it is a

18     Serbian publication.  Where it's published, I'm not clear.  Although I do

19     understand that Vreme International is a publication that is published

20     outside of Serbia and not simply within Serbia, and I would note that

21     this article comes from Vreme International.  Thank you.

22             JUDGE MOLOTO:  The parties will come back to the Chamber about

23     that point, at which time I guess the Chamber will decide on the

24     admission.

25             MR. JEREMY:  Microphone, Your Honour.

Page 28496

 1                           [Trial Chamber confers]

 2             JUDGE MOLOTO:  Judge, any questions to the witness?

 3             Mr. Corokalo, that brings us to the conclusion of your testimony

 4     in this court.  You are now free to go home.  Thank you very much for

 5     coming all the way to come and testify, and may you please travel back

 6     home safely.

 7             Mr. Ivetic, does the Defence have a next witness ready?

 8             MR. IVETIC:  We do, Your Honours.  My colleague, Mr. Stojanovic,

 9     will be handling the next witness.

10             JUDGE MOLOTO:  Mr. Stojanovic.

11             MR. STOJANOVIC: [Interpretation] That's correct, Your Honour.

12                           [The witness withdrew]

13             JUDGE MOLOTO:  Can I ask if we are fetching the witness, to

14     verify?

15                           [The witness entered court]

16             JUDGE MOLOTO:  Mr. Sarenac, I suppose.  Before you make -- give

17     your evidence, the Rules require that you make a declaration to tell the

18     whole -- the truth, and the declaration has been given to you.  Will you

19     please read out the declaration.

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

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

22                           WITNESS:  RAJKO SARENAC

23                           [Witness answered through interpretation]

24             JUDGE MOLOTO:  Thank you very much.  You may be seated.

25             THE WITNESS: [Interpretation] Thank you.

Page 28497

 1             JUDGE MOLOTO:  You will first be examined by Mr. Stojanovic.

 2     Mr. Stojanovic is counsel for Mr. Mladic and he's to your left.

 3             Mr. Stojanovic.

 4                           Examination by Mr. Stojanovic:

 5        Q.   [Interpretation] Good afternoon, sir.

 6        A.   Good afternoon, Mr. Stojanovic.

 7        Q.   According to our customary procedure here, would you please tell

 8     us your full name.

 9        A.   I am Rajko Sarenac, and I am a member of the Serbian ethnicity

10     from Bosnia and Herzegovina.  I participated in the war in Bosnia and

11     Herzegovina, and I was a member of the Republika Srpska Army.

12        Q.   Thank you.  Mr. Sarenac, at one point in time did you provide --

13     did you make a statement to the Defence of General Mladic in writing?

14        A.   Yes.  And I signed that statement.

15             MR. STOJANOVIC: [Interpretation] Your Honour, could we have

16     65 ter 1D01736 in e-court.

17        Q.   Mr. Sarenac, could you please take a look at the screen.  Can you

18     tell us whether what we see on this cover page of this statement, is that

19     your signature?

20        A.   Yes.

21        Q.   Thank you.

22             MR. STOJANOVIC: [Interpretation] Could we now please have the

23     last page of this document.

24             THE WITNESS: [Interpretation] Yes.

25             MR. STOJANOVIC: [Interpretation]

Page 28498

 1        Q.   Mr. Sarenac, please, wait a minute.  Is this signature and the

 2     date that appears on this document, is this your signature and did you

 3     put in that date?

 4        A.   Yes.

 5        Q.   Thank you.  Now I would like to -- I would like you to look at

 6     paragraph 20 of this statement.

 7             Mr. Sarenac, did you, during the preparation for your appearance

 8     before the Court, did you point out that in the penultimate line in the

 9     English version and then the last line in the B/C/S version, the word

10     Sulic, last name, was mistyped?  It should be Zulic, Z?

11        A.   Yes, it should be Zulic with a Z.

12        Q.   Thank you.  With this typographical correction and after having

13     made the solemn declaration before this Court, would you provide the same

14     answers and would those answers be the full truth about the events that

15     you are testifying about?

16        A.   Yes.

17        Q.   Thank you.

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

19     tender document 65 ter 1D01736 into evidence.

20             JUDGE MOLOTO:  Yes, Mr. Weber.

21             MR. WEBER:  Good afternoon, Your Honours.  No objection.

22             JUDGE MOLOTO:  No objection.

23             1D01736 is admitted into evidence.  May it please be given an

24     exhibit number, Madam Registrar.

25             THE REGISTRAR:  Document 1D1736 receives number D786, Your

Page 28499

 1     Honours.

 2             JUDGE MOLOTO:  Thank you very much.

 3             Yes, Mr. Stojanovic.

 4             JUDGE FLUEGGE:  Mr. Stojanovic, the name "Zulic" in both versions

 5     is written with a Z.  I really don't understand what the correction would

 6     be.

 7             MR. STOJANOVIC: [Interpretation] Your Honours, in B/C/S it is a

 8     Zu, Zulic, not Z, Zulic.

 9             MR. IVETIC:  If I can assist, it's the accent mark that should

10     not be on the Z.  So it's the Z but it's the accent mark that is the

11     difference between two letters in the Serbo-Croatian language.

12             JUDGE FLUEGGE:  Thank you for that clarification.

13             JUDGE MOLOTO:  [Microphone not activated].

14             MR. STOJANOVIC: [Interpretation] Your Honour, perhaps it's just

15     the way I pronounced it that it didn't come across clearly.

16             JUDGE MOLOTO:  Thank you so much.

17             JUDGE FLUEGGE:  That is clarified.

18             JUDGE MOLOTO:  Okay.

19             MR. STOJANOVIC: [Interpretation] Thank you.  I would also like to

20     tender an associated exhibit which relates to paragraph 17 of the

21     statement.  And under 65 ter, that bears the number 1D05027.

22             MR. WEBER:  No objections, Your Honours.

23             JUDGE MOLOTO:  Thank you, Mr. Weber.

24             1D05027 is admitted into evidence.  May it please be given an

25     exhibit number.

Page 28500

 1             THE REGISTRAR:  Document 1D5027 receives number D787, Your

 2     Honours.

 3             JUDGE MOLOTO:  Thank you very much.

 4             MR. STOJANOVIC: [Interpretation] With your leave, Your Honours, I

 5     would like to read the witness -- the resume or the short statement of

 6     this witness, the summary statement.

 7             JUDGE MOLOTO:  You may do so.  Thank you so much.

 8             MR. STOJANOVIC: [Interpretation] During the war in Bosnia and

 9     Herzegovina, Colonel Rajko Sarenac held a number of jobs of high

10     responsibility, beginning with a job at the Operations Group Kupres

11     followed by his post as assistant commander for moral, religious, and

12     legal affairs in a number of VRS units at first within the 2nd Krajina

13     Corps, then within the Guards Brigade, attached to the Main Staff of the

14     VRS, and then as chief of armoured and mechanised units, and a trainer at

15     the training centre in Bileca and military school centre Rajko Balac in

16     Banja Luka.

17             With his unit, he was in a number of theatres of war in Bosnia

18     and Herzegovina, including the theatres in Bratunac, Srebrenica, Gorazde,

19     Jahorina, Trnovo, Nisic plateau, and the general area around Vares.  He

20     speaks about his experiences that he went through at those theatres.

21             He witnessed General Mladic's treatment of a captured member of

22     the BH police forces in Trnovo in July 1993, and he's aware of the

23     position of the Main Staff of the VRS on the reception and pull-out of

24     the Croatian population from the Vares general area.  He says that

25     several thousand people, men, women, old men, and children were evacuated

Page 28501

 1     from there.  They were sent towards Sarajevo and Kiseljak via the

 2     territory under VRS control, or across VRS territory.

 3             He also testifies that after the evacuation of the Croatian

 4     population from Vares, an HVO unit was established, the Croatian Defence

 5     Council, which together with VRS units secured positions at the Nisic

 6     plateau.

 7             The witness met General Mladic on several occasions on the basis

 8     of which he saw that his family and military background, his integrity

 9     and perseverance, stand in great contrast with the crimes of genocide

10     that he is charged with.

11             After the war, the witness worked in the commission for the

12     gathering of documents on crimes against the Serbs where he had occasion

13     to meet on several occasions with representatives of The Hague Tribunal

14     that related to the exchange or, rather, hand-over of documents relevant

15     to the job that the witness performed at that time.

16             Your Honours, this is the summary statement of this witness, and

17     I would now like to ask him several questions.

18             JUDGE MOLOTO:  Just before you do that, you said that related to

19     the exchange or, rather, hand-over of documents relevant to the job that

20     the witness performed at that time.  Hand-over of these documents by who

21     to who and what documents are these?

22             MR. STOJANOVIC: [Interpretation] Your Honour, paragraph 30 of the

23     witness statement deals with that.  The witness handed over documents

24     that had been gathered and that related to a case before this court.  And

25     as a representative of that commission attached to the VRS, he actually

Page 28502

 1     had these documents in his possession.

 2             JUDGE MOLOTO:  Thank you.

 3             MR. STOJANOVIC: [Interpretation] Your Honour, I see the time.  I

 4     have about -- I need about ten more minutes, so perhaps this would be the

 5     right moment to take the break.

 6             JUDGE MOLOTO:  You can't use the next five and use the ten later

 7     when you come back?

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

 9        Q.   Mr. Sarenac, could you please take a look at the following

10     document.

11             MR. STOJANOVIC: [Interpretation] And, for the record, I'll say

12     that now this is document D786.

13        Q.   Paragraph 20 of your statement, where you say that you remember

14     the moment when, together with a complement of the Sarajevo Romanija

15     Corps units, you entered Trnovo, and at the time the Main Staff commander

16     of the VRS was at the head of it.  And then you talk about the commander

17     of the police station in Trnovo.  And based on what it says here, could

18     you please tell us, briefly, your observations of the situation, your

19     direct observations of the situation, that you mentioned here?

20        A.   Very well.  Thank you.  On that day, which was the 11th of July,

21     1993 in the afternoon, when the Guards Brigade units entered, and I was

22     with the Guards Brigade units, at that same time, the commander of the

23     Main Staff, General Mladic, entered Trnovo.  When we entered Trnovo and

24     came to the centre, all of a sudden from the direction of Treskavica

25     hotel, a shot -- or several shots could be heard, but that's not really

Page 28503

 1     relevant, whether it was one or more, but the security and members of the

 2     army at that moment headed for the hotel, and General Mladic headed

 3     there, too.  Immediately following that, perhaps a few minutes later, a

 4     vehicle came towards us, a police vehicle.  When this vehicle was stopped

 5     by one of our members and when his ID was checked, the man said who he

 6     was and why he was there and where he was headed.  He provided a brief

 7     statement.  He said that he was on the way to his home, allegedly, to

 8     take his sports shoes.

 9             Soon thereafter, General Mladic arrived.  He saw immediately what

10     the situation was.  He exchanged a few words with this person mentioned

11     here, Zulic, and then he pulled the man aside, talked to him, and

12     realised that he was the person who was -- thanks to whom, in fact,

13     General Mladic's uncle and aunt were saved because he intervened, and he

14     said that he was the person most responsible, most credited for it.

15     After this, after this conversation with General Mladic, General Mladic

16     said that if that was true, everything will be all right.

17             It would probably have been all right anyway.  But because he

18     said that this was true, that he was credited for saving these people,

19     and unfortunately not many men were saved, he then turned to a colonel

20     and said to him, "Lazo, this man, no harm should come to this man.

21     Provide security and when I return we will take him over and he will be

22     exchanged."  That's how it happened in the end, that was the outcome.

23             And I learned, although I didn't see it myself, that later on

24     General Mladic arranged for the said Zulic and the other two people that

25     he had allegedly saved meet on Mount Jahorina at the hotel on which

Page 28504

 1     occasion this person provided his statement that was then shown on

 2     Serbian television.  That's all on my part.

 3             If you have some additional questions, I can answer them.

 4        Q.   Thank you, Mr. Sarenac.  I will have a few more questions but

 5     that will come after the break.

 6        A.   Thank you.

 7             JUDGE MOLOTO:  Mr. Stojanovic, we will take a break.

 8             And, Mr. Sarenac, we will take a break for 20 minutes.  Will you

 9     please follow the usher and we will see you in 20 minutes' time.

10                           [The witness stands down]

11             JUDGE MOLOTO:  We take a break and will resume at 20 to 2.00.

12     Court adjourned.

13                           --- Recess taken at 1.20 p.m.

14                           --- On resuming at 1.41 p.m.

15             JUDGE MOLOTO:  May the witness please be brought into the

16     courtroom.

17                           [The witness takes the stand]

18             JUDGE MOLOTO:  Mr. Stojanovic.

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

20             Could we please bring up in e-court D786.  Let me just repeat for

21     the record, D786.  And let us focus on paragraph 24.

22        Q.   Mr. Sarenac, in paragraph 24, you talk about your unit's stay on

23     the plateau, and you say that with a part of the units of the Sarajevo

24     Romanija Corps and the Drina Corps, you took control of the

25     Nisici-Brgule-Vares road with the aim of receiving and evacuating the

Page 28505

 1     Croat population from the general area of Vares pursuant to the orders of

 2     the Main Staff of the VRS, and you mention the total number of people who

 3     got out at that time.

 4             Do you have any more detailed information as to how and in which

 5     way these Croat expellees left for Kiseljak and Sarajevo?

 6        A.   Can I start?  May I start answering?

 7        Q.   Please go ahead.

 8        A.   The Croat populous that lived around Vares was under threat from

 9     the Muslim forces.  They probably decided on their own to try to get out

10     of that dangerous area around Vares.  The only way out was the road

11     leading towards the territory controlled by the VRS, and that's the road

12     Vares-Brgule-Nisici and onto Kiseljak and Sarajevo.

13             The Main Staff of the VRS, after receiving this information,

14     issued an order to its units, including the 1st Guards Brigade, that this

15     road should be unblocked and that it should be made possible to receive

16     and allow the Croat population to evacuate.  Among those civilians, there

17     were also members of the HVO of Vares.

18             After they got out, I received a report that General Mladic

19     showed up on one section of the road in order to reassure those people.

20             MR. WEBER:  Your Honours, I'm just standing to express my

21     concern.  The Chamber has received evidence related to the events in

22     Vares.  I was just wondering if in this discussion we could have a little

23     time context.  There is a reference to an order from the VRS Main Staff

24     and then a following report.  If -- when we're discussing this, if we

25     could break it down a little bit just so we could have some temporal

Page 28506

 1     understanding of how it's related to the other evidence.

 2             JUDGE MOLOTO:  Mr. Stojanovic.

 3             MR. STOJANOVIC: [Interpretation]

 4        Q.   You heard, Mr. Sarenac.  I am directing you again to

 5     paragraph 24.  It says:  "In December 1993, I was sent to the Nisici

 6     plateau," but the Prosecutor is asking was this happening in December

 7     1993 or after the new year in 1994?  Could you give us a more precise

 8     time-frame?

 9        A.   That's the end of 1993.  Let me just add that after the Croat

10     population pulled out, a unit was formed led by one of their commanders

11     who continued to operate in co-ordination with our forces to secure

12     positions facing Vares.

13        Q.   Thank you, Mr. Sarenac, for your answers.  That was all for the

14     moment.  Now you will be examined by the Prosecution.

15             MR. WEBER:  Just before beginning with the examination.  Just so

16     I understand clearly, is it then that -- is it the Defence's position

17     that all these things happened from December 1993 onward, according to

18     this witness?

19             JUDGE MOLOTO:  Are you asking the Defence or do you want to ask

20     that from the witness?

21             MR. WEBER:  To me, it's still not clear from the record.

22             JUDGE MOLOTO:  Is it -- wouldn't you be able to clarify it with

23     the witness?

24             MR. WEBER:  I can ask the first question if you want.

25             JUDGE MOLOTO:  I suggest you ask the question.

Page 28507

 1             MR. WEBER:  Okay.  Thanks, Judge.  No problem.

 2             JUDGE MOLOTO:  Mr. Sarenac, you will now be cross-examined by

 3     Mr. Weber.  Mr. Weber represents the Prosecution in this case, and you

 4     will see him to your right.

 5             MR. WEBER:  Thank you, Your Honours.

 6                           Cross-examination by Mr. Weber:

 7        Q.   Good afternoon, Mr. Sarenac.

 8        A.   Good afternoon.

 9        Q.   I just want to very quickly pick up where the questioning just

10     left off.

11             Do I understand correctly that your evidence related to the

12     departure of the Croat population and members of the HVO relates to

13     events that occurred from December 1993 and thereafter?

14        A.   Could you be more specific?  What occurred in December 1993?

15     I've already said that the Croat population pulled out from Vares towards

16     the end of 1993.

17        Q.   It is very simple.  Everything you described happened from

18     December 1993 and thereafter, today?  I'm not going to spend a lot time

19     with you on this.  I'm just asking you to confirm it.  It appears that

20     that's what you're saying.

21        A.   Not from December.  Towards the end of 1993.  Not only December

22     necessarily.  It could have been in November, too.

23        Q.   Okay.

24        A.   I did not mention a date, a particular day.  Towards the end of

25     1993.

Page 28508

 1        Q.   All right.  That's less clear but I understand that that's what

 2     you know.  I'm going to move on and talk about your statement quickly and

 3     some information that's in it before we finish at the end of today.

 4             In paragraphs 4, 6, and 7 of your statement, you discuss the

 5     liberation of Kupres in April 1992.  Is it correct that Kupres is a

 6     municipality in western Bosnia and Herzegovina bordering the Bosnian

 7     Krajina, which is to the north?

 8        A.   Yes.  It's in the territory of the Republic of

 9     Bosnia-Herzegovina, the western part of it, Kupres itself.

10        Q.   The JNA 9th Corps participated in the liberation of Kupres;

11     correct?

12        A.   Yes.

13        Q.   General Mladic was present in the area of Kupres during these

14     operations?

15        A.   I don't know whether he was present.  At the time when I came, he

16     wasn't there or during the liberation.  He visited later.  But I cannot

17     tell you which date.  It was in the beginning of April.  I know he came,

18     I was at negotiations with Croats then in Pakovo Selo.  We were

19     negotiating about a possible exchange of our captives.

20        Q.   Sir, the Chamber has received evidence through General Mladic's

21     notebooks that he attended a meeting in Sipovo, which is just to the

22     north of Kupres, on the 4th of April, 1992.  Is this the period in which

23     you became aware that General Mladic was in Bosnia around this time, near

24     Kupres?

25        A.   General Mladic was at that time commander of the Knin Corps, and

Page 28509

 1     he had received orders from the General Staff of the SFRY that he should

 2     move with his units to liberate Kupres from paramilitary Croat forces.

 3     There was no JNA presence at Kupres.  It was simply that the entire

 4     population was attacked by Croat military and paramilitary forces.  They

 5     captured Kupres --

 6        Q.   Sir, we are going to go through the operations.  If you can

 7     listen carefully to my questions, we'll actually go very quickly.

 8             In paragraph 6 of your statement, you indicate that

 9     General Mladic telephoned you following the liberation of Kupres.  Where

10     were you when he called you?

11        A.   Right.  I was in the operations centre of the operative group at

12     Kupres.  I was the officer on duty.

13        Q.   Where was General Mladic calling from?

14        A.   I suppose from his command post in Knin.

15        Q.   Okay.  What -- do you recall the approximate date of this call?

16        A.   8 or 9 April.  I don't remember the exact date.  But it was in

17     the beginning of April after the fighting had stopped.  He called me, and

18     I can quote approximately what he said --

19        Q.   No, sir, sir, sir, if we could go with my questions here.

20             MR. WEBER:  Could the Prosecution please have Exhibit P3090 for

21     the witness.

22        Q.   And, sir, I'd like to discuss with you before we end today the

23     activities of the JNA 9th Corps immediately before and during the

24     operations in Kupres.  Before you will be a 5 April 1992 JNA 9th Corps

25     regular combat report from General Mladic.

Page 28510

 1             MR. WEBER:  Could the Prosecution please have page 2 of the

 2     English.

 3             THE WITNESS: [Interpretation] All right.

 4             MR. WEBER:

 5        Q.   Toward the end of item 4 --

 6             MR. WEBER:  Which is at the bottom of the page in the B/C/S, if

 7     we could please have that.

 8        Q.   -- General Mladic refers to a 9th Corps request and 2nd Military

 9     District order and states:

10             "We ask that the units in the Kupres region be given logistical

11     support."

12             MR. WEBER:  Could we now please have page 2 of the B/C/S

13     original.

14        Q.   General Mladic then articulates his decisions, the first one is:

15             "To follow the activities of the part of mobilised men in the

16     Kupres region and to maintain and heighten the level of combat readiness

17     of the mobilised men."

18             Is it correct, sir, that General Mladic and the 9th Corps were

19     involved in mobilising and providing logistical support to men in the

20     area of Kupres at the outset of April 1992?

21        A.   General Mladic was the commander, but with his orders he made his

22     subordinates responsible for doing this.  Some of the units, so parts of

23     the units of the Knin Corps, were involved in combat now and he was

24     issuing combat assignments.  I don't see what's controversial here.

25        Q.   I'm not looking to actually -- sir, I'm just going through the

Page 28511

 1     information with you.  We also see in this document that General Mladic

 2     orders to continue with the mobilisation forming, equipping, and arming

 3     of the mobilised units in Bosansko Grahovo and Bosanski Petrovac.  Those

 4     were also formations that were to the -- in Bosnia to the west of Kupres,

 5     correct?

 6        A.   East of Kupres.  Oh, no, no.  To the west.  Well, yes, that's the

 7     area of responsibility of the 2nd Army, including the Knin Corps.  At

 8     that time, there were no boundaries established within the seceded state.

 9        Q.   Sir --

10        A.   We had our own regimen and --

11        Q.   Sir --

12        A.   -- our own aspect of the territory.

13        Q.   I'm sorry to interrupt you, but I'm actually going to try to be

14     quite efficient with you and if you could please listen to my questions.

15             In paragraph 7 of your statement, you referred to events in the

16     Kupres-Suijca area.  Is it correct that the JNA 9th Corps undertook

17     offensive activities along this axis in early April 1992?

18        A.   It's correct.

19        Q.   And just -- we'll look at this and then quickly.

20             MR. WEBER:  Could the Prosecution have P4259 for the witness.

21     Coming up will be a 9 April 1992 JNA 9th Corps regular combat report from

22     General Mladic.

23        Q.   In the middle of item 2 is where I'm going to focus your

24     attention.  General Mladic refers to a special emphasis on the 11th

25     Border Detachment and on planning the execution of offensive activities

Page 28512

 1     along the axis of Kupres-Suijca.  Based on the answers you just gave, is

 2     it correct that this is the axis that you were discussing in your

 3     statement?

 4        A.   I'm reading what you just cited.

 5        Q.   Sir, it's about middle of the way and under item 2.

 6     Approximately the middle of the page for you.

 7        A.   I see soldiers have been received, cease-fire, emphasis.  I don't

 8     see the axis.

 9             JUDGE FLUEGGE:  It should be the bullet point before what you

10     have read.

11             JUDGE MOLOTO:  Bullet point number 4.

12             THE WITNESS: [Interpretation] Maybe I'm looking at a different

13     document.

14             MR. WEBER:

15        Q.   At --

16             MR. WEBER:  I don't know if we are zoomed in too far.  I believe

17     that on the right side of the document, the Kupres-Suijca axis is just

18     kind of cutting off just slightly.  There.  If it's --

19        Q.   Sir, do you see it now?  It begins in the B/C/S with "pracena je

20     situacija."

21        A.   Paragraph 2, commands and units of the 9th Corps --

22        Q.   Sir --

23        A.   -- are mainly --

24             JUDGE MOLOTO: [Microphone not activated]

25             MR. WEBER:

Page 28513

 1        Q.   Sir, I'm actually asking you from the fourth bullet point down

 2     under item 2.  You see that?

 3        A.   "The situation in the sector of Kupres was monitored with a

 4     special focus on ..."

 5        Q.   Sir, that's the axis that you're talking about in your statement;

 6     right?

 7        A.   Yes.  That's the axis in Kupres.  Suijca and further towards

 8     Livno.

 9             MR. WEBER:  Could we now go down to item 4, which is in -- on

10     page 2 of the English translation, the part that I'll be referring to,

11     it's towards the bottom of the B/C/S original.

12             THE WITNESS: [Interpretation] Yes, I found it.

13             MR. WEBER:

14        Q.   Okay.  And it's at the very end of item 4 that I'm going to be

15     referring you to, which is right at the bottom of the page, the last

16     sentence in front of you.

17             General Mladic indicates that the team for mopping up the

18     battle-field has returned from the region of Kupres.  Is it correct that

19     areas of Kupres had already been liberated by 9 April 1992?

20        A.   Yes.

21             MR. WEBER:  Could the Prosecution please have page 2 of the B/C/S

22     original.

23             THE WITNESS: [Interpretation] It's correct.  That's the area that

24     was given to us to liberate and it had been done by that time.

25             MR. WEBER:

Page 28514

 1        Q.   Sir, under General Mladic's decisions at the top of the page

 2     before you, General Mladic states:

 3             "Receive and inform the 11th Operations Group of the situation in

 4     the region of Kupres."

 5             This is the operations group commanded by Stanko Ledic, which you

 6     referred to in your statement; correct?

 7        A.   Colonel Letic, Stanko Letic.  That's the group.  At that time we

 8     were already at Kupres, before the 9th of April.

 9        Q.   Sir, the goal and the purpose of the operations in Kupres were

10     part of a broader process of creating a Serbian state in Bosnia and

11     joining it with the Serbs in the Krajina region of Croatia; right?

12        A.   No, not right.  How did you come up with that?

13        Q.   Sir --

14        A.   Kupres was a town.

15        Q.   -- could I --

16             MR. WEBER:  Could I please have 65 ter 31612 for the witness.  In

17     the B/C/S original, could we please have focus -- could we please focus

18     on the box in the lower left corner of the page.

19        Q.   Sir, this is a 4 May 1992 article from Glas entitled:

20     "Colonel Stanko Letic in Sipovo, time for a Serbian army."  In this

21     article, Colonel Letic, your superior commander, states:

22             "This is the process of creating a Serbian state in Serbian

23     Bosnia.  This is the time for Serbian accord.  The Serbian people has no

24     more blood for letting.  For the sake of the unification of the Serbian

25     people, we have to join up with the Knin Krajina.  There is no more

Page 28515

 1     living in that state for the Ustashas, and we have to wipe the floor with

 2     them.  All those capable of battle should go to fight against the

 3     Ustashas on the Kupres battle zone.  This goes for the Muslims too.  If

 4     they fight against the Ustashas, they will have all the same rights as

 5     the Serbs.  If not, they will be second-rate citizens in the new state

 6     that will be created - the United Serbian States."

 7             Sir, as indicated by your superior, Colonel Letic, is it correct

 8     that Kupres was part of a process of creating a Serbian state in Bosnia

 9     and joining it with the Knin Krajina?

10        A.   This is the first time I hear of it.  I would never believe it.

11     That was certainly not our mission.  Maybe if that was somebody's

12     political decision or political will, it's totally different.  That was

13     not what the army was pursuing.

14        Q.   Sir, I put it to you that your statements are contradicted by

15     your own commander, his contemporaneous statements at the time.  I'm not

16     looking to debate it with you.  But if you have anything else to say

17     before I tender the document, I just want to make you aware that you are

18     contradicted by Colonel Letic.

19        A.   Can I say something about this?  Because you've already asked me.

20     Yes or no?

21        Q.   Sir, do you have anything additional to say that you have not

22     said already about you being contradicted?

23        A.   I don't know what you find questionable here.  He's talking about

24     the fight against the Ustasha movement.  Not about any non-Serb people.

25     What's wrong with that?  I think it's perfectly all right.  We had come

Page 28516

 1     there to defeat the Ustashas or paramilitary forces, not another people.

 2     Those who had committed --

 3        Q.   Sir --

 4        A.   -- a serious crime against Serbs in Kupres.  But you probably

 5     know about that.

 6             MR. WEBER:  The Prosecution tenders 65 ter 31612 into evidence.

 7             MR. STOJANOVIC: [Interpretation] The Defence objects, Your

 8     Honours.  From this document and the witness's answers, we don't know

 9     whether this reporter reported the statement by Stanko Letic correctly.

10     This could also be a journalist's interpretation.  And the witness knows

11     nothing about this and none of it is consistent with his knowledge.

12             JUDGE MOLOTO:  Mr. Weber.

13             MR. WEBER:  I'm not sure that this actually needs a response,

14     but -- and it -- obviously the witness has actually, in part, said that

15     he sees nothing wrong with this.

16             Number two, it's a newspaper article directly quoting his colonel

17     at the time, Colonel Letic.  It describes the position of the individual

18     who was commanding the 11th Operations Group.  It's relevant, and, you

19     know, it's a newspaper article with a quotation from Colonel Letic

20     expressing a view.

21             We ask that it be admitted.  It's being offered to contradict the

22     witness with respect to the part he has not acknowledged.

23             JUDGE MOLOTO:  In any case, Mr. Stojanovic, it's not absolutely

24     correct to say that the witness knows nothing about it.  He agrees with

25     it.  He says there is nothing wrong with it.  So it seems to be

Page 28517

 1     consistent with his understanding of the situation at the time.

 2             MR. STOJANOVIC: [Interpretation] Yes, Your Honours.  The witness

 3     also said that that was not the mission of the Yugoslav Peoples' Army.

 4             JUDGE MOLOTO:  No --

 5             MR. STOJANOVIC: [Interpretation] The way the journalist quoted

 6     Letic's words.

 7             JUDGE MOLOTO:  Okay.  It does look like we don't understand each

 8     other here.  The witness says it is not the mission of the Yugoslav Army

 9     to kill Muslims but certainly the Ustashas.

10             So your objection is overruled.  The document is admitted into

11     evidence.  May it please be given an exhibit number.

12             THE REGISTRAR:  Document 31612 receives number P6926, Your

13     Honours.

14             JUDGE MOLOTO:  Thank you so much.

15             Mr. Weber.

16             MR. WEBER:  Your Honours, I'm about to actually go into a brand

17     new area.  I do see the time, and I think it may be more practical and

18     more coherent to just start tomorrow fresh.

19             JUDGE MOLOTO:  Absolutely.  Absolutely.

20             Sir, we've come to the end of the day today.  We can't carry on

21     for today.  We'll have to come back tomorrow morning again at 9.00 in the

22     morning.  But before you leave, I would like to warn you not to talk to

23     anybody or communicate with anybody whatsoever about the testimony you

24     have given so far or the testimony you still have to give in this case.

25     Okay?  And especially you may not talk even to the Defence team.

Page 28518

 1             See you tomorrow morning.  You may follow the usher.

 2             THE WITNESS: [Interpretation] Thank you.

 3                           [The witness stands down]

 4             JUDGE MOLOTO:  Before we adjourn, there is just one item that the

 5     Chamber would like to deal with.

 6             The Chamber has concerns about some of the recent video

 7     conference link motions filed by the Defence.  Often the medical

 8     documentation annexed to these motions does not provide sufficient

 9     information about the witness's current health condition or how that

10     condition might affect his ability to travel to The Hague.

11             The Chamber reminds the parties that video conference link

12     motions should be accompanied by supporting documentation, such as recent

13     medical evaluations, that specifically address a witness's ability to

14     travel, or a recent statement from the witness indicating the reasons why

15     they are unable or unwilling to travel.

16             Having said that, the Chamber stands adjourned to tomorrow,

17     Wednesday, the 19th of November, 2014, in courtroom I, at 9.30 in the

18     morning.

19             Court adjourned.

20                           --- Whereupon the hearing adjourned at 2.16 p.m.

21                           to be reconvened on Wednesday, the 19th day

22                           of November, 2014, at 9.30 a.m.