1 Monday, 18 May 2015
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.32 a.m.
5 JUDGE ORIE: Good morning to everyone in and around this
7 Mr. Registrar, would you please call the case.
8 THE REGISTRAR: Good morning, Your Honours. This is case
9 IT-09-92-T, the Prosecutor versus Ratko Mladic.
10 JUDGE ORIE: Thank you, Mr. Registrar.
11 The Chamber was informed that there was one preliminary matter to
12 be raised by the Prosecution.
13 Mr. Traldi.
14 MR. TRALDI: Yes, Mr. President, good morning.
15 Just to respond to and accept the Chamber's invitation at the end
16 of the hearing Thursday to put our requests for admission regarding
17 portions of Mr. Basara's previous statements on the record. The
18 Prosecution asks that 65 ter 27968a, an excerpt from a record of Basara's
19 prior recorded interview, be admitted as P7322 which number has been
20 reserved for an excerpt from that interview.
21 The Prosecution also tenders 65 ter 31876a, an excerpt from
22 Mr. Basara's testimony in the Stanisic and Zupljanin case.
23 JUDGE ORIE: Any objections?
24 MR. LUKIC: I don't know what's the proper should be then, asked
25 to include what we want from those transcripts and interviews?
1 JUDGE ORIE: If you want to add anything, of course then the
2 question arises to what extent the portions you are seeking, whether they
3 have been dealt with by the witness. I mean, it's not just an extract
4 coming out of the blue, but of course it's because attention has been
5 paid or at least the matter has been covered. But if you want to think
6 about that.
7 Mr. Traldi, I take it that you'll give Mr. Lukic sufficient time
8 to consider it.
9 MR. TRALDI: Of course, Mr. President. And I've just been
10 reminded that the specific pages that we used and the transcript pages on
11 which those pages of his previous interview and testimony were used
12 during his examination are provided in an e-mail we sent to the Chambers
13 and Defence on 24 April at 10.44.
14 JUDGE ORIE: Mr. Lukic, I take it that you want to review and see
15 what your response will be.
16 MR. LUKIC: Yes.
17 JUDGE ORIE: Then we'll wait for a while, but we now know what is
18 uploaded in order to be -- at this moment what is uploaded where the
19 Prosecution seeks 7322 admission and also what is uploaded as well as the
20 extracts from the testimony is concerned. Would it be wise to have
21 already a number reserved for that as well?
22 Mr. Registrar, for 31876a could you provisionally assign a
24 THE REGISTRAR: That will be P7389, Your Honours.
25 JUDGE ORIE: P7389 is reserved for that purpose.
1 Mr. Lukic, we'll hear from you, well, let's say, this week?
2 MR. LUKIC: Can we postpone it till the next week? This week is
3 really full for me.
4 JUDGE ORIE: Well, the next week means a postponement of four
5 weeks, but if you do it by e-mail then -- this is indeed a very full
6 week, so if it is -- well, let's say this month still. And if it's not
7 this week, then you can do it by -- through e-mail.
8 MR. LUKIC: Thank you, Your Honour.
9 JUDGE ORIE: And then we'll see after that.
10 Is the -- is the Defence ready to call its next witness.
11 MR. LUKIC: Yes, we are, Your Honour. Mr. Savo Sokanovic.
12 JUDGE ORIE: Could the witness be escorted into the courtroom.
13 But perhaps before the witness enters the courtroom,
14 Mr. Registrar, I'd like to briefly move into private session.
15 [Private session]
3 [Open session]
4 THE REGISTRAR: We're now in open session, Your Honours.
5 JUDGE ORIE: Yes. I don't know where ... could someone check
6 whether the witness is waiting behind the doors or still on its way?
7 MR. TRALDI: If you don't mind, Your Honour.
8 JUDGE ORIE: Yes, the witness should be on his way. I would not
9 have minded at all, I would have appreciated it, but I see the door is
10 opening already.
11 [The witness entered court]
12 JUDGE ORIE: I spoke too quickly because my appreciation,
13 Mr. Traldi, disappeared from the transcript, which it should not.
14 Good morning, Mr. Sokanovic. Can you hear me in a language you
16 THE WITNESS: [Interpretation] I can hear you. Good morning to
18 JUDGE ORIE: Good morning, Mr. Sokanovic. Before you give
19 evidence, the Rules require that you make a solemn declaration, of which
20 the text is now handed out to you.
21 THE WITNESS: [Interpretation] I solemnly declare that I will
22 speak the truth, the whole truth, and nothing but the truth.
23 WITNESS: SAVO SOKANOVIC
24 [Witness answered through interpreter]
25 Examination by Mr. Lukic:
1 JUDGE ORIE: Thank you. Please, be seated.
2 Mr. Sokanovic, you'll first be examined by Mr. Lukic. You find
3 Mr. Lukic to your left. Mr. Lukic is counsel for Mr. Mladic.
4 Please proceed.
5 MR. LUKIC: Thank you, Your Honour.
6 Q. [Interpretation] Good morning, Mr. Sokanovic.
7 A. Good morning, Mr. Lukic.
8 Q. We speak the same language, so I will make sure to pause after
9 your answers, and you try to do the same after my questions. This is for
10 the benefit of the interpreters who need to interpret everything.
11 Could you please slowly tell us your name for the record.
12 A. Savo Sokanovic.
13 Q. Could you please tell us your father's name, your date of birth,
14 and your place of birth.
15 A. Maj father's name was Vojislav. I was born on the
16 27th January 1951 in Malo Polje hamlet near Kozlovaca.
17 Q. Your municipality?
18 A. Han Pijesak.
19 Q. General, could you just briefly tell us something about your
20 education. Which schools did you finish?
21 A. I finished the elementary school in the place where I was born.
22 After that, I completed the air force high school, the air high school
23 for politics of the JNA, the school of politics, and the school of
24 national defence after the end of the war in Bosnia and Herzegovina.
25 Q. When you attended Military Academy, what were you studying? I
1 believe that it was not recorded properly.
2 A. I specialised in telecommunications.
3 Q. Again, I believe that your answer is not complete.
4 Telecommunications in what field?
5 A. Air force and anti-aircraft defence.
6 Q. Thank you. And now could you please give us the time-frame as
7 much as can you remember of your professional career. Where did you
8 serve and what positions did you occupy before the war and during the
10 A. I completed a Military Academy in 1973. Up to 1978, I worked as
11 the commander of the independent platoon of communications battalion in
12 Sarajevo. It was 321st Platoon. From 1978 until 1992, i.e., when the
13 war broke out in the former Republic of Bosnia and Herzegovina, I
14 performed various duties in the educational centre of the air force and
15 anti-aircraft defence in Rajlovac in Sarajevo. I was the commander of
16 the cadet platoon. I was a teacher, assistant commander of the cadet
17 battalion. I was in charge of a group of teachers, assistant commander
18 of the secondary military school for air force and anti-aircraft defence.
19 Then I was a teacher at Military Academy for -- of air force and
20 anti-aircraft defence. I was the head of -- of -- an educational
21 programme. And finally --
22 THE INTERPRETER: The interpreter missed the last position.
23 MR. LUKIC: [Interpretation]
24 Q. Would you please repeat your last position. The interpreters
25 could not follow you.
1 A. Assistant commander of the Military Academy of air force and
2 anti-aircraft defence.
3 Q. When the war broke out in Bosnia and Herzegovina, where were you
4 and did you stay there or were you assigned to a different duty?
5 A. First of all, my belief, and I believe that that belief was
6 shared by most of my colleagues, was that Bosnia-Herzegovina as a
7 multi-ethnic state is not a place where a war could ever happen.
8 However, as the conflict spread from Slavonia across Croatia, and it
9 could already be felt in the air that it would spread onto
10 Bosnia-Herzegovina as well, certain members of the cadet contingent and
11 members of the faculty started leaving the JNA and moving back to their
12 own midst. At the same time, information started reaching us, despite
13 our belief that there would be no conflict, that various paramilitary
14 formations were being set up, such as the Green Berets and the Patriotic
16 Q. Just a moment.
17 JUDGE MOLOTO: Your question, Mr. Lukic, had been where were you
18 when the war started. We haven't got an answer to that yet.
19 MR. LUKIC: [Interpretation] I will go back to that part.
20 Q. You have just heard the Judge's intervention.
21 A. I was teaching at the Military Academy of air force and
22 anti-aircraft defence. When the war broke out, for a while, I was at
23 Butmir airport together with some of the cadets and teachers from the
25 Q. Why did you go to Butmir?
1 A. We received a task from our commander, actually the commander of
2 the 2nd Military District, to protect the infrastructure at the airport,
3 the facilities there, and the equipment that was stored there.
4 Q. When you finished work, did you go home? How did you move about
5 at the time?
6 A. At the time, I didn't go home. Not only then but even before
7 then. For at least a month or two months we would go home only
9 Q. Why?
10 A. Because conflicts had already started, interethnic conflicts, and
11 the JNA and the 2nd Military District tried to prevent interethnic
12 conflicts. And we were on duty all the time, and those of us who had to
13 be engaged were engaged. Not me personally. At the time, I was not
15 Q. Where does your family live in the spring 1992?
16 A. Until the end of April, they lived in Sarajevo. And then they
17 fled, became refugees, I don't know how to express it, or they were
18 expelled first to Bijeljina and then to Belgrade.
19 Q. Where were you when the JNA withdrew from Bosnia-Herzegovina?
20 A. On the 12th of May, 1992, with the last remnants of the Military
21 Academy, I transferred from Butmir airport to Belgrade.
22 Q. Did you go back to Bosnia-Herzegovina?
23 A. Yes. In the end of July, I believe it was the 31st of July, I
24 returned and joined the Army of Republika Srpska.
25 Q. Where were you assigned? Where were you deployed in the end of
1 July 1992?
2 A. I reported to the Main Staff, and I was assigned to the sector
3 for morale, religious, and legal affairs of the Main Staff of the VRS.
4 Q. How many people were you in that sector; if you remember?
5 A. When I arrived, there were seven members in that sector.
6 Q. To what level were you manned in that sector?
7 A. It was supposed to have 40 men, and we were eight.
8 Q. While we're on the subject, what were the main problems in the
9 organisation of the Army of Republika Srpska?
10 A. There were many problems. A state of war had not been declared
11 so that the army operated and worked under peacetime laws; whereas, in
12 practice, it was in war already. That made command very difficult but
13 also all the other activities and responsibilities of the commands.
14 Second, the army did not have a centralised and unified system of
15 procurement and equipment. It lacked all the necessary elements. It had
16 to rely primarily on local communities and businesses on the ground.
17 Third, in the organisation of the army, there were two prevailing
18 concepts: One concept that supported the establishment of units,
19 primarily brigades, based on the territorial principle; and the second
20 concept advocating that the army should be organised based on
21 ex-territorial manning, and that second principle was backed by the
22 Main Staff.
23 Another problem for the army was the lack of the necessary
24 unified and uniform care for the families of fallen fighters and the
25 population that had left its own areas of residence, so many of our
1 personnel were preoccupied with their own family problems, including
2 members of the command.
3 Q. Thank you. To what level were you manned with professional
5 A. To a very small extent. The manning level was very low.
6 Q. Can you give us some numbers.
7 A. Relative to the total number of personnel in the army, the
8 percentage of professional officers was 2 to 3 per cent, at a maximum.
9 Q. And the territory that you were supposed to defend? What was it
11 A. The territory was very stretched out with a very long line of
12 separation with the opposing sides, upward of 2.000 kilometres which made
13 it impossible to employ the army adequately.
14 Q. Thank you. Let us go back to your own sector. Did your sector
15 have smaller organisational units; and, if so, what kind?
16 A. Our sector was organised into sections, and there were four
17 sections: The section for morale and religious affairs; the section for
18 information; the section for civilian affairs; and the section for legal
20 Q. In which section were you?
21 A. I was deployed in the section for morale and religious affairs.
22 Q. You've told us earlier that the manning level was not good in
23 your entire sector. Was there a section that didn't have a single
25 A. Yes. The section for civilian affairs had nobody. In one part
1 of the section for morale and religious affairs, in addition to two
2 persons who were dealing with morale and morale guidance, the same people
3 had to deal with religious affairs, because there was nobody specialising
4 in that. And in the section for information, there were two people; and
5 in the section for legal affairs also two.
6 Q. In the section for information, who was working there? What was
7 their rank?
8 A. In the beginning, the head of section was Sergeant Borislav
9 Djurdjevic, a staff-sergeant, and there was another person who was a
10 typist. Later, heads of sections rotated. For a while, it was
11 Captain First Class Mladen Petrovic. Then for two months, it was
12 Colonel Vukota Vukovic. Then for a longer while, it was Colonel Stanko
13 Misic. And in the end, Colonel Milovan Milutinovic.
14 Q. Who was your superior?
15 A. General Milan Gvero.
16 Q. And who was superior to General Gvero?
17 A. The commander of the Main Staff of the VRS, General Ratko Mladic.
18 Q. What was your position in the sector?
19 A. I was head of the section for morale, guidance and religious
20 affairs. In the beginning, my rank was lieutenant-colonel and then I was
21 promoted into colonel.
22 Q. In the course of the war, did you become head of one of the
23 sections or sectors? Did you change position during the war?
24 A. No. The answers to both questions is no.
25 Q. When did you become head of section for moral guidance?
1 A. In December 1992. Until then, I was a desk officer in the
3 Q. During the war, were you reassigned to any other duties?
4 A. No.
5 Q. In your sector for morale guidance, religious, legal affairs, did
6 sections regularly meet?
7 A. No, they did not.
8 Q. When would they meet, if ever?
9 A. Between sections, communication was usually through direct
10 contact and by telephone. Because part of the sector was deployed at the
11 main command post in --
12 THE INTERPRETER: The interpreter didn't hear.
13 THE WITNESS: [Interpretation] And another part was in
14 Han Pijesak, and communication was then usually by phone, especially
15 during cease-fires, then we would meet all together.
16 JUDGE ORIE: Witness --
17 MR. LUKIC: Yeah, okay.
18 JUDGE ORIE: -- you said that you had contacts by telephone
19 because part of the sector was deployed at the main command post in ...
20 And then the interpreters did not hear where that main command
21 post was.
22 THE WITNESS: [Interpretation] That is the main command post
23 deployed in Crna Rijeka, and another part was in the logistical command
24 post in Han Pijesak.
25 JUDGE ORIE: Please proceed.
1 MR. LUKIC: Thank you, Your Honour.
2 Q. [Interpretation] Where were you?
3 A. I was at the main command post.
4 Q. How did the reporting go inside the sector and vis-à-vis the rest
5 of the Main Staff and who reported to the Main Staff on issues of moral
6 guidance, for instance?
7 A. Heads of sections usually reported by telephone to the superior -
8 that is to say, head of the sector - except for me who was there, so I
9 did not need to use the telephone so often. The head of sector, I
10 suppose, reported to the Main Staff - that is to say, the commander and
11 assistant commanders - at occasional meetings or in direct contact,
12 especially in situations when something important from the area of our
13 sector was discussed.
14 Q. Did units report on these issues to the Main Staff?
15 A. On issues concerning moral guidance and other issues relevant to
16 our sector, subordinate units made monthly reports and submitted them to
17 the Main Staff, and in the Main Staff it would be put on the desk of the
18 head of sector and then forwarded to me or somebody else from the sector
20 In addition to that, if there was an event relevant and important
21 for morale between two reports, subordinate units would send an interim
22 report, but that happened rarely.
23 And, finally, as part of the regular daily combat reports, there
24 was an item dedicated to the level of morale and the situation on our
25 territory, on the territory of the unit. And that part of the report was
1 written by organs in the command who were in charge of reports, and the
2 head of sector at the Main Staff had the responsibility to look at that
3 part of the combat report or, if he was absent, then I would do it.
4 Q. Could you just explain the competencies and the main tasks of the
5 sector for morale guidance, religious and legal affairs, and your main
7 A. The section for morale guidance and religious affairs --
8 Q. Excuse me, just a moment. I believe that my question did not
9 have to do with the sector primarily. It is not correctly recorded.
10 I'll repeat it.
11 Could you explain the competencies and the principle tasks of the
12 section for morale guidance within the sector for morale guidance,
13 religious and legal affairs, and your main responsibilities.
14 A. Section for morale guidance monitored the state of morale and
15 factors that had a positive impact on the troops' morale and those who
16 had a negative impact on the troops' morale. Based on instructions -- or
17 rather, the instruction for monitoring and assessing combat morale in the
18 Army of Republika Srpska which was issued in 1992, the section used the
19 indicators from the instruction to assess combat morale. All that was
20 done based on the monthly reports received from subordinated units, based
21 on the information contained in regular daily reports, based on the
22 information personally gathered by the officers who visited the units or
23 any other information.
24 Based on all that, the section compiled its reports on the
25 troops' morale for the previous month. All the elements were
1 incorporated, and there was also a conclusion and the proposal of
2 measures that had to be undertaken at the level of subordinated units and
3 commands. There was also a proposal for the contents of those measures
4 that would be undertaken by the Main Staff of the Army of
5 Republika Srpska itself. There was also a proposal of the measures that
6 should be undertaken by the Supreme Command, i.e., the highest state
7 organs, all with a view to strengthening the troops' morale.
8 That information was sent to the commanders' collegium and, more
9 often than that, because not everybody was present at those meetings, the
10 information of that nature was looked at by the chief of sector, and all
11 those who participated would make their proposals. The report was
12 fine-tuned and sent to the president of the republic. And the
13 subordinated the units were sent this for their information only, and
14 feedback was requested from them.
15 JUDGE ORIE: Mr. Lukic, the Chamber has now listened for some 45
16 minutes to matters of which most of them at least they do escape our
17 sense of relevance.
18 Try to get to the points you want to make with this witness,
19 because if you want to counter the evidence presented by the Prosecution,
20 which is, of course, also including structures but always in one way or
21 another related to the crimes charged, get to a point that we understand
22 how the evidence of this witness challenges the evidence presented by the
23 Prosecution, rather than in vague terms as: To this was the organisation
24 sometimes people attended; sometimes people did not attend. We had
25 meetings, but sometimes we had no meetings.
1 Get to the point. Please proceed.
2 MR. LUKIC: Your Honours, it does take -- when it's live
3 testimony, it does take to have some introduction, and I think that
4 it's --
5 JUDGE ORIE: Well, fine. I understand that. That's the reason
6 why I'm saying that 80 per cent of the testimony escapes our relevance.
7 Some introduction, fine. We now -- you've scheduled it for two and a
8 half hours. We have listened 45 minutes to introduction. Get to what
9 you want to convince the Chamber of.
10 Please proceed.
11 MR. LUKIC: Thank you. Can we have P5082 on our screens, please.
12 JUDGE ORIE: While we're waiting for it, we have a tight schedule
13 this week, so we're not very much inclined if examination proceeds as it
14 does now to grant any additional time.
15 Please proceed.
16 Q. [Interpretation] General, this document was drafted in
17 February 1995, and it is about the responsibilities and the recruitment
18 of the organ for moral guidance, religious, and legal affairs in the
19 units and institutions of the Army of Republika Srpska.
20 At the end of the document, on the last page thereof, there is a
21 typed name of General Ratko Mladic. In the version that we have, there
22 is no signature; however, in the document on the screen, we see that
23 there is a signature, as a matter of fact.
24 Can I go back to the first page, please. Thank you.
25 Are you familiar with this document?
1 A. Yes.
2 Q. Does this document have anything to do with your division or your
4 A. This is about the responsibilities and the recruitment of the
5 organ for moral guidance, religious, and legal affairs in the Army of
6 Republika, the entire army. The document was drafted by the sector.
7 Chiefs of various decisions used the rules and their experience to work
8 out those responsibilities. So this document covers the entire military
9 ranging from the General Staff to the lowest of units, i.e., a platoon.
10 Q. Let me ask you something about the relationship with the media.
11 What was the position of the Main Staff and your division and sector
12 vis-à-vis the media, both national and foreign, and representatives of
13 international organisations?
14 A. That was within the purview of the division for information. The
15 attitude towards international -- or, rather, the relationship with
16 UNPROFOR and other international organisations was within the purview of
17 the division for co-operation with international organisations. To be
18 very concrete and answer your question, the position was that we should
19 be fair and professional in dealing with journalists and representatives
20 of international organisations. The same was requested from them; i.e.,
21 there should have been reciprocity in our mutual relationship.
22 MR. LUKIC: [Interpretation] I'd like to call up 1D5391.
23 Q. This document was issued on the 15th of March, 1995. The
24 document was signed, and we don't need to see it, or, rather, it was
25 signed on behalf of General Milan Gvero. Since this is a teletyped
1 message, the signature is not displayed. It was sent to all the corps,
2 as you can see, and to some other addressees to some other units.
3 In the first paragraph, we read:
4 "We have lately been aware that commands and units are following
5 different procedures in informing the public and treating domestic and
6 foreign journalists whereby they are seriously violating the guide-lines
7 on informing the public about the VRS, order of the RS president ...
8 issued in 1994 and other orders regulating these issues. Such behaviour
9 has resulted in revealing an increased amount of information constituting
10 military secrets, which...."
11 First of all, you've seen this document during proofing. How
12 come that military secrets were leaked? What was the procedure when it
13 came to keeping military secrets?
14 A. Disclosing confidential military information which primarily
15 concerned the deployment, the size, the strength, the equipment, the
16 planned tasks, results, this information was leaked in two ways. The
17 first one was -- originated from the units. Desk officers or assistant
18 commanders for moral guidance and information were poorly informed and
19 for other reasons leaked information that constituted revealing military
20 secrets. And the second case was when journalists visited the deployment
21 area of a unit, sometime with the best of intent and sometimes not,
22 published information that constituted revealing military secrets.
23 Q. What was the role of the sector headed by General Gvero when it
24 came to the protection of military secrets?
25 A. At the very beginning, i.e., 1992, the sector issued an
1 instruction on how to inform the general public about the activities of
2 the VRS, and this instruction is referred to in this document as well.
3 Later on, on several occasions whenever certain occurrences were
4 observed, it issued additional instructions. The chief of sector's
5 personal attitude was that these instructions had to be strictly
6 observed, that military intelligence had to be kept secret because there
7 were occasions when a leakage of such confidential information cost
9 MR. LUKIC: We would offer this document into evidence,
10 Your Honour.
11 JUDGE ORIE: I didn't hear your last words.
12 MR. LUKIC: We would offer this document into evidence, 1D05391.
13 JUDGE ORIE: Mr. Registrar.
14 THE REGISTRAR: As Exhibit D1053, Your Honours.
15 JUDGE ORIE: Admitted into evidence.
16 We're close to a break, Mr. Lukic. Still, even that military
17 secrets should be kept confidential, should not leak, is not an
18 astonishing thing, and the link to the crimes charged is still not clear
19 to us, and therefore also not the relevance of this information. And
20 that's for the last well over ten minutes now that we have listened to
22 I mean, if there would have been no leakage, would that have
23 changed considerably the situation?
24 MR. LUKIC: This gentleman is in the sector of morale and legal
1 JUDGE ORIE: Yes, I understand that. But it's about relevance
2 for this case; that's what I'm talking about. I leave it to that.
3 You have two minutes until the break.
4 MR. LUKIC: Can we have 65 ter 14781, please.
5 Q. [Interpretation] General, this is a document which was issued on
6 the 20th of June, 1992. Its title is: "Prevention of Reprisal and
7 Treatment of Journalists and Representatives of International
9 Under 1 --
10 MR. LUKIC: I think it's the break time. Maybe we should first
11 go to the break and return, because this one will probably take another
12 five to ten minutes for this document.
13 JUDGE ORIE: We'll take a break.
14 Could the witness be escorted out of the courtroom.
15 We'll take a break of 20 minutes, Mr. Sokanovic.
16 [The witness stands down]
17 JUDGE ORIE: We will resume at ten minutes to 11.00.
18 --- Recess taken at 10.30 a.m.
19 --- On resuming at 10.52 a.m.
20 JUDGE ORIE: While we are waiting for the witness to be escorted
21 into the courtroom, I would briefly like to deal with P1655.
22 The Prosecution has requested on the 5th of May during the
23 testimony of Nedjelko Trkulja that Exhibit P1655 not be broadcast. The
24 exhibit was then temporarily placed under seal and the Chamber requests
25 that the Prosecution provide further information on the record this week
1 as to why Exhibit P1655 should be kept confidential.
2 Of course, we do not know whether that needs to be done
3 confidentially or not, but I leave that in your hands.
4 [The witness takes the stand]
5 JUDGE ORIE: Mr. Lukic, you may proceed.
6 MR. LUKIC: [Interpretation] Thank you.
7 Q. General, we have before us a document dated 20th June, 1992, a
8 document from the Main Staff of the VRS. As we see at the bottom, the
9 name of Major-General Milan Gvero is typewritten.
10 Let me just ask you: What was the position, the policy of the
11 Main Staff, towards the civilian population of the opposite side?
12 A. The Main Staff did not treat any civilian population as its
13 adversary or enemy that should be attacked. On the contrary, the
14 position was that the civilian population should be treated properly,
16 Q. Did the Main Staff, through its subordinate units, try to
17 organise expulsions of that population, torching and looting of their
19 A. No.
20 Q. If information reached the Main Staff about such actions, such as
21 torching of property or any action against civilians, what would the
22 Main Staff do?
23 A. As we see from this document of the sector, the persons involved
24 were cautioned and instructions were issued as to what should be done and
25 what consequences would be triggered by failure to obey, and the security
1 organs initiated, or at least should initiate, criminal complaints if
2 such things happened. I can give you one example. The Main Staff itself
3 was located less than 1 kilometre from a Muslim settlement, and for a
4 very long time no measures were taken, although there had been incidents
5 created by the other side.
6 JUDGE ORIE: Mr. Lukic, I'm then wondering how the answer
8 What then happened?
9 THE WITNESS: [Interpretation] Your Honours, are you asking me?
10 JUDGE ORIE: Yes. Well, you are giving an example of what was
11 done if anyone from your armed force would do anything against civilian
12 population. You give an example but you said: For very long time, no
13 measures were taken although there had been incidents created by the
14 other side. So apparently are you talking about not protecting the
15 civilian population again actions undertaken by your own soldiers but by
16 the others.
17 Could you give us one example of ill-treatment of the civilian
18 population reported and then what action was taken against your own
19 soldiers that had shown this behaviour against the civilian population?
20 Just one example to start with.
21 THE WITNESS: [Interpretation] Your Honours, maybe what I said was
22 not interpreted properly or maybe I was not clear enough. I cited an
23 example where the civilian population very close to the Main Staff, less
24 than 1 kilometre, lived and enjoyed protection from our side. Anyone who
25 wanted to do anything against that civilian population was stopped.
1 JUDGE ORIE: That's not the kind of example I'm seeking. What
2 I'd like you to tell us of one instance where your own soldiers
3 misbehaved against the civilian population and what action was then taken
4 in terms of investigations, prosecutions, whatever. Could you give us
5 one such example?
6 THE WITNESS: [Interpretation] Your Honour, I cannot give you an
7 example like that because I can't remember. That was within the purview
8 of the prosecutor's offices and the courts.
9 JUDGE ORIE: Yes, but you're telling us that whenever this was
10 reported, action would be taken, et cetera, et cetera, so apparently you
11 are familiar with what should have been but -- and I think it touches
12 upon the morale as well, and you show us this document. But not one
13 example of your own soldiers misbehaving and then action taken by the
14 Main Staff to investigate or to prosecute or whatever. No example?
15 THE WITNESS: [Interpretation] Right now, I can't remember.
16 JUDGE ORIE: Please proceed, Mr. Lukic. And this is exactly the
17 difference between general observations and concrete facts.
18 MR. LUKIC: This is exactly why we introduced that long
19 introduction, to show you what competencies of this gentlemen were
20 [Overlapping speakers] --
21 JUDGE ORIE: But finally to -- [overlapping speakers].
22 MR. LUKIC: At last, I will follow your questions now trying
23 further to clarify what his role was.
24 JUDGE ORIE: Yes, but I am and this Chamber is very much
25 interested, I'm not saying exclusively, but very much interested in what
1 happened on the ground. And now we've seen a document which states what
2 should be done, and then my question is was that done, and then the
3 witness can't give us any example, so we are remaining then very much on
4 the abstract level; whereas, the Chamber is as much interested in the
5 concrete level as well.
6 Please proceed.
7 MR. LUKIC: [Interpretation]
8 Q. General Sokanovic, your sector and your section, did they deal
9 with investigations of criminal acts?
10 A. No, and it was not in their area of work.
11 Q. What is the role of your section in terms of preventative action?
12 A. Through our briefings, contacts, and in other ways, we cautioned
13 about possible consequences of wrong-doing, but the fact that we
14 cautioned doesn't mean that we were supposed to enforce it. The
15 competent authorities were supposed to enforce it. Within the sector,
16 our section, and within the Main Staff of the VRS, instructions applied
17 to all the institutions and all the commands of the army.
18 Q. In this document signed by late Major-General -- or, rather,
19 General Milan Gvero, we read:
20 "In our previous documents, we have several times pointed out the
21 need to prevent reprisals against innocent people (looting, burning,
22 destruction, and maltreatment).
23 "Such actions are not and must not be characteristic of the
24 members of our army ..."
25 These warnings addressed to subordinate units, were they honest
1 and sincere in your opinion, or were they designed to conceal different
2 behaviour that was pre-planned?
3 A. No, these warnings were sincere.
4 Q. We discussed representatives of the foreign media. Were they in
5 any kind of danger of reprisal?
6 A. Yes.
7 Q. Why?
8 A. Some people and a number of fighting men were wounded or killed,
9 and their families, comrades in arms, and relatives were very embittered
10 for that. I don't know for what reasons. Perhaps because of their pain
11 and their experience. But they were in real danger of reprisal, and we
12 also warned about that, and we pointed out the need to protect them from
13 anything like that.
14 JUDGE MOLOTO: I don't understand the answer, Mr. Lukic. Your
15 question was: Whether foreign media representatives were in any kind of
16 danger. The witness says:
17 "Some people and a number of fighting men were wounded ..."
18 And he's talking about these fighting men being protected against
19 danger. Now, would representatives of the foreign media be fighting
21 MR. LUKIC: [Interpretation]
22 Q. You heard the dilemma voiced by Judge Moloto. Could you please
23 explain what you meant.
24 A. A number of fighting men but not only fighting men; also the
25 civilian population were embittered and were hard-hit by the death of
1 their comrades in arms or relatives or by their wounding. We thought it
2 was possible when representatives of the foreign media appear, but not
3 only the foreign media, also the local media, that could lead to
4 embitterness -- bitterness, revolt, and even reprisal. I don't remember
5 that a single foreign reporter was killed in the territory controlled by
6 the VRS.
7 JUDGE MOLOTO: You can go ahead.
8 MR. LUKIC: [Interpretation]
9 Q. What kind of danger were foreign reporters in?
10 A. Well, they were at risk of being attacked or even liquidated.
11 Q. Apart from the warnings sent out by your sector, did you also
12 provide security or was security the job of someone else?
13 A. You mean foreign reporters?
14 Q. Yes.
15 A. Providing security to reporters in the territory of
16 Republika Srpska, regardless of whether it was a combat zone or somewhere
17 behind the lines was the responsibility of two types of authorities:
18 Partly the Ministry of Interior and partly the army, especially when
19 reporters would go to military installations or areas involved in the
21 JUDGE ORIE: Could I ask Mr. Traldi or Mr. Tieger: Is
22 endangering foreign journalists part of your case? Putting them at risk,
23 attacking them?
24 [Prosecution counsel confer]
25 JUDGE ORIE: We've heard evidence of foreign journalists, but --
1 MR. TIEGER: Mr. President, I think you can see by the length of
2 the discussion between Mr. Traldi and myself that we're hard-pressed to
3 understand the precise relevance of this concern about journalists to the
4 actual charges in the case. We're not suggesting that there isn't some
5 manner in which it can bare on that, but as the Court's question itself
6 suggested, it's not a specific charge and it's not particularly embedded
7 in -- in the overall Prosecution case.
8 JUDGE ORIE: Mr. Lukic, if there's no real issue about protecting
9 foreign journalists to -- why do we hear that? --
10 [Prosecution counsel confer]
11 JUDGE ORIE: You may proceed.
12 MR. LUKIC: [Interpretation]
13 Q. Mr. Sovanovic --
14 JUDGE FLUEGGE: I think it's Mr. Sokanovic.
15 MR. LUKIC: Sokanovic.
16 JUDGE ORIE: It's the second time.
17 MR. LUKIC: Second time.
18 JUDGE ORIE: I don't correct you if you're speaking your own
19 language, Mr. Lukic, but we also have to protect the witness as well.
20 MR. LUKIC: I apologise to Mr. Sokanovic as well.
21 Q. Mr. Sokanovic, what was the position of the Main Staff? Were
22 journalists to be allowed to write freely on what they wanted to see,
23 obviously with the caveat from military secrets had to be protected?
24 Were foreign journalists allowed to travel the length and the breadth of
25 Republika Srpska?
1 A. The position of the Main Staff was to allow journalists to write
2 freely, that they had to make sure that military secrets were not
3 revealed, and that they could move freely wherever their own personal
4 safety or military secrets were not threatened.
5 JUDGE ORIE: Mr. Lukic, again a sweeping statement. We have
6 heard detailed evidence about the first visit to Omarska by one of the
7 journalists. We have seen quite a lot of documents about what happened
8 in the Srebrenica area on details on who would be allowed yes or no.
9 These sweeping statements do really not assist in better understanding
10 the situation apart from -- I mean, these are but -- and we have seen
11 that before, and we have heard other witnesses say in general every
12 journalist was free to report and to go wherever he went unless, and of
13 course the focus is on the "unless."
14 Let's proceed. If the witness has any specific knowledge,
15 specific events, specific limitations, in the freedom of movement of
16 journalists and further reasons for that, we'd like to hear it very much,
17 but general statements we've heard quite a bit.
18 Please proceed.
19 MR. LUKIC: You are very impatient today, Your Honour. We'll
20 come -- next document will speak about that. We will offer this one into
22 JUDGE ORIE: Mr. Registrar.
23 THE REGISTRAR: 65 ter number 14781 will be Exhibit D1054.
24 JUDGE ORIE: Admitted.
25 MR. LUKIC: Next document we would like to see 65 ter 05852.
1 Q. [Interpretation] Mr. Sokanovic, the document before us was issued
2 on the 26th of July, 1995.
3 MR. LUKIC: If we can see the bottom of the document in both
4 versions, please.
5 Q. [Interpretation] The document has a signature stamp of the deputy
6 chief of sector, Colonel Savo Sokanovic. Is that you?
7 A. Yes.
8 Q. What was your role in the Main Staff with regard to foreign
9 journalists and reporters?
10 A. Can I expand on that, please? Not only foreign reporters but all
11 reporters who wanted travel through Republika Srpska and visit certain
12 facilities and units addressed the Ministry of Information of the
13 government of Republika Srpska. More often than not they would present
14 themselves personally at its door, and then that request was forwarded to
15 the Department for Information which was in Han Pijesak.
16 Since they didn't know what was the situation like in the field,
17 whether there were any combat activities where the journalists wanted to
18 go, they would forward that request to the chief of sector, i.e., myself,
19 with a request to collect information and send the request back so that
20 they could answer. That was a standard procedure that was applied. And
21 then based on the position of the operative organ who was familiar with
22 the situation on the field, the superior organs of information and
23 security and its -- and their opinion, a consent or approval would be
24 given for the journalists' free passage, if at all possible.
25 Q. In this document, we can see that the team of ZDF journalists
1 were allowed passage from Pale across Rogatica, Visegrad, towards
2 Belgrade. Was all this information on combat activities also collected
3 even when a team of journalists wanted to pass through? What was your
4 role in the collection of that information?
5 A. As I've just explained, an approval was sought for every
6 situation for a mere passage or a longer stay with a unit in an area of
7 combat activities.
8 Q. In your answer, you said what should have been done. Did you
9 personally collect information, for example, from the security sector or
10 from the operations sector in the area where combat was ongoing?
11 A. Yes, it was either me or one of the colleagues who were members
12 of the organ at that time.
13 Q. You have previously told us that the protection of those
14 reporters was dual. We can see that they would be accompanied by the
15 police patrols from Pale. How did you know that the MUP would be in
16 charge of their security?
17 A. In two ways: One way was that part of the request was also
18 police protection, which was then regulated in keeping with the rules of
19 the Ministry of Interior; and the second way was when such teams passed
20 through areas where there was no combat, so the military did not have to
21 provide security. A previous order of the president of Republika Srpska
22 defined that both the MUP and the military provided protection for teams
23 of journalists as needed.
24 THE INTERPRETER: Could the witness please be instructed to move
25 away from the microphone. Thank you.
1 JUDGE ORIE: Witness, could you move slightly away from the
2 microphone. Although I'm not certain that it -- this resonance is caused
3 by the closeness or whether it's anything else. Could you please -- the
4 usher will stay with you until after you have restarted answer -- started
5 the answer to your next question.
6 Mr. Lukic, security for journalists, as we established a minute
7 ago, was not a major issue.
8 Please proceed.
9 MR. LUKIC: Thank you, Your Honour. We would offer this document
10 into evidence.
11 JUDGE ORIE: Mr. Registrar.
12 THE REGISTRAR: That will be Exhibit D1055, Your Honours.
13 JUDGE ORIE: Admitted.
14 Please proceed.
15 MR. LUKIC: [Interpretation]
16 Q. And now I'd like to ask you about humanitarian convoys.
17 What do you know by the co-ordination body of the government of
18 Republika Srpska that dealt with issues relative to humanitarian convoys?
19 A. The president of the Republika Srpska issued an order to set up a
20 co-ordination body for humanitarian organisations. A representative of
21 the military was a member of that body. That body was headed by
22 Mr. Kalinic or Krajisnik, I'm not sure, somebody from the top echelons of
23 the government. There was a member from the Ministry of the Interior.
24 Another member was from the commissariat for refugees and displaced
25 person. Humanitarian organisations that wanted to deliver humanitarian
1 aid or do other things in the territory of Republika Srpska or those who
2 wanted to pass through the territory of Republika Srpska had to address
3 that co-ordination body. The representative of the military of
4 Republika Srpska participated in the work of the co-ordination body and
5 the final position of the co-ordination body was binding.
6 MR. LUKIC: Can we 65 ter number 12957.
7 Q. [Interpretation] We have just talked about this. This document
8 was issued in December 1993, and it deals with the co-ordination body.
9 You've already told us something about that.
10 If the co-ordination body allowed a convoy to pass through the
11 territory, what was the role of the military following such a decision?
12 A. Either the military or the police, depending on the nature of the
13 convoy, if such a convoy just passed through Republika Srpska to go
14 elsewhere, the military and the police were duty-bound to check the list
15 of personnel and cargo of the convoy, and if there were no discrepancies
16 or hindrances, they were supposed to allow their free and unhindered
17 passage. If there was a problem, the convoy would be kept and the issue
18 would be dealt in an adequate way.
19 For example, sometimes they would enter with a surplus of cargo
20 that was not covered by the convoy manifest. Such cargo would be kept at
21 the check-point, and when the convoy returned on its way back it would
22 pick up the cargo and take it away.
23 MR. LUKIC: We would offer this document into evidence.
24 JUDGE ORIE: Mr. Registrar.
25 THE REGISTRAR: Exhibit D1056, Your Honours.
1 JUDGE ORIE: No speaking aloud, please.
2 Please proceed, Mr. Lukic.
3 Yes, I first should have -- admitted into evidence.
4 MR. LUKIC: Thank you, Your Honour.
5 JUDGE ORIE: The record is not entirely clear. D1056 is
7 Please proceed.
8 MR. LUKIC: Thank you.
9 Q. [Interpretation] When it comes to your sector, did it try to act
10 pre-emptively with regard to POW camps?
11 A. Yes. They did it in the following sense. Although this was not
12 within the sector's jurisdiction, still we issued warnings about the
13 respect for the rights of prisoners. We also stated that the
14 representatives of the International Red Cross and other international
15 organisations should be allowed free visits. So those were the warnings
16 and instructions we issued.
17 JUDGE ORIE: Any concrete example of such a warning, Witness?
18 MR. LUKIC: Can we have on our screens, Your Honour, 1D05432.
19 JUDGE ORIE: If that's an example, then there's no need for the
20 witness to answer my question at this point.
21 JUDGE FLUEGGE: 1D5432.
22 MR. LUKIC: Yes, Your Honour.
23 [Defence counsel confer]
24 MR. LUKIC: [Interpretation] It seems that there's no translation
25 at this moment.
1 Q. For the benefit of all the others who don't understand B/C/S, I
2 will say that the document was issued on the 28th of May, 1993. The
3 title is: "Instruction on the Actions of the Units of the Army of
4 Republika Srpska when Visiting POW Camps and Military Investigation
6 On the last page, that is to say this next page, let's look at
7 the signature. It's signed General Milan Gvero. And we see it was
8 delivered to all the corps and the command of the air force and
9 anti-aircraft defence.
10 MR. LUKIC: [Interpretation] Can we go back to page 1.
11 JUDGE ORIE: It's not signed, but the author is -- well,
12 Mr. Lukic, sometimes you have --
13 MR. LUKIC: [Overlapping speakers] ...
14 JUDGE ORIE: -- you have commented on the situation. I leave it
15 to that.
16 MR. LUKIC: Yes, my mistake.
17 JUDGE ORIE: Yes.
18 MR. LUKIC: This is a --
19 JUDGE ORIE: But you accept that this was sent by Mr. Gvero?
20 MR. LUKIC: Well, I spoke with this witness on this document
21 during the preparation, and then I can ask him. It may be better then.
22 JUDGE ORIE: Well, I'm asking for the position of the Defence,
23 but ...
24 MR. LUKIC: It is -- it's typewritten. Whether he signed it or
25 not, it cannot be seen from this document.
1 JUDGE ORIE: My question is whether you accept that it was
2 sent by Mr. Gvero.
3 MR. LUKIC: It is definitely not sent by Mr. Gvero. It's
4 somebody from the centre.
5 JUDGE ORIE: Well, yes, that it was sent and that this was
6 authored by General Gvero.
7 MR. LUKIC: I can ask the witness. I cannot testify on this
9 JUDGE ORIE: Well, you can -- you can present the position of the
10 Defence on it, which may save a lot of questions as well now and then.
11 But if you don't want to answer that question, then just move on.
12 MR. LUKIC: Thank you.
13 JUDGE ORIE: Mr. Traldi.
14 MR. TRALDI: Just if it might assist, we've got a translated
15 version of what we believe to be the same document under a different ERN.
16 It's uploaded under 65 ter 32561, and my colleague has just released it,
17 in case Mr. Lukic would prefer to work with that one.
18 MR. LUKIC: Thank you for your help.
19 JUDGE ORIE: The Chamber would certainly prefer to see the
20 English version as well.
21 MR. LUKIC: Can we have then 65 ter 32561, please. I can read
22 this translation.
23 JUDGE ORIE: Yes, I can imagine that you can. First of all, you
24 accept that it's the same -- it's not the same document but it's another
25 copy of --
1 MR. LUKIC: The same number appears on the top.
2 JUDGE ORIE: Yes. So that's -- although it may be -- there were
3 some -- some handwriting on it, but the typed text or the printed text is
4 the same?
5 MR. LUKIC: Yes, Your Honour.
6 JUDGE ORIE: Please proceed.
7 MR. LUKIC: Thank you, Your Honour.
8 Q. [Interpretation] Mr. Sokanovic, is this a document drafted in
9 your sector?
10 A. I didn't hear part of your question.
11 Q. Sometimes I speak too fast. Did this document originate in your
12 sector; if you know?
13 A. Yes. We see the registry number from our sector. We can't see
14 the signature because it was sent by teletype. A teletype cannot
15 transmit a signature, but we see the stamp at the end confirming that a
16 certain unit had received this document.
17 MR. LUKIC: Can we see the second page of this document? We
18 don't know if there is a stamp on this one. There is. It's slightly
19 different stamp, but we -- we can use this document.
20 Q. [Interpretation] In your sector, were you able to monitor the
21 enforcement of this or is this just an instruction? Who was supposed to
22 do something about this?
23 A. [Interpretation] This is only an instruction.
24 Q. Who was supposed to monitor its enforcement?
25 A. POW prisons were established by corps, and each corps had a
1 commander of such a prison. He was supposed to monitor the situation and
2 report to the corps commander, and if the corps commander decided
3 something was important enough, he would submit it to the commander of
4 the Main Staff.
5 MR. LUKIC: We would offer this document into evidence; so it's
6 65 ter 32561.
7 JUDGE ORIE: Mr. Registrar.
8 THE REGISTRAR: That's Exhibit D1057, Your Honours.
9 JUDGE ORIE: Admitted into evidence.
10 MR. LUKIC: [Interpretation]
11 Q. Mr. Sokanovic, which service in the Main Staff was in charge of
12 following the media?
13 A. It was the section for information within the sector for morale,
14 religious, and legal affairs.
15 Q. At the Main Staff, were you able to follow foreign media such as
16 the CNN, BBC, Deutsche Welle?
17 A. No.
18 Q. At that time, was there any cable television in
20 A. I don't know about Bosnia-Herzegovina, but not where we were.
21 Q. Did you have Internet?
22 A. No.
23 Q. Did you read foreign newspapers and did you receive foreign
25 A. No.
1 Q. At the Main Staff, did you have satellite aerials to receive
2 foreign TV programming?
3 A. No.
4 Q. Thank you. Let me now ask you about problems in getting
6 In those years of war, were there any problems in gathering
8 A. Yes. I was not head of that section, but I know for a fact that
9 there were problems. I can even tell you about some of them.
10 Q. Yes, please.
11 A. The first part of the problem was in gathering information. That
12 is to say, whether the units from bottom to top regularly gather
13 information and forward it to higher levels. That was the job of this
14 section. But unfortunately, it was not the case. Due to lack of
15 personnel or lack of experience, it functioned more or less in some
16 places not at all, in other places moderately well.
17 The second part of the problem was the lack of equipment.
18 Cameras, printers, copying machines, communications equipment. It was
19 very difficult to pass information on.
20 The next problem was with generalisations. Inadequately trained
21 people were not always able to make an appropriate analysis and summarise
22 information into reports. Communication was towards units and towards
23 the public. There were limitations to our technical ability.
24 As far as the operation of the army is concerned, a particular
25 problem was that our troops were stretched thin along an extremely long
1 separation line. It was not always possible for troops on the front line
2 to be well-informed unless a company commander would go from trench to
3 trench and inform them personally because he was unable to gather them
4 for a briefing.
5 Another problem was that troops who would go on leave rarely
6 followed any media. They were too preoccupied with their family
7 problems, with gathering wood for the winter, providing for their
8 children's education, dealing with domestic problems. These people had
9 neither the interest nor the possibility to follow the media.
10 JUDGE ORIE: Mr. Lukic, could I ask one question in relation to
11 one of the documents you have shown to the witness.
12 You were shown this where you said it was just an instruction for
13 prisoners of war, how to treat them. Now, that document explains that
14 the ICRC could only speak with prisoner of war who would be prosecuted
15 for war crimes or crimes against humanity in the presence of an examining
16 magistrate or an investigative judge. What's the basis for this presence
17 of such a judge under international law when the ICRC would visit such a
19 THE WITNESS: [Interpretation] Your Honour, I can't give you a
20 reliable answer to this question because I see by the number here that
21 this document was drafted in the legal section, but I know that a
22 prisoner should be allowed to speak to representatives of the ICRC
23 without the presence of anyone from the side who is holding these
25 JUDGE ORIE: Yes. But for certain situations, the document
1 contradicts this. So if you have no explanation for that, we'll just
2 move on.
3 Please proceed, Mr. Lukic.
4 MR. LUKIC: I can give you the position of the Defence. If
5 somebody is submitted to the investigating judge, he is only --
6 [Overlapping speakers] ...
7 JUDGE ORIE: Mr. Lukic --
8 MR. LUKIC: [Overlapping speakers] ...
9 JUDGE ORIE: -- allow me to just be a bit amused. A minute ago
10 where I asked for the position of the Defence you said I can't give it
11 because you -- you should ask the witness. Now, I asked the witness
12 something, and -- of factual about a document and what explains the
13 content of the document. Now you say we can tell it what it is. We'll
14 hear from you any submissions from that in the interpretation of this
16 MR. LUKIC: I can explain. The first one was factual question,
17 the second one is legal question. And I come from that legal system, and
18 I have a position on that one. On the matter of the signature of the
19 gentleman where I was not present, I cannot have my position.
20 JUDGE ORIE: Mr. Lukic, my question was a factual one is whether
21 this witness can explain the content of that. This witness can't do
22 that. I take it that you will be in a position later to elaborate on it
23 when you make any submissions on legal matters.
24 Please proceed.
25 MR. LUKIC: Thank you.
1 Can we have 1D5422 on our screens, please.
2 [Defence counsel confer]
3 MR. LUKIC: [Interpretation] Until we get some help from our
4 colleague Mr. Traldi and Ms. Janet Stewart, we'll have to work with the
5 B/C/S version.
6 Q. We have looked at this document during proofing, the two of us.
7 It's a document from the sector for intelligence and security affairs,
8 the security administration, the Main Staff of the VRS. At the
9 Main Staff, there was a security administration; correct?
10 A. Yes.
11 Q. At the Main Staff, was there an information administration?
12 A. No.
13 Q. In para 2 in this document -- in fact, let's first read what it's
14 about. The first paragraph says -- it's the first paragraph above what
15 we see now on the screen.
16 MR. LUKIC: Bit more further -- up. Thanks.
17 Q. [Interpretation] It says in the middle of this paragraph:
18 "As far as providing information to the public on combat
19 activities from the 6th of October to the 12th of October 1995, it's
20 necessary that security organs and units of military police fully comply
21 with the cited orders."
22 And there is an order from the sector for morale, religious, and
23 legal affairs of the Main Staff of the VRS cited at the top.
24 In item 2, we read:
25 "Individual reporters or crews from the media may enter the
1 combat zone only with the approval of the Main Staff of the VRS, signed
2 by the commander of the Main Staff, Lieutenant-General Ratko Mladic or
3 assistant commander Lieutenant-General Milan Gvero, or Colonel
4 Savo Sokanovic, the head of the information administration."
5 But you've just told us that there was no information
6 administration at the Main Staff?
7 A. Yes.
8 Q. Were you the chief of the information administration?
9 A. I couldn't be the chief of something that didn't exist. I
10 wasn't, because there was no such administration. Second, I was head of
11 the section for morale and religious affairs, not the section for
13 Q. Even if we agree that the term is wrong, you were not chief of
14 section for information either, were you?
15 A. No, I was not.
16 JUDGE ORIE: Mr. Lukic, I'm looking at the clock. Time for a
18 MR. LUKIC: Time for a break.
19 JUDGE ORIE: Time for a break. And could you tell us how much --
20 Could first the witness be escorted out of the courtroom.
21 [The witness stands down]
22 JUDGE ORIE: Mr. Lukic, any forecast as far as timing is
24 MR. LUKIC: I will stay inside two and a half hours.
25 JUDGE ORIE: Yes. Then before we take the break, I stopped you
1 earlier when you wanted to explain on the basis of your knowledge of your
2 own system. You may have misunderstood my question. My question was
3 where the justification is found in international law. Because in the
4 document, of course, it is easily stated that internal law would overrule
5 Article 126 of the Geneva Convention of this -- on the treatment of
6 prisoners of war, and that is -- we are looking forward if you, at a
7 later point in time, deal with a legal issue how internal legislation
8 could overrule any rights granted by the Geneva Conventions.
9 We take a break, and we resume at quarter past 12.00.
10 --- Recess taken at 11.53 a.m.
11 --- On resuming at 12.18 p.m.
12 [The witness takes the stand]
13 JUDGE ORIE: You may move on, Mr. Lukic.
14 MR. LUKIC: Thank you, Your Honour.
15 First I would tender 1D5422 to be MFI since we do not have
17 MR. TRALDI: No objection.
18 JUDGE ORIE: Mr. Registrar.
19 THE REGISTRAR: That's MFI D1058, Your Honours.
20 JUDGE ORIE: Marked for identification pending uploading a
22 Please proceed.
23 MR. LUKIC: Thank you.
24 Q. [Interpretation] Let me ask you about paramilitary formations.
25 In the Main Staff, did you know that there were paramilitaries in
1 the territory of Republika Srpska?
2 A. Yes.
3 Q. What was the position of the Main Staff regarding members of the
5 A. The presence of paramilitaries was very pronounced at the
6 beginning in the initial period. I don't want to go through all of their
7 names, but I would like to say that the position of the Main Staff and
8 the Army of Republika Srpska was that paramilitary units should be
9 absolutely subordinated to the units of the VRS army, not just formally.
10 Unfortunately, the process was very long and hard and despite the
11 requests and demands of the political and military leaderships, some
12 units that were subordinated to the VRS still acted as paramilitary
13 formations and they were very hard to control and command.
14 The last known presence of a paramilitary formation that I am
15 aware of within the VRS was in 1995. I believe that it was in the month
16 of October 1995. I'm talking about Arkan's unit. The commander of the
17 Main Staff, General Mladic, approached the president of Republika Srpska
18 and gave him an ultimatum with regard to that unit, asking him that that
19 unit should be removed from the territory of Republika Srpska, and that
20 eventually happened.
21 JUDGE FLUEGGE: May I put one question to the witness.
22 When did the commander, General Mladic, approach the president?
23 When did that take place?
24 THE WITNESS: [Interpretation] When that paramilitary unit arrived
25 in the western part of Republika Srpska. As far as I can remember, I
1 believe that it was in the month of October 1995.
2 JUDGE FLUEGGE: Thank you.
3 MR. LUKIC: [Interpretation]
4 Q. Where were you in October 1995?
5 A. I was in Banja Luka at the forward command post of the
6 Main Staff.
7 Q. I would like to ask you about the relationship with the civilian
8 authorities. Did the military co-operate with the civilian authorities
9 in Republika Srpska?
10 A. The military did co-operate with the civilian authorities. The
11 quality of that co-operation ranged and it varied. Let me say that we
12 co-operated with the local bodies of authority and economic entities,
13 that co-operation with the brigade level. We co-operated with the
14 regional authorities and economic structures, that co-operation was
15 exercised by corps commands. And then at the level of the Main Staff,
16 there was co-operation with the bodies of authority at the level of
17 Republika Srpska, of course.
18 Of course, there was no co-operation with the Supreme Command,
19 who was the Supreme Commander, the military carried out his orders. But
20 there was co-operation with the assembly, with the government, with
21 commissions for refugees and displaced persons, with the Ministry of the
22 Interior, the Ministry for Religious Affairs, and all the other important
23 organs of authorities that were of some significance for the functioning
24 of defence and the military. That co-operation most commonly concerned
25 the provision of bare necessities for the military, their families, and
1 the families of fallen soldiers.
2 The co-operation varied from one body to another. Among those
3 who co-operated with the civilian authorities was also the Department for
4 Information. That co-operation oscillated with time and it varied from
5 one body to the other, so there were periods when there was very good
6 co-operation with some bodies and then there was a lull in that
7 co-operation or even a tension between those bodies.
8 Q. Were there any conflicts with any of the civilian authorities,
9 especially when it came to the financial situation of the military?
10 A. Yes, there were conflicts. One of the issues at stake was the
11 concept of organising the military.
12 Q. What organ are you talking about, first of all.
13 A. The Ministry of Defence because the Ministry of Defence was in
14 charge of providing finances for the military. The Ministry of Defence
15 advocated a different way of organising the military. According to them,
16 they wanted the logistics sector, the sector for organisation, personnel,
17 and mobilisation, and the sector for morale guidance, religious affairs,
18 and legal affairs to be parts of the Ministry of Defence, whereas the
19 Main Staff would only have a commander and his staff. Also, there were
20 conflicts with the Ministry of Information. There was also a period
21 when -- or, rather, several periods when there were conflicts and
22 tensions with the Supreme Commander, himself, i.e., the president of the
24 MR. LUKIC: [Interpretation] Let's have a look at 1D5415.
25 We'll check if we have a translation. It doesn't seem to have
1 been uploaded.
2 Q. Let me tell you what the document is about. It was issued by the
3 Main Staff of the VRS on the 26th January, 1994. It was faxed, and the
4 signature block contains the name of Colonel Savo Sokanovic.
5 Do you remember this document, Mr. Sokanovic?
6 A. Yes, I do.
7 Q. Under paragraph 1, it says --
8 JUDGE ORIE: Could we inquire whether any translation does exist?
9 Is the Prosecution aware of -- Mr. Lukic, this is now the third document
10 without a translation.
11 Yes, Mr. Traldi.
12 MR. TRALDI: I was just going to say no, we're not, and that we'd
13 checked when we got the Defence's list whether we had translations for
14 any of them and provided the ones we had.
15 JUDGE ORIE: Yes. Mr. Lukic, it cripples the Chamber, more or
16 less, if we can't have a look at the document in its entirety and if you
17 just read portions, and since this is now the third time today --
18 MR. LUKIC: I can -- since this is short document, if you want
19 me, I can read the whole document.
20 JUDGE ORIE: It takes more time, even. That's -- but let's -- if
21 you first put your questions to the witness, then we'll ...
22 MR. LUKIC: [Interpretation]
23 Q. Mr. Sokanovic, the first thing that we can read in this document,
24 apart from a list of addressees, including all the corps, as well as the
25 air force and anti-aircraft defence, and some other units, it says here:
1 "The government of Republika Srpska issued a decision on
2 centralising all procurement for the VRS in 1994. Contracting
3 procurements of equipment and materiel will be done by the Ministry of
4 Defence. The military needs to express its requirements."
5 In practice, did this decision ever take off the ground?
6 A. No, unfortunately not.
7 Q. Now come that you issued this document?
8 A. This document was drafted after a session of the government of
9 Republika Srpska. Numerous requests came from the VRS from its
10 Main Staff to secure provisions for the military, and the government
11 finally took it upon itself to arrange centralised procurement according
12 to the requirements of the military. In that decision, it also says that
13 requests should be submitted, segregated by the type of materiel and
14 equipment and their quantities.
15 On behalf of this sector, I sent this document to the units
16 asking them to express their requirements and submit them to us so that
17 they might be supplied with what they needed. Obviously, this refers to
18 the requirements of the sector -- not only the sector but the entire
19 organ for moral, guidance, religious and legal affairs across the board,
20 across the military.
21 Q. After that, how did your chain of procurement go? How did you
22 get your supplies after January 1994? Did you continue sticking to your
23 old ways or did the Ministry of Defence change its attitude towards the
24 Army of Republika Srpska?
25 A. Nothing changed. Everything was as it had been before. As for
1 my specific requirements, we did not receive anything. Everything was
2 dealt with to the extent possible through the nations, through gifts from
3 other bodies.
4 Q. This document is just an illustration of what you told us before.
5 MR. LUKIC: [Interpretation] We would like to tender it into
6 evidence to be marked for identification first.
7 JUDGE ORIE: Mr. Registrar.
8 THE REGISTRAR: That will be MFI D1059.
9 JUDGE ORIE: Marked for identification.
10 Next subject, please, Mr. Lukic.
11 MR. LUKIC: Yes.
12 Q. [Interpretation] And let me now ask you something about strategic
13 goals. In your interview with the Prosecutor, you were asked about that.
14 At the end of the war, did you have a very clear picture as to
15 what the borders of Republika Srpska were or were to be?
16 A. No.
17 MR. LUKIC: [Interpretation] I'd like to call up 1D5421.
18 JUDGE ORIE: Mr. Lukic, could you be a bit more precise by what
19 you meant by "at the end of the war"?
20 MR. LUKIC: On the 17th of October, 1995.
21 JUDGE ORIE: Thank you.
22 That's how you understand the question as well, Witness?
23 THE WITNESS: [Interpretation] Yes.
24 JUDGE ORIE: Please proceed.
25 MR. LUKIC: [Interpretation] Unfortunately, we have another
1 document without translation. We requested a translation but we haven't
2 received it yet.
3 This is a document issue by the sector for morale guidance,
4 religious, and legal affairs.
5 JUDGE ORIE: Mr. Lukic, when did you request a translation?
6 MR. LUKIC: I have to check with my Case Manager. Probably not a
7 long time ago.
8 JUDGE ORIE: Yes, because if it was this morning or yesterday,
9 then, of course, that sheds some light on level of preparation.
10 MR. LUKIC: It sheds lights more on our --
11 JUDGE ORIE: No further comments, Mr. Lukic. I know that --
12 MR. LUKIC: But if you comment on our work, we should probably
13 have the right to respond.
14 JUDGE ORIE: Well, you're not in the same position as the Bench
15 is. Let that be clear.
16 Please proceed.
17 MR. LUKIC: Thank you.
18 Q. [Interpretation] Do you know, Mr. Sokanovic, how and why this
19 document was created?
20 A. Yes. This document was created after a session of the
21 National Assembly of Republika Srpska held in October 1995 after the fall
22 of 30 municipalities in the western part of Republika Srpska and three
23 municipalities in the area of Ozren.
24 JUDGE ORIE: Mr. Traldi.
25 MR. TRALDI: We - which I assume everyone understands not to mean
1 me but Ms. Stewart - appear to have found a translation under a different
2 ERN which we're going to pull up in Sanction.
3 JUDGE ORIE: Yes. We'd like to have a look at it.
4 Please proceed, Mr. Lukic.
5 MR. LUKIC: [Interpretation]
6 Q. This document was shown to you by the Prosecution during your
7 interview, if my notes are correct.
8 MR. LUKIC: [Interpretation] But we need page 2.
9 [Trial Chamber confers]
10 MR. LUKIC: [Interpretation] In B/C/S.
11 Q. Halfway through the page, we see:
12 "The political leadership and the National Assembly have still
13 not, to this day, determined the borders of Republika Srpska that the
14 military are supposed to reach or to defend. Quite to the contrary.
15 Most frequent discussions were about percentages and ceding territory."
16 Who drafted this document, if you can remember, Mr. Sokanovic?
17 MR. LUKIC: We can have maybe might try have English translation
18 so you can --
19 JUDGE ORIE: Yes, if it's in Sanction, it may cause some
20 problems, but I don't know.
21 MR. LUKIC: No, I read everything I wanted from the B/C/S
22 version, so we can have this section. It's last quarter of the document.
23 JUDGE ORIE: If we could have the document on our screen through
24 Sanction in English.
25 JUDGE FLUEGGE: We have it.
1 JUDGE ORIE: We have it, yes.
2 MR. LUKIC: Should start with: "... political leadership... "
3 Q. [Interpretation] We see you are on the signature line.
4 MR. LUKIC: We have to go back, if you don't mind. Go back
5 slowly. A bit further. A bit more. Yeah. A bit more. I didn't have
6 this document, so I really couldn't locate where -- should be:
7 "... the political leadership and assembly ..."
8 A bit further up, please. Bit more. That's it, in the middle of
9 the page. Thank you.
10 "To this day, the political leadership and the National Assembly
11 have not determined the borders of the RS which the army is supposed to
12 defend or reach."
13 Q. [Interpretation] On the 17th of October, 1995, when this document
14 was created -- in fact, from the 14th to the 16th October, when the 54th
15 Session of the National Assembly of Republika Srpska took place, combat
16 had already been terminated and there was no more fighting until the
17 signing of the Dayton Accords. Had you asked is the assembly or the
18 government or the president before to tell you the objective of your
19 fighting, all of it in the light of the strategic objectives that were
20 put to you during the interview; can you remember?
21 A. Yes, I remember. I was asked about that during the interview and
22 I said then that I personally, and many other people with whom I
23 discussed it, did not know clearly defined objectives of the Army of
24 Republika Srpska, and this gave rise to several letters addressed first
25 to the Ministry of Defence, or the government, or the president of the
1 republic - I can't remember anymore all the people to whom we wrote -
2 asking that our goals be defined. Because all the time, as far as I know
3 and the way I saw it, the objective we had in our head was to protect the
4 population, to defend the territory, to restore peace that would be
5 lasting and fair. That was the objective we had in our minds and the
6 objective we pursued.
7 Q. Earlier today you gave us one example that, in your view,
8 reflects that there were no objectives of the war, and you were talking
9 about a village belonging to the other ethnic group situated very close
10 to the Main Staff headquarters. Can you tell us the name of that village
11 or those villages?
12 A. Yes, it's Krivace Plane, Potplanje, Podzeplje. All of these
13 villages were very close to the Main Staff.
14 JUDGE ORIE: Mr. Traldi, you were on your feet.
15 MR. TRALDI: I don't recall the witness -- actually, if the
16 witness could take off his head phones for a moment assuming --
17 JUDGE ORIE: Do you speak or understand the English language,
18 Witness? Could you take off your earphones for a second.
19 THE WITNESS: [Interpretation] Just a few words.
20 MR. TRALDI: I didn't re-call the witness's testimony -- I
21 recalled the witness mentioning the example. I didn't recall his
22 testimony, that this example reflected that there were no objectives of
23 the war, and so I was wondering if Mr. Lukic could provide an explanation
24 of -- or a reference.
25 JUDGE ORIE: Mr. Lukic, there was a spontaneous observation by
1 the witness about protecting civilians in a nearby village, but
2 Mr. Traldi is now asking about whether -- how to link that to the
3 objectives of the war in the absence of such objectives.
4 MR. LUKIC: It's not on the record, it's still in my head. Maybe
5 I jumped ahead because I know I spoke with this witness --
6 JUDGE ORIE: Please proceed --
7 MR. LUKIC: -- and he mentioned that in this sense.
8 JUDGE ORIE: Well, not as far as we could hear, but please move
10 MR. LUKIC: Thank you.
11 JUDGE ORIE: Mr. Mladic is speaking too loud -- too loudly and
12 should refrain from doing that.
13 Please proceed, Mr. Lukic.
14 MR. LUKIC: I just want to inform my colleague that I'm closing
15 to an end in a couple of minutes.
16 Q. [Interpretation] Mr. Sokanovic, these villages you've just
17 mentioned, were they armed?
18 A. There were armed people there. They had armed units. I don't
19 think every resident had a weapon.
20 Q. Did you know they were armed?
21 A. We knew because on two occasions they had launched combat actions
22 against members of the staff and staff units. In one incident, one
23 person was killed, and in the other action, I believe 14 members of the
24 VRS were captured.
25 Q. Was it clear at that moment what should be done?
1 A. In that situation, the Army of Republika Srpska did not take any
2 armed action. Instead, we tried to find a way towards peaceful
4 Q. What part did you play in that?
5 A. I worked on drafting a leaflet, a flyer with a proclamation that
6 was to be addressed to the residents of these villages, saying that we
7 should continue living peacefully side by side, that they should respect
8 the authorities of Republika Srpska.
9 [Trial Chamber confers]
10 MR. LUKIC: I would offer this document into evidence to be MFI'd
11 until the translation is verified, probably.
12 [Prosecution counsel confer]
13 [Trial Chamber confers]
14 JUDGE ORIE: Mr. Mladic, we saw thumbs up which you should
15 refrain from doing. We heard again loud speaking. This is the last
16 warning. The slightest contravention of what you are supposed to do will
17 now immediately result in removal from the courtroom. Let that be clear.
18 Please proceed, Mr. Lukic.
19 MR. LUKIC: Thank you.
20 JUDGE ORIE: Mr. Traldi, you were on your feet. I don't know.
21 MR. TRALDI: Simply to say that we have no objection, and
22 Ms. Stewart has provided the Defence's Case Manager with the translation,
23 so I imagine it'll be uploaded and released shortly.
24 MR. LUKIC: Thank you.
25 JUDGE ORIE: Please proceed.
1 You have tendered the document when I intervened.
2 MR. LUKIC: Yes, it's 1D -- or is it under different 65 ter --
3 no. It's 1D05421.
4 JUDGE ORIE: Mr. Registrar.
5 THE REGISTRAR: That will be MFI D1060, Your Honours.
6 JUDGE ORIE: And is ...
7 [Trial Chamber confers]
8 JUDGE ORIE: Until we have the new translation attached to this
9 one, we'll wait for a second to have it admitted and have it marked for
10 identification until this administrative matter has been resolved.
11 Please proceed.
12 MR. LUKIC: Thank you, Your Honour.
13 Q. [Interpretation] I'll ask you now briefly about your personal
14 losses during the war. Did you lose anyone in the war in
15 Bosnia-Herzegovina between 1992 and 1995?
16 A. Unfortunately, yes.
17 Q. Who did you lose?
18 A. My father.
19 Q. How did your father die?
20 A. An armed unit of the so-called BH Army raided his unprotected
21 village, torched the houses, looted the property, and killed those who
22 had not managed to get away quickly enough. My father was an elderly
23 man, ill. He didn't even have time to leave his house. He was torched
24 together with the house.
25 And I also lost another eight relatives, including two who had
1 lived in Sarajevo and were identified rather late, in 2000-and-some year.
2 They were identified at a location in Sarajevo.
3 THE INTERPRETER: Microphone, please.
4 MR. LUKIC: [Interpretation]
5 Q. Tell us exactly which location it was where they were exhumed.
6 A. Kazani.
7 Q. General Sokanovic, thank you. This is all that we had for you at
8 the moment. Thank you for answering our questions.
9 A. Welcome.
10 JUDGE ORIE: Thank you, Mr. Lukic.
11 Mr. Sokanovic, you'll now be cross-examined by Mr. Traldi.
12 You'll find Mr. Traldi to your right. Mr. Traldi is counsel for the
14 Mr. Traldi.
15 Cross-examination by Mr. Traldi:
16 Q. Good afternoon, sir.
17 A. Good afternoon.
18 Q. Now, Mr. Lukic mentioned your interview with the Office of the
19 Prosecutor during direct examination. That was in 2004. Can I take it
20 that your position is that you told the truth in that interview?
21 A. Yes, yes. It was a long interview, and communication wasn't very
23 Q. But your position is you told the truth; yes?
24 A. Yes.
25 Q. I want to briefly follow up on a couple of the topics that were
1 discussed on direct examination.
2 First, you mentioned that a state of war was not declared for the
3 entire Republika Srpska. You're aware that a state of imminent threat of
4 war had been declared beginning in April 1992; correct?
5 A. I don't know about that. At least I can't recall that at this
6 moment. But the state of war was proclaimed towards the end of 1995.
7 Q. Do you recall the Law on All People's Defence, the ONO?
8 A. I remember the Law on All People's Defence of the Socialist
9 Federal Republic of Yugoslavia.
10 Q. Do you recall that under the law that one of the consequences of
11 a declaration of a state of imminent threat of war is a general
13 A. I am not disputing that, but the Socialist Federal Republic of
14 Yugoslavia no longer existed.
15 Q. Well, a general mobilisation was declared in Republika Srpska,
16 for instance, by President Karadzic on the 20th of May, 1992; right?
17 A. If I remember well, an approximate date -- on that approximate
18 date, the president of the republic issued the decision on the
19 organisation and establishment of the Army of Republika Srpska and
20 required the Main Staff to make a draft of that decision. So I suppose
21 one of the things written there was that the units should be manned and
22 they couldn't be manned without mobilisation. But the state of war was
23 not declared.
24 Q. Do you recall that under the ONO, one of the consequences of that
25 general mobilisation was the transfer of the military to a wartime
2 A. I don't recall that and it doesn't sound logical, because if
3 there's a state of war, then the army should be operating under wartime
4 rules, and the state should be operating under wartime laws.
5 Q. So you don't re-call Article 8 of the ONO clarifies that the
6 armed forces and other state and other organs transfer from a peacetime
7 form of organisation to a wartime form of organisation when mobilisation
8 is introduced. Your testimony today is you don't remember that?
9 A. I don't remember that, but I maintain that mobilisation in and of
10 itself still does not mean a state of war. Because peacetime laws
11 continue to be in force.
12 Q. Now, you weren't -- I have been asking about mobilisation. You
13 weren't involved yourself in mobilisation or manning of the army; right?
14 A. No, nor was I in the Army of Republika Srpska on that date in
15 May. And even later, that is not within the competencies of the sector
16 for morale, religious, and legal affairs.
17 Q. You are familiar, however, with the combat readiness report that
18 the army did, the VRS did in 1993; right?
19 A. You mean analysis?
20 Q. Of combat readiness for the VRS, yes.
21 A. Yes. Not in detail but I know about it.
22 Q. Would your sector have worked on the sections of the report
23 dealing with, for instance, morale?
24 A. I suppose so. That would be logical.
25 Q. And this is an authoritative document; yes?
1 A. I don't know what to answer. I cannot assess its weight. It
2 certainly has some weight.
3 Q. Well, your sector and the other Main Staff sectors worked on
4 analyses relevant to your own areas of work; right?
5 A. I suppose so. And if we worked, because this is an analysis of
6 the combat readiness of the army, we also gathered information from
8 Q. And you gathered information from the corps, the corps gathered
9 information from the brigades; right?
10 A. That's how it should be.
11 Q. And this both reflected what the army had been doing and helped
12 guide next steps; right?
13 A. As far as I remember, from theory, each analysis should involve
14 dealing with one particular issue and end in a conclusion and a proposal
15 of measures.
16 Q. Now, you wouldn't have worked on the section dealing with
17 mobilisation and manning because that wasn't part of your responsibility;
19 A. Generally speaking, we did not deal with that. But if it touched
20 upon morale, it could have been mentioned as one of the factors impacting
21 on the morale of the troops.
22 Q. Well, but the mobilisation and manning sections would have been
23 dealt with by the relevant Main Staff sector, not by your sector or your
24 section; right?
25 A. Yes, it was the responsibility of the sector for organisation,
1 mobilisation, and personnel, but the issue could also be treated in the
2 part of the analysis that dealt with morale, religious, and legal
3 affairs. It could be included there as an element that had a positive or
4 adverse effect on the morale of the troops, on logistic, et cetera.
5 Q. Well, since it could have an impact on morale, then you're surely
6 aware that in the combat readiness report, the sector for organisation,
7 mobilisation, and personal noted that three VRS corps - the SRK [Realtime
8 transcript read in error "RSK"], the 1st Krajina Corps, and the
9 Drina Corps - were actually manned above 100 per cent of the set manning
10 levels; right?
11 JUDGE MOLOTO: Mr. Traldi, did you say RSK or SRK? You are
12 recorded as RSK.
13 MR. TRALDI: Thank you, Your Honour. It's an important
14 distinction and I did say SRK, I think. I certainly meant to.
15 JUDGE MOLOTO: Absolutely.
16 MR. TRALDI:
17 Q. Would it be useful if I repeated the question, sir?
18 A. No, I don't think that's necessary. Certainly, all the elements
19 were considered in some way to the extent needed. Whether that was taken
20 into account at the time or not, I can't say. But I'm not challenging
21 the facts you are putting to me or what is written there, but the quality
22 of manning these corps and the entire army is very important.
23 If you just allow me to say this --
24 Q. Sir --
25 A. Whether, for instance, we had enough officers and
1 non-commissioned officers --
2 Q. I understand. What I'm asking you is, yes or no, whether you
3 recall that as of the promulgation by the combat readiness report in the
4 1993, the three corps I mentioned - the Drina Corps, the
5 Sarajevo-Romanija Corps, and the 1st Krajina Corps - were all manned in
6 terms of number of personnel at above 100 per cent of establishment
7 levels. Do you recall that? Yes or no?
8 A. No, I can't remember.
9 Q. Do you recall how establishment levels were set?
10 A. For the entire military? Mr. Prosecutor, do you mean the entire
12 Q. I mean do you recall how or who was responsible for determining
13 what the establishment level of a particular brigade or a particular
14 corps was.
15 A. Mr. Prosecutor, that was established by the organs for
16 organisation, mobilisation, and personnel affairs in consultation with
17 organs at lower levels and in keeping with the prevalent rules.
18 Q. Now, just quickly before we go to the break, you mentioned on
19 direct that the corps commands and the air force command would include
20 reports on morale in their daily combat reports. The commander of the
21 Main Staff as well as the assistants to the commander had to be familiar
22 with those daily combat reports; right?
23 A. I said that in regular combat reports at those levels of command,
24 there was a paragraph referring to combat morale and situation on the
25 front line. This doesn't mean that all assistant commanders were
1 familiar with those reports. If all of them were present, which was
2 rare, I can't rule out the fact that they may have been informed.
3 However, it would be the chief of sector for morale, religious,
4 and personnel affairs or legal affairs who would be best suited to learn
5 about that particular paragraph in combat reports.
6 JUDGE ORIE: Mr. Traldi, you said before we go to the break.
7 That was three minutes ago.
8 MR. TRALDI: And I see we're now at the time, Mr. President.
9 JUDGE ORIE: We take the break.
10 Witness, you may follow the usher. We'd like to see you back in
11 20 minutes.
12 [The witness stands down]
13 JUDGE ORIE: We resume at 25 minutes to 2.00.
14 --- Recess taken at 1.15 p.m.
15 --- On resuming at 1.36 p.m.
16 JUDGE ORIE: Mr. Traldi.
17 MR. TRALDI: Just if I might use the time, if we could pull up 65
18 ter 07988.
19 [The witness takes the stand]
20 JUDGE ORIE: You may proceed, Mr. Traldi.
21 MR. TRALDI: Thank you, Mr. President.
22 Q. Sir, this is the 1st Krajina Corps' report dated the 30th of
23 September, 1992, on current issues of combat morale. This is a document
24 that, based on your position at the time, you would have reviewed
25 personally; right?
1 A. I was still not the chief of department for moral guidance and
2 religious affairs. Dosen Zivko was still in that position. This doesn't
3 mean that I did not review the document, but I would need some time to
4 look at it.
5 Q. Well, let's look at page 2 for the moment in both languages, and
6 I'm interested in the second paragraph in both languages.
7 The 1st Krajina Corps is writing about UNPROFOR, the Red Cross,
8 and then in the second paragraph refers to certain journalists who they
9 suggest are writing more and more objectively and portraying the real
10 state of affairs and give a certain confidence and belief in their good
11 intentions. They say:
12 "Soldiers and units have accepted with trust only the Russian
13 delegation and the most recent articles in the Russian press."
14 Now, it's clear that the 1st Krajina Corps' organ for legal,
15 moral, and religious affairs was able to keep track of what was going on
16 in the international press; right?
17 A. I suppose so because they were in a big city, and it was the
18 strongest information department with a well-developed press centre.
19 Q. In fact, as one of the officers in that department, Milos Solaja
20 testified they had an analytical group for monitoring international
21 media; right?
22 A. Quite possible yes.
23 Q. Now, you told Mr. Lukic on direct examination that you weren't
24 able to keep track of what going on in the international press. In fact,
25 the Main Staff could simply have asked one of its subordinate corps;
2 A. Hmm, they could but they did not.
3 Q. Well, among other things, they were receiving information in
4 these morale reports on what the international press was saying, weren't
5 they? Like we see here.
6 A. Those were just sporadic examples.
7 Q. And when international media coverage was published either on
8 Bosnian Serb television, or the Bosnian Serb press, the press in the
9 Republic of Serbia, or the press in Croatia, or in Bosnian territory, the
10 Main Staff's sector for legal, moral, and religious affairs would track
11 it through its monitoring of those sources of media; right?
12 A. I've already told you that neither the sector nor the information
13 department that were in charge of this had no technical capabilities for
14 direct monitoring. They also couldn't read foreign press. The only
15 newspapers that they could read were those from Republika Srpska and
16 Serbia. They knew as much as they could hear or read in the domestic
18 Q. Now, in fact, your -- the instruction you drafted that
19 General Mladic signed that Mr. Lukic showed you on direct - and for the
20 record, that's P5082 - that talks about monitoring enemy media, doesn't
22 A. Yes, but the instruction was drafted in 1995.
23 Q. Now, when you were asked about it in your interview, you said
24 this department had a duty to -- first to watch Muslim and Croat TV
25 stations so that -- to see what kind of information they are
1 broadcasting. Do you stand by that today?
2 A. I stand by that, with a caveat: I don't recall having mentioned
3 Croatian media, but I'm not excluding that. I don't remember having
4 mentioned TV situations but, rather, radio stations. We could not
5 receive any television signals that didn't emanate from Republika Srpska.
6 JUDGE ORIE: Is it -- is it well understood yet in your interview
7 you did not mention TV and only radio?
8 THE WITNESS: [Interpretation] As far as I can remember, that's
9 correct. They could monitor radio and television programmes of
10 Republika Srpska and those of Bosnia and Herzegovina.
11 JUDGE ORIE: Yes. You said they could monitor radio and
12 television programmes. And a minute ago, you said:
13 "We could not receive any television signals that didn't emanate
14 from Republika Srpska."
15 So you're excluding Croatian television; is that correct?
16 THE WITNESS: [Interpretation] As far as I can remember, and based
17 on what I can remember, I would exclude that, yes.
18 JUDGE ORIE: Yes. Mr. Traldi, I don't know whether -- I take it
19 that there's a verbatim transcript of the interview?
20 MR. TRALDI: There is, Mr. President.
21 JUDGE ORIE: And there is an audio recording?
22 MR. TRALDI: There is.
23 JUDGE ORIE: Yes. Could you please read to the witness then what
24 he said if you did not yet intend to do that.
25 Witness, we have an audio recording -- well, the Chamber not yet,
1 but there is an audio recording of your interview. So therefore, if you
2 are telling us that the transcript is not accurate - and Mr. Traldi will
3 put it to you most likely - then we'll just check it on the basis of the
4 audio to find out whether you said -- referred to television in that
5 context or not.
6 Mr. Traldi.
7 MR. TRALDI: If we could have 65 ter 32563. And we'll be looking
8 for ...
9 [Prosecution counsel confer]
10 MR. TRALDI: While it comes up, if I might tender the last
11 document, just so I don't forget.
12 JUDGE ORIE: Mr. Registrar.
13 THE REGISTRAR: 65 ter 07988 will be Exhibit P7390, Your Honours.
14 JUDGE ORIE: P7390 is admitted.
15 MR. TRALDI: And if we could have page 44 in the English and 55
16 in the B/C/S.
17 And, I'm sorry, I'm seeing a different page in the B/C/S than I'd
18 expected. If we could have e-court page 55.
19 JUDGE ORIE: That's the English? And for B/C/S -- it comes in
20 the reversed sequence. Usually we have the B/C/S at the left and ... I
21 do not mind, but ...
22 MR. TRALDI: I am afraid I do, as we're not -- we now don't have
23 the right page. If we could have 44 in the English and 55 in the B/C/S.
24 And the English, it will be listed as the original.
25 JUDGE ORIE: Now we have two times the English version.
1 MR. TRALDI:
2 Q. Now, we see starting at the bottom of the English --
3 JUDGE ORIE: Yes, but we don't have the right page in B/C/S yet.
4 MR. TRALDI: I apologise. And if we could go back, I think, a
5 single page.
6 JUDGE ORIE: Okay.
7 MR. TRALDI: That's not --
8 JUDGE ORIE: Could we have -- I don't know whether the page
9 numbering at the bottom corresponds with the page numbers. It seems at
10 least in the English that it does, but it looks as if we are on page 14
11 now on the B/C/S, which is difficult to understand as corresponding with
12 page 55 unless there are more documents.
13 MR. TRALDI: My understanding is the B/C/S pages are numbered by
14 the tape, whereas the English is numbered as a whole. And we can see on
15 the English we're looking for the start of T000-2724A. And it appears to
16 me the start of that is on page 55 in the B/C/S.
17 Now, we see at the very bottom of the English that the
18 interviewer refers to a paragraph in the document dealing with the
19 monitoring of enemy media, and if we could then turn to the next page in
20 both languages. Now, we have -- sorry. If we could go back to the
21 bottom of the previous page in the B/C/S. I'd skipped an important
23 Q. We see you describe, beginning at line 20, the duty of the
24 information department regarding the monitoring of enemy media. Is it
25 clear to you from what's written there that this included monitoring
1 Muslim and Croat television, based on your answer in your interview?
2 JUDGE MOLOTO: Where do we see this in the English?
3 JUDGE FLUEGGE: Line 2.
4 MR. LUKIC: There is clear -- if the witness can take off his
6 JUDGE ORIE: Could you please take off your headphones for a
8 MR. LUKIC: This is clear translation issue. It says "stations."
9 In English we have TV stations.
10 JUDGE ORIE: Let's -- what exactly are we talking about? Lines.
11 MR. LUKIC: Line 20 --
12 JUDGE ORIE: Line 20.
13 MR. LUKIC: -- in B/C/S. Line 2 in English. And then in line 23
14 in B/C/S, it says what is not TV. In English we have TV added.
15 JUDGE ORIE: Let's have a look.
16 [Trial Chamber confers]
17 JUDGE ORIE: Could perhaps the witness --
18 MR. LUKIC: To read --
19 JUDGE ORIE: Yes. Witness, Witness, could you put on your
20 earphones again.
21 Could you slowly read what is recorded here as -- on line 20, can
22 you read that? Where it starts with: "Ovi organi..."
23 Could you slowly read that?
24 THE WITNESS: [Interpretation] "These organs therefore monitor the
25 media of the enemy, the opponent, and our own information about the enemy
1 published in the media. Namely this organ, i.e., the department that was
2 in charge to the extent possible, monitor Muslim and Croatian stations
3 and to listen to what they publish and to monitor stations of
4 Republika Srpska and to see what they publish."
5 JUDGE ORIE: Yes, now I heard the witness read quite a bit in the
6 beginning of what something that doesn't appear at all in the English.
7 Or am I wrong? It's certainly not the same -- well, I think it is --
8 what then follows seems to be more or less the same, that is, about radio
9 and newspapers and then the confirmation by the witness, yes --
10 MR. LUKIC: And in Serbian it's "listen" in English it says
12 JUDGE ORIE: Yes.
13 MR. LUKIC: So --
14 JUDGE ORIE: Then this portion certainly needs --
15 Witness, you will understand that we carefully look at what your
16 statement is and --
17 Mr. Traldi, it may be that you move on for the time being and
18 that you have it reviewed so that we can be certain that what is put to
19 the witness is really what he said.
20 MR. TRALDI: We'll certainly do that, Mr. President.
21 JUDGE ORIE: Then please proceed for the time being.
22 JUDGE MOLOTO: Before you do, Mr. Traldi. Did I hear you correct
23 that you said the English is the original?
24 MR. TRALDI: Yes, and it -- well, it's been uploaded as the
25 original but it's based on an audio recorded interview where the witness
1 would have been speaking in Serbian --
2 JUDGE MOLOTO: Okay. So it's actually in terms of the audio
3 Serbian is the original.
4 MR. TRALDI: Yes. And the audio is what we'll check against.
5 JUDGE MOLOTO: Thank you.
6 JUDGE ORIE: But here a technique is used in which one portion is
7 in the one language and -- one version is the one language, the other one
8 in the other language, whereas sometimes we have a different technique
9 being used for recording; that is, that always the switch from one
10 language to the other can be followed on the one and only transcript.
11 Here, apparently, work has been done on it, and I take it that we would
12 consider whatever is spoken in English in that respect as original, and
13 whatever is spoken in B/C/S, that in that respect it is original.
14 That's how I understand the technique being used here. So if you
15 verify it, then it should be done on the basis of the audio checking
16 whether B/C/S-spoken words appear right in the B/C/S. And then later, of
17 course, the translations become relevant as well.
18 MR. TRALDI: Yes, Mr. President.
19 JUDGE ORIE: You have a bit to do or to be done.
20 MR. TRALDI: We'll try to handle it, thank you.
21 JUDGE ORIE: Please proceed.
22 MR. TRALDI:
23 Q. Sir, I'm going to turn to a different topic.
24 One of the things that your Main Staff sector did was publish a
25 magazine called Srpska Vojska; right?
1 A. Yes.
2 MR. TRALDI: Can we have 65 ter 02362.
3 JUDGE FLUEGGE: Could you repeat the number, please.
4 MR. TRALDI: 02362. And in line 10 I think I'd said they
5 published the magazine.
6 Q. Now, this is the transcript of the 22nd Session of the
7 Republika Srpska Assembly held on the 23rd and 24th of November, 1992.
8 This is around the time Srpska Vojska was created; right?
9 A. Yes.
10 Q. And, in fact, you and General Gvero went to the assembly to
11 attend a promotion for the first issue; right?
12 A. Probably. Although I don't remember.
13 MR. TRALDI: If we could have page 29 in the English and page 28
14 in the B/C/S.
15 Q. We see a reference to the promotion of the magazine. We read a
16 reference to Minister Ostojic speaking. He was the minister for
17 information in the RS government at the time; right?
18 A. Yes.
19 Q. Now he says in pertinent part beginning in the fourth line and in
20 reference to Srpska Vojska:
21 "The very name and emblem of the magazine, which is issued by the
22 editorial office of the Main Staff of the Serbian army, shows that the
23 news network ... of the Serbian people is developing in the direction
24 determined by the SDS, and carried out and channelled by the National
25 Assembly and its executive organs."
1 He's describing here the role and function of Srpska Vojska;
3 A. Yes, he, indeed, describes that.
4 Q. Now below that - and turning to the next page in the B/C/S - we
5 see your superior, General Gvero speak. And in the second paragraph of
6 his remarks, he says, in pertinent part, that Srpska Vojska has a small
7 editorial board and "it is my pleasure to present to you
8 Lieutenant-Colonel Savo Sokanovic, a young editor and a local man."
9 Now this is a reference to you; correct?
10 A. Yes. Although I haven't found it in the text, but I believe what
11 you say.
12 Q. Well, in the B/C/S version, it's under General Gvero's name, in
13 the second full paragraph, the fifth line on the far right. Do you see
14 it? I see you've nodded but you have to articulate your answer for the
16 A. I found it. Thank you. I apologise.
17 Q. And the Second-Lieutenant Djurdjevic he refers, who he says is
18 the editor, that's also an officer in the Main Staff's sector for legal,
19 morale, and religious affairs; correct?
20 A. Yes, at that time he was head of the section for information.
21 MR. TRALDI: Your Honours, P7196 consists of an excerpt from this
22 assembly session. What I'd request leave to do is simply add these pages
23 in both languages to that exhibit.
24 JUDGE MOLOTO: P what?
25 MR. TRALDI: 7196.
1 JUDGE MOLOTO: Thank you.
2 JUDGE ORIE: Mr. Lukic, if there's anything for contextualisation
3 you would like to add, I take it that you'll inform Mr. Traldi without
4 delay. We'll wait and see how the extract is changed and then an
5 instruction will be given to Mr. Registrar once you have uploaded the new
7 Please proceed.
8 MR. TRALDI: Now can we have 65 ter 19225.
9 Q. What we see here is the first issue of Srpska Vojska dated the
10 18th of November, 1992.
11 Now turning to page 2 in both languages, we see an editorial by
12 General Gvero titled: "The Voice of Serbian Dignity and Chivalry."
13 Turning to page 3 in the middle in the English and towards the
14 bottom of the page in the B/C/S, the eighth paragraph, so the third
15 paragraph from the bottom, we see that he writes in pertinent part:
16 "Our greatest value is the unity of the political and military
17 leadership at all levels of the state, the unity of the people and the
18 army, and a willingness to fight for victory."
19 General Gvero is setting out the state of co-operation between
20 the VRS and the political authorities at that time; correct?
21 A. Mr. Prosecutor, this is a feature from this magazine from the
22 very beginning of the war in Bosnia-Herzegovina, and his message is, if I
23 have the right to interpret someone else's words at all, is what our
24 greatest value is, and I personally don't see anything wrong with it.
25 Unity of the political --
1 Q. Sir --
2 JUDGE ORIE: Witness --
3 THE WITNESS: [Interpretation] -- leadership, the army, and the
4 people --
5 JUDGE ORIE: -- no one is claiming that there is anything wrong
6 in it. Mr. Traldi just seeks your confirmation of this being an
7 expression of the co-operation between the civilian structures and the
8 military structures. You are -- apparently you have something on your
9 mind that you are accused of something, which is not the case. You
10 appear as a witness. So I do understand that you say there's nothing
11 wrong, but it does express as was suggested by Mr. Traldi ...
12 THE WITNESS: [Interpretation] Can I just say briefly one thing?
13 JUDGE ORIE: Well, if it's relevant, as in to the answer, then
14 we'd like to hear it, otherwise ... otherwise not.
15 THE WITNESS: [Interpretation] I just wanted to say that this is
16 the beginning, the early days of the fighting, December 1991.
17 JUDGE ORIE: That's -- that's the reason why Mr. Traldi mentioned
18 the date: November 1990 -- I think it was November 1992 instead of
19 December 1991, is it?
20 MR. TRALDI: It was, Mr. President.
21 JUDGE ORIE: Yes, you're referring to December 1991, Witness, but
22 the document we looked at is the first edition which was published in
23 November 1992. You agree?
24 THE WITNESS: [Interpretation] I agree. I agree.
25 JUDGE ORIE: Please proceed, Mr. Traldi.
1 MR. TRALDI:
2 Q. Sir, just so the record is clear, I take it you agree that
3 General Gvero is there setting out the state of co-operation between the
4 military and civilian authorities as of November 1992; right?
5 A. Well, reading this text it appears to be so, but this can also be
6 interpreted as something that would be desirable. We need this unity.
7 It's our greatest value. That's the message.
8 Q. Now some of the other things we read in this text are references
9 to a 500-year Turkish occupation, reference to forced conversions of
10 Serbs, and a description of the war to that point as a "national
11 liberation war to save and preserve the Serbian people."
12 Past crimes against Serbs and the need to preserve the very
13 existence of the Serbian people by winning the war were ongoing themes in
14 Srpska Vojska's work; correct?
15 A. In our lands, it's very difficult to get a view of anything
16 without looking back to the past. Regrettably so. And unfortunately
17 some of the causes of this conflict lie in the unresolved matters from
19 JUDGE ORIE: But the question was a different one: Whether past
20 crimes against Serbs and the need to preserve the very existence of the
21 Serbian people by winning the war, whether these were ongoing themes in
22 Srpska Vojska's work.
23 Were they or were they not?
24 THE WITNESS: [Interpretation] They were themes, but certainly not
1 MR. TRALDI:
2 Q. Turning briefly to page 4 in the English, page 3 in the B/C/S,
3 and I see the time, so I'm going to ask you just three very focused
4 questions about this article. This is an interview with General Mladic
5 titled: "Our Enemies Have No Chance." He is asked at first about the
6 struggle so far and refers to avoiding what he calls a new 1941. This is
7 also a reference to past crimes against Serbs; correct? Yes or no.
8 A. Yes, yes, there were crimes.
9 Q. Later in his answer at the end of the first column in the B/C/S,
10 we see that he says that:
11 "At all events we should thank all those progressive people and
12 the movement or, rather, the SDS who woke the bulk of the Serbian people
13 and opened their eyes to these stormy events, which undoubtedly saved
14 many of them."
15 This is an illustration of the unity General Gvero was describing
16 between the military and political leadership at that time; correct?
17 A. Yes. And at that time, there were no great differences.
18 Q. Turning to page 7 in the English, page 5 in the B/C/S in the
19 middle, we read General Mladic is asked about differences between the VRS
20 and the JNA, and he says, in pertinent part:
21 "The difference between our army and the JNA is that this is an
22 army with a clear goal before it."
23 At that point, the objectives of the war, the six strategic
24 objectives, were perfectly clear to General Mladic and to the VRS; right?
25 MR. LUKIC: Objection. Is it read to the witness or is
1 General Mladic referencing so those six objectives? Can we find it in
2 the text?
3 JUDGE ORIE: It's -- well, I didn't understand the question to be
4 that it quoted literally General Mladic.
5 Mr. Traldi.
6 MR. TRALDI: That's correct. What I was --
7 JUDGE ORIE: But perhaps you rephrase the question in such a way
8 that Mr. Lukic's concerns are removed.
9 MR. TRALDI:
10 Q. I'll break it up into two very short yes or no questions, sir.
11 General Mladic says:
12 "The difference between our army and the former JNA is that this
13 is an army with a clear goal before it."
14 Now, that reflects that at that point General Mladic and the VRS
15 were clear about the goals of the war; right?
16 MR. LUKIC: Objection. Calls for speculation. What
17 General Mladic thought at that time, this witness cannot know that.
18 MR. TRALDI: The witness testified he was one of the editors of
19 this publication.
20 MR. LUKIC: Editor? [Indiscernible] everything what somebody
21 thinks or means? Could he project to publish something? It's very
23 JUDGE ORIE: The question was broader than just General Mladic.
24 You as an editor of this publication and as a member of the VRS,
25 do you understand this to be an expression that the objectives of the war
1 were clear for the VRS?
2 THE WITNESS: [Interpretation] The letters are very small. Could
3 you please highlight this passage for me?
4 JUDGE ORIE: Could the relevant portion be enlarged.
5 MR. TRALDI: We are looking for the third column, I believe, in
6 the B/C/S at the top of the page.
7 MR. LUKIC: I think we cannot continue this way today. We should
8 read everything what General Mladic said what the objective is.
9 JUDGE ORIE: You can do so in re-examination. The questions are
10 now focusing on what is published here as an interview, or at least
11 that's how I understand what it is, an interview in this magazine with
12 General Mladic. And if there are good reasons to believe that this is
13 not what he said, you have an opportunity in re-examination, Mr. Lukic,
14 to address that matter.
15 Witness, is it large enough for you now?
16 THE WITNESS: [Interpretation] I can see the text, but I don't see
17 any "goals."
18 MR. LUKIC: First of all, the question was plural. Here we have
19 one goal. So it's misleading as well.
20 JUDGE ORIE: Okay. That's -- have you found where it says
21 what -- that this is an army with a ... let me just see.
22 You read the relevant portion, Mr. Traldi.
23 MR. TRALDI:
24 Q. Now Srpska Vojska quotes General Mladic saying the difference
25 between our army and the former JNA is that this is an army with a clear
1 goal before it. Now, first, you understand that to mean that the purpose
2 of the war was clear at that time, right, yes or no?
3 A. Mr. Prosecutor, he is speaking in the same sense that I mentioned
4 before that it was -- the goal was the protection of the people, the
5 defence of the territory, the restoration of peace --
6 Q. Sir, I hadn't asked you at this stage yet what the goal was.
7 What he is saying -- what you understand him to be saying is that the
8 purpose of the war at that stage is clear. Yes?
9 A. That's what is written here.
10 MR. TRALDI: Your Honours, I see the time. I'll explore the
11 topic further tomorrow. I'd ask that a number be reserved for these
12 three articles from this issue.
13 JUDGE ORIE: Mr. Registrar, could you already reserve a number.
14 THE REGISTRAR: That will be P7391, Your Honours.
15 JUDGE ORIE: Thank you for that.
16 Witness, we'd like to see you back tomorrow at 9.30 in the
17 morning in this same courtroom. But before you leave this courtroom, I'd
18 like to instruct you that you should not speak or communicate in whatever
19 way with whomever about your testimony, irrespective of whether that is
20 testimony you have given today or whether it is testimony still to be
21 given tomorrow.
22 If that is clear to you, you may follow the usher.
23 JUDGE MOLOTO: Mr. Traldi, which three articles are you talking
24 about? Are you talking about the three --
25 MR. TRALDI: I'd -- what I'd meant was, and I spoke, I think,
1 imprecisely, the cover, General Gvero's piece, and then the interview
2 with General Mladic.
3 JUDGE MOLOTO: That's 65 ter 19225.
4 MR. TRALDI: From 19225, yes.
5 JUDGE ORIE: The witness may follow the usher.
6 [The witness stands down]
7 JUDGE ORIE: Mr. Traldi, when you earlier said that you had not
8 asked yet what these goals or that goal would be, you may have forgotten
9 about that you, in page 76, line 4, you said:
10 "At that point the objectives of the war, the six strategic
11 objectives were perfectly clear to General Mladic."
12 So you did clearly refer to what a goal or the goals would have
13 been and therefore it was not fair to the witness to say I didn't ask you
14 that yet.
15 MR. TRALDI: I agree, Mr. President. I'd simply intended to
16 focus the witness on the immediately preceding question and I -- of
17 course, I did so inartfully.
18 JUDGE ORIE: Yes, but he could have been confused and could have
19 thought that you were still thinking in terms of the six strategic goals.
20 We -- with apologies, we were unable to finish on time. We'll
21 adjourn for the day and we resume tomorrow, 19th of May, 9.30 in the
22 morning, in this same courtroom, I.
23 --- Whereupon the hearing adjourned at 2.25 p.m.,
24 to be reconvened on Tuesday, the 19th day of May,
25 2015, at 9.30 a.m.