Tribunal Criminal Tribunal for the Former Yugoslavia

Page 35752

 1                           Tuesday, 19 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

 6     courtroom.

 7             Madam Registrar, could you please call the case.

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

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

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             There is one preliminary but so short that we could already ask

12     the witness to be escorted into the courtroom.  It is about D01060.  The

13     translation which was provided by the Prosecution has now been uploaded

14     by the Defence, and therefore it seems that the English translation was

15     uploaded into e-court under doc ID number 1D19-2264 can be attached to

16     D01060, and D1060 is admitted into evidence.

17             I do understand, Mr. Traldi, that there was still some puzzles in

18     relation to the transcription of the interview of the witness but that

19     you'll further sort that out.

20             MR. TRALDI:  Yes, Mr. President.  I've spoken with Mr. Lukic and

21     we're in agreement as to how to proceed.

22             Just briefly for the Chamber, essentially the transcript is

23     correct as to the original words spoken in both languages, so the English

24     translation was essentially correct for the English -- sorry, the English

25     transcript.  The B/C/S transcript essentially correct for the B/C/S.

Page 35753

 1     We've had it reviewed, and what I intend to do is simply pull up the

 2     relevant page of the reviewed version in B/C/S, ask the witness to read

 3     it for the record, and ask if he confirms it.

 4             JUDGE ORIE:  That seems to be a very practical way of resolving

 5     the matter.  Something apparently has gone wrong then in translation or

 6     the transcription of the translation.

 7                           [The witness takes the stand]

 8             JUDGE ORIE:  Good morning, Mr. Sokanovic.

 9             THE WITNESS: [Interpretation] Good morning.

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

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

12     beginning of your testimony.  And Mr. Traldi will now continue his

13     cross-examination.

14             Please carefully listen to the question and try to answer them as

15     directly as possible.

16             Please proceed.

17             MR. TRALDI:  Could we have 65 ter 32563A, page 55, in the B/C/S

18     only.

19                           WITNESS:  SAVO SOKANOVIC [Resumed]

20                           [Witness answered through interpreter]

21                           Cross-examination by Mr. Traldi: [Continued]

22        Q.   And as it comes up, good morning, sir.

23        A.   Dobro jutro [No interpretation].

24        Q.   Now, this is a portion of the transcript of your interview with

25     the Office of the Prosecutor that we looked at yesterday.  We've had it

Page 35754

 1     reviewed overnight, and what I'm going to ask to you do is simply begin

 2     at line 20, read the reviewed version of your answer slowly into the

 3     record, and then at the end tell us if you confirm the truthfulness and

 4     accuracy of what you've read.  Beginning at line 20 with your initials

 5     and the words "ovi organi."

 6        A.   "These organs were following the media, information media of the

 7     enemy, and our information about the enemy were published by the media.

 8     This organ, or this section, was in charge to the extent possible to

 9     monitor the Muslim/Croat media and to listen -- stations and to listen

10     what they were broadcasting also to listen to the stations in

11     Republika Srpska to see what they were broadcasting."

12        Q.   And do you confirm the truthfulness and accuracy of that answer?

13        A.   Yes.

14        Q.   So the record is clear, the organ or the sector that we're

15     speaking of is the Main Staff's sector for legal, moral, and religious

16     affairs; correct?

17        A.   The discussion here is about the information sector and the text

18     says:  "This organ," in line 3, "This organ, or department, was entrusted

19     to the extent possible," and so on and so forth.

20        Q.   The information section, which staff sector in the Main Staff was

21     that part of?

22        A.   That section was one of the sections in the sector for morale,

23     legal, and religious affairs.

24             MR. TRALDI:  Can we have 65 ter 32646.

25        Q.   Now, these are instructions issued by General Gvero dated the

Page 35755

 1     9th of March, 1993.  Below point 1, on the first page in both languages,

 2     we read about the presentation of what he describes as anti-Serbian

 3     propaganda in other countries.  And turning to page 2 in the English in

 4     the first full paragraph, so the paragraph immediately above the Roman

 5     numeral II, and at the bottom of page 1, and top of page 2 in B/C/S, we

 6     read his evaluation that:

 7             "In other countries every citizen can see this for themselves on

 8     a daily basis on their TV screens or hear it from their radios or read it

 9     in the newspapers and magazines."

10             Now this reflects that General Gvero was aware as of March 1993

11     that foreign media was reporting that serious crimes had been committed

12     by Bosnian Serb forces.  Yes?

13        A.   Mr. Prosecutor, the text in front of me is very illegible.  I

14     didn't manage to find the paragraph that you have just read to me.

15             JUDGE ORIE:  Yes, I had some concerns there as well, Mr. Traldi.

16     Could you, first of all, could we try to have the -- to have it enlarged

17     to the extent possible for the witness.  Even if need be, only the B/C/S

18     on the screen so that it can be further enlarged.  And second, could you

19     then slowly read it again, the portion that you had in your mind.

20             We'll try to make it better legible for you, Witness.

21             MR. TRALDI:

22        Q.   Now can you see at the very top of the page here a reference from

23     General Gvero to the fact that every citizen can see this for themselves

24     on a daily basis on their TV screens or hear it from their radios or read

25     it in their newspapers and magazines; right?

Page 35756

 1        A.   Yes.

 2        Q.   Now, if we could scroll down to the middle of page 2 in the

 3     B/C/S, just to make clear that they are able to read that he's aware of

 4     to read and see and hear.  In the middle of the page as we have it now,

 5     General Gvero refers to specific allegations:  Aggression, ethnic

 6     cleansing, crimes, obstruction of humanitarian aid, and other activities.

 7             As of this point, early March 1993, it's clear that he was aware

 8     that such allegations were being made in the international press; right?

 9        A.   Mr. Prosecutor, I cannot say what General Gvero knew or didn't

10     know.  Specifically it states here that those carrying out an anti-Serb

11     campaign will attempt - attempt - among other things to find arguments in

12     our media, to charge Serbs and their army for ethnic cleansing crimes,

13     interfering with the delivery of humanitarian aid, and so on and so

14     forth.

15             THE INTERPRETER:  We cannot hear the witness very well, the

16     interpreters note.

17             JUDGE ORIE:  Witness, you are speaking away from the microphone.

18     Can the microphone be adjusted.  The usher will assist you.  The

19     interpreters have difficulties in hearing you.

20             Could you resume your answer.  You said:

21             "... among other things to find arguments in our media, to charge

22     Serbs and their army for ethnic cleansing crimes, interfering with the

23     delivery of humanitarian aid, and so on and so forth."

24             Was that the last part of your answer, or did you say anything

25     after that?

Page 35757

 1             THE WITNESS: [Interpretation] No.

 2             MR. TRALDI:

 3        Q.   Now, you said you can't say what General Gvero knew or didn't

 4     know.  At this point, the 9th of March 1993, he was your immediate

 5     superior; right?

 6        A.   Yes.

 7        Q.   How often would you meet?

 8        A.   Sometimes we met on a daily basis, several times, and then at

 9     other times, we wouldn't see each other for a whole month.

10        Q.   His office was about 30 metres away from yours?  Or the building

11     his office was in was about 30 metres away from the building your office

12     was in?

13        A.   Yes, that's right.

14        Q.   And what we're reading about here, information about the war,

15     information about the actions of Bosnian Serb forces in the media, that

16     was part of his job, part of your job, part of the responsibilities of

17     the sector he ran and in which you worked; right?

18             MR. LUKIC:  Objection.  We exactly do not see it here as this

19     gentleman said.  This document says in English and it's the same in

20     Serbian:  Among other things, the campaigners -- the anti-Serbian

21     sentiment will try.  We do not see what happened, what -- it's his

22     what -- assumption of General Gvero what somebody will try.

23             MR. TRALDI:  Is it Mr. Lukic's case that there'd been no reports

24     of such crimes before this time?

25             MR. LUKIC:  I'm discussing this document that is in front of this

Page 35758

 1     witness.  There are --

 2             JUDGE ORIE:  Let's try to clearly separate the objection against

 3     the question and what Mr. Lukic's case is.  These are two different

 4     matters.  At the same time, could you -- in your question, could you

 5     phrase it again Mr. Traldi, and could you avoid anything that could be

 6     possibly understood as not quoting correctly the text before us, and then

 7     of course you can put whatever question you want.

 8             MR. TRALDI:

 9        Q.   Coverage and potential coverage of the war and of the actions of

10     the VRS was part of General Gvero's responsibilities, part of your

11     responsibilities, and part of the responsibilities of your sector, his

12     sector in the Main Staff; right?

13        A.   It was part of the responsibilities of the chief of the sector,

14     i.e., General Gvero, and the section for information in the sector for

15     morale, religious, and legal affairs.

16        Q.   So what I'm putting to you is your testimony that you can't say

17     what General Gvero knew about international coverage of the actions of

18     the VRS at that time is not the truth.  That you, at the time, were aware

19     that he was aware of the nature and the tone of international coverage of

20     the regular allegations of crimes by Bosnian Serb forces, including the

21     VRS.  That's the truth; right?

22        A.   No, I didn't know.

23        Q.   Below that, General Gvero writes about particularly sensitive

24     information that at the time is coming out the Eastern Bosnia and

25     suggests that this information should be carefully monitored.  That's

Page 35759

 1     because the Main Staff was capable of monitoring the information coming

 2     out of Eastern Bosnia at the time; right?

 3        A.   The Main Staff received information from subordinate units and

 4     commands, including those that were located in that area.

 5        Q.   In fact, by this time, the Main Staff's sector for legal, moral,

 6     and religious affairs was putting out daily reports on what it termed

 7     Muslim and Croat propaganda; right?

 8        A.   I think that they were not doing it at that time.  I think we're

 9     talking about early 1993 here.  But during a certain period, yes.  I

10     cannot remember the time-period though in which they did so.

11        Q.   Now, we may have occasion to look at one or two later and see if

12     we can refresh your recollection.  But for the moment, this time,

13     March of 1993 in Eastern Bosnia, one of the things that happened was the

14     enclave of Cerska fell; right?

15        A.   Yes, that was when Cerska was liberated.

16        Q.   And the people living in Cerska, the Muslims who had been there,

17     they fled when it was, as you say, liberated; right?

18        A.   I assume so, but I wasn't there.  According to my information,

19     though, they did leave that area.

20        Q.   And there was a humanitarian crisis in March 1993 in the

21     Srebrenica enclave; right?

22        A.   I didn't have information about whether there was a humanitarian

23     crisis or not.  But in any case, a large number of people arrived in the

24     area, and the living conditions then were not the same as they were

25     before.

Page 35760

 1        Q.   When you say "not the same," they were very bad, the living

 2     conditions; right?

 3        A.   I assume so.  I really cannot say because I didn't have the

 4     opportunity to see so for myself.

 5        Q.   Now, you testified yesterday that the Main Staff's position was

 6     that journalists could write freely and move freely.  We read here that

 7     in the context of the events we just discussed, General Gvero's position

 8     is:

 9             "All uncontrolled and unorganised movements of the local and

10     foreign journalists in the theatre of war must be prevented."

11             This is an example of General Gvero applying a more restrictive

12     policy than the one you described yesterday; right?

13        A.   Mr. Prosecutor, I do see the paragraph.  I see what you have just

14     read out to me.  In general the position of the Main Staff, which sent

15     instructions to the units, was that domestic and foreign journalists for

16     their personal safety should not be permitted or permitted extremely

17     rarely to move about the combat zone.  Naturally, journalists could not

18     move around unless they were accredited in the proper way by the Ministry

19     of Information.

20             MR. TRALDI:  Your Honour, I tender this document.

21             JUDGE ORIE:  Before we decide on that --

22             Witness, the conditions or the limitations on the free movement

23     here, as far as can I read, have got nothing to do with safety but are

24     about a risk of propaganda or misinformation.  Would you agree with that?

25     Because I don't see any reference to safety.  I see it's embedded in a

Page 35761

 1     document which deals with anti-Serb propaganda.

 2             THE WITNESS: [Interpretation] Your Honour, the Prosecutor put

 3     this question to me right after several questions that had to do with the

 4     Cerska operation.

 5             JUDGE ORIE:  Yes.  Now, I think the Prosecutor was asking the

 6     sensitivity of the information, and he wanted to find out what that was.

 7     But I'm now putting the question to you whether you agree that the

 8     context of this document is not one that refers to safety and security of

 9     the journalists but which is about a risk of publications which are

10     anti-Serb.

11             THE WITNESS: [Interpretation] Your Honour, you could interpret it

12     in that way, but you could interpret it also in a different way.  On the

13     basis of this text, it's difficult to see what it's all about.  I think

14     that in the specific instance there should have been no danger from this

15     information being released in view of the fact that the UNPROFOR

16     commander, General Morillon, happened to be in Srebrenica at that time

17     himself.

18             JUDGE ORIE:  Now, what I read in this document - and there may

19     have been some confusion in the questions put by Mr. Traldi as well - is

20     that there is concern about the information which is provided by the

21     Serbs themselves is used for arguments so as to accuse the Serbs from all

22     kind of things.  That's the context of this document.

23             And, Mr. Traldi, I'm saying that it may not have always been very

24     clear because information in your questions it's not always clear whether

25     you refer to information coming from the Serbs, as we find clearly on the

Page 35762

 1     bottom of the previous page and then the top of this page, and then the

 2     information you can read in the media which, of course, is something

 3     different.

 4             But that's the context, Witness, isn't it?  Abuse of your

 5     information for accusing the Serbs of all kind of things, that's the

 6     context.  Do you agree or do you not agree; and, if not, and if you think

 7     it's more about safety, please point at where specifically safety and

 8     security is referred to.

 9             THE WITNESS: [Interpretation] Your Honour, this part of the text

10     in front of me, I don't see anywhere that the safety of journalists is

11     discussed.  It also says that we particularly believe the information

12     from the area to be sensitive, and the position of the Main Staff, and it

13     regulated this through instructions, that the information should be

14     issued regularly in an objective way and in a timely way.  That it should

15     be truthful.

16             JUDGE ORIE:  Please proceed, Mr. Traldi.

17             MR. TRALDI:  Your Honours, I'd tender the document.

18             JUDGE ORIE:  You did that already.

19             Madam Registrar.

20             THE REGISTRAR:  Document 32646 receives number P7392,

21     Your Honours.

22             JUDGE ORIE:  P7392 is admitted.

23             Please proceed.

24             MR. TRALDI:  Can we have P6646.

25        Q.   Now, this is a document dated the 19th of November, 1994,

Page 35763

 1     entitled:  "Directions on Some Current Issues Regarding Public

 2     Information."  And it's sent to the assistant commanders for moral

 3     guidance, religious, and legal affairs of the various corps, the various

 4     logistics bases, and several other units.  Those are all units, corps,

 5     and logistics bases directly under -- directly subordinated to the VRS

 6     Main Staff; right?

 7        A.   Yes, that's right.

 8        Q.   This is your document; right?  You produced it.

 9        A.   I think so, but I cannot see the end of the document.

10             MR. TRALDI:  Let's turn to the end for the witness.

11             THE WITNESS: [Interpretation] Yes, I see that.  I signed it.

12             MR. TRALDI:

13        Q.   And this document sets out generally how VRS units are to behave

14     in terms of public information, what information to provide; right?

15        A.   I suppose so.  I didn't manage to read the entire document.  That

16     is one of the guide-lines that we sent out.

17        Q.   Is this a document you would have produced on your own authority

18     or would one of your superiors have had to approve it?

19        A.   I did not have authority of my own.  Whenever General Gvero was

20     present, if I wrote anything, I wrote it on his orders and with his

21     approval, or if somebody else wrote it, then I would sign it.

22        Q.   So General Gvero would have approved this document being

23     disseminated; right?

24        A.   In principle, yes.

25        Q.   All right.

Page 35764

 1             MR. TRALDI:  Can we have page 2 in the English, please.

 2        Q.   I'm directing your attention to point 12 which we already see in

 3     front of you in the B/C/S.  We read that this part of the document, you

 4     direct those units:

 5             "Mask our offensive activities maximally.  Do not inform the

 6     public about these, but in the advanced stage, present them as ... the

 7     natural right to self-defence and a forced response, in other words, a

 8     counteroffensive."

 9             You are directing that the public be intentionally misled about

10     the VRS's offensive operations; right?

11             THE INTERPRETER:  Interpreter's note:  Could the witness please

12     speak directly into the microphone, not on the side.  Thank you.

13             JUDGE ORIE:  Witness, could you try to speak directly into the

14     microphone.  And it could perhaps be adjusted again.  Perhaps you sit

15     slightly back or that it ...

16             Yes, we're not blaming you for anything, but we try to hear the

17     words you are speaking.

18             Please proceed.

19             THE WITNESS: [Interpretation] I do apologise for these

20     difficulties.  I don't know whether you can hear me properly now.

21             THE INTERPRETER:  Interpreter's note:  Yes.  Thank you.

22             THE WITNESS: [Interpretation] Thank you.

23             JUDGE ORIE:  Could you now please answer the question whether you

24     were intentionally instructed to mislead the public about offensive

25     activities.

Page 35765

 1             THE WITNESS: [Interpretation] So in any war, all conflicting

 2     armies try up to a maximum to conceal --

 3             JUDGE ORIE:  No one yet asked whether it's justified or whether

 4     there were good reasons to do that.  The question simply is whether you

 5     instructed that the public should be misled intentionally about offensive

 6     activities.

 7             THE WITNESS: [Interpretation] Your Honour, we gave instructions

 8     to mask activities to a maximum degree so that they would remain secret

 9     so that they do not be made public.

10             THE INTERPRETER:  And we didn't hear the end of the sentence.

11             JUDGE ORIE:  Could you please repeat the end of your answer.

12             THE WITNESS: [Interpretation] At a later stage, it should be

13     portrayed as a counteroffensive.  If that's what I said at the end.

14             MR. TRALDI:

15        Q.   And, sir, what I'm putting to you is that aside from masking the

16     operations, separate from any attempt to keep them secret, what you're

17     suggesting is that offensive activities should be presented as part of

18     self-defence or as counteroffensives as a forced response rather than the

19     offensive activities that you're saying in this document that they were.

20     That is an instruction to mislead the public; right?  Yes or no?

21        A.   Precisely as written here, Your Honours and Mr. Prosecutor.

22        Q.   That is precisely yes, it is an instruction to mislead the

23     public; right?

24        A.   I don't know why we would have any reason to deceive our public

25     in any way.

Page 35766

 1        Q.   One reason that you intended -- one reason you issued this order

 2     to deceive the public in the -- at home and abroad, was you knew the

 3     offensive activities of the VRS were controversial and prompted

 4     international criticism; right?

 5        A.   I really cannot give an answer because I'm not aware of such

 6     criticism.

 7        Q.   Your evidence today, as you sit there, is you're aware of no

 8     international criticism of the VRS during the war for its offensive

 9     activities; is that right?

10        A.   Mr. Prosecutor, in this stage - so in this stage - I really

11     cannot recall that we had this information.  I personally did not have

12     any information pertaining to the international public.  I state that

13     with full responsibility.

14        Q.   Do you recall as you sit there any international criticism of the

15     VRS or the Bosnian Serbs at all?

16        A.   I recall individually some of these pieces of information that

17     were written up via the information department on the basis of listening

18     to the radio of Republika Srpska in Bosnia-Herzegovina.  Some part where

19     this criticism was being conveyed, too.

20        Q.   How about coverage of the camps right around when you joined the

21     Main Staff?  Do you recall international criticism of conditions in the

22     camps run by the VRS and other Bosnian Serb forces?

23        A.   Mr. Prosecutor, in relation to that I do remember because

24     precisely a day or two or three - I cannot remember exactly right now -

25     after I arrived in the Main Staff and joined the Army of

Page 35767

 1     Republika Srpska, I was sent to report to the president of

 2     Republika Srpska in Pale so that he could issue concrete orders to me and

 3     that on behalf of the army I should accompany the ICRC and foreign

 4     journalists when they visit prisons for prisoners of war.  I think that

 5     that was after one of the peace conferences.  And I carried out that

 6     mission; I remember that.

 7        Q.   Which camps did you visit?

 8        A.   The first day we visited -- it was towards the end of the day,

 9     actually.  We visited the prison of Kula in Sarajevo.  That is in the

10     area that is nowadays called east Sarajevo.  Then the next day, we

11     visited Keraterm, Trnopolje, and another prison, but I really cannot

12     recall the name.  Perhaps if you could jog my memory.  I certainly

13     wouldn't mind.  But at any rate, it was those three.

14             What was proposed was that the prison in Batkovic and in

15     Batkovici -- Bijeljina too and also the one in Manjaca be visited, but

16     people from this convoy were not interested in visiting these prisons.

17        Q.   You said you can't recall the name of the third prison.  Would it

18     refresh your recollection if I said Omarska?

19        A.   Yes, yes, Omarska.

20        Q.   So at the beginning of your time in the Main Staff, you visited

21     Omarska, Keraterm, Trnopolje, among other camps run by the Bosnian Serbs;

22     right?

23        A.   Yes.

24        Q.   Now, the Chamber has received a great deal of evidence about

25     these visits.  Earlier -- so I'm not going to go through them in detail.

Page 35768

 1     But earlier I asked whether you recalled any international criticism of

 2     the VRS or the Bosnian Serbs at all.  You said you recalled some pieces

 3     of information written up via the information department.  Now, in fact,

 4     there was an enormous amount of international condemnation of the

 5     conditions in the camps that you visited together with these journalists

 6     as a representative of the Main Staff; right?

 7        A.   Yes, as a member of the Main Staff who was not assigned a

 8     particular duty until then.  I want to say that these three camps that

 9     you mentioned, with the exception of Kula, were under the control of -

10     what was it called then? - the Ministry of Interior something, the centre

11     of public security, and so on and so forth.  The prison in Kula was under

12     the control of the army.

13        Q.   And there had been preparations made by subordinate units

14     directed by the Main Staff to get the camps ready for these visits;

15     right?

16        A.   That I don't know, but of course there was a representative of

17     the government and a representative of the Ministry of Interior there,

18     along with me.

19        Q.   You said you were sent to President Karadzic.  Did you have any

20     discussions with other Main Staff officers about what was being done to

21     get ready for these visits or about what you would be likely to see on

22     these visits?

23        A.   No.  It was a brief issuing of an order by General Gvero.  It was

24     a spoken order.  I was supposed to report to the president of the

25     republic urgently, and I was supposed to take journalists and members of

Page 35769

 1     the ICRC around, and all other instructions I will get from the president

 2     of the republic.

 3             MR. TRALDI:  Can we have 65 ter 31356.

 4        Q.   This is an order issued by Colonel Dragan Ilic, at the time the

 5     commander of the East Bosnia Corps to the POW camp commander.  We see

 6     it's dated the 3rd of August, 1992.  That's around the time of your

 7     visit; right?

 8        A.   Maybe a day after the visit or the day when the visit was

 9     supposed to take place.  I quite simply cannot recall the date.

10        Q.   Now, he is directing that prisoners over the age of 70 be

11     released.  Were you aware at the time of your visit that the VRS was

12     detaining prisoners over the age of 70 in its camps?

13        A.   I was in the Kula prison and I don't think I saw any elderly

14     persons there as prisoners.  It's not that I think so; I'm sure.

15        Q.   I'm going to ask again for an answer to my question.  Were you

16     aware at the time of your visit that the VRS was detaining prisoners over

17     the age of 70 in its camps?  Yes or no.

18        A.   No.

19        Q.   Detaining elderly people, people who visibly appeared to be

20     non-combatants, that's the sort of thing that would prompt the sort of

21     international condemnation that came as a result of the visits to and

22     coverage of the camps; right?

23        A.   It would only be natural to expect that kind of condemnation.  I

24     cannot give you an answer to that question because this was written by

25     the commander of the Eastern Bosnia Corps, and I repeat once again that I

Page 35770

 1     am more and more certain that we travelled on the second; that is,

 2     Saint Ilijas day.  That's when we were in Kula.  And on the 3rd we were

 3     in Prijedor.

 4             MR. TRALDI:  Your Honour, I'm going to move on.  Before I do,

 5     I'll tender this one.

 6             JUDGE ORIE:  Madam Registrar.

 7             THE REGISTRAR:  Document 31356 receives number P7393.

 8             JUDGE ORIE:  P7393 is admitted.

 9             MR. TRALDI:

10        Q.   Did Colonel Ilic later acquire a position in the Main Staff?

11        A.   Yes.

12        Q.   He became the chief of the sector for operations; right?

13        A.   No.

14        Q.   What position did he get?

15        A.   He became the head of the operations organ in the staff.  The

16     operative staff of the Main Staff, actually.

17             MR. TRALDI:  Can we have P2879.

18        Q.   Now, this is an order issued by General Mladic dated the 3rd of

19     August, 1992.  See it's sent to the commander personally.  It says:

20             "Pursuant to the agreement of political leadership of three BiH

21     peoples, reached at the recent negotiations in London and in goal of

22     preparation of the POW camps for visits and making possible for foreign

23     journalists and members of the International Committee of the Red Cross

24     to visit them."

25             He issues an order, first to:

Page 35771

 1             "... undertake measures through the MUP and authorities to

 2     arrange POW camps in your zones of responsibility and prepare them for

 3     visits by foreign journalists and the International Committee of the Red

 4     Cross team."

 5             This the visit you took part in; correct?

 6        A.   I suppose so, yes.

 7        Q.   Looking at point 3, he notes:

 8             "You will be additionally informed on the precise time of the

 9     visit to POW camps.  The tour started 3 August 1992 in the zone of

10     responsibility of Sarajevo-Romanija Corps."

11             Does that refresh your recollection as to the date of your visit

12     to Kula?

13        A.   Yes.

14        Q.   And you were aware in the late summer/early fall of 1992, you and

15     the morale sector yourself were aware that the VRS was detaining people

16     it had no legal basis to detain; right?

17        A.   I cannot say anything for sure because the organ for morale and

18     religious affairs to deal with prisons and POWs.  Sometimes some

19     information would arrive as an indicator or factor that affected combat

20     morale.

21        Q.   And that information that would sometimes arrive as a factor that

22     affected combat morale was that the VRS was detaining people it had no

23     legal basis to detain; right?

24        A.   No.

25             JUDGE ORIE:  Mr. Mladic --

Page 35772

 1             THE WITNESS: [Interpretation] No, or I'm not aware of any such

 2     thing.

 3             JUDGE ORIE:  Mr. Mladic, we had a few incidents yesterday about

 4     speaking aloud.  I gave you a last warning.  I repeat that now and next

 5     time will result in consequences.

 6             Please proceed.

 7             And, Witness, Mr. Sokanovic, you just focus on Mr. Traldi who is

 8     examining you.

 9             MR. TRALDI:  Can we have P3951.

10        Q.   This is a 1st Krajina Corps combat morale report for August 1992

11     dated the 3rd of September.  General Gvero would have reviewed this

12     report personally and shared the contents with General Mladic and the

13     collegium; right?

14        A.   I reviewed -- or, rather, he reviewed that.  Now, he was supposed

15     to communicate that if he thought it was of significance, but that does

16     not necessarily mean that he did communicate that.

17        Q.   Turning to the page 3 in the English and to page 4 in the B/C/S

18     under the category "The Effect of the Political and Security Situation in

19     the Territory on Combat Morale," so at the very bottom of the page in the

20     English, we read that the 1st Krajina Corps is reporting:

21             "Certain tensions are still present in the Kotor Varos, Kljuc,

22     Sanski Most and Prijedor areas," and we haven't scrolled quite far enough

23     down in the English yet, "because of a large number of arrested citizens

24     for whom there is no evidence or criminal reports that they participated

25     in the armed rebellion."

Page 35773

 1             So General Gvero by this point -- at this point, 3rd of

 2     September 1992, he's being informed by a subordinate corps that a large

 3     number of people have been arrested with no legal basis; right?

 4        A.   That is what is written here, but it doesn't say who it was that

 5     took them prisoner.

 6        Q.   The Chamber has received evidence that by this time most of them

 7     were being detained at Manjaca, including some who'd been transferred

 8     from facilities run by the police.  Were you aware of that?

 9        A.   It was well known that the prison of Manjaca existed; however, in

10     this case, as can be seen from this text, it says here that the centre of

11     security services contributes to this situation headed by Drljaca.  And

12     yesterday we discussed this.  At the time, there were many paramilitary

13     formations that were prominent precisely in these places.

14        Q.   Sir, I understand you're attempting to focus on the public

15     security station.  At this point, my question is:  Were you aware that

16     these people who'd been arrested and detained with no legal basis were

17     being detained at the VRS-run Manjaca camp, yes or no?

18        A.   No.

19             MR. TRALDI:  Your Honour, I see it's time for the break.

20             JUDGE ORIE:  It is time for the break.

21             Witness we'd like to see you back in 20 minutes.  You may now

22     follow the usher.

23                           [The witness stands down]

24             JUDGE ORIE:  We'll resume at ten minutes to 11.00.

25                           --- Recess taken at 10.31 a.m.

Page 35774

 1                           --- On resuming at 10.56 a.m.

 2             JUDGE ORIE:  Mr. Traldi, could you inform the Chamber whether

 3     you're on track as far as time is concerned.

 4             MR. TRALDI:  I am.  And I should say that's based on what I've

 5     been informed, which is that have I about 45 minutes left.

 6             JUDGE ORIE:  Yes.

 7             MR. TRALDI:  Assuming that, as usual, Madam Registrar is correct

 8     in that regard, then I'm on track.

 9             JUDGE ORIE:  Yes, the information is correct.

10                           [The witness takes the stand]

11             JUDGE ORIE:  You may continue, Mr. Traldi.

12             MR. TRALDI:

13        Q.   You mentioned one of the places you visited was Kula.  I have a

14     couple of questions for you about it.  First, was Radovan Karadzic on the

15     same visit to Kula you went on?

16        A.   No.

17        Q.   Are you aware of coverage in the international press of him

18     handing out a small number of discharge certificates on a visit to Kula

19     in early August 1992?

20        A.   No, I'm not aware of that.

21        Q.   Now, the Chamber has received evidence that 10.000 or more

22     civilians passed through Kula, were detained there, were eventually

23     exchanged during the war.  Is it your evidence that you don't know

24     anything about that either?

25        A.   I don't know anything about it, no.

Page 35775

 1        Q.   The Chamber has also received evidence that days after your visit

 2     to Omarska, the prisoners from Omarska were transferred to Manjaca and

 3     that the people who were transferred included minors, people who were

 4     elderly, people who were ill, people who, in the view of the Manjaca

 5     guards, couldn't hold a gun let alone run or shoot.  Did you see people

 6     like that on your visit to Omarska?

 7        A.   When I went to Omarska, I did not attend any talks, but I did

 8     have the opportunity to see some prisoners, among whom were people who

 9     were, I would say, first of all, of a weak physical constitution.

10        Q.   People who looked like they hadn't been getting enough food;

11     right?

12        A.   Yes.

13        Q.   You saw people who looked like they hadn't been getting enough

14     food on your visit to Trnopolje too; right?

15        A.   I was not in a position to see how much food they were getting.

16        Q.   You were in a position to see them.  They looked, they were of a

17     very weak, very thin physical constitution.  In your words, they looked

18     like they hadn't been getting enough food; right?

19        A.   Individually, yes, but not all.

20        Q.   And the Chamber has received evidence that some of the ones who

21     looked that way had been transferred from Keraterm where you said you

22     visited.  Were you aware, as the Chamber has received evidence, the

23     Main Staff was that a large number of prisoners had been killed at

24     Keraterm just about ten days earlier?

25             MR. LUKIC:  I was patient enough.  I object to this type of

Page 35776

 1     questions, that the Chamber received the evidence.  Is that question for

 2     this witness?  Should he comment on that, what chamber received?  Or

 3     should he answer anything when Chamber received evidence?

 4             JUDGE ORIE:  Well, I think it's reminding the witness.  But,

 5     Mr. Traldi, if you want to respond.

 6             MR. TRALDI:  As Mr. Lukic I thought said, but perhaps did not,

 7     the same objection has been raised and ruled on by the Chamber before, I

 8     think, in the context of Witness Dragojevic's testimony.  It's a practice

 9     that we've followed throughout the Defence case and Mr. Lukic has

10     objected a couple of times recently, but I think it's fair for the

11     record.

12             MR. LUKIC:  If there is an evidence that -- this evidence should

13     be shown to the witness.

14             JUDGE ORIE:  No, that's not necessary.  I -- unfortunately, you

15     don't understand in that respect.  What you do is you tell the witness

16     that the Chamber is not blank on these matters but that we have received

17     information about it.  Whether that's convincing or not, whether that

18     establishes facts or not, the question is not to comment on that

19     evidence.  The question is:  Are you aware that a large number of persons

20     were killed ten days before that, an event on which this Chamber has

21     received some evidence.

22             Now, the knowledge of the witness does not depend on the evidence

23     this Chamber receives.

24             MR. LUKIC:  Why mention the evidence then?

25             JUDGE ORIE:  Well, you could do without, and then in the next

Page 35777

 1     question -- but in itself it's not improper to tell the witness that this

 2     Chamber is not blank in this field, that we have received evidence,

 3     whatever that evidence is.

 4             That's my ruling.  The witness may answer the question.

 5                           [Trial Chamber confers]

 6             JUDGE ORIE:  Judge Moloto who is educated, I would say, in the

 7     system, would like to add something to my ruling.

 8             JUDGE MOLOTO:  The purpose for telling the witness the evidence

 9     is to give the witness an opportunity to either confirm or deny that

10     evidence, and if he does confirm then you can follow -- you can close the

11     question, but if he does deny you can follow up to find out on what

12     basis.  That's the reason.

13             MR. LUKIC:  Thank you, Your Honour.  But I informed this Chamber

14     that many of my witnesses complained that it is very confusing to them.

15     They don't know what to do if with that type of question.

16             JUDGE MOLOTO:  It's unfortunate if they are confused but that's

17     the procedure.

18             JUDGE ORIE:  You could have explained it then what the situation

19     is as I explained it a minute ago to you, Mr. Lukic.  The objection is

20     denied.

21             Witness, were you aware that some ten days before a large number

22     of people were killed in Keraterm?  And again, this Chamber -- again,

23     this Chamber is not blank on the matter.  We have received evidence

24     related to such an event.

25             THE WITNESS: [Interpretation] Your Honours, I've already answered

Page 35778

 1     the Prosecutor's question.  I did not have any knowledge about --

 2             THE INTERPRETER:  We did not hear the last few words of the

 3     witness's answer.

 4             JUDGE ORIE:  Could you repeat the last few words.  You said you

 5     didn't have any knowledge about ...

 6             THE WITNESS: [Interpretation] About ten days before the

 7     International Red Cross arrived and the international journalists whom I

 8     accompanied, that any killings of people were committed who were in

 9     Keraterm.

10             JUDGE ORIE:  Mr. Traldi.

11             MR. TRALDI:

12        Q.   Now, that massacre was included in a daily combat report to the

13     Main Staff.  Is it your evidence that nobody at the Main Staff said,

14     "Okay, you're going to Keraterm.  You should know people were killed.

15     You should know it's a recent massacre site."  Nobody briefed you about

16     that?

17        A.   Yes, you are correct.  Nobody told me that.

18        Q.   Were the journalists taken to room 3 at Keraterm?

19        A.   I don't know.  I don't even know what room 3 is, and I cannot

20     recall any details.

21        Q.   Did you go by a room with bullet-holes in the door?

22        A.   I did not notice anything like that.

23        Q.   And you didn't take them into a room where there were still

24     traces of blood, traces of an execution?

25             MR. LUKIC:  Is it established that at the time when this

Page 35779

 1     gentleman was there there were traces of killings still?

 2             JUDGE ORIE:  No, that's suggested in the question and the witness

 3     can answer.

 4             MR. LUKIC:  No, no, did you take them to the room where there

 5     were traces.

 6             JUDGE ORIE:  To a room, I think it was.

 7             MR. LUKIC:  Yeah, to --

 8             JUDGE ORIE:  To a room --

 9             MR. LUKIC:  -- where traces --

10             JUDGE ORIE:  -- where there were traces.  That's a perfectly

11     permissible question.

12             MR. LUKIC:  But we don't know whether there were traces at the

13     time.

14             JUDGE ORIE:  Mr. Lukic, the witness will tell us what he knows,

15     and there's a suggestion that there was a room with traces of blood.

16     Now, the witness can either confirm or deny that.  It's not that it

17     should be established.  By the way, this Chamber has not established any

18     facts at this moment about these matters.  We do that at the end.  We do

19     it in our judgement.

20             MR. LUKIC:  Your Honour, but we received --

21             JUDGE ORIE:  Mr. Lukic, the objection is denied.  We'll continue.

22             Did you take them to a room in which there was traces of blood?

23             THE WITNESS: [Interpretation] Your Honour, I did not see traces

24     of blood in any room or in any facility.  I don't know which room they

25     were taken to because in that part -- or actually, in all of those

Page 35780

 1     prisons, the team was led by a member of the public security centre from

 2     Prijedor.

 3             JUDGE ORIE:  You yourself were not present in those rooms, if I

 4     understand you well?  In what, as you called them, prisons.

 5             THE WITNESS: [Interpretation] That's correct, I was not present.

 6             JUDGE ORIE:  Please proceed, Mr. Traldi.

 7             MR. TRALDI:

 8        Q.   I just have a couple of more questions on this topic, sir.

 9             First, when you say "those three prisons," you mean Omarska,

10     Keraterm, and Trnopolje; right.

11        A.   That's right.  And I apologise.  In my previous answer to

12     Mr. President, the Presiding Judge, not that I was not in any of the

13     rooms.  I was in a restaurant, or the canteen, and I was in the office of

14     the prison warden.

15        Q.   That's at Omarska; right?

16        A.   Yes.

17             JUDGE ORIE:  I may have been confused by not knowing exactly what

18     prison or prisons the witness was talking about.

19             Could you -- if you say anything about either Keraterm or

20     Trnopolje or Omarska to make clear which of those facilities you are

21     referring to.

22             Please proceed.

23             MR. TRALDI:

24        Q.   Now, you said you saw people who didn't -- who appeared they

25     didn't have enough food, people appeared in a weak physical condition.

Page 35781

 1     Did you tell General Gvero about that when you got back to the

 2     Main Staff?

 3        A.   When I returned to Pale, I drafted a report that I submitted to

 4     the president of the republic.

 5        Q.   And did you also tell your superior?

 6        A.   I informed him about what I saw.

 7        Q.   And it would have been his responsibility to inform

 8     General Mladic, inform the collegium of the Main Staff; right?

 9        A.   That's the way it should have been, yes.

10        Q.   And there were people wearing military uniforms as guards, at

11     least at Trnopolje; right?

12        A.   I think so, yes.  It's an area around the school and some

13     construction material warehouse that was fenced in with a wire fence.

14        Q.   And around that area, people wearing VRS uniforms serving as

15     guards; right?

16        A.   During that period, the police and the army wore mostly

17     camouflage uniforms.  In some situations, the police also had blue

18     uniforms as well as the camouflage uniforms.  I think, even though I

19     cannot remember right now, that they had camouflage uniforms; although, I

20     cannot really state that with certainty.

21        Q.   And you're aware the VRS did external security at Omarska; right?

22     The VRS was responsible for external security at Omarska.

23        A.   No, I -- I don't know that.  I didn't know that.

24        Q.   Are you aware of any measures that your superior, General Gvero,

25     or anyone else on the Main Staff took after this visit to investigate,

Page 35782

 1     for instance, the Prijedor Brigade commanders related to the VRS's

 2     involvement in those camps?

 3        A.   I don't know if this happened.  What I do know is that when we

 4     were received by the Prijedor public security service -- centre chief, I

 5     learned that those three prisoners [as interpreted] were under the

 6     jurisdiction of the Ministry of Interior.

 7             JUDGE FLUEGGE:  Did you say "those three prisoners," or did you

 8     say "those three prisons"?

 9             THE WITNESS: [Interpretation] Those three prisons, Keraterm,

10     Omarska, and Trnopolje.

11             JUDGE FLUEGGE:  Thank you.

12             MR. TRALDI:

13        Q.   Now the Chamber has received a great deal of evidence about

14     Slobodan Kuruzovic who at the time was in charge of Trnopolje.  Do you

15     recall if you met him?

16        A.   I think that I'm hearing the name for the first time so that I

17     cannot really say if I met him or not.

18        Q.   Did you meet the warden at Trnopolje?  Yes or no.

19        A.   Yes.

20        Q.   He was wearing a green camouflage uniform; right?

21        A.   Perhaps, but I'm finding it difficult to remember.

22        Q.   I'm going to move away from Prijedor now.  In fact, the VRS

23     continued detained civilians into 1993 and longer; right?

24        A.   I don't know about that, or I just cannot remember that at this

25     moment.

Page 35783

 1             MR. TRALDI:  Can we have P6915.

 2        Q.   As it comes up, this is going to be an order by

 3     General Milovanovic dated the 24th of April, 1993.

 4             MR. TRALDI:  And the document is P6915.

 5             JUDGE MOLOTO:  Is it 6915 or 6195.

 6             MR. TRALDI:  6915.  Thank you, Your Honour.

 7             JUDGE FLUEGGE:  6915.

 8             JUDGE ORIE:  Please proceed.

 9             MR. TRALDI:

10        Q.   Now, we see here, and we don't have the B/C/S, but it's an order

11     General Milovanovic is issuing to the various corps and the air force and

12     anti-aircraft defence to provide details of prisoners to the Main Staff

13     with the aim of conducting talks on the exchange of prisoners of war and

14     civilians.

15             MR. TRALDI:  And if we could have page 2 in the English only, and

16     it's the end of the text in the B/C/S.

17        Q.   He's directing that lists be provided of "Muslim prisoners of war

18     and captured civilians in prisons of the RS."

19             Is it your evidence that you, though you were in the Main Staff

20     at the time, were not aware that there were captured civilians, captured

21     Muslim civilians, in RS prisons?

22        A.   Yes, I've already answered that.

23        Q.   Now, the Chamber has received a number of lists of prisoners kept

24     by subordinate units - for instance, P6804, P6805, and P7239 - that

25     reflected, among others, the detention of 100-year-old Muslim women.  So

Page 35784

 1     I'd put to you that it's clear from this document the Main Staff was

 2     aware and that you are testifying today that are you not aware of

 3     civilians being detained because you know it to have been unlawful.

 4     That's the truth; right?

 5        A.   No.  I'm just one of the members of the Main Staff, and in a

 6     sector that as for POW camps, their keeping, their exchanges -- or rather

 7     exchanges of prisoners, we had nothing do with that.  I had nothing to do

 8     with that.

 9        Q.   No corps commanders or corps assistant commanders for security

10     and intelligence were dismissed after the publicity about the terrible

11     criminal conditions in the camps, were they?

12        A.   No.  As far as I know, not a single one was dismissed.  And I

13     assume, as far as the content of their work is concerned, there were

14     other omissions as well.

15        Q.   And no guards were sentenced to terms of imprisonment in the VRS

16     military justice system, were they?

17        A.   I don't know.

18        Q.   In one of the lists of prisoners that contained elderly people

19     and Muslim civilians that I referred to, P7239, was the TG Visegrad list.

20     At the time, its commander was Dragisa Masal.  He was also promoted to

21     serve at the Main Staff afterwards; right?

22        A.   I don't know what year that was.  I don't know from what year

23     that report is.  General Dragisa Masal was then a colonel.  He was not

24     promoted.  He was transferred from that position to another position in

25     the Main Staff.  The actual transfer did not mean that it was any kind of

Page 35785

 1     reward.

 2        Q.   Do you have more authority as chief of artillery in the

 3     Main Staff or as the commander of TG Visegrad?

 4        A.   Mr. Prosecutor, it depends on the area involved.  The commander

 5     of the tactical group is the commander and he is sovereign, if I can put

 6     it that way, in terms of the unit or units that he commands.  And the

 7     chief of a certain service is primarily in charge of the professional

 8     management of that particular service in the army.

 9        Q.   Now, we've been talking about the detention of civilians.  Your

10     view in your interview was that on all three sides people were reluctant

11     to talk about civilian victims and often described them as soldiers;

12     right?

13        A.   Yes, that's right.

14        Q.   That's -- in your view, then, it was wasn't popular to make known

15     that there were civilian victims of the acts of the VRS or any of the

16     other parties to the conflict; right?

17        A.   I don't know whether he was popular, as you had put it.  I would

18     kindly ask you, if it's not a problem, to remind me of that particular

19     part.

20             MR. TRALDI:  Can we have 65 ter 32563, page 43 in the English and

21     54 in the B/C/S.  And, actually, let's have 32563a but the same pages.

22        Q.   And we see you're asked:

23             "What would happen if a crime against a large number of civilians

24     was committed?  Would that case be handed over to the security

25     department?"

Page 35786

 1             You say:

 2             "Yes, I'm not sure whether directly to the security department or

 3     directly to the prosecutor.  Anyway, it had to be investigated and then

 4     the measures undertaken.  You have to be aware that all three sides

 5     almost never spoke or very rarely spoke about, you know, the civilian

 6     victims.  Unfortunately, that's the reality.  So usually everyone was,

 7     you know, treated, referred to as the soldiers."

 8             And you say:

 9             "Sometimes that was right because soldiers throw away their

10     weapons."

11             And you add that:

12             "Everyone knew the civilians were protected by the

13     Geneva Conventions."

14             First, do you stand by your answer in your interview that I've

15     just described?

16        A.   Yes, precisely the last sentence that you read out confirms that.

17     Because people, I mean, were portrayed as civilians and they were

18     combatants in actual fact.

19        Q.   Now, sir, you're focusing on a different part of your answer.

20     What you say in the beginning of the answer is that civilians would be

21     described as soldiers, all three sides almost never spoke about civilian

22     victims, and everyone was treated and referred to as soldiers.

23             First, do you stand by that portion of your answer?

24        A.   I'm trying to find it now.  It's at the very beginning.

25        Q.   Should be the third, fourth, and fifth sentences.

Page 35787

 1        A.   Well, I'm counting the sentences now, and the third one says:

 2             "Unfortunately, that is reality.  And all were mostly treated as

 3     combatants.  Sometimes that was done rightly because when somebody would

 4     get into a bad situation, they knew they would fair better if they threw

 5     away their rifles and presented themselves as civilians."

 6             And then further on, there is the part that refers to protection

 7     by the Geneva Conventions.

 8             JUDGE FLUEGGE:  And now please read the sentence before the word

 9     "unfortunately."

10             THE WITNESS: [Interpretation] Judge, sir, it says:

11             "You should know that all three sides almost never spoke about

12     civilian victims, and if so, very little.  Everyone was treated and

13     referred to as soldiers."

14             This pertains to statements made to the media.  And, of course,

15     such statements would disturb the public, and I presume that that is the

16     reason why that didn't -- that -- that there was no wish to show it that

17     way, as victims in that area.  Civilians.

18             JUDGE FLUEGGE:  And now listen to the next question.

19             MR. TRALDI:

20        Q.   First, can I take it you stand by that portion of your answer as

21     truthful and accurate?  Yes or no.

22        A.   Yes, in the sense in which I spoke.

23        Q.   Second, you've been doing the same thing this morning, denying

24     knowledge of civilian victims, because you know they're entitled to legal

25     protection because it could be disturbing, the same thing you did during

Page 35788

 1     the war; right?

 2        A.   I don't actually understand your question.  Please, could you

 3     repeat it.

 4        Q.   Sure.  Let me break it up.

 5             First, the statements made to the media that you said -- in which

 6     you said everyone was treated or referred to as soldiers, those were made

 7     through the sector for legal, moral, and religious affairs; right?

 8        A.   This information went through that sector.

 9        Q.   And what I'm putting to you this morning is that your claims that

10     you didn't see the civilians, the elderly people who were detained at

11     some of the camps, that's part of the same policy, denying knowledge of

12     civilian victims, because, as you say in your answer, everyone knew they

13     were entitled to legal protection; right?

14        A.   Knowing that they had the right does not mean that that was

15     denied.  I'm telling that I did not know of that suffering, and this here

16     is a general question that has to do with information about conflicts.

17        Q.   I'm going turn now to a few more statements made by the media

18     during the war.

19             MR. TRALDI:  Can we have first 65 ter 32585.

20        Q.   This is an article in the "New York Times" from May of 1993.

21             MR. TRALDI:  If we could have the end of the article in both

22     languages.

23        Q.   We read that General Gvero is quoted, and we don't have it quite

24     in the English yet.  Or -- and at the very end, he says:

25             "We say everybody has to live on his own territory.  Muslims on

Page 35789

 1     Muslim territory, Serbs on Serbian."

 2             Says:

 3             "This is pure Serbian territory ..."

 4             And if we look two paragraphs up, we see that the area being

 5     described is the Drina valley, and they describe what had happened to the

 6     property in that area, houses blasted by tank fire, mosques reduced to

 7     rubble.

 8             First question:  You were aware that your superior officer

 9     considered this area to be purely Serbian territory; right?

10        A.   Oh, I don't know.  I had no way of knowing what my superior

11     officer was thinking.

12             On the other hand, I don't know which territory he means.

13     Perhaps he was in a village that was predominantly Serb.  The territory

14     of the entire Bosnia-Herzegovina, the former Bosnia-Herzegovina, is like

15     a leopard skin, and there are differences, different ethnic groups, from

16     one village to another.

17        Q.   And what General Gvero is saying everybody has to live on his own

18     territory, Muslims on Muslim territory, Serbs on Serbian.  There were

19     plenty of mixed villages before the war -- there were plenty of mixed

20     territories.  What he is saying is the ethnic groups in Bosnia should be

21     separated; right?

22        A.   Not to be separated.  Everybody should live in his own territory,

23     rather.  And now if that territory borders on the neighbours' territory

24     that belongs to another group, they should live one by the other.  It

25     doesn't mean that they have to be separated physically, and that was not

Page 35790

 1     possible after all.  Most mixed marriages in the former Yugoslavia were

 2     in the former Socialist Republic of Bosnia-Herzegovina.  How can you

 3     divide beds?

 4        Q.   In fact, it's exactly what happened.  Not that beds were divided

 5     but that villages that had been mixed became villages that had only one

 6     ethnicity in them; right?

 7        A.   Mostly yes, but not in all cases.

 8             MR. TRALDI:  Your Honours, I tender this document.

 9             JUDGE ORIE:  Madam Registrar.

10             THE REGISTRAR:  Document 32585 receives number P7394,

11     Your Honours.

12             JUDGE ORIE:  P7394 is admitted.

13             Mr. Traldi, you are coming closer and closer to your 45 minutes.

14     You're aware of that.

15             MR. TRALDI:  I am.  I think, with the Chamber's indulgence, I'll

16     finish at the end of the session.

17             JUDGE ORIE:  That's more than the 45 minutes.

18             MR. TRALDI:  Probably by a couple.  Although, my math -- I admit

19     my math's gotten a little bit off during the session.

20             JUDGE ORIE:  Well, we restarted at five minutes to 11.00.  That's

21     45 minutes ago.  I think there are a few minutes taken by the Judges.

22     Could you conclude in the next five minutes.

23             MR. TRALDI:  I'll do my best, Your Honour.

24             Can we have 65 ter 05716.

25             JUDGE MOLOTO:  5-7.

Page 35791

 1             MR. TRALDI:  1-6.  It's correct in the transcript.

 2        Q.   Now, this isn't a statement to the press.  It's an order signed

 3     by Lieutenant-Colonel Pandurevic dated the 25th of April, 1995.  His

 4     brigade also responsible for an area of the Drina valley.  And he writes

 5     in pertinent part:

 6             "The moment has come when the issue of liberating the Serbian

 7     lands from Poturice will be finally resolved in this area by a resolute

 8     and successful action of our forces."

 9             And turning to page 2 in B/C/S, writes in pertinent part:

10             "The adequate response of our forces meant that we realised that

11     there would be no peace and security in Semberija and Donja Podrinje

12     until the Poturice were completely defeated and driven out of this area."

13             Now, this is a reflection of the same goal of separation that

14     Gvero was expressing being turned into a document at the brigade level;

15     right?

16             MR. LUKIC:  Objection.  Objection.

17             THE WITNESS: [Interpretation] No.

18             JUDGE ORIE:  What's your objection, Mr. Lukic?

19             MR. LUKIC:  What kind of separation we saw in the previous

20     document.  I think it says Muslims on Muslim territory, Serbs on Serb

21     territory.  What kind of separation we see there?

22             JUDGE ORIE:  Mr. Traldi.

23             MR. TRALDI:  We see obvious facial physical separation between

24     the Muslims who are supposed to live on the Muslim territory and the

25     Serbs who are supposed to life on the Serb territory.

Page 35792

 1             JUDGE ORIE:  Yes.  Now --

 2             MR. LUKIC:  Is that interpretation or we can see it in the

 3     document?

 4             JUDGE ORIE:  It's put to the witness that this is what this

 5     document reflects and that's a proper question.  The objection is denied.

 6             Please proceed.

 7             THE WITNESS: [Interpretation] I did not provide a full answer.

 8             MR. TRALDI:

 9        Q.   And you're welcome to do so now, sir.

10        A.   So I said no.  This is a document of the commander of one

11     brigade.  Unfortunately, we had commanders who did not follow the

12     positions of the Main Staff in terms of command and control and who would

13     sometimes deviate from these positions of the Main Staff.

14             This the first time I see this document.  This the first time I

15     hear some of these expressions, and I cannot agree that it's the same as

16     what was quoted in one of those periodicals related to Gvero's statement.

17             MR. TRALDI:  Your Honours, I tender the document.

18             JUDGE ORIE:  Madam Registrar.

19             THE REGISTRAR:  Document 5716 receives number P7395,

20     Your Honours.

21             JUDGE ORIE:  Admitted into evidence.

22             Mr. Traldi, I verified with Madam Registrar.  It's from now that

23     you have five minutes left, and then it's the 45 minutes.  I'm strict

24     because of this week's agenda.

25             MR. TRALDI:  I understand and I'm very grateful to both of you.

Page 35793

 1        Q.   Now the word "poturice," yes or no, as you've heard I have

 2     limited time, that refers to Muslims; right?

 3        A.   Among part of the people, yes.

 4             MR. TRALDI:  Can we have P3918.

 5        Q.   As it comes up, sir, during the war, your salary was paid out of

 6     the 30th Personnel Centre; right?

 7             JUDGE MOLOTO:  Can you just repeat the P number?

 8             MR. TRALDI:  P3918.

 9        Q.   Sir, could you answer the question, if you remember it?

10        A.   Yes.

11        Q.   Yes, your salary was paid out of the 30th Personnel Centre;

12     right?

13        A.   Yes, paid as part of the assistance of the Federal Republic of

14     Yugoslavia, and it was my family that received my salary so that they

15     could live at all.

16        Q.   Now, this is an article entitled:  "War for a Fair Peace,"

17     published in Srpska Vojska.  If we turn to page 2 in the English, still

18     on page 1 in the B/C/S at the top of the third column, we see a reference

19     to a speech by General Mladic, and he says in pertinent part that:

20             "A part of our people was blinded by the idea of togetherness,

21     brotherhood, and unity."

22             Those are slogans from the old Communist area Yugoslavia that

23     referred to the idea that the various ethnic groups should live together;

24     right?

25        A.   Brotherhood and unity meant brotherhood and unity with the

Page 35794

 1     Slovenes too, and there were very few of them in, say, Bosnia-Herzegovina

 2     or Montenegro.  So brotherhood and unity between Montenegrins and

 3     Slovenes.

 4             MR. TRALDI:  Could we have page 3 in the English, 2 in the B/C/S.

 5        Q.   We read under the heading "Return of Unity" General Mladic

 6     pointing out as a positive in the creation of Republika Srpska and the

 7     army "the high patriotic awareness of the Serbian people" who, he says,

 8     "had headed a call to join in defence from an Ustasha invasion," and he

 9     says that "came as a result of the clearly defined goals of our struggle

10     at the Assembly Session of Republika Srpska held on the 12th of May,

11     1992."

12             First, like in the Srpska Vojska article we saw yesterday,

13     General Mladic is saying here that the goals of the war are clear; right?

14        A.   It was very small, so I couldn't finds the relevant part.

15     However, I still stand by what I said; namely, that throughout the war

16     there was this objective aimed at the survival of the Serb people, life

17     in their own territory, freedom, and the establishment of lasting and

18     permanent peace.  As for this, I do apologise to you.  I didn't manage to

19     find it in the text so I barely heard what you were saying or, rather,

20     what the interpreter was interpreting.

21             JUDGE ORIE:  Witness, perhaps could the left part being enlarged.

22             I take it it's the first column somewhere in the middle, Mr.

23     Traldi, that you were reading from.

24             MR. TRALDI:  It is.  Just below the heading: "Return of Unity."

25             JUDGE ORIE:  Yes, could that be enlarged so that the witness is

Page 35795

 1     better able to read it.

 2             THE WITNESS: [Interpretation] Yes.

 3             JUDGE ORIE:  Yes.  Could you please read it?  And could you also

 4     read -- a reference is made to the Assembly Session of the

 5     Republika Srpska of the 12th of May in relation to the clearly defined

 6     goals, and could you consider whether what you told us were the

 7     objectives are the ones that were clearly defined during this assembly

 8     session?

 9             THE WITNESS: [Interpretation] Am I supposed to read it out loud,

10     this text?

11             JUDGE ORIE:  No.  You could just read it for yourself and then --

12     because you rightly expressed your concern that you couldn't read it.

13     Now you have read it?

14             THE WITNESS: [Interpretation] Now, yes.

15             JUDGE ORIE:  Yes.  Now, in your previous answer you referred to

16     goals as formulated by yourself, whereas here, in relation to the goals

17     of the struggle, a reference is made to the Assembly Session of the

18     Republika Srpska of the 12th of May.  Those goals defined there and then,

19     are that the same as you mentioned in your answer previously?

20             THE WITNESS: [Interpretation] Listed as at that session, no, but

21     the essence is in what I said.

22             MR. TRALDI:

23        Q.   The goals listed at that session were the strategic objectives;

24     right?

25        A.   Yes.

Page 35796

 1        Q.   And finally, sir, later in this article, and I'm just going to

 2     put the quote to you, President Karadzic is quoted, and he says this

 3     generation of Serbs in the RSK and the Republika Srpska have the duty to

 4     "save the Serbian people and once and for all avoid the danger of

 5     extermination and create a state in which there will be none of its

 6     enemies."

 7             Creating a state in which there would be none of what he termed

 8     the Serb people's enemies, that meant what General Gvero said:  Serbs

 9     living on Serb territory, Muslims living on Muslim territory; right?

10        A.   No.  The enemy does not stand for people.  The enemy is somebody

11     who fights against the system, against the state, or something else.

12     Here, I don't understand that as President Karadzic saying that other

13     peoples should not live in Republika Srpska but those who fight against

14     Republika Srpska cannot and should not live there.  Those who do not

15     recognise that authority.

16             JUDGE ORIE:  Mr. Traldi, your time is --

17             MR. TRALDI:  It is, Your Honour, and I have no further questions.

18             JUDGE ORIE:  No further questions.

19             We'll take break.

20             Mr. Lukic, could you give us any indication -- but, first, we'll

21     ask the witness to be escorted out of the courtroom.

22                           [The witness stands down]

23             JUDGE ORIE:  Mr. Lukic, could you tell us how much time you would

24     need.

25             MR. LUKIC:  I'm trying to calculate.  It's not easy.  By this, I

Page 35797

 1     had several objections now -- that I have to clarify with the witness

 2     now.  So I guess 15, 20 minutes.

 3             JUDGE ORIE:  15, 20 minutes.  I add to this that the Chamber has

 4     some concerns about hearing the evidence of all the witnesses this week.

 5     It's a very tight schedule, and there's perhaps an option to have some

 6     additional time on Thursday, extended session in the afternoon, but the

 7     parties are urged to see that they strictly limit themselves so that we

 8     don't have to send a witness away and then to see that witness back in

 9     four weeks from now.

10             We take a break and will resume at quarter past 12.00.

11                           --- Recess taken at 11.54 a.m.

12                           --- On resuming at 12.19 p.m.

13             JUDGE ORIE:  We're waiting for the witness to be escorted in the

14     courtroom.

15             I do understand that neither party has major problems in having

16     an extended session, if need be, on Thursday, and we are -- although we

17     are preparing for it, of course, if we don't need it, it would be even

18     better.  In the same vein, we'll also consider whether or not to start at

19     9.00 on Thursday which would perhaps --

20                           [Trial Chamber confers]

21             JUDGE ORIE:  Every day to gain some time, half an hour a day, and

22     that's before four weeks non-sitting, and it's also in the interest of

23     your witnesses, Mr. Lukic.  And, of course, you came up with a very tight

24     schedule for this week.  I'm not blaming you for it, but we have to deal

25     with it.

Page 35798

 1             MR. LUKIC:  Although I think it's more due to long

 2     cross-examinations, not to our number of our witnesses.  We brought only

 3     four.

 4             JUDGE ORIE:  Yes, but all viva voce witnesses.

 5                           [Trial Chamber confers]

 6             JUDGE ORIE:  Mr. Lukic, it was also intended that you perhaps

 7     discuss with Mr. Mladic a start at 9.00 exceptionally and -- for a couple

 8     of days.

 9                           [The witness takes the stand]

10             JUDGE ORIE:  Mr. Sokanovic, you'll now be re-examined by

11     Mr. Lukic.

12             Please proceed.

13             MR. LUKIC:  Thank you, Your Honour.

14                           Re-examination by Mr. Lukic:

15        Q.   [Interpretation] Good day, Mr. Sokanovic.

16        A.   Good day, Mr. Lukic.

17        Q.   My colleague Mr. Traldi said that by imposing the immediate

18     danger of war according to the ONO law, and -- one would move from

19     peacetime organisation into wartime organisation.  Had the state of war

20     been declared, would the civilian organs of authority also switch to

21     wartime organisation?

22        A.   Yes, they would.

23        Q.   Actually, on the ground after you arrived to Bosnia and

24     Herzegovina in late July 1992, the territory controlled by the Army of

25     Republika Srpska, in practice, was it under a wartime organisation or did

Page 35799

 1     the civilian organs and the army continue to act in accordance with

 2     peacetime laws?

 3        A.   They acted according to peacetime laws.

 4        Q.   Thank you.

 5             MR. LUKIC: [Interpretation] We need to look at P7391 now, please.

 6        Q.   You were shown this document, the Srpska Vojska newspaper.

 7             MR. LUKIC: [Interpretation] We need to look at page 2 in both

 8     versions.

 9        Q.   At the bottom of the page here, in the B/C/S --

10             MR. LUKIC:  And if we can go down in English version.  Although

11     it was called the second page in English, we obviously have to go to the

12     third page in English, and it's the third paragraph from the bottom,

13     fourth on the screen from the top.

14        Q.   [Interpretation] It states that General Milan Gvero says:

15             "Our greatest value is the unity of the political and military

16     leadership at all levels ..."

17             Can you please tell us what was General Gvero's relationship with

18     President Karadzic?  Their personal relationship between General Gvero

19     and President Karadzic.

20        A.   Well, if I could say it in the briefest possible terms, it was

21     bad overall, with quite frequent verbal disagreements and plenty of

22     dislike.  Some parts of the leadership of the ruling party, for the most

23     part officers of the former Yugoslav People's Army, and particularly

24     General Gvero, because of his previous duties, believed that he was a

25     throw-back from the past and somebody who was a proponent of brotherhood

Page 35800

 1     and unity and other values from the previous system.

 2        Q.   And did President Karadzic make any demands of General Gvero and

 3     the Main Staff regarding their status?

 4        A.   Yes, there were a number of demands.  First of all, there were

 5     requests -- actually, not requests, orders that he should not appear in

 6     the public information media.  Then that he should be replaced and

 7     pensioned off.  And this was something that was explicitly stated twice:

 8     Once at a session of the People's Assembly of Republika Srpska in

 9     Sanski Most; and for the second time at a session of the Assembly of

10     Republika Srpska in --

11             THE INTERPRETER:  The interpreters did not understand the place.

12             JUDGE ORIE:  Could you tell us the Assembly of Republika Srpska

13     was held where?

14             THE WITNESS: [Interpretation] Your Honours, the first assembly

15     session that I meant was in Sanski Most.  And the second one was in

16     Banja Luka.

17             JUDGE ORIE:  Please proceed.

18             MR. LUKIC: [Interpretation]

19        Q.   This is the end of 1992, and we talked about it.  Are you aware

20     that in 1993 President Karadzic scheduled a meeting regarding the

21     replacement of General Mladic?

22        A.   Mr. Lukic, I don't know whether this was in the form of a

23     meeting, but I know that in 1993 the initiative came from the president

24     of the republic to replace the commander of the Main Staff, Ratko Mladic,

25     and then at least one more time there could have been another request

Page 35801

 1     before that, but I remember this one very well because it came after the

 2     fall of the Republic of the Serbian Krajina and the fall of the -- part

 3     of the area of Republika Srpska, in the western part of Republika Srpska.

 4             JUDGE ORIE:  Mr. Lukic.

 5             MR. LUKIC:  Can I consult with the witness?

 6             JUDGE ORIE:  You can consult with -- not with the witness but

 7     with your client.

 8             MR. LUKIC:  My client, yes.

 9             JUDGE ORIE:  Mr. Lukic, but at non-audible volume.  Should that

10     be clear.

11                           [Defence counsel confer]

12             MR. LUKIC: [Interpretation] We need to look at page 7 of this

13     same document in the English version and page 5 in the B/C/S.

14        Q.   This is an interview with General Mladic.  You were asked about

15     the six strategic goals from his statement.

16             MR. LUKIC: [Interpretation] We need to look at the right-hand

17     upper column in the B/C/S version.

18             JUDGE FLUEGGE:  We should enlarge it further.  Yes, only focus on

19     the right column.

20             MR. LUKIC:  Yes.  It's the middle one.  We have the right one,

21     yeah.  And it's the last paragraph in English version.

22        Q.   [Interpretation] General Mladic compares the JNA and the Army of

23     Republika Srpska, but I'm not going to read the whole thing.  But he says

24     about the Army of Republika Srpska:

25             "This is a people's army and a people's army cannot be defeated.

Page 35802

 1     What is the source of the difference in the effectiveness and

 2     organisation of these two armies?  I would say that, apart from our army

 3     having a clearer strategic goal, it is here to protect its own people.

 4     The people are here and, just like its people, it has no place to

 5     retreat."

 6             Does that correspond to what you understood to be the strategic

 7     goals of the fight of the Army of Republika Srpska?

 8        A.   Yes, precisely.

 9             MR. LUKIC: [Interpretation] Could we now look at P6646.

10        Q.   This is your document from November 1994.

11             MR. LUKIC: [Interpretation] We need to look at page 2.

12        Q.   Item 12, you were asked about the masking of offensive activities

13     and that the public was not informed about it.  This was concealed from

14     the public and they were misinformed.

15             MR. LUKIC: [Interpretation] Can we now go back to page 1, item 1

16     of the document, please.

17        Q.   Item 1 states:

18             "In the present context, point out the intensification of Muslim

19     offensive operations, their commitment to the war option, and the

20     hypocritical behaviour of the Croatian side in the civil war on the

21     territory of the former B and H."

22             At that time, in late 1994 thus, was this a misrepresentation of

23     the reality or was this an instruction about reporting truthfully;

24     namely, at that time, were there intensive Muslim offences ongoing at

25     that time and was their commitment to the war option clear?

Page 35803

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

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

 3             THE WITNESS: [Interpretation] Yes, and precisely for this reason.

 4     This instruction was written for the purposes of informing the public.

 5             MR. LUKIC: [Interpretation]

 6        Q.   In paragraph 5 --

 7             MR. LUKIC: [Interpretation] So we need to look at page 2 in the

 8     English version.

 9        Q.   -- where it states in paragraph 5:

10             "Point out the international community's double standards towards

11     the sides in the conflict ..."

12             Is this something that was misinformation or did it correspond to

13     the actual situation on the ground?

14        A.   No, this was realistic.

15             JUDGE ORIE:  Mr. Lukic, the Chamber - and I checked with my

16     colleagues - is puzzled by your questions.  Because number 1 is about the

17     other parties' operations, whereas paragraph 12 is about Serb operations,

18     and there was no suggestion, as far as I understand, that in every

19     respect the instructions were always to -- to not tell the truth on all

20     things but specifically on offensive Serbian operations after having

21     masked them at a later stage to present them as defensive.

22             That is totally unrelated, as far as the Chamber understands,

23     with the matters you're raising now in your questions.

24             Please proceed.

25             MR. LUKIC:  Thank you, Your Honour.  If the Prosecution can

Page 35804

 1     stipulate that the rest of this information is truthful --

 2             JUDGE ORIE:  No, it's not about -- these are instructions.  What

 3     the Prosecution did is to put to the witness that instruction number 12

 4     was an instruction to give false information.  They did not touch upon

 5     the other instructions, whether that would be -- and so therefore,

 6     there's no -- of course, if you want to stipulate, Mr. Traldi, you're

 7     free to do that.  But it is unrelated and there was no suggestion that

 8     all the other instructions would lead to untruthful information.  That

 9     was not suggested in any way.  Only 12 did.  Let's leave it to that.

10             Please proceed.

11             MR. LUKIC:  But the whole document was introduced --

12             JUDGE ORIE:  I said let's leave it to that, Mr. Lukic.

13             MR. LUKIC:  I have to continue with this document, Your Honour.

14             JUDGE ORIE:  Well, not saying you can't continue with the

15     document, but please put questions which are related to what was dealt

16     with in cross-examination.

17             MR. LUKIC: [Interpretation]

18        Q.   Mr. Sokanovic, according to you, the other items in this

19     document, were they intended to misinform the public or was the intention

20     to inform the public properly?

21        A.   The intention was to properly inform the public, and this

22     guidance was drafted as a supplement to the instruction about informing

23     the public, and it had to do with the actual or current political and

24     military situation in the former Bosnia and Herzegovina.

25        Q.   Very well.

Page 35805

 1             MR. LUKIC: [Interpretation] Can we have page 2 now in B/C/S.  Let

 2     us look at paragraphs 9 and 12 in the English version.

 3        Q.   Was there an order issued by the president of the republic,

 4     Mr. Sokanovic, about a ban on providing information in the media about

 5     the movements, formation names, and insignia of VRS units?

 6        A.   Yes, there was.

 7        Q.   Revealing offensive activities, would that mean disclosing a

 8     military secret?

 9        A.   Yes.  And that was already indicated in previous documents, how

10     detrimental such things would be.

11        Q.   What would you say?  What was your intention?  In paragraph 12,

12     were you implementing paragraph 9?

13        A.   Yes, precisely.

14             JUDGE ORIE:  Without leading, Mr. Lukic.

15             MR. LUKIC:  It's hard to not lead at least a bit and stay in a

16     time-frame.

17             JUDGE ORIE:  You should properly examine the witness.

18             MR. LUKIC: [Interpretation]

19        Q.   In 1994 in November, did the Army of Republika Srpska capture

20     anything on the ground?

21        A.   No.

22        Q.   Who was carrying out offensive activities in 1994 in

23     November when this information was being sent, when this paper was being

24     sent?

25        A.   Offensive activities were carried out by the so-called Army of

Page 35806

 1     Bosnia and Herzegovina and the Croatian Democratic Council, and in that

 2     period, that is to say, just before this, they took about 250 square

 3     kilometres of territory of Republika Srpska.

 4        Q.   Thank you.  Let us just look at P6915 now, please.

 5             JUDGE MOLOTO:  Just say the number, please, again, Mr. Lukic.

 6             MR. LUKIC:  Yes, it's P6915.  [Interpretation] We had the same

 7     problem with calling up this document when my colleague Mr. Traldi was

 8     calling it.

 9        Q.   So we have a document of the Main Staff of the Army of

10     Republika Srpska before us.  It's dated the 24th of April, 1993.  The

11     name of General Manojlo Milovanovic is typewritten at the bottom of the

12     document.  Lists are being required of different POWs and detained

13     civilians.

14             Do you know that in the territory of Republika Srpska there were

15     civilian prisons?

16        A.   There were prisons under the control of the Ministry of the

17     Interior.

18        Q.   You were asked a lot about prisons and camps.  Apart from that

19     visit a few days after you arrived in the territory of Bosnia-Herzegovina

20     yet again from Serbia, did you have any duties that had to do with

21     prisons and camps in territory that was under VRS control?

22        A.   No, I did not have any such duties.

23        Q.   Did you have any duties related to the interrogation of detained

24     persons, or was this within somebody else's purview?

25        A.   No, this does not belong to the sector for morale and religious

Page 35807

 1     affairs.

 2             JUDGE ORIE:  Mr. Lukic, the witness repeatedly told us this in

 3     response to the questions put by Mr. Traldi, so to that extent it's

 4     repetitious and it's not -- please proceed.

 5             MR. LUKIC:  Okay.  I have one more question.

 6        Q.   [Interpretation] Mr. Sokanovic, just this.  Do you know which

 7     prisoners General Milovanovic was asking for through this document that

 8     is before us?

 9        A.   Mr. Lukic, I said I think a moment ago that this was the first

10     time I'm seeing this document.  Now I managed to look at it a bit more,

11     and I see that information is being requested about prisoners of war,

12     Serbs from the territory of Republika Srpska that are in the prisons of

13     the Republic of Croatia and Herceg-Bosna and Serb and Montenegrins from

14     the territory of the former SRBiH and national minorities from the

15     territory of Yugoslavia that are in the prisons of the Republic of

16     Croatia and Herceg-Bosna but were members of the JNA, then civilians who

17     are in prisons in the Republic of Croatia and Herceg-Bosna, then

18     civilians from the territory of the former BiH that are in the villages

19     and towns of the Republic of Croatia and Herceg-Bosna, then captured

20     Croatian civilians from the territory of the Republic of Croatia and

21     Herceg-Bosna who are in prisons of Republika Srpska.

22        Q.   All right.  You read that from the document.  But do you know

23     which prisons General Milovanovic was referring to?  Did you talk to him

24     about that?  Do you have any personal knowledge about this activity?

25        A.   I did not talk to him.

Page 35808

 1        Q.   Very well.

 2             MR. LUKIC: [Interpretation] Let's just look at a document

 3     briefly, P7395.

 4        Q.   This is a document of the Command of the 1st Zvornik Brigade.

 5     It's signed by Colonel Vinko Pandurevic.

 6             You were asked what the word "poturice" meant.  In the first

 7     paragraph, from the very beginning, it says:

 8             "The moment has come when the issue of liberating the Serb lands

 9     from Poturice will finally be resolved in this area by a resolute and

10     successful action of our forces.  Obviously, the enemy cannot be allowed

11     to bring into question the fate of the Serb people in this area anymore

12     by countless violations of truces signed to date."

13             Who is it that is violating the truces?  The soldiers of the

14     other side or civilians?

15        A.   Soldiers, of course.  How could civilians do that?  They do not

16     have the force to do that, and they are not signatories.

17        Q.   All right.  Let us now read the second part that was read out to

18     you, the beginning of the second page in B/C/S.

19             MR. LUKIC:  It's pretty condensed in English version.

20             JUDGE ORIE:  The part that was quoted was the lower part.

21             MR. LUKIC:  Yes, it's beginning --

22             JUDGE ORIE:  "Adequate response..."

23             MR. LUKIC:  -- at the beginning of the first page and it goes

24     onto the second page.

25        Q.   [Interpretation] This is what was put to you:

Page 35809

 1             "The adequate response of our forces meant that we realised that

 2     there would be no peace and security in Semberija and Donja Podrinje

 3     until the Poturice were completely defeated and driven out of this area

 4     in the fight for a single Serb territory.  Our response to the enemy

 5     offensive enemy combat operations have been going on for one month in our

 6     brigade's zone of responsibility."

 7             When you read this in context, how would you understand the word

 8     "poturice" here?  Does it refer to Muslim civilians --

 9        A.   No, no.

10        Q.   -- or their military forces?

11        A.   What is meant here is military forces.  Because it is against

12     them that the offensive was taking place or, rather, it was a response to

13     their offensive, and it says in the next sentence that this is a

14     responses to their offensive.

15        Q.   Now let us go back to page 1 of this version.

16             MR. LUKIC: [Interpretation] Line 11 in B/C/S.  And the last

17     third -- the fifth line from the bottom of the first paragraph in the

18     English version.  It starts with the word:  "And ..."

19        Q.   This is what it says.  I quote:

20             "And so the Poturice launched an all-out offensive against

21     Majevica and Vlasic and other strategic features and areas in

22     Republika Srpska."

23             So this part, does it have to do with the military or civilians?

24        A.   It is only military forces that can launch an offensive.  So it

25     is the army, not civilians.

Page 35810

 1        Q.   Thank you, Mr. Sokanovic.  That is all we had.  Thank you.

 2        A.   Thank you.

 3                           [Trial Chamber confers]

 4             JUDGE ORIE:  Mr. Traldi, do you have any further questions?

 5             MR. TRALDI:  I do.  Less than ten minutes.  I'll be brief.

 6             MR. LUKIC:  And we have one translation issue, I'm sorry.

 7             JUDGE ORIE:  Yes, let's first hear that one.

 8             MR. LUKIC:  In this part -- I was just warned by my colleague

 9     Ivetic that in this part it says "Muslims" not "poturice."  So it was

10     actually --

11             JUDGE ORIE:  Where is that in?

12             MR. LUKIC:  It's --

13             JUDGE ORIE:  Could we have the right page in both B/C/S and

14     English?  Because the word "poturice" is mentioned several times in the

15     document.

16             JUDGE MOLOTO: [Microphone not activated]

17             JUDGE ORIE:  Are we still on page 1?

18             MR. LUKIC:  Yes, we are, Your Honour.

19             JUDGE ORIE:  Which line in B/C/S?  To be compared with which line

20     in ...

21                           [Trial Chamber confers]

22             MR. LUKIC:  No, we have to -- we stand corrected.

23             JUDGE ORIE:  You stand corrected.  Okay.

24             MR. LUKIC:  Yeah.

25             JUDGE ORIE:  That's fine.

Page 35811

 1             Mr. Traldi.

 2                           Further cross-examination by Mr. Traldi:

 3        Q.   Stay on this document, sir.  Second paragraph,

 4     Lieutenant-Colonel Pandurevic or in Lieutenant-Colonel Pandurevic's

 5     document, we read:

 6             "We must dash for all time their hope of creating a Muslimanija

 7     extending to the Drina and the Sava and make it possible for our people

 8     to return to their centuries-old homes, Vitinice, Rastosnice, and other

 9     Serbian places in the area."

10             MR. TRALDI:  Now, can we have 65 ter 02559, page 296.  In the

11     B/C/S.  296 in the B/C/S.

12             If we go to line 28, we see Vitinice.  And if we turn to the next

13     page for the 1991 numbers, we see on the left side the columns and the

14     headings total persons, Croats, Muslims, Serbs.  If we scroll down to

15     line 28, we see that before the war Vitinice was a village comprised of

16     2900 [Realtime transcript read in error "2800"] Muslims, about 200 Serbs.

17        Q.   So the homes that Lieutenant-Colonel Pandurevic is saying "our

18     people should be able to return to," those are homes that at the

19     beginning of the war were inhabited by Muslims; right?

20        A.   Well, this is the first time I'm seeing this, so it's hard for me

21     to give any comment.  But again, I'm saying it would be best to ask

22     Mr. Pandurevic what it was that he meant.  But homes do not date back

23     only to the Second World War.  There are some that date back to before

24     that, that are older than that.

25        Q.   So do you --

Page 35812

 1             JUDGE FLUEGGE:  Just a correction for the transcript.  In line 16

 2     of page 58, Mr. Traldi said "2900" Muslims.

 3             MR. TRALDI:  Thank you, Your Honour.

 4        Q.   So what you said just now, are you agreeing with

 5     Colonel Pandurevic that it would appropriate for villages that had been

 6     Serb at the Second World War, before the Second World War, even older

 7     than that, to be made Serbian again as a result of operations conducted

 8     in 1995?

 9        A.   No, I do not agree.  I think - and that's what I've been

10     explaining all along - that the territory of Republika Srpska should not

11     be populated by the Serb people only, and the territory that would be

12     under the political leadership of the Croat people should not be

13     populated by Croats only.  And the same goes for the third sides.  And

14     that is not possible even if somebody wanted to do that.

15        Q.   Your Honours, I won't tender this.  I assume my colleague agrees

16     that I've correctly recited the pre-war census figures for this village?

17             JUDGE ORIE:  Mr. Lukic, no problem as far as that is concerned?

18     That's on the record.

19             Please proceed.

20             MR. TRALDI:

21        Q.   Mr. Lukic asked you about your order in November 1994 to

22     maximally mask offensive activities and present them at their advanced

23     stages as defensive or as counterattacks.  First, did I correctly

24     understand your answer that in giving that instruction you understood

25     yourself to be implementing an order from the supreme commander,

Page 35813

 1     President Karadzic?

 2        A.   Mr. Prosecutor, it's not clear to me which instruction you -- you

 3     mean, because very different instructions would come from the president

 4     of the republic, Mr. Karadzic.

 5        Q.   Well, you issued an instruction to mask offensive activities

 6     maximally, you issued an instruction to present them at the advanced

 7     stages as counter-attacks or -- part of the natural right to

 8     self-defence.  On re-direct, you said you had believed yourself to have

 9     been implementing point 9 in the same document, an order from Karadzic

10     about military secrets.  So I want you to confirm now that in ordering

11     the offensive activities to be masked maximally, presented as defence,

12     you were implementing an order from Karadzic; right?

13        A.   Mr. Prosecutor, first of all, I cannot order anybody.  I don't

14     have that authority.  I could give guidance or instructions.  The

15     document refers to a document by the president of the republic,

16     Mr. Karadzic, and I assume that it was drafted on the basis of what was

17     written in that order.

18             As for the masking, masking is one of the measures used to

19     protect secret data about the deployment, size, strength, intentions --

20             JUDGE ORIE:  Was this what you asked, Mr. Traldi?  The second

21     part not.

22             You have answered the question.

23             MR. TRALDI:

24        Q.   Finally, sir, Mr. Lukic asked you about the relationship between

25     President Karadzic and General Mladic and President Karadzic and

Page 35814

 1     General Gvero.  Those generals kept their positions on the Main Staff

 2     throughout the war; right?  Yes or no.

 3        A.   Yes.

 4        Q.   Now, could we have P3076, page 18 in English and 13 in B/C/S.

 5             As it comes up, I'll remind you of the article we saw on

 6     cross-examination where President Karadzic noted the duty of the Serbian

 7     people to avoid the danger of extermination and create a state in which

 8     there will be none of its enemies.

 9             Now, we need page 18 in the English.  This is part of the

10     transcript of the 37th Session of the Bosnian Serb Assembly.

11     General Mladic is speaking, and he says at the end of this long

12     paragraph --

13             JUDGE ORIE:  Could we first give an opportunity to the witness to

14     find it and to be able to follow your reading, Mr. Traldi.

15             MR. TRALDI:  And I'd --

16             JUDGE ORIE:  And if you then slowly read it.

17             MR. TRALDI:

18        Q.   The end of this long paragraph, we read General Mladic say:

19             "The next thing is that this is our historical chance to create a

20     state.  Not any kind of state, but an all-Serbian state of a round shape

21     with access to the sea and horogravske and horografske facilities and as

22     little enemies as possible, those who could be our potential enemies and

23     raise against us again in a few years."

24             Sir, what I'm putting to you is regardless of any temporary

25     disagreements that you may have mentioned on re-direct, when it came to

Page 35815

 1     what mattered, the purpose of the war, President Karadzic and

 2     General Mladic were in such lockstep that they described that purpose in

 3     almost the same terms.  That's the truth; right?

 4        A.   I cannot confirm that this in case because then I would need to

 5     read the entire speech.  Because one sentence, even if it's in agreement

 6     with the other person, in this case the president of the republic, does

 7     not mean that there wasn't a conflict between them.  I stand by my words

 8     that there were serious clashes.

 9        Q.   I have no further questions for this witness, Your Honours.

10             JUDGE ORIE:  Thank you, Mr. Traldi.

11             Mr. Sokanovic, this concludes your testimony.  I would like to

12     thank you very much for coming a long way to The Hague and for having

13     answered all the questions that were put to you, questions put to you by

14     the Defence, by the Prosecution, by the Bench.  I wish you a safe return

15     home again.  You play follow the usher.

16             Mr. Mladic, I again and again have to emphasise that you should

17     not speak aloud.

18                           [The witness withdrew]

19             JUDGE ORIE:  Mr. Ivetic, may I take it that you'll examine the

20     next witness.

21             MR. IVETIC:  That is correct, Your Honour, and he should be in

22     stand by in the room.

23             JUDGE ORIE:  Yes.  Now, what would you prefer, to take the break

24     now so that to -- and then that we would resume at 1.30 so that you have

25     an uninterrupted 45 minutes, or would you like to start for five minutes?

Page 35816

 1             MR. IVETIC:  I think the first option is more agreeable so we

 2     have an uninterrupted ...

 3             JUDGE ORIE:  Then we'll take the break first and we'll resume at

 4     1.30.

 5                           --- Recess taken at 1.09 p.m.

 6                           --- On resuming at 1.33 p.m.

 7             JUDGE ORIE:  We're waiting for the next witness to be escorted in

 8     the courtroom.

 9             Mr. Lukic, I understand that the Defence has problems with

10     extended sessions.

11             MR. LUKIC:  Although I said -- yes, Your Honour.  Although I said

12     at the beginning that we do not have a problem, I was reminded that we

13     have scheduled a lot of meetings before we depart for our field trip.  We

14     travel on Saturday to investigate Tomasica, and we have to have really

15     many meetings on Thursday and Friday already scheduled.

16             JUDGE ORIE:  Yes.  I had as well.  I moved them in order to --

17             MR. LUKIC:  We do not have where to move them.  We will be absent

18     for a month.

19             JUDGE ORIE:  Okay, Mr. Lukic.  I do understand that your schedule

20     is so busy that's not even a way to move for two hours.  I leave it to

21     that at the time being.

22             The parties are invited to further discuss whether they can fit

23     the examination of the remaining witnesses of this week within an agreed

24     time schedule.  Again, the Chamber is available for extended sessions on

25     Thursday.  If not, then, of course, you should take measures so as to not

Page 35817

 1     leave a witness here for four weeks.

 2             MR. LUKIC:  What we wanted to inquire with the Prosecution,

 3     probably that should be a topic of our conversation, is we might send one

 4     witness back.

 5             JUDGE ORIE:  Yes, that should be the last-resort solution but

 6     finally it might come to that.

 7                           [The witness entered court]

 8             JUDGE ORIE:  Witness, it's not very polite to continue with our

 9     conversation when you enter the courtroom.  Mr. Pajic, I presume.

10             Mr. Pajic, before you give evidence, the Rules require that

11     you -- yes.  Before you give evidence, the Rules require that you give a

12     solemn declaration.  The text is now handed out to you.  May I invite to

13     you make that solemn declaration.

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

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

16                           WITNESS:  VELO PAJIC

17                           [Witness answered through interpreter]

18             JUDGE ORIE:  Thank you.  Witness, please be seated.  You'll first

19     be examined by Mr. Ivetic.  You find Mr. Ivetic to your left, standing.

20     Mr. Ivetic is a member of the Defence team of Mr. Mladic.

21             Mr. Ivetic, please proceed.

22             MR. IVETIC:  Thank you, Your Honour.  Can first my colleague

23     Mr. Lukic be excused.  He has to attend to something and --

24             JUDGE ORIE:  Yes, one of his meetings perhaps.  Yes, you are

25     excused, Mr. Lukic.

Page 35818

 1                           Examination by Mr. Ivetic:

 2             MR. IVETIC:

 3        Q.   Good day, Mr. Pajic.  I would ask you to state your full name so

 4     that we can have it properly entered into the trial record.

 5        A.   First of all, I would like to greet all those present in the

 6     courtroom.  I am Velo Pajic.  I come from Rogatica, Republika Srpska,

 7     Bosnia-Herzegovina.

 8        Q.   And, sir, have you testified previously at this Tribunal as a

 9     witness?

10        A.   Yes, in November 2008 in the Popovic case.

11             JUDGE MOLOTO:  Mr. Ivetic, I note that in the summary provided

12     the witness was born in the 11th century; is that correct?

13             MR. IVETIC:  That's definitely an error.  Without having it in

14     front of me, but I'm sure it's an error.  I will address that with the

15     witness, Your Honours.

16        Q.   Sir, could you tell us where and when you were born?

17        A.   I was born on the 28th of July, 1960, in Rogatica, the

18     then-Republic of Bosnia-Herzegovina.

19        Q.   And, sir, can you briefly outline for us the educational

20     institutions that you attended, both civilian and military in nature?

21        A.   I completed elementary school in 1975 in Borike near Rogatica,

22     and then I completed the secondary military school of the land forces in

23     Belgrade, the communications section of that school.

24        Q.   And upon completion of your education, did you become a member of

25     the military?

Page 35819

 1        A.   Yes.  Upon completion of my schooling, I joined the

 2     Yugoslav People's Army, and my rank was sergeant.

 3        Q.   Okay.  What were your total years of service within the military

 4     during your career?

 5        A.   I spent the period from 1979, from the 18 -- until the 18th of

 6     May, 1992 in the Yugoslav army, not counting the years of my schooling.

 7     That was the period I spent in the Yugoslav People's Army.  Then I was in

 8     the Army of Republika Srpska from the 18th of May, 1992, until the 1st of

 9     April, 1995.  Then I spent the rest of my time until retirement in the

10     Podgorica garrison --

11             THE INTERPRETER:  And the interpreter kindly asks the witness to

12     repeat the other information.

13             MR. IVETIC:

14        Q.   Could you repeat the date when you stopped serving in the Army of

15     Republika Srpska?  I believe that is what is needed.

16        A.   Until the 1st of April, 2002.

17        Q.   The date when you left the Army of Republika Srpska.  Was that

18     2002 or some other date?

19        A.   Yes, 2002.

20        Q.   Okay.  And what was the highest rank that you attained prior to

21     your retirement?

22        A.   The highest rank was captain.  I was captain when I retired.

23        Q.   Okay.  And how did your service in the VRS end?

24        A.   From the 18th of May, 1992, until the 1st of April, 2002, I

25     served in the 67th Communications Regiment of the Main Staff of the Army

Page 35820

 1     of Republika Srpska performing the duties of commander of the 2nd Platoon

 2     of the frequency-carrying devices of the 4th Communications Garrison.  I

 3     served in the special purpose facility Goljak 1, or G-1 for short.

 4        Q.   In April of 2002 when you left the VRS, where did you go?  You

 5     indicated that you were in a garrison in Podgorica.  Could you repeat

 6     where you went and where you retired?

 7        A.   Once I completed my term in the Army of Republika Srpska, on the

 8     1st of April, 2002, I went to the Podgorica garrison as commander of a

 9     radio-relay node which was located in the Lofcin [phoen] facility near

10     Podgorica, and then on the 31st of December 2003 I was relieved of that

11     post.

12        Q.   And within which armed forces was that?

13        A.   The Army of Yugoslavia, and then it was renamed as the Army of

14     Serbia and Montenegro.

15        Q.   Now I want to take you back to the beginning of 1992 when

16     tensions broke out in Sarajevo.  To what post or position were you

17     assigned within the JNA at that time?

18        A.   Once I completed military school, I went to work at the garrison

19     in Sarajevo military post 1519.  And then I worked at the Secretariat for

20     National Defence --

21             THE INTERPRETER:  Could the witness please slow down.

22             MR. IVETIC:

23        Q.   Sir, [Interpretation] could you please speak more slowly so that

24     the interpreters could catch what are you actually saying.

25        A.   Very well.  So after 1985 I was sent to Konjic where special

Page 35821

 1     purpose facilities were located, which were maintained by my unit, the

 2     one from military post 1519, where I remained until 1992, the 9th of May,

 3     1992.

 4             The special purpose facilities, if I may clarify, were intended

 5     for the command and control of the armed forces of the former SFRY in war

 6     time by the Presidency, so it was the facility -- DILJ0 was the war time

 7     command post of the former Yugoslavia.  At the time, the -- a facility

 8     D-1 was also there.  It was a radio-relay station which was linked with

 9     D-0, and the distance between them was 1.5 kilometres.

10        Q.   [In English] And as far as D-0 is concerned, what kind of

11     military structure or building was that?

12        A.   I already said that these were special purpose underground

13     facilities where there were rooms located for control and command, where

14     the communications centre was situated, and the engine and electrical

15     facilities for the operation of the facility in special circumstances.

16        Q.   And what, sir, were your precise duties within the special

17     purposes facility DILJ0 or D-0 at Konjic?

18        A.   I was the commander of the section.  My task was to maintain the

19     telephone devices and the main frequency-carrying devices.

20        Q.   Was feature D-0 operational or functional prior to the outbreak

21     of war in Bosnia-Herzegovina?

22        A.   D-0 was operational.  I think it began to work in Trnovo and it

23     was first launched in 1981.

24        Q.   Okay.  How long in 1992 did you stay at that post, the feature

25     D-0, at the Konjic garrison?

Page 35822

 1        A.   In 1992, sometime in early 1992, I was transferred to the T-1

 2     facility because I completed higher school and I received the rank of

 3     second-lieutenant.  So I'm talking about the D-1 facility, which is

 4     1 kilometre or 1.5 kilometres away.  I was the commander of that

 5     facility.  I stayed there until 9th of May, 1992.

 6             Let me just remind you that D-0, D-1, and T-1 were facilities

 7     which were encircled by the Croat-Muslim forces.  The encirclement lasted

 8     sometime from February until the 9th of May when we managed to pull out

 9     from the encirclement.  We had to leave that area on foot.  There were

10     about 38 of us senior officers, and we were joined on the way by

11     civilians, women, children, and then we reached another sector.

12             So I repeat again:  We passed through the lines of the enemy

13     forces, of the KOS forces and the Green Berets, and we came to the

14     Bijelasnica mountain, from where we were transferred to the command of

15     the 398th Brigade by choppers in the evening on the 9th of May, 1992.

16        Q.   During the time-period that were encircled by these forces from

17     February until the 9th of May, how did you and others that were at that

18     location survive in terms of supplies and food and the like?

19        A.   During the last month, it was very difficult.  Let me just remind

20     you that those facilities were being supplied with food for the next six

21     months.  So this happened in November.  Since this was already May, it

22     meant we were running low on food, and there were many more of us than

23     during peacetime periods so that we were forced to eat mouldy crackers

24     and there were some other dry foods that we had to eat, just basic

25     foodstuffs.

Page 35823

 1        Q.   You indicated that eventually the -- you were transferred by

 2     choppers to the command of the 398th Brigade.  Could you tell us in what

 3     city that brigade command is located where you were transferred by

 4     helicopters?

 5        A.   The brigade command.  Earlier there were three communication

 6     regiments, later this 398th Brigade was formed.  Its seat was in

 7     Belgrade.

 8        Q.   Now, in terms of the JNA personnel that had been under

 9     encirclement with you at the facility T-1 who were withdrawn to Belgrade

10     by helicopters, what was the ethnicity of those personnel?

11        A.   At that time all the ethnic groups were represented there.  There

12     were ethnic Croat, ethnic Muslims.  We had ethnic Albanians there as

13     well.

14        Q.   Okay.

15        A.   That is to say, we all got out of there together, including these

16     civilians that joined us.  They were taken to the garrison in Belgrade,

17     all of that by helicopter.

18        Q.   And how long did you stay in Belgrade?

19        A.   I stayed in Belgrade from the 9th of May in the evening until the

20     18th of May, 1992.

21        Q.   And where did you go after the 18th of May, 1992?

22        A.   After that day, I was transferred in a service vehicle to

23     Han Pijesak, the area of Crna Rijeka.

24        Q.   Okay.  And just to complete the circle, to which unit did you

25     belong at the time that you were in Crna Rijeka after the 18th of May,

Page 35824

 1     1992?

 2        A.   The unit where I served in Crna Rijeka from the 18th of

 3     May onwards was the 67th Communications Regiment of the Main Staff of the

 4     Army of Republika Srpska, the company for communications for garrison

 5     communications, the commander of the 2nd Battalion for frequency-carrying

 6     devices.

 7        Q.   Now, as commander of this 2nd Platoon within the

 8     67th Communications Regiment, can you tell us what the strength in terms

 9     of manpower of that platoon was in reality when you became its commander?

10        A.   It was just me on my own, one.

11        Q.   Did the manpower of that platoon change during the duration of

12     the war and the duration of your time at Crna Rijeka?

13        A.   Well, I don't know.  Actually, yes, later.  I got this soldier

14     who was doing his military service all the time, so basically it was I

15     and that soldier who were there, in that platoon.

16        Q.   Now, what was the manpower strength of that platoon supposed to

17     be per establishment protocol?

18        A.   According to establishment, about 25.

19        Q.   Now, you already told us earlier that you were at the Goljak 1

20     feature.  Could you tell us what is the Goljak 1 feature?  What kind of a

21     structure or installation is it?

22        A.   Goljak 1, abbreviated as G-1, was a special purposes facility.

23     They were called D and M and G features, and they were envisaged for

24     command and control in wartime conditions; specifically, G was envisaged

25     as the command post in wartime of the then-7th Army.

Page 35825

 1        Q.   And which command post of the 7th Army of the former SFRY forces

 2     was this feature Goljak 1 intended to be?

 3        A.   Goljak was in Han Pijesak in the area of Crna Rijeka.  That's

 4     about 8 kilometres away from Han Pijesak.  And the command post of the

 5     7th Army was in Zlatiste in Sarajevo - the war time command post, I

 6     repeat.

 7        Q.   What were your precise duties within this position as commander

 8     of the 2nd Platoon within the 67th Communications Regiment?

 9        A.   My duties were to establish and maintain radio relay and wire

10     communications.

11        Q.   And how long did you spend working at this same physical location

12     at that same position?

13        A.   Ten years.  Or, rather, nine years, ten months, approximately.

14     The 18th of May, 1992, until the 1st of July, 2002.  Almost ten years.

15        Q.   Did your duty post or position title ever change?

16        A.   Yes.  In 1999, I became commander of the G features.  I'm saying

17     G features because there was also G-2 and G-3; in addition to G-1, that

18     is.

19        Q.   Were these additional features G-2 and G-3 outfitted and

20     operational during the time-period of the war; that is to say, from 1993

21     to 1995?

22        A.   G-2 was partly equipped; that is to say, there were certain

23     premises but the communications were not installed.  Also, the bathroom

24     facilities did not function.  And G-3, the building was just set up but

25     it was not properly outfitted.

Page 35826

 1        Q.   Okay.  I'd like to take a look together at a Prosecution exhibit,

 2     P6848 in e-court.  Sir, when that comes up on your monitor, I'll ask you

 3     first if you recognise what is depicted in that picture.

 4             MR. IVETIC:  If we could perhaps have just one copy and enlarge

 5     it, that might assist us all.

 6        Q.   Sir, do you recognise what is depicted in this picture?

 7        A.   Yes, I do.  This is the overground building of G-1, and it was

 8     called Vila Javor.

 9        Q.   Now you say this is the overground building of G-1.  Where in

10     relation to this building that we have on our screen is the entrance to

11     the underground facility of G-1?

12        A.   This facility was used not only in this case but in all other

13     such cases.  It was just used as a disguise for entering the underground

14     facility.  You enter through this door or through the garage door, and

15     then you would go further on into the underground facility, G-1.

16        Q.   Okay.  Now, I would like to ask you what kind of communications

17     systems were available to the Main Staff of the VRS at Crna Rijeka at

18     G-1?

19        A.   In G-1, there was an automatic telephone exchange that was called

20     OM 60/250, automatic three digit numbers.  And then there was also an

21     exchange table, as we called it, for communication between direct and

22     automatic connections.  Then there was also a room where there were

23     telephones, or rather frequency-carrying devices.  Then there was a room

24     where telegraphs were, teleprinters, and also the encryption station.

25     Teleprinter encryption station.

Page 35827

 1        Q.   And just to be clear, where was the command of the Main Staff of

 2     the VRS located at Crna Rijeka?

 3        A.   The command of the Main Staff was a kilometre away from this

 4     Vila Javor facility.  It was in prefabricated buildings about 1 kilometre

 5     away from this facility, and the commander of the Main Staff,

 6     General Mladic, was in Vila Javor, that facility.

 7        Q.   What kinds of communications technology were available to the

 8     Main Staff during the war to communicate with those outside of

 9     Crna Rijeka?

10        A.   There was a communications system and these were wire

11     communications, radio communications, and radio-relay communications.

12        Q.   Okay.  I would like to first focus on radio-relay communications,

13     the last one you mentioned.  Could you briefly explain for us how those

14     functioned and -- to describe the difference between radio-relay

15     communications and radio communications which was the second of the items

16     that you identified?

17        A.   Radio-relay communications were used for transmitting speech and

18     written material through wireless telecommunications, through

19     electromagnetic waves that were modulated at higher frequencies, and

20     through antennae they were transmitted to the other side.  In order -- I

21     mean, I a radio relay devices, I mean, the ones that we had at the time

22     in that period were as follows:  RRU-800, FM-200, SNC-1306B, and RRU-1.

23     Those were the types that we had, and there had to be other equipment

24     plugged into that.  Now, it depends on whether these were protected or

25     unprotected communications.

Page 35828

 1             THE INTERPRETER:  Interpreter's note:  Could the witness start

 2     again now with the specific communications.

 3             MR. IVETIC: [Interpretation]

 4        Q.   The interpreters could not follow the last part of your answer.

 5     Could you please repeat the last part after you identified RRU-1.  And

 6     then you said that the difference in relation to other equipment is, and

 7     then could you please complete what it was that you were trying to say.

 8        A.   I listed the types of equipment.  Once again --

 9             THE INTERPRETER:  Interpreter's note:  Could the witness please

10     slow down.  Thank you.

11             JUDGE ORIE:  Witness, you should really slow down.  Otherwise,

12     parts of your words will be lost.

13             I leave it in your hands, Mr. Ivetic, where to resume.

14             THE WITNESS:  Okay.

15             MR. IVETIC:

16        Q.   Sir, if you could resume speaking slowly.  You had just finished

17     talking about the RRU-1 and said it depended on equipment that could be

18     attached to all these RRU devices, whether they were protected

19     communications or ...

20             And that is where we lost the translation, so if could you please

21     take up your answer from approximately there and repeat it, this time

22     more slowly, so that the interpreters can catch every word.

23        A.   Very well.  So there were two types of radio-relay

24     communications.  There was one type that were protected and the other

25     type that were unprotected.  Protected radio-relay communications were

Page 35829

 1     between radio-relay stations, and this also goes for unprotected ones.

 2     It was 50 kilometres.

 3             In order for protected communication to be communicated, we need

 4     FM-200, then antennae, then AND 310, and of course a generator.

 5             In order to have unprotected communication, analogous, we also

 6     need two radio-relay communication stations 50 kilometres away.  We need

 7     a proper signal; that is to say, an excellent signal that can guarantee

 8     communication.  Everything else could be a problem for relaying written

 9     communication and speech.  For that, we would need RRU-800, SNC-1306B,

10     12K and V120.

11             Again, I'm saying that their frequency for RRU-800 and for FM-200

12     is from 610 to 960 megahertz.  For SNC, it is a higher frequency, 4.400

13     to 4.600 megahertz and from 4.800 to 5.000 megahertz.

14        Q.   Now, in relation to the radio-relay communications between the

15     Main Staff and subordinated units, were those of the -- of the encrypted

16     and protected or of the open type or unprotected type that you have

17     described?

18        A.   Between the Main Staff and subordinated units, it went without

19     saying; that is to say, the logistic command post, the staff units of the

20     1st and 2nd Krajina Corps, then the Eastern Bosnia Corps, the

21     Sarajevo-Romanija Corps, the Presidency, the Army of Yugoslavia, we had

22     both.  That is to say, we had protected and unprotected types of

23     radio-relay communications.

24        Q.   You've listed several, and I'm looking at the transcript, what

25     about the radio-relay communications between the Main Staff and the

Page 35830

 1     Drina Corps?

 2        A.   Yes, I forgot to mention that.  There was also radio-relay

 3     communication with -- along two relay routes.  One was protected and the

 4     other one was unprotected.  This one, the unprotected one, was RRU-800,

 5     RM4, where the frequency distribution of channels 3- to 800 kilohertz,

 6     and the protected one functioned, and the number was 0674, and the

 7     previous one was 0607.

 8        Q.   And now between the unprotected and the protected radio-relay

 9     routes between the Main Staff and the Drina Corps, for what type of

10     communications was each used during the war?

11        A.   The secured route, 0674, which after the change, because of the

12     same direction on the neighbouring facility was changed to 0658, operated

13     eight protected channels.  This was done on the relay device FM-200.

14     Multi-challenge device with a time distribution or frequency binary or

15     secured transfer of the channel.  These eight channels were connected

16     directly to channels to an intercom or a telephone exchange on the other

17     side.  The commander of the Main Staff of the Drina Corps.  The second

18     channel was the operations centre of the Main Staff of the Army of

19     Republika Srpska, the operations centre of the Drina Corps.  The third

20     channel was the exchange of the Main Staff of the RS, the exchange of the

21     Drina Corps.  And then the fourth channel was used for an automatic

22     telephone number from the existing exchange, which was at the G-1

23     facility, 332, that was the phone number.  The telegraph had an

24     alternative.  The telegraph communications were -- meaning the transfer

25     of written information, since they were secured, encrypted, where the

Page 35831

 1     data was processed, they could be transferred either through the analog

 2     or the digital system.  So if one route was cut, we had an alternate

 3     route where this could function.

 4             So let me go back to these encrypted telegrams.  They were

 5     protected on the digital and the analogue route, and all of that was

 6     processed in the range from 600 to 900 megahertz.  Now, I'm talking about

 7     the FM-200 and the RRU-800 devices.

 8             JUDGE ORIE:  Mr. Ivetic, I need one minute before we adjourn so,

 9     therefore --

10             MR. IVETIC:  Let's stop here then.

11             Witness, we'll adjourn for the day soon.  We'd like to see you

12     back tomorrow morning, 9.30 in this same courtroom.  Before you leave, I

13     instruct you that you should not speak or communicate with whomever about

14     your testimony, whether that is testimony you've given today or whether

15     it's testimony still to be given tomorrow or even the day after tomorrow.

16     If that is clear to you, you may follow the usher.

17             THE WITNESS: [Interpretation] Yes, that's clear.

18             JUDGE ORIE:  You may follow the usher.

19                           [The witness stands down]

20             JUDGE ORIE:  I'd like to briefly move into private session.

21                           [Private session]

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 35832

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

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

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             The Chamber would like to hear from the parties if there's any

12     conclusion as far as scheduling for this week is concerned, because we

13     were about, on the basis of what -- of the information provided by the

14     Defence, to start organising an extended session for Thursday, but that

15     seems to be uncertain by now.

16             Therefore, as soon as the parties have agreed or have concluded

17     their discussions on the matter, the Chamber would like to be informed

18     without delay.

19             We adjourn for the day, and we'll resume tomorrow, Wednesday, the

20     20th of May, 9.30 in the morning, in this same courtroom, I.

21                            --- Whereupon the hearing adjourned at 2.16 p.m.,

22                           to be reconvened on Wednesday, the 20th day of May,

23                           2015, at 9.30 a.m.