Tribunal Criminal Tribunal for the Former Yugoslavia

Page 37291

 1                           Wednesday, 15 July 2015

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand via videolink]

 5                           --- Upon commencing at 9.30 a.m.

 6             JUDGE ORIE:  Good morning to everyone in and around this

 7     courtroom.

 8             Mr. Registrar, would you please call the case.

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

10     IT-09-92-T, the Prosecutor versus Ratko Mladic.  Thank you.

11             JUDGE ORIE:  Thank you, Mr. Registrar.

12             I would like to verify first whether the videolink is functioning

13     well.  Can you --

14             THE REGISTRAR: [Via videolink] Yes, good morning, Your Honours.

15     We can see and hear you clearly.

16             JUDGE ORIE:  Thank you.  We can see and hear you clearly as well.

17             Therefore, after I have reminded Mr. Kelecevic that, and please

18     listen well, Mr. Kelecevic, you're still bound by the solemn declaration;

19     that is, that you'll speak the truth, the whole truth, and nothing but

20     the truth.  You're still bound by that solemn declaration.  Mr. Traldi

21     will now continue his cross-examination.

22             Mr. Traldi, please.

23             MR. TRALDI:  Thank you, Mr. President.

24                           WITNESS:  BOSKO KELECEVIC [Resumed]

25                           [Witness testified through interpreter]

Page 37292

 1                           [Witness testified via videolink]

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

 3        Q.   Good morning, sir.

 4        A.   Good morning.

 5        Q.   I'm going to turn now to Kotor Varos.  The 5th Corps Brigade

 6     responsible for Kotor Varos was the 122nd Brigade under

 7     Colonel Bosko Peulic; right?

 8        A.   Yes.

 9             MR. TRALDI:  Can we have 65 ter 02660.

10        Q.   This is an excerpt from the minutes of the 13th Session of the

11     National Defence Council of Kotor Varos municipality, held on the 7th of

12     April.  Looking under item 1, we see that one of the recorded speakers is

13     Lieutenant-Colonel Peulic, described as "the commander of the JNA unit

14     based in our municipality."

15             Now this is a reflection that by early April 1992 the

16     122nd Brigade had been deployed back to Bosnia from Croatia and was

17     responsible for, among other places, the area of Kotor Varos; right?

18        A.   Yes.

19             MR. TRALDI:  Your Honour, I tender the document.

20             JUDGE ORIE:  Mr. Registrar.

21             THE REGISTRAR:  It shall be assigned Exhibit P7479.  Thank you.

22             JUDGE ORIE:  Admitted.

23             MR. TRALDI:

24        Q.   When the VRS came into being, the VRS unit responsible for

25     Kotor Varos, this brigade, became the 22nd Brigade and Colonel Peulic

Page 37293

 1     remained the commander; right?

 2        A.   Yes.

 3             MR. TRALDI:  Can we have 65 ter 02596.

 4        Q.   As it comes up, sir, Peulic's unit participated in moving

 5     non-Serbs out of the Kotor Varos; right?

 6        A.   I don't know, I mean, what it is that you mean.  Moving Serbs

 7     where?

 8        Q.   Moving non-Serbs from Kotor Varos out of the Republika Srpska;

 9     right?  Colonel Peulic's unit participated in that.

10        A.   Yes.  That was his area of responsibility, yes.

11        Q.   And this is an extract from the minutes of the 100th Session of

12     the War Presidency in Kotor Varos held on the 16th of October, 1992.  You

13     don't claim that you were still in an information vacuum in Doboj at that

14     point, do you?

15        A.   Yes, it was precisely the month of October when I was busy

16     concerning Brod; that is to say, facing the Sava.  It was only on the

17     7th of October that Brod was liberated.

18             JUDGE ORIE:  Mr. Traldi, one of your previous questions was the

19     participation of Peulic's unit in moving non-Serbs out.  You then asked

20     the witness to confirm that.  He said:  "Yes.  That was his area of

21     responsibility ..."

22             But it was not very clear whether he also confirmed your

23     proposition that Peulic's unit was involved in the moving out.

24             MR. TRALDI:  I recognise that, Mr. President.  In the interest of

25     the efficiency because it's addressed in the documents that I'm using,

Page 37294

 1     I'd moved on.

 2             JUDGE ORIE:  Then I understand why you did not insist on an

 3     answer at that point in time.

 4             Please proceed.

 5             MR. TRALDI:

 6        Q.   So this is the 16th of October after the 7th when Brod fell, and

 7     at the bottom of this page, in both languages, we see president

 8     Nedjelko Dj pointed out that:

 9             An International Red Cross team had been in the area again

10     yesterday, that the negotiators had gone to Vecici too, that the initial

11     results from Vecici were not favourable, that they'd had met the other

12     side's representatives, (Bastina), that a list containing the names of

13     12- to 1500 people had been compiled, that this will require about 30

14     buses, and intensified activity relating to move out should be expected.

15             I'm going to turn now to P3715, an excerpt of another meeting of

16     the Kotor Varos War Presidency held two days later on the 18th of

17     October.

18             Now, in the middle of the middle of the first paragraph we read

19     that:

20             The same president of the War Presidency mentions that as for the

21     action of surrendering weapons and the moving from the territory of

22     Kotor Varos, the drive and all activities had been conducted on the

23     orders of the government and the Presidency of Republika Srpska.

24             And in the second paragraph, that:

25             Lieutenant-Colonel Peulic stressed that he had participated from

Page 37295

 1     the very beginning (11 June) in preparing all the activities, that there

 2     was no straying from the general policy and goals, stop the fratricidal

 3     war in these parts, prevent the entry of armed unit, disband all

 4     paramilitary units, allowing only the VRS to exist and operate.

 5             Now, when he says he participated in preparing all the activities

 6     in the context of their discussion of moving people out, what he is

 7     saying is, as I put to you a moment ago, his unit participated in moving

 8     people out, moving non-Serbs out, of Kotor Varos; right?

 9        A.   I think that he said that he participated but not on his own.

10     The MUP forces took part to a considerable degree, and they were legal in

11     the area of responsibility of Bosko Peulic and along that axis.

12        Q.   Turning to the second page in both languages --

13             JUDGE ORIE:  Witness, could you tell us where you read this in

14     the document?  Perhaps we go back to the first page.

15             THE WITNESS: [Interpretation] I didn't read it in the document at

16     all.  I know what the position of the corps command was.

17             JUDGE ORIE:  Witness, were you present during that meeting?

18             THE WITNESS: [Interpretation] I was not present.  I was busy.

19     I'm telling you, I was --

20             JUDGE ORIE:  Witness, you've answered that question.

21             So therefore, if you say I think that he said, you have neither a

22     basis for that in the document nor any personal observation, not being

23     present.  Is that correctly understood?

24             Please proceed.

25             Mr. Lukic.

Page 37296

 1             MR. LUKIC:  Yes, Your Honour.  I would like the document to be

 2     read, not interpreted.

 3             JUDGE ORIE:  Well, the part was --

 4             MR. LUKIC:  Because whenever it's interpreted, it's not correct

 5     and it's confusing the witness.

 6             JUDGE ORIE:  Well --

 7             MR. TRALDI:  I take exception to Mr. Lukic's statement.

 8             JUDGE ORIE:  That's a sweeping statement, that whenever it's

 9     interpreted that it's --

10             MR. LUKIC:  Why --

11             JUDGE ORIE:  Mr. Lukic, not again --

12             MR. LUKIC:  I don't --

13             JUDGE ORIE:  Do not interrupt me again, Mr. Lukic.

14             MR. LUKIC:  Okay.

15             JUDGE ORIE:  I think that the relevant part was read literally.

16     If you think it was not, please tell us where Mr. Traldi misread --

17             MR. LUKIC:  In B/C/S.

18             MR. TRALDI:  Your Honours, I'd ask that the witness's headphones

19     be removed.

20             MR. LUKIC:  No, no, no.  He heard -- Mr. Traldi -- needs to hear

21     the rest because otherwise he would be confused.

22             THE INTERPRETER:  Could the speakers kindly be asked not to

23     overlap.

24             JUDGE ORIE:  Mr. Lukic --

25             MR. LUKIC:  Yes, but [Overlapping speakers] here.

Page 37297

 1             JUDGE ORIE:  I am at a point to consider with my colleagues to

 2     take measures if --

 3             MR. LUKIC:  Against the Prosecution who is not reading the

 4     document but interpreting it wrongly.  You should take the action against

 5     him, not against me.  I'm trying to correct these proceedings.

 6             JUDGE ORIE:  Stop immediately.  Sit down, Mr. Lukic.  Sit down,

 7     please.

 8             When Mr. Traldi addresses me in order to ask the Court that the

 9     witness takes off his earphones, he's perfectly entitled to do so.

10     That's where you intervened.  The problem is since there are overlapping

11     speakers that perhaps not always the transcript says anything.

12             Could the witness --

13             MR. LUKIC:  Your Honour, I object --

14             JUDGE ORIE:  Mr. Lukic, again please.  If the witness takes off

15     his earphones, that is exclusively for the purpose of the witness not

16     following our discussions.  If something wrongly was read to the witness,

17     after we've discussed it, when the witness puts on his earphones again,

18     he'll be informed about any mistake and it will be corrected.  And I

19     think you should be confident that that's the procedurally proper way to

20     proceed.  And that's what I'm going to do now.

21             Could the witness take off his earphones.

22             Mr. Lukic, where do you think that what Mr. Traldi read is an

23     error.

24             MR. LUKIC:  Last paragraph on the first page in B/C/S version.

25             JUDGE ORIE:  Let's have a look.  Let's have a look.  And where do

Page 37298

 1     we find it --

 2             MR. LUKIC:  It was implied that something illegal was done.

 3     First sentence says, I'll read in B/C/S --

 4             JUDGE ORIE:  Okay.  Let me go to the relevant page.  It is which

 5     page?

 6             MR. LUKIC:  It's probably the next page in English.

 7             JUDGE ORIE:  I'm looking at the page in the transcript,

 8     Mr. Lukic.  Because that's where we find what Mr. Traldi read.

 9             MR. LUKIC:  The question was really long.  And it encompasses two

10     documents.

11             JUDGE ORIE:  That's fine.  Where did he misstate the evidence in

12     the transcript?  I give you time to find it.

13             MR. LUKIC:  Thank you.

14                           [Trial Chamber confers]

15             MR. LUKIC:  Page 4, line 5.  And next document continues from the

16     line 13 --

17             JUDGE ORIE:  Let's start with you say page 4, line 5.

18             MR. LUKIC:  Yes.

19             JUDGE ORIE:  Okay.  What's wrongly quoted there?

20             MR. LUKIC:  Nothing is quoted, Your Honour.

21             JUDGE ORIE:  Okay.  What is misrepresented there.

22             MR. LUKIC:  That -- I'll read in B/C/S.

23             [Interpretation] "Colonel Peulic, taking the floor again, pointed

24     out that one should not give up on the position and agreements reached

25     concerning the surrender of weapons" --

Page 37299

 1             THE INTERPRETER:  Interpreter's note:  We didn't hear the end.

 2             JUDGE ORIE:  One second, Mr. Lukic.  First of all, if you read

 3     something which you say Mr. Traldi misrepresented, I'd like first to know

 4     exactly what part of the transcript we should look at in order to find

 5     out whether your are right or not.

 6             What in the transcript was said, which you then later will tell

 7     us why it is inconsistent with the text of the document before us.

 8             What did he say that is wrong?

 9             MR. LUKIC:  It was implied.  Nothing was quoted.  I cannot find

10     you what is quoted wrongly.  Nothing was quoted.  I'm trying to quote.

11             JUDGE ORIE:  Where does it misrepresent?

12             MR. LUKIC:  Page 4, line 5 until line 12.

13             JUDGE ORIE:  Okay.  I read there:

14             "So this is the 16th of October after the 7th when Brod fell."

15             Now, that is not in the document.  I think that's an introduction

16     by Mr. Traldi.

17             MR. LUKIC:  Yes.

18             JUDGE ORIE:  Is that wrong?

19             MR. LUKIC:  It's not wrong.

20             JUDGE ORIE:  It's not wrong.

21             And at the bottom of this page in both languages, we see

22     President Nedjelko, let me see, pointed out that an

23     International Red Cross team had been in the area yesterday.

24             Is that right or is that wrong?

25             MR. LUKIC:  Sorry, I was trying to find it in the document that's

Page 37300

 1     on our screen.

 2             JUDGE ORIE:  I think I saw it once, but Mr. Traldi --

 3             MR. TRALDI:  It's in the previous document.

 4             MR. LUKIC:  Previous document that we have on our screens, yes.

 5             JUDGE ORIE:  The previous document, okay.

 6             That's agreed.  Please do not overlap.  So it's agreed that that

 7     was in the previous document.  But there's no dispute about it.  That the

 8     negotiators had gone to Vecici too.  I think that was also read from that

 9     document.  That the initial results from Vecici were not favourable.

10             Perhaps we move to the previous document so as to be able to

11     verify every single.

12             MR. TRALDI:  Can we have back 65 ter 02596.

13             JUDGE ORIE:  Okay.  There we have it at the bottom, Mr. Lukic.

14             "President Nedjelko D pointed out that..."

15             Okay.  We'll now continue because what we've read until now I

16     think is almost literally if not literally at all what is presented in

17     this document.

18             "... that the initial results from Vecici were not favourable..."

19             Is that what the document says?

20             "... that they had the other side's representative (Bastina),"

21     which is literally in the document.

22             "That a list containing the names of 12 to 1500 people had been

23     compiled, that this will require about 30," and then it says "expected,"

24     but it's about buses apparently.

25             Now you said there was a misquote from lines 5 to 12.  Where is

Page 37301

 1     it?

 2             MR. LUKIC:  It was suggested.

 3             JUDGE ORIE:  What was suggested?  Look at the text.

 4             MR. LUKIC:  That there was something illegal.  It's enough to

 5     omit --

 6             JUDGE ORIE:  Mr. Lukic --

 7             MR. LUKIC:  It's misleading if you omit the crucial part:  That

 8     there is agreement - there is agreement - and he wants to respect the

 9     agreement.  That's the next paragraph.

10             JUDGE ORIE:  That is the next paragraph.

11             MR. LUKIC:  Of the English version.

12             JUDGE ORIE:  Okay.  So the proper way of dealing with this is

13     that you invite Mr. Traldi under those circumstance or you address us to

14     invite Mr. Traldi to include the next paragraph as well.  If Mr. Traldi

15     does so, the problem is resolved.  If Mr. Traldi does not, then you have

16     a possibility in re-examination to present the proper context --

17             MR. LUKIC:  Yes.

18             JUDGE ORIE:  And that's --

19             MR. LUKIC:  It's next first sentence, Your Honour.

20             JUDGE ORIE:  There's nothing -- okay.

21             MR. LUKIC:  Everything is in this next sentence, Your Honour.

22     Everything.

23             JUDGE ORIE:  Well, that's your position, and you may present your

24     position in re-examination.

25             Mr. Lukic, you presented a statement of the witness in which,

Page 37302

 1     without any source, without any further explanation, he says something

 2     about Kotor Varos.  Mr. Traldi may explore that.  If you think he is

 3     doing that out of context, you have an opportunity to correct that.

 4             MR. LUKIC:  But then I will really need a lot of time to correct

 5     everything that was misrepresented.

 6             JUDGE ORIE:  Well, what you should have done, Mr. Lukic, you

 7     should have presented a statement of the witness which gives proper

 8     sources and which is not just sweeping statements.

 9             MR. LUKIC:  If I may, Your Honour --

10             JUDGE ORIE:  I leave it to that for the time being.

11             I have two further observations to be made.  First, if you stand,

12     Mr. Lukic, you wait for being given an opportunity to address us.

13             MR. LUKIC:  Thank you.

14             JUDGE ORIE:  Then you should not object to questions made by the

15     Bench unless there is an obvious error made by the Bench and if you want

16     to gently point at that possibility, you have an opportunity to do so.

17     But apart from that, no objections against questions by the Bench.  And

18     again, whatever happens, re-examination is the proper time to deal with

19     the matter.

20             If that's clear, then we'll continue after we have invited the

21     witness to put on his earphones again.  And perhaps he can see me.

22             Mr. Traldi, I leave it in your hands.  You know what Mr. Lukic

23     invited you to do.  I leave it to you whether you want to follow that

24     invitation, yes or no.

25             MR. TRALDI:  Let's have P3715 back, just to complete my questions

Page 37303

 1     about that document.

 2        Q.   As it comes up, sir, I want to return to the last thing you said.

 3     Now, you said based on your knowledge in the corps command the MUP had

 4     also participated in this moving people out of Kotor Varos.  Do I

 5     correctly understand your evidence that both the MUP and Colonel Peulic's

 6     unit participated in this moving out of a large number of people from

 7     Kotor Varos after the visit by the Red Cross team to these Muslim and

 8     Croat villages and an agreement on moving those people out was reached.

 9     That's what you know; right?

10        A.   I've already said that I know that, for the most part, the MUP

11     forces or, rather, the civilian authorities were the mainstays of these

12     activities; the Crisis Staff, the War Presidency of the municipality of

13     Kotor Varos, that is.

14             MR. TRALDI:  If we can have page 2 of this document in both

15     languages.

16        Q.   We see it's Slobodan Z speaking, and just so you know it's the

17     Prosecution's position that's Slobodan Zupljanin, battalion commander in

18     Peulic's brigade, and he says that, among other things:

19             "... thus far everybody had taken part in activities, including

20     Momcilo Komljenovic, and Savo Tepic, who is also absent.  All activities

21     were agreed bearing in mind --"

22             THE INTERPRETER:  Could Mr. Traldi please give us a reference in

23     B/C/S as to where he is reading from.  Thank you.

24             MR. TRALDI:  It's the top of the page in both languages.

25             JUDGE ORIE:  I think you skipped half a line, Mr. Traldi.

Page 37304

 1             MR. TRALDI:  That's right.  It starts in the middle of the second

 2     sentence at the words "thus far."  And I'll start reading again:

 3             "... thus far, everybody had taken part in activities, including

 4     Momcilo Komljenovic, and Savo Tepic, who is also absent.  All activities

 5     were agreed bearing in mind directives from higher organs: The Main Staff

 6     of the Army of Republika Srpska and the Presidency of Republika Srpska."

 7        Q.   Now the directives from the Main Staff, those were relayed to

 8     Peulic' unit through the 1st Krajina Corps command, right?  They would

 9     issue a directive to you, you would pass down an order to

10     Colonel Peulic's unit.

11        A.   Yes.

12             MR. TRALDI:  Can we have 65 ter 31380.

13        Q.   Now this an issue of Novi Vjesnik, dated two days later, 20

14     October, 1992.  We read and it's the middle of the page on the left in

15     B/C/S:

16             "A vehicle of the International Red Cross is escorting 350

17     Croatian and Muslim soldiers and thousands of civilians liberated by

18     exchange - along a winding road through Central Bosnia - from Kotor Varos

19     to the free territory in Travnik."

20             And this is an example of what we discussed yesterday, exchanges

21     resulting in people being moved out of the RS, non-Serbs being moved out

22     of RS and into Muslim and Croat territory; right?

23        A.   You are asking me whether this is correct?  This kind of moving

24     out?

25        Q.   I asked you a very specific question.  This is an example of what

Page 37305

 1     we discussed yesterday, exchanges resulting in the moving out of

 2     non-Serbs from the RS into Muslim and Croat territory; right?

 3        A.   Yes.

 4             MR. TRALDI:  Your Honours, I tender 65 ter 02596 and 31380 as

 5     public exhibits.

 6             JUDGE ORIE:  Mr. Registrar.

 7             THE REGISTRAR:  They shall be assigned Exhibit P7480 and P7481,

 8     respectively.  Thank you.

 9             JUDGE ORIE:  Both are admitted.

10             MR. TRALDI:  Can we have 65 ter 31913.

11        Q.   Now this is an article titled: "From the War Log," in a

12     publication known as Vlasicki Vidici from the 19th of November, 1993.  If

13     we turn to page 2 in the English and the top of the far right column on

14     page 1 in the B/C/S, we see the words:  "Blockades of Kotor Varos, SDS

15     takes over power."

16             When Colonel Peulic said his unit had participated in all the

17     activities from the 11th of June, from the beginning, this is the

18     beginning he is talking about, the blockade and take-over of Kotor Varos

19     on the 11th of June; right?

20        A.   I really don't know what he had in mind.  As a soldier, though, I

21     do know that he participated within his area of responsibility in the

22     implementation of the tasks involved.  This was also definitely a part of

23     that and it was done together with the civilian authorities.

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

25             JUDGE ORIE:  Mr. Registrar.

Page 37306

 1             THE REGISTRAR:  It shall be assigned Exhibit P7482.  Thank you.

 2             JUDGE ORIE:  P7482 is admit into evidence.

 3             MR. TRALDI:

 4        Q.   We saw Vecici mentioned in one of the documents we looked at

 5     earlier.  At the end of October and early November 1992, the 1st Krajina

 6     Corps was regularly reporting to the Main Staff about negotiations with

 7     the residents of Vecici; right?

 8        A.   Yes.

 9        Q.   And Mladic was in the 1st Krajina Corps's area of responsibility

10     at the time; right?

11        A.   I wouldn't be able to say whether he was there at that time.

12             MR. TRALDI:  Can the Prosecution have P2884.

13        Q.   This is an excerpt of the minutes from the meeting of the

14     Kotor Varos War Presidency on the 2nd of November, 1992.  We see under

15     point II, President Djekanovic said that Colonel Bogojevic would come

16     during the day and that Mladic had ordered that any agreement with him

17     regarding, what we see in the English, Vucic should be implemented.

18             So Colonel Bogojevic, that's the corps's assistant commander for

19     security; right?

20        A.   Yes.

21        Q.   Now if we turn to page 3 in the English and 2 in the B/C/S, we

22     see a continuation of that session.  We see Colonel Bogojevic,

23     Major Trivic, Lieutenant-Colonel Novakovic, Captain Zupljanin and

24     Captain Balaban are all present.  Captain Balaban was also an officer in

25     the corps's security organ; right?

Page 37307

 1        A.   Yes, he was a reserve of officer.

 2        Q.   And we see that Colonel Bogojevic informed all present that he

 3     had received explicit orders from General Mladic that no one was to be

 4     allowed to leave Vecici until the unconditional surrender of weapons was

 5     completed.

 6             This reflects Mladic's taking personal involvement, personal

 7     control of what was to be done regarding the negotiations with the Vecici

 8     residents; right?

 9        A.   I can't confirm that Mr. Mladic took part personally.  I simply

10     don't know.  I can't confirm whether he was there at the time.  If it was

11     in November, I was still at the command post in Doboj, or, rather, at

12     Trebava.

13        Q.   Now I hadn't suggested that he took part in the negotiations

14     personally.  What I'm putting to you is what we see here is he is clearly

15     giving personal direction, taking personal control of what the

16     negotiation position is going to be; right?

17        A.   I could agree, but I cannot assert that it was the case.  I

18     simply don't remember and don't know.  I don't remember any such words

19     being uttered.

20        Q.   You are aware, though, that in the 48 hours after this session,

21     approximately 150 Muslim men from Vecici were taken prisoner by the VRS

22     and murdered in and around the Grabovica school in Kotor Varos; right?

23        A.   I know about it from reports.  But as far as I know, again, it

24     had to do with the civilian authorities and their treatment of those

25     people in the school at Grabovica.

Page 37308

 1        Q.   Prisoners surrender to the VRS, they're held by the VRS in a

 2     school, they're murdered.  It's the VRS's responsibility; right?

 3        A.   I cannot assert that.  I don't know if the school was secured by

 4     the army or civilian authorities, i.e., the police or the MUP.  I can't

 5     say.  I don't know.

 6        Q.   Now, first you said as far as you know it had to do with the

 7     civilian authorities.  Now you say you don't know who secured the school.

 8     You immediately tried to ascribe responsibility to the civilian

 9     authorities --

10             JUDGE ORIE:  Witness, please do not interrupt Mr. Traldi when he

11     puts a question.

12             Please.

13             MR. TRALDI:

14        Q.   You tried to ascribe responsibility to the civilian authorities

15     even though you do not know, as you confirmed, who secured them because

16     you know this was a terrible, terrible crime; right?

17        A.   The crime did take place.  I don't know who was securing the

18     school at that point in time.

19             JUDGE ORIE:  Witness, it's not an answer to the question.

20             But, Mr. Traldi, apparently the witness has seen some reports and

21     that's all apparently what he knows.  I think we've seen some of those

22     reports as well.

23             MR. TRALDI:  I agree, Mr. President, and I'll move on.

24             JUDGE ORIE:  Therefore, it's for the Chamber further to interpret

25     the evidentiary material.

Page 37309

 1             Please proceed.

 2             MR. TRALDI:

 3        Q.   Turning to Sanski Most, about which I will be very brief.  The

 4     primary brigade in Sanski Most was the 6th Brigade under both the JNA and

 5     the VRS; right?

 6        A.   Yes.

 7        Q.   The commander was Branko Basara, both before and after the

 8     transformation; right?

 9        A.   He was removed after a while and replaced by Colonel Nikola

10     Kajtez.  I don't recall the date, but I do know that the corps command

11     ordered the change in the command of the 6th Brigade.

12             MR. TRALDI:  Can we have 65 ter 32460.

13        Q.   This is a report dated the 6th of March, 1993, from

14     operational group 2 command, and we see it comes from the commander,

15     Branko Basara.

16             So you said he was removed.  In fact, he was put in command of an

17     operational group.  And as with Colonel Arsic's transfer to head

18     OG Doboj, this was promotion; right?

19        A.   He did not hand over his duties at this time.  I can't really say

20     when.  I said that there was a change in the brigade command.  A brigade

21     commander, in addition to his duties, also had the duties of commander of

22     the Tactical Group 3.  I don't know.  I can't remember now when Basara

23     was removed from the position of brigade commander, the 6th Brigade

24     commander.

25        Q.   What I'm putting to you very simply is as after the destruction

Page 37310

 1     of Muslim villages that we discussed briefly yesterday in Sanski Most by

 2     the 6th Brigade, Colonel Basara was given command of an operational group

 3     which comprised several brigades.  That's the truth, right?

 4        A.   I stand by what I said.  He was the brigades commander, and at

 5     the same time he was the commander of Tactical Group 2.

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

 7             JUDGE ORIE:  Mr. Registrar.

 8             THE REGISTRAR:  It shall be assigned Exhibit P7483.  Thank you.

 9             JUDGE ORIE:  Admitted into evidence.

10             Witness, you earlier said that a brigade commander in addition to

11     his duties also had the duties of commander of Tactical Group 3, whereas

12     in your most recent answer you referred to Tactical Group 2.  At least

13     that's how it was translated to us, interpreted to us.

14             THE WITNESS: [Interpretation] 3.  I apologise.

15             JUDGE ORIE:  Thank you.

16             THE WITNESS: [Interpretation] It is Tactical Group 3.  There were

17     several.

18             JUDGE ORIE:  Yes, please proceed.

19             MR. TRALDI:  Can we have 65 ter 32174.

20             THE WITNESS: [Interpretation] I apologise.

21             MR. TRALDI:

22        Q.   As it comes up, sir, you know that after those destructions of

23     Muslim villages by the 6th Brigade, large numbers of Muslims and Croats

24     moved out of Sanski Most; right?

25        A.   I do know that they moved out.

Page 37311

 1        Q.   Now these are the conclusions of the Sanski Most Municipal

 2     Assembly in 1993, adopting the municipal census.  Turning to page 6 in

 3     the English, 7 in the B/C/S, we see the figures for various years.  Under

 4     Orthodox in 1991, we see just over 25.000; 1993, almost 28.000; we see

 5     Muslims have gone from over 28.000 to just over 4.000; Catholics, over

 6     4.000 to just over 1.000.

 7             So over 25.000 non-Serbs had fled Sanski Most after the

 8     destruction of their villages; right?

 9        A.   I can't say how many.  As the Chief of Staff, I wasn't involved

10     in this.  I was engaged on combat operations.  This was the domain of the

11     assistant commander for civilian protection.  If this was the case, then

12     I'll take it at face value.

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

14             JUDGE ORIE:  Mr. Registrar.

15             THE REGISTRAR:  It shall be assigned Exhibit P7484.  Thank you.

16             JUDGE ORIE:  Admitted.

17             MR. TRALDI:

18        Q.   And you know that in Prijedor and Kljuc as well, the

19     municipalities we discussed yesterday, large numbers of Muslims and

20     Croats left those municipalities, fled those municipalities after the

21     operations and the crimes we discussed; right?

22        A.   Yes.

23        Q.   Now, finally, sir, you say in your statement that prisoners from

24     the Prijedor camps were transferred to Manjaca.  You don't mention this

25     in your statement, but several prisoners were killed in that transport by

Page 37312

 1     members of the Prijedor police; right?

 2        A.   I can't confirm that.  I can only confirm that when they arrived

 3     at the gate of Manjaca camp, there were several people dead on the

 4     trucks.  I know about that.  The camp warden refused to take them over.

 5     He said that they should be returned, that he would only take over living

 6     and healthy people.  Thus, the bodies were returned, but I don't know

 7     where.

 8             Therefore, my answer is the army did not secure the transport of

 9     prisoners to Manjaca.  Again, it was done by the civilian authorities,

10     i.e., members of the MUP.

11             JUDGE ORIE:  Witness, could I invite you to carefully listen to

12     the question because there was no suggestion in the question that they

13     were killed by the army.  Mr. Traldi, if I understood you well.

14             MR. TRALDI:

15        Q.   In fact, sir, I take it we agree that they were killed by the

16     Prijedor police; right?

17             JUDGE ORIE:  Now my second observation, Mr. Traldi, would be the

18     following:  That your question was not unambiguous.  Exactly by the

19     Prijedor police, whether that refers to the transport or to the killing

20     is not entirely clear, I think, in the language you used.

21             MR. TRALDI:  I take the point.

22        Q.   Sir, I take it we agree that they were killed by members of the

23     Prijedor police; right?

24        A.   That was my presumption as well.

25        Q.   And none of the camp guards from the military police battalion

Page 37313

 1     attached to the corps command were disciplined for just allowing this to

 2     happen, were they?

 3        A.   I don't see that anything of the sort happened.  He simply did

 4     not allow them to enter the facility at Manjaca.

 5        Q.   And the corps command had lists of the people who were detained

 6     at Manjaca; right?

 7        A.   The corps command had very orderly lists with the particulars of

 8     the people held at Manjaca.

 9        Q.   And the transfer from Prijedor camps to Manjaca, that occurred

10     after the first visit by international journalists to the Prijedor camps;

11     right?

12        A.   I wouldn't know.  I didn't have time to read the newspapers at

13     the time.

14        Q.   A Defence witness named Milovan Milutinovic said that you and

15     General Talic ordered him to accompany the journalists.  Was he lying?

16        A.   If General Talic told him to do that, it wasn't my custom to say

17     anything following him.

18        Q.   But if he mentioned your name.  Your evidence is that's not true;

19     right?

20        A.   I am not saying it isn't true.  What I don't know is whether

21     Milutinovic received any such order, if I may so, from me or, rather,

22     instruction.

23             JUDGE ORIE:  But, Witness, if you say you don't know whether you

24     gave such an order, a minute ago you said you wouldn't know whether

25     something happened after a visit of the journalists because you didn't

Page 37314

 1     read the newspapers.  But, of course, there is some friction between

 2     giving an order to do something and telling us that you didn't know

 3     because you had not read the newspapers.

 4             THE WITNESS: [Interpretation] Your Honour, I said that bearing in

 5     mind what happened in front of the gate concerning the reception of those

 6     prisoners and their entry to Manjaca camp.

 7             JUDGE ORIE:  Well, if that is what you intended to say, then it

 8     was not an answer to the question because the question was whether those

 9     prisoners were transferred to Manjaca after the Prijedor camps had been

10     visited by journalists.  That was the issue.

11             Please proceed, Mr. Traldi.

12             MR. TRALDI:

13        Q.   And you know, in fact, that that was the context.  You know it

14     was right after the Prijedor camps had been visited by journalists

15     because you issued orders about that visit; right?

16        A.   I know that the corps command, i.e., the organs of the corps

17     command who were tasked with dealing with Manjaca, issued instructions

18     and regulations about the treatment of POWs and --

19        Q.   Sir, I'm going to stop you.

20        A.   -- internal rules of the camp.

21        Q.   Sir, stop.  That's evidence you've provided already.  It is not

22     in any way a response to my question.

23             You issued orders regarding the journalists' visits to the

24     Prijedor camps in August 1992 that a moment ago you said you didn't know

25     anything about because you didn't read the papers; right?

Page 37315

 1        A.   I never issued orders.  If something had been ordered previously

 2     by the commander, and I see that Mr. Milutinovic mentions having received

 3     an order from General Talic.

 4             JUDGE ORIE:  No, you are not exactly copying what Mr. Traldi told

 5     you.  Mr. Traldi told you that Mr. Milutinovic had told this Court that

 6     such orders were given by General Talic and you.

 7             Are you saying that that's not what happened?

 8             THE WITNESS: [Interpretation] Again, I say that I don't remember

 9     communicating with Milutinovic whatsoever.

10             In any case, whenever the commander issued an order, I did not

11     issue a different one.  I simply implemented his.

12             JUDGE ORIE:  Yes.  Which could mean that you pass on the order to

13     your subordinates.  Is that well understood?

14             THE WITNESS: [Interpretation] I don't remember whether I passed

15     it on.  It was the duty of other organs, those in charge of morale and

16     security.

17             JUDGE ORIE:  Please proceed, Mr. Traldi.

18             MR. TRALDI:

19        Q.   In fact, you knew about this context, everybody knew about this

20     context because the Main Staff had issued orders to get those camps ready

21     for the visit that were passed down to the 43rd Brigade through the corps

22     command; right?

23        A.   Those ICRC visits and the visits of other international

24     organisations were at times announced and at others time unannounced.  I

25     can't say now which one was or was not announced.  It was up to them.

Page 37316

 1        Q.   Two weeks after this visit, ICRC access was cut off for a period

 2     of about a week while the Manjaca prisoners were processed; right?

 3        A.   I can't say that the date is correct.  But if there was any

 4     processing done at the time, I suppose any visits were disallowed.  I

 5     suppose.

 6        Q.   And I see --

 7             JUDGE ORIE:  Could I --

 8             You earlier were asked about -- to prepare the camps for visits

 9     of journalists and you were asked about that.  And then you answered

10     about visited by the ICRC and other international organisations.  Could

11     you also answer the question in respect of the visit of journalists?

12             THE WITNESS: [Interpretation] I can't.  I don't know the period.

13     I wasn't familiar at all with the visit of journalists to Manjaca camp.

14             JUDGE ORIE:  Mr. Traldi, the --

15             THE WITNESS: [Interpretation] I can't discuss that directly.

16             JUDGE ORIE:  Mr. Traldi, the Chamber has received quite some

17     substantial and detailed evidence about these matters, and this witness

18     apparently was either not involved or has no recollection of being

19     involved or what his involvement was.

20             Therefore, I suggest that you consider to move on.

21             MR. TRALDI:  I will, Your Honour.  And I see we're at the time

22     for the break.  I think I'm very near the end and can be most efficient

23     if I have a few minutes to reorganise, but I wouldn't expect to be more

24     than a few minutes in the next session.

25             JUDGE ORIE:  Then we'll take a break now.

Page 37317

 1             We resume at 10 minutes to 11.00.

 2                           [The witness stands down via videolink]

 3                           --- Recess taken at 10.30 a.m.

 4                           [The witness takes the stand via videolink]

 5                           --- On resuming at 10.52 a.m.

 6             JUDGE ORIE:  Could I ask that the witness takes off his earphones

 7     for a second.  Thank you.

 8             Mr. Lukic, the Chamber unanimously finds that we need to react to

 9     your behaviour yesterday and today.  And as a matter of fact, the Court

10     would have expected apologies which were not expressed.  Sufficient

11     guidance has been given to you by now how you should deal with the

12     matters you wanted to raise, though in an inappropriate way.  If it

13     happens again, I'll have to use my priority button and will switch off

14     your microphone if it happens again.

15             I leave it to that for the time being, and I'm confident that it

16     will not happen again.

17             We'll proceed.  Could the witness put his earphones on again.

18             Mr. Traldi.

19             MR. TRALDI:

20        Q.   Just a few more questions, General.

21             First, the activities we've looked at of the 1st Krajina Corps

22     and other Bosnian Serb forces in the Bosnian Krajina, the detention of

23     Muslim and Croat civilians, their removal through exchange, destruction

24     of villages and moving out of the residents, killing of the residents,

25     the corridor operation as well, those were part of how those forces

Page 37318

 1     implemented the goals articulated in the first and second strategic

 2     objectives as well as in General Gvero's proclamation about the war that

 3     we saw on Monday; right?

 4        A.   Yes.

 5        Q.   Finally, sir, I want to step back in time.  When did you first

 6     meet General Mladic?

 7        A.   Mladic is a classmate of mine.  We've known each other from

 8     school.  We attended the academy together from 1961 to 1965, graduated

 9     together.

10             MR. TRALDI:  I'm going to ask Mr. Van hooydonk to play an

11     audio-clip, 65 ter 32715A, from your interview.  CLSS has confirmed, so

12     we'll only need to play it once.  Just for Your Honour's reference, the

13     clip includes consecutive interpretation done at the time.

14             JUDGE MOLOTO:  Could you repeat the number.

15             MR. TRALDI:  32715A.  In CLSS's review, they've made a couple of

16     small edits which do not change, I'd submit, the portions I intend to

17     rely on.  Those edits reflect that the transcript we've -- due to those

18     edits the transcript we've uploaded reflects CLSS's view of the most

19     precise translation of the witness's words rather than just the

20     consecutive interpretation that's on the audio.

21             JUDGE ORIE:  And you'll rely on that version in English.

22             MR. TRALDI:  Yes.

23             JUDGE ORIE:  Yes.

24             Please proceed.

25                           [Audio-clip played]

Page 37319

 1             "Reporter:  Thank you, General.  What kind of commander was

 2     General Mladic?

 3             "[Interpretation] [Voice-over] As I said, we were in school

 4     together, at the academy together.  We were in class together from 1961

 5     until 1965.  I didn't know him well then because he came from a

 6     vocational school to the academy, and I, I came from a military,

 7     secondary military school, but we did know each other.  They knew me

 8     better than I knew them because I played football and things like that.

 9             "They knew me better than I knew them.  We really didn't stay in

10     touch later on.  Milovanovic knows him very well.  They served together

11     in Macedonia.  That is, the 3rd Military District.  I only met him once

12     he arrived in Knin.  First he came as operations officer, then he was

13     Chief of Staff, and then the corps commander, and while -- while I was in

14     Sarajevo in the 2nd Military District for those two months, he was the

15     commander of the Knin Corps which was part of the 2nd Military District.

16     If you ask me on a personal level, I think he was very decisive, very

17     energetic.  I think he went through all the phases of the ranks, the

18     command duties, and operational staff duties.  I think he's -- he's

19     difficult to work with.  That's what I mean.

20             "Reporter:  Why was he acquainted --"

21             MR. TRALDI:

22        Q.   Sir I, just have one question:  Do you stand by the portion of

23     your interview with the Office of the Prosecutor that we just heard?

24             And, sorry, we've lost a question in the transcript.

25        A.   May I respond now?

Page 37320

 1             JUDGE ORIE:  Mr. Traldi, I take it that you expect the witness to

 2     respond your question now.

 3             MR. TRALDI:  I do.

 4             JUDGE ORIE:  Please answer the question.

 5             THE WITNESS: [Interpretation] Everything I said then, I stand by

 6     that.  I didn't quite understand the translation of the last sentence or

 7     the last sentence or two?  I don't know if it changes the substance,

 8     though.

 9             MR. TRALDI:

10        Q.   I'm going to re-ask you that last question just for the clarity

11     of our record.  After you'd explained that he was difficult to work with,

12     you were asked: "Is he a brutal man?" and you responded:   "That's what I

13     mean."

14             Do you stand by that portion of your interview as well?

15        A.   After the word "okrutan," "cruel" is not right.  He is energetic.

16     I said that at the very beginning, that he is energetic, and he

17     perseveres in his orders.  "Okrutan," "cruel," that would not be the

18     adequate word.  I would withdraw that from that text.

19             MR. TRALDI:  Your Honours, I tender 65 ter 32715A.  It's just the

20     page on the screen, and that completes my cross-examination.

21             JUDGE ORIE:  Mr. Registrar.

22             THE REGISTRAR:  It shall be assigned Exhibit P7485.  Thank you.

23             JUDGE ORIE:  P7485 is admitted into evidence.

24             JUDGE FLUEGGE:  I would like to put on the record that we stopped

25     the audio at 11 minutes, 30.4 seconds, and the last question was not

Page 37321

 1     heard when we listened to the audio.

 2             JUDGE ORIE:  Well, at least not in the interpretation.  Because I

 3     do remember that just before we stopped, we heard "why" which seems to be

 4     the question following the question about the personality of Mr. Mladic,

 5     and I also wondered -- I don't think we listened for 11 minutes to the --

 6     to the audio.  Therefore, Mr. Traldi, at what point in time did we start?

 7     I missed it.

 8             MR. TRALDI:  8.41, Your Honour.

 9             JUDGE ORIE:  8.41 up to 11 minutes, 30.4 seconds.

10             MR. TRALDI:  And 8.41 refers to this particular tape from the

11     several tapes that were made of that audio-recorded interview.

12             JUDGE ORIE:  Yes.  And together with the audio we receive the

13     transcription and also the corrected transcription, if I may say so.

14             Mr. Lukic, you announced already that you would have questions in

15     re-examination.  Therefore, please proceed.

16             MR. LUKIC:  Thank you, Your Honour.  Yes, I do have questions.

17                           Re-examination by Mr. Lukic:

18        Q.   [Interpretation] Good day once again, Mr. Kelecevic.

19             Maybe there was an overlap.  Good day once again, Mr. Kelecevic.

20        A.   Good day.

21        Q.   I'm going to ask you something now so that we do it in the right

22     order.  Your role in 1991 related to the corridor and what effect that

23     had on your knowledge about other things that were happening at that time

24     in Bosnia-Herzegovina.

25             First, I'd like to ask you --

Page 37322

 1        A.   Well, I think that you meant 1992.  Not 1991.

 2        Q.   Yes, I meant 1992.  I do apologise.  Thank you for that.

 3        A.   Well, in 1992 --

 4        Q.   I'm going to ask you --

 5        A.   Please go ahead.

 6        Q.   I'm going to pause a bit between questions and answers so that

 7     the interpreters could interpret everything we're saying.

 8             JUDGE ORIE:  Your microphone is off.

 9             MR. LUKIC:  My microphone was on.

10                           [Trial Chamber confers]

11             JUDGE ORIE:  Yes, I see that at the far end of the videolink, at

12     least on our screen, it's indicated that the microphone is off.

13             Mr. Registrar, could you please verify.

14             Could the representative of the Registry at the far end confirm

15     that the microphone is on or is it off?

16             I get no response to that at this moment, whereas I now see that

17     the witness apparently is --

18             THE REGISTRAR: [Via videolink] Your Honours, I'm afraid we've

19     lost the audio on the English channel.  We're trying to reactivate that.

20             JUDGE ORIE:  Then I again seek the assistance of the witness

21     again to say that we'll wait until it has been restored.

22             THE WITNESS: [Interpretation] I can hear.

23                           [Trial Chamber confers]

24                           [Trial Chamber and Registrar confer]

25             JUDGE ORIE:  Since communication with the far end is not only

Page 37323

 1     difficult through the microphone system but also by telephone, we'll take

 2     a short break.  Everyone is requested to remain standby.  We hope to

 3     resume within a couple of minutes.

 4                           [The witness stands down via videolink]

 5                            --- Break taken at 11.09 a.m.

 6                           --- On resuming at 11.17 a.m.

 7                           [The witness takes the stand via videolink]

 8             JUDGE ORIE:  Let's start with testing the videolink.

 9     Mr. Registrar at the far end of the videolink, could you confirm that you

10     can see us and that you can hear me?

11             THE REGISTRAR: [Via videolink] Yes, Your Honour, we can see and

12     hear you now clearly.

13             JUDGE ORIE:  Thank you.  We can see and hear you as well.

14             Therefore, Mr. Lukic, you may proceed.

15             MR. LUKIC:  Thank you, Your Honour.

16        Q.   [Interpretation] Mr. Kelecevic, you mentioned that on Mondays you

17     attended meetings of the staff or rather the command of the 1st Corps.

18     Was it every Monday that you attended these meetings?

19        A.   No.

20        Q.   From April until December 1992?

21        A.   No, no.  Attending these collegium meetings, that was on Mondays.

22     But it depended on my commitments at the command post where I was from

23     the 28th of April, 1992.

24        Q.   When did Operation Corridor end?

25        A.   Operation Corridor, it can be said that it ended when the

Page 37324

 1     1st Corps linked up with the eastern Bosnian forces, and that is the

 2     liberation of Bosanski Brod on the 7th of October, 1992.  However, quite

 3     a bit remained unclear there.  There were still tasks to be carried out,

 4     that is.

 5        Q.   Did the combat end in relation to the corridor in October 1992?

 6        A.   Combat never ended.  How do I put this?  It's not that there were

 7     organised attacks all the time, but as we soldiers would say, there were

 8     always provocations in all sectors, north and south.

 9        Q.   The 1st Krajina Corps, did it suffer any losses?

10        A.   The 1st Krajina Corps responded to that fire, enemy fire, against

11     the Serb forces in the corridor.

12        Q.   The 1st Krajina Corps, the 1st Krajina Corps, did it sustain any

13     losses at the corridor?

14        A.   Losses in those moments, if you're referring to the end of

15     October, that is, there were losses that were lesser but they were still

16     there.

17        Q.   Could you tell us now where your command posts were, where you

18     were from the 28th --

19             JUDGE ORIE:  It looks on our screen as if the microphone at the

20     far end of the videolink has been switched off, and I further put on the

21     record that the video is sometimes interrupted, if only for split

22     seconds.

23             Witness, could you indicate, give me a signal whether you still

24     hear me through the B/C/S channel?

25             I saw that you said something.  If you hear me, could you just

Page 37325

 1     raise your hand for a second.

 2             THE WITNESS:  [Indicates]

 3             JUDGE ORIE:  Yes, apparently the witness hears us.  Apparently

 4     the registrar at the far end of the videolink does not hear us, and

 5     apparently the microphone is either switched off or is not functioning,

 6     and the video is of bad quality.

 7             We take another break to see whether it can be restored.

 8     Everyone is expected to remain standby.

 9                            --- Break taken at 11.24 a.m.

10                           [The witness stands down via videolink]

11                           --- On resuming at 11.30 a.m.

12                           [The witness takes the stand via videolink]

13             JUDGE ORIE:  While everyone is still working on the quality of

14     the videolink connection, until that has been -- until any improvement

15     has been achieved, the Chamber would use the time dealing with procedural

16     matters which are already, for quite some time, outstanding.

17             THE REGISTRAR: [Via videolink] Your Honours, if I may interrupt,

18     we have established connection by an alternative route.  So I think we

19     can proceed for now.

20             JUDGE ORIE:  Then I'll skip my plans.  Let's use the videolink as

21     long as it is good.

22             Mr. Lukic, it's not easy for you, but give it another try.

23             MR. LUKIC:  Thank you, Your Honour.

24        Q.   [Interpretation] General, let's give it one more try.

25             Please tell us where your command posts were between the 28th of

Page 37326

 1     April and December 1992?

 2        A.   My first command post, which was improved, or makeshift, so to

 3     speak, was some 15 kilometres away from Prnjavor, between Prnjavor town

 4     and Derventa.  The place is called Vrelo.

 5        Q.   Please stop.  Please tell us what kind of communications you had

 6     at Vrelo?  What kind of communications means.

 7        A.   You mean communication with the corps command?

 8        Q.   Yes.

 9        A.   Radio communication and a telephone line with the command post in

10     Stara Gradiska in Slavonia.  That was because my commander was still

11     there at the time.

12        Q.   What was it that did you not have that a command post should?

13        A.   At that command post, I did not have the possibility to receive

14     dispatches, at least not all of them, and there were no radio relay

15     communications that were necessary at the time.  We only had them later,

16     in mid-May.

17        Q.   Did you move from that command post; and, if so, where to?

18             THE INTERPRETER:  Interpreter's note:  The sound is too poor.

19             JUDGE ORIE:  I think --

20             MR. LUKIC: [Interpretation]

21        Q.   Please stop.  We are losing you.

22             JUDGE ORIE:  Mr. Lukic, I take it that you also cannot hear the

23     witness in his own language.

24             MR. LUKIC:  It's very hard, Your Honour.

25             JUDGE ORIE:  Yes.  And there's not a reliable --

Page 37327

 1             MR. LUKIC:  Interruptions, yeah.

 2             JUDGE ORIE:  Yes.  Then, Witness, we'll deal with other matters

 3     while everyone is working hard to restore the quality of the audio and

 4     video connection.  Please take off your earphones for a moment.  We'll

 5     continue with other matters.

 6                           [The witness stands down via videolink]

 7             JUDGE ORIE:  Then the skipped plans are activated again.

 8             I'll start with some remaining issues from the testimony of

 9     Dragisa Masal.  I start with P7227.

10             On the 18th of March of this year, P7227 was marked for

11     identification pending a revised B/C/S translation to be found on

12     transcript pages 33364 through 33367.

13             On 27 March, the Prosecution advised the Chamber and the Defence

14     via an e-mail that a new translation had been uploaded into e-court under

15     doc ID M001-2055-BCST and requested its admission.

16             If there are no objections by the Defence, and apparently there

17     are not, and if it's a translation issue, then, of course, you always can

18     revisit it, Mr. Lukic, on short-term.

19             The Chamber therefore instructs the Registry to replace the

20     existing B/C/S translation of P7227 with the new translation and admits

21     P7227 into evidence.

22             I move to P7242.  On the 19th of March, P7242 was marked for

23     identification, pending the provision of a complete copy of the original

24     document and a revised B/C/S translation.  Transcript pages 33425 through

25     33429.

Page 37328

 1             On the 15th of April, the Prosecution advised the Chamber and the

 2     Defence that document P7242, as currently uploaded into e-court, is the

 3     only version the Prosecution has in its possession and that the existing

 4     B/C/S version includes a translation of the legible portions of the

 5     document.  Consequently, the Prosecution requests the admission of

 6     document P7242 as it currently exists.

 7             The Chamber has not heard yet from the Defence on this matter.

 8     If there's no objection, and I hear of none, the Chamber hereby admits

 9     P7242 into evidence.

10             I move to P7250, P7251, and P7252.

11             On the 23rd of March, P7250, 7251, and 7252 were marked for

12     identification pending English translations, transcript pages 33512

13     through -513.  On that same day, the Defence stated that once the

14     translations were provided it would not object to their admission.

15             On the 15th of April, the Prosecution advised the Chamber and the

16     Defence that revised translations of documents P7250, P7251, and P7252

17     had been uploaded into e-court under documents ID 0429-2654-ET,

18     ID 0436-6230-ET, and ID 0431-6085-ET respectively.

19             The Chamber instructs the Registry to attach the new translations

20     and hereby admits P7250, P7251, and P7252 into evidence.

21             Videolink still not being properly restored, I continue with

22     remaining issues from the testimony of Savo Sokanovic.

23             I start with P7391.  During the testimony of this witness on the

24     18th of May, the exhibit number P7391 was reserved for excerpts of the

25     document bearing Rule 65 ter number 19225, a collection of five magazine

Page 37329

 1     articles.  Only two of these articles were used during the testimony of

 2     Sokanovic.

 3             On the 18th of June, the Prosecution advised the Chamber that it

 4     has uploaded the two articles into e-court as documents bearing

 5     Rule 65 ter number 19225a and requested to replace P7391 with this

 6     document.

 7             I see that there are no objections from the Defence.  The Chamber

 8     hereby instructs the Registry to replace the current P7391 with document

 9     bearing Rule 65 ter number 19225a and admits P7391 into evidence.

10             I move to D1059 which was marked for identification during the

11     testimony of Savo Sokanovic on the 18th of May, pending English

12     translation.

13             On the 29th of June, the Defence e-mailed the Chamber and

14     Prosecution and advised that the translation had been uploaded into

15     e-court under doc ID 1D19-2319.  The Chamber instructs the Registry to

16     attach this translation and admits D1059 into evidence.

17             P7196.  These transcript excerpts from the 22nd Session of

18     Republika Srpska Assembly were admitted on the 9th of April, 2015, into

19     evidence as Exhibit P7196.  During the testimony of Savo Sokanovic on the

20     18th of May, additional excerpts of this transcript were used.

21             On the 26th of May, the Prosecution e-mailed the Chamber and

22     Defence and advised that it had added these excerpts to the excerpts

23     admitted as P7196 and uploaded the combined excerpts into e-court as

24     document bearing Rule 65 ter number 02362b.  The Prosecution requested in

25     this e-mail this document to be admitted.

Page 37330

 1             I hear of no objections from the Defence.  The Chamber hereby

 2     instructs the Registry to replace the current P7196 with document

 3     Rule 65 ter number 02362b and admits it into evidence.

 4             Next item is the remaining issue from the testimony of

 5     Nedjo Vlaski.

 6             On 5th of November of last year during the testimony of

 7     Nedjo Vlaski, D745 was marked for identification.  The Prosecution at

 8     that time objected to the admission on the grounds of lack of provenance

 9     and lack of foundation through the witness.  The Defence then stated that

10     it would seek admission when it was able to provide the Prosecution with

11     information about the document's origin.  As a result of the Defence

12     remaining silent on two occasions when the Chamber asked it whether it

13     still intended to seek admission of D745, the Chamber, on the 14th of

14     May of this year, denied admission without prejudice and gave the Defence

15     a week to revisit the matter.

16             On the 20th of May, the Defence e-mailed the Chamber and the

17     Prosecution and advised that Vlaski, and I quote, "confirmed that the

18     document was provided to him by the Serbian security service."

19             Is the Prosecution in a position to make a further submission

20     with regard to the provenance and consequences for its position as far as

21     admission of D745 is concerned?

22             MR. TRALDI:  We'll have to consult and we'll get back to you,

23     Your Honour.

24             JUDGE ORIE:  Then we'll hear from you.  And after having heard,

25     we'll consider whether the matter is ripe for being decided.

Page 37331

 1             Then the next item -- is there any way that the ... efforts to

 2     make a call should not reach our earphones?  Not to say that one should

 3     stop trying, but if it can be down without hearing it, that would be

 4     appreciated.

 5             The next one is documents listed as associated exhibits to

 6     Rule 92 ter statement of Milenko Karisik.

 7             On the 26th of January of this year, the Defence filed a motion

 8     for the admission of the statement of Milenko Karisik.  The motion also

 9     contained a request for the addition of a number of documents to the

10     Defence's Rule 65 ter exhibit list as well as their admission into

11     evidence.  Among them were documents bearing Rule 65 ter numbers 1D5310,

12     1D5311, and 1D5312.

13             Ultimately, the Defence did not request their addition to its

14     Rule 65 ter list and admission into evidence during the witness's

15     testimony on the 16th and the 17th of March.  For the benefit of a clean

16     trial record, the Chamber hereby notifies the Defence that it considers

17     the Defence's requests in relation to these documents withdrawn if it

18     does not hear from the Defence by the 30th of July of 2015.

19                           [Trial Chamber confers]

20             JUDGE ORIE:  For the next item, we should briefly move into

21     private session.

22                           [Private session]

23   (redacted)

24   (redacted)

25   (redacted)

Page 37332











11  Pages 37332-37333 redacted.  Private session.















Page 37334

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10                           [Open session]

11             THE REGISTRAR:  We're back in open session, Your Honours.  Thank

12     you.

13             JUDGE ORIE:  Thank you, Mr. Registrar.

14             Next item deals with translation of P7372.

15             This exhibit was marked for identification on the 7th of May of

16     this year, pending an English translation.

17             On the 20th of May, the Prosecution advised that a translation

18     was ready and indicated that it would request attachment and admission.

19             On the 21st of May, the Defence objected to the translation by

20     e-mail.  The Chamber invites the parties to reach an agreement on the

21     translation within two weeks from today and to inform the Chamber of

22     this.  If an agreement cannot be reached within this time, the parties

23     are directed to make their submissions on the record.

24                           [Trial Chamber confers]

25             JUDGE ORIE:  Then I move on to a few remaining issues from the

Page 37335

 1     testimony of Branko Basara.

 2             On the 24th of April of this year, the Prosecution notified the

 3     Chamber and the Defence that it intended to offer into evidence two

 4     documents through Witness Basara, document bearing 65 ter number 27968a

 5     for which exhibit number P7322 was reserved, and document bearing

 6     65 ter number 31876a.

 7             On the 18th of May, the Prosecution requested admission of P7322

 8     and document bearing 65 ter number 31876a for which P7389 was reserved on

 9     that same day.  The Chamber granted the Defence until the end of May to

10     raise objections, if any, and this can be found at transcript pages 35671

11     through -73.  As of today's date, the Defence has not articulated any

12     objections.

13             The Chamber therefore admits P7322 and P7389 into evidence.

14             Next item is the remaining issue from the testimony of

15     Goran Dragojevic.  During his testimony on the 14th of May of this year

16     P7387 was marked for identification pending a translation into English.

17     This can be found at transcript page 35639.

18             On the 9th of June, the Prosecution informed the Chamber that a

19     translation had been uploaded into e-court under doc ID number

20     0146-7733-1-ET.

21             The Chamber hereby instructs the Registry to attach the

22     translation and admits P7387 into evidence.

23             As always, Mr. Lukic, if there's any problem with a translation,

24     you can revisit the matter.

25                           [Trial Chamber confers]

Page 37336

 1             JUDGE ORIE:  Although I've still a few matters on my agenda, I

 2     think we should first take a break and we will resume.

 3             And Mr. Registrar at this side of the videolink is invited to

 4     communicate by whatever means with the persons at the far end of the

 5     videolink that we'll resume at 20 minutes past midday.

 6             We take a break.

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

 8                           --- On resuming at 12.23 p.m.

 9                           [The witness takes the stand via videolink]

10             JUDGE ORIE:  I do understand that the videolink is functioning

11     well now again.  Let's just test it.

12             Mr. Registrar at the far end of the videolink, can you hear me

13     and can you see us?

14             THE REGISTRAR: [Via videolink] Yes, Your Honour, I can hear you

15     and see the courtroom.

16             JUDGE ORIE:  Yes.  And we can see and hear you as well.

17             However, before Mr. Lukic will continue the re-examination, I'd

18     like to briefly deal with time estimates.

19             Could you tell us approximately, where you said you need a lot of

20     time, how much time you'd need?

21             MR. LUKIC:  I thought that I would be able to see how it

22     develops.  I have a lot of questions, really.  I will try to be as

23     concise as possible, but at least five hours.

24             JUDGE ORIE:  Which would mean that, Mr. Traldi, any --

25             MR. TRALDI:  Just to put on the record that there hasn't been a

Page 37337

 1     re-examination significantly longer than an hour and a half in this trial

 2     to this point, that adding up the Prosecution's re-directs, for instance,

 3     on Witnesses Butler, Brown, Higgs, Donja, and Theunens with a net cross

 4     of about 26 hour, four times the cross of this witness, we did about

 5     three, three to four hours total re-direct for those five witnesses, and

 6     I'd submit it's not an appropriate use of re-examination, to spend five

 7     hours.

 8             JUDGE ORIE:  Mr. Lukic, before I make further observations, do

 9     you wish to respond to what Mr. Traldi said?

10             MR. LUKIC:  Your Honour, so many documents were opened and shown

11     to this witness, and of course we are not going through every single one,

12     but I have to challenge the presentation made by the Prosecution.

13             JUDGE ORIE:  Mr. Lukic, at the very beginning of the testimony of

14     this witness I already have drawn your attention to the fact that you

15     present this witness - and it's not for the first time - giving, well,

16     rather general statements about a multitude of matters without giving

17     proper sources.  Those matters you've dealt with in the presentation of

18     this witness.  So therefore, they're not triggered by the

19     cross-examination.

20             The cross-examination took a long time, but I would say that one

21     could understand that it took such a long time, because if you say in

22     Kotor Varos there was never anything like a plan, you raised the issue

23     about the plans of removal in Kotor Varos.  You didn't give any sources,

24     et cetera, so the Prosecution thought that they would have to respond to

25     that in cross-examination.

Page 37338

 1             But it's not a matter raised in cross-examination, it's a matter

 2     raised in-chief by introducing evidence which is lacking any detail.  But

 3     the subject matter was part of the examination-in-chief, and

 4     re-examination is to respond to matters triggered in cross-examination.

 5             Now I'm not saying that this Chamber finds that you should not

 6     have -- well, that you should not be given an opportunity to deal with

 7     some of those matters, but the way in which the whole examination of this

 8     witness is approached is asking for these kind of difficulties, and

 9     whether five hours will be granted, let's not at this moment finally

10     decide on it.

11             You're invited to focus on what you consider the most important

12     matters.  We'll then see what level of importance we will experience,

13     rather than all kind of details which do not really affect what the

14     witness said either in his statement or in cross-examination, and then at

15     the end of this day we'll see where we stand, because this Chamber is

16     intending to see whether we could finalise the hearing of the evidence of

17     this witness and the next witness by Thursday, quarter past 2.00.

18             If it would turn out that it's still of great relevance and

19     despite the fact that most of the matters may not have been raised, at

20     least the basic substance of it, by the cross-examination but rather by

21     the way in which you presented your evidence in chief, if we would

22     already give some additional time going over quarter past 2.00 tomorrow,

23     we'll then consider whether there's any opportunity have an extended

24     session on Thursday to see whether we can conclude hearing the evidence

25     of this and the next witness by tomorrow, perhaps not at 2.15 sharp.

Page 37339

 1             Let that be of guidance to you and the credit you may expect also

 2     depends on how your re-examination develops.

 3             We'll now proceed, Mr. Lukic.

 4             I see the witness is putting up his earphones again.

 5             Please proceed, Mr. Lukic.

 6             MR. LUKIC: [Interpretation]

 7        Q.   General Kelecevic, can you hear me?

 8        A.   Yes, I can.

 9        Q.   You started explaining something but our communication was

10     interrupted, and we did not hear it to the end.  Please tell us when and

11     why you left the command post at Vrelo between Prnjavor and Derventa.

12        A.   The command post at Vrelo was abandoned first and foremost

13     because of shelling coming from the Croatian and Muslim forces in the

14     general area of the command post.  We moved the group some 5 or 6

15     kilometres away to the village of Strpci and I accompanied them.

16        Q.   How long did you stay in Strpci?

17        A.   We stayed there until the beginning of June, I think.  I don't

18     know the date, but sometime in early June.  The situation became more

19     complex in the -- on the axis Brod-Derventa and on the axis

20     Odzak-Modrica.

21        Q.   What kind of communication means did you have at that command

22     post and which ones were lacking?

23        A.   For the most part it was radio communication and shorter coded

24     dispatches.  We did not have those until mid-June when we went to Rudanka

25     near Doboj.  That was the third command post in May.

Page 37340

 1        Q.   How long did you stay at Rudanka?

 2        A.   There we carried out a detailed assessment of the situation and

 3     proposals were made to -- for a decision by the commander, and many other

 4     things were prepared.  We stayed there until the 20th of June, I think,

 5     when we went to the area of Trebava and Duge Njive.  It is a village

 6     between Doboj and Duge Njive.  The name of the village is Osecina.  We

 7     were in the school building.

 8        Q.   How long did you stay there?  What kind of equipment did you or

 9     did you not have?

10        A.   At Osecina there were already several commanders there who

11     frequented the place, and all the necessary communication was there so as

12     to be able to receive even longer dispatches.  We were already preparing

13     for the opening up of the corridor.  At that time, enemy forces had

14     already taken Derventa and continued towards Johovac and Foca.  From the

15     other side, from Odzak and Modrica, they had cut off the area around the

16     19th.  They had cut off the corridor in the general area of Modrica.

17        Q.   Until what time did you stay at Duge Njive?

18        A.   We stayed there -- well, it was an observation post of sorts

19     there which we reached from Osecina.  Duge Njive is some --

20             JUDGE FLUEGGE:  Mr. Lukic, for the third time you ask about time

21     he stayed there.  The witness didn't answer [Realtime transcript read in

22     error "witness answered"] that question.  You should focus the witness

23     and invite the witness to answer the question short and precisely.

24     Otherwise, you will lose court time.

25             MR. LUKIC:  Thank you, Your Honour.

Page 37341

 1        Q.   [Interpretation] General, if you remember --

 2             JUDGE FLUEGGE:  I said -- sorry, I have to correct my --

 3             MR. LUKIC:  It's wrongly entered in the transcript.

 4             JUDGE FLUEGGE:  I said the witness didn't answer that question.

 5     That was what I said.

 6             MR. LUKIC:  That's what I heard.

 7        Q.   [Interpretation] General, until what time did you remain in

 8     Duge Njive?  Perhaps you can tell us a date.

 9        A.   I can't tell you precisely.  What I can tell you is that we

10     stayed in Duge Njive until sometime in late November in Osecina.  Then we

11     moved to the town of Doboj and we stayed there until mid-December or so.

12        Q.   Until what time did you stay in Doboj?  And if you left, why?

13        A.   The same thing happened.  Our command post was detected and

14     targeted.  Two of our soldiers were killed, and we were forced to move

15     the command post to Prnjavor.  In Prnjavor, the command post became

16     operational sometime in mid-December 1992.

17        Q.   Was the command post in Prnjavor fully developed?  Did you have

18     the equipment you needed?

19        A.   Yes.  The command post in Prnjavor developed gradually to a

20     full-fledged command post which remained there until the end of the war.

21        Q.   Thank you.

22             MR. LUKIC: [Interpretation] Could we have P431, please.

23        Q.   We have before us the minutes of an assembly session of the

24     Serbian people in BH, the 16th session of the 12th of May, 1992.

25             MR. LUKIC: [Interpretation] We need page 41 in English and 34 in

Page 37342

 1     B/C/S.

 2        Q.   My learned friend Mr. Traldi quoted a portion of this, where it

 3     is stated that General Mladic said that "we're not starting from

 4     scratch," and then he quoted the text further.

 5             Let me ask you this:  In your view, what sort of army was it

 6     supposed to be, the VRS?  In your view, what was its goal?

 7        A.   First of all, the VRS had its basic task to preserve the Serb

 8     people and territory, as well as the citizens who wished to remain in

 9     that area.

10        Q.   As far as you know, and you spent the war there, was the plan to

11     occupy territory or hold onto territory which was not considered Serbian?

12        A.   No such plan existed.  The plan was, as I said, to maintain the

13     territory where the Serbs were in the majority.

14        Q.   Following the part that was read out to you, it is rather

15     difficult to find it in this densely typed text in B/C/S.

16             JUDGE MOLOTO:  In the English, it's somewhere in the middle here,

17     sir.

18             MR. LUKIC:  Yes.

19             JUDGE MOLOTO:  "That is a very important.  Our starting point are

20     the armed Serbian people," and then goes up to "phantom Ustasha dragon."

21             MR. LUKIC: [Interpretation]

22        Q.   In the middle of the page the line begins with the words "wiped

23     out," and then it continues by saying:

24             "We are not going ..."

25             That is what I intend to read.

Page 37343

 1             It is line 13 in the B/C/S.

 2             General, I will read it out for you.

 3        A.   Yes, it's difficult for me to read it.

 4        Q.   This is ascribed to General Mladic:

 5             "We are not going to create a conquering army.  That is my

 6     proposal.  We do not want a conquering army.  We do not need what is not

 7     ours.  We are creating an army which will defend successfully the traces

 8     our fathers have left behind and protect our children from the conquering

 9     ambitions of Nazi mercenaries which will bring freedom to its people and

10     enable it to live in peace and serenity in its environment and its

11     centuries'-old hearths."

12             We have a problem it seems with the translation at the end of the

13     sentence, because in English we have -- we think that instead of

14     "hearths" the translation should read "hearthstone."

15             The next question, General.  You were asked about the strategic

16     goals.  You said that you don't remember how you learned about those

17     precisely.  We can find it at transcript page 37136, lines 1 through 8.

18             In your view, what was the strategic goal of the VRS?

19        A.   The strategic goal of Republika Srpska was as I said, i.e.,

20     preserve the Serb territory, the Serb people, and make it possible for

21     all those who wished to live and work there to do so while respecting the

22     authorities of Republika Srpska.

23        Q.   At transcript page 37136, you were asked about the first and

24     second strategic goals together.  My learned friend Traldi asked you as

25     follows, and I'll read it out, and you can you listen to the translation.

Page 37344

 1             [In English] I quote:

 2             "Q. And the objectives that you learned of, those included, most

 3     importantly, for the 1st Krajina Corps separation from Muslims and Croats

 4     and the establishment of a corridor connecting the Bosnian Krajina with

 5     the eastern part of Republika Srpska through the Posavina region; right?

 6             "A.  That was the task, but I wouldn't say that we had to

 7     establish a corridor."

 8             [Interpretation] And then you continue about the corridor.

 9     However, for the time being, we're going to leave the corridor aside, and

10     this is what I'm going to ask you.  The first strategic objective that

11     the Prosecutor asked you about, the separation of Muslims and Croats, was

12     that discussed?  What was your understanding of this, if you've heard of

13     this strategic objective?

14        A.   I cannot say that unambiguously that is how I understood this

15     objective, I mean, but I know the idea of my commander; namely, that the

16     objective was that we are not separated in this harsh sense.  I repeat

17     that.  But that those, I repeat, who wished to live in the area of

18     Republika Srpska can live there, and that is my view to this day.

19             JUDGE ORIE:  Could I ask one follow-up question.

20             Are you telling us that the strategic goals, as you understood

21     them, are different from the ones as formulated for the Republika Srpska,

22     or did have the army its own version of the strategic goals?

23             THE WITNESS: [Interpretation] It's not a big difference.  The

24     essence of that answer would be the essence.  There doesn't have to be a

25     strict separation of the --

Page 37345

 1             JUDGE ORIE:  Witness, did you have a different one?  Whether the

 2     distinction was big or small, we'll consider that.  But does it mean that

 3     you were not fully in line with the strategic goals as formulated and

 4     published for the Republika Srpska?

 5             THE WITNESS: [Interpretation] I was for these strategic goals,

 6     but I tried to explain it in a bit more detail.

 7             JUDGE ORIE:  That's not an answer to my question, but Mr. Lukic

 8     may proceed.

 9             MR. LUKIC: [Interpretation]

10        Q.   Let us take a look at how General Mladic saw this.

11             MR. LUKIC: [Interpretation] In English, it's page 9.  In the

12     B/C/S version, it is page 8.

13             I cannot see it in the English version.  In the B/C/S version, it

14     is the very top of the page.

15             [In English] Probably it's the previous page in English.

16             JUDGE ORIE:  Mr. Traldi.

17             MR. TRALDI:  Yes, Your Honour.  I'm not sure what Mr. Lukic is

18     pointing towards, but I'd just ask first if he clarify who he is

19     representing the speaker is in this portion of the assembly session.

20             JUDGE ORIE:  Mr. Lukic.

21             MR. LUKIC:  My understanding is that General Mladic is speaking.

22             JUDGE ORIE:  Okay.  If you have the right page, we'll be able to

23     verify that on the basis of the document.

24             MR. LUKIC:  Actually this is Karadzic, sorry.  This is Karadzic.

25             JUDGE ORIE:  It's Mr. Karadzic.  Okay.  Then, is it still

Page 37346

 1     relevant?

 2             MR. LUKIC:  Can we see the bottom of the page, please.  Then go

 3     to the next one in English.

 4             JUDGE ORIE:  Which strategic goal you're looking for?

 5             MR. LUKIC:  In English it's second paragraph, but it's a bit

 6     different from the B/C/S.  The second -- before the second.

 7     [Interpretation] It is line 3.

 8             JUDGE ORIE:  If you just start reading slowly, Mr. Lukic, we may

 9     be able to find it.

10             MR. LUKIC:  Mm-hm.

11             [Interpretation] "Separation from those who are our enemies and

12     who have used every opportunity, especially in this century, to attack

13     us, and who would continue with such practices if we were to stay

14     together in the same state."

15             Mr. Kelecevic, do you have any knowledge as to how your

16     colleagues from the 1st Krajina Corps understood this strategic goal, if

17     they knew about it at all?

18             MR. TRALDI:  Your Honour, I'm going to object.

19             THE WITNESS: [Interpretation] That strategic goal --

20             JUDGE ORIE:  If Mr. Lukic first finishes his question, then you

21     may object, Mr. Traldi.

22             And the witness is invited not to answer until we have dealt with

23     it.

24             Mr. Lukic.

25             MR. LUKIC:  I finished my question Your Honour.

Page 37347

 1             JUDGE ORIE:  You finished your question.

 2             Then, Mr. Traldi.

 3             MR. TRALDI:  I don't object to Mr. Lukic drawing the witness's

 4     attention to any portion of the speech.  But if he's going to be

 5     representing that this describes the strategic goal, then he should read

 6     the part beginning at the words:  "The first such goal is..."

 7             JUDGE ORIE:  At least's that's what you invite him to do --

 8             MR. TRALDI:  Yes.

 9             JUDGE ORIE:  -- as least to avoid any confusion.

10             Mr. Lukic.

11             MR. LUKIC:  In B/C/S, it -- it begins as I read, Your Honour.

12             JUDGE ORIE:  Yes.

13             MR. LUKIC:  In B/C/S it's top of the page.  It's easily to be

14     checked.  The first paragraph on this page.

15             JUDGE ORIE:  I leave it --

16             MR. LUKIC:  In English -- that's why I said in English it's a bit

17     different.  The paragraph is a bit differently composed.  But --

18             JUDGE ORIE:  Please --

19             MR. LUKIC:  -- I can accept that it's the first strategic

20     objective.

21             JUDGE MOLOTO:  What is the first strategic objective?

22             MR. LUKIC:  Separation of our enemies.

23             JUDGE ORIE:  Put the question to the witness.  You have put a

24     text to him.  And if there's any further need to deal with that, you have

25     an opportunity to do so, Mr. Traldi.

Page 37348

 1             Please put the question to the witness again.

 2             MR. LUKIC:  Yes.

 3        Q.   [Interpretation] So, Mr. Kelecevic, did you talk to your

 4     colleagues and what was their understanding, and did they know about this

 5     strategic goal before 1993 when it was published in the Official Gazette?

 6        A.   May I respond?

 7             JUDGE ORIE:  Please do so.

 8             THE WITNESS: [Interpretation] That strategic goal was understood

 9     by most officers of the corps as I said originally.  Those who were ready

10     to live together with the Serb people and to follow the same policy, of

11     course, naturally they should stay in the same state.  In my view, that

12     is the essence.

13             JUDGE ORIE:  Mr. Lukic, perhaps we should ask the witness.

14             What state would that be that you would then stay in together?

15             Witness, could you please answer that question.

16             THE WITNESS: [Interpretation] That state would be, first of all,

17     Republika Srpska and where most of the Serb people live.

18             JUDGE ORIE:  Yes.  And that is how you understood, your

19     colleagues understood the first strategic goal?

20             THE WITNESS: [Interpretation] Yes, that is how we understood it,

21     of course.  We were not avoiding our mother state, the Republic of

22     Serbia.

23             JUDGE ORIE:  Please proceed.

24             JUDGE MOLOTO:  Mr. Lukic, before you proceed.  When Mr. Traldi

25     asked you to start somewhere, you said that where you started was the

Page 37349

 1     beginning of the first goal as you -- as it's written in the B/C/S.

 2             Now, there is a sentence in the English which I would like to

 3     check with you if it's not there the Serbian -- in the B/C/S, and if it

 4     is not there then it raises the question of a translation.

 5             Before that sentence that you started from, there is a sentence

 6     that says:

 7             "The first such goal is separation from the other two national

 8     communities.  Separation of states."

 9             Do you have that sentence in B/C/S?

10             MR. LUKIC:  It's on the previous page, Your Honour.  On this

11     page, I read what is in this paragraph on this page on the B/C/S.

12             JUDGE MOLOTO:  Okay.

13             MR. LUKIC:  I will read that sentence now.

14             JUDGE MOLOTO:  Okay -- no, no, no.  If it's there, that's fine.

15     Because that was what Mr. Traldi was trying to draw your attention to.

16     That's where the first goal starts.

17             MR. LUKIC:  See, now we went back one page and paragraphs are

18     differently divided.

19             JUDGE MOLOTO:  Fine.

20             MR. LUKIC:  In B/C/S those were two paragraphs, in English only

21     one.

22             JUDGE MOLOTO:  Okay.

23             JUDGE ORIE:  I think there is no disagreement any further on what

24     the text says on whatever page it may be.

25             MR. TRALDI:  I agree.

Page 37350

 1             JUDGE ORIE:  Yes.  Please proceed.

 2             MR. LUKIC: [Interpretation]

 3        Q.   Now I'm going to read out what I did not read out a moment ago.

 4     So we went one page back in B/C/S, the last paragraph on this page in

 5     B/C/S, and it is the second page -- the second paragraph on this page in

 6     English.  This is what is written there.  I quote:

 7             "The Serb side in Bosnia-Herzegovina, the Presidency, the

 8     government, the Council for National Security which we have set up, have

 9     formulated the strategic priorities of the Serb people.  That is to say,

10     the strategic goals for the Serb people.  The first such strategic goal

11     is separation from the other two national communities, separation of

12     states."

13             Today do you understand what is meant by this separation of

14     states?  I don't know if you've heard the question.  Do you have a

15     position on that?  Was this discussed in the Army of Republika Srpska

16     what this means, "separation of states"?

17        A.   May I respond?

18             JUDGE ORIE:  Please, do.

19             THE WITNESS: [Interpretation] Separation of states, well, I

20     assume that the officers I communicated with then believed that this is

21     first of all separation in Bosnia-Herzegovina if there is no other way of

22     reaching agreement and living together.  Separation of states was not

23     meant to be separation from the Republic of Serbia.  If you are asking me

24     for the broader concept, where Serbs lived - in Banija, Kordun, Lika,

25     Northern Dalmatia, Slavonia east and west - then Serbs were also supposed

Page 37351

 1     to live in those areas safely, securely.

 2             MR. LUKIC: [Interpretation]

 3        Q.   Do you know when Alija Izetbegovic declared mobilisation?

 4        A.   Well, I cannot remember the exact date --

 5        Q.   If not, then we're not going to guess.

 6        A.   No.

 7        Q.   Also it was put to you that General Mladic held inflammatory

 8     speeches at this assembly, referring to Ustashas.  At that time and

 9     before that time - that is to say, before the 12th of May, 1992 --

10     actually, let us start with the elections in 1990 when the HDZ came to

11     power.  What were the symbols that were adopted by the Republic of

12     Croatia; do you remember?

13        A.   I do remember.

14        Q.   Tell us.

15        A.   Symbols, first of all, well, first of all, they changed the flag

16     and the five-pointed star.  They took the chess-board as the symbol of

17     the Independent State of Croatia, and that is the symbol --

18             JUDGE ORIE:  One second.  The relevance of all this is still

19     arguable.

20             But, Mr. Traldi, is it the position of the Prosecution that the

21     Croats would not have used inflammatory language and if -- would not have

22     taken a rather nationalistic cause by emblems.  Is that your -- is that

23     the position or is there agreement that all parties may have ...

24                           [Prosecution counsel confer]

25             MR. TIEGER:  Mr. President, if I may respond to that.  I think it

Page 37352

 1     would be easier if we kept it as narrow and concrete as possible.  So

 2     there is certainly, to begin with, no dispute about the adoption of the

 3     chequer-board symbol at the time.

 4             Now, and I suspect -- I mean, Mr. Lukic could go on to other

 5     concrete steps or policies implemented by Croatian authorities that may

 6     or may not be relevant, and we could address those at once, but to go on

 7     to the characterisation and the impact might be more difficult.

 8             But, yes, there were nationalistic symbols employed by other

 9     sides.

10             JUDGE ORIE:  Please, Mr. Lukic --

11             MR. LUKIC:  I will move on.

12             JUDGE ORIE:  -- keep this in mind when you move on.

13             MR. LUKIC:  Only the witness said, and I would like the

14     transcript to reflect it, that in line 11, page 60:  "And that is the

15     symbol of Ustashas."

16        Q.   [Interpretation] General, now I'm going to ask you who

17     Rajko Kovacevic is.

18        A.   Rajko Kovacevic is a colonel in the command of the brigade in

19     Bjelovar, the garrison there.

20        Q.   Is that all you know of him, from the 1990s?

21        A.   No.

22        Q.   How did Mr. Kovacevic fair?  What was his destiny?

23             JUDGE ORIE:  Mr. Traldi.

24             MR. TRALDI:  I admit I don't immediately see how

25     Colonel Kovacevic or the garrison in Bjelovar is relevant.

Page 37353

 1             JUDGE ORIE:  Mr. Lukic.

 2             MR. LUKIC:  It's complete example, it's not just a story, of what

 3     happened in Croatia, and this gentleman has, I think, personal knowledge

 4     about this.

 5             JUDGE ORIE:  It's still linked to the previous one?

 6             MR. LUKIC:  Yes, Your Honour.

 7             JUDGE ORIE:  Is there any --

 8             MR. TRALDI:  I didn't cross-examine about Croatia in 1991 at all.

 9             MR. LUKIC:  We had inflammatory speeches, and those were not only

10     speeches in Croatia.

11             JUDGE ORIE:  What would like to put to the witness so that we can

12     first find out whether there's any dispute about the matter with the

13     Prosecution?

14             MR. LUKIC:  I want to ask him about concrete actions of Croatian

15     state.

16             MR. TRALDI:  Your Honour, I maintain my objection.  This is in no

17     way arises from the cross-examination I did.

18                           [Trial Chamber confers]

19             MR. LUKIC:  It does.

20             JUDGE ORIE:  Witness, before we decide on the objection, are you

21     aware of specific examples of inflammatory speeches by members of the

22     Croatian or the Muslim community specifically in 1991, and could you tell

23     us what you know about that?

24             THE WITNESS: [Interpretation] First of all, I would like to say

25     that the Republic of Croatia --

Page 37354

 1             JUDGE ORIE:  Witness, no.  I'd like you to answer my question.

 2     Do you have specific examples on your mind of inflammatory speeches such

 3     as this person said this on that occasion?  And I'm talking about

 4     Croatian or Muslim inflammatory speeches.

 5             THE WITNESS: [Interpretation] I am familiar with the speeches

 6     made by my commander, Martin Spegelj, who was arming and establishing an

 7     army apart from the JNA.

 8             JUDGE ORIE:  Okay.  He is a Croat?

 9             THE WITNESS: [Interpretation] Yes, he's a Croat, but he was a

10     general of --

11             JUDGE ORIE:  Okay.  Where did he make such an inflammatory

12     speech, if it was inflammatory?

13             THE WITNESS: [Interpretation] Well, it doesn't have to be

14     inflammatory, but he did hold such speeches in the area of Virovitica,

15     the garrison.

16             JUDGE ORIE:  But I asked you to give examples of inflammatory

17     speeches by Croats or Muslims and -- well, specific ones; that is, where

18     and when, by whom, and what they said.

19             THE WITNESS: [Interpretation] Well, all right.  Right now I

20     cannot give you exact examples, but I know, for instance, this commander

21     who -- yes.

22             JUDGE ORIE:  Witness, no.  You've answered my question.

23             Mr. Lukic, there's no dispute about similar attitudes taken by

24     the other parties.  The witness can't give us any examples.  You're

25     invited to move on.

Page 37355

 1             MR. LUKIC:  Thank you, Your Honour.

 2        Q.   [Interpretation] You mentioned the corridor in your testimony.

 3     What kind of information did you have before the operation of the opening

 4     up of the corridor was initiated?  What kind of forces were there in

 5     Derventa, Brod, Johovac, meaning 60 kilometres deep into the territory of

 6     Bosnia-Herzegovina across the Sava?

 7        A.   Yesterday or the day before I said that the Croat Muslim forces

 8     came from the north, from the Sava.

 9        Q.   Yes, that is precisely what you said.  Croat Muslim forces.

10             THE INTERPRETER:  Interpreter's note:  Would the speakers not

11     overlap.

12             THE WITNESS: [Interpretation] Croat forces came from the area of

13     Slavonski Brod in Croatia, and of course it also included the Croats from

14     Slavonski Brod.  They also came from the direction of Odzak and Modrica.

15             Let's make one thing clear:  Most of the Croatian forces came

16     from Brod and Derventa; and the Muslim forces came from Odzak and

17     Modrica.

18             MR. LUKIC: [Interpretation]

19        Q.   Very well.  As far as I understand, because Slavonski Brod means

20     something else to us.  You said Croats came from Slavonski Brod.  What

21     country is that?

22        A.   I said it is Croatia.

23        Q.   The Republic of Croatia?

24        A.   Yes.  Everything across the Sava is the Republic of Croatia.

25        Q.   While we seem to skip some things over every and now and then,

Page 37356

 1     for the record we need to have it perfectly clear and that is why I

 2     apologise for this clarification.

 3             You were asked about Colonel Hasotic and about the fact that he

 4     was replaced by Colonel Vukelic.  What do you know about

 5     Colonel Hasotic's departure, was he driven away, did he leave

 6     voluntarily, did he retire, did he stay, and, if, so until when?

 7        A.   When I arrived in the corps in March 1992, Hasotic was at the

 8     position of assistant commander of the corps for morale and political and

 9     legal affairs.  He remained at that position until a certain date which I

10     cannot recall now.  In any case, he was in that position for at least a

11     month while I was there.

12             Later on, sometime in May - again, I can't be precise - Vukelic

13     came in his stead.  There are orders in existence that can be verified

14     with the personnel department.  I think he left because most of the

15     fighters in the corps and the officers simply did not trust an officer in

16     charge of morale to be someone of a different ethnicity.  They considered

17     a Serb to be appropriate, reflecting the majority ethnic composition of

18     the units.

19        Q.   At transcript page 37146, lines 7 through 10, you were asked

20     about whether you know that General Talic and General Jokic were members

21     of the Crisis Staff, and you said that you knew about Talic being on the

22     Crisis Staff list, whereas you were not certain about Jokic.  Do you know

23     anything about the participation in the Crisis Staff, how often he

24     attended the meetings, did he have the right of vote, if you know?

25        A.   I know he was a member of the Crisis Staff.  He would go there

Page 37357

 1     when his tasks and duties permitted him to do that.  He wasn't always

 2     there.

 3             JUDGE ORIE:  Mr. Lukic, could I seek one clarification from the

 4     witness.

 5             Witness, you said that Hasotic was not -- because being a Muslim,

 6     he should not be in that position, commander of the corps for morale and

 7     political and legal affairs.

 8             Now, in your statement in paragraph 8 --

 9             Mr. Mladic should not speak aloud.

10             In your statement in paragraph 8, you say that colleagues were

11     not treated differently because of their ethnicity, and you give Hasotic

12     as an example.  Now, at the same time you tell us now that because he was

13     a Muslim he could not be trusted in that position and that therefore he

14     could not continue to do that work.  There's at least some friction

15     between using Hasotic as an example of how no difference was made in

16     relation to people of other ethnic origin and now telling us that because

17     he was a Muslim he could not hold that position in a plurality Serb army.

18             Any explanation for that?

19             THE WITNESS: [Interpretation] I do.  I assert that Hasotic lacked

20     the authority and the confidence of the rank-and-file members.  In

21     addition to Hasotic, there was a brigades commander by the name of

22     Smail Omic.  After a while, he too asked to be relieved of his duty

23     because he did not enjoy the full trust of his officers who were

24     predominantly Serb.

25             JUDGE ORIE:  Did Mr. Hasotic asked to be relieved of his office?

Page 37358

 1             THE WITNESS: [Interpretation] At the time, Hasotic did not ask

 2     for it, but --

 3             JUDGE ORIE:  Let me stop you there because I try to understand

 4     the comparison you made.

 5             Please, the next question, Mr. Lukic.

 6             MR. LUKIC: [Interpretation] Let us look at document number P3032.

 7        Q.   It is dated the 11th of May, 1992, with Lieutenant-General

 8     Ratko Mladic's typed signature.

 9             Let me ask you about the preamble of the order.  We are still

10     dealing here with the 2nd Military District Command, a day before the VRS

11     was formally established.  It states:

12             "... where needed in order to protect Serbian people and honest

13     members of other nationalities in the Serbian Republic of BH and

14     consolidate the operational position of units of the 2nd Military

15     District ..."

16             MR. LUKIC: [Interpretation] Let us look at P7460 next.  Command

17     of the 5th Corps dated the 12th of May, the next day.

18        Q.   This order is issued referring to the previous document,

19     basically consisting of the same preamble:

20             "For the purposes of protecting the Serbian people and honourable

21     member of other peoples in the SRBH and also for the purpose of us

22     strengthening the operational and tactical position of units of the

23     5th Corps ..."

24             Later on, on the 17th of May, another document was issued, we

25     will not show it, but it is P7122, it is something we have already seen,

Page 37359

 1     by the command of the 343rd Brigade.  They followed up on the -- on this

 2     command of the 5th Corps command.

 3             What is your understanding of the term "honourable members of

 4     other peoples"?

 5        A.   I've explained it several times already.  All those who

 6     implemented the tasks aimed at achieving this idea of the Serbian people

 7     about living together with others.  So all those who were in favour of

 8     co-existence with the Serbs and who were of military age and could be

 9     assigned to war units.

10        Q.   While we're still on this document, I will jump forward and ask

11     you something else about it so as not to have to go back to it later on.

12             Let me ask you this:  After the outbreak of the conflict, did the

13     VRS forcibly mobilise members of the non-Serb population in the territory

14     it controlled; if you know?

15        A.   I'm not familiar of any such cases.

16             THE INTERPRETER:  Interpreter's note:  We did not hear the end of

17     the answer.

18             MR. LUKIC: [Interpretation]

19        Q.   In this document, in item 2 --

20             THE INTERPRETER:  Interpreter's note:  Could we please have the

21     reference on the screens.

22             MR. LUKIC: [Interpretation]

23        Q.   It reads:  "Make sure that all able-bodied conscripts of Serb

24     nationality are conscripted" --

25             JUDGE FLUEGGE:  Can we go to the next page.

Page 37360

 1             MR. LUKIC:  It is the next page, I'm sorry.  I'll start from the

 2     next page.

 3             JUDGE FLUEGGE:  Next page in English.

 4             MR. LUKIC: [Interpretation]

 5        Q.   General, in item 2, we see as follows:

 6             "Ensure that without fail all conscription-eligible persons of

 7     Serbian ethnicity are mobilised as well as conscription-eligible persons

 8     of other ethnicities if they wish to fight for the just cause of the

 9     SRBH's struggle."

10        A.   This is what I said, at least the gist of it.

11        Q.   Could this be applied to the entire war?

12        A.   Yes, once the mobilisation is concluded, it is finished for the

13     time being, but there were several waves of conscription.

14             Now, there were cases in the 1st Corps, if I may say --

15             MR. LUKIC:  I think it's the break time, Your Honours, and

16     because I have to move to another document.

17             JUDGE ORIE:  Yes.  We'll take a break now and we'll resume at

18     quarter to 2.00.

19                           [Witness stands down via videolink]

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

21                           --- On resuming at 1.49 p.m.

22             JUDGE ORIE:  The Chamber understands that there's still have been

23     technical problems but let's just test to start with whether you can see

24     us and hear me.

25             I again now seeing that you've put on your headphones, could the

Page 37361

 1     registrar at the far end of the videolink confirm that he hears me and

 2     that he sees us.

 3             THE REGISTRAR: [Via videolink] Your Honour, we have lost the

 4     English channel again, so I cannot hear what's being said in the

 5     courtroom.

 6             JUDGE ORIE:  Okay.  Then we'll continue with procedural matters

 7     while waiting for the connection to the restored.  Once it is functioning

 8     again, we'd like to be informed about it.

 9             THE REGISTRAR: [Via videolink] Yes, Your Honours.  We have just

10     been reconnected.

11             JUDGE ORIE:  Yes, and now you can hear me and see us?

12             THE REGISTRAR: [Via videolink] Yes.

13             JUDGE ORIE:  Then let's continue, Mr. Lukic, and I wish you the

14     best as far as connections with concerned.

15             MR. LUKIC:  Thank you, Your Honour.

16             Can we have P7122 on our screens, please.

17        Q.   [Interpretation] General, before us is a document of the 343rd

18     Motorised Brigade command dated the 17th of May, 1992, Prijedor.  In item

19     1, we see that the following is being ordered:

20             "The commander of the staff of the Serbian municipality of

21     Prijedor, core members of the command and documentation shall be

22     relocated to the Zarko Zgonjanin barracks ..."

23             Do you know how many TOs they're existed in May, June, and

24     July of 1992, in Prijedor, all the way to September?

25        A.   I don't know precisely.  I know that there should be only one

Page 37362

 1     Territorial Defence when talking about the municipal TO Staff.

 2        Q.   One of organisations.  Let me ask you specifically:  Do you know

 3     anything about a logistics base in Cirkin Polje?

 4        A.   I don't know.

 5             JUDGE ORIE:  Mr. Traldi.

 6             MR. TRALDI:  I think my objection has been over taken by the

 7     witness's answer, but I'd object to further questions in that line.

 8             JUDGE ORIE:  Because?

 9             MR. TRALDI:  I think that logistics base is beyond the scope of

10     cross-examination.  It wasn't raised.  Again, it's -- depending on a

11     further question Mr. Lukic asks, if any, I'll articulate it more

12     specifically.  But just that I'd ask that if another one comes up, the

13     witness be instructed to wait.

14             JUDGE ORIE:  Yes, scope of cross-examination.

15             Please proceed, Mr. Lukic.

16             MR. LUKIC:  Since witness knows nothing about this, I will just

17     move on.

18             JUDGE ORIE:  Yes, please do.

19             MR. LUKIC:  Now I would ask to have P7325 on our screens.  7325.

20     And all the questions will be in relation to another document which we

21     are not going to open.  It's P2874.

22        Q.   [Interpretation] General, have you been shown this document which

23     was signed by the late General Gvero.  I will skip a number of questions

24     so as to speed things up.  I will go immediately to the part that was

25     read out to you by the Prosecution, which is on page 2 in both versions.

Page 37363

 1             In the English, it is the second paragraph; in the B/C/S, the

 2     third on this page, where some percentages are mentioned.  It reads:

 3             "The state-building Serbian people," I will skip the percentages,

 4     "... must fight for a total partition from the Muslim and Croatian people

 5     and must create their own state ..."

 6             However, you were not read out the following which comes

 7     immediately after this part.

 8             "It is only then that they will be able to decide for themselves

 9     who to join with, whom to link up, and in what way.  They do not want

10     what does not belong to them, what has not been theirs for centuries, but

11     they are not cede an inch of their territory."

12             We have already discussed delineation along border-lines and

13     ethnic lines.  I wanted to show you the last paragraph in the B/C/S next,

14     and it is also the last in the English.  In the B/C/S, we will have to

15     move to the next page after a while.

16             It reads:

17             "The Army of the Serbian Republic of BH is the army of the

18     Serbian people of all loyalists and patriots and of all the citizens who

19     are prepared to fight in its ranks for the just goals of the Serbian

20     people, the defence of the republic's territorial integrity and peace in

21     these parts."

22             Let me ask you this:  Do you have any information about whether

23     anyone, ever, being non-Serb and wanting to join the VRS was refused by

24     the 1st Krajina Corps?

25        A.   I'm not aware of any such case, but I do know that, for

Page 37364

 1     example -- would you allow me to respond to that?

 2        Q.   Go ahead, yes.  Briefly.

 3        A.   However, I do know that an entire platoon of ethnic Muslims in

 4     Derventa in the 322nd Brigade under the command of Djuharic,

 5     Captain Djuharic, also a Muslim, they stayed on in that unit up until the

 6     end of the war, and their name was Mesa Selimovic.

 7        Q.   Thank you.  I would like that finish with this document and then

 8     we're going to move onto the next one.

 9             MR. LUKIC: [Interpretation] 65 ter 02775, please.

10             [In English] Maybe it does have a P number, but I don't have it

11     registered.

12             THE REGISTRAR:  65 ter 2775 has already been admitted as

13     Exhibit P7463.  Thank you.

14             MR. LUKIC:  Thank you, Mr. Registrar.

15        Q.   [Interpretation] You were asked on transcript page 37170, I'm

16     going to quote the question and the answer, line 5.  It is related to the

17     distribution of weapons referred to in this document:

18             "Q. [In English] Now, this is an example of the 5th Corps arming

19     those subordinated Territorial Defence units that we talked about

20     earlier; right?

21             "A. Yes."

22             [Interpretation] So please do focus on the date, the 5th of May,

23     1992.  On the 5th of May, 1992, were TO units subordinated to the

24     5th Corps.

25        A.   Already then they were, and we have already seen an order that

Page 37365

 1     regulated that.  But let me say this, too:  Most probably this has to do

 2     with the return of weapons to these units in Gradiska and the other ones

 3     from the warehouses, depots.  Until then, that equipment was kept there.

 4        Q.   Do you know, for instance, in Kotor Varos, whether the

 5     composition of the Territorial Defence was mixed at that time, the 5th of

 6     May?  Were all ethnicities in the Territorial Defence or not?

 7        A.   I know of one particular case, an officer near Siprage, that's

 8     near Kotor Varos, that he stayed on until the end of the war.

 9        Q.   The 5th of May, 1992.  Do you know that there was a mixed

10     Territorial Defence in Kotor Varos or do you not know about that?

11        A.   I do not know about that.

12        Q.   Thank you.  Now let us look at P7464.  This is an interview given

13     by the late General Talic to Glas.  Portions of this document have

14     already been read out to you where General Talic says that nothing will

15     be taken from the Krajina.

16             And now I'm going to ask you the following:  Do you know about

17     any attempts of having weapons taken out, transported from the area of

18     the Krajina at the time?

19        A.   I am not aware of any such cases.  All of this equipment and

20     weaponry stayed in the territory of the 5th Corps.  I'm talking about the

21     5th Corps.

22        Q.   We'll move on.  In the same text, on page 3, we looked at it

23     yesterday, there was a reference to the school centre Petar Drapsin and

24     the Kosmos company.

25             Do you know whether military facilities, industrial facilities,

Page 37366

 1     whether they remained in territory held by the BH army and the HVO?

 2        A.   I know about that, I mean, in general terms, but I cannot speak

 3     individually about particular municipalities and so on.  I am more

 4     familiar with the situation in Croatia.

 5        Q.   Just a moment, please.  It will seem that you're saying something

 6     that I didn't ask you about.

 7             My next question:  Do you know whether there was any military

 8     equipment, weaponry, and military facilities left in Croatia?

 9        A.   I know about that because I served there.  Until the end of 2001,

10     I was in the territory of Croatia.  Everything stayed there.  The entire

11     structure.  Only 240 tanks to begin with.

12        Q.   All right.  Now let us look at P7467.

13             Yesterday we spoke about this, this document.  In the last

14     paragraph it says:

15             There is no official information about the purpose of General

16     Adzic's visit.  However, it is believed that ... and so on and so forth.

17             Were you personally informed about this meeting?

18        A.   I wasn't.  I see it's the 30th of April, and on the 30th of

19     April I was already at this new post for two days, and then I stayed on

20     there.  But later on, I did hear that that meeting had been held.

21        Q.   On transcript page 37188, lines 8 to 13, you were asked about the

22     establishment of operative groups.  Why were operation groups

23     established?

24        A.   Operation groups were established only for more successful and

25     better command and control over units.  I already said that the corps had

Page 37367

 1     127.000 soldiers, 48 units.  The front line was 1.260 kilometres long.

 2     It was manned from 27 municipalities and that that was only possible

 3     through establishing larger groups.  That is operations group, tactical

 4     groups, and those were units that could be independent, and that was the

 5     only way in which there could be successful command and control over

 6     units.  I don't know which commander could command 48 communications.

 7             JUDGE ORIE:  Mr. Lukic, I was not aware reading the transcript

 8     that it was any issue for the Prosecution on why and whether for good

 9     reasons or not operation groups were established.

10             Now apparently you focus on this, and I thought that was a

11     totally different matter.

12             MR. LUKIC:  I thought it would be just short answer.  I'll move

13     on.

14             JUDGE ORIE:  Yes, but -- I mean, short answers or long answers,

15     if it's irrelevant or it doesn't in any way challenge the evidence

16     presented in cross-examination, then even short answers should not be

17     there.

18             Please proceed.

19             MR. LUKIC:  Thank you, Your Honour.

20        Q.   [Interpretation] On transcript page 37189 from line 17 to

21     line 23, there was a reference to the command post in Manjaca.  You said

22     that that post at that time was not fully activated.

23             Command -- or, rather, was the command ever there in operative

24     terms?

25             MR. TRALDI:  Objection.

Page 37368

 1             JUDGE ORIE:  Objection, based on?

 2             THE WITNESS: [Interpretation] No.

 3             MR. TRALDI:  First, it's not responsive to cross.  The command

 4     and a command post are different things.

 5             JUDGE ORIE:  This is -- should we not invite the witness to take

 6     his earphones off if you're --

 7             MR. TRALDI:  Yes, Your Honour.  I apologise.

 8             JUDGE ORIE:  Could you take your earphones off for a second.

 9             MR. TRALDI:  What I put to the witness was that a command post

10     was there.  Asking whether the command was there, as in the corps

11     command, doesn't I think arise out of the question I asked.

12             MR. LUKIC:  Exactly.  That's why I want to establish that command

13     was never there.  Just command post, technically.  But we have to know

14     whether 1 kilometre from Manjaca camp was command of this corps ever or

15     at that time.  I think it's crucial.  Command post means nothing.  If

16     it's --

17             JUDGE ORIE:  The witness said:

18             "... I have to stress that command post at that time was not

19     fully activated.  It had a communications system and it had a security

20     detail ... but the main command post was in Stara Gradiska."

21             MR. LUKIC:  Yes, at that time.

22             JUDGE ORIE:  Yes.

23             MR. LUKIC:  And I want to ask him whether at a later point in

24     time, ever, a command of his corps or part of command of his corps was

25     ever there.  That's my intention.

Page 37369

 1             MR. TRALDI:  Understanding Mr. Lukic's better, I'll withdraw my

 2     objection.

 3             JUDGE ORIE:  Yes.  Then please could the witness put on his

 4     earphones again.

 5             And I think it's to some extent implicit on what there was and

 6     what there was not.

 7             Please proceed.  Use your time as you wish, Mr. Lukic, but don't

 8     be surprised --

 9             MR. LUKIC:  I will use at least half a minute to conclude.

10             JUDGE ORIE:  Please do.

11             MR. LUKIC: [Interpretation]

12        Q.   So, General, at that location that we discussed, at Manjaca, and

13     you said it was not fully activated, this command post, and that it had a

14     communications system.  At that time or perhaps later, was the command or

15     part of the command of the 1st Krajina Corps ever there?

16        A.   During the final operations in 1995 when the area of

17     Mrkonjic Grad, Sipovo, and so on - I don't want to waste time by

18     enumerating all of that - that command post was activated.  That's the

19     command post at Manjaca.

20        Q.   Before that?

21        A.   Before that, the command post --

22        Q.   No, no, at Manjaca.  Was the command ever at Manjaca of the

23     1st Corps?

24        A.   The command was not there at all.  It was just communications

25     equipment, security, and the operations duty officer.

Page 37370

 1        Q.   Thank you, General.  That will be all for the day, so we will be

 2     troubling you tomorrow as well.  We'll have to.

 3             JUDGE ORIE:  Then we'll conclude -- could the witness put on his

 4     earphones again.

 5             We'll conclude for the day.  We would like to see you back

 6     tomorrow morning at 9.30, Witness.  And I again instruct you that you

 7     should not speak or communicate in whatever way, with whomever, about

 8     your testimony, whether already given or still to be given.

 9             We can now disconnect the videolink.

10             THE WITNESS: [Interpretation] I understand.  I understand.

11                           [Witness stands down via videolink]

12             JUDGE ORIE:  Then, Mr. Lukic.

13             MR. LUKIC:  I am moving fast since I skipped some questions.

14             JUDGE ORIE:  Okay.  What is the expectation so that we can look

15     at it for tomorrow?

16             MR. LUKIC:  I think session and a half, if videolink is okay.

17             JUDGE ORIE:  Mr. Traldi, having heard the re-examination as it

18     developed until now, what would be your expectation if the re-examination

19     would not change its character.

20             MR. TRALDI:  It's a little bit hard to gauge because the scope of

21     it is unprecedented in this trial, but I wouldn't say I have terribly

22     much thus far.  Ten minutes or less for certain, but I could be more

23     accurate in the morning.

24             JUDGE ORIE:  Then let's try to work out a plan for tomorrow.

25             Mr. Lukic, we will reserve the first two sessions to conclude the

Page 37371

 1     evidence of this witness.  That's two hours.  If the videolink is

 2     functioning well, that should do.  We would then finish at 11.50.  We'd

 3     resume at 10 minutes past 12.00 with the next witness, and I think all

 4     together the evidence of that witness should not take more than two

 5     hours.  Half an hour and one hour.  That's one hour and a half.  That

 6     leaves some time.  That would bring us to, most likely, 2.30.

 7             The Chamber wants to deliver quite a number of decisions and

 8     needs approximately 30 to 40 minutes for the remainder.  Perhaps a little

 9     bit less because we've done already quite a bit with it.  We'll try to

10     arrange for an extended session tomorrow and trying to finish not later

11     than half past 3.00 in the afternoon.

12             MR. LUKIC:  For evidentiary matters, probably we don't need

13     Mr. Mladic for us.

14             JUDGE ORIE:  I beg your pardon.  For the?

15             MR. LUKIC:  For evidentiary matters probably we do not need

16     presence of Mr. Mladic.

17             JUDGE ORIE:  You mean procedural matters?

18             MR. LUKIC:  Procedural, yeah.

19             JUDGE ORIE:  Well, Mr. Mladic is --

20             MR. LUKIC:  I'll consult with him soon.

21             JUDGE ORIE:  Yes, if he waives his right to be present.  If we

22     get to the details of D so-and-so numbers, then I leave it entirely in

23     the hands of the Defence whether such a waiver will come or not.

24             We adjourn for the day, and we'll resume tomorrow, Thursday, the

25     16th of July, 9.30 in the morning, in this same courtroom, I.

Page 37372

 1                            --- Whereupon the hearing adjourned at 2.19 p.m.,

 2                           to be reconvened on Thursday, the 16th day of July,

 3                           2015, at 9.30 a.m.