150812IT

Page 37654

1 internet. So there is a mixture.

2 JUDGE ORIE: Yes. And that's all put together in one file. Yes?

3 THE WITNESS: [Interpretation] Yes, that's right.

4 JUDGE ORIE: We'll see whether that assists.

5 Then we'll now continue to hear your evidence.

6 Mr. Lukic.

7 But before we do so, Mr. Gojkovic, I'd like to remind you that

8 you are still bound by the solemn declaration you have given at the

9 beginning of your testimony, that you'll speak the truth, the whole

10 truth, and nothing but the truth.

11 Mr. Lukic.

12 MR. LUKIC: Thank you, Your Honour.

13 WITNESS: DRAGIC GOJKOVIC [Resumed]

14 [Witness answered through interpreter]

15 Re-examination by Mr. Lukic:

16 Q. [Interpretation] Good morning, Mr. Gojkovic. Good morning,

17 Mr. Gojkovic.

18 A. Good morning.

19 Q. Yesterday we were talking about the mosque in Srebrenica, the

20 destroyed mosque in Srebrenica. Do you have any information where the

21 military units went after Srebrenica, and do you know how? This is after

22 the action in Srebrenica.

23 A. As far as I know, although I wasn't really interested much in all

24 of that, I know that the units set off towards Zepa immediately after

25 Srebrenica. It's also -- it was also a safe area.

Page 37655

1 Q. Do you know when that was? If you don't, just say so and we'll

2 move on.

3 A. I really don't know.

4 Q. Do you know when the police station was set up in Srebrenica?

5 Again, if you don't know just say so.

6 A. I really don't know.

7 MR. LUKIC: [Interpretation] Could we please look at P7493.

8 Q. You were shown the document yesterday. It's from the command of

9 the 1st Engineers Regiment, signed by Major Nastic; is that correct?

10 A. Yes.

11 MR. LUKIC: [Interpretation] Can we please look at the next page.

12 Only the part that was translated into English has been uploaded. We

13 will ask that the whole document be translated. We have the whole

14 document in front of us. I didn't know that it was uploaded in the way

15 in which it was given to us.

16 Q. But I'm going to ask you this: When the engineering units were

17 out in the field, how did they communicate with the units that they were

18 resubordinated to or to whom they were providing support? Do you know

19 what the communications were between the engineers units and these other

20 units when they worked together?

21 A. Well, in any case, the communication was difficult.

22 Q. Do you know what sort of communications you had? Was it radio

23 communications, personal contacts?

24 A. It was a combination. Mostly we went to the actual units.

25 Q. Did you have radio communications with these units?

Page 37656

1 A. No. We communicated exclusively through units to which our units

2 were resubordinated, yes. In such cases, yes, but it was rare.

3 Q. We will find that in this blocked-out part of the document.

4 A. Well, if I can just continue. There was the case of the

5 Prnjavor Brigade to which we sent a pioneers platoon during the corridor

6 operation. We could never bring that platoon back to us, the

7 Prnjavor Brigade never allowed it to come back to our unit.

8 Q. All right. Thank you. I can see that my colleague is on his

9 feet, so could you please just stop for a moment.

10 MR. TRALDI: I've taken a moment on this line of questioning,

11 Your Honour, but I don't see how it arises from my cross-examination and

12 so I'd object.

13 JUDGE ORIE: Mr. Lukic.

14 MR. LUKIC: It arises from the document provided to us.

15 MR. TRALDI: It arises from portions of the document that weren't

16 tendered, that weren't used with the witness, and so doesn't arise from

17 cross-examination, in my submission.

18 JUDGE ORIE: Unless there's such a contextual issue that we could

19 not stop reading where this document, which is not a complete document --

20 MR. TRALDI: Unless -- right. Unless it relates to the portions

21 that were used or tendered or to another topic from cross-examination,

22 but I don't understand that to be the submission that Mr. Lukic made.

23 JUDGE ORIE: Mr. Lukic, is there any direct link to the

24 cross-examination apart from that it's the same document? But is it, as

25 far as the subject matter concerned, related?

Page 37657

1 MR. LUKIC: The --

2 JUDGE ORIE: If not, then --

3 MR. LUKIC: There is also one portion further in this document

4 that will be directly linked to the portion we read yesterday, but we

5 think that this is also crucial in understanding the situation in the

6 field.

7 JUDGE ORIE: Well, it's not a matter of whether it's crucial to

8 understand the situation in the field but rather whether it's linked to

9 what was raised during cross-examination. It's not a reopening of your

10 examination-in-chief.

11 The Chamber has, of course, difficulties in evaluating what you

12 said, because it was only the limited portion that was uploaded. And

13 this leads me to another question. You said we have now the whole of the

14 document before us. I see that the redacted document is three pages in

15 B/C/S as uploaded, and the redaction on page number 3 goes to the very

16 bottom of that. Does that mean that under the black part that we see --

17 as a matter of fact, we don't see that it's there, that the document

18 ends?

19 MR. TRALDI: Your Honour, maybe I can assist.

20 What we'd uploaded originally as the full version of the B/C/S

21 was this full document and a couple of attachments to the document. What

22 was admitted was just the portion that I used with the witness, and

23 that's section 2, the Morale of Unit, and the cover page, just to reflect

24 what the document is.

25 So the original B/C/S, 32853 has, I think, 24 pages including the

Page 37658

1 attachments.

2 JUDGE ORIE: So what is in a redacted format before us is not the

3 whole of the document?

4 MR. LUKIC: Is not the whole of the document.

5 JUDGE ORIE: Okay. Then you said there was another part which

6 could be directly linked to cross-examination. If you would ...

7 [Trial Chamber confers]

8 JUDGE ORIE: Mr. Lukic, you announced that there was another

9 portion which will be, as you said, directly linked to the portion you

10 read yesterday. Is it -- were you --

11 MR. LUKIC: Mr. Traldi --

12 JUDGE ORIE: -- Mr. Traldi.

13 MR. LUKIC: Mr. Traldi read yesterday.

14 JUDGE ORIE: Okay. Then tell us where it is, what it is, so that

15 we can see whether it's --

16 MR. LUKIC: Yes. So Mr. Traldi was talking yesterday about

17 forcible mobilisation of a big number of people, especially Muslims and

18 Croats. And on page 7 in B/C/S, that's not translated, under number 6,

19 which is Security, "Bezbednost."

20 I will read the portion of the document.

21 JUDGE ORIE: Please do so.

22 MR. LUKIC: [Interpretation] "Extreme nationalism did not have any

23 effect on our units. Members of both the Croatian and Muslim ethnic

24 groups, for the most part, did not respond to the call up to the unit,

25 but those who did respond initially mostly remained in the units."

Page 37659

1 Q. Mr. Gojkovic, do you know --

2 A. Yes, I know about this and this remark is correct.

3 Q. Any mobilisation, by its very nature, is forceful?

4 A. That's correct.

5 Q. Were there any arrests, however, in your unit of Muslims and

6 Croats who did not respond to the call up, as far as you know?

7 A. No. Not a single Muslim or Croat was brought to the unit by

8 force. As long as I was the commander, I assume afterwards as well when

9 Milan Nastic was the commander and Stanko Vuckovic as well, it was the

10 same.

11 JUDGE ORIE: Well, we're not that much interested in assumptions,

12 but I do understand that that's what the witness assumes.

13 Please proceed.

14 MR. LUKIC: [Interpretation]

15 Q. As for this part that is in front of us and that has been

16 translated, I am going to ask you something. Do not read. What was the

17 material situation of the soldiers who were members of your unit?

18 A. As far as equipment, explosives, et cetera, it was quite

19 satisfactory. As far as uniforms are concerned, food, finance, it was

20 miserable, really.

21 Q. Did people receive salaries?

22 A. No. Perhaps some individual companies that could ensure

23 something for a certain number of soldiers, those who were better off,

24 but most of the members of the unit did not receive any money whatsoever.

25 Q. Could you tell us, briefly now, how this functioned? People were

Page 37660

1 in the army and you say some companies did make payments.

2 A. Well, you had certain companies. I mean, all people who

3 responded to call up had worked before that. There were some companies

4 that were better off and that managed, in some way, to pay salaries to

5 their employees. That kind of thing did happen. It's not that these

6 were big salaries but they did receive some money. However, it was

7 really a small number of soldiers, members of the unit, that were

8 affected.

9 Q. Since there is a reference here to the deteriorated materiel

10 situation in this part that was translated, could you tell us about

11 clothing, footwear, beds, bedding?

12 A. Very poor. What can I tell you? I mean, if you have a situation

13 when most of your soldiers hitch-hike to the front line and back, that is

14 telling.

15 Q. Thank you. We're done with this document, I believe.

16 JUDGE ORIE: Could I ask one additional question.

17 This Chamber has heard evidence that Muslims and Croats were not

18 always still employed by their companies and that some were fired or sent

19 away. Do you know anything about whether Serbs, Muslims, and Croats were

20 equally treated as far as payment by their companies is concerned? If

21 you don't know, tell us as well.

22 THE WITNESS: [Interpretation] If they were a member of the unit,

23 all were treated equally. It depended on the companies involved, how

24 well off they were.

25 JUDGE ORIE: But was the situation in the companies, as far as

Page 37661

1 continued employment is concerned, the same for all ethnicities?

2 THE WITNESS: [Interpretation] That's correct. The same.

3 JUDGE ORIE: Are you aware or do you have any knowledge about

4 some ethnicities not being able to continue to work in their companies,

5 whereas others were?

6 THE WITNESS: [Interpretation] No, no. Everybody. All members of

7 other ethnicities who happened to be in the army of Republika Srpska

8 remained at their jobs. We never received any complaints from a single

9 soldier.

10 JUDGE ORIE: Yes, but apart from complaints do you have factual

11 knowledge about Muslims, Croats, and Serbs being equally employed and

12 continued to be employed by their companies?

13 THE WITNESS: [Interpretation] This was discussed fairly often at

14 briefings, and there were no such problems.

15 JUDGE ORIE: Please proceed.

16 MR. LUKIC: [Interpretation] Thank you.

17 Q. Now I'm going to ask you something that was discussed rather

18 extensively yesterday, and I must say that it remains unclear to me,

19 even. You were asked how those 10 places of worship were destroyed in

20 combat and 84 after the withdrawal of the JNA, how you made this

21 distinction.

22 You said that in Riedlmayer's report you found a source for that.

23 Could you tell us -- could you explain this to us: On the basis of what

24 did you draw these conclusions?

25 A. On the basis of the state of the building involved and the

Page 37662

1 description that Riedlmayer provided in his report, and then I singled

2 out Kotor Varos, Hambarine -- no, no. It's the mosque in Haradjani

3 [phoen] in Kotor Varos, in Vecici Kotor Varos, the new mosque in Vecici

4 Kotor Varos. It's the mosque Hadrovic [phoen] in Kotor Varos. It's the

5 mosque in Prijedor. The Prijedor mosque in Cevici. It's Suceska mosque

6 in Srebrenica, it is the Tokalici mosque in Srebrenica. It's the mosque

7 in Sase in Srebrenica. It's the mosque in Vidikovac also in Srebrenica.

8 And it's the town Catholic church also in Srebrenica. I worked on that

9 basis.

10 Had I had a bit more time -- the Trial Chamber objected that it

11 was not done in detail, and had I had more time, I would have dealt with

12 it in greater detail.

13 JUDGE FLUEGGE: Mr. Lukic, in your question you referred to the

14 withdrawal of the JNA. Did you mean JNA? I remember that we discussed

15 yesterday the --

16 MR. LUKIC: VRS.

17 JUDGE FLUEGGE: -- withdrawal of the VRS.

18 MR. LUKIC: Thank you, Your Honour, you are right.

19 JUDGE FLUEGGE: But I take it that the witness understood it in

20 the same way.

21 MR. LUKIC: Yes, I hope so.

22 JUDGE FLUEGGE: That you wanted to refer to the VRS.

23 MR. LUKIC: Yes, thank you.

24 JUDGE ORIE: Could I ask one additional question here.

25 Witness, the large number is destruction of religious building

Page 37663

1 taking place after VRS withdrawal. That's, as you described it, for 84

2 buildings. Are you telling us that in Mr. Riedlmayer's report you would

3 find whether or not at the time he assumed the buildings were destroyed

4 that he gives information as to whether the VRS had withdrawn, yes or no?

5 THE WITNESS: [Interpretation] I really cannot say with

6 certainty -- I mean, well, you see, maybe there were some soldiers who

7 remained in a particular area. I cannot say anything. I didn't manage

8 to analyse that kind of thing.

9 JUDGE ORIE: Witness, I'm asking you whether you found that

10 information in Mr. Riedlmayer's report for all of those 84 for which you

11 said that they had been destroyed after VRS withdrawal. Whether

12 Mr. Riedlmayer --

13 THE WITNESS: [Interpretation] No.

14 JUDGE ORIE: -- gives that information.

15 THE WITNESS: [Interpretation] No, no, no. No.

16 JUDGE ORIE: So earlier I think you emphasized that whatever you

17 found here was based on Mr. Riedlmayer's report.

18 Now, if Mr. Riedlmayer's report does not contain information

19 about VRS withdrawal, how for those 84 you could establish on the basis

20 of Riedlmayer's report that the VRS had withdrawn?

21 THE WITNESS: [Interpretation] As for these 10 buildings,

22 Riedlmayer and --

23 JUDGE ORIE: Witness, Witness, Witness --

24 THE WITNESS: [Interpretation] -- the photographs.

25 JUDGE ORIE: Witness, I'm talking about the 84 destroyed after

Page 37664

1 VRS withdrawal.

2 THE WITNESS: [Interpretation] I assume that -- let me tell you,

3 as for these 10 buildings, Mr. Riedlmayer mentions them but the way in

4 which other buildings were destroyed. I mean, there is no combat there.

5 No nothing. He includes these 10 buildings at the time of combat, and

6 that can be seen from the pictures.

7 So if one says that in Cerici, in the Prijedor municipality, a

8 minaret was targeted and it fell onto the building; that is to say, it

9 was not blown up, it was targeted using other weapons, that's what I'm

10 talking about.

11 JUDGE ORIE: Witness, do I understand your testimony well that if

12 Mr. Riedlmayer does not state that the destruction took place during

13 combat operations that you assumed, more or less automatically, that the

14 VRS had withdrawn when the building was destroyed?

15 THE WITNESS: [Interpretation] Your Honour, Riedlmayer doesn't

16 write about that anywhere, and he doesn't draw any conclusions. He just

17 takes statements from witnesses, and he takes information from the

18 Islamic religious community. Riedlmayer never mentions anything like

19 that. He doesn't draw any conclusions. He just transmits what he was

20 told by others. So he did not devote himself to an analysis of that,

21 either.

22 JUDGE ORIE: Please proceed.

23 MR. LUKIC: [Interpretation].

24 Q. I'm going to put a leading question, and I don't think that

25 anybody will mind.

Page 37665

1 The information that the VRS had withdrawn, that is your

2 conclusion?

3 A. Absolutely.

4 JUDGE ORIE: And a conclusion based on what?

5 THE WITNESS: [Interpretation] That conclusion is based on the

6 fighting simply stopping. That the units withdrew, that there were no

7 war operations. Now, whether somebody was just milling about in order to

8 loot, torch, that is something I cannot say. I cannot speak about that.

9 I don't know.

10 You know what? Everybody wears a uniform and then somebody who

11 saw somebody in uniform doing something near a mosque and saying it's a

12 soldier, well, that's very hard to explain.

13 JUDGE ORIE: Witness, let me then clearly ask you the following:

14 You say once combat stops, you automatically assume that troops are not

15 functional anymore in securing control over that area. Is that how we

16 have to understand your testimony?

17 THE WITNESS: [Interpretation] That's right.

18 JUDGE ORIE: Thank you. That's an answer.

19 Please proceed, Mr. Lukic.

20 MR. LUKIC: Thank you, Your Honour.

21 Q. [Interpretation] I'm just going to put one more question. Why do

22 you draw that conclusion? On what basis?

23 A. Well, I have some experience. I spent four years in the war and

24 I saw how units of the VRS operated. When Modrica was liberated, when --

25 well, I can't -- Kotor Varos, when Kotor Varos was liberated, the army

Page 37666

1 withdrew immediately, automatically. They had nothing to do. What would

2 they have to do? When the place was liberated, they would withdraw their

3 equipment. And whether hyenas came in, doing whatever it was that they

4 did, I cannot talk about that. I cannot testify about that.

5 JUDGE ORIE: Let's just take one example, once, whether there was

6 much combat or not, I leave that alone. But once -- as you express it,

7 for example, Srebrenica was liberated, does that mean that all the troops

8 disappeared from that area?

9 THE WITNESS: [Interpretation] I personally think that they had

10 nothing more to do. I mean, I don't know when it was that the leadership

11 of the state appointed a president, when a government was set up. I

12 cannot talk about that. I cannot testify about that. But I think that

13 once combat operations are over, I don't see what the role of the army

14 would be there. Only if there were to be a military administration.

15 JUDGE ORIE: Please proceed.

16 MR. LUKIC: [Interpretation] Thank you.

17 Q. You mentioned seven hours. You said that you worked on this for

18 seven hours.

19 A. Yes.

20 Q. You were paid to work for seven hours, but how long did you work

21 personally?

22 A. I think about 140 hours, but then all my assistants -- so I think

23 that the figure would be --

24 THE INTERPRETER: Interpreter's note: We did not hear the

25 figure.

Page 37667

1 JUDGE ORIE: Could the witness repeat the figure.

2 MR. LUKIC: [Interpretation]

3 Q. It hasn't been recorded, how long your assistants?

4 A. I worked 130 hours. And the people I involved in this effort, I

5 think that 500 hours would be the figure involved.

6 Q. Thank you.

7 JUDGE MOLOTO: Sorry, Mr. Lukic.

8 MR. LUKIC: Yes.

9 JUDGE MOLOTO: Mr. Gojkovic, at page 18, line 21, you are

10 recorded as having said that you worked 140 hours; and at page 19,

11 line 3, you said 130 hours. Can you just tell us which is correct

12 between the two?

13 THE WITNESS: [Interpretation] 140 hours. However --

14 JUDGE MOLOTO: Thank you so much.

15 THE WITNESS: [Interpretation] -- when that was translated here in

16 The Hague Tribunal, then it was 130 so then I said that. I mean, it's

17 the Registry, actually.

18 JUDGE MOLOTO: Thank you, Mr. Lukic.

19 MR. LUKIC: Thank you, Your Honour.

20 [Interpretation] Can we now take a look at 1D5894.

21 Q. Before it appears on our screens, you mentioned a conversation

22 with Mr. Davidovic. Did you take a document from him?

23 A. Yes. I talked to him and I took a document that had to do with

24 the destruction of the Ferhadija mosque in Banja Luka.

25 Q. We received that document late, so we didn't manage to translate

Page 37668

1 it. It's a document of the Ministry of Religion of the government of

2 Republika Srpska from 8th of May, 1995, and it says:

3 "Announcement" --

4 A. I'm sorry, Mr. Lukic. This is a document from 1995, and it has

5 to do with the destruction of the Petricevac monastery near Banja Luka.

6 Q. We can see the signature, that was Minister Dragan Davidovic at

7 the time, and you mentioned it in your testimony. Is that the document

8 that you took from him?

9 A. Yes. And he told me then that he had the same sort of document

10 for the two mosques that were destroyed in 1993 but he wasn't able to

11 find it.

12 Q. Could you please just tell us what the gist of the document was?

13 Is it -- does it indicate that the minister or the Ministry for Religion

14 was in favour or against the destruction?

15 A. Absolutely against. As is the case for the vast majority of the

16 citizens of Banja Luka.

17 MR. LUKIC: We would ask Your Honours to MFI this document, since

18 there is no translation. And it was discussed yesterday during the

19 cross-examination.

20 JUDGE ORIE: Well, the document was not discussed but the

21 information received from the minister, I think, was -- Mr. Davidovic was

22 something that was discussed.

23 MR. TRALDI: We have no objection to MFI'ing it.

24 JUDGE ORIE: Madam Registrar, the number would be?

25 THE REGISTRAR: Document 1D5894 receives number D1184, Your

Page 37669

1 Honours.

2 JUDGE ORIE: D1184 is marked for identification.

3 MR. LUKIC: And the last document I would like to show is P7496.

4 JUDGE ORIE: While waiting for it, could I ask the witness: The

5 document which was on our screen a second ago only in the B/C/S version,

6 did you provide that to the Defence?

7 THE WITNESS: [Interpretation] I did.

8 JUDGE ORIE: When did you do that?

9 THE WITNESS: [Interpretation] I did it at the time when I was

10 providing the Defence team in Banja Luka with documents, hard copies of

11 documents.

12 JUDGE ORIE: And was that in --

13 THE INTERPRETER: Could the witness please repeat what he said.

14 THE WITNESS: [Interpretation] It was on the 2nd of February,

15 2015.

16 JUDGE ORIE: Yes. So it's for quite a while in the hands of the

17 Defence, I do understand.

18 Please proceed.

19 MR. LUKIC: [Interpretation] Thank you.

20 Q. You were shown the document yesterday. It's an article from the

21 "New York Times." An excerpt was read to you where Simo Drljaca says

22 that you should not only knock down the minaret but also you need to

23 shake the foundations of the mosque. Were you aware of the position of

24 the authorities? Do you know what the position was of Mr. Karadzic, for

25 example? We have that in this document and it wasn't read to you, but do

Page 37670

1 you know about it?

2 A. I don't know about Karadzic, but I know about the reaction. I

3 sat with Mr. Radic on a number of occasions. He was the president of the

4 Banja Luka municipality at the current post of General Talic in Prnjavor,

5 and I know that this was very strongly condemned.

6 As for Mr. Simo Drljaca, his statement does not comport with the

7 actual situation of the buildings that were destroyed in the field. This

8 is his own story. He didn't actually implement on the ground what he's

9 talking about here.

10 Q. Let me ask you this: Neighbouring municipalities around

11 Prijedor, were places of worship destroyed in those municipalities; do

12 you know?

13 A. Since I held the bridge across the river Sava from Jasenovac to

14 Srbac in the municipality of Dubica in 1992, nothing was destroyed, in

15 the Gradiska municipality nothing was destroyed, in Srbac, Laktasi

16 municipalities, nothing was knocked down either. Banja Luka also.

17 Except when I was the commander of the pontoon battalion, one Catholic

18 building was torched in Topola, and I sent the military police there,

19 then, to see what had happened, and I also provided security there until

20 the people from the Gradiska MUP arrived. The first building that was

21 destroyed in the territory of the municipality of Gradiska was sometime

22 in February 1993.

23 Q. I will just ask you this. It's about the people under your

24 command, Serbs, Muslims, Croats, other ethnic groups as well. What sort

25 of training did they receive? Was there any difference in training of

Page 37671

1 people from different ethnic groups in terms of their equipment, weapons?

2 A. No, it was all uniform. There was no difference. Again, I would

3 like to say that the operations officer in my regiment was a Croat

4 throughout the whole war. He was a really good officer.

5 JUDGE ORIE: Could you please limit your answers to what is

6 asked.

7 Please proceed.

8 MR. LUKIC: Thank you, Your Honour.

9 THE WITNESS: [Interpretation] I understand, Your Honour.

10 MR. LUKIC: [Interpretation]

11 Q. I'm not going to show you the document. You were shown

12 yesterday, some documents from the radical party paper, Vojislav Seselj's

13 party. You were shown two cartoons. The text from this article as well

14 as the activities of Dr. Seselj, what sort of influence did they have on

15 the work of your unit? Did you read that paper, Zapadna Srbija?

16 A. I never read the paper during the war. I never saw it. I don't

17 remember its name. At the time, the work of the Serbian Radical Party

18 was something that I was not interested at all, and ultimately

19 General Mladic ordered that we were not permitted to be members of any

20 political party. This was something that also was in force after the

21 war. A witness of The Hague Tribunal -- I actually didn't know anything

22 about the work of Dr. Vojislav Seselj, and I didn't know anything about

23 him.

24 Q. Mr. Gojkovic, thank you very much. These were all the questions

25 that we had for you.

Page 37682

1 A. When we were going to the wedding, it was Mladjo Kenjic who was

2 driving us, and there was no communications equipment in the car.

3 Q. Did you see your husband, General Mladic, during those days that

4 he was using any communications equipment, either his own or somebody

5 else's?

6 A. No, no, no. I mean, even before when he would come, he did not

7 do that, and this time he didn't either.

8 Q. Mrs. Mladic, thank you. That is all that the Defence have for

9 you at this moment.

10 A. You're welcome.

11 JUDGE ORIE: Thank you, Mr. Lukic.

12 Ms. Mladic, you'll now be cross-examined by Ms. Hasan. You'll

13 find Ms. Hasan to your right. Ms. Hasan is counsel for the Prosecution.

14 Ms. Hasan, please proceed.

15 MS. HASAN: Good morning, Your Honours. Good morning everyone.

16 Cross-examination by Ms. Hasan:

17 Q. Good morning, Mrs. Mladic.

18 A. Good day.

19 Q. When was it that you married Mr. Mladic?

20 A. We got married on the 24th of April, 1966.

21 Q. So am I right that you will have just had your 49th wedding

22 anniversary?

23 A. Yes, you're right.

24 Q. When was it that you first learned that the Tribunal here in

25 The Hague had issued an indictment against your husband?

Page 37683

1 A. It would be perhaps in 1996, 1997 that I heard that.

2 Q. Well, I can imagine that that's a pretty significant event, to

3 learn that criminal charges for genocide, war crimes, and crimes against

4 humanity are being laid against your husband. You don't even remember

5 the year, whether it was 1996, 1997?

6 A. No, I really cannot recall when it was that I first heard about

7 that. But I think it was 1996.

8 Q. When you learned that, I take it you were afraid for your

9 husband?

10 A. Yes, of course.

11 Q. And you didn't want to see anything bad happen to him; is that

12 right?

13 A. Yes, that's right.

14 Q. You certainly didn't want to see -- don't want to see your

15 husband convicted for any of these crimes, do you?

16 A. Well, I am sure that he could not have committed such crimes, and

17 that is why I believe that he does not deserve to be convicted.

18 Otherwise, I condemn any crime, even if it were committed by my husband.

19 Q. When was the last time you were in touch with your husband before

20 he was arrested?

21 A. I beg your pardon, could you please repeat that question?

22 Q. When was the last time you were in touch with your husband before

23 he was arrested?

24 A. On the 28th of June, 2001. I think the day when

25 President Milosevic was arrested. My husband was at home and soon, a

Page 37684

1 couple of hours later, he left the house, I think.

2 Q. And you formed the belief that your husband was dead, isn't that

3 right, at some point after he left?

4 A. Well, I was convinced because he had had strokes in 1996, as far

5 back as that. So we were thinking we hadn't heard from him, about him,

6 for a long time, and that is why we thought that. And later on when he

7 was arrested, it became obvious that he was in a very difficult state.

8 Q. Now, you refer to "we." Who are you referring to there?

9 A. When I said "we," I said "we believed that he was sick and that

10 he was not alive," is that it? When I'm saying that, I'm referring to

11 myself and my son.

12 Q. And when was it then that you first formed the belief that your

13 husband was dead?

14 A. Well, you know what? As I was thinking -- because I knew what

15 his condition was, and we thought that he was living a hard life. And

16 it's not that I saw something specific or heard something specific, no.

17 Q. But at some point you started to believe that your husband was no

18 longer alive. When was that?

19 A. Well, say, 2011.

20 Q. The same year that he was arrested?

21 A. As far as I can remember.

22 Q. So up until --

23 A. Well, maybe not that much. I don't know. Maybe half a year

24 before that. I really cannot remember now.

25 Q. So about half a year before 2011. Until that point in time,

Page 37685

1 Mrs. Mladic, you believed your husband -- you knew your husband to be

2 alive?

3 A. I assumed so. I couldn't be sure. The man had left, many years

4 had passed, a whole decade, and that was the thinking of me and my son.

5 Because a lot of time had gone by, and he wasn't in very good health when

6 he left.

7 Q. Now, in December of 2008 the authorities in Belgrade found

8 weapons in a closet in your home, in your apartment in Belgrade. That's

9 right?

10 A. Yes.

11 Q. You were charged with the illegal possession of weapons?

12 A. Yes.

13 Q. And those charges were eventually withdrawn, weren't they?

14 A. Yes. I won the dispute.

15 Q. Well, Mrs. Mladic, isn't it the case that the charges were

16 withdrawn? There was no verdict at the end of the trial?

17 A. There was no verdict and the court charges were covered by the

18 state. I didn't have to pay for the cost of the case.

19 Q. And when I'm -- you may have misunderstood me. When I say the

20 charges were eventually withdrawn, I mean the -- I'm talking about the

21 allegations that were made against you.

22 A. Perhaps I don't understand the terminology that well.

23 Q. Okay. Let me try and clarify. The criminal allegations that

24 were brought against you for the illegal possession of the arms, those

25 allegations were dropped? The prosecution decided not to pursue that

Page 37686

1 further? Is that right?

2 A. I'm not a lawyer, so that's why I'm saying -- well, all right.

3 You could put it like that.

4 Q. All right. Let's move on now. You told the court in Belgrade

5 that you had no idea what was in that cupboard. You recall that?

6 A. Correct, yes. That's correct.

7 Q. And why was it that you didn't open the cupboard to see what was

8 in there?

9 A. I did open it because I knew that there were things of his in

10 there. He's an officer, and if he tells us not to touch anything in

11 there, that's what we do. We don't touch anything in there.

12 Q. And "he," you're referring to your husband, Mr. Mladic?

13 A. Yes, my husband, General Mladic.

14 Q. And he told you not to touch anything in the cupboard. When did

15 he tell you that?

16 A. Yes. I cannot remember the date, but that was during the period

17 when he was at home, when he would come home from time to time. And for

18 a long time still the state was providing the security.

19 Q. So we're talking about before the last time you saw him in 2001.

20 When you say "it was when he would come from time to time," are you

21 talking about from the wartime or are you talking about after that?

22 A. I'm talking about the time after that.

23 Q. And did he tell you before he left in 2000 -- or six months

24 before -- sorry. In 2001, did he tell you not to touch what was in that

25 cupboard?

Page 37687

1 A. No, not then. He didn't say then. We knew before that time that

2 we weren't supposed to touch it. But he got ready hastily and he left

3 the house, and then after that, he didn't say anything.

4 Q. Up until the apartment was searched in 2008, Mrs. Mladic, you

5 complied with your husband's instructions not to open the cupboard.

6 That's what you claim?

7 A. Yes, yes.

8 Q. So one can say that you are faithful to your husband?

9 A. Look, I have spent my whole life with my husband. Since the time

10 he was a second-lieutenant to a general, as an officer, and even before,

11 he would bring things home. And then if he said, "Please don't touch

12 that," both myself and the children would respect that. We wouldn't

13 touch it if he told us not to.

14 Q. And this despite his absence over many, many years?

15 A. Yes.

16 Q. Now, Mrs. Mladic, did you discuss the substance of your testimony

17 here today with anyone?

18 A. Yes, I spoke with the lawyer. Just the lawyer, not anybody else.

19 Q. And when you mention "the lawyer," you're talking about

20 Mr. Mladic's Defence team? Is that who you're referring to?

21 A. Yes, yes. He just said that he had my statement, he gave it to

22 me, and I have the statement with me now.

23 Q. And who was it that first contacted you regarding the details of

24 your husband's activities between the 14th and the 17th of July, 1995?

25 A. Nobody contacted me. I was summoned sometime in July 2014 to

Page 37688

1 give a statement, so I gave a statement.

2 Q. Now, Mrs. Mladic, do you recall that -- now you're referring here

3 to being summoned in July 2014 to give this statement that we've looked

4 at here today.

5 A. Yes, yes.

6 Q. Now, my question is --

7 A. Yes, that's right.

8 Q. My question was when was it that you first were contacted about

9 the activities - your activities and your husband's activities - between

10 the 14th and 16th of July, 1995? Was that the first time -- that wasn't

11 actually the first time you had been contacted in regards to that, was

12 it?

13 A. That was the first time that I was contacted regarding that, yes.

14 Q. Right. So you don't remember being contacted by the war crimes

15 department in Belgrade in 2012 regarding these dates? You don't remember

16 that?

17 A. Ah, yes. No, no. You have just reminded me that I was called

18 once. I really couldn't remember right away. I'm trying to remember now

19 the -- the date. Yes, you are correct. But I really cannot remember the

20 date.

21 Q. It was a long time ago, so you don't remember; isn't that right,

22 Mrs. Mladic?

23 A. Yes, yes. It was much earlier. I can't remember, but it was

24 before 2014.

25 Q. And, Mrs. Mladic, what is it that you remember -- or what is it

Page 37689

1 that you were told about the significance of these days that you were

2 asked about by the war crimes department and the high court in Belgrade

3 as well as by the Defence of General Mladic?

4 A. They asked me whether he was at home during those days, the 14th,

5 the 15th, and the 16th of July. I think that was the gist of it.

6 Perhaps there was some other questions, but I don't remember.

7 Q. Were you told why they were interested in those dates?

8 A. I don't think so.

9 Q. I take it that means you don't remember?

10 A. No, no. I really cannot remember. I can't say anything that

11 wouldn't be ...

12 Q. Okay. Mrs. Mladic, you certainly were aware that during those

13 dates that you were asked about, that thousands of Bosnian Muslim men and

14 boys were executed after the fall of Srebrenica? You were aware of that,

15 weren't you?

16 A. I heard about some things from the media.

17 Q. When did you first hear about these atrocities?

18 A. Perhaps again 2000-something, when things started happening. I

19 mean, we had some information about the events, when it was happening.

20 There were some things shown on TV. Then later in 2000 -something, there

21 was a propaganda that started that it was just the Serbs who had

22 committed the crime, that it was a major crime. So I think in

23 2000-something this propaganda started appearing. It was in the media,

24 it was in newspapers, on television, and so on.

25 Q. Mrs. Mladic, now, you told us that you knew that your husband had

Page 37690

1 been indicted sometime in either 1996 or 1997, and you didn't at any

2 point ask what those crimes were?

3 A. I did. I did when I started to listen to all of those things

4 which, in my opinion, was propaganda, and we heard some things earlier

5 that were completely different during the war. And at one point I asked

6 him, "Ratko, please tell me the truth. Did you issue any order regarding

7 these crimes that happened in Srebrenica?" And at that point, he got

8 very serious and he looked at me sharply, and he said, "Are you doubting

9 me?"

10 Q. So, in fact, Mrs. Mladic, you did understand at the time you

11 learned about the indictment that there had been serious and grave crimes

12 that had been committed after the fall of Srebrenica?

13 A. Like I said, I was following this in the media. I was reading

14 about it. Some people said it was a very high number; for example,

15 General MacKenzie wrote in the Novosti newspaper that it couldn't be so,

16 it couldn't be that many, if crimes did occur, they were at a much

17 smaller scale, and so on. I knew that some crime was committed. That's

18 why I asked him about it.

19 Q. Now, it has been many years since then. Do you accept that over

20 7.000 Muslim men and boys were massacred?

21 A. No, I don't accept that.

22 JUDGE ORIE: Mr. Lukic.

23 MR. LUKIC: What was the base for this question?

24 JUDGE MOLOTO: It's just a question.

25 JUDGE ORIE: Well, it's -- that's the question. Apparently

Page 37691

1 whether the witness accepts what was alleged to have happened. That's,

2 at least I take it Ms. Hasan, that that's what your question was about.

3 The witness has answered the question.

4 Please proceed.

5 MS. HASAN:

6 Q. Now, how long did it take you, when you were asked about the

7 events between 14 and 17 July, did it take you to remember the details of

8 those dates?

9 A. Well, look: I didn't need a lot of time because that was the

10 first time that he was in Belgrade for three days. Secondly, there was

11 this wedding. In the evening before, he said that there would be this

12 wedding. In the morning, the following day, there was a difficult moment

13 for me. We had also lost our daughter. I was still wearing black in

14 mourning. And then before he went off for a meeting, he told me, "Buy a

15 pretty dress." And this is what I remember.

16 Q. Okay, Mrs. Mladic, now you said you didn't need a lot of time,

17 okay, to remember. So you remember the details --

18 A. Yes, because of those moments.

19 Q. Let me finish. Okay. So when you were asked about this, you

20 immediately remembered the details of what took place on those dates?

21 You didn't --

22 A. What do you mean? Where were things happening? I don't

23 understand the question. What do you mean? You mean the things that

24 happened in Belgrade or the things that were happening in Srebrenica? I

25 don't understand.

Page 37692

1 Q. Let me clarify. When you were asked about what took place

2 between the 14th and the 17th of July, I understood you to be saying that

3 you --

4 A. [Overlapping speakers] ...

5 Q. Just let me finish the question.

6 I understood you to be saying that it didn't take you a lot of

7 time to remember the details of what took place; is that correct? It's a

8 simple question.

9 A. What was happening during these days, you mean; on the 14th,

10 the 15th, and the 16th of July. Is that what you mean?

11 Q. Yes.

12 MR. LUKIC: And it should be -- sorry, sorry. Stop --

13 THE WITNESS: [Interpretation] Yes, yes, I didn't need a lot of

14 time for those days.

15 MR. LUKIC: [Interpretation] Just one moment. Could you please

16 stop for a moment.

17 JUDGE ORIE: Mr. Lukic.

18 MR. LUKIC: The witness asked that question specifies where.

19 That was confusion. Where: Srebrenica or Belgrade?

20 JUDGE ORIE: Yes. When you clarified, Ms. Hasan, I think you are

21 not that clear in clarifying what the witness asked.

22 And I think, Mrs. Mladic -- but please correct me when I'm wrong,

23 Ms. Hasan, that how much time it took to remember what happened in those

24 days, that you are constantly referring to what happened in Belgrade

25 during those days.

Page 37693

1 Is that what you intended to ask the witness?

2 MS. HASAN: Yes.

3 JUDGE ORIE: When you said, Mrs. Mladic, that you didn't need a

4 lot of time for those days, you were referring for that you didn't need a

5 lot of time to remember what happened during those days in Belgrade. Is

6 that how we have to understand your answer?

7 THE WITNESS: [Interpretation] Yes, yes, yes.

8 JUDGE ORIE: Thank you.

9 I think the matter has been clarified. Please proceed.

10 MS. HASAN:

11 Q. So in the process of responding to the questions put to you by

12 the high court in Belgrade, the war crimes department, and by, well,

13 initially by them, you didn't have to consult in advance of that with

14 anybody? You didn't talk to anyone, you didn't talk to --

15 A. No, no, I didn't talk to anyone.

16 Q. Now, you say in your statement that you -- and this is at

17 paragraph 2 of your statement, that you remember -- you say:

18 "I remember my spouse, Ratko Mladic, coming home in the evening

19 hours of 14 July ..."

20 So that's when you recall he arrived from Bosnia; that's right?

21 A. Yes, yes. That he arrived, yes.

22 Q. Do you remember what day of the week the wedding was?

23 A. No. No, I cannot confirm the day. No.

24 Q. Okay. Just so we're all on the same page, whose wedding was it

25 that you attended?

Page 37694

1 A. It was the wedding of Biljana Djurdjevic and Zarko Stojkovic.

2 Q. Right. So going back to the evening of the 14th of July when you

3 say your husband arrived from Bosnia, you say he came in the evening

4 hours. What time did he arrive?

5 A. I cannot remember the time exactly, but he came sometime early in

6 the evening.

7 Q. And early in the evening is approximately what time? Give me an

8 hour.

9 A. Well, let's say that it was about 7.00, 7.00 and a bit.

10 Something like that.

11 Q. Now, Mrs. Mladic, when you gave your -- when you answered a

12 question before the high court in Belgrade in March of 2012, you swore to

13 tell the truth, didn't you?

14 A. Yes.

15 Q. And after answering questions in the courtroom, a statement was

16 compiled, it was read to you, you said you had no objections to it, and

17 you signed it; isn't that right?

18 A. The statement you mean? Yes.

19 Q. Well, let's look at that statement.

20 MS. HASAN: It's 65 ter 32878.

21 Q. This is the record of the witness interview compiled on 19 March

22 2012 before the judge for preliminary proceedings of the high court in

23 Belgrade, war crimes department.

24 JUDGE ORIE: Mrs. Mladic, before the next question will be put to

25 you, apparently you have some paper before you. Could you tell us what

Page 37695

1 papers? Is that your own statement as given to the Defence, or is it

2 anything else?

3 THE WITNESS: [Interpretation] It's the statement that I gave to

4 the Defence.

5 JUDGE ORIE: Thank you.

6 Please proceed.

7 MS. HASAN:

8 Q. So you see here the front page.

9 MS. HASAN: If we can just turn to page 2 in the English and 3 in

10 the B/C/S, please.

11 Q. That's your signature there, Mrs. Mladic, isn't it?

12 A. [No interpretation]

13 Q. Well, I'd like to look at --

14 THE INTERPRETER: The interpreters didn't hear what the witness

15 said.

16 MS. HASAN:

17 Q. Could you repeat your answer to that question, Mrs. Mladic. Is

18 that your signature?

19 A. Yes.

20 MS. HASAN: And if we can go back to page 1 in the English and

21 page 2 in the B/C/S.

22 Q. At the bottom of the page in the English -- I'm not sure that's

23 the -- yeah. That first paragraph there, you state that:

24 "I went with my husband, Ratko Mladic, to the wedding of

25 Biljana Djurdjevic and Zarko Stojkovic in the church in Admirala Geprata

Page 37696

1 Street on 16 July 1995. I remember the exact date because it was four

2 days after Petrovdan day and my husband had arrived in Belgrade two days

3 before."

4 You go on to say:

5 "I remember that he got up early on 14 and 15 July and went to

6 some meetings ..."

7 I'm going to stop there. Now, you say in your statement that you

8 reviewed, you had no objections to, and you signed, that you remember he

9 got up early on the 14th of July. So, according to this statement, your

10 husband was with you on the morning of the 14th July. Presumably

11 you're -- I understand this statement to mean he was there sometime the

12 night of the 13th or early morning hours on the 14th.

13 Today and in your statement that you provided in July 2014, you

14 say that your husband arrived on the evening of 14th of July. So,

15 Mrs. Mladic, which of these two versions would you like us to accept as

16 the truth as you claim it to be?

17 A. He got up in the morning of the 14th and the 15th. He was in the

18 house. So he came in the evening of the 14th and then went to meetings

19 in the morning -- I mean, during the night, late at night he came at

20 home, and we woke up on the morning of the 15th.

21 Q. So --

22 THE INTERPRETER: Interpreter's note: We didn't hear the last

23 sentence.

24 THE WITNESS: [Inaudible]

25 THE INTERPRETER: Interpreter's note: We cannot hear any of

Page 37697

1 this.

2 JUDGE ORIE: Mrs. Mladic, one second, please. Since you are

3 holding your hands before your mouth, the interpreters cannot hear you.

4 Can you please restart your answer. And perhaps Ms. Hasan again puts the

5 question to you so that we have everything in full on the record.

6 Perhaps if you bend over a little bit to the right, that you

7 should take care that the microphone is close enough to ...

8 Ms. Hasan, could you please repeat your question.

9 MS. HASAN:

10 Q. Essentially, Mrs. Mladic, what I want to know is which version of

11 the two statements of your account of what happened on the 14th of July

12 do you want us to accept as the truth: The one which says that he

13 arrived in Belgrade and you remember he got up early on the 14th and 15th

14 of July and went to some meetings; or the version where you say he

15 arrived in the evening hours of 14th July?

16 A. Yes, this statement that I gave in July 2014.

17 Q. So were you not telling the truth when you provided this

18 statement to the high court in Belgrade?

19 A. It's not that I wasn't telling the truth. At that moment I

20 probably couldn't remember.

21 Q. So you were mistaken about that, weren't you?

22 A. Yes, I was mistaken. I was mistaken, yes.

23 Q. Turning to the day of the wedding, do you recall what time you

24 left your house that morning, the morning of the 16th of July?

25 A. We got ready in the morning and -- it wasn't that early. We were

Page 37698

1 there probably around 10.00. Other members of the wedding party had

2 already arrived; that is to say, the bride and bridegroom were there, the

3 bridegroom's parents, then Biljana Djurdjevic's mother, and her people.

4 So we arrived at the end, Ratko and I.

5 Q. Just to follow-up on this answer to your question, the -- you say

6 here that:

7 "We were probably there around 10.00 ..."

8 And I take it that you are referring to arriving at the bride's

9 apartment; is that right?

10 A. Yes, yes. That's the time we arrived at the bride's apartment.

11 Now, whether it was quarter to 10.00 or 10.00, but it was around that

12 time.

13 Q. And as you provide in your statement, you then proceed to go to

14 the ceremony in the church, and you leave thereafter to the restaurant

15 Dva Ribara to return home at about 6.00 p.m. that day.

16 A. Yes, yes. Around that time, yes.

17 Q. Now, how long did the journey take you from the restaurant to

18 your home?

19 A. Well, say, around half an hour.

20 Q. So, according to you, you arrive at your home at about 6.30 p.m.;

21 is that right?

22 A. Yes, roughly. Well, you know what, I mean, I cannot say whether

23 it's ten minutes more or less. But approximately. I mean, really, I

24 wasn't looking at my watch and writing things down.

25 Q. So your husband, he, once you arrive at home, he leaves the

Page 37699

1 vehicle, and, as I understand it, he went to the apartment to change into

2 his uniform; is that right?

3 A. No. We returned together from Biljana Djurdjevic's and Zarko's.

4 We returned home together. But my husband changed. And since I wore

5 that dress, the only one that wasn't completely dark, I wore that dress.

6 Q. Okay. But when you arrived in the vehicle with driver Kenjic and

7 your husband at your home that evening, did you enter the apartment with

8 your husband, or did you stay and wait in the vehicle?

9 A. We are talking about the 16th of July, are we?

10 Q. Yes, after you leave the restaurant, you say that you went home

11 at about 6.30. You claim it took you about a half an hour to get home

12 and that your husband then changed into his uniform. I just want to

13 know, did you enter the apartment with your husband? Did you stay

14 waiting for him in the vehicle?

15 A. No, no. I entered the apartment with my husband.

16 Q. How much time when you say you spent in the apartment before you

17 left to the VMA?

18 A. Well, not a lot of time. Just enough time for him to change.

19 Q. Ten minutes, 15 minutes, an hour?

20 A. Well, say, 15, 20 minutes. Something like that.

21 Q. Was anyone else besides you and your husband in the apartment?

22 A. No, no one. Because at that time my son was on summer vacation

23 with his girlfriend.

24 Q. So then you drive --

25 JUDGE ORIE: Ms. Hasan, are you on -- moving --

Page 37700

1 MS. HASAN: Yes.

2 JUDGE ORIE: -- to another subject?

3 MS. HASAN: I'm not, but we can -- I know that it is the time for

4 the break, and I can just pause there.

5 JUDGE ORIE: Yes.

6 Ms. Mladic, we'll take a break of 20 minutes. We would like to

7 see you back after the break. You may now follow the usher.

8 [The witness stands down]

9 JUDGE ORIE: We will resume at 20 minutes past midday.

10 --- Recess taken at 12.00 p.m.

11 --- On resuming at 12.21 p.m.

12 JUDGE ORIE: While we are waiting for the witness to be brought

13 in, Ms. Hasan, and I'm also looking at you, Mr. Lukic, that statement

14 before the Belgrade court was apparently in a criminal case?

15 MS. HASAN: No, Your Honour. This was pursuant to a request from

16 the OTP to the war crimes department to investigate -- to conduct an

17 investigation into the video that was taken at the VMA on the 16th of

18 July, and this hearing that took place was part and parcel of the

19 investigation they conducted.

20 JUDGE ORIE: That's also why you are recorded, if it's at least

21 you, Mr. Lukic, to be present. Although, maybe someone else. But that

22 you were there as counsel for Mr. --

23 No loud speaking.

24 MR. LUKIC: There is no translation at all in B/C/S.

25 JUDGE ORIE: Oh. If there is no translation, we should seek the

Page 37701

1 assistance of technicians and/or --

2 MR. LUKIC: It's okay now.

3 JUDGE ORIE: It's okay now?

4 MR. LUKIC: Yes.

5 JUDGE ORIE: I see Mr. Mladic is nodding yes.

6 You were present as Defence counsel?

7 MR. LUKIC: As a Defence counsel.

8 JUDGE ORIE: For Mr. Mladic?

9 MR. LUKIC: I was there with Mr. Sajlic who was actually

10 Mrs. Mladic's lawyer. And I was recorded, and I was there, I think, only

11 at the beginning.

12 [The witness takes the stand]

13 MR. LUKIC: That's why I was recorded.

14 JUDGE ORIE: Yes. That means that --

15 MR. LUKIC: -- [Overlapping speakers] ... it was only Mr. Sajlic

16 was present.

17 JUDGE ORIE: That means that counsel are present in a context in

18 which they apparently then represent a witness at the same time being

19 involved in the --

20 MR. LUKIC: My -- my assumption was that Mrs. Mladic was the

21 witness at that moment, not that there was no proceedings against her.

22 JUDGE ORIE: No, I'm not saying that there were. But, of course,

23 I was wondering. I saw that you and Mr. Sajlic were present, at least

24 that's what's recorded. And, of course, I asked myself in what capacity

25 you were there and in what capacity Mr. Sajlic was there. And what

Page 37702

1 may -- well, I'm just seeking at this moment to establish these facts. I

2 leave it to that.

3 Ms. Hasan, you may proceed.

4 MS. HASAN:

5 Q. We left off, Mrs. Mladic, talking about the evening of the 16th

6 of July. And now once Mr. Mladic changed into his uniform, you said you

7 spent, I believe it was given or take, 15 minutes at the apartment and

8 then you proceeded to the VMA; is that right?

9 A. Yes.

10 Q. Our investigation has revealed that it takes about -- it's about

11 13 kilometres to the VMA from your apartment, so it would take

12 approximately 13 or so minutes to get there. Is that about right, as far

13 as you can recall?

14 A. Well, I cannot remember how much time it took us to get there.

15 It depends on the traffic, too. Sometimes it's a bit longer. And then

16 if there is no traffic, it's quicker.

17 Q. Well, Mrs. Mladic, you do recall arriving at the VMA in the

18 evening; is that right?

19 A. Yes, yes.

20 Q. It was still light outside?

21 A. Yes, light.

22 Q. Now, are you familiar with Ned Krajisnik?

23 A. I did not understand.

24 Q. Do you know who Ned Krajisnik is? He was present at the VMA at

25 this meeting that you attended?

Page 37703

1 A. No, I cannot remember him. No.

2 Q. Are you familiar with Milan Lesic?

3 A. Yes, yes.

4 Q. And he too was also present at this meeting at the VMA that you

5 attended?

6 A. Yes, yes. I remember that, yes.

7 Q. Well, Mrs. Mladic, both Ned Krajisnik and Milan Lesic who

8 attended this meeting with you have testified before this Tribunal, and

9 I'm just going to read you very short portions from their testimony.

10 MS. HASAN: Could we take a look at 32880. That's 65 ter. And

11 this is the testimony of Ned Krajisnik. It's in the Perisic case on the

12 2nd of November, 2009.

13 And if we turn to page 2, please.

14 Q. Line 22, he was asked:

15 "Do you recall approximately what time of day this meeting in the

16 VMA board room was taking place?"

17 Answer --

18 A. Sorry, this is in English and I don't understand English.

19 Q. Mrs. Mladic, I should have explained this to you before I

20 started. But I will read it out to you so you can hear it in a language

21 you understand. So --

22 A. All right.

23 Q. -- let me start again.

24 "Q. Do you recall approximately what time of day this

25 meeting in the VMA boardroom was taking place?

Page 37704

1 "A. I believe it was late afternoon."

2 Okay? Now let's look at what Milan Lesic said.

3 MS. HASAN: If we can turn to 65 ter 32884.

4 Q. And beginning at line 23. And again, Mrs. Mladic, I will read

5 this out so that you can hear it in your language.

6 "Q. Today we had a look at a video excerpt. The date was

7 the 16th, and it was at the VMA in Belgrade. Do you remember what time

8 it was when you went to visit Mladic on that occasion?"

9 And Milan Lesic responds:

10 "The time, sir, I'm not aware of the time. I remember that we

11 came from Sofia first day in VMA, and I don't recall the time unless

12 video or picture shows otherwise, and from the Belgrade when we -- the

13 scanner arrived, scanner too, following morning we went to Pale. As

14 well, I don't remember exact time. Was in the afternoon, as I believe,

15 that we were there."

16 So, Mrs. Mladic, both Milan Lesic and Ned Krajisnik --

17 A. Yes, all right.

18 Q. -- believe that this meeting at the VMA where you were present

19 took place in the afternoon of the 16th of July and not as you provide

20 now, which is late -- sorry, which is in the evening.

21 So my question to you, Ms. Mladic, is this was a long time ago.

22 This happened some 20 years ago. And it's really not surprising that you

23 don't remember some details, but isn't it the case that you're also

24 mistaken about when this meeting took place at the VMA?

25 A. No, I'm not mistaken. I know when we returned from the wedding.

Page 37705

1 And maybe they thought it was in the afternoon because it's summer time.

2 The days are long. So they could not recall.

3 JUDGE ORIE: Ms. Mladic.

4 THE WITNESS: [Interpretation] Because I know --

5 JUDGE ORIE: Ms. Mladic --

6 THE WITNESS: [Interpretation] Yes?

7 JUDGE ORIE: If I intervene, as I did a second ago, it was in

8 order to give Mr. Lukic an opportunity to object to the question.

9 Mr. Lukic, do you still want to object or, the answer being

10 given, can we proceed?

11 MR. LUKIC: It was suggested that it's not surprising that

12 Ms. Mladic does not remember, and I don't find it anywhere that she does

13 not remember. And she just explained that she does remember.

14 JUDGE ORIE: Yes. Now you -- of course, you can suggest in a

15 question something that is not in evidence yet, or even an alternative

16 scenario.

17 However, Ms. Hasan, this was 80 per cent of the question,

18 rather -- and then only 20 per cent remained on the subject matter

19 itself. That's not the balance we would appreciate most. You explained

20 three, four, five times why Mrs. Mladic could have a different -- may

21 have had a different recollection, and if you suggest that, no problem,

22 but not three, four times and then ask the question.

23 Please proceed.

24 MS. HASAN:

25 Q. So you're claiming, Mrs. Mladic, that Milan Lesic and

Page 37706

1 Ned Krajisnik are wrong?

2 A. Yes, it's not possible that it was in the early afternoon hours.

3 So if they think that after 6.00 is still the afternoon, because it's

4 day-time, then that's it. But certainly ...

5 Q. And, Mrs. Mladic, I'd like to just -- I'd just like to

6 understand. Now, when I asked you about the 14th of July about when your

7 husband arrived, now what was it, in fact, that made you remember that he

8 arrived to your home the evening of the 14th July and correct the earlier

9 statement you had given to the Belgrade high court?

10 A. I thought about it a bit more. They called me in then. Perhaps

11 it was a bit quick and maybe I couldn't really find my way. But when I

12 gave this some thought, I came to that conclusion. I know that he left

13 soon after that. He said, "I'm going to meetings," and it was still

14 day-time for a long time after he left the house.

15 Q. Now, in that answer you said:

16 "I thought about it a bit more. They called me in then."

17 Who are you referring to when you say "they"?

18 A. I mean when they called me in to -- I mean, Milenko Dundjar to

19 give this statement. In July 2014.

20 Q. So in July 2014 when you meet with Milenko Dundjar, it's at that

21 point that you changed your mind about when it was that General Mladic

22 arrived on the 14th?

23 A. Yes, yes. He questioned me for quite a while, so ...

24 Q. So, in fact, it was during the process of questioning by

25 Mr. Dundjar that it was suggested to you that, in fact, General Mladic

Page 37707

1 hadn't arrived in Belgrade on the morning but rather on the evening of

2 the 14th?

3 A. Nothing was suggested to me. I came to that conclusion and

4 that's the statement I made.

5 Q. Now were you aware, Mrs. Mladic, that it is the Defence's

6 position in this case that General Mladic arrived on the evening of

7 the 14th?

8 A. Yes. He came in the evening of the 14th.

9 Q. Let's move on, Mrs. Mladic.

10 JUDGE ORIE: Well, the answer is not without ambiguity.

11 The question was not whether he arrived on the 14th but whether

12 you were aware that it -- that position that is taken by the Defence --

13 MR. LUKIC: If I may, Your Honour?

14 JUDGE ORIE: Yes.

15 MR. LUKIC: Maybe Mrs. Mladic should remove her headphones.

16 JUDGE ORIE: Yes.

17 Do you understand the English language, Mrs. Mladic?

18 THE WITNESS: [Interpretation] No, I don't. I don't.

19 JUDGE ORIE: Could you take off your earphones for a second.

20 MR. LUKIC: And it's not the position of the Defence --

21 JUDGE ORIE: Okay.

22 MR. LUKIC: -- that Mr. Mladic arrived in the evening.

23 JUDGE ORIE: You could have objected to the question --

24 MR. LUKIC: We do object.

25 JUDGE ORIE: -- as phrased as such.

Page 37708

1 Ms. Hasan, there is an objection against you putting to the

2 witness what the Defence's position is, where this is now contradicted by

3 Mr. Lukic.

4 MR. LUKIC: That he arrived to Belgrade, not to their home, and I

5 will try to clarify it with Mrs. Mladic.

6 JUDGE ORIE: Okay. Let's ...

7 Ms. Hasan, apparently the -- no, one second.

8 Mrs. Mladic.

9 Apparently the issue is arrival in Belgrade and arrival at home

10 on the 14th. That seems to be the -- what keeps the parties apart in

11 view of what the Defence's position is.

12 The witness has not answered the last question anyhow. If you

13 would say, well, let's move on, as you suggested, but then it may be

14 clear that your question has not been answered. At least --

15 MS. HASAN: Okay.

16 JUDGE ORIE: -- not in an unambiguous way.

17 MS. HASAN: Okay, then I can --

18 Q. Mrs. Mladic, if you could answer --

19 JUDGE ORIE: Now we have to ask Mrs. Mladic to put on the

20 earphones again.

21 Yes.

22 You rephrase the question, Ms. Hasan.

23 MS. HASAN:

24 Q. Mrs. Mladic, you were aware, then, that it is the Defence's

25 position that General Mladic was in Belgrade on the 14th of July in the

Page 37709

1 evening?

2 MR. LUKIC: Objection.

3 JUDGE ORIE: Was he not in Belgrade? Is that your position,

4 Mr. Lukic? That's --

5 MR. LUKIC: Not only in the evening.

6 JUDGE ORIE: That's not part of the question.

7 MR. LUKIC: But he said --

8 JUDGE ORIE: Is it the Defence's position that he was there in

9 the evening, notwithstanding that he may have been there earlier during

10 that day?

11 MR. LUKIC: Then it's true.

12 JUDGE ORIE: Yes. And then the objection was not justified, I

13 would say.

14 Please proceed, Ms. Hasan. Perhaps you repeat the question again

15 and that you seek an answer. I'm now not inviting you to rephrase the

16 question but to repeat the question.

17 MS. HASAN:

18 Q. Mrs. Mladic, you were aware then that it is the Defence's

19 position that General Mladic was in Belgrade on the 14th of July in the

20 evening?

21 A. Well, regardless of that, now I am sure that he was in Belgrade

22 on the 14th.

23 JUDGE ORIE: You say "regardless of that," but the question is

24 about that. Were you aware that the Defence, and apparently you agree

25 with what may have been the Defence position then, that Mr. Mladic was in

Page 37710

1 Belgrade on the evening of the 14th? Did you know that that was the

2 position taken by the Defence?

3 THE WITNESS: [Interpretation] I don't know. It probably is.

4 Yes, yes.

5 JUDGE ORIE: Ms. Hasan, please proceed.

6 [Prosecution Counsel Confer]

7 MS. HASAN:

8 Q. And at what point did you understand that it was probably the

9 Defence's position?

10 MR. LUKIC: I'm --

11 JUDGE ORIE: One second.

12 THE WITNESS: [Interpretation] I wasn't thinking about that.

13 MR. LUKIC: I was --

14 JUDGE ORIE: Yes.

15 MR. LUKIC: -- "I don't know," "it probably is," so asking now

16 when this witness was aware that it probably is, it cannot be connected

17 in that way.

18 JUDGE ORIE: Ms. Hasan, you should have laid a foundation for

19 that question which is not there at this point in time, because the

20 answer of the witness could well be understood that she now, here,

21 considers it a probability that it's the Defence's position. And then to

22 say when, that, of course, we could have -- you could have expected the

23 witness to say, well, just now. But I think she has answered the

24 question. She didn't think about it any earlier, which I think everyone

25 would agree hints at considering it a probability at this very moment.

Page 37711

1 Please proceed.

2 MS. HASAN:

3 Q. And, Mrs. Mladic, were you aware that it is the Defence's

4 position -- were you aware at any point that it was the Defence's

5 position that General Mladic was not in Belgrade on the morning of the

6 14th as you had told the high court in Belgrade?

7 JUDGE ORIE: Before you answer that question.

8 Mr. Lukic, it reflects the position of the Defence? The first

9 part.

10 MR. LUKIC: Yes, it does.

11 JUDGE ORIE: Yes.

12 Could you then answer the question, Witness, whether you were

13 aware at any point in time that it was -- it's the Defence's position

14 that General Mladic was not in Belgrade on the morning of the 14th as you

15 had told the high court in Belgrade?

16 THE WITNESS: [Interpretation] We didn't talk about it.

17 JUDGE ORIE: Were you aware of --

18 THE WITNESS: [Interpretation] No.

19 JUDGE ORIE: One second, please.

20 [Trial Chamber confers]

21 JUDGE ORIE: Please move on, Ms. Hasan.

22 MS. HASAN:

23 Q. During the meeting at the VMA, you recall, as you say in your

24 statement, that Mr. Mladic was on the phone with someone. Do you recall

25 who that was?

Page 37712

1 A. No, I don't.

2 Q. You provide, and this is at paragraph 7 of your statement, D1185,

3 you say that:

4 "I remember that while we were in the meeting at the VMA Ratko

5 had a telephone conversation with someone. I recall that he did not

6 order anything to anyone during the talks, nor did he use such a tone

7 while he was talking on the phone."

8 Now, you've seen the video that was taken during this meeting,

9 which includes this telephone call; right?

10 A. Are you going to show the video?

11 Q. No, I'm asking you whether you have seen that video.

12 A. I have seen it, yes.

13 Q. And did you see it recently? Did the Defence show it to you?

14 A. They showed it to me when I was providing my statement in July

15 2014.

16 Q. And you recall that that video showed General Mladic on the

17 phone; right?

18 A. Yes. Yes, yes. And I remember that he got up in that room where

19 we were and he was using just a regular phone during the conversation.

20 Q. Did that video that you watched accurately reflect what

21 General Mladic said?

22 A. I think so, yes.

23 Q. Well, I'm going to read you from the transcript of that video.

24 MS. HASAN: This is P01147. It's B/C/S page 90.

25 Q. So that you can follow what I'm reading. Now, he gets on the

Page 37713

1 phone and he says --

2 JUDGE MOLOTO: Shouldn't we also have the English on the screen?

3 MS. HASAN: Yes.

4 JUDGE MOLOTO: I know you're going to read it, but ...

5 MS. HASAN: Oh, yes, it's page 94 in the English.

6 JUDGE MOLOTO: Thank you.

7 MS. HASAN:

8 Q. So he gets on the phone and he says:

9 "Well, then, you should send Gojko. Have him come over tonight

10 and send two more cars, two more cars and have them report here tonight.

11 I'm not going while they're in the air.

12 "Yes.

13 "No, no, no, I know.

14 "Okay, here's what we'll do. How about the stadium at Legenda's

15 place?

16 "Great, you don't have to send a car for me, I'll get there.

17 Here: You send two cars, have them report tomorrow. They should leave

18 in the morning, not tonight; two cars should leave at 8.00 and report to

19 the VMA, to the Doctor Pero Janjic, Lieutenant Colonel; Milan Lesic and

20 six others are to come there, yes."

21 Now, I'll skip a bit.

22 And he then asks:

23 "Alright. How are the things up there, at Vinko's?"

24 Now, Mrs. Mladic, that's Vinko Pandurevic he's talking about;

25 right?

Page 37714

1 A. I cannot confirm that. Probably, but I cannot confirm it.

2 Q. But you know who that is? You know who Vinko Pandurevic is?

3 A. I don't know him personally, but I have heard of him. Yes, I

4 have heard of him. He was an officer of the army of Republika Srpska.

5 Q. So then your husband goes on and he says:

6 "Very well," I've skipped a line, "Very well, full steam ahead;

7 maximum security and don't wait up for the orders; as soon as they show

8 up in the air, shoot them down."

9 And if we turn a page in the English, starting at line 1, he

10 says:

11 "Whatever, shoot them down at high altitude."

12 Now, Mrs. Mladic, when General Mladic is on the phone and he is

13 telling the person he's talking to "as soon as they show up in the air,

14 shoot them down," that's an order, isn't it?

15 A. I cannot say. I'm not versed in that, whether it's an order or

16 not. Orders are usually issued on a secure line, and this is just a

17 regular telephone. I think that he was talking, but he was probably

18 talking about NATO planes that were in the air. And it wasn't safe. It

19 wasn't safe for him to go now. I don't know.

20 Q. So the bottom is -- line is, Mrs. Mladic, that you really don't

21 know whether what -- what qualifies as an order and what doesn't; right?

22 A. Yes. I don't know what qualifies as an order, no.

23 Q. You go on in your statement and you say that you left the VMA,

24 and this is at paragraph 6, but I'll read it to you:

25 "We stayed in the meeting for more than an hour and a half. I

Page 37715

1 remember that Ratko spoke with all the individuals at the meeting, which

2 is why I believe that the meeting lasted longer than an hour and a half.

3 We came home after the meeting and went to bed."

4 Now, Mrs. Mladic, were you with your husband the entire time at

5 the VMA?

6 A. Yes, yes. I was with him the entire time.

7 Q. And you left together?

8 A. Yes, and we returned home together.

9 Q. You say, in your statement -- oh, sorry. Do you remember who

10 drove you home?

11 A. Mladjo Kenjic.

12 Q. And you remember that night, you said, very well; right?

13 A. I remember that meeting, that there were about ten people there.

14 I knew two of them: Milan Lesic and Dr. Pero Janjic. I knew the two of

15 them personally. I didn't know the others. So I remembered meeting the

16 two of them.

17 Q. But you remember going home with your husband that night?

18 A. Yes, yes. And we were brought home by Mladjo Kenjic.

19 Q. Now, were you with your husband the entire night?

20 A. Yes, we were together the entire night. We went to sleep

21 together and then we woke up together in the morning.

22 Q. What time was it that you came home, that you arrived at your

23 apartment after the VMA?

24 A. I cannot say exactly, but it was approximately -- it was

25 definitely after 9.00 or 9.30. It was after 9.00 in the evening,

Page 37716

1 approximately. I cannot give you an exact time.

2 Q. What time did you go to bed?

3 A. Soon after. We were tired. It was a long day. We were on our

4 feet the whole day, from morning till night.

5 Q. So you didn't do anything between your arrival at your apartment

6 and going to bed? You just got ready for bed?

7 A. No, nothing special. We maybe had some refreshments, we got

8 ready for bed. Nothing else.

9 Q. You said that it was approximately -- it was after 9.00 or 9.30

10 in the evening that you arrived at your apartment.

11 Now, you say that you did nothing special. You got some

12 refreshments and you got ready for bed. Did your husband engage in any

13 other business that night?

14 A. No, not that evening. He didn't do any work. Mostly when he

15 comes to Belgrade, he comes to attend meetings and then he spends time at

16 home. He would be just coming for a short while, then he would go

17 quickly for meetings, and coming back.

18 Q. So when you were -- when you say he didn't do any work that

19 evening, Mrs. Mladic, did your husband, I take it then, didn't take any

20 calls that night in your apartment?

21 A. No, no, he didn't take any calls. Definitely.

22 Q. And did your husband make any calls that evening in your

23 apartment?

24 A. No, no, he didn't call anyone from the apartment.

25 [Prosecution Counsel Confer]

Page 37717

1 MS. HASAN:

2 Q. Now, Mrs. Mladic, when you were at the VMA you said you were with

3 your husband the entire time. Once the meeting was completed, okay, in

4 the boardroom that you were in, what did you do after that?

5 A. Nothing. We took the lift down and we went to the car and then

6 we went home. We didn't do anything special.

7 Q. Do you recall having visited the wounded in the hospital either

8 before or after that meeting?

9 A. I cannot remember, really. I can't remember.

10 Q. So after your -- you finish with the boardroom meeting, you take

11 the lift, you go down, and you were with General Mladic the entire time.

12 Did he make any other calls in your presence besides the call that he

13 made from the VMA that we just discussed?

14 A. No, there were no other calls.

15 Q. Mrs. Mladic, I have one document more to show you and then we'll

16 be done.

17 MS. HASAN: 65 ter 32576.

18 Q. Mrs. Mladic, you're aware that there are the Banjica barracks

19 near to the VMA?

20 A. I'm sorry, I didn't hear you. There are what?

21 Q. Military barracks near the VMA, the Banjica. Banjica.

22 A. Uh-huh, Banjica. Yes, yes.

23 Q. And you are aware that there is a landing place for helicopters

24 just near the VMA?

25 A. I -- I didn't know that, no.

Page 37718

1 Q. But you were aware that your husband, in travelling to Belgrade

2 at times arrived by helicopter; isn't that right?

3 A. I don't know how he got there. When he arrived, he just entered

4 the house. He rang the doorbell and he went in. I didn't see how he got

5 there.

6 Q. So you have no knowledge of whether or not he ever took the

7 helicopter to Belgrade or from Belgrade back to the RS?

8 A. I have no knowledge, no, about that. I would see him off at the

9 door, he would leave, I don't know who would drive him away or bring him

10 home.

11 MS. HASAN: I have nothing further, Your Honours.

12 JUDGE ORIE: Thank you, Ms. Hasan.

13 JUDGE FLUEGGE: Are you tendering the last document?

14 MS. HASAN: I don't think she was able to comment on it, so I

15 think we can save it for another witness.

16 JUDGE ORIE: Yes.

17 MS. HASAN: Your Honours, if I may just make one correction,

18 which is the RFA that the OTP had sent for the war crimes department to

19 conduct an investigation was to look into the filming and photography of

20 the wedding ceremony and the reception, not, as I stated, the video of

21 the VMA. We just checked that in the RFA.

22 JUDGE ORIE: Yes, that's hereby corrected.

23 Mr. Lukic, any further questions for the witness?

24 MR. LUKIC: I do, Your Honour. Not too many.

25 JUDGE ORIE: Please proceed.

Page 37725

1 member of the Defence team of Mr. Mladic.

2 Please proceed, Mr. Ivetic.

3 MR. IVETIC: Thank you, Your Honours.

4 Examination by Mr. Ivetic:

5 Q. Good day, sir.

6 A. Good day, Mr. Ivetic.

7 Q. Could I ask you to first please state your full name, first and

8 last, for purposes of the record.

9 A. My name is Mile Dosenovic.

10 Q. I would next like to look at 65 ter number 1D5848 with you.

11 While we wait for it, it should be a copy of your CV.

12 A. Yes.

13 Q. Sir, have you had occasion to review the document that is now on

14 the screen in front of you?

15 A. Yes, this is the information I provided.

16 Q. And do you believe everything to be correct and up to date in

17 terms of this information?

18 A. Yes.

19 Q. If I can ask just a few questions about your education, first.

20 It's listed here that you attended the communications school for junior

21 officers in Ljubljana. What kind of communications were the subject of

22 your studies at this school?

23 A. Your Honours, I completed the communications school for

24 non-commissioned officers in Sentvid in Ljubljana. It was a school for

25 NCOs, communications NCOs in the JNA. We would have two or three

Page 37726

1 specialties, radio telegraphy, telephones, and sometimes radio relay. We

2 get this basic knowledge concerning communications. And from there,

3 people became squad leaders in the JNA in communications units.

4 Q. And if we look at the entry for the military academy of ground

5 forces communications department in Belgrade, it is listed that you spent

6 four years there. How many of those four years were devoted to

7 communications?

8 A. I spent four years at the military academy of ground forces, and

9 the curriculum is the same for the first three years. And then

10 communications were studied within that framework, but that would be for

11 all services. And then it was only during the fourth year that one

12 specialised, depending on the service involved, and I attended training

13 for communications officers for one year in Belgrade. And that is where

14 we were trained for the overall system of communications. So there was

15 no sub-specialisation, as it was, in the school for NCOs.

16 JUDGE ORIE: Witness, could I ask you to focus your answers very

17 much on the question, because the simple answer to the last question

18 would have been one year out of the four. The question was how many

19 years were devoted to communications.

20 THE WITNESS: [Interpretation] Your Honour, four years of

21 schooling at the military academy; three years of general training, all

22 the same for all the services. General military training.

23 JUDGE ORIE: Witness, I'm not asking you to further elaborate on

24 your answer. I'm trying to keep you focused on what is asked, that was

25 just how many years were dedicated to communications. And you went far

Page 37727

1 beyond that.

2 Please proceed, Mr. Ivetic.

3 MR. IVETIC: If we can go to the next page in English, and it

4 starts at the bottom of this page in B/C/S and goes to the next page in

5 B/C/S.

6 Q. I see here you were a teacher of tactics at the Communications

7 School Centre in Belgrade. First of all, under what organ did that

8 school fall under?

9 A. The School Centre for Communications was within the JNA for

10 training personnel for the communications service. I assumed my duty as

11 teacher of tactics within the tactics department at that school centre.

12 Within that department, there were several different streams; teachers

13 for high schools, teachers for higher schools, and teachers for

14 post-secondary schools. I was in the group of teachers for

15 post-secondary schools. And if necessary, I also taught down there for

16 secondary military schools and higher military schools because I was

17 qualified to teach at all levels.

18 Q. And in terms of the tactics, what kind of tactics are we talking

19 about here that you taught?

20 A. Tactics in communications means training personnel how to use

21 personnel and equipment from a tactical point of view. That is the very

22 basis of this training, how equipment should be used and how personnel

23 should be used in certain situations.

24 Q. Now, if you could just clarify for us. You said that you were in

25 the group of teachers for post-secondary schools. Who most often were

Page 37728

1 your pupils? At what level were they?

2 A. Post-secondary schools? Well, most reserve officers of the JNA.

3 That's that, this post-secondary education. Sometimes there would be

4 groups for courses, different courses. And then sometimes there was

5 NCOs, lower-ranking officers, and then I would teach that subject too.

6 Q. If we could turn to the second page in the Serbian. And the next

7 entry that we see is at the same school as officer in charge of studies

8 and improvement of curricula. What duties in relation to communications

9 did that position entail?

10 A. I was assigned from the tactics department to the teaching and

11 scientific development, and I was supposed to be in charge of studies and

12 improvement of curricula. The basic aim was to develop curricula, then

13 to see how the subject matter was being dealt with, acquired, also if it

14 is necessary to make certain improvements. And also the library falls

15 under this department for scientific development. And I would always be

16 the first to look at the literature that came in, and I was trying to

17 find the best ways and means of improving the teaching there. This was

18 basically my duty.

19 Q. And I see also that at some point in time for part of 1992 and

20 1993 you were a teacher of tactics at the Yugoslav Army School Centre.

21 What subjects did you teach at that institution at that time?

22 A. I went to the so-called hot beds of crisis in 1991 for Slovenia,

23 then Kupres, within a unit, that was called the 11th Operations Group.

24 And then from there, in 1993 -- no, 1992, went to Drvar. However,

25 because of certain family problems, I had to go back to Belgrade for a

Page 37729

1 while. Again, I worked at the tactics department until I returned yet

2 again to the 2nd Krajina Corps. I taught at the department as I've

3 already explained -- as I already explained the first time, that is.

4 Q. Now, at the time-period that you were chief of communications of

5 the 2nd Krajina Corps, what was your rank?

6 A. I became chief of communications of the 2nd Krajina Corps in

7 October 1993, as lieutenant-colonel. In June 1994, I got the rank of

8 colonel and I remained with that rank and in that position until the end.

9 MR. IVETIC: Your Honours, we would tender 1D5848 as the next

10 Defence exhibit at this time.

11 JUDGE ORIE: Madam Registrar.

12 THE REGISTRAR: Document 1D5848 receives number D1186, Your

13 Honours.

14 JUDGE ORIE: D1186 is admitted.

15 MR. IVETIC: Thank you.

16 Q. Now, sir, I want to ask you: Were you tasked with drafting an

17 expert report for purposes of the Mladic case?

18 A. I was given a task at the request of the Defence of

19 General Mladic to write this paper that you have now.

20 MR. IVETIC: If we can call up in e-court 1D05787. And I do have

21 another copy in hard copy for the witness, if he needs it. I'm told, I

22 think, that the witness already has his copy in court.

23 Q. Sir, is that accurate? Do you have your copy in court?

24 A. I have it in front of me.

25 Q. Then now we also have it on the --

Page 37730

1 JUDGE ORIE: Is that a clean copy, Witness, or is there anything

2 written on it by yourself?

3 THE WITNESS: [Interpretation] There are notes that I wrote

4 myself.

5 JUDGE ORIE: Then would you please put them away, and you will

6 receive a clean copy which you may consult if you need. Because the

7 parties and the Chamber should be aware of what is in front of you when

8 you answer the questions.

9 MS. HASAN: Your Honours, there is a few more, just, documents,

10 and --

11 JUDGE ORIE: Yes. Could you put away all other documents and

12 just ...

13 If you want to consult any of the other documents, you should

14 address the Chamber and ask for permission to do so and explain why you

15 need to do it. Not to say that you're not allowed to do it, but we would

16 like to know what you're reading before you answer questions.

17 Please proceed.

18 MR. IVETIC:

19 Q. Sir, are you familiar with the document that we now have in front

20 of us and of which you've been given a clean hard copy?

21 A. Yes, I'm familiar with the document. I drafted it.

22 Q. Now, during proofing in preparation for today, did you have

23 occasion to review the report with me to check for any corrections that

24 were needed to the same?

25 A. I did look over it. There are some corrections that need to be

Page 37731

1 made.

2 Q. If we can first turn to page 32 in the English, page 47 in the

3 Serbian, and focus our attention, once we get there, on

4 paragraph 10.16.5.

5 And, sir, focusing your attention to the last full sentence in

6 this paragraph --

7 MR. IVETIC: And if we could not broadcast the same, actually.

8 Q. Could you tell us what correction you had to this section.

9 A. The sentence should read:

10 "When the strength of the VHF radio wave weakens, such a wave

11 does not shift to a lower frequency and such radio waves cannot fully

12 bend to follow the surface of the earth."

13 JUDGE FLUEGGE: Could we have the document on the screen without

14 broadcasting it? Thank you.

15 MR. IVETIC:

16 Q. And --

17 JUDGE ORIE: Is it right that we are moving from page 32 to 33

18 for the relevant portion?

19 MR. IVETIC: Yes, I apologise. It starts on page 32 and then

20 goes to 33. I was looking at the --

21 JUDGE ORIE: Yes.

22 MR. IVETIC: -- B/C/S.

23 JUDGE ORIE: We start at the very last line.

24 MR. IVETIC:

25 Q. And, sir, in relation to this paragraph, staying with this

Page 37732

1 paragraph, are there any other corrections that you wish to make us aware

2 of?

3 A. Yes. Footnote 41 on this same page. The number of the document

4 has been mixed up. 47. I need to see which page that is. Page 53 in my

5 version. Those two documents were switched and that's evident from the

6 actual text.

7 Q. And going back to --

8 JUDGE MOLOTO: Is that footnote 41 still?

9 MR. IVETIC: Footnote 41 and footnote 47 I'm --

10 JUDGE MOLOTO: What has been switched?

11 MR. IVETIC: The contents of the footnote, Your Honours.

12 JUDGE ORIE: So we should read the content of footnote 41 as it

13 appears in footnote 47 and the other way around?

14 MR. IVETIC:

15 Q. Sir, is that accurate?

16 A. Yes, it is.

17 JUDGE ORIE: Thank you.

18 Please proceed.

19 MR. IVETIC:

20 Q. And in relation to paragraph 10.16.5, are there any other

21 clarifications or corrections in relation to the same? And that's back

22 on page 47 of the Serbian original.

23 A. Could you please repeat?

24 Q. In relation to paragraph 10.16.5, is there any other

25 clarification or correction that you want to advise us of as to that

Page 37733

1 paragraph?

2 A. No. As far as the paragraphs are concerned, I don't have any

3 more changes that I would like to make or corrections.

4 Q. What about as to the placement of this paragraph, 10.16.5?

5 A. I had that in my own document. This whole paragraph, when the

6 work was being done, has been transferred to chapter 11. So I would like

7 to place this paragraph as the first one in paragraph 11 and to be

8 deleted from this section that is marked with paragraphs 10.

9 Q. And if we could turn to page 56 in the Serbian and page 37 in the

10 English, and focus on footnote number 48, I would ask you what

11 corrections you have as to that particular footnote; footnote 48 of your

12 report?

13 A. When the work was being done on the study, something has been

14 dropped out, and these are the radio relay directions of the Drina Corps.

15 I mentioned all of them and said how many channels they had, but I think

16 page 2 there has been omitted. So what I would like is to have that page

17 put back.

18 Q. Let me see if I can clarify with you. Are you referring to the

19 recitation of channels that appears in paragraph 11.12.1 of your report?

20 That is in the B/C/S at the middle of the page.

21 A. Yes. If the document were to be shown, you would see that that

22 is the second page of that document.

23 Q. Okay. And now looking at the actual footnote itself, there are

24 three documents or ERN numbers that are given as the source for the

25 information in this paragraph. Do you have a correction as to the

Page 37734

1 documents that are listed, these three documents in footnote 48 of your

2 report?

3 A. I just need an addition, actually. No changes. These are

4 documents that the last digits are 91 and 92. This second page has been

5 omitted.

6 THE INTERPRETER: Could the witness please be asked to repeat the

7 number.

8 THE WITNESS: [Interpretation] There is another correction. This

9 third document referred to in this footnote, there has been a permutation

10 of the numbers in the last one, 0426 and 0734, but it should read 07 --

11 7034.

12 MR. IVETIC: If I --

13 JUDGE ORIE: Yes.

14 MR. IVETIC: Go ahead.

15 JUDGE ORIE: If you could try to resolve the matter where the

16 interpreter said the witness be asked to repeat.

17 MR. IVETIC:

18 Q. Sir, in relation to the two pages where you said the second page

19 had not been recited in your report, the interpreters asked you to repeat

20 the numbers. Could you please do so to allow the interpreters to get the

21 accurate information.

22 A. It's document number 0431-4791. And the second page of that

23 document, 0431-4792. That page has been omitted. So I'm just asking

24 that to be added to this paragraph 11.12.1.

25 MR. IVETIC: To assist those of us using the numbers from this

Page 37735

1 case, that document at issue that is being discussed is D00879 in these

2 proceedings.

3 JUDGE ORIE: Yes, I'm a bit puzzled by where the witness says

4 that that page has been omitted, whereas in the footnote I find a clear

5 reference to that page.

6 MR. IVETIC: Let me ask --

7 JUDGE ORIE: Yes, you may have a clue to what --

8 MR. IVETIC: I do, I do.

9 JUDGE ORIE: -- how to resolve it.

10 MR. IVETIC: I'm trying to see that --

11 JUDGE ORIE: If you do that, then that would be your last job for

12 today, at least in this courtroom, Mr. Ivetic.

13 MR. IVETIC:

14 Q. Sir, when you say that the second page has been omitted, are you

15 talking about in the footnote or somewhere else in your report?

16 A. I have that document in front of me, number -- this first number.

17 That's the first page. Page 2 is under a different number. It's been

18 cited but it hasn't been put into this paragraph 11.12.1.

19 Q. So when you say that the -- a document has not been put into the

20 paragraph, are you commenting upon the listing of radio relay routes and

21 channels that is in paragraph 11.12.1 which cites to footnote 48?

22 A. Yes, that's right.

23 JUDGE ORIE: Mr. Ivetic, that's still pretty unclear to us,

24 because what we see is a six-line description of radio relay routes and

25 then a footnote with three sources. That's footnote 48, which is

Page 37736

1 attached to the last one. But where then that document that -- that page

2 which appears in the footnote, how is that to be linked to what part of

3 this listing is entirely unclear.

4 Perhaps -- I saw that there was a kind of a proofing note matter.

5 We'll check whether it becomes clear from now. If not, then you should

6 try to assist us in a better way tomorrow morning.

7 MR. IVETIC: I will, Your Honours.

8 JUDGE ORIE: Because we'll adjourn for the day.

9 MR. IVETIC: Thank you.

10 JUDGE ORIE: Witness, we'll adjourn for the day and we'll

11 continue tomorrow morning at 9.30 in the morning. I'd like to instruct

12 you that you should not speak or communicate in whatever way with

13 whomever it may be about your testimony. You should not speak or

14 communicate, whether that's testimony you've given today - very limited -

15 or that's testimony still to be given tomorrow.

16 If that is clear to you, you're invited to -- if that's clear to

17 you, you may follow the usher. And if you want to take any of your

18 papers that were -- more or less you were deprived of by the usher, then,

19 of course, you are free to take them with you.

20 See you tomorrow morning, 9.30.

21 THE WITNESS: [Interpretation] Thank you, Your Honour.

22 [The witness stands down]

23 JUDGE ORIE: We adjourn for the day and will resume tomorrow,

24 Thursday, the 13th of August, 9.30 in the morning, in this same

25 courtroom, I.

Page 37737

1 --- Whereupon the hearing adjourned at 2.17 p.m.,

2 to be reconvened on Thursday, the 13th day

3 of August, 2015, at 9.30 a.m.