Tribunal Criminal Tribunal for the Former Yugoslavia

Page 37649

 1                           Wednesday, 12 August 2015

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.36 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             Madam Registrar, would you please call the case.

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

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

 9             JUDGE ORIE:  Thank you, Madam Registrar.

10             The Chamber was informed that there were a few preliminary

11     matters to be raised by the parties.

12             Mr. Traldi.

13             MR. TRALDI:  Thank you, Mr. President, and good morning.

14             Regarding the additional pages from 65 ter 19777, the Prosecution

15     yesterday used page 68 in B/C/S and 69 in English from that document; the

16     diary of a Defence witness named Nenad Davidovic.  The Prosecution has

17     uploaded B/C/S pages 68 through 70, and English pages 69 through 71, of

18     the diary, as well as the portions already admitted as P7418 under 65 ter

19     19777F.

20             JUDGE MOLOTO:  Sorry, Mr. Mladic doesn't hear.

21             JUDGE ORIE:  Yes, there seems to be a problem with the audio.

22             Mr. Mladic, can you hear me now?  Apparently not.

23             Could the usher assist or could technicians assist.

24             Can you hear me?

25             Mr. Mladic, can you hear me now in a language you understand?  I

Page 37650

 1     see your thumbs-up.  Therefore, we'll proceed.

 2             Could I invite you to restart, Mr. Traldi.

 3             MR. TRALDI:  Yes, Mr. President.

 4             Regarding the additional pages from 65 ter 19777, the Prosecution

 5     yesterday used page 68 in B/C/S and 69 in English from that document,

 6     which is the diary of a Defence witness named Nenad Davidovic.  The

 7     Prosecution has uploaded B/C/S pages 68 through 70 and English pages 69

 8     through 71 of the diary, along with the portions already admitted as

 9     P7418 together under 65 ter 19777F.

10             The three pages in each language represent what's clearly the

11     notes of that meeting on June 24th that I'd inquired about.  If the

12     Defence have no objection, we request that the Court officer be

13     instructed to assign P7418 to 65 ter 19777F.

14             JUDGE ORIE:  I saw that Mr. Lukic was nodding in a sense that

15     there is no objection.

16             Madam Registrar, would you please replace the existing document

17     known as P7418 by the new one under the number 65 ter 19777F, and the

18     newly uploaded version is now admitted, still under the same number as

19     P7418.

20             Mr. Lukic, the Chamber was informed that you had a few matters as

21     well.

22             MR. LUKIC:  Yes, Your Honour.  And good morning, Your Honours.

23             First, we would address our filing in regard of one of our 92 bis

24     statements for Simic, Ljubisav.  We filed it but we have to redact a few

25     more portions because we spoke with the Prosecution yesterday, and

Page 37651

 1     they -- there was a dead-line for the Prosecution to respond to our

 2     motion and we agreed that we will withdraw this motion and file another

 3     one with the additional redactions, since there were some remarks in that

 4     statement that are directly in connection with the conduct of Mr. Mladic.

 5             JUDGE ORIE:  Yes.  Mr. Lukic, please assist me.  Was the previous

 6     filing, was that a confidential one?

 7             MR. LUKIC:  I don't think so.

 8             JUDGE ORIE:  And the redactions are such that they do not touch

 9     upon confidentiality but rather on what is permitted under Rule 92 bis?

10             MR. LUKIC:  Yes, Your Honour.

11             JUDGE ORIE:  So, therefore, there may be no need to put it under

12     seal but rather to focus exclusively for purposes of this procedure on

13     the new one?

14             MR. LUKIC:  Yes, Your Honour.

15             JUDGE ORIE:  That's hereby on the record.  We'll receive in due

16     time a response by the Prosecution.

17             MR. TRALDI:  Within two weeks after the Defence --

18             JUDGE ORIE:  Yes.

19             MR. TRALDI:  -- files the new motion.

20             JUDGE ORIE:  Yes, of course.  You can't respond before it's

21     filed.  That's understood.

22             That was the Simic filing.  Anything else, Mr. Lukic?

23             MR. LUKIC:  Yes, Your Honour.  We, as you ordered yesterday, we

24     checked on this expertise by Mr. Gojkovic, and English version is missing

25     only that one picture.  That's the only discrepancy.  But there were some

Page 37652

 1     differences in B/C/S.  For example, somehow computer turned on page 2 in

 2     English there were numbers, 1 to 8; in B/C/S, there were bullet points.

 3     So we will change B/C/S now to have numbers.

 4             And there is one more page missing in B/C/S.  It's -- in English,

 5     it's page 23.  It's just situation plan for Petricevac church.  Somehow

 6     that page was left out in B/C/S version.  So that will be added in B/C/S

 7     version as the page 21a, so we have the same sequence of pages that we

 8     discussed on the record.

 9             JUDGE ORIE:  I think, then, that we are dealing mainly with an

10     administrative matter rather than any matter of substance.

11             MR. LUKIC:  Yes.

12             JUDGE ORIE:  Therefore, you're invited to upload all the correct

13     versions, and we'll proceed meanwhile since it doesn't touch upon the

14     substance.

15             MR. LUKIC:  And the new version will be uploaded under number

16     1D05892A.

17             JUDGE ORIE:  Yes.  We'll see when it appears.

18             Anything else?  If not, the witness can be escorted into the

19     courtroom.

20             Meanwhile, I can inform the parties that Mr. Gojkovic yesterday

21     provided not the USB stick itself because there were other files on it

22     which are not relevant for this procedure, he considered them to be

23     private.  He was invited to have the relevant files copied onto another

24     USB stick.

25                           [The witness entered court]

Page 37653

 1             JUDGE ORIE:  Now, there seems to be a problem with opening that

 2     file, but the new USB stick -- the USB stick on which the file was

 3     copied, it was only one file, has been handed over to one of the members

 4     of Chamber staff, and Chamber staff will seek the assistance of our

 5     technicians to see whether they can open that file, yes or no, and then

 6     it will be made available to the parties.

 7             Good morning, Mr. Gojkovic.  I just informed -- can you hear me

 8     in a language you understand?

 9             THE WITNESS: [Interpretation] Yes, I hear you.  Good morning.

10             JUDGE ORIE:  Mr. Gojkovic, I just explained to the parties that

11     there was a follow-up yesterday afternoon where you were invited to

12     provide files of earlier versions or at least versions of your report

13     that you were hesitant to hand over the whole of the USB stick because

14     there were files on it which are not relevant for us.  Therefore, one

15     file has been copied onto another USB stick which has been now handed

16     over to Chamber staff.

17             There were some problems in opening that file, and we are seeking

18     assistance to have it opened.  But if you could inform us in any way as

19     to what format that file is so that we would be assisted in trying to

20     open it, you're invited to give that information now.

21             THE WITNESS: [Interpretation] It was all done in Word, A4 format.

22             JUDGE ORIE:  Then we'll see whether this Word file -- was it --

23     as far as you remember, was it a doc file or was it a docx file?

24             THE WITNESS: [Interpretation] I don't remember that.  Some of --

25     parts of the documents were done in PDF, some documents I took from the

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 37672

 1        A.   Thank you.

 2             JUDGE ORIE:  Thank you, Mr. Lukic.

 3             Mr. Traldi, any further questions for the witness?

 4             MR. TRALDI:  Just very, very, briefly, Your Honour.

 5             JUDGE ORIE:  Within five minutes?

 6             MR. TRALDI:  Within five minutes.

 7             JUDGE ORIE:  Then I suggest that we'll continue for those five

 8     minutes and then hear the next witness after the break.

 9                           Further Cross-examination by Mr. Traldi:

10        Q.   Sir, first, Mr. Lukic asked you this morning about salary

11     payments to people in the 1st Krajina Corps' engineering units.  You

12     yourself received salary during the war from the VJ in Belgrade; right?

13        A.   That's correct.

14        Q.   Through the 30th Personnel Centre?

15        A.   That's correct.

16        Q.   So did the other officers who'd come over from the JNA to the VRS

17     when the transformation occurred; right?

18        A.   That's correct.

19        Q.   Finally, sir, this morning you were asked again about the

20     distinction between mosques that you determined were destroyed during

21     combat operations and mosques destroyed after VRS withdrawal.  You said

22     you assumed that when the combat operations were over the VRS left.  Is

23     it correct that you did not study any VRS documents to determine when VRS

24     operations, setting aside whether they were combat or not, ended in a

25     particular village?

Page 37673

 1        A.   I can show that best through an example:  Fighting in Lisina,

 2     near -- well, in the Prnjavor municipality was conducted over a couple of

 3     days.  Something like that.  But the mosques were destroyed for months

 4     after that.  It didn't happen in a single day.

 5        Q.   Now, Lisina, that's not one of the mosques addressed in your

 6     report or Mr. Riedlmayer's; right?

 7        A.   That's correct.  That's correct.

 8        Q.   And --

 9        A.   All I'm saying is that --

10        Q.   Sir, if you could just let me go one step at a time, please, so

11     we get this done quickly.

12             When you give the explanation you just gave about Lisina, you're

13     giving information you remember from when you were deployed in the

14     Prnjavor area during the war; right?

15        A.   No, no.  It was while I was carrying out combat assignments, and

16     I would pass by there, and then I could see when the mosques were

17     destroyed.  It was not -- they were not demolished all in one day.  It

18     took a period of time.  The Prijedor mosques were --

19        Q.   What I'm asking is about your methodology over the last couple of

20     months or at the time the 630 hours spent on developing this report.

21     During that period, for a village like Novoseoci or Rizvanovici or

22     Ahatovici, is it correct that you reviewed no VRS documents during the

23     preparation of the report to determine when VRS operations in that

24     village had ended?

25        A.   My methodology, Mr. Prosecutor, was more or less the same as that

Page 37674

 1     of Mr. Riedlmayer.  I could not rely on anything else --

 2             JUDGE ORIE:  Witness, you're not invited to compare your

 3     methodology with that of Mr. Riedlmayer.  The simple question was whether

 4     you systematically, and I heard the word "systematically," reviewed

 5     documents as to whether after combat was over, whether operations of

 6     whatever kind by the VRS continued and whether you studied that on the

 7     basis of documentary evidence.

 8             I see you are nodding no, that you did not.  Is that well

 9     understood?

10             THE WITNESS: [Interpretation] I tried.  But at the time I could

11     not have access to any documents.  I went to the archives, but I could

12     get none of the documents, so I exclusively relied on the report.

13             JUDGE ORIE:  Thank you.

14             MR. TRALDI:  I've no further questions.

15             JUDGE ORIE:  No further questions.

16             MR. LUKIC:  I'm sorry, if the witness can just take off his

17     headphones please.

18             JUDGE ORIE:  Could you take off your earphones for a second,

19     Witness.

20             MR. LUKIC:  If Your Honours want to check it with the witness, in

21     the document that was redacted and translated only in a small portion,

22     which is P7493, it is mentioned how many active-duty officers were in

23     that unit.  It's at 1.4, when it was discussed about salaries received

24     from the Belgrade.

25             MR. TRALDI:  I -- if Mr. Lukic has the e-court page, I'd

Page 37675

 1     appreciate it.  I don't understand what 1.4 officers are.

 2             MR. LUKIC:  It's not in the e-court, because you put only two

 3     pages.

 4             MR. TRALDI:  No, the e-court for 65 ter 32853 --

 5             MR. LUKIC:  Okay.

 6             MR. TRALDI:  -- is the full document.

 7             MR. LUKIC:  It's page 13 of 65 ter 32853.  And it says "active

 8     duty officers, reserve," and total number of soldiers.  So you will see

 9     active-duty officers, 1.4.

10             JUDGE ORIE:  You're drawing our attention to a portion of the

11     documentary evidence.

12             MR. LUKIC:  Yes.  And that's what we ask -- we will ask for this

13     document to be translated in full.

14             JUDGE ORIE:  Yes.  You'd say we'll find most likely information

15     in that document --

16             MR. LUKIC:  Yes --

17             JUDGE ORIE:  -- which is not visible for us at this moment.

18             MR. LUKIC:  And 1.5 is officers, commissioned officers, and

19     soldiers in total.

20             JUDGE ORIE:  So we're -- at this moment, we are discussing the

21     content of the evidence, and I think that's not appropriately done at

22     this moment.

23             MR. LUKIC:  That's why I asked for the witness to take off his

24     headphones.

25             JUDGE ORIE:  Yes.  And we'll see once we have before us the whole

Page 37676

 1     of the document.  Parties have ample opportunity to argue about it and

 2     what it tells us or what it doesn't tell us.

 3             MR. TRALDI:  I agree.  And, as always, we're open to Mr. Lukic

 4     suggesting any additional portions from the document he's interested in.

 5             JUDGE ORIE:  Yes, that's clear.

 6             Mr. Lukic, can the witness put on his earphones again?

 7             MR. LUKIC:  Yes, he can.  Thank you, Your Honour.

 8             JUDGE ORIE:  Yes.  Witness.

 9             Mr. Gojkovic, the parties have no further questions for you.

10     Neither has the Bench.  Which means that we are at the end of hearing

11     your testimony.  I would like to thank you very much for coming a long

12     way to The Hague and for having answered the questions that were put to

13     you.  You're excused.  You may follow the usher, and I wish you a safe

14     return home again.

15             THE WITNESS: [Interpretation] Thank you, Your Honour.

16                           [The witness withdrew]

17             JUDGE ORIE:  Mr. Traldi, you're on your feet.

18             MR. TRALDI:  We spend so much time together it's easy to misplace

19     us.

20             JUDGE ORIE:  Well, I wouldn't call you identical twins yet, but

21     please proceed.

22             MR. TRALDI:  Perhaps I was flattering myself.

23             Just to ensure that we have the right people here at the

24     beginning of the next session, Your Honour, I know the tendering of the

25     report remains pending.  But because we're still awaiting the Word

Page 37677

 1     document, I wonder if we might postpone that until we have ...

 2             JUDGE ORIE:  I see from Mr. Lukic nodding that he doesn't

 3     disagree or even agrees.  Further time will be given for the tendering of

 4     the report and any objections to it.

 5             We take a break and will resume at 11.00.

 6                           --- Recess taken at 10.39 a.m.

 7                           --- On resuming at 11.02 a.m.

 8             JUDGE ORIE:  Mr. Lukic, is the Defence ready to call its next

 9     witness?

10             MR. LUKIC:  Yes, Your Honour, we are.  We are calling

11     Ms. Bosiljka Mladic.

12             JUDGE ORIE:  Could the witness be escorted into the courtroom.

13                           [The witness entered court]

14             JUDGE ORIE:  Good morning, Mrs. Mladic, I assume.  Before you

15     give evidence, the Rules require that you make the solemn declaration.

16     The text is now handed out to you.  May I invite you to make that solemn

17     declaration.

18             THE WITNESS: [Interpretation] I solemnly declare that I will

19     speak the truth, the whole truth, and nothing but the truth.

20                           WITNESS:  BOSILJKA MLADIC

21                           [Witness answered through interpreter]

22             JUDGE ORIE:  Thank you.  Please be seated, Ms. Mladic.

23             Ms. Mladic, you'll first be examined by Mr. Lukic.  You'll find

24     Mr. Lukic to your left.  Mr. Lukic is counsel for Mr. Mladic.

25             Please proceed.

Page 37678

 1             MR. LUKIC:  Thank you, Your Honour.

 2                           Examination by Mr. Lukic:

 3        Q.   [Interpretation] Good day, Mrs. Mladic.

 4        A.   Good day.

 5        Q.   For the record, could you please slowly state your name and

 6     surname.

 7        A.   Bosiljka Mladic.

 8        Q.   Mrs. Mladic, at one point in time did you give a statement to

 9     members of the Defence team of General Mladic?

10        A.   Yes, I did.

11             MR. LUKIC: [Interpretation] Can we now please see 1D1749 in

12     e-court.

13             THE WITNESS: [Interpretation] I have the English version here.

14             MR. LUKIC: [Interpretation]

15        Q.   Just a moment, please.  What you're looking at is the transcript,

16     and on the other screen you will see your statement.

17             Mrs. Mladic, there is a document before us.  Do you see a

18     signature there?

19        A.   Yes.

20        Q.   Do you recognise the signature?

21        A.   Yes.

22        Q.   Whose signature is it?

23        A.   It's mine.

24        Q.   Thank you.

25             MR. LUKIC: [Interpretation] Can we now take a look at the last

Page 37679

 1     page of this document.

 2             THE WITNESS: [Interpretation] We can.

 3             MR. LUKIC: [Interpretation]

 4        Q.   Do you see a signature on this page?

 5        A.   Yes.

 6        Q.   Do you recognise it?

 7        A.   Yes.

 8        Q.   Whose signature is it?

 9        A.   It's mine.

10        Q.   What is written in your statement, does that correspond to what

11     you said to the members of the Defence team of General Mladic?

12        A.   Yes.

13        Q.   To the best of your knowledge, what is contained in the

14     statement, is it correct and truthful?

15        A.   Yes, it is correct and truthful.

16        Q.   If I were to put the same questions to you today, would you give

17     me the same answers?

18        A.   Yes, I would give the same answers.

19        Q.   Thank you.

20        A.   You're welcome.

21             MR. LUKIC:  I would tender the statement of Mrs. Mladic into

22     evidence.

23             JUDGE MOLOTO:  Any summary for the public?

24             MR. LUKIC:  Yes, I will read the summary.

25             JUDGE ORIE:  No objections, Ms. Hasan?

Page 37680

 1             Madam Registrar.

 2             THE REGISTRAR:  Document 1D1749 receives number D1185, Your

 3     Honours.

 4             JUDGE ORIE:  D1185 is admitted.

 5             MR. LUKIC:  I will read a short summary, a very short summary.

 6             JUDGE ORIE:  Please do so.

 7             MR. LUKIC:  Mrs. Mladic is our alibi witness in connection of the

 8     whereabouts of Mr. Mladic from 14th to 17th of July, 1995, and

 9     Ms. Mladic, Bosiljka, is General Mladic's wife.  She will testify that in

10     the period from 14th until 17th of July, 1995 General Mladic was in

11     Belgrade along with her, and she will provide details on General Mladic's

12     whereabouts on those dates.

13             This is a short summary.  And I will, with your leave, Your

14     Honours, have several questions for Mrs. Mladic.

15             JUDGE ORIE:  Please proceed as you suggest.

16             MR. LUKIC:  Thank you, Your Honour.

17        Q.   [Interpretation] Mrs. Mladic, in your statement you refer to the

18     dates of the 14th, 15th, and 16th, and the morning of the 17th of July,

19     1995.  This is what I'm going to ask you now:  Your husband,

20     General Ratko Mladic, where was he during the night between the 14th and

21     15th of July, 1995?

22        A.   He was at home with me in Belgrade.

23        Q.   Your husband, General Mladic, where was he during the night

24     between the 15th and 16th of July, 1995?

25        A.   He was with me at home in Belgrade.

Page 37681

 1        Q.   Your husband, General Mladic, what was he during the night

 2     between the 16th and 17th of July, 1995?

 3        A.   He was at home with me in Belgrade.

 4        Q.   How do you know that General Mladic spent the night at home?

 5        A.   I know because we were preparing for a wedding on the 16th of

 6     July.  He arrived in the evening, in the evening hours, and he

 7     immediately reminded me that we need to prepare for this wedding.  So I

 8     remember those days.  He -- yes?

 9        Q.   Did you go to sleep together?

10        A.   Yes.  We went to sleep together, we had dinner together, we got

11     up together, we had breakfast, had coffee, talked.

12        Q.   Thank you.

13        A.   You're welcome.

14        Q.   Those days, while you were with General Mladic between the 14th

15     and the morning of the 17th, did you notice that he had some kind of

16     communications equipment?  Did he have a radio, a Motorola, or something?

17        A.   No, he had none of that.  He just wore his uniform when he

18     entered the house.

19        Q.   Did you see Mladjo Kenjic or anybody else who was escorting

20     General Mladic?  Did they have any communications equipment?

21        A.   No, I did not notice any communications equipment on anyone.

22        Q.   In the statement, you said that at one moment you travelled by

23     car and that Mladjo Kenjic drove you.  In the car where you were riding

24     with General Mladic, did you see any communications equipment, a radio or

25     something?

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 37719

 1             MR. LUKIC:  Thank you.

 2                           Re-examination by Mr. Lukic:

 3        Q.   [Interpretation] Mrs. Mladic, how many times in your life were

 4     you the matron of honour at somebody's wedding?

 5        A.   This was the first time for me.

 6        Q.   On working transcript page 49, line 9, something was suggested to

 7     you, and I'm going to ask you this:  Do you know whether on the 14th of

 8     July, 1995 General Mladic came to your home in Belgrade directly from

 9     Bosnia, or did he previously attend some meetings and do you know that?

10        A.   I don't know whether he came straight from Bosnia or from some

11     meetings.  He didn't have a lot of time.  He didn't stay long.  He said,

12     "I'm going to a meeting with President Milosevic and some representatives

13     of the international community."  This is what I remember.

14        Q.   And do you know whether he was attending any meetings before that

15     or not?  Maybe you have no knowledge of it.

16        A.   No, I don't know anything about it.

17        Q.   I would like us to take a look briefly at this document, P1147,

18     transcript.  The transcript that was before you.  It contains this

19     conversation, too, that was transcribed.  Or rather, written down.  This

20     telephone conversation from the VMA.

21             You were asked whether General Mladic gave any orders to this man

22     over the telephone, and you said I don't know what an order is.

23             MR. LUKIC: [Interpretation] We need page 90 in B/C/S and page 94

24     in English.  We have a problem with the translation, part of it.  And now

25     I'm going to indicate the part where we have a problem.  And I'm

Page 37720

 1     saying -- well, it is where General Mladic starts.

 2        Q.   It says:

 3             "Mladic ..."

 4             And then underneath it says:

 5             "Mladic, telephone conversation."

 6             In B/C/S it is line 4, underneath the second time the name

 7     "Mladic" is typed out.  Line 6 in the English version.  In the English

 8     version, it says:

 9             "[In English] Okay.  Here is what we'll do ..."

10             [Interpretation] And now I'm going to read out the B/C/S version,

11     what it was that General Mladic said.

12             JUDGE ORIE:  Mr. Lukic, is there a translation issue?  Because

13     you are -- you are using -- if there is, it's not through a witness that

14     we resolve translation issues.

15             MR. LUKIC:  The witness was questioned exactly on this portion.

16             JUDGE ORIE:  Then you should refrain from any of those comments.

17     You should read to the witness what, in your view, is the best version

18     and ask questions.

19             MR. LUKIC:  This is the only version.

20             JUDGE ORIE:  Not to hint at any discrepancy or whatever.  You

21     just follow up on what was done.  And there is no way that in

22     re-examination you could suggest to a witness that there are translation

23     issues.  There may be.  They can be resolved.  But then you read what, in

24     your view, is the right version, and then we check later on - you can

25     check as well, and we don't need the witness for that - whether the

Page 37721

 1     translation is correct or not.  You can do that on the spot if you have

 2     any problem, but first put to the witness what is the correct version in

 3     this document.  Please do so.

 4             MR. LUKIC:  Thank you, Your Honour.

 5        Q.   [Interpretation] What is recorded here is that General Mladic

 6     said:

 7             "Okay.  You and I will agree ..."

 8             This is what I'm going ask you:  Were you ever out in the field

 9     where General Mladic was during the war?

10        A.   Yes.

11        Q.   Did you see him in Bosnia when he was issuing orders?

12        A.   Yes.

13        Q.   When he issued orders, did he say to his subordinates that they

14     will agree on something, or did he tell them what they would do?

15        A.   No, he would tell them what they should do.

16        Q.   Thank you.

17             JUDGE MOLOTO:  Mr. Lukic, just for me to be able to follow.  Can

18     you refer us into the English where --

19             MR. LUKIC:  Yes.

20             JUDGE MOLOTO:  -- you say "can we agree"?

21             MR. LUKIC:  There is no such a thing in English.  That's exactly

22     the problem.

23             JUDGE MOLOTO:  Right, but --

24             MR. LUKIC:  In English it says:  "Okay.  Here's what we will do."

25     It's the sixth line under second name -- line.

Page 37722

 1             JUDGE MOLOTO:  I see that.

 2             MR. LUKIC:  In B/C/S it says, I will quote [Interpretation]:

 3     "Okay.  You and I will agree ..."

 4             JUDGE ORIE:  Any further questions?

 5             MR. LUKIC:  No further questions.

 6             JUDGE ORIE:  No further questions.

 7             MR. LUKIC:  Thank you.  I just want to thank Mrs. Mladic.

 8             JUDGE ORIE:  Yes.  And I take it that you would like to have

 9     reviewed the --

10             MR. LUKIC:  Yes.

11             JUDGE ORIE:  -- the translation --

12             MR. LUKIC:  Yes, Your Honour.

13             JUDGE ORIE:  -- of this portion.

14             MR. LUKIC:  Yes, please.

15             JUDGE ORIE:  Whereas you suspect that where it says "here's what

16     we will do," is that some kind of an agreement should be part of the

17     translation.

18             Okay.  That's -- I think it's a P exhibit.

19             MR. LUKIC:  Yes, it is.

20             JUDGE ORIE:  Therefore, Ms. Hasan, you are aware now of the

21     potential problem in translation, and I take it that you will have it

22     reviewed and report to the Chamber.

23             Then, Mrs. Mladic -- yes, Ms. Hasan.

24             MS. HASAN:  Your Honour, if I can just put one question to the

25     witness.

Page 37723

 1             JUDGE ORIE:  Yes, if you have another question.  The Chamber has

 2     no questions.

 3                           Further Cross-examination by Ms. Hasan:

 4        Q.   Mrs. Mladic, the portion where it says, which Mr. Lukic just

 5     brought up to you, following that, your husband talks about "how about at

 6     the stadium at Legenda's place?"

 7             Now, do you know Legenda?

 8        A.   No, no.

 9        Q.   Okay.  Are you aware that Legenda's place is in Zvornik?

10        A.   No.

11        Q.   You had mentioned that General Mladic would not have flown that

12     night for fear of being shot at.  Now, you understand that flying to

13     Zvornik would not have posed a threat to General Mladic as he would not

14     be flying near the area of Zepa, where the NATO aircrafts were?

15        A.   But he stayed at home.

16             MS. HASAN:  I've nothing further.

17             JUDGE ORIE:  Thank you, Ms. Hasan.

18             Ms. Mladic, this concludes your testimony in this court.  I would

19     like to thank you very much for coming a long way to The Hague and for

20     having answered all the questions that were put to you by the parties and

21     by the Bench, and I wish you a safe return home again.

22             THE WITNESS: [Interpretation] Thank you.

23             JUDGE ORIE:  You may follow the usher.

24                           [The witness withdrew]

25             JUDGE ORIE:  We'll take a break.

Page 37724

 1             Mr. Lukic, is the Defence ready to call its next witness after

 2     the break?

 3             MR. LUKIC:  Yes, Your Honour, we are.  And my colleague, Ivetic,

 4     would lead our next expert witness.

 5             JUDGE ORIE:  Yes.  We resume at 20 minutes to 2.00.

 6                           --- Recess taken at 1.18 p.m.

 7                           --- On resuming at 1.43 p.m.

 8             JUDGE ORIE:  Mr. Ivetic, the Defence will call now Mr. Dosenovic?

 9             MR. IVETIC:  That is correct, Your Honours.

10             JUDGE ORIE:  Then we'll wait for him to enter the courtroom.

11                           [The witness entered court]

12             JUDGE ORIE:  Good afternoon, Mr. Dosenovic --

13             THE WITNESS: [Interpretation] Good afternoon.

14             JUDGE ORIE:  -- I take it.  Before you give evidence, the Rules

15     require that you make a solemn declaration of which the text is now

16     handed out to you.  May I invite you, and take your time to put on your

17     glasses, to make that solemn declaration.

18             THE WITNESS: [Interpretation] I solemnly declare that I will

19     speak the truth, the whole truth, and nothing but the truth.

20                           WITNESS:  MILE DOSENOVIC

21                           [Witness answered through interpreter]

22             JUDGE ORIE:  Thank you.  Please be seated.

23             THE WITNESS: [Interpretation] Thank you.

24             JUDGE ORIE:  Mr. Dosenovic, you'll first be examined by

25     Mr. Ivetic.  You'll find him standing to your left.  Mr. Ivetic is a

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.