Tribunal Criminal Tribunal for the Former Yugoslavia

Page 26705

 1                           Tuesday, 7 October 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.05 a.m.

 6             JUDGE AGIUS:  Good morning, everybody.  Good morning, Madam

 7     Registrar.  Could you call the case, please.

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

 9     IT-05-88-T, The Prosecutor versus Vujadin Popovic, et al.

10             JUDGE AGIUS:  Thank you.  All the accused are present.

11     Prosecution, today we have Mr. McCloskey and Mr. Vanderpuye.  Amongst the

12     Defence teams, I notice the absence of Ms. Tapuskovic, Mr. Nikolic,

13     Mr. Bourgon, and Mr. Petrusic.  All right the witness is already present.

14             Good morning to you, Professor.

15             THE WITNESS: [Interpretation] Good morning.

16             JUDGE AGIUS:  I hope you had a good rest.  We are going to

17     continue with your testimony today.  I don't think we will finish today,

18     but we'll make an effort to reduce it as much as possible.

19             Mr. Lazarevic, he is in your good hands.

20             MR. LAZAREVIC:  Good morning, Your Honours.  Good morning,

21     everybody.

22             I would first like to express my gratitude to my colleagues from

23     the Prosecution for providing us with English translation of the

24     document.  Unfortunately, it hasn't still been released in the e-court

25     system, but hard copies have been delivered.  So, I think, we can safely

Page 26706

 1     proceed with the translation that we have right now.

 2             JUDGE AGIUS:  We are talking of 4D192; aren't we?  Yes.

 3             MR. LAZAREVIC:  Yes, Your Honours.  Right.

 4                           WITNESS:  MLADEN BAJAGIC [Resumed]

 5                           [Witness answered through interpreter]

 6                           Examination by Mr. Lazarevic:  [Continued]

 7        Q.   [Interpretation] Good morning, Professor Bajagic.

 8        A.   Good morning.

 9        Q.   Yesterday, when we adjourned, we were discussing document 4D129.

10     That's tab number 10 in your binder.

11             MR. LAZAREVIC:  [Microphone not activated] ... read 192.

12             JUDGE AGIUS:  For the record, today we are sitting pursuant to

13     Rule 15 bis, only for the first session, due to an urgent matter that

14     Mr. Justice Stole had to attend to.

15             MR. LAZAREVIC: [Interpretation]

16        Q.   Mr. Bajagic, do you have in front of you the set of rules on the

17     internal organisation of MUP?

18        A.   Yes, I do.

19             MR. LAZAREVIC: [Interpretation] Let us now look at Article 10

20     which is on page 5 in the B/C/S version.

21        Q.   This article lays down organisational units within MUP.  Let us

22     just look at the subtitle above Article 10.

23        A.   Yes.

24        Q.   What is this about?

25        A.   This is the public security service.

Page 26707

 1        Q.   Now, let us read Article 10.  Can you tell me under item 1, it

 2     reads:  "Special Brigade."  Can you tell me something about this?

 3        A.   Yes.  Article 10 lays down organisation units of the police

 4     administration and number 1, it's special brigade of police.

 5        Q.   Can you tell us what detachments can we see underneath and the

 6     locations under?

 7        A.   Under subitems (a) to (d), it says that the special police

 8     brigade has five detachments located in Banja Luka, Bijeljina, Doboj,

 9     Sarajevo, and Trebinje.

10        Q.   Very well.  And, now, in the previous paragraph of Article 10,

11     functionally speaking, where the police special brigade was, part of

12     which system it was?

13        A.   In view of Article 7 and 10 of this set of rules, we see that the

14     special police brigade is part of the public security service within the

15     seat of the ministry.

16        Q.   And, of course, the first sentence in Article 10 gives -- can you

17     give us more details?

18        A.   Within the police administration of this public security service,

19     within the seat of the ministry.

20        Q.   Now, in order to clarify to the Chamber the difference between

21     the organisation in functional terms and organisational terms, let us

22     take an example of the special police brigade as set out in this set of

23     rules, and the security services centre.

24             Can you explain what was the relationship between these two

25     units.  Was there any hierarchical relationship or any other

Page 26708

 1     relationship?

 2        A.   These two forms of organisations in the police, there was no

 3     hierarchical relationship.  As we can see, the public security service is

 4     part of the ministry; and within it, there's police administration.  At

 5     that time, one of its organisational parts was the special police

 6     brigade.

 7             On the other hand, the security services centre or the Public

 8     Security Centre was organised within the Ministry of Interior on a

 9     territorial basis.  Therefore, there was no hierarchical relationship

10     between the two; that is to say, no subordination or superiority.  I

11     presume that there were just some forms of cooperation because both these

12     segments were part of the MUP.

13        Q.   I have finished with this document for now, and now I would like

14     us to move to the next period of the development of MUP of Republika

15     Srpska; that's the period 1993-1995.  You will find it under number 11 in

16     your binder.

17             MR. LAZAREVIC: [Interpretation] That's Exhibit 4D194; pages 5 and

18     6 in B/C/S, and pages 11 and 12 in English.

19        Q.   We are talking about Article 61.  First of all, let's say that

20     this is the consolidated version of the constitution of Republika Srpska

21     of the 31st of December 1992, and now we will move to Article 68.

22             Do you have it in front of you?

23        A.   Yes.

24        Q.   Let us first look what Article 68 defines, the first sentence.

25        A.   Yes.

Page 26709

 1        Q.   Let us now look at item 2.  Can you give me your comment on this?

 2        A.   Under chapter 4 of this constitution, the first sentence of

 3     Article 68 reads that the following shall be regulated and provided by

 4     the republic; and under 2 it reads, defence and security of the republic.

 5        Q.   Let us now look at item 13.

 6             MR. LAZAREVIC: [Interpretation] That's on page 6 in B/C/S and on

 7     page 12 in English.

 8        Q.   Item 13, what does it speak about?

 9        A.   It sets down the rights and obligations of the republic in terms

10     of organising and defining responsibilities of state bodies.

11        Q.   Did that refer to MUP as well?

12        A.   Definitely.  MUP is one of the administrative organs.  It is part

13     of the state administration.

14        Q.   Can we now move to Articles 104 to 107.

15             MR. LAZAREVIC: [Interpretation] In the e-court system, that's on

16     pages 8 and 9 in B/C/S, and page 18 in English.

17        Q.   Do you have it in front of you, Articles 104 to 107?

18        A.   Yes, I do.

19        Q.   Can you tell us something more about chapter 7 where these

20     articles are contained?

21        A.   Chapter 7, entitled "Defence," regulates the right and duties;

22     and Article 104 says that it's the right and the duty of all citizens to

23     defend and protect the sovereignty and the constitutional order of

24     Republika Srpska.  That's Article 104.

25        Q.   Now, what about Article 105, tell us what it says?

Page 26710

 1        A.   Article 105 says that Republika Srpska has its army consisting of

 2     a standing and a reserve force, and that the standing army is composed of

 3     professional soldiers and those in the compulsory military service.

 4        Q.   Can we just briefly discuss Article 106.  Who commands the Army

 5     of Republika Srpska pursuant to Article 106?

 6        A.   Pursuant to Article 106, the Army of Republika Srpska both in

 7     peacetime and wartime is commanded by the president of the republic in

 8     accordance with the constitution.

 9        Q.   And now, briefly, what about Article 108 [as interpreted], what

10     does it regulate?

11        A.   Article 107 [as interpreted] regulates court marshals --

12     actually, military courts and military prosecutors.

13        Q.   Now, looking at this entire chapter regulating the issue of

14     defence, can you tell me, is there any mention herein of MUP as one of

15     the defence components?

16        A.   According to the provisions of chapter 7, the MUP is not

17     understood in the traditional sense as part of the armed forces of

18     Republika Srpska.

19        Q.   Let us now look at the next document which is the Law on

20     Amendments to the Law.  That's tab 12 in your binder.  So this is the Law

21     on Amendments to the Law on the Ministry of the Interior -- I'm sorry.  I

22     misspoke.

23             This is the Law on Amendments to the Law on Internal Affairs,

24     dated 30th December 1993.

25             MR. LAZAREVIC: [Interpretation] That's 4D207 in e-court.

Page 26711

 1        Q.   Let us first look at Article 1 of this law, which is, of course,

 2     and page 1 in B/C/S and as well in the English version in e-court.

 3        A.   Yes.

 4        Q.   Let's look at the law together.  It's Article 3.

 5        A.   Yes, I've read it.

 6        Q.   And you can see yourself that in addition to the change in the

 7     title of the public security service into the public security sector,

 8     that the national security service changes into the public security

 9     service.  Does this law bring any other more significant changes to the

10     organisational structure?

11        A.   As we can see in Articles 1 and 2 of this law, the former service

12     becomes a sector.  Further on, the national security service changes its

13     name into the state security sector or department.  We are talking about

14     terminology here rather than any other more essential changes.

15        Q.   Very well.  And now I would like to move on to the next set of

16     rules under number 4D212, which is the Law on Internal Affairs, dated

17     25 March 1994.  In your binder, it is under tab 13.

18             MR. LAZAREVIC: [Interpretation] I would like us to look at

19     Article 3 of that law, which is on page 1 in the B/C/S version and on

20     pages 2 and 3 in the English version.

21        Q.   I would also like to look at the definition of Internal Affairs

22     provided for by this law.  Let's then look at Article 3 first.

23             I apologise.  Let me rephrase my question.

24             Pursuant to Article 3, what would be the tasks and duties under

25     the scope of Internal Affairs?

Page 26712

 1        A.   In the sense of this article, Internal Affairs imply the

 2     following:  Duties and tasks of public security; duties and tasks of

 3     state security; and, under 3, duties and tasks related to some

 4     administrative affairs, such as personal identity card, personal name,

 5     maintaining the registry of the dead, and permanent residence of

 6     citizens, citizenship, vital registers, and so on and so forth.

 7        Q.   Very well.

 8             MR. LAZAREVIC: [Interpretation] Let's move on to Article 24 in

 9     this law, which is in e-court on page 3 of B/C/S and on page 6 of the

10     English version.

11        Q.   Could you please tell me what the article defines in terms of the

12     police and its organisational units in a public security station?

13        A.   According to Article 24, police stations or public security

14     stations shall have police stations established in addition to reserve

15     police stations.  In other words, in a public security station, there are

16     police stations.  And Article 24 also envisages that a police station can

17     also have its departments outside of the station headquarters, and the

18     organisational form of such a unit is the so-called station department.

19        Q.   Very well.

20             MR. LAZAREVIC: [Interpretation]  Let's move to Article 27 on the

21     same page in B/C/S; and in English, it is on pages 6 and 7.

22        Q.   I would like us to focus on certain tasks that are performed by

23     the ministry headquarters.  In Article 27, you see that it starts with

24     the following words:  "The ministry headquarters itself shall have the

25     following duties and tasks."

Page 26713

 1             I would like to draw your attention to the second bullet point in

 2     this article.  Could you please explain the meaning of the second bullet

 3     point?

 4        A.   Pursuant to Article 27 of this law, the ministry headquarters

 5     itself shall have the following duties and tasks; and pursuant to bullet

 6     point 2, these include to monitor, direct, and coordinate the work of the

 7     Public Security Centres and public security stations.

 8        Q.   We are still talking about Article 27.  Let's move to the next

 9     column on your right-hand side.  Let's first look at the third bullet

10     point from the bottom, and could you please tell us what it defines?

11        A.   According to this, the ministry headquarters is in charge of

12     preparing proposals for the organisation and the total number of the

13     reserve police in the republic, as well as the criteria for the

14     replenishment thereof.

15        Q.   Let's look at the next bullet point immediately thereafter.  Can

16     you please explain?

17        A.   Yes, I'll try.  According to this bullet point of Article 27, the

18     ministry headquarters is in charge of activating the reserve police force

19     in emergency situations pursuant to an order issued by the president of

20     the republic.

21        Q.   Can we please move on to the next bullet point.

22        A.   Yes.  The next bullet point says that the ministry headquarters

23     will procure weapons and requisite equipment for the active and reserve

24     police from the allocated funds approved from the state budget, which

25     means that the ministry headquarters is in charge of the global

Page 26714

 1     procurement of weapons and requisite equipment for the entire Ministry of

 2     the Interior and all its organisational units, and that would be my

 3     comment.

 4        Q.   And now let's move ton the next bullet point, and that will be my

 5     last about this article.  Can you please comment upon the next bullet

 6     point in this article?

 7        A.   According to this bullet point, the ministry headquarters is in

 8     charge of establishing programs of professional training and continuous

 9     education of the active and reserve police, i.e., members of the Ministry

10     of the Interior, as well as other authorised official, and they also

11     check their professional abilities and skills.

12        Q.   Let's then summarize.  All these tasks and duties that we have

13     just listed, who is in charge of those?  Who is supposed to perform those

14     tasks and duties?

15        A.   According to Article 27, we can see that all these duties and

16     tasks are discharged by the ministry headquarters.

17        Q.   Very well then.

18             MR. LAZAREVIC: [Interpretation] Let's look briefly at Article 30

19     of this law, which is on page 3 in B/C/S, and on pages 7 and 8 in the

20     English version of this law in e-court.

21        Q.   And let's please look at paragraph 1 which says:  "Education of

22     appropriate police units."  Now that you've looked at Article 30, could

23     you please tell us under whose authority would be this task?

24        A.   The establishment of appropriate police units is under the

25     authority of the ministry headquarters.

Page 26715

 1             MR. LAZAREVIC: [Interpretation] Let's move on to Article 31 of

 2     this law, which is on page 4 in B/C/S and on page 8 in the English

 3     version of this document in e-court.

 4        Q.   Do you have Article 31 before you?

 5        A.   Yes.

 6        Q.   Who is in charge of the establishment of a unit or several units

 7     to carry out a particular duty or task pursuant to Article 31 of this

 8     law?

 9        A.   Pursuant to Article 31, the establishment of one or several units

10     to carry out a particular duty or task is under the authority of the

11     minister of the interior.

12        Q.   And just one more question about this.  The officer in charge of

13     such a unit pursuant to Article 31, who is such an officer responsible

14     to?  Who does he report to?

15        A.   The officer or officers of such unit or units report directly to

16     the minister of the interior.

17        Q.   Very well.  We will no longer need those documents for the time

18     being.  The next document that I would like us to look at is the set of

19     rules on the internal organisation of the Ministry of the Interior, dated

20     1 April 1994.  In your binder, it is under tab 14.

21             MR. LAZAREVIC: [Interpretation] This is Exhibit number 4D144.  We

22     will start with page 2 in B/C/S, which is the same page in the English

23     version of the document.

24        Q.   Let's first look at Article 2 of this book of rules or this

25     regulation, paragraph 2 thereof.

Page 26716

 1        A.   Yes.

 2        Q.   Can you please read paragraph 2 for us?

 3        A.   It reads:  "The minister's office is composed of the following

 4     component bureau for information:  Under 1 -- under 2, Bureau for the

 5     Suppression of Illegal Trade of Drugs and Opiates; under 3, a helicopter

 6     unit; under 4, Directorate for Common Affairs; and, finally, under 5,

 7     special police brigade.

 8        Q.   Very well.  And now when we look at the provisions of Article 2,

 9     paragraph 2 of this set of rules in comparison with the previous

10     regulation that we discussed, which is 4D192, would the solution under

11     which the special police brigade is placed under the office of the

12     minister, would that constitute a change, a material change to the law?

13        A.   Yes.  From the moment this set of rules came into force, the

14     special police brigade belonged to the office of the minister; and before

15     that or up to then, before this set of rules was adopted, the special

16     police brigade was part of the police administration, the public security

17     service in the ministry headquarters.  So there is a significant

18     difference here.

19        Q.   Thank you very much.  Let's talk about the same article of this

20     set of rules.

21             MR. LAZAREVIC: [Interpretation] Let's look at the penultimate

22     paragraph on page 5 in B/C/S or page 2 in the English version in e-court.

23        Q.   Could you please tell us what the provision you see here defines?

24        A.   I apologise.  Are we still talking about Article 2?

25        Q.   Yes, we are.

Page 26717

 1        A.   According to Article 2, the minister's office is in charge of the

 2     use of the special police brigade upon the minister's orders.

 3        Q.   We are talking about the penultimate and ultimate paragraph which

 4     is on page 4 in your document; penultimate paragraph and the last

 5     paragraph of Article 2, which is page 5 in e-court.

 6             But in your version, it's --

 7        A.   Yes, I can see it.

 8        Q.   Do you see the penultimate paragraph of this article which starts

 9     with the words "special police brigade"?

10        A.   Yes, I've found it.

11        Q.   Can you please now look at this paragraph?

12        A.   According to this paragraph, a special police brigade is in

13     charge of discharging special tasks and duties which are as follows:

14     Under 1, participation in combat; under 2, neutralizing sabotaging

15     terrorist groups and individuals; under 3, restoring public peace and

16     order where the two had been greatly violated; under 4, it performs

17     defence preparations of the brigade's wartime composition; under 5,

18     performs special training of the brigade members.

19             JUDGE KWON: [Previous translation continues] ... we are looking

20     at.

21             MR. LAZAREVIC:  Your Honours, we are talking about Article 2,

22     second to last paragraph of Article 2.

23             JUDGE KWON:  Thank you.

24             MR. LAZAREVIC:  [Interpretation]

25        Q.   Could you please continue?

Page 26718

 1        A.   Let me continue.

 2             Monitors and proposes material of technical equipment of the

 3     brigade in the accordance with the latest world achievements in the field

 4     of arming technical instruments, police equipment; keeps prescribed

 5     records; and, finally, realises other assignments and tasks that are

 6     ordered to the brigade by the minister.

 7        Q.   And the first task of the special police brigade, what would it

 8     be according to this article?

 9        A.   According to this provision of this article, the first and the

10     foremost task of the special police brigade is to participate in combat.

11        Q.   And now let's look at the last paragraph of this article.  Do you

12     have it in front of you?  Can you tell me something about it?  What does

13     it define and set out?

14        A.   The last paragraph of this article defines the overall

15     organisation of the special police brigade, and it says that the special

16     police brigade includes in its complement, first, the brigade command,

17     and, second, special police detachments.  Then it enumerates --

18             JUDGE KWON:  Sorry.  Could you check whether we have English

19     translation of that part.  I have difficulty.

20             MR. LAZAREVIC:  I apologise.  I will check, if Your Honours can

21     bear with me for one minute.

22                           [Defence counsel confer]

23             MR. LAZAREVIC:  Yes, Your Honour, I was just advised by my

24     co-counsel that is he looking at it.  I think we do have the translation

25     in the e-court system.

Page 26719

 1             JUDGE KWON:  Are we looking at the correct page now?

 2             MR. LAZAREVIC:  It should be -- it's the following page in

 3     English.  It should be page 3, I think.

 4             JUDGE KWON:  We are talking about Article 6?

 5             MR. LAZAREVIC:  Article 2, Your Honour.

 6             JUDGE KWON:  Page 3 is --

 7             MR. LAZAREVIC:  Yes, Your Honours.  It's a partial translation,

 8     not whole document is translated, only the relevant part that we intended

 9     to use with this witness.

10             JUDGE AGIUS:  Okay.  Let's proceed.  Thank you, Judge Kwon.

11             MR. LAZAREVIC: [Microphone not activated]

12             THE INTERPRETER:  Microphone please.

13             MR. LAZAREVIC: [Interpretation]

14        Q.   Dr. Bajagic, relative to the previous rule book, has the number

15     of detachments increased in this one?

16        A.   The number of detachments of special police is increased by two.

17     The previous rule book envisaged five, and this rule book envisages the

18     existence of seven special police detachments; namely, the Sarajevo

19     Detachment, Banja Luka, Doboj, Bijeljina, and Prijedor detachments that

20     were previously in existence, and two new ones:  Sekovici and Bilice.

21        Q.   Can we now move on to Article 57 of these rules.

22             MR. LAZAREVIC: [Interpretation] It's in page 7 in B/C/S and 5 in

23     English.

24        Q.   Can you tell us what does Article 57 govern?

25        A.   According to Article 57 of these rules, the headquarters of the

Page 26720

 1     ministry is to be set up in case a state of war is proclaimed, and that

 2     headquarters of staff, rather, is to be managed by the minister.

 3        Q.   Go on, please.

 4        A.   The article goes on to specify who the staff consists of, and it

 5     enumerates the minister, deputy minister, various heads of the public

 6     security department and the state security department, the commander of

 7     the special police brigade, the brigade command, and the commander of the

 8     PJP.

 9        Q.   Could you look at the last paragraph in this article.  What is

10     understood under the term used here, "police forces"?

11        A.   Pursuant to this article, police forces consist of members of the

12     special police brigade and members of the active and reserve police.

13        Q.   All right.  Let us now go back to Article 6.

14             MR. LAZAREVIC: [Interpretation] It is to be found on page 6 in

15     the e-court system in B/C/S, and in English, it's on page 3.

16        Q.   Do you have Article 6 before you?

17        A.   Yes.

18        Q.   Can you tell us what are the various organisational units

19     according to this article that existed within the public security

20     department?

21        A.   As we can see from Article 6, the Public Security Department or

22     Sector included the following organisational units:  1, the police

23     administration; 2, crime prevention administration; 3, border affairs and

24     foreigners administration; 4, inspectorate for firefighting and

25     preventative technical protection; 5, analysis and information

Page 26721

 1     administration; 6, administration for communications and encryption;

 2     7, administration of legal affairs; 8, duty operation centre; 9, centre

 3     for breeding, training, and usage of service dogs and horses; and, 10,

 4     public security centres.

 5        Q.   All right.  Let us move on to Article 15.

 6             MR. LAZAREVIC: [Interpretation] Those are pages 10 and 11 in

 7     B/C/S, and in English, it's 3 and 4.

 8        Q.   Based on this article, can you tell us which organisational units

 9     form the police administration?

10        A.   The organisational units of the police administration as part of

11     the public security sector are:  1, police squad; 2, police station,

12     securing physical persons and facilities; 3, police station for railway

13     station security -- for railway security; 3 [as interpreted], department

14     for road traffic security; and, finally, a section for defence affairs

15     and special operational activities.

16        Q.   Can we dwell for awhile on the section for defence affairs and

17     special operational activities.  Here, in this Article 15, under this

18     subheading midway down the paragraph, it says:  "Proposes formations and

19     organisations of separate police units, PJP."  Is that the case according

20     to this article?

21        A.   Pursuant to this article, the section for defence affairs and

22     special operational activities which belongs to the police administration

23     is responsible for drafting proposals concerning formations and

24     organisation of separate police units, PJP.

25        Q.   Just to remind ourselves, let us go back to Article 57.

Page 26722

 1             MR. LAZAREVIC: [Interpretation] That's page 7 in B/C/S, and 5 in

 2     English in e-court.

 3        Q.   Now, in your comments, you mentioned also the role of the PJP

 4     commander.  Let me ask you, before this rule book was adopted, did such a

 5     function, did such a position, PJP commander, exist?

 6        A.   To the best of my knowledge, this is the first reference to the

 7     position of PJP commander.

 8        Q.   All right.  We won't be needing this document any longer, for the

 9     time being.

10             JUDGE KWON:  Mr. Lazarevic, I'd like to personally have the full

11     translation of Article 2 and Article 56 and preceding articles which you

12     deal with the PJP, if you could make sure.

13             MR. LAZAREVIC:  Yes, Your Honour.  We'll request the full

14     translation, and as soon as it arrive, it will be uploaded in e-court.

15             JUDGE KWON:  Thank you.

16             MR. LAZAREVIC: [Interpretation]

17        Q.   Mr. Bajagic, let us move on to a set of rules that were valid in

18     July 1995 regarding the organisation and powers of the MUP in July 1995.

19             MR. LAZAREVIC: [Interpretation] They are to be found in e-court

20     as 4D413.

21        Q.   In your binder, it's tab 15.  I will give a reference now and

22     we'll move on slowly through these laws:  The laws on the application of

23     the Law on Government in Republika Srpska during state of war or

24     immediate threat of war; second, law on the application of the Law on

25     Ministries during immediate threat of war or state of war; three, the law

Page 26723

 1     on the application of the Law on Defence during the immediate threat of

 2     war or state of war; four, law on the application of the Law on the Army

 3     during immediate threat of war or state of war; and, five, the law on the

 4     application of the Law on Internal Affairs during immediate threat of war

 5     or state of war.

 6             The first law that I would like to look at and hear your comments

 7     is the Law on the Government of Republika Srpska during the immediate

 8     threat of war or state of war.  That's Exhibit 4D413; your tab 15.

 9             MR. LAZAREVIC: [Interpretation] We want Article 3, paragraph 2.

10     It's on page 1 in B/C/S, and page 2 in English.

11        Q.   Now, having looked at Article 3, tell me, what is the purpose of

12     these provisions?  In which way do they lay the framework for the

13     functioning of the ministry during the immediate threat of war.

14        A.   Article 3 says that the government of Republika Srpska exercises

15     its constitutional and legal functions through ministries, district,

16     commissioners offices, local authorities, and war presidencies of

17     municipalities.  By virtue of this very law, it's Article 3, the

18     government of Republika Srpska exercises its powers through republic

19     ministries including the one on the interior.

20        Q.   The next law I want to look at is the Law on Defence during

21     immediate threat of war or state of war.

22             MR. LAZAREVIC: [Interpretation] That's page 3 in both B/C/S and

23     English, 4D413.

24        Q.   Your tab 15.

25             First of all, one general question:  Can you tell us, does this

Page 26724

 1     law change the role of the MUP compared to its peacetime role pursuant to

 2     Article 2.

 3        A.   Are we talking about the law on the application of the Law on

 4     Defence?

 5        Q.   Precisely.

 6        A.   Yes.  Article 2 says that the armed forces of Republika Srpska

 7     shall consist of the Army of Republika Srpska, one; and, two, the units

 8     of the Ministry of the Interior of Republika Srpska.  It's a significant

 9     change, if you wanted my comments, because for the first time units of

10     the MUP are mentioned as a component of the armed forces.

11        Q.   My question is:  Is this about the entire structure of the

12     Ministry of the Interior or just its units?

13        A.   The law on the application of the Law on Defence in immediate

14     threat of war and state of war is very clear and precise.  It refers to

15     the units of the Ministry of the Interior.

16        Q.   And the Ministry of the Interior as an administrative body, does

17     it continue to operate with all its powers regardless of the fact that an

18     immediate threat of war or state of war has been declared?

19        A.   The circumstances of immediate threat of war and state of war

20     imply a certain expansion of the powers and role of the Ministry of the

21     Interior; but in any case, the ministry continues to discharge its

22     functions normally within its jurisdiction just as in peacetime.  It

23     continues to be engaged in protecting law and order, the personal

24     security of citizens and their property, crime prevention, et cetera.

25        Q.   I would now like to look at 4D416 [as interpreted].  It's your

Page 26725

 1     tab 73.  I think it's the second binder.

 2             MR. LAZAREVIC:  It was the wrong document, I notice, in the

 3     e-court.  It's 461.

 4        Q.   [Interpretation] Mr. Bajagic, do you see the document?

 5        A.   Yes, I do.

 6        Q.   First, let me ask you this:  You did not draft this diagram

 7     yourself?

 8        A.   No, I didn't.

 9        Q.   Have you seen it before?

10        A.   Yes, while I was preparing my report and before I came to this

11     courtroom.

12             JUDGE AGIUS:  One moment.  I notice Mr. Borovcanin.  Do you wish

13     to consult with your lawyer, Mr. Borovcanin?

14             MR. LAZAREVIC:  I apologise.  We have two different schematics

15     here; one on the right and the one on the left.

16             JUDGE AGIUS:  No, no.  I noticed him trying to attract your

17     attention.

18             MR. LAZAREVIC:  That's what Mr. Borovcanin wanted to indicate, I

19     think.

20             JUDGE AGIUS:  Thank you.  Let's proceed then.

21             MR. LAZAREVIC:  It's 461.  The one on the left side is right, but

22     on the right side is not correct.

23        Q.   [Interpretation] I'm sorry.  Can we continue now.

24        A.   No problem.

25             MR. LAZAREVIC:  Your Honours, I believe that the B/C/S version

Page 26726

 1     should be in the e-court system, too.  I don't know what seems to be the

 2     problem.

 3        Q.   [Interpretation] Very well.  We can proceed.

 4        A.   I actually don't need it.

 5        Q.   Can you tell me what this diagram represents?

 6        A.   This diagram represents the organisation of armed forces of

 7     Republika Srpska according to the applicable laws.

 8        Q.   This diagram pursuant to the law on the implementation of the Law

 9     on Defence in the state of imminent threat of war and state of war, the

10     first box says:  "Armed Forces of Republika Srpska."

11        A.   Yes, Armed Forces of the RS.

12        Q.   Beneath it is what?

13        A.   The box beneath it says:  "Commander in Chief, President of the

14     RS," and that is according to the law.  Next to him, we have Supreme

15     Command, and there are two lines, one going to the Supreme Command made

16     up of, naturally, in addition to the commander in chief, RS,

17     vice-president, the president of the national assembly of Republika

18     Srpska, the prime minister of the RS, the minister of defence and the

19     minister of the interior.

20        Q.   Let's move now to the next level.  Tell me, what does it

21     represent?

22        A.   It represents two main components of the armed forces of the RS

23     pursuant to the law on the implementation of the Law on Defence in an

24     immediate threat of war and a state of war.  There's the Main Staff and

25     the police forces staff; and underneath, according to the law, we have

Page 26727

 1     the RS army and MUP units.

 2        Q.   Very well.  I think we have finished with this document.

 3             Let us now look on the law on the implementation of Law on

 4     Internal Affairs during an imminent threat of war and state of war.

 5     That's Exhibit 4D413, and it's tab 15 in your binder.

 6             MR. LAZAREVIC: [Interpretation] First of all, let us look at

 7     paragraphs 1 and 2 of Article 4.  It's on page 4 in B/C/S, and on page 9

 8     in English.

 9             THE WITNESS: [Interpretation] Yes.

10             Pursuant to Article 4, the ministry [Realtime transcript read in

11     error "minister"] is considered to be a part of the armed forces of RS,

12     and its forces are managed or controlled by the president of the republic

13     as the commander in chief?

14             MR. LAZAREVIC:  For the transcript, it's on page 21, line 22.

15     Instead of "the minister," it says "the ministry."  It should read "the

16     ministry."

17             It seems to be that there is one more correction.  It should read

18     "Answer" instead of "Question."  This was not the question; this was the

19     answer.

20             JUDGE AGIUS:  When the mistakes are minor, let's leave them for

21     later.  You can see them with the -- otherwise, let's stick to

22     corrections that need to be made immediately; otherwise, one could get

23     complete misunderstanding of what is going on.

24             So let's proceed.

25             MR. LAZAREVIC:  Very well, Your Honour.

Page 26728

 1        Q.   [Interpretation] Mr. Bajagic, we were talking about paragraphs 1

 2     and 2 of Article 4, and you responded by saying that the ministry was

 3     considered part of the armed forces.

 4             Can you continue where you left off, and that is paragraph 2 of

 5     Article 4.

 6        A.   Paragraph 2 of Article 4 of this law says that the Ministry of

 7     the Interior is responsible and in charge of carrying out the orders of

 8     the president of the republic.

 9        Q.   In your opinion, what is the significance of these provisions?

10        A.   The Law on Internal Affair, or the law on the implementation of

11     this law, for the first time clearly defines the position of the ministry

12     at a time when a state is in an immediate threat of war or at war.  In

13     the basic law, the ministries for the first time defined as a part of the

14     armed forces of Republika Srpska.

15        Q.   Let's look now at article 5 of this law.

16             MR. LAZAREVIC: [Interpretation] It's on the same page in B/C/S,

17     and on pages 9 and 10 in English.

18        Q.   During your testimony, we already said that this defines the

19     measures that the ministry can undertake during an imminent threat of war

20     or the state of war.  How would you assess the powers vested in the MUP

21     compared to those in peacetime?

22        A.   I think that, yesterday, we said or discussed almost all of these

23     administrative actions envisaged by this law.  We even said how

24     completely different powers these are or whether some of these existed

25     before but were only amended and altered.

Page 26729

 1             But, in my judgement, it is only natural to see the expansion of

 2     powers of all participants in the security system, including the Ministry

 3     of the Interior, when it comes to an immediate threat of war or a state

 4     of war.

 5        Q.   Very well.  So far, we spoke about different laws and bylaws

 6     governing the position and the structure of the RS MUP.  In order for the

 7     Honourable Chamber to be able to follow better these issues, let us now

 8     look at a number of charts.  Let's first look at the one attached to your

 9     expert report, and it's tab 16 in your binder?

10             MR. LAZAREVIC: [Interpretation] That's chart 1A, and that's

11     4D448.

12        Q.   I think we have the right document both in e-court and before

13     you.  Can you please now explain this chart to me.  First of all, this is

14     a chart depicting the organisation of MUP of the Republika Srpska in

15     July 1995; is that correct?

16        A.   Yes, it is.

17        Q.   Let us now start with this top box which says "The Ministry of

18     Interior."  How is it being divided according to this chart?

19        A.   According to this chart, an attempt was made to portray the

20     organisation of MUP that existed in July in 1995, and that was according

21     to the laws in place at the time.  There are actually three levels of

22     organisation here.  As we can see on the right-hand side of this chart,

23     it says level 1, level 2, and level 3.

24             Level 1 implies how the ministry is organised within its very

25     seat which, conditionally speaking, has several global organisational

Page 26730

 1     segments.  In addition to the public security department and the state

 2     security department, on the left-hand side, you can also see a number of

 3     units.  That's the office of the minister, the service for public

 4     information, education centre, and the special police brigade.  Also,

 5     there is the finance administration and personnel administration.  These

 6     are organisational units that exist at the seat of the ministry.

 7             In addition to that, as you can see from the chart, there are

 8     individual administrations as organisational parts of the public security

 9     department, and I can enumerate them, if necessary.

10        Q.   Please go ahead.

11        A.   Within the public security department, there's the police

12     administration, the criminal investigation police administration,

13     the administration for analysis, IT, and automatic data processing, the

14     administration for communications and crypto protection, the

15     administration for legal affairs and aliens, and, finally, the

16     firefighting inspectorate and for technical prevention.

17        Q.   Let me just ask you this:  In this chart, you did not elaborate

18     any further the state security department; this is more to do with the

19     public security department.

20        A.   Yes.  As you can see, the line going from the Ministry of the

21     Interior goes to the public security department, and the state security

22     department was not the subject of my analysis, it was not in my remit.

23     That's why I put it like this, but I thought it was necessary to show it

24     that it was part of the Ministry of the Interior.

25        Q.   Okay.  We spoke now about level 1, and you said this refers to

Page 26731

 1     the seat of the ministry.  What is level 2 in your chart?

 2        A.   As we can see, level 2 after we mentioned the seat are actually

 3     regional organisational units of the MUP established on a territorial

 4     principle.  We have public security centres at the second level.  And in

 5     brackets in this chart, it just says that there were ten of them, one to

 6     ten.  And in the appendices you can find precisely which centres these

 7     were.  So this is as far as level 2 goes.

 8        Q.   Can you tell us something about level 3 now?

 9        A.   Concerning level 3, we can see that these are organisational

10     units of MUP at an even lower level and these are public security

11     stations.  In any case, there were more of them than the centres because

12     public security stations generally coincided with the territory of

13     municipals; therefore, we see this territorial principle.

14        Q.   Very well.  I think we have finished with this chart; and before

15     the break, can we please look at the next document.  I suppose we shall

16     have ample time to discuss it.  That's chart 1B attached to your report.

17     And as far as I understand, it derives from chart 1A.

18             MR. LAZAREVIC: [Interpretation] That's 4D449.

19        Q.   Tab 16 in your binder.

20        A.   Yes, I have it before me.

21        Q.   Just bear with me for a moment, we are awaiting for both versions

22     to appears in e-court.  Let me check if they are correct.  Yes, they are.

23     Can you explain now explain for the Trial Chamber what the sketches

24     represents.  I believe that it derives from the schematic 1A. Could you

25     please explain the schematic 1B that we have in front of us?

Page 26732

 1        A.   The schematic 1B which is in front of us is a derivative from the

 2     left part of the previous schematic.  In order to provide a more detailed

 3     explanation of the organisation of the Ministry of the Interior and its

 4     headquarters what it is envisaged to do under the law.  The Ministry of

 5     the Interior had two offices in Bijeljina and Pale.

 6             It says here that the Ministry of the Interior in the

 7     headquarters has a minister, a deputy minister, advisors, chiefs,

 8     directors and other organisational views, as well as the chief of the

 9     police force.

10        Q.   Could you please slow down a little.  We have problems with the

11     transcript?

12        A.   I apologise.

13        Q.   Can you please repeat what you just said?

14        A.   The Ministry of the Interior in its headquarters has minister; a

15     deputy minister; ministers advisors, five of them to be more precise;

16     chiefs of internal control inspectorate, one person; five chief

17     inspectors; and chief police force staff.

18        Q.   Can we move on please.

19        A.   Yes.

20             And, ultimately, in addition to that, the ministry in its

21     headquarters has the minister's office, public information service,

22     finance directorate, personnel directorate, and special police brigade,

23     which means that the left part of the first schematic has only been

24     enlarged in this schematic.  Nothing else.  We also see on the right-hand

25     side of this schematic only the titles of the public security department

Page 26733

 1     and the state security department in the squares?

 2        Q.   Very well.  Just one more question, please in this regard.  Here

 3     there's reference to the chief of police force staff.  Would that be the

 4     minister himself?

 5        A.   No.  It wouldn't be the minister of the interior, no.  This is

 6     just the position that exists and has been envisaged in the headquarters

 7     of the Ministry of the Interior.

 8             MR. LAZAREVIC:  Well, to develop further, and I don't believe

 9     we'll be able to finish with his answer in five minutes.  So maybe it's

10     time to have a break right now.

11             JUDGE AGIUS:  Okay.  We'll have a break now, 25 minutes.

12             How much longer do you think you will be?

13             MR. LAZAREVIC:  Well, I believe that I will take the rest of the

14     day, and, probably, I must say by looking at the way I'm progressing,

15     probably first session tomorrow.

16             JUDGE AGIUS:  So that will be in excess of the six hours that you

17     indicated.  Okay.

18             MR. LAZAREVIC:  Well, slightly.

19             JUDGE AGIUS:  Twenty-five minutes.

20                           --- Recess taken at 10.23 a.m.

21                           --- On resuming at 10.58 a.m.

22             JUDGE AGIUS:  Yes, let's resume.  Mr. Lazarevic.

23             MR. LAZAREVIC:  Thank you, Your Honour.

24        Q.   [Interpretation] Dr. Bajagic, we left it off considering the

25     schematic 4D449.  I would like to move on to the next schematic in your

Page 26734

 1     expert report to tab 16 on page 3.

 2             MR. LAZAREVIC: [Interpretation] It is 1C; and in e-court, it's

 3     4D450.

 4             THE WITNESS: [Interpretation] Yes.

 5             MR. LAZAREVIC: [Interpretation]

 6        Q.   It arises from the title of the scheme that this is the

 7     organisation of the Ministry of the Interior in its headquarters as it

 8     was in July 1995?

 9        A.   Yes.

10        Q.   Could you please give us your comment of this schematic?

11        A.   With regard to the previous schematic, this also provides the

12     schematic of the Ministry of the Interior of the Republika Srpska in

13     July 1995, with a special emphasis on the public security department and

14     again on the left side, the exclamation, i.e., the overview of the

15     organisational units that belong to the headquarters itself.

16             We can see that in the Ministry of the Interior, there is the

17     public security department with six squares depicting organisational

18     units of the public security departments -- or rather, administrations or

19     directorates.  I can go on and enumerate them.

20             Public security department has the following organisational

21     units:  Under 1, the police administration; under 2, the administration

22     of the crime prevention police; under 3, the administration for analysis

23     IT, and automatic processing, data processing; under 4, the

24     administration for communications and encryption; under 5, administration

25     for legal affairs and foreigners; and, finally, under 6, fire protection

Page 26735

 1     and technical protection directorate.

 2        Q.   I apologise.  There are two more directorates or administrations,

 3     but they are not within the public security department in your schematic.

 4     Why?

 5        A.   No.  Just like in the schematic that I entitled 1B, which is a

 6     different scheme from this one, I said that in addition to the ministers

 7     office, the information office, and special police brigade, the MUP in

 8     the headquarters also has the directorate for material and equipment -

 9     this is the square on the left-hand side - and the director for

10     personnel.  These do not belong to the public security department, but,

11     rather, to the Ministry of the Interior and its headquarters.

12        Q.    Obviously, in your schematic, we can also see that the special

13     brigade is also there.

14        A.   Yes.  You can see it in the schematic that the special police

15     brigade belongs to the Ministry of the Interior in its headquarters.

16        Q.   Thank you very much.  We will no long need in document.  Can we

17     now look at the following schematic that you have drafted and attached to

18     your expert report.  You will find it under tab 16 on page 4.

19             MR. LAZAREVIC: [Interpretation] This is 1D, schematic 1D; and in

20     e-court, it is 4D451.

21             [In English] We provided hard copies, just in order for everyone

22     to follow.

23             [Interpretation] Very well.  I believe we have both documents in

24     e-court, both in B/C/S and English.  They are identical.

25        Q.   Could you now please give us a brief outline of the

Page 26736

 1     organisational scheme of the public security department?

 2        A.   This schematic provides a detailed overview of the organisational

 3     structure of the public security department.  Immediately below the long

 4     square depicting the words "public security department," you can see

 5     listed the chief of public security department, his deputy and assistant,

 6     followed by chief inspector, as well as the technical personnel.  Let me

 7     not go through each and every one of them.

 8             And, also, within the management part of the public security

 9     department, we also have the duty service and finance section.  You will

10     find those on your left-hand side, the left-hand side of the page.

11        Q.   Very well then.  And, now, please, could you explain the second

12     row of squares?

13        A.   As we have already said it, the police directorate has six

14     particular directors.  We can see that the police directorate, which is

15     emphasized in bold; then criminal police directorate; analytics and

16     information directorate; communications and crypto-protection

17     directorate; legal and foreigners directorate; and fire protection and

18     technical prevention inspectorate.

19        Q.   We already had all those in the previous schematic.

20             MR. LAZAREVIC: [Interpretation] I should apologise.  We have been

21     warned that you are talking too fast.

22             THE WITNESS: [Interpretation] I apologise.  I will repeat.

23             The police directorate, criminal police directorate, analytics

24     and information directorate, communications and crypto-protection

25     directorate, legal and foreigners directorate, fire protection and

Page 26737

 1     technical protection inspectorate.

 2             MR. LAZAREVIC: [Interpretation]

 3        Q.   Very well.  And now I would kindly ask you to explain the further

 4     subdivision that you depict in the schematic?

 5        A.   As you can see in the schematic, a special emphasis has been

 6     placed on the police directorate.  It is in the bold square, and we can

 7     see how it is actually organised.  Immediately below the square, you can

 8     see that there are some key figures such as chief and his deputy, as well

 9     as the commander of special police units or PJPs.

10        Q.   In accordance with this schematic, therefore - and I believe that

11     it was based on the regulations that you analysed and that we have

12     already discussed - the commander of the special police units is attached

13     to the police directors?

14        A.   Yes.  And, of course, the schematic has been drafted based on the

15     laws and rules, i.e., bylaws that accompany those laws.

16        Q.   Very well.  Can you now please continue explaining the schematic

17     ever the police directorate?

18        A.   Yes.  The police director ate also has the following

19     organisational units:  Under 1, sector of state border affairs, general

20     police section, road traffic safety section, and defence affairs section.

21        Q.   Very well.  And just let's wrap it up, there is the general

22     police section here.  Could you please explain the two organisational

23     units underneath?

24        A.   Underneath, it is says that the general police section within the

25     police directorate, there is police station for securing persons and

Page 26738

 1     facilities for securing persons and the rail traffic safety police

 2     station.

 3        Q.   Very well.  I believe that we will no longer need this document,

 4     and I would like to call up the following schematic.  In your binder, you

 5     will find it on page 9, tab 16.

 6             MR. LAZAREVIC: [Interpretation] This is a schematic number 6 and

 7     the number of this exhibit is 4D456.

 8             THE WITNESS: [Interpretation] Yes.

 9             MR. LAZAREVIC: [Interpretation] I apologise.  I just wanted to

10     check that we have these documents in e-court -- actually, that we have

11     the corresponding B/C/S and English versions.

12        Q.   Can you tell me now, this chart represent the organisation of the

13     Zvornik Public Security Centre.  Can you tell me, first, what is the top

14     part of the chart represent?  What do these diagonal boxes represent?

15        A.   This is an organisational chart of one of the public security

16     centres, the one in Zvornik, which in view of the first chart that we saw

17     today belongs to the second level of organisation in the MUP.  We said

18     that there were ten public security centres and the Zvornik centre is

19     highlighted here in this bold box, and diagonally from it are the names

20     of other public security centres that existed at the time.

21        Q.   Can you just tell us what these centres were, their names?

22        A.   I will just read them from left to right, or from top to bottom.

23     That's Banja Luka, Bijeljina, Doboj, Drvar, Zvornik, Mrkonic Grad,

24     Prijedor, Sarajevo, Srbinje, and Trebinje Public Security Centres.

25        Q.   Let us now move on to the Zvornik Public Security Centre, and can

Page 26739

 1     you explain to us the organisational chart of this particular centre?

 2        A.   Here it goes.  In addition to its two executives, that is, the

 3     chief and the deputy chief of the Zvornik Public Security Centre, there

 4     are also seven departments and sections within the centre, and that

 5     applies to other centres as well.

 6             I'm going to name them from left to right:  Number 1 is police

 7     department; number 2 is crime prevention department; number 3,

 8     administration for personnel and foreigners; next to it is the fire

 9     protection section; number 5, communications and crypto-protection

10     department; number 6, analytics and automatic data processing department;

11     and number 5 [as interpreted], finance department.

12        Q.   Let me ask you this:  With regard to the police department as one

13     of the seven department within the Zvornik Public Security Centre, can

14     you tell us the positions listed in the box underneath?

15        A.   We can see that this has been specially highlighted here in this

16     box, that it has the police department chief within the public security

17     centre, the PJP commander, or the commander of special police units; and

18     these are probably these two subsections for defence preparation

19     organisation and mobilisation, and police work improvement and monitoring

20     subsection.

21        Q.   Very well.  Therefore, according to this chart, the PJP commander

22     at the Zvornik Public Security Centre is within the police department; is

23     that correct?

24        A.   Yes.

25        Q.   Let us now move on with further explanation of this chart.  The

Page 26740

 1     next, so to speak, lower level of organisation represents what?

 2        A.   I referred you to the first chart when I said that there were

 3     three levels, and the public security sections represent the third level

 4     of organisation and these are regional units.  Within the public security

 5     centre, there are, as we can see, five public security stations; namely,

 6     Bratunac, Vlasenici, Milici, Sekovici Public Security Stations, and the

 7     Skelani Police Station.  They are organised according to the territorial

 8     principle, and they are at a lower organisational level.

 9             And, of course, within the public security centre itself, there

10     are two police stations as part of their internal organisation.  These

11     are the Zvornik Police Station and the Road Safety Police Station of

12     Zvornik.  The Zvornik Police Station had general jurisdiction within the

13     centre.

14        Q.   Can I now ask you, please, to tell us the following:  In this

15     last box, which is made up of dotted lines, you made some comments about

16     the Zvornik Public Security Centre, PJPs.  Can you explain that in

17     detail?

18        A.   In light of the organisation and the area of responsibility [as

19     interpreted] of the PJP, and with regard to the second and third level of

20     organisational MUP, we see that the PJP units of the Zvornik centre are

21     made up of six companies.  That refers to all the public security

22     stations and police stations combined, and that each company is made up

23     of the personnel from all police stations or public security stations.

24             These are actually members of all police stations and public

25     security stations that gather together occasionally, and they constitute

Page 26741

 1     a provisional unit, and, in terms of formation, they constitute a

 2     separate unit.  They are actually a formation at the level of a public

 3     security centre.

 4             MR. LAZAREVIC:  [Previous translation continues] ... problem with

 5     transcript, I was just advised by my legal assistant.  It's page 34 and

 6     it's on line 7.  It speaks about the "area of responsibility" of the PJP.

 7     He was speaking -- he never actually mentioned any "zone of

 8     responsibility" of the PJP.  He was talking about "territorial principle"

 9     of establishing PJP, not the "zone of responsibility."

10             JUDGE AGIUS:  Thank you.

11             Do you confirm that, Professor?

12             THE WITNESS: [Interpretation] I can repeat.  The police stations

13     vis-a-vis the public security centre implies occasional gathering of

14     PJPs.  It stems from the territorial organisation of these two levels;

15     that is, public security stations, police stations, and public security

16     centres.

17             JUDGE AGIUS:  Okay.  Thank you.

18             MR. LAZAREVIC:  [Interpretation] Very well.  I think this is

19     clarified.  Perhaps the interpretation was somewhat ambiguous.

20        Q.   Let us now move on to a separate part of your expert report, and

21     it deals with the special police brigade --

22             JUDGE KWON:  Mr. Lazarevic, if you could ask the witness to

23     clarify the difference of SJB and PS in this schematic, police station

24     and public security station.

25             MR. LAZAREVIC:  Yes, Your Honour, I will gladly do that.

Page 26742

 1        Q.   [Interpretation] Mr. Bajagic, you have heard what Honourable

 2     Judge Kwon said.  Can you please explain the difference between public

 3     security stations and police stations according to your chart?

 4        A.   A public security station is at level three of the organisational

 5     chart of minister.  They are regional units set up on a territorial

 6     principle, and they are in charge of duties that involve such tasks as

 7     maintaining law and order, general jurisdiction of police like prevention

 8     of crime, et cetera.

 9             Police stations, however, are smaller in size than the public

10     security stations, and they are predominantly involved in general police

11     work.  These are uniform policemen discharging general duties and tasks.

12             MR. LAZAREVIC: [Interpretation] Just as an additional

13     clarification, I'm sorry, I can probably assist the Honourable Judge to

14     follow this better.

15        Q.   Let me ask you this:  Does this depend on whether we are talking

16     about municipalities or some smaller places?

17        A.   This refers to smaller places.  I can add this, and this will

18     help you make a distinction better:  Public security stations also have

19     subsections for administrative actions; whereas, police stations don't

20     have those.

21             JUDGE KWON:  Thank you.

22             MR. LAZAREVIC:  You are welcome.

23             THE INTERPRETER:  Could the witness please speak away from the

24     microphone.  He is too close for the interpreters.

25             MR. LAZAREVIC: [Interpretation]

Page 26743

 1        Q.   Mr. Bajagic, let us move on now to a separate section of your

 2     report that deals with the special police brigade or police, as it had

 3     been originally called --

 4             THE INTERPRETER:  Interpreter's correction:  Militia, as it had

 5     originally been called.

 6             MR. LAZAREVIC: [Interpretation]

 7        Q.   Explain, please, how the special police brigade of the Ministry

 8     of Interior of the Republika Srpska was established?

 9        A.   Within the Ministry of the Interior of the Socialist Republic of

10     Bosnia-Herzegovina --

11             MR. LAZAREVIC:  Obviously, this was not my question.  What I can

12     read --

13             JUDGE AGIUS:  [Overlapping speakers] ... explain how the ministry

14     of the Republika Srpska was established.

15             MR. LAZAREVIC:  No.  I was referencing to the special police

16     brigade of the MUP of Republika Srpska.  I mean, this is really something

17     that I asked the witness.

18             JUDGE AGIUS:  Thank you.

19             Professor, the interpreters have kindly asked you to keep away

20     from the microphone as much as you can because your voice is --

21             JUDGE KWON:  [Overlapping speakers] ... strong enough.

22             JUDGE AGIUS:  Yeah.  Thank you.

23             Mr. Lazarevic, you have put your question and the professor can

24     now answer it.

25             THE WITNESS: [Interpretation] I apologise.

Page 26744

 1             MR. LAZAREVIC: [Interpretation]

 2        Q.   Professor, could you please tell us about the beginnings of the

 3     special brigade of the MUP of Republika Srpska.  How did it come to be?

 4        A.   We have to bear in mind the fact that in the Ministry of the

 5     Interior of the Socialist Republic of Bosnia-Herzegovina, up to 1992,

 6     there was a similar unit and it was known as a special police detachment.

 7             When the ministry broke up and when the Ministry of the Interior

 8     first of the Serbian Republic Bosnia-Herzegovina and then of Republika

 9     Srpska were created and encompassed the pre-war special police

10     detachment, this would be the nucleus of the future special police

11     brigade, later to be known the special police brigade of the Republika

12     Srpska MUP.

13        Q.   All right.  Let us now look at the next document in your binder.

14     It's tab 17.

15             MR. LAZAREVIC: [Interpretation] In e-court, it's 4D523, and it's

16     a three-page document.  Let us look at page 1, please.

17             All right.  Now we have it in e-court, both B/C/S and English.

18        Q.   Can you tell me first in the upper left corner.  It's the Serbian

19     republic of Bosnia-Herzegovina, Ministry of the Interior, Sarajevo.  Can

20     you tell us what CSB means?

21        A.   Security services centre.  We know that from the acronyms, and

22     then it goes on to specify special unit, police squad [as interpreted].

23        Q.   Can you tell us what kind of document this is?

24             THE INTERPRETER:  Interpreter's correction:  It's not police

25     squad, it's police detachment.

Page 26745

 1             THE WITNESS: [Interpretation] This is a list of employees who

 2     were employees in May 1992 at the special unit of the police detachment.

 3     The list is for the down payment on salaries paid out for that month, and

 4     we see the names of the members of that unit.

 5             MR. LAZAREVIC: [Interpretation] Can we look at the last page of

 6     this document both in B/C/S and in English.

 7             THE WITNESS: [Interpretation] Yes.

 8             MR. LAZAREVIC: [Interpretation]

 9        Q.   Can you tell me the total number of members of the special unit

10     as it was then?

11        A.   We see it was 170 members of the special police detachment.

12        Q.   From all the documents and information that you had at your

13     disposal in writing your expert report, would you say that this number

14     increased during the war in Bosnia from 1992 through 1995?

15        A.   Of course, it increased, also, in view of the changed position

16     and responsibilities and duties that were assigned to the special police,

17     in view of the complexity of their work, the needs that arose, the number

18     of members gradually increased.

19        Q.   In order to better understand the legislative framework in which

20     the special police brigade operated, I'd like to go through various rule

21     books and regulations that governed the powers and responsibilities of

22     the special police brigade within the MUP of Republika Srpska.

23             MR. LAZAREVIC: [Interpretation] We have already had occasion, and

24     I'd only like to remind the Chamber of the Law on Internal Affairs,

25     4D172; and the organisation of the ministry in immediate threat of war

Page 26746

 1     and state of war dated September 1992, that's 4D192.

 2        Q.   These laws envisaged the special brigade as part of the ministry

 3     in its seat.  It was also in the centre of public security as we saw in

 4     your organogram.  In your tab 10, you will find the document I want to

 5     look at now.

 6             MR. LAZAREVIC: [Interpretation] It's 4D192, Article 23.  It's

 7     page 10 in B/C/S, and the pages that are important in English are 7

 8     and 8; in fact, page 8 in e-court, the very beginning.

 9             [In English] I apologise.  It's not in e-court, it's in the draft

10     translation that we provided.  It showed up in the e-court.

11        Q.   [Interpretation] We are now looking at the beginning of

12     Article 23, item 1, where it says "special police brigade."

13        A.   Yes.

14        Q.   It's best to proceed this way:  What were the responsibilities

15     and duties of the special police brigade?

16        A.   Pursuant to Article 23 of these rules, item 1, the special police

17     brigade performs the following duties and tasks:  1, detection,

18     apprehension, and liquidation of sabotage terrorist groups and

19     individuals; 2, restoring law and order after serious violations and

20     disturbances; 3, providing physical security to designated persons and

21     facilities; 4, participating in the adoption and implementation of the

22     defence plan of the ministry in its seat; 5, performing defence

23     preparations of the combat complement of the brigade; 6, performing

24     professional training of brigade members; 7, monitoring and proposing the

25     equipment of the brigade with materiel and equipment; and, 8, keeping the

Page 26747

 1     records that are envisaged; and, 9, performing other duties and

 2     responsibilities ordered to it.

 3        Q.   When it says here "performing other duties pursuant to orders in

 4     view of the war in Bosnia," what are these other duties?

 5        A.   When analysing the entire legislative framework and the bylaws

 6     governing the responsibilities and powers of the special police brigade,

 7     and bearing in mind the events especially in the state of war, it was my

 8     judgement that this means participation in combat activities.

 9        Q.   Just one more question in this regard:  Having reviewed all these

10     tasks and having told us that this is also a reference to performing

11     combat activities, which aspect of activity was dominant for the special

12     police brigade, especially during the war in Bosnia?

13        A.   We see from this a list of tasks of the special police brigade,

14     detection, apprehension, et cetera; but, certainly, participation in

15     combat activities became one of the dominant duties of the special police

16     brigade over time.

17        Q.   Very well.  I'd like to move on to the next document, please.  In

18     your binder, it's tab 16, page 5.

19             MR. LAZAREVIC: [Interpretation]  It's 4D452.

20        Q.   I am sorry.  I'll put my question to you.  I'm just waiting for

21     the document in e-court.  Do you have it in front of you now?  It's the

22     organogram of the special police brigade.

23             We've just discussed the rule on the internal organisation of the

24     MUP in immediate threat of war, circumstances in the state of war dating

25     back to 1993, and now I'd like you to explain about the structure of the

Page 26748

 1     special police brigade under the new rules.

 2        A.   May I begin now?

 3        Q.   Go ahead.

 4        A.   The special police brigade, under the rules in effect at the

 5     time, had a command within which, as we see on the left-hand side, there

 6     was a company for dealing with special jobs, a company for securing

 7     facilities, and a logistical unit.

 8        Q.   May I just put a few questions to you.  What were the tasks of

 9     the company for special or extraordinary tasks?

10        A.   Those were peculiar tasks and affairs, as stated here, concerning

11     the special police brigade, combat against sabotage terrorist groups and

12     so on, establishing special regimen of traffic around specially protected

13     installations, et cetera.  That's one of the basic tasks.  I stated that

14     in greater detail in my report.  I'm trying to find it now.

15        Q.   I don't want to dwell on it too long --

16        A.   Hostage situations, aircraft hijackings, really special or

17     specialised tasks that concern the special police brigade.

18        Q.   I'd look to look at the right-hand side of your organogram where

19     it states "police detachments."

20        A.   Yes.  That's the other part of the organisational structure of

21     the special police brigade, and we can see that these are police

22     detachments of which there were five at the time under those rules.

23     Those were Banja Luka, Bijeljina, Doboj, Sarajevo, and Trebinje

24     Detachments.

25             MR. LAZAREVIC:  Just for Your Honours' information, this

Page 26749

 1     schematic was made pursuant to 4D519, for which we don't have a

 2     translation, so we haven't used it in the course of the examination.  But

 3     as soon as the translation of this document arrives, it will be available

 4     in e-court.

 5        Q.   [Interpretation] In your report, para 130 of your report --

 6             MR. LAZAREVIC: [Interpretation] It's 4D499; page 39 in e-court in

 7     B/C/S, and page 40 in English.

 8        Q.   -- I read that the seats or basis of the special detachments of

 9     the police coincided with the security services centre.  Did this fact

10     affect command and management jurisdiction in any way?  Could these

11     special police detachments be commanded, for instance, by the chief of

12     the security services centre, for instance?

13        A.   No.  All police detachments which belong, as we know, to the

14     special police brigade, were directly subordinated to the command of the

15     special police brigade; thus, the chief of the security service centre,

16     or the public security centre, could not give any orders or have any

17     relation of superiority towards the police detachments.

18        Q.   All right.  Now I'd only like to sum up briefly because we've

19     already had occasion to analyse the law amending the Law on Internal

20     Affairs, dated 30th December 1993.  We've spoken about it.  It was 4D207

21     in tab 12.  We talked about the renaming of the services into public

22     security sector and state security sector, and the renaming of "milicija"

23     into "policija."  At that time as far as the special police brigade is

24     concerned, did that law bring any other change except for the name?

25        A.   No, not at that time.  A change did occur, but later.

Page 26750

 1        Q.   Fine.  Now I'd like to show you another document.  In your binder

 2     it's tab 18, and it's the rules on the job specification within the

 3     Ministry of the Interior, dated 5 October 1994.

 4             MR. LAZAREVIC: [Interpretation]  And in e-court, it's page 5 in

 5     B/C/S, in page 2 in English.  This is an unofficial translation that

 6     we've been able to provide.  Let us look at Article 2.

 7        Q.   I am sorry.  I didn't mention it before, but it's your page 5.

 8     Just above that -- sorry.  Just below that is Article 3.

 9        A.   Yes.

10             MR. LAZAREVIC:  4D145.  It's page 3 in the e-court in English.

11        Q.   [Interpretation] Do you have that before you?

12        A.   Yes.

13        Q.   Do you see the title, "Special Police Brigade"?

14        A.   Yes, I do.

15        Q.   Can you please explain the definitions of this provision?

16        A.   This provision of Article 2 defines the activities and tasks for

17     which the special police brigade is in charge, and they are listed.

18        Q.   Very well.  I'm interested in the second paragraph within the

19     subtitle "Special Police Brigade."  Look at the second paragraph where it

20     says:  "In it's composition," and so on and so forth.

21        A.   Yes.  I can see it.  It says here:  "In its composition, the

22     special police brigade contains a command of the brigade and special

23     police detachments," and a list of six is given -- actually, seven

24     special police detachments are listed.  In other words, the number is

25     increased by two with respect to the original organisation.  This is the

Page 26751

 1     kind of change that happened.

 2        Q.   Very well.  And now I would just like to show something else

 3     which is not that important, but, still, I would like to show some other

 4     relevant parts of this paragraph.

 5             MR. LAZAREVIC: [Interpretation] Let's look at the job

 6     specification, which is on pages 11 through 13 and page 8 in the English

 7     version in e-court, and also page 9 of the English version.

 8        Q.   Let us just say that different positions in the brigade are

 9     mentioned here.

10        A.   Yes.

11        Q.   And pages 13 to 17 refer to the job specification of jobs in the

12     special police detachment; wouldn't that be correct?

13        A.   Yes.  We can see that this is a list or job specification both in

14     the brigade command as well as in the detachments.

15        Q.   Very well.  We will not dwell upon this document because it's

16     rather self-explanatory.  What I'd like to look at now is tab 16 in your

17     expert report, which is your page 6, schematic number 3.

18             MR. LAZAREVIC: [Interpretation] and in e-court, it is 4D453.

19     Very well.  We have both pages on the screen, both in B/C/S and in

20     English.

21        Q.   Let me ask you this:  This is the organisation of the special

22     police brigade, in keeping in the rules dated 5 October 1994, the rules

23     that we have just looked at together.  And you have told us that it was

24     part of the police administration or police directorate and the public

25     security sector; wouldn't that be correct?

Page 26752

 1        A.   Yes.

 2        Q.   Can you now help us to understand this schematic better.  Could

 3     you please tell us what we can see on the left-hand side of the

 4     schematic?

 5        A.   We can see the whole schematic of the special police brigade

 6     organisation.  On the left-hand side, you can see the command in the

 7     large square with all the personnel and officials that make up such a

 8     command.

 9             In keeping with the law and rules, these people are or these

10     officials are commander, deputy commander, assistant commander for

11     operational tasks, assistant commander for intelligence and security,

12     assistant commander for operational work and teaching, assistant

13     commander for logistics, head of communications, and other professionals

14     and technical staff that belong to the staff according to the job

15     specification of the command.

16        Q.   In order to help us understand this schematic better, there are

17     three more rectangular areas that are attached to the command.  Can you

18     please explain?

19        A.   Yes.  These represent, first, the teaching and instruction team

20     on the two logistical support team; and under 3, communication or signal

21     section.

22        Q.   Very well then.  Now I would kindly ask you to explain for us the

23     right-hand part of this schematic.  The title is "Special Police

24     Detachments."

25        A.   According to the rules that were in effect at the time, special

Page 26753

 1     police detachments were as follows:  Sarajevo, Sekovici, Bilice,

 2     Bijeljina, Doboj, Banja Luka, and Prijedor.  At that moment, the special

 3     police brigade had seven special police detachments.

 4        Q.   Very well.  I believe that we will no longer need this document.

 5     I would like us to look at the document under tab 19 in your binder.

 6             MR. LAZAREVIC: [Interpretation] This document is P54.

 7        Q.   While we are waiting for the document to appear in e-court, maybe

 8     we could just briefly analyse it.  Could you please tell us, in the left

 9     upper corner, it says:  "Republika Srpska, Minister of the Interior,

10     Special Police Brigade, Bijeljina" and the date is 20 February 1995.

11             Could you please tell us, under RE, what is the document about?

12        A.   The special police brigade in this document addresses the top of

13     the Ministry of the Interior, and provides comments under rules on the

14     job specification in the Republika Srpska MUP with regard to the special

15     police brigade.

16        Q.   We will not dwell upon too long on the document; it will be

17     further analysed through another schematic.  However, based on this

18     document, would you be able to tell us it depicts more aspects that are

19     depicted in the job specification; isn't that correct?

20        A.   The command of the special police brigade informs the Ministry of

21     the Interior about the mistakes and omissions in the book of rules that

22     had already been passed, and provides a clear guidelines how things

23     should look in the book of rules with regard to the actual situation on

24     the ground.  In view of that --

25        Q.   I apologise for interrupting you --

Page 26754

 1        A.   In view of that, we can see that nine special police detachments

 2     are mentioned in this document, as opposed to what we have just seen as

 3     the existence of seven different police detachments, which I can list.

 4        Q.   No, that will not be necessary.  We will look at the schematic

 5     that you prepared, and I believe that it will provide a good explanation

 6     of the reasons for this mistake.

 7             It is your binder tab 16, page 7?

 8             MR. LAZAREVIC: [Interpretation] And in e-court, it is 4D454, or

 9     document number 4.

10        Q.   This is the schematic of the organisation of the special police

11     brigade that was in place in July 1995.  We can see it in your schematic.

12     It was drafted based on the comments provided on the 20th of February

13     1995, which is precisely the document that we have just seen in e-court;

14     wouldn't that be correct.

15        A.   Yes.

16        Q.   Could you please explain the schematic that we are looking at, at

17     the moment?

18        A.   Just like the previous schematic, this one also depicts, on the

19     left-hand side, the composition of the special police brigade command,

20     starting with the commander to the technical and professional staff, as

21     well as the three units that belong to the command:  Education and

22     structure, communication section, logistics platoon.

23             Obviously, in the centre, or to the right-hand side, with regard

24     to what we have just mentioned, we can see the list of the then-existing

25     special police brigade detachments.

Page 26755

 1        Q.   Can you please answer --

 2        A.   What is listed --

 3        Q.   I apologise.

 4        A.   The special detachments that are listed are or Jahorina,

 5     Sekovici, Bilice, Bijeljina, Doboj, Banja Luka, Prijedor, Ilidza, and

 6     Srbinje.

 7        Q.   Very well.

 8        A.   And as I have listed them, that was numerical denotation,

 9     starting with Jahorina being the first special detachment, to Srbinje

10     being the ninth special detachment.

11        Q.   From 1 to 9?

12        A.   Yes, from 1 to 9.

13        Q.   Very well.  Now I would like us to look at the following

14     schematic, which is attached to the expert report.  It is page 8 under

15     tab 16.

16             MR. LAZAREVIC: [Interpretation] It is schematic number 5.  The

17     Exhibit number in e-court is 4D455.  We believe that we have the document

18     in e-court in both languages.

19        Q.   I would just like to clarify this schematic.  This is the

20     organisation of a specific police detachment which was in place in

21     July 1995, pursuant to the Rule 108 1/94 that we have already discussed.

22     In other words, this the schematic of the special police detachment, as

23     posed to the previous schematic that depicted the organisation of the

24     special police brigade?

25        A.   Yes.

Page 26756

 1        Q.   Tell me, please, what is on the left-hand side of this schematic?

 2        A.   This is the schematic of the special police detachment with the

 3     structure of the command of the special police detachment on the

 4     left-hand side of the schematic.  The command is supposed of the

 5     commander, the deputy commander, an assistant for intelligence and

 6     security, a logistics assistant, as well as the communications squad.

 7        Q.   Very well.  You have also provided us with the direct line of

 8     communication [as interpreted] leading from the command rightwards

 9     towards the platoons?

10        A.   Yes.  The special police detachment has four platoons which are

11     also known as special platoons:  A special platoon, a mechanized armour

12     platoon, a fire support platoon, and a logistics support platoon.

13        Q.   Very well.  I apologise.  I will interrupt you just for a moment

14     in order to correct something in the transcript.

15             MR. LAZAREVIC: [Interpretation] There is an error that should be

16     taken care of immediately.

17             [In English] On page 48, it's line 16.  It's "line of command,"

18     instead of "line of communication."

19             JUDGE AGIUS:  Thank you, Mr. Lazarevic.

20             MR. LAZAREVIC:

21        Q.   [Interpretation] I apologise, Professor.  Let's go back to where

22     I interrupted you.  Could you please tell us about the platoons.  Could

23     you please repeat the names of the platoons within a special police

24     detachment?

25        A.   As I already told you, there were four platoons.  We can see

Page 26757

 1     semi-circle lines because every platoon has a commander, and circular

 2     arrows or curved arrows point to the first, second, and third squad of

 3     the special platoon.  Within the mechanised armoured platoon, there are

 4     four squads in total.  Within the fire support platoon, there are three

 5     squads.  And, finally, the logistics support platoon has three squad and

 6     a service squad or department that was support to that platoon.

 7        Q.   In order to finalise this subject relating to the special police

 8     brigade, one question more before we move to the PJPs:  Tell me, in 1995,

 9     did the special police brigade have a staff of its own?

10        A.   No, it didn't.  As we can see from all the charts and what is

11     stipulated by the law and the set of rules, the special police brigade,

12     or the SPB, had a command, and we saw who the members of the commands

13     were, and it had detachments.  There was no staff within the SPB.

14        Q.   Thank you very much.  I'm sorry.  Are you feeling well?

15        A.   Everything is all right.

16             JUDGE KWON:  Everything is okay.  Can I see the 65 ter 4D454

17     again.  I wanted to ask this question because the witness said that in

18     relation to the previous schematic, 453, which depicts the system in

19     1994, he said that at that time special police brigade was within the

20     police directorate within this public security department; but by this

21     time, by 1995, the special police brigade has become subordinated

22     directly to the MUP.  I wanted to be clear about this.

23             MR. LAZAREVIC:  By all means, Your Honour.  I will try to clarify

24     this.  Can we have 4D450.

25        Q.   [Interpretation] Mr. Bajagic, in order to remove any dilemmas

Page 26758

 1     from our mind, in this chart that we saw before, this represents the

 2     organisational chart existing in July 1995; and on the left-hand side --

 3     I'm sorry.  This is 1C in your report, 450.

 4        A.   I can see it.

 5        Q.   In accordance with this chart, the SPB is directly in the office

 6     of the minister; is that correct?

 7        A.   Yes.  In July 1995, the SPB belonged to the office of the

 8     minister at the ministry headquarters.  It was not within the public

 9     security department and police administration.  That was the situation

10     that is existed before.

11        Q.   Therefore it was directly subordinated to the minister?

12        A.   Yes.  The SPB was directly subordinated to the Ministry of the

13     Interior.

14             JUDGE KWON:  Thank you.

15             MR. LAZAREVIC:  By all means.

16             JUDGE AGIUS:  Thank you, Judge Kwon, and thank you, Mr. Lazarevic

17     and Professor.

18             Let's go on.

19             MR. LAZAREVIC: [Interpretation]

20        Q.   Mr. Bajagic, let us now move on to the subject of PJPs.  In your

21     report, you have cited as a legal basis for the establishment of PJP

22     Articles 24, 31 -- and 31 of the Law on Internal Affairs of the 15th of

23     April 1992.  This is 4D212.  That's document number 1 in your binder.

24             First of all, let us look at Article 31 of this law.

25             MR. LAZAREVIC: [Interpretation] That's on page 4 of the B/C/S

Page 26759

 1     version and on page 8 of the English version.

 2             THE WITNESS: [Interpretation] I'm sorry.

 3             MR. LAZAREVIC: [Interpretation]

 4        Q.   I am sorry, tab 1.  Do you have it before you?

 5        A.   Yes.

 6        Q.   So, in Article number 31, if we look at the first paragraph of

 7     this article, I don't want to go into a detailed analysis, but what I

 8     would like to note about this first paragraph is that I would like to

 9     hear who is authorised to engage the PJPs for a specific task and duties?

10        A.   Pursuant to Article 31, if the interest of public order and

11     security demands so, the minister shall demand the formation of

12     certain -- of police units made up of members of other sections.  That is

13     what I mentioned in paragraph 142 of my expert report.  That was one of

14     the legal bases for establishing the PJPs.

15        Q.   Thank you very much.  Can we now look at the exhibit that we've

16     already seen at your tab number 14.  That's the rules on internal

17     organisation of MUP, dated the 1st of April 1994.  I'm specifically

18     interested in Rule 10 of these rules.

19             MR. LAZAREVIC: [Interpretation] That's Exhibit 4D144; page 9 in

20     e-court in B/C/S, and page 3 in English.  This is the translation

21     provided by the defence since we haven't yet received an official

22     translation from the CLSS.

23        Q.   Can you see Article 10 before you?

24        A.   Yes, I can.

25        Q.   Let's look at what it lays down and stipulates.  Tell us exactly

Page 26760

 1     what precisely this article provides for, and let's begin with

 2     paragraph 1.

 3        A.   Paragraph 1 of Article 10 says that public security centres and

 4     public security stations for the purpose of neutralizing sabotage and

 5     terrorist groups and for participating in combat activities, when

 6     necessitated, special police units will be established made up of active

 7     duty policemen from the wartime structure.

 8        Q.   Pursuant to paragraph 2 of this Article 10, who is the one to

 9     decide the strengths and the composition of PJP units?

10        A.   It is to be decided by the Minister of the Interior.  He is

11     responsible on the basis of a special or separate decision as it is

12     stipulated in paragraph 2.

13        Q.   According to this article, the PJP is made by active duty

14     policemen and wartime formation --

15             MR. LAZAREVIC: [Interpretation] Article 15 on pages 10 and 11 in

16     B/C/S -- I apologise.  That's in e-court on page 10 and in the English

17     version it is on page 3 -- or rather 4.

18        Q.   Let's look at the last paragraph of Article 15.  Can you see it?

19        A.   Yes, I can.

20        Q.   We can also see here somewhere in the middle of this --

21             THE INTERPRETER:  Interpreters would kindly ask the counsel to

22     slow down, please.

23             MR. LAZAREVIC: [Interpretation] Let's move on to Article 47 of

24     this book of rules.  This is page 34 in e-court, page 5 in the English

25     translation.

Page 26761

 1        Q.   Do you see Article 47 in front of you?

 2        A.   Yes.

 3        Q.   Let's now look at paragraph 2 -- or rather, paragraph 1, which

 4     should be paragraph 2 of Article 47, which starts with special units.

 5     Could you please tell us what you see written in there?

 6        A.   It says here that special police units are commanded by the

 7     commander of the unit in the centre, and the commander of the special MUP

 8     units is in command of the joint units.  Do you need any further

 9     explanation?

10        Q.   I believe that this regulation that we have just quoted is

11     self-explanatory, and there's no need for any further elaboration.

12             Let's just round the thing off.  Let's look at the law on the

13     implementation of the Law on the Interior in the situations of the threat

14     of war or imminent threat of war.  We have already seen this document.

15     This is under tab 15.

16             MR. LAZAREVIC: [Interpretation] The Exhibit number is 4D413.  The

17     page that we are looking for is 4 in B/C/S and page 12 in English.

18        Q.   Do you see Article 12 in this law, please?

19        A.   Yes.

20        Q.   Could you please specify what this article defines?

21        A.   Article 12 defines or sets out that the Minister of the Interior

22     shall establish special police units, in addition to the special police

23     brigade, to carry out combat tasks.

24        Q.   And the primary reason that is mentioned here are combat tasks?

25        A.   Yes, the article is clear enough in that respect.

Page 26762

 1             MR. LAZAREVIC:  Is this a convenient moment to break because I'm

 2     going to another set of documents.

 3             JUDGE AGIUS:  Sure.  Let's have a 25 minute break.  Thank you.

 4                           --- Break taken at 12.24 p.m.

 5                           --- On resuming at 12.52 p.m.

 6             JUDGE AGIUS:  Yes, Mr. Lazarevic, and we need to accelerate a

 7     bit.

 8             MR. LAZAREVIC:  I'll do my best, Your Honour.  However, I was

 9     also advised by the Prosecution that they will reduce their

10     cross-examination because so far they don't see reason for four hours of

11     cross-examination.  So we'll be on schedule, I can assure you this.

12             JUDGE AGIUS:  But that should be indicative as to why I'm telling

13     you to accelerate.

14             MR. LAZAREVIC: [Interpretation]

15        Q.   Dr. Bajagic, let's move to the documents that follow.  In your

16     tab 21, there's Exhibit 4D213, the order to establish PJP, dated

17     12 September 1994.

18        A.   Yes.

19        Q.   Following the instructions of the president of the Chamber, I'd

20     like to make a few points relative to this document.  Let's look at

21     item 4 of this order.  Can you tell us within whose jurisdiction --

22        A.   Item 4 says that it's the Minister of the Interior, or his

23     deputy, are authorised to approve the use of PJP.

24        Q.   Can we turn to page 2 of this document.  It's item 6.  Tell us,

25     what does it say?

Page 26763

 1        A.   Item 6 says that members of the PJP, when not engaged in the

 2     execution of combat tasks, shall perform their regular duties as an

 3     organisational unit of the MUP.

 4        Q.   Let us look at this attachment to the order to establish PJP.

 5     It's document under tab 22, and it's 4D214.

 6             MR. LAZAREVIC:  Can we have the next page of this document,

 7     excuse me.  First, I would like to see page number 2 and then page

 8     number 1.

 9        Q.   [Interpretation] Dr. Bajagic, we have the document on the screen

10     now, but I'd like to make sure that you have the same document before

11     you.  It's an organogram where it says "PJP, 5712."

12        A.   Yes, I do have it.

13        Q.   This organogram was attached to the document we looked at

14     previously.  Can you tell us, really very briefly, how is the structure

15     of the PJP shown here?

16        A.   It's the overall organisation of PJP.  It shows there are four

17     brigades of special units of the police, and it shows the structure of

18     the brigades themselves, how many battalions they have, together with

19     their sections of support and communications.

20        Q.   I won't spend much time on this document.  Can we now see page 1

21     of the same document.  It's also an organogram.

22        A.   Yes.

23        Q.   We can't see all of it on the screen.  It's the structure of PJP

24     Zvornik.  Just tell us about the structure as shown here?

25        A.   This is a detailed schematic of the PJP Zvornik with its command,

Page 26764

 1     and we see that PJP Zvornik had four companies, one support platoon, and

 2     one communication section; and then we see the breakdown of various

 3     companies with their commands and platoons.

 4        Q.   All right.  I think we are finished with this document.  We don't

 5     need to go into details.  Let us look at the next document related to the

 6     previous one.

 7             In 4D213, it said that the way -- the manner of usage shall be

 8     prescribed by a separate instruction, and this now is the instruction on

 9     the establishment of the PJP, tab 23.

10             MR. LAZAREVIC: [Interpretation] As I've already said, it's the

11     instruction on the establishment and use of PJP, dated 12 September 1994,

12     4D215.

13             THE WITNESS: [Interpretation] I have it.

14             MR. LAZAREVIC: [Interpretation]

15        Q.   Let's wait for it to be called up in e-court.

16             Let us look at the subheading (a), the Establishment of PJP.  How

17     does the document defined?  How shall PJP be established?

18        A.   It says:  "PJP shall be formed from the combat complement of the

19     Ministry of the Interior."  It defines the criteria and the requirements

20     for members and certain other matters, such as levels of responsibility

21     within the PJP.

22        Q.   Fine.  Let us look at subheading(b) where it says "Use of the

23     PJP."  What does paragraph 1 stipulate?

24        A.   Paragraph 1 stipulates that orders to use PJP shall be given

25     through the PJP commander by the Minister of the Interior or his deputy.

Page 26765

 1        Q.   What about paragraph 2?  It is concerns the use of PJP.  Can you

 2     tell us how this instruction defines it?

 3        A.   Two tasks of the PJP are defined here in detail.  It says:  "The

 4     PJP will be used for the execution of combat tasks and complex police

 5     duties within the scope of MUP activities."

 6        Q.   So the PJP is not used exclusively for combat?

 7        A.   No.  You can see it from this document and from reality, complex

 8     police tasks from the jurisdiction of the MUP imply what they imply, and

 9     they do not mean combat activities.

10        Q.   Thank you.  Can we just look at the next page of this document,

11     the second paragraph.  What powers are given to the chief of the public

12     security centre?

13        A.   The chief of the public security centre may allow the use of PJP

14     at the level of his open centre, if so required by the circumstances, and

15     if the situation and the timing does not allow any consultation with the

16     minister.  That means in situations that qualify as emergency.

17        Q.   Now let us look at what the procedure for using PJP was like in

18     practice.  I would like to look at P13 [sic].  In your binder, it's tab

19     69.  In the second binder, it's tab 69.

20             MR. LAZAREVIC:  That's not the right document.  I apologise.

21             It's P31.  Sorry.  Yes, that's the right one.

22        Q.   [Interpretation] To speed things up, I'll say what this document

23     is about.  It's a dispatch from the Main Staff of the Army of Republika

24     Srpska, the intelligence and security sector.  The date is 19 March 1995,

25     and the author of this document is indicated as assistant commander,

Page 26766

 1     Major-General Zdravko Tolimir.  The subject of the document is indicated

 2     as "The establishment of the security system and control of the

 3     territory."

 4             I had like to go through the important points of this document.

 5     Let us look at the addressee.

 6        A.   This dispatch was sent to the president of Republika Srpska,

 7     first; to the Ministry of the Interior; and to the state security sector;

 8     and the command of the Drina Corps, for their information.

 9        Q.   Let us look at paragraph 3.  It begins somewhere halfway through

10     the paragraphs with the words "We hereby propose ..."

11             Obviously, it is proposed to use MUP units and it goes from the

12     Main Staff to the president of the republic, and it defines the proposed

13     tasks for the MUP units.

14        A.   That's correct.

15        Q.   Thank you.

16             MR. LAZAREVIC: [Interpretation] We won't be needing this document

17     anymore.  Let us look at the next document.  It's 4D --

18             THE INTERPRETER:  Could counsel repeat which 4D exhibit?

19             JUDGE AGIUS:  Yes.  The interpreters need you to repeat which 4D

20     document you are referring to.

21             MR. LAZAREVIC:  It's 4DP6.

22             JUDGE AGIUS:  Thank you.

23             MR. LAZAREVIC: [Interpretation]

24        Q.   Mr. Bajagic, this is an order from the president of the republic,

25     Radovan Karadzic.  The date a 21st of March 1995.  Can you tell us what

Page 26767

 1     is the order?

 2        A.   As we can see from the text, the president of the republic,

 3     pursuant to the constitution and the laws, orders that with a view to

 4     establishing a regimen of security and control in a given area of the

 5     territory, the possibility be considered of stationing certain units in

 6     Konjevic Polje.

 7        Q.   In your opinion, is this document related to the previous one we

 8     looked at?

 9        A.   Certainly.  The previous document was dated 19 March 1995, and

10     this one is dated 21st March 1995.

11        Q.   The next document I'd like us to look at is document 4DP7.  It's

12     in your tab 25.

13        A.   [No interpretation]

14             JUDGE AGIUS:  Yes.  We are not receiving any interpretation, at

15     least I'm not and Judge Prost isn't either.

16             MR. LAZAREVIC: [Interpretation]

17        Q.   Mr. Bajagic, there seems to be a technical problem with the

18     interpretation.  It's fine now.

19             JUDGE AGIUS:  Mr. Lazarevic, it's fixed.

20             Go to line 9, and what we have in the transcript is:  "The next

21     document I'd like to look at is document 4DP7.  It's in your tab 25."

22             That's where the translation stopped, so you can go ahead from

23     there.

24             MR. LAZAREVIC:  Yes, Your Honour.

25        Q.   [Interpretation] So, this is a document signed by the Minister of

Page 26768

 1     the Interior, Zivko Rakic.  It's sent to the President of the Republika

 2     Srpska, Dr Radovan Karadzic.  The date we see is 23 March 1995, and it

 3     references the telegram of 21st March 1995.

 4             What does this document say?

 5        A.   This document as we can see says that the Minister of the

 6     Interior had followed the order of the president of Republika Srpska, and

 7     they inform him that they had sent the 2nd Company of the PJP to the

 8     designated area from the public security centre of Zvornik, in order to

 9     establish a security regime in control of the territory over the

10     uninhabited parts of the territory, rather.

11        Q.   Do you see any relationship between this and the previous two

12     documents?

13        A.   Certainly.

14        Q.   Let us look at the next document.  It's in your tab 70.

15             MR. LAZAREVIC: [Interpretation] It's P8 in e-court.

16             THE WITNESS: [Interpretation] Yes.

17             MR. LAZAREVIC: [Interpretation]

18        Q.   There it is.  To speed things up a little, I will analyse this

19     briefly myself.  This is an order that the Supreme Commander of the armed

20     forces of Republika Srpska, President Karadzic, sent on the 22nd

21     April 1995 to the Main Staff of the Army of Republika Srpska and to the

22     MUP of Republika Srpska.

23             Let us just see.  In the first paragraph, below the words "I

24     hereby order..." what kind of information did President Karadzic have?

25        A.   In the first paragraph of this order, it says that:  "The Main

Page 26769

 1     Staff of the army must in the future define more precisely and more

 2     specifically requests for engagement and use of MUP units in keeping with

 3     the provisions of the law."

 4             And in the second paragraph, it says that:  "The MUP is required

 5     when sending MUP units into combat as part of the Army of Republika

 6     Srpska to regulate precisely the responsibilities of the commanding

 7     officers and commanders when they are resubordinated to the VRS unit

 8     commander."

 9        Q.   And the last document on this topic is in tab -- under tab 71 in

10     your binder.

11             MR. LAZAREVIC: [Interpretation] It's 4D261.

12        Q.   Have you got it?

13        A.   Yes.

14        Q.   We have it on the screen now.

15             This was sent from the Main Staff of the VRS on the 23rd of April

16     1995.  It was signed, as we can see on page 2, by Chief of Staff

17     Colonel-General Milan Milovanovic.  It was sent to the command of the

18     first and 2nd Krajina Corps, Sarajevo Romanija corps, the East Bosnian

19     Corps, the Herzegovina Corps, and the Drina Corps.

20             And since this document contains practically the entire previous

21     document that had been are forwarded to the previous corps, I'd like to

22     look at page 2, the last paragraph.

23        A.   Yes.

24        Q.   What is written in that last paragraph?

25        A.   Bearing in mind the entire text of this order, where it says in

Page 26770

 1     the beginning, with a view to overcoming certain problems and dilemmas,

 2     the last paragraph says:  In the future follow the order to engage the

 3     police units only through the Main Staff of the VRS."

 4        Q.   That's what Colonel General Milovanovic says, it's not contained

 5     in the previous document; right?

 6        A.   Right.

 7        Q.   Very well.  Thank you very much.

 8             And now I'd like to move on to my next topic -- or rather, your

 9     next topic in your expert report, and the topic is the training centre on

10     Mount Jahorina.

11             Let's look at document 91 in your binder.

12             MR. LAZAREVIC: [Interpretation] This is 4D212 in e-court; page 7

13     in English -- I apologise, it will be page 7 in B/C/S, and pages 16 and

14     17 in English.

15        Q.   This is Article 63 of the Law on the Internal Affairs.

16        A.   I've got the document.

17        Q.   Could you please tell us what the article prescribes, Article 63?

18        A.   Article 63 in chapter 7 of this law says that, in the ministry,

19     there is a training centre for the education of the staff of the ministry

20     of Internal Affairs; and in the seconds paragraph, it says that its task

21     is to prepare and educate personnel to work at the ministry.

22        Q.   Let's move on to Article 65.  Could you please tell us what this

23     means?

24        A.   In its first paragraph, this article says that the centre

25     provides education for the personnel who are earmarked for work at the

Page 26771

 1     Ministry of the Interior, and the second paragraph says that the centre

 2     also provides education for some other legal persons.

 3        Q.   And let's just look at another short article, which is

 4     Article 66.  Could you please explain?

 5        A.   According to Article 66, the centre also has a school for

 6     interior and the boarding or a dorm.

 7        Q.   What would be the main function of the education centre,

 8     according to these articles?

 9        A.   It would be the education and training, as well as continuous

10     education and specialist education, of the personnel working at the

11     Ministry of the Interior, be it the education and training of the already

12     existing staff or those who intend to join the ministry in the future.

13        Q.   Thank you very much.

14             The next document I would like to show you consists of two

15     consecutive documents.  The first one is document -- I apologise, in your

16     binder they are under 26.

17             MR. LAZAREVIC: [Interpretation] The document number is 4D251.

18             THE WITNESS: [Interpretation] I can see the document.

19             MR. LAZAREVIC: [Interpretation]

20        Q.   Very well then.  What I would be interested in is the following:

21     You see that this was sent to the special brigade of the police at

22     Jahorina terminal -- actually, this is the sender.

23             Let's now pay attention to the date.  The date is 16 April 1995.

24     Let's pay attention to the second part of the second page starting with

25     words "the current agreement."

Page 26772

 1        A.   I can see that.

 2        Q.   My question arises from this dispatch.  In addition to the

 3     trainers and the special police brigade, who else was involved in the

 4     training of the participants in the course?

 5        A.   As you can see from this document, in addition to the instructors

 6     from the special police brigade, the training course also involved

 7     teachers from the school of the interior and the name of the specific

 8     teacher is mentioned here as Nedo Sevo, as well as the psychologist Aco

 9     Milic from the school.  In other words, there were two people involved

10     from the school.

11        Q.   And just to pinpoint that and attach it to a certain time period,

12     I would like us to look at the first sentence of this document starting

13     with words, "In the evening of 5 February 1995 ..."

14        A.   Yes, I'm with you.

15        Q.   We would then have to say that this is about the group of

16     trainees who arrived from the CJB Zvornik?

17        A.   Yes.

18        Q.   And the total number of trainees is given at 142?

19        A.   Yes.

20        Q.   The following document I'd like to show you is under number 27, a

21     very brief document in your binder.

22             MR. LAZAREVIC: [Interpretation] In the e-court system, it is

23     4D252.

24             THE WITNESS: [Interpretation] I've got the document in front of

25     me.

Page 26773

 1             MR. LAZAREVIC: [Interpretation]

 2        Q.   Could you please tell us something about this document.  This

 3     document is a request in view of the problems, the problem being that

 4     officers had failed to arrive, and there is a request placed on the staff

 5     to send urgently an officer.  Could you please explain?

 6        A.   This means that a request is being sent in view of the failure of

 7     one officer to arrive, that his replacement should be sent, and the

 8     person is specified here, in order to work with the trainees.  In other

 9     words, a request is made upon the special police brigade to send another

10     person who would be helping with the course.

11        Q.   Let's just summarize the two documents and draw a conclusion

12     based on the two.  In addition to the members of the special police

13     brigade who were sent to help with the training, and teachers from the

14     school, what other commitments did the special brigade police have

15     towards this education centre?

16        A.   As far as I can tell, the commitment on behalf of the special

17     police brigade was to send a certain number of officers, as previously

18     agreed, who will participate in the implementation of a certain training

19     programme for trainees, together with the teachers from the school.

20        Q.   Thank you very much.  We will no longer need this document.

21             In other words, we are talking about a special course for

22     policeman; wouldn't that be correct?

23        A.   Yes, it would.

24        Q.   The following documents that I would like to look at is under

25     tab 28 in your binder.

Page 26774

 1             MR. LAZAREVIC: [Interpretation] This is 4D511.

 2        Q.   Let's look at the front page of this document.  This is a report

 3     on the work of the special police brigade for June 1995.  It was drafted

 4     in Bijeljina in July 1995, as we can see.

 5             MR. LAZAREVIC: [Interpretation] Let's look at page 2 both in the

 6     English version as well as in B/C/S.

 7        Q.   You can see, under A, the title, "Statistical overview of days

 8     worked in the course of June 1995."  The fifth bullet point here is days

 9     spent in professional training; 2.413 days is the total sum.

10        A.   Yes.

11        Q.   What would be your interpretation of this particular entry days

12     spent in professional training and the figure that appears next to this?

13        A.   My opinion is that this is, as we can see, a very significant

14     number of days.  However, a day is compound number of all the days spent

15     at all forms of professional education, of all the members of the special

16     police brigade, which includes education within the brigade as well as

17     any forms of training or education that was provided to the school as

18     courses for future policeman or current policemen.

19             In other words, this is a total sum of all the different

20     educations that I've just mentioned.

21        Q.   As far as I can understand, this also includes the number of days

22     that members of the special police brigade spent in training as well as

23     the days they spent in training others as instructors?

24        A.   Yes, you are right.

25        Q.   Very well.  Let's look at the following document which is

Page 26775

 1     connecting with this one.  This is your tab 29.

 2             MR. LAZAREVIC: [Interpretation] Exhibit number 4D95 [as

 3     interpreted].

 4             THE WITNESS: [Interpretation] Yes, I have it.

 5             MR. LAZAREVIC: [Interpretation]

 6        Q.   So this is a report on the work of the SPB in the period

 7     January-September 1995; but underneath, it says that the report refers to

 8     the period between 1st of January 1995 and 15th October 1995, and the

 9     date in the upper left corner is 4th of November 1995.

10        A.   Yes, I see.

11        Q.   Let's look at page 2; and towards the bottom of this page, it

12     also says number spent in training, 32.772.  Can you see that?

13        A.   Yes, I can.

14        Q.   Does this basically confirm your conclusion?

15        A.   Yes, it does.  It confirms what I said earlier, and this is nine

16     and a half months.  That is the aggregate number of days over nine months

17     that members of the SPB spent in training, and the previous document

18     related only to one month.

19        Q.   Very well.  The trainees at the training centre, what kind of

20     obligations did they have vis-a-vis the Ministry of the Interior?

21        A.   Once you become a candidate or a trainee policeman and you attend

22     a course, you undertake an obligation, first and foremost, to attend the

23     training regularly, to attend classes regularly, to behave properly in

24     accordance with the rules of service, and all other things that involve

25     this kind of special training and education.

Page 26776

 1        Q.   Let us now look at the next document.  That's your tab 30 in your

 2     binder.

 3             MR. LAZAREVIC: [Interpretation] That's 4D253.  It's a dispatch

 4     dated -- I am sorry, a dispatch that is 13/95, dated 9th of April 1995.

 5        Q.   It is addressed to the office of the minister as well as to the

 6     police forces staff, and so on and so forth.  Let us only look at one

 7     sentence from this document, which begins:  "On 8th April 1995 ..."

 8        A.   Yes, I can see that.

 9        Q.   And here see the names of some 15 trainees who left without

10     permission?

11        A.   Yes.

12        Q.   And the next sentence begins in that respect.

13             Can you tell me what was suggested and proposed to do?

14        A.   The suggestion or the proposal was made that certain measures be

15     taken against these trainees, and the staff wanted feedback information

16     about what other measures were taken with respect to other trainees,

17     whether this would involve disciplinary measures or things like that.

18     I'm now talking about those who left the course without permission.

19        Q.   Let's look at the next document which is in your tab 67.

20             MR. LAZAREVIC: [Interpretation]   That's Exhibit 4D358; page 8 in

21     B/C/S, and page 19 in English.

22        Q.   We already seen this, but I would like to focus on Article 83 of

23     this law, and I would like to hear your comments.

24        A.   Did you say tab 67?

25        Q.   Yes, tab 67, and Article 83 of the law.  Can you please look at

Page 26777

 1     it.

 2        A.   Yes.

 3        Q.   What does Article 83 provide?

 4        A.   Article 83 provides for the following:  If a participant in the

 5     course for policemen willfully leaves the course, is expelled from the

 6     course because of his own fault, fails to complete the course

 7     successfully, is bound to refund the costs of the course -- or rather,

 8     the proportionate amount of the course, which means that if a person has

 9     established a certain relationship with the ministry, this person is

10     bound to refund the money to the ministry.

11        Q.   Is this document in some way related to the previous document?

12        A.   Probably.  The previous document is based op this by requesting

13     that report be submitted about what measures have been taken, and whether

14     they have been taken at all in compliance with Article 83, when it refers

15     to those who willfully left the course.

16        Q.   Thank you very much.

17             The next document that I would like us to look at is in your

18     tab 31.

19             MR. LAZAREVIC: [Interpretation] This is Exhibit P726.  This is an

20     order issued by the commander chief addressed to all ministries and the

21     government of RS, presidents of municipalities, and the Main Staff of the

22     VRS.  It bears the date of 16th June 1995.

23        Q.   As I said, this is an order, and this document has already been

24     analysed during this trial.  I'm particularly interested in item 3 of

25     this document, paragraph 2 or subitem (2).  Can you tell me what it

Page 26778

 1     contains?

 2        A.   Item 3 of this order, subitem (2), says that the Ministries of

 3     Defence and of Interior shall undertake necessary actions for the return

 4     of conscripts from the Federal Republic of Yugoslavia and their

 5     recruitment in the units of the armed forces.

 6        Q.   Let's look now at the next document.  That's -- just a second.

 7     It's your tab 15.  So this is the law on the implementation of the Law on

 8     Army during a state of imminent threat of war or a state of war.

 9             MR. LAZAREVIC: [Interpretation] That's Exhibit 4D413; page 3 in

10     B/C/S and page 7 in English.

11        Q.   Can we look at Article 12 of this law, please.

12        A.   Which law?

13        Q.   I am sorry.  That's law on the implementation of the Law on the

14     Army in the state the immediate threat of war or state of war.

15        A.   Yes, I have it; Article 12.

16        Q.   Can you just tell us what this Article 12 governs?

17        A.   This article governs -- the deployment of reserve forces to the

18     army is to be carried out by the ministry of Defence.  So the obligation

19     of the Ministry of Defence would be to deploy military conscripts.

20        Q.   Based on the documents that you had an opportunity to go through,

21     and based on these regulations, what would happen to those conscripts

22     once they completed their training?

23        A.   Well, once military conscripts completed their training as

24     prescribed, they are supposed to be assigned to the armed forces of

25     Republika Srpska, and we know which of these two forces we are talking

Page 26779

 1     about.

 2        Q.   And just one more document before we finish for today.  That's

 3     your tab 32 in folder 1.

 4             MR. LAZAREVIC: [Interpretation]  That's Exhibit 4D300.  So this

 5     is a letter sent by Tomislav Kovac, the deputy minister to the president

 6     of the Republika Srpska.  It's dated the 23rd of June 1995.

 7        Q.   Let us just look at the first paragraph.

 8        A.   Yes, I see it.

 9        Q.   What can you tell us based on this first paragraph?  How many

10     conscripts have been handed over to the VRS?

11        A.   The deputy minister informs hereby the president of Republika

12     Srpska that from the reception centre in Janja, 1.586 conscripts were

13     delivered to the VRS, out of which 149 conscripts were handed over to the

14     MUP staff in Jahorina.

15        Q.   Is this document in any way related to the order of the commander

16     in chief we have seen a minute ago?

17        A.   Precisely so, indeed.  Within mobilisation affairs, both the

18     Ministry of Defence and the Ministry of the Interior have certain

19     obligations.

20        Q.   Thank you, Dr. Bajagic.

21             JUDGE AGIUS:  Thank you.

22             We'll adjourn for today, resuming tomorrow at 9.00.

23                           --- Whereupon the hearing adjourned at 1.44 p.m.

24                           to be reconvened on Wednesday, the 8th day of

25                           October, 2008, at 9.00 a.m.