Tribunal Criminal Tribunal for the Former Yugoslavia

Page 33883

 1                           Friday, 3 July 2009

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 12.34 p.m.

 5             JUDGE AGIUS:  Good afternoon.

 6             Mr. Registrar, could you call the case, please.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon to

 8     everyone in and around the courtroom.

 9             This is case number IT-05-88-T, the Prosecutor versus

10     Vujadin Popovic et al.  Thank you.

11             JUDGE AGIUS:  Thank you.

12             For the record, we are sitting pursuant to Rule 15 bis, at least

13     this first session.  We'll have to see about the second.  Judge Kwon

14     couldn't be with us.

15             All the accused are present, and the composition is as it was

16     yesterday -- yes, as it was yesterday, except I don't see Ms. Tapuskovic

17     today.

18             Any preliminaries?  Who wishes to go first?

19             Mr. Josse.

20             MR. JOSSE:  I'm grateful.

21             I think this is an unopposed application to add one document to

22     our 65 ter list.  Mr. McCloskey has been good enough to indicate to me

23     that he has no objection.

24             JUDGE AGIUS:  Okay.  Can you, for the record, indicate the

25     document?

Page 33884

 1             MR. JOSSE:  It's going to be 6D346.

 2             JUDGE AGIUS:  Thank you.

 3             Confirmed, Mr. McCloskey?

 4             MR. McCLOSKEY:  Yes, Mr. President.

 5             JUDGE AGIUS:  Thank you.  So the document will be included in

 6     your 65 ter list, Mr. Josse.

 7             Mr. McCloskey.

 8             MR. McCLOSKEY:  And could we go into private session just

 9     briefly?

10             JUDGE AGIUS:  Yes, of course.  Let's go into private session for

11     a short while, please.  Wait, Mr. McCloskey.

12                           [Private session]

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Page 33885











11 Pages 33885-33886 redacted. Private session.















Page 33887

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 5                           [Open session]

 6             JUDGE AGIUS:  We are in open session.

 7             MR. JOSSE:  To facilitate what your senior legal officer is

 8     attempting to do, could we indicate that we do not intend to call the

 9     fifth witness next week.

10             JUDGE AGIUS:  Okay, thank you.

11             For that information, I was coming to you on that precisely,

12     either now or later.

13             Let's proceed now.  Let's bring the first witness.

14             By the way, because, again, of logistical problems that we have

15     today, our intention is to sit roughly up to and not beyond 3.30 today.

16     That being the case, I'm suggesting a break of 15 minutes or so at

17     quarter to 2:00, if that is agreeable.  All right?

18             MR. JOSSE:  To state the obvious, it's clearly highly desirable

19     to finish both these witnesses today.

20             JUDGE AGIUS:  That's our intention as well.

21             MR. JOSSE:  I'm only stating the obvious, though, Your Honour.

22             JUDGE AGIUS:  Okay, thank you.

23                           [The witness entered court]

24             JUDGE AGIUS:  Good afternoon to you, sir.  Can you hear me?

25             THE WITNESS: [Interpretation] Yes, I can hear you.

Page 33888

 1             JUDGE AGIUS:  Welcome to this Tribunal.  You're about to start

 2     giving testimony.  Before you do so, you need to make a solemn

 3     declaration that you will be testifying the truth.  Please proceed with

 4     reading out aloud your solemn declaration.

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

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

 7                           WITNESS:  NEDELJKO ZORANOVIC

 8                           [The witness answered through interpreter]

 9             JUDGE AGIUS:  Okay, thank you.  Please make yourself comfortable.

10             Mr. Krgovic will ask you a few questions, and then we'll see who

11     follows after him, what cross-examination.

12             Mr. Krgovic.

13             MR. KRGOVIC: [Interpretation]  Good afternoon, Your Honours.

14                           Examination by Mr. Krgovic:

15        Q.   Good afternoon, Mr. Zoranovic.

16        A.   Good afternoon.

17        Q.   My name is Dragan Krgovic, appearing for the Defence of

18     General Gvero.  I'm going to put to you questions.  Since we are speaking

19     the same language, as I told you in proofing, please make a pause between

20     my question and your answer so that we do not overlap, so that the

21     interpreters may interpret what we are going to talk about.

22             Mr. Zoranovic, could you please state your full name and surname?

23        A.   My full name and surname is Nedeljko Zoranovic.

24        Q.   Do you have a nickname?

25        A.   My nickname is Nedjo.

Page 33889

 1        Q.   Please tell us your place and date of birth.

 2        A.   I was born on the 4th of August, 1957, the village of Vucinici

 3     [phoen], the municipality of Kladanj, in Bosnia and Herzegovina.

 4        Q.   What qualifications do you have?

 5        A.   I'm a car body mechanic -- or a car mechanic.

 6             THE INTERPRETER:  Correction.

 7             MR. KRGOVIC: [Interpretation]

 8        Q.   What is your profession now?

 9        A.   I'm a professional truck driver in international transportation.

10        Q.   When did you enter into service of the Army of the Republika

11     Srpska?

12        A.   I'd entered service in 1993.

13        Q.   Which unit?

14        A.   The Milici Brigade, and I was recorded as a member, as a soldier,

15     in 1993 there.

16        Q.   After that?

17        A.   After that -- no, I apologise.  If I may correct myself.  I

18     entered the military brigade in 1992.  I apologise.  My mistake.  After

19     that, in 1993 I came to the Main Staff.  I cannot recall the date or the

20     month.

21        Q.   Which duty did you perform?

22        A.   As a driver.  My duty at the Main Staff was that of a driver.

23        Q.   Until when were you a driver at the Main Staff?

24        A.   Until the end of the war, I remained as a driver at the

25     Main Staff.

Page 33890

 1        Q.   Did you have a specific task to be somebody's permanent driver or

 2     were matters arranged differently?

 3        A.   I had no specific duties.  I was not assigned to any general or

 4     officer.  I was the driver to all of them, both General Mladic,

 5     General Gvero, General Milovanovic.  I drove as ordered.

 6        Q.   The end of July 1995, did you drive General Gvero to the UNPROFOR

 7     check-point in the area of Zepa?

 8        A.   Yes.

 9        Q.   Do you recall the date?

10        A.   I cannot recall the date.  I cannot recall the exact date, but I

11     know that on that one occasion, I drove him to the check-point, the

12     UNPROFOR check-point there.

13        Q.   Who was with you on that occasion?

14        A.   General Gvero and his escort, Branko.

15        Q.   Who was the permanent driver of General Gvero?

16        A.   General Gvero's permanent driver was Dragan Rajak.

17        Q.   Do you know why he did not perform his duties those days?

18        A.   I don't know, but he was absent.  And since I was in that unit, I

19     was assigned to that task.  I was sent to drive General Gvero on that

20     day.

21        Q.   Did you drive General Gvero on some other occasion to the Zepa

22     area those days at the end of July?

23        A.   No, that was the only occasion.  This was the only time that I

24     drove him in that direction.

25        Q.   On that day, when did you depart on your journey?

Page 33891

 1        A.   Yes, I do remember.

 2        Q.   What was the time of day?

 3        A.   I think around noon.  I cannot be more specific.  During the day,

 4     around noon, maybe in the afternoon, that sort of thing.

 5        Q.   How long did you -- I apologise.  First of all, where did you

 6     depart from?

 7        A.   We departed from Han Pijesak.

 8        Q.   How long did the trip take?

 9        A.   It took us some one hour to the UNPROFOR check-point, maybe even

10     more than one hour.

11        Q.   Did General Gvero, his escort, tell you what was the purpose of

12     your trip?

13        A.   Well, I knew, approximately.  To reach General Mladic, we were

14     supposed to have a brief encounter with him, and that we would be going

15     back shortly afterwards.

16        Q.   When you reached the check-point, where were you while there?

17        A.   When we arrived at the check-point, I stayed by my car.  This is

18     my duty.  Regardless of who I'm driving or wherever I am, I'm duty-bound

19     to stand by the car to -- for security reasons, to care for it.

20        Q.   Did you see the people in the field next to the road?  Did you

21     recognise any of them?

22        A.   Yes, there were some people I recognised; General Mladic,

23     General Krstic.  I saw Legenda, it seemed to me.

24        Q.   When you say "Legenda," who do you mean by that?

25        A.   The man from the Zvornik Brigade.

Page 33892

 1        Q.   Could you hear what was spoken between those people?  How far

 2     away were you?

 3        A.   I couldn't hear what they spoke about.  I was standing by my

 4     vehicle.  And since I could park my car wherever I wanted, I parked it in

 5     the shade, and I stood by it.  I could not hear anything.

 6        Q.   Did you see the buses that were passing by?

 7        A.   Yes, I did see buses passing by.  They were at a distance from

 8     me.

 9        Q.   How long did you stay there?

10        A.   Well, I cannot be very specific, but very briefly, maybe an hour

11     or so.  We didn't stay there very long.

12        Q.   Where was General Gvero's escort, where was he?

13        A.   Well, he was close to him.  He's his bodyguard, and this is where

14     he's supposed to be.

15        Q.   When you set off back, did anybody tell you where you were going

16     and which route to take?

17        A.   Well, nobody else but my superior officer tells me anything, and

18     at that time it was General Gvero.  He just told me, We're going back to

19     Han Pijesak.  And when we got there, he told me we would be going on a

20     longer trip, We are going to proceed to Banja Luka, and this is what he

21     said.

22        Q.   Well, departing and going back, I mean, between Han Pijesak and

23     the check-point, did you make any stops along the way?

24        A.   No, no, we did not.

25        Q.   On the journey from Rogatica to the UNPROFOR check-point, were

Page 33893

 1     there any VRS check-points?

 2        A.   No, there were none.

 3        Q.   What did you do when you arrived back to Han Pijesak?  Which

 4     route did you take, and did you stay there a while?

 5        A.   When we arrived at Han Pijesak, we stayed there very briefly.  I

 6     was told that I was going on a longer trip to Banja Luka, and after that

 7     we departed for Vlasenica.

 8        Q.   Did you stop at Vlasenica?

 9        A.   Yes.  We dropped by the Drina Corps headquarters.

10        Q.   What did you do there?

11        A.   Well, as a driver, I stood by my vehicle.  I stayed outside.

12     General Gvero went where he went, and there I took another vehicle.

13             MR. KRGOVIC: [Interpretation] I would like to show the witness

14     6D346, please.

15        Q.   Please take a careful look at this document.  Please take note of

16     the date in the upper left-hand corner.  What the date is.

17        A.   The 26th of July, 1995.

18        Q.   Can you see your name on this document?

19        A.   Yes, I can see it down there.

20        Q.   And is that your signature?

21        A.   Yes.

22        Q.   Do you remember this document?

23        A.   I remember that event.  Now, whether I -- or, rather, I remember

24     that I took over a Pajero vehicle from Dragomir Vukosavljevic.

25        Q.   And did you then proceed in that vehicle?

Page 33894

 1        A.   Yes, that's correct.  We took this vehicle and drove to

 2     Banja Luka.

 3        Q.   And why did you need this car?

 4        A.   Well, it's my assumption -- it's an all-terrain vehicle, and you

 5     can go anywhere in it.  You can tour everything.

 6        Q.   When did you reach Banja Luka; do you remember?

 7        A.   I can't recall, but it was in the afternoon.  I don't recall the

 8     exact time, but in the afternoon.

 9        Q.   How far is Han Pijesak from Banja Luka?  How long would it take

10     you to drive?

11        A.   Well, from Han Pijesak to Banja Luka, it's about three or four

12     hours to drive.

13        Q.   The way you drive it?

14        A.   Well, the way I drive it, it could be less, it could be more.  It

15     all depends on the orders of the generals.  Sometimes they say, Step on

16     it, we have to be there early, and then I would do it.  But sometimes it

17     was, Let's go at a leisurely pace, and then it takes you a longer time.

18        Q.   How long did you remain in Banja Luka on that occasion?

19        A.   Well, on that occasion, I believe that we were 15 or 20 days.

20     That's how it was.

21        Q.   Did anything happen to the car that you drove in to Banja Luka?

22        A.   Well, yes.  As soon as we got there, the escort, General Gvero's

23     escort, took the vehicle.  I don't know whether I gave him the keys or

24     whether he took them on his own.  And he went to fill up the car, and he

25     rolled it over.  That's why I really remember this event quite clearly:

Page 33895

 1             MR. KRGOVIC: [Interpretation] Thank you very much.  I have no

 2     further questions for this witness, Your Honours.

 3             JUDGE AGIUS:  Thank you.

 4             I take it none Defence teams wishes to cross-examine this

 5     witness.

 6             Mr. McCloskey.

 7             MR. McCLOSKEY:  Thank you, Mr. President.

 8                           Cross-examination by Mr. McCloskey:

 9        Q.   Witness, good afternoon.  My name is Peter McCloskey.  I

10     represent the Prosecution in this case.

11             Were you shown the video of Boksanica with General Gvero, and the

12     Muslim buses, and General Mladic?

13        A.   Yes, the Defence counsel showed it to me.

14        Q.   When?

15        A.   Well, it was maybe one or two months ago, something like that.  I

16     don't know exactly.

17        Q.   And when was the first time Defence counsel spoke to you about

18     anything?

19        A.   The Defence counsel first spoke to me sometime last year.  I

20     don't know whether it was in May or in April.  I can't really recall.  I

21     don't recall the time.

22        Q.   Now, when you saw the video, did you see yourself in it?

23        A.   I couldn't see myself on the video.

24        Q.   Did you see your vehicle in it?

25        A.   No, not my vehicle either.

Page 33896

 1        Q.   Did you look for your vehicle or yourself while watching the

 2     video?

 3        A.   Well, I didn't really try.  I saw what I saw, but I didn't see

 4     myself or my vehicle.

 5        Q.   Did anyone ask you to look for yourself or your vehicle while you

 6     were -- while they were showing it to you?

 7        A.   No.

 8        Q.   So if you left Han Pijesak around noon, when was it that

 9     General Gvero actually ate lunch?

10        A.   I don't really recall.  He may have had lunch at the

11     Corps Command with his associates, and I really don't remember.  I was

12     not there.  I didn't see them.

13        Q.   Well, he could very well have had lunch at Boksanica with

14     General Mladic in one of the buildings at the check-point, too; correct?

15        A.   I didn't see him have lunch there, either, because it was just a

16     meeting at the check-point, on a meadow.

17        Q.   So he could have had lunch with the generals and you didn't see

18     it because you were sitting over by your car the whole time?

19        A.   Yes, that's correct.

20        Q.   And there were buildings at that -- at that check-point?

21        A.   There were no buildings there.

22        Q.   Sir, we've seen other shots of that check-point.  There's

23     actually a room -- there's a radio room.  Did you ever see the radio

24     room, go inside the radio room of the building?

25        A.   No, I didn't go there.  That's what I said, and let me say it

Page 33897

 1     once again.  We were under orders that wherever we took the generals to,

 2     it was our duty to remain inside or beside our cars, for security

 3     reasons.

 4        Q.   Now, on the way -- either on the way to Boksanica or on the way

 5     back from Boksanica, did you ever stop the vehicle where there was an

 6     UNPROFOR officer along the road somewhere?

 7        A.   Well, I can't confirm that with any certainty.  I don't recall.

 8     I really don't recall making any stops or any officers stopping.  I don't

 9     remember.

10        Q.   And there has been evidence in this case that General Gvero,

11     during the ten days prior to this date, was travelling different places

12     by car.

13        A.   Yes.

14        Q.   Who was taking him around during that period, that ten-day period

15     leading up to the 26th of July, which is the date we know that this

16     Boksanica footage occurred?

17        A.   Well, it's difficult to remember who drove him.  I may have

18     driven him somewhere, but you should really jog my memory.

19        Q.   All right.  Let me go to 65 ter 4559.

20             And, sir, this is a synopsis of an intercepted conversation from

21     three days earlier, 23 July, which it's the Prosecution's position is a

22     reliable account.  It was done by the Croatian forces over the radio

23     waves.  And if you could take a moment to look at that.

24             And I'll tell you that as we look at the substance of this, it

25     mentions that two soldiers had been wounded that day, and we have a

Page 33898

 1     report in evidence here, 146, from the Drina Corps that indicates, on the

 2     23rd of July, two soldiers were wounded in the Zepa operation.  We also

 3     have indications that -- from a commander taking part in that operation,

 4     that there was a bridgehead on 23 July.  And we've recently identified

 5     that there was an old rail line before the war in Zepa.

 6             And so when I read this, I want to ask you -- you asked me to

 7     refresh your recollection:

 8             "An unknown participant, who today, on 23 of July 1995, escorted

 9     General Gvero during a battle-field inspection at Zepa, said the

10     following regarding the situation in the enclave.  'From the beginning of

11     the Serb attack on Zepa, 17 Serb soldiers were wounded, including two

12     from today.  The progress of the Serbs is halted currently at a

13     bridgehead and the railway tracks.'"

14             Now, if you had been driving him on this day, this would have

15     been a battle-field inspection, which meant that you might have been in

16     the line of fire.  So I'm sure you remember that.

17        A.   Well, to be quite frank, I cannot confirm that I drove him on

18     that date or, indeed, that I didn't drive him, but it's more likely that

19     I didn't.  This is unfamiliar to me.  I can't tell you anything about it.

20     The only thing that I perhaps can correct here, and I find it a bit odd,

21     that it says here the "railway line" or the "railroad tracks."  As far as

22     I know, there are no tracks in Zepa, as far as I know.  Well, but as a

23     driver, I didn't see any.

24        Q.   Well, let me go to 65 ter 4587, and I'll give you a hard map of

25     this version.  It's an old map, it's from 1959, and it's our view that

Page 33899

 1     there are railway -- a railway line is the dotted black-white-black-white

 2     line that you can see begins on the left side of the picture and goes

 3     down through trig point 862, then goes over near trig point 997, and you

 4     can see it twisting around.  Whether it's an old rail line from a mine or

 5     something else, I don't know, but did you ever see any kind of old

 6     abandoned rail line or railroad setup in that area?

 7        A.   No, I never saw anything, any railroad tracks, any railway lines,

 8     anything that had to do with railways there, so I can't really tell you

 9     anything about it.

10        Q.   Well, clearly the Muslims were there until the 26th of July.  Did

11     you ever get in that area after that?

12        A.   I did not go there after that date.

13        Q.   All right.  Then let's go to a few days before that, the 20th of

14     July, roughly a week, maybe -- well, six days before Boksanica.  You'd

15     been to the Jela Restaurant?  It's abandoned and -- well, it was the last

16     time I was there, anyway.  Do you know where the Jela Restaurant is, sort

17     of out in the field, not far from Han Pijesak?

18        A.   Could you please tell me the name of the restaurant.

19        Q.   "Jela."

20        A.   Yes, yes, yes, it sounds familiar.

21        Q.   Well, I think the officers of the VRS used it for functions, ate

22     there.  It was not far from HQ.  I'm sure you've eaten there yourself.

23     Right?

24        A.   Well, Jela was not a restaurant for just the officers and us

25     drivers.  Anyone could go there and eat or drink and pay for the food and

Page 33900

 1     drinks.  It was just a normal kind of restaurant.

 2        Q.   Right.  And did you drive anyone there on the 20th of July?

 3     I can tell you, General Mladic was there, General Gvero was there,

 4     General Milovanovic was there, General Krstic was there.  That's just to

 5     name a few.  It was a big party as a send-off for General Zivanovic, and

 6     there were a lot of drivers there.  Do you remember that?

 7        A.   Well, I can't really remember that.  I do remember being there on

 8     one occasion.  I drove somebody there, I don't remember who, and then I

 9     went back to my command post.  I simply drove somebody there and went

10     back.

11        Q.   So do you have any memory of driving anyone on the 20th of July,

12     just six days before Boksanica, which you obviously have a memory of,

13     even though you weren't even on the tape?

14        A.   I really can't confirm that.  I don't remember.  It was a long

15     time ago.  Fifteen years have passed, and it's very difficult for me to

16     say, so I can't remember.

17        Q.   All right.  Well, now let's go to the 16th of July, a few days

18     before that.

19             And if we go to P02942, this is also in evidence in this case,

20     and it is a UN document that indicates that -- it should be the -- 2942

21     is -- it is 2942.  Ms. Stewart has it on her screen, so -- there we go.

22     And we can -- and if we can -- this gives us an idea.  It's a code cable

23     dated 17 July.  But if we could flip to the second page in the English,

24     under -- it's actually the next page in the English.  It should be page 3

25     in the English.  That's it, and it's 3 in B/C/S.

Page 33901

 1             This is one of the records of at least one or two others that I

 2     won't take the time to show you that shows that General Gvero, on the

 3     16th, was meeting at the Jahorina Hotel with UNHCR.  Now, is there a

 4     Jahorina Hotel in Pale or Han Pijesak?

 5        A.   There is a Jahorina Hotel at Pale.

 6        Q.   All right.  And I'm sure you took senior officers there to meet

 7     with various international organisations while you were there as a

 8     driver, did you not?

 9        A.   That's correct.

10        Q.   All right.  How about 16 July, some ten days before you recall

11     taking General Gvero to Boksanica?  If you thought about this, do you

12     recall taking him to Pale, all the way over to Pale, to meet with the

13     UNHCR?

14        A.   I have to say this again.  We, the drivers, were very busy.  We

15     couldn't -- we didn't know anything about dates or meetings because we,

16     and I as a driver, don't know anything about that, because nobody told

17     us, We're going there to meet such and such a person, or to go there.

18     They would just tell us, Drive to Pale.  And once we got there, the

19     senior officer, Gvero or whoever, would leave the car and go to those

20     buildings, and we didn't know where he went or what he did.  We stayed by

21     the car, guarding the vehicle.  And I can't really tell you whether I

22     drove him or didn't.  I cannot remember that, because we were very busy.

23     We would sometimes -- well, I would sometimes drive General Gvero, just

24     to give you an example, to Pale, and then come back to Han Pijesak, and

25     then I would have to drive other officers to other places.  We really

Page 33902

 1     worked hard, we were very busy, and we can't really know anything about

 2     what was going on.

 3        Q.   Well, surely you would remember, if you took General Gvero to the

 4     Srebrenica battle line, to a little forward command post out in the woods

 5     overlooking Srebrenica, when the fight was going on on July 9th, a few

 6     days earlier.

 7        A.   Well, now you reminded me of the 9th of July.  I can recall one

 8     occasion when I drove -- well, I don't know whether that was the date or

 9     not, I can't really claim that, but I did drive General Gvero to

10     Belgrade.  And I was there with him in Belgrade, and I can -- I seem to

11     be able to recall that on our way back, between Vlasenica and Zvornik, I

12     don't know whether he stopped somewhere.  But it was just a very brief

13     stop, and I can't really say where it was, who he visited, what he talked

14     about.  I was not duty-bound to know any of that.  It was my duty to just

15     drive the general where I'm told and then to bring him back.

16        Q.   So this was July 9th that you took him to Belgrade?

17        A.   Well, the exact date, well, I can actually say that with some

18     certainty, because I can recall when it was that I got back from

19     Belgrade.  I went straight home.  I had some days off because the 12th of

20     July is my family feast, our Patron Saints feast, and that's why I took

21     those days off and I went home to celebrate it.

22        Q.   So did you tell -- you must have told the Defence attorneys about

23     this trip to Belgrade on July 9th that you took with General Gvero?

24        A.   Yes, yes, I did say that.  I recall that.

25        Q.   And did they suggest you might need to testify about that?

Page 33903

 1        A.   Well, they did tell me, If you are questioned, you only need to

 2     say what you know.  And I shared with you everything that I know.  I

 3     can't go beyond that.  A long time has passed, and it's too long for me

 4     to be able to have a very clear memory of it all.

 5             MR. McCLOSKEY:  Could I ask the Defence to get proofing notes

 6     from that session where he told them about going to Belgrade on the 9th?

 7             JUDGE AGIUS:  Mr. Josse.

 8             MR. JOSSE:  I made an error yesterday, Your Honour.

 9             If Your Honour recalls --

10             MR. McCLOSKEY:  Perhaps we should do this without the witness.

11             MR. JOSSE:  Absolutely.

12             JUDGE AGIUS:  Okay.  Do you understand English, Mr. Zoranovic?

13             THE WITNESS: [Interpretation] No.

14             JUDGE AGIUS:  All right.  Can I ask you to remove your

15     headphones, please.  Thank you.

16             Mr. Josse.

17             MR. JOSSE:  As Your Honours will recall, yesterday the Court

18     reminded the Defence that we hadn't put a number of these witnesses on

19     our 65 ter list, and I said that two had been on the list.  I made an

20     error.  Three had been on the list.  The third was this gentleman.  So he

21     was on our list of last year.  And for what it's worth, I don't have it

22     in front of me, but the 65 ter summary dealt with the events of the

23     9th of July at Pribicevac.  So it was our original intention to call him

24     as part of the Defence case, that we then, for wont of a better word,

25     abandoned.  As the Court knows, we decided not to call any evidence at

Page 33904

 1     that particular juncture.  And he was on the list in that regard.  So

 2     that's the first thing to bear in mind.

 3             We then submitted the new list, as the Court is well aware, in

 4     relation to the new evidence, and for reasons that I'd rather not go into

 5     at the moment, largely because I maintain they're privileged, we chose

 6     not to ask him about the events of the 9th of July.

 7             My learned friend is quite entitled to cross-examine him about

 8     it, and he's doing that, but we submit we're under no duty whatsoever to

 9     produce proofing notes so far as matters that relate to things we are not

10     asking him about.  Where, I asked my learned friend, do the Rules say we

11     have to supply that information to him?  We have to supply statements,

12     and as I made clear yesterday, we did that so far as yesterday's witness

13     is concerned.  There's no statement in existence, and we're under no duty

14     to provide a proofing note or our own notes, which are privileged in the

15     extreme, I submit, in terms of our dealing with witnesses.

16             JUDGE AGIUS:  Thank you, Mr. Josse.

17             Mr. McCloskey, shall we proceed?

18             MR. McCLOSKEY:  Yes, Mr. President.  I have about a five-line

19     blurb from Mr. Josse on that point, and if that's what he wants to

20     submit, that's what I'll take.

21             JUDGE AGIUS:  Okay.  Let's proceed.

22             MR. McCLOSKEY:

23        Q.   So, sir, when did you first tell the Defence about your July 9th

24     trip?

25        A.   Well, the first time, I think it was last year, when we met for

Page 33905

 1     the first time.

 2        Q.   Well, we received that note in a filing of 30 April 2008, so it

 3     would have had to have been before that.  So how long before spring-time

 4     or April did you meet with them and discuss that?

 5        A.   Well, it might have been that date.  I really don't know.  I

 6     don't remember the dates, but it's possible that -- well, it may have

 7     been on that date.

 8        Q.   Well, who did you go with?  Who was his personal escort then?

 9        A.   Well, General Gvero, when he went to Belgrade, he did not have an

10     escort.  He just went there in a car with a driver.

11        Q.   And how were you able to remember that you took him there on

12     July 9th?

13        A.   Well, again, there is something that I have just remembered.  His

14     father-in-law -- I took his father-in-law to Negotin.  Well, I remember

15     him as an elderly gentleman, very neat in his appearance and behaviour,

16     and we talked about all kinds of things.  That's what I remember.

17        Q.   My question is:  You would have been going back many, many years,

18     11, 12 years.  Thinking back on what you did that -- earlier, did you

19     review any log-book, any diary?

20        A.   No, we didn't keep any records, apart from when we went to

21     Serbia, we would get some kind of a travel order to get fuel.  That's the

22     only thing that I remember.  I don't remember there being anything else.

23        Q.   So did someone tell you -- someone remind you that you'd actually

24     picked him up on 9 July?

25        A.   I don't understand the question.  Could you please be more

Page 33906

 1     specific?  I didn't understand the question.

 2        Q.   Well, sometimes what happens, when someone contacts a witness,

 3     they may sit down with a lawyer who says, You remember where you were on

 4     9 July, 1995, when you took General Gvero to someplace, and then ask you

 5     if you remember taking him someplace in July.  They might give you a

 6     date; they might leave it open; they might show you something.  How did

 7     that happen?  Or you may have got a call from General Gvero from jail, or

 8     a family member, or a friend.  It's normal.

 9        A.   Yes, yes.  Well, yes, I said I remembered the 9th of July because

10     I got days off.  And we returned on the 9th of July, and I was given some

11     days off to celebrate my Patron Saints Day on the 12th of July.  From

12     that day onwards, I cannot recall the exact number of days off that I was

13     given.

14        Q.   Okay.  When you came driving back, you say, from Belgrade on

15     9 July -- correct?

16        A.   Yes, that would be so, to the best of my recollection.  I used

17     the 12th of July, my Patron Saints Day, as a reference point.  We

18     returned in good time for me to be with my family to celebrate my

19     Patron Saints Day.

20        Q.   Around what time did you leave Belgrade?

21        A.   I really cannot recall the exact time, but it must have been in

22     the afternoon, as far as I can recall.

23        Q.   And tell us where you went.  You're a driver, you're a

24     professional driver.  You know your routes, you know the towns, the

25     villages.  Tell us where you went.  I don't need all the villages.  Did

Page 33907

 1     you go Belgrade-Zvornik?

 2        A.   Yes, that's correct, we went through Zvornik.

 3        Q.   And from Zvornik, where did you go?

 4        A.   From Zvornik, we took the normal route, Zvornik to Vlasenica,

 5     through Konjevic Polje.

 6        Q.   And when you got to Konjevic Polje, did you turn towards Bratunac

 7     or towards Milici and Vlasenica?

 8        A.   Well, as I said, I cannot be specific as to what I recall.  We

 9     went and stopped, but I cannot recall exactly where we stopped.

10        Q.   Listen to my question.  When you got to Konjevic Polje, did you

11     head towards Bratunac or towards Milici?  The Court's very familiar with

12     these places, so just tell us which way you went.

13        A.   No, we did not turn towards Milici, because they are on the main

14     road.  I believe that we took a turn close to Konjevic Polje.  I

15     believe -- I cannot recall specifically, but I'm sure that we didn't take

16     the Milici road.

17        Q.   Sir, did you go to Bratunac?

18        A.   No, we didn't go through Bratunac.

19        Q.   So after Konjevic Polje, how long did you drive until you

20     stopped?

21        A.   Well, as far as I can recall, it wasn't a long journey.  We drove

22     back very fast, very soon.

23        Q.   Sir, how long, after turning on -- turning off at Konjevic Polje,

24     did you drive until you reached your -- you next stopped the car?  I'm

25     sure you know that Bratunac is some 25, 30 kilometres from

Page 33908

 1     Konjevic Polje, and if you didn't make it to Bratunac, you must have

 2     stopped somewhere between Konjevic Polje and Bratunac; right?

 3        A.   That's correct, we did not go to Bratunac.  Well, somewhere

 4     there, as I tell you, it's very difficult to be specific, we turned off

 5     at someplace, but then we drove back very soon afterwards to continue our

 6     journey.

 7        Q.   Well, that's what I want to know, sir.  Where did you go?

 8        A.   I cannot really tell you.  In Konjevic Polje or around

 9     Konjevic Polje, we did not go to Milici.  We took a turn off somewhere

10     there, but I cannot be specific, I cannot recall.  It's very difficult to

11     confirm and be very precise.

12        Q.   Well, where did you stop; around houses, around a field?  And why

13     did you stop?

14        A.   I cannot recall.  Please do not make me invent things I cannot

15     really recall.  As I'm telling you, we took a turn, but nobody told me

16     where would we be going.  I'm told to stop.  I stand by my vehicle and do

17     as I'm told, but I cannot recall how things unfolded.

18        Q.   Well, let me read you what the Defence of General Gvero told us:

19             "The witness was a driver in the VRS Main Staff who on occasions

20     drove General Gvero.  The witness will testify that in early July 1995,

21     he took General Gvero to Belgrade for a family visit.  He then collected

22     him a few days later on 9th and drove him to Pribicevac, where they

23     remained for about one hour.  He then drove General Gvero back to

24     Han Pijesak."

25             Have you ever heard of the word "Pribicevac"?

Page 33909

 1        A.   I heard the word "Pribicevac" when I was mentioned that place by

 2     the Defence counsel.  It had been unknown to me before that.

 3        Q.   And so where did you tell the Defence counsel you took

 4     General Gvero after you turned off at Konjevic Polje?

 5        A.   I told the Defence the same thing, that we took a turn off the

 6     road, but I cannot recall any place called Pribicevac.  I cannot recall

 7     who he was seeing there.  I cannot confirm anything of that.

 8             MR. McCLOSKEY:  Thank you, sir.

 9             I don't have anything further.

10             JUDGE AGIUS:  Thank you.

11             I suggest we have the break now.  But before we do so, is there

12     re-examination?

13             MR. KRGOVIC:  No, Your Honour.

14             JUDGE AGIUS:  Thank you.

15             Judge Stole?

16             Judge Prost?

17             Mr. Zoranovic, that brings your testimony to an end.  On behalf

18     of the Trial Chamber, I wish to thank you for having come over, and also

19     I wish you a safe journey back home.  Thank you.

20             Documents, Mr. Krgovic?

21             MR. JOSSE:  Just that one, 6D346.

22             JUDGE AGIUS:  Objections?

23             MR. McCLOSKEY:  No, Mr. President.

24             JUDGE AGIUS:  Thank you.

25             Documents, Mr. McCloskey?  You used the map and you used

Page 33910

 1     something else toward --

 2             MR. McCLOSKEY:  The map, and that is 4587, and the famous

 3     intercept which he invited me to refresh his recollection with, 4559.

 4             JUDGE AGIUS:  And you had another one regarding the delivery of

 5     the car.  That's already in?

 6             MR. McCLOSKEY:  That was a Defence exhibit, and the other one was

 7     already in.

 8             JUDGE AGIUS:  Okay, thank you.

 9             Objections?

10             MR. JOSSE:  Yes.

11             Very briefly, I'll repeat the objection I made yesterday, relying

12     on the Prlic decision.

13             Your Honour, so far as the Croatian intercept is concerned, the

14     Court's already ruled on that at T-32547, on the 10th of March of this

15     year.  I accept that arguably the position has changed somewhat in the

16     light of this particular witness's evidence, but we rely on that ruling.

17             In addition to that, the submissions the Court was ruling upon on

18     that day had been made on the 29th of January of this year; in other

19     words, before the 20th of February, when the Prlic decision came out.

20     And in our submission, that particular intercept undoubtedly falls foul

21     of the Appeals Chamber's decision and should not be admitted into

22     evidence-

23             THE COURT:  Okay.

24             MR. JOSSE:  And the map will flow from that, Your Honour.

25             JUDGE AGIUS:  Okay.  Thank you.

Page 33911

 1             Yes, Mr. McCloskey.

 2             MR. McCLOSKEY:  Yes, Mr. President.

 3             The Defence continues to make these things in issue.  I get asked

 4     questions by witnesses, I use the documents before me.  I think the Court

 5     has absolute discretion, in these matters, to take it or not take it and

 6     to give it whatever weight or not weight that you would like, and I will

 7     just stand by that.

 8             JUDGE AGIUS:  Okay, thank you.

 9             We will reserve our position as we did yesterday.  Actually, we

10     have already discussed it amongst ourselves, but in the absence of

11     Judge Kwon, I wouldn't like to make a pronouncement.  Thank you.

12             Fifteen -- how long will the next one last on

13     examination-in-chief?

14             MR. KRGOVIC:  Twenty, thirty minutes.

15             JUDGE AGIUS:  And you, Mr. McCloskey?

16             MR. McCLOSKEY:  It shouldn't be long.

17             JUDGE AGIUS:  All right.

18             Okay.  So we'll have a 20-minute break.  Thank you.

19                           --- Recess taken at 1.44 p.m.

20                           --- On resuming at 2.05 p.m.

21             JUDGE AGIUS:  All right.  The next witness.

22                           [The witness entered court]

23             JUDGE AGIUS:  Good afternoon to you, Mr. Jovanovic.  You're most

24     welcome to this Tribunal.  You're about to start giving evidence.  Before

25     you do so, you're required by our Rules to make a solemn declaration to

Page 33912

 1     the effect that you will be testifying the truth and the whole truth.

 2             Please read that text aloud, and that will be your solemn

 3     confirmation.

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

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

 6                           WITNESS:  SASA JOVANOVIC

 7                           [The witness answered through interpreter]

 8             JUDGE AGIUS:  Thank you.  Please make yourself comfortable.

 9             Mr. Krgovic will go first, ask you some questions.

10             Mr. Krgovic.

11             MR. KRGOVIC: [Interpretation] Thank you, Your Honour.

12                           Examination by Mr. Krgovic:

13        Q.   Good afternoon, Mr. Jovanovic.  May I introduce myself.  My name

14     is Dragan Krgovic, appearing for the Defence of General Gvero, and I'm

15     going to examine you today.

16             Please state your full name and surname.

17        A.   My full name and surname is Sasa Jovanovic.

18        Q.   What is the place and date of your birth?

19        A.   I was born in Zagreb, in Croatia, on the 18th of April, 1971.

20        Q.   What qualifications do you hold?

21        A.   I finished my primary school in Zagreb.  After that, I graduated

22     from the Air Force Secondary School at Rajlovac near Sarajevo.

23        Q.   Were you a member of the JNA?

24        A.   Yes, I was a member of the JNA from the 14th of July, 1990, when

25     I graduated from the Secondary Military School.

Page 33913

 1        Q.   When did you join the VRS, and which unit did you join?

 2        A.   I joined the Army of the Republic of Srpska in winter 1992, on

 3     the 22nd of December, 1992.  The command of my unit was headquartered at

 4     the Zalozani Airport close to Banja Luka, the 89th Helicopter Mixed

 5     Squadron.

 6        Q.   What duty do you hold then?

 7        A.   In the Technical Department of the Helicopter Unit.

 8        Q.   Were you transferred for a time, and when, to the Main Staff of

 9     the VRS?

10        A.   I did the so-called duty service at the Main Staff in 1993,

11     because a helicopter for the use of the commander and the Main Staff was

12     there, and I was transferred there in 1993.  I was permanently on duty,

13     and I stayed there until the end of the war.

14        Q.   What were your duties, in terms of this helicopter that was

15     there?  What was your position?

16        A.   In the meantime, I graduated a flying or pilot course for the

17     Gazelle-type helicopter, and I was a pilot in the crew of that

18     helicopter.  The helicopter Gazelle has usually an airman and a pilot.  I

19     was the airman.

20        Q.   I'm going to repeat the question.  What was your duty with

21     respect to the helicopter?  It's not clear from this transcript.  What

22     was your duty, and what was the duty of your colleague?

23        A.   The Gazelle helicopter, which was available to the Main Staff and

24     was used by the Main Staff, personally commanded by the -- by

25     General Mladic, had two crew members, the pilot and flight mechanic.  My

Page 33914

 1     role was that of the flight mechanic.  I maintained the helicopter, made

 2     sure that it's ready before the flight, during the flight, navigation

 3     duties.  That would briefly be my role.

 4        Q.   Flight engineer?

 5        A.   That's correct, flight engineer.

 6        Q.   Which rank did you have during the war?

 7        A.   During the war, I held the rank of sergeant first class.

 8        Q.   What is your occupation now?

 9        A.   Currently, I work at the Batajnica Airport in Belgrade in the

10     Army of Serbia.

11        Q.   What is your rank, and what are your duties currently?

12        A.   My current rank is staff-sergeant first class, and I'm a flight

13     engineer on a transport aircraft, AN-26.

14        Q.   Who was your superior officer while you were at the Main Staff?

15        A.   The crew in the helicopter were subordinated personally to the

16     commander of the Main Staff, General Ratko Mladic, and we were there for

17     his personal needs and uses.  The other flights which we performed were

18     performed pursuant to his personal order and his personal permission.

19        Q.   What duties did you perform in July 1995; the same duties or some

20     other duties?

21        A.   In July 1995, I was performing the same duties as the flight

22     engineer of the Main Staff's helicopter which was there for the

23     commander's personal use.

24        Q.   Did you fly, in July 1995, General Mladic towards Zepa?

25        A.   Yes, I did.

Page 33915

 1        Q.   In late July 1995, did you drive General Mladic or fly

 2     General Mladic towards the Boksanica area, where there was an UNPROFOR

 3     check-point?

 4        A.   Yes.

 5        Q.   Could you please tell us how long did it last?  Was it just once,

 6     and how long was it?

 7        A.   To the best of my recollection, we drove him there several times

 8     in that period.  Well, that's the period between, let's say, the

 9     beginning of the crisis in the Zepa area, sometime on the 19th of July,

10     until the 29th of July.  I think that we actually took him there every

11     day, to the Zepa area.  Well, several times a day, in fact.

12        Q.   When you got there, how did you take off, where did you land, and

13     how did you go back?

14             THE INTERPRETER:  Interpreters note, could counsel please speak

15     into the microphone.  We can barely hear him.

16             JUDGE AGIUS:  Did you hear that, Mr. Krgovic?

17             MR. KRGOVIC:  I apologise, Your Honour.

18             JUDGE AGIUS:  Thank you.

19             MR. KRGOVIC: [Interpretation]

20        Q.   When you left for the Zepa area, where did you take off, and

21     when, and when did you return to your point of origin?

22        A.   In those days, we would take off from Crna Rijeka, where the

23     Main Staff was, that's where the helicopter was too.  I was usually in

24     the morning.  So just after dawn we would go to the Boksanica area, and

25     we would stay there until the evening, and we would be returning at dusk.

Page 33916

 1             MR. KRGOVIC: [Interpretation] Your Honours, I would like to ask

 2     Ms. Stewart for some assistance.  We have problems with playing videos.

 3     If a video-clip could be played.  It's already in evidence.  It's about

 4     Boksanica, and it's less than a minute long.

 5             JUDGE AGIUS:  Is that possible, Ms. Stewart?  Thank you.

 6                           [Video-clip played]

 7             MR. KRGOVIC: [Interpretation]

 8        Q.   Do you recognise yourself on this footage?

 9        A.   Yes, that's me occupying the left-hand seat in the cockpit of the

10     helicopter.

11        Q.   Do you remember, sir, this flight, this helicopter flight?

12        A.   Yes, I do remember most of the flights, including this one.

13        Q.   Who was with you in the helicopter on that day; do you remember?

14        A.   It was General Ratko Mladic and a cameraman from the press centre

15     of the Main Staff.

16        Q.   Did he have any security detail with him?

17        A.   I'm not sure.  I assume that there was, because he would

18     sometimes take his security detail with him.  Sometimes he would leave

19     them behind, if there were some other passengers, because you can put

20     three passengers in the rear of the helicopter.

21             Just a moment, I'm sorry.  If the general did not take his

22     security or bodyguards with him, then usually the pilot and myself would,

23     upon the arrival, escort the general, as his bodyguards, until his

24     security detail arrived.

25        Q.   When you arrived at the check-point, the UNPROFOR check-point,

Page 33917

 1     where did you land; do you remember?

 2        A.   Yes, I do.  It was a meadow, a clearing about 50 metres by

 3     150 metres large, and we landed on the left-hand side, near the macadam

 4     road.  It was actually to the left of the macadam road, running across

 5     the clearing, if you look in the direction of the check-point, the

 6     UNPROFOR check-point itself.

 7        Q.   Do you know General Gvero?

 8        A.   I know General Gvero by sight, since he was also in the

 9     Main Staff.

10        Q.   Did you see him on that day when this clip was recorded?

11        A.   Yes, I did see General Gvero on that day.

12        Q.   Do you remember who else was present there at the clearing,

13     meadow, next to him?

14        A.   You mean of the officers?

15        Q.   The officers and anyone else who might have been there.

16        A.   Well, General Krstic, General Tolimir, and Vinko Pandurevic was

17     there for a very short period of time, and a man whose nickname was

18     Legenda.  I don't know his actual name.  He was from the Zvornik Brigade.

19     And there was also the commander of the Rogatica Brigade and the

20     commanders of the local battalions deployed in that area.  The

21     interpreter was also there, a girl from the press centre, the cameraman.

22     Colonel Dudnjik was also there.  He was commander of the UNPROFOR unit

23     headquartered there or stationed there.  That's what I was able to

24     observe.

25        Q.   You were no longer visible on the footage.  Where were you, in

Page 33918

 1     relation to the people that you just mentioned?

 2        A.   Well, it was my personal position, in terms of being in

 3     photographs and being recorded in any way, well, I'm simply not in favour

 4     of that.  I don't have an inclination.  I don't want to be photographed

 5     or filmed.  So throughout the war, I always tried to be behind the

 6     camera.  I didn't want to have my face -- my photographs taken.  That's

 7     simply not something that I craved.  So from the time we got off the

 8     helicopter, I was always behind the cameraman, but I was also close by

 9     General Mladic, who was moving about the clearing.

10        Q.   Did you have an opportunity to hear any of the conversations of

11     the people there?

12        A.   Yes, most of the conversations, because I was close by.

13        Q.   What was General Mladic doing at the time while these people were

14     on the clearing together with him; do you remember?

15        A.   Well, he came there, first of all, because several buses were

16     supposed to evacuate the population from the Zepa area.  He wanted to

17     check each and every bus to ensure the safety and to talk to the people.

18     That was his priority task.  That was why he was there.

19             Some officers had been invited by him there.  They were there to

20     be given orders personally by him for some military operations that were

21     to be taken on another part of the front-line, and that's why they were

22     there.  Well, I can tell you which officers got there for the first time.

23     They had never been there.  They got there to get orders.

24        Q.   Officers who were supposed to go to a different part of the

25     front-line.  Which ones do you mean?

Page 33919

 1        A.   Vinko Pandurevic and Legenda.

 2        Q.   Did you have an opportunity to hear what General Mladic told

 3     them?

 4        A.   Well, I heard snippets of his instructions, the orders that he

 5     issued to them.  I could tell you, well, just very briefly.  Since there

 6     was a crisis at the part of the front-line facing Drvar in Krajina, in

 7     the Bosnian Krajina, he ordered them to move elements of their unit, the

 8     Zvornik Brigade, to put a stop to an advance by the Croatian Army and to

 9     recapture Grahovo.  The front-line at the time was somewhere between

10     Grahovo and Drvar, so he ordered them to head, together with elements of

11     their units -- of their unit, to that area.

12        Q.   Do you remember what General Gvero talked about with

13     General Mladic?  Were you able to hear?

14        A.   General Gvero came suddenly to that area that we're talking

15     about, and he asked to talk to General Mladic.  At first, General Mladic

16     told General Gvero to move, and I understood that to mean that he was in

17     some kind of a waiting room, so to speak; to wait until Mladic has

18     finished his other urgent business.  And then once it was done,

19     General Mladic would talk to him.

20             General Gvero came there because he wanted to discuss some issues

21     with General Mladic, because for several days he had been unable to get

22     in touch with him, because the general was avoiding contacts with any

23     officers that were not working on Zepa or, more specifically, the

24     Boksanica thing.

25        Q.   And how did you know that?  Did you hear that from the

Page 33920

 1     conversation, or is this some knowledge that you had from some other

 2     source?

 3        A.   Well, General Mladic said, on several occasions, that

 4     General Gvero was trying to get in touch with him, but he didn't -- well,

 5     he had other more urgent business to deal with.

 6        Q.   And did General Gvero and General Mladic talk finally at one

 7     point?

 8        A.   Yes.  When the buses with the people left, the general approached

 9     the General Gvero, and they talked about this issue that prompted

10     General Gvero to come to Boksanica.

11        Q.   And did you have an opportunity to hear what they were saying?

12        A.   Yes, although at one point I, as a non-commissioned officer, as a

13     subordinate, found it a little bit unpleasant because their discussion

14     was rather heated, and that is not something that a subordinate officer

15     was supposed to hear.

16        Q.   Could you tell us what was said, very briefly.  To the best of

17     your recollection, what was the course of the conversation?

18        A.   General Gvero had been aware of the crisis at the Krajina

19     front-line for a couple of days, and since the general is from that part

20     of Republika Srpska, he wanted, as a general, to assist in stabilising

21     that part of the front-line with his presence, with his presence as a

22     general.  But he couldn't leave the Main Staff without the approval of

23     his commander.  He asked the general to let him go to Mrkonjic Grad, and

24     at one point he said something that even General Ratko Mladic accepted at

25     one -- at a later stage.  He said, I am wasting time here with 10 or 12

Page 33921

 1     Muslim villages, and at the same time two towns with the greatest

 2     majority of Serbs fell.

 3        Q.   And how did the conversation end?

 4        A.   General Mladic was angry after that conversation, but he did give

 5     his oral approval to General Gvero.  He said to him, literally, Go and

 6     report to Milovanovic.  Pack yourself and go and report to Milovanovic,

 7     General Milovanovic.

 8        Q.   And did General Gvero leave?

 9        A.   Yes, immediately, and we stayed in that area, the Boksanica area,

10     until the end of the day.

11        Q.   How long did you remain in that area, in Zepa area, after that?

12     Did you at one point leave that area and go somewhere else in those days?

13        A.   In those days, well, we stayed there for a few days.  And in the

14     meantime, the events in Krajina became increasingly more dramatic and

15     alarming, and the general decided to personally go to that part of

16     Republika Srpska to be able to analyse the situation, the developments,

17     and to do something to recapture those two towns.

18        Q.   And do you remember when you actually left for Krajina?

19        A.   On the 29th of July.

20        Q.   And in the period between the 26th and the 29th, did

21     General Mladic go to Zepa?

22        A.   Yes, he did.

23        Q.   And how long did he stay there?

24        A.   Well, the same procedure.  We would go there in the early

25     morning, and we would remain the whole day, until the evening.  In fact,

Page 33922

 1     one day, because of the necessity, he didn't want to go back to

 2     Crna Rijeka, to the Main Staff, but he remained in Borika.  He spent the

 3     night there in a house.  It was a large weekend home that belonged to

 4     Dzemal Bijedic, a former official -- high-ranking Communist official in

 5     Bosnia, and we spent a night there.  We, the crew, the two of us, spent

 6     the night together with him in a room.

 7        Q.   And where did you go on the 29th, to what part of Krajina?

 8        A.   The first order issued to us by the general was to fly him by

 9     helicopter to Bijeljina, to the East Bosnia Corps Command.  The flight of

10     the helicopter through the corridor was quite risky.  It was not safe at

11     all.  We reached Bijeljina, and at the time when the helicopter was about

12     to land he decided that we should fly on to Banja Luka, because he was in

13     a hurry, and it would take him several hours to get there by car.  And so

14     we flew over the corridor by helicopter, and we landed in the barracks

15     where the Air Force Command was in the town itself.

16        Q.   And after that?

17        A.   After that, the general stayed there very briefly.  And after

18     that, we flew to the command post of the 2nd Krajina Corps at Ostrelj.

19     It's a saddle between Petrovac and Drvar.

20        Q.   Closer to Drvar?

21        A.   That's correct, closer to Drvar.

22        Q.   On that occasion when you saw General Gvero, did you see him

23     earlier, coming to the Boksanica area while you were there?

24        A.   The only time that General Gvero came to the Boksanica area was

25     on that occasion which I described.  He stayed there very briefly.  He

Page 33923

 1     waited to have a word with the general, and after this very brief

 2     conversation he left.  And before or after that, he did not visit the

 3     area.

 4        Q.   Another clarification.  When you asked -- where asked about the

 5     fall of those towns -- I was saying "they were falling," and it says in

 6     the transcript that they had fallen, those -- the most Serb towns.

 7        A.   Yes.

 8             MR. KRGOVIC: [Interpretation] I apologise.  A moment, please.

 9        Q.   Just a moment.  This sentence that Mr. Gvero uttered, when did

10     you hear it afterwards rendered by General Mladic?

11        A.   That sentence was uttered by General Gvero, and General Mladic

12     was angry when he heard it.  But afterwards, having slept on it, he

13     understood the meaning of that sentence, and the next time I heard that

14     sentence was out of the words of General Mladic, when we landed at

15     Ostrelj, the Command of the 2nd Krajina Corps.  He literally said to the

16     corps commander and those present -- he repeated that same sentence.

17        Q.   Could you repeat that sentence, please.

18        A.   You're losing time, about 10 or 12 Muslim villages, and you've

19     lost, too, most Serb of the towns.

20        Q.   Can we repeat what -- how I heard it:  "You are wasting time on

21     two -- 10 to 12 Muslim villages, while two of the most Serb towns are

22     falling."

23             JUDGE AGIUS:  I think it's clear enough from what he stated

24     earlier.  Let's proceed and conclude, Mr. Krgovic, please.

25             MR. KRGOVIC: [Interpretation] Thank you, Your Honours.

Page 33924

 1             I have no further questions for this witness.

 2             JUDGE AGIUS:  I suppose no questions -- Mr. Haynes, please.

 3                           Cross-examination by Mr. Haynes:

 4             MR. HAYNES:

 5        Q.   Good afternoon, Mr. Jovanovic.  I'm going to ask you just a few

 6     questions on behalf of Vinko Pandurevic.

 7             You've told us there was a girl present at Boksanica on the day

 8     that you were there.  Had you seen her before, or did you see her on

 9     other occasions?

10        A.   Yes, I used to meet her earlier.  She was part of the press

11     centre of the Main Staff.  Her name was Tanja.  That's as far as I knew.

12     She was there at the Main Staff from the beginning of the war as

13     interpreter for English.  General Mladic took her with him to Boksanica

14     on several occasions to conduct conversations with the UN officers, and

15     she interpreted those conversations.

16        Q.   I thank you for that answer.  You've saved me asking you about

17     four more questions.

18             So we can take it, can we, that on the day of the video,

19     General Mladic anticipated he would require translation into English?

20        A.   I suppose that he had envisaged.  In my post, I could not know

21     anything about that, but maybe he had arranged for a meeting with the UN

22     officers who'd been supposed to come to the Boksanica area.  But her

23     presence there indicated that there might be some conversations, but

24     maybe she was there for a "just-in-case" purpose.

25        Q.   And do you now recall whether, in fact, on that day

Page 33925

 1     General Mladic met General Smith?

 2        A.   I'm not sure whether he met General Smith on that day.  I know

 3     that he had a meeting with General Smith at the Jela Motel on the main

 4     road from Han Pijesak to Sokolac and that he talked to him in the

 5     Boksanica area.  I cannot recall the exact date when Smith arrived, but I

 6     recall his arrival and his entourage's arrival or his security detail's

 7     arrival, because I talked to them.

 8        Q.   Thank you.  Two other things.  That was the only occasion you saw

 9     Vinko Pandurevic at Boksanica, wasn't it?

10        A.   Yes, that was the only occasion.  I knew him by sight as the

11     commander of the Zvornik Brigade, and this is why I recognised him.  But

12     this was the only time that I saw him at Boksanica.

13             MR. HAYNES:  Mr. Jovanovic, thank you very much.

14             JUDGE AGIUS:  Thank you.

15             No one else from the Defence teams?  None.

16             Mr. McCloskey.

17             MR. McCLOSKEY:  Mr. President, this is -- all this information is

18     brand new to me.  I have about a maybe ten-line report on this.

19             JUDGE AGIUS:  Of how much importance is it?

20             MR. McCLOSKEY:  The locations and flights of General Mladic,

21     these are very important areas, potentially.  And when I study them, I'll

22     have a chance to cut the wheat from the chaff.  And we're not going to

23     finish today, anyway.

24             JUDGE AGIUS:  He'll stay here and come back Monday.  I mean,

25     there's no --

Page 33926

 1             MR. McCLOSKEY:  That's fine with me, Mr. President.  I don't know

 2     why I don't have a proofing note.  I don't know why all this information,

 3     orders to Vinko Pandurevic, didn't come to us.  I'm at a loss.  But if

 4     I can have --

 5             JUDGE AGIUS:  Okay.  Go for half an hour, and then we'll continue

 6     Monday.

 7                           [Trial Chamber confers]

 8             JUDGE AGIUS:  Can you at least proceed with part of your

 9     cross-examination today or not?

10             MR. McCLOSKEY:  I was going on that you'd said we were stopping

11     at 3.00.

12             JUDGE AGIUS:  At 3.00, 3.15.

13             MR. McCLOSKEY:  I would prefer to do it all at once so I can

14     study it.  I'm completely unprepared, I've got to tell you.

15             JUDGE AGIUS:  Then if you can check, what's our schedule Monday,

16     morning or afternoon?  I think it's in the morning.

17                           [Trial Chamber and registrar confer]

18             JUDGE AGIUS:  It's in the morning.

19             We'll continue Monday morning at 9.00.  Thank you.

20                           [The witness stands down]

21                           --- Whereupon the hearing adjourned at 2.45 p.m.,

22                           to be reconvened on Monday, the 6th day of July,

23                           2009, at 9.00 a.m.