Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15324

 1                           Tuesday, 6 December 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.19 p.m.

 5             JUDGE ORIE:  Good afternoon to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.

 8             This is case number IT-03-69-T, the Prosecutor versus

 9     Jovica Stanisic and Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             I'd like to deal with a few procedural matters before we start

12     with the examination of the witness.  First, for Witness Grekulovic no

13     public summary is yet available and therefore should be filed, or has it

14     been filed meanwhile?

15             MR. JORDASH:  I thought it had been filed but we'll take of that

16     straight away.

17             JUDGE ORIE:  It could be that this is -- my list is not updated.

18     I hadn't checked it just prior to the session.  Could the

19     Stanisic Defence already inform the Chamber whether Witnesses DST-071

20     and 081 are to be dropped or whether you maintain them on your list.

21             MR. JORDASH:  We maintain them on the list but with this

22     indication that DST-081 is most unlikely to come.  We, to be frank, have

23     not been able to contact him for some time, so we are not expected him to

24     come but I would just like to keep the option open in case he makes a

25     reappearance which he has an inclination to do.  DST-071 we are checking

Page 15325

 1     what precise date he is available.  We expect him to come.

 2             JUDGE ORIE:  Yes.  May I then already invite the other parties to

 3     either start thinking about the giving of evidence out of turn.  I think

 4     the Prosecution was not very much in favour of allowing witnesses to give

 5     their evidence out of turn.  We do not know, of course, when witness

 6     DST-071 is expected to appear, but is there anything you would like to

 7     say about it, Mr. Groome.

 8             MR. GROOME:  Your Honour, obviously our preference would be that

 9     the Stanisic case finishes, but we have, I think, demonstrated our

10     flexibility if there is compelling reasons that that should not be the

11     case.

12             JUDGE ORIE:  And the Simatovic Defence.

13             MR. BAKRAC: [Interpretation] Your Honours, the Defence of the

14     accused Simatovic is in the same position as the Prosecution.  We would

15     like the Stanisic case to be completed, but if that is impossible, then

16     we are prepared to bring our first witness next week.

17             MR. JORDASH:  Just to remind Your Honours, when we spoke to

18     the -- this particular witness, last he said January was the earliest he

19     could come, so we are anticipating that he will commit to January.

20             JUDGE ORIE:  Okay.  We'll further follow this up.  Then I think

21     the OTP would like to have its submissions and requests on the dead-lines

22     for the Stanisic Defence bar table motions, to have them on the record.

23     I refer to an e-mail sent, I think it was on the 29th of November -- sent

24     by Thomas Laugel to many others, in which, and I try to summarise,

25     Mr. Groome -- in which the Prosecution insists on the Stanisic Defence

Page 15326

 1     following the procedure for bar table motions as the procedure as set out

 2     in the Chamber's guidance, guidance given on the 19th of February, 2010,

 3     and the 5th of July, 2010, for the filing of the bar table motions.  It

 4     mainly being that the appropriate practice is that bar table motions

 5     should be made as joint submissions including the comments of both

 6     parties as to the relevance and authenticity of the charge, and in

 7     relation to that, after having set out that the Prosecution has followed

 8     this guidance, the Prosecution requests that one week per 100 documents

 9     should be given to prepare the comments.  And apart from that, your

10     request that the present portions of the unredacted requests for

11     existence and the responses, that these pertinent portions would be

12     provided to the Office of the Prosecution.  And the last part of the

13     request is that the request itself be put on the record, and even an

14     offer to do it if the Chamber would so request.  I think I summarised the

15     basics of the requests; is that correct?

16             MR. GROOME:  Yes, Your Honour, with one exception.  It's only the

17     pertinent portions of the RFA that we are requesting.  It's not the RFAs

18     in total but simply the portions that are necessary for us to valuate the

19     document.

20             JUDGE ORIE:  Yes, the pertinent portions of the unredacted RFA

21     requests and responses.  That's ...

22             Mr. Jordash.

23             MR. JORDASH:  This is what we are doing, but we would ask that we

24     be able to do it in the timetable indicated by Your Honour, which is, I

25     think the 15th for the first two and then the 9th of January for the

Page 15327

 1     third.  That's --

 2             JUDGE ORIE:  I have the first draft, so the first tables already

 3     being presented.

 4             MR. JORDASH:  Not the tables but the list of the documents for

 5     the first and the second have been supplied to the Prosecution.

 6             JUDGE ORIE:  Yes.  That's how many documents?

 7             MR. JORDASH:  Off the top of my head I'm not sure, but it's

 8     probably -- it's probably about 600, I think.

 9             JUDGE ORIE:  Yes.  And when they were provided?

10             MR. JORDASH:  The first was -- the first was provided last week

11     and I think the second was provided yesterday ... [overlapping speakers]

12             JUDGE ORIE:  Which means for 600 documents --

13             MR. JORDASH:  Yes.

14             JUDGE ORIE:  -- that's approximately six weeks, one week per 100

15     documents, and then looking at the time-limits, I don't know which parts

16     should appear in the December portion.  If that's more than 200, then it

17     might not be easy to -- for the Prosecution to --

18             MR. JORDASH:  It is more than 200.  That's the larger document, I

19     think.  The larger list.  Le me just try to get the numbers.

20             MS. MARCUS:  Your Honours, if I may.

21             JUDGE ORIE:  Yes, Ms. Marcus.

22             MS. MARCUS:  Thank you.  The list is not helpful because the list

23     is only a list of 65 ter numbers.  It doesn't include any information

24     about origin or authenticity or relevance.  So for us to respond to that

25     is not possible.  So what we are -- what we were talking about is not --

Page 15328

 1     and, by the way, the list also has changed so they submitted it and then

 2     they made several revisions, which I understand they are working on it,

 3     so that's not the problem, but the problem is that the 100 documents per

 4     week would be from the moment that we receive the table, that includes

 5     the information about origin, authenticity and relevance, then we can

 6     begin our own review.

 7             JUDGE ORIE:  Mr. Jordash, the lists not providing the necessary

 8     relevant information, it's one; and the second is the numbers and the

 9     time the Prosecution would have available to prepare its comments.

10             MR. JORDASH:  That's right, the list doesn't contain that

11     information.  That's the time-consuming part.  I understood from the

12     discussion in the court last week that by providing a list that would

13     give the Prosecution a head start they would be able to look at the

14     documents, many of which are from their own 65 ter list, in fact, I would

15     say a good 50 per cent are -- and if not more, and be able to say whether

16     they accept origin and relevance, which is, on the face of many of the

17     documents, quite clear.

18             JUDGE ORIE:  Ms. Marcus, if they were on your own 65 ter list,

19     then perhaps it's less troublesome.

20             MS. MARCUS:  Your Honours, for those documents that are from our

21     65 ter list, I would agree.  We would like to know what the relevance is

22     so that we can express our position, but I agree with that for our 65 ter

23     list.  For those that are their 65 ter documents, however, we would

24     definitely need the additional information before we review, otherwise we

25     are doing a review of the documents twice.

Page 15329

 1             JUDGE ORIE:  Yes.  So I do understand, Mr. Jordash, that, as you

 2     said, that's -- what we are doing at this moment is correct and at the

 3     same time it's done at such a pace and with such timing that joint

 4     filings to be received by the Chamber - when was it - the first, on the

 5     15th of December, I think, is almost impossible.

 6             MR. JORDASH:  Well, I hadn't understood that that was the

 7     dead-line, that we had to do a joint filing on that date, but that might

 8     be my misunderstand but --

 9             JUDGE ORIE:  But bar table motions are to be filed and the format

10     as found in the guidance by the Chamber, isn't it?

11             MR. JORDASH:  Well, yes, I mean --

12             JUDGE ORIE:  I mean, what for us to do, to have a bar table

13     motion which is incomplete and no one, the Chamber, of course, is --

14     want -- wants to know what is in evidence.

15             MR. JORDASH:  Yes.  It was only my understanding that we had

16     to -- like I say, I might have misunderstood this but it was my

17     understanding that we had to provide the relevant charts to the

18     Prosecution on those dates.  We are -- everybody on the team other than

19     myself and an intern is working on it.  And they are working seven days a

20     week to get it done.  I mean, it really is an impossible task to do it

21     any faster.  But everybody is planning to finish off the year in a rather

22     unpleasant way to get this finished.  The volume is massive and we are

23     doing what we can.  There's simply no more resources to call upon to do

24     it.

25             JUDGE ORIE:  We'll further consider it.

Page 15330

 1             Mr. Jordash, you have raised a few matters last week about the

 2     health of Mr. Stanisic.  The Chamber staff has followed up with you and

 3     one of the consequences of this follow-up was that you suggested eight

 4     questions to be put to the reporting medical officer.  The Prosecution

 5     has not objected to these questions and the Chamber will ask OLAD to

 6     instruct the reporting medical officer to address these questions in his

 7     next weekly report, and there is a possibility that we would add one or

 8     two questions to those.

 9             MR. JORDASH:  Your Honour, yes.  I can inform Your Honours that

10     Mr. Stanisic's new treatment commenced yesterday.  He was taken to the

11     Bronovo hospital and provided with the new medication, and, so, to that

12     degree there's been some resolution.

13             JUDGE ORIE:  Yes.  And one question, therefore, is:  Does it need

14     an answer anymore, is it?  When does the -- I think that was one of the

15     questions [overlapping speakers] --

16             MR. JORDASH:  Yes, that has been dealt with.

17             JUDGE ORIE:  [Overlapping speakers]...  new medication.  One of

18     the -- one of the additional questions for me would be:  I've got no idea

19     what exactly the reasons are that this medication has to be started in

20     hospital rather than in another situation, whether there's -- whether

21     this has any effect on Mr. Stanisic's health.  Again, I'm not

22     interesting -- interested in the details, but if the start of the

23     medication -- how to administer the medication, if that's to be done in

24     hospital, of course, the immediate question is whether this has any

25     effect on -- if only temporarily, on his well-being.

Page 15331

 1             MR. JORDASH:  Yes.  I can perhaps cast a little light in that

 2     Your Honours may recall last year the beginning of similar treatment and

 3     a reaction in the UNDU, and I -- I'm supposing but I don't know that

 4     because the treatment is similar, although different, that caution has

 5     been exercised this time and he receives [overlapping speakers] --

 6             JUDGE ORIE:  Yes.  Rather to -- so then the main reason would be

 7     not the way in which the medication is administered, but rather to

 8     monitor very carefully and from very closely the possible effect of the

 9     new medication when administered for the first time.

10             MR. JORDASH:  Could I just take a moment.

11             JUDGE ORIE:  Yes.

12             MR. JORDASH:  Yes, I think that's the case, to monitor the two

13     new medication that he has taken and I think the reaction he had last

14     year was at the beginning and so the recommendation is now to have the

15     monitoring at the very beginning.

16             JUDGE ORIE:  Yes.  And since it started yesterday, any specific

17     matter to report, or at this moment --

18             MR. JORDASH:  No, my co-counsel saw Mr. Stanisic today and he

19     seemed to be in much finer form.

20             JUDGE ORIE:  That's good to hear anyhow.  That's ...

21             Then I move on to the next item.  Serbia has requested

22     transcripts of the 21st of November.  The request was to be provided for

23     the transcripts of the 54 bis hearing of the 21st of November, and first

24     of all, most of this hearing was held in public session and is,

25     therefore, available on the Tribunal's website, but there are also two

Page 15332

 1     private session parts, and the Registry is hereby instructed to provide

 2     Serbia with these parts, these parts being transcript pages 15022,

 3     line 24, until 15031, line 22.  That was the first portion.  And the

 4     second being 15052, line 19, up to 15057, line 24.  And the Registry is

 5     also instructed to inform the Republic of Serbia of the Chamber's

 6     decision I just rendered.

 7             I put on the record some developments in relation to the Brown

 8     expert report.  The Stanisic Defence had requested that the dead-line for

 9     Friday, Mr. Brown's report, was moved to the 15th of December, 2011.  The

10     Prosecution had also requested to be provided with the draft report but

11     as no such draft report is in the Stanisic Defence's possession, the

12     Chamber denied that request.  Perhaps unnecessary to add to this,

13     Mr. Jordash, that the Trial Chamber was not really amused to receive a

14     request for an extension of time on the very day the dead-line expired.

15             MR. JORDASH:  No, and we apologise for that.  We did our best to

16     contact the expert but couldn't.

17             JUDGE ORIE:  Yes.  It's quite amazing these days that you can't

18     get hold of someone for such a relatively long period of time in this

19     modern times where communication seems to be possible every minute of the

20     day, every day of the week.  I'm not blaming you for it, but if you can't

21     make a dead-line, then perhaps you should make yourself a bit better

22     available for those who may want to inquire into that, meeting the

23     dead-line.

24             Then the next and the last one on my list, the Stanisic Defence

25     has urgently requested provisional release for Mr. Stanisic.  Are you

Page 15333

 1     considering to request leave to reply, Mr. Jordash?

 2             MR. JORDASH:  No, thank you.

 3             JUDGE ORIE:  Mr. Groome.

 4             MR. GROOME:  Your Honour, I am not sure whether the Chamber

 5     inadvertently omitted to give its ruling with respect to the Brown

 6     report, but having spoken about it, I don't see on the record any

 7     decision with respect to that extension request.

 8             JUDGE ORIE:  I think we moved to the 15th but we'll check where

 9     exactly is to be found, Mr. Groome, and if we only agreed without

10     informing the parties in an appropriate way then we'll correct that as

11     and as possible.

12             I have no further procedural matters on my list.  Is the ... is

13     the Stanisic Defence ready to continue its cross-examination of witness

14     Milovanovic?

15             MR. JORDASH:  Yes.

16             JUDGE ORIE:  Then could he be escorted into the courtroom.

17                           [The witness entered court]

18             JUDGE ORIE:  Good afternoon, Mr. Milovanovic.  I would like to

19     invite you to --

20             THE WITNESS: [Interpretation] Good afternoon.

21             JUDGE ORIE:  -- make a solemn declaration that you'll speak the

22     truth, the whole truth, and nothing but the truth.

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

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

25                           WITNESS:  MANOJLO MILOVANOVIC [Resumed]


Page 15334

 1                           [Witness answered through interpreter]

 2             JUDGE ORIE:  Thank you, Mr. Milovanovic.  Please be seated.

 3             THE WITNESS: [Interpretation] Thank you.

 4             JUDGE ORIE:  Mr. Milovanovic, you are not here for the first time

 5     in this case.  It was developments that happened after you testified

 6     which caused the parties to call you back to further examine you on

 7     matters which were not already available at the time of your examination

 8     in April 2001 [sic].  You'll first now be further cross-examined by

 9     Mr. Jordash, and as you know by now, Mr. Jordash is counsel for

10     Mr. Stanisic.

11             Mr. Jordash, are you ready?  Mr. --

12             MR. GROOME:  Your Honour, just so there's no confusion and this

13     witness has testified in other cases, I believe you misspoke when you

14     said "2001," you meant "2010" --

15             JUDGE ORIE:  I intended to say 2010, as a matter of fact, that I

16     said April, I think I added, and it was April 2010, so that's what I had

17     on my mind.  And I talked about in this case.

18             Mr. Jordash, are you ready?

19             MR. JORDASH:  Yes, thank you.

20                           Further Cross-examination by Mr. Jordash:

21        Q.   Good afternoon, Mr. Milovanovic.

22        A.   Good afternoon.

23        Q.   You were given a number of files, I hope, yesterday.  Did you

24     have an opportunity to read through them.  I know there was quite a lot

25     to get through.

Page 15335

 1             JUDGE ORIE:  Could I perhaps -- Mr. Milovanovic, the Chamber is

 2     aware that you asked for a postponement of your testimony so that you

 3     could read it all.  We have decided that we would start with your

 4     examination even if you would not have read it all, so, therefore, don't

 5     feel guilty in any way of not having digested, which, as far as was

 6     reported to the Chamber, which seems to be quite a lot of material.  But

 7     perhaps you answer the question of Mr. Jordash.

 8             THE WITNESS: [Interpretation] May I be heard, please.  Already in

 9     Banja Luka I learned that there would be some materials waiting for me

10     here.  They asked me if I wanted the materials to be on a CD or on paper,

11     and I requested a hard copy.  Yesterday when I arrived there were three

12     binders waiting for me, 400 pages long.  I managed to go through one

13     until 11.00 in the evening.  I went halfway through the second one and I

14     did not even manage to open the third one.  I'm telling you this just so

15     that you know what I've been able to read.  The first one I read through;

16     the second one-half way; the third one I didn't even touch because, well,

17     it was physically impossible to go through all of them.

18             MR. JORDASH:  Thank you.

19        Q.   And thank you very much for the effort.  I'm sorry to have put

20     you under such time constraints.  Let's see where we can get to.  First

21     of all, before I return to the Mladic diaries, let me just indicate what

22     I would like to do, which is, in the main, take you through some of the

23     Mladic diaries and see if you have any knowledge of certain things

24     described in there, and see if you are able to elaborate on some of the

25     things that are in there.  That's going to be the principal focus.

Page 15336

 1             Before we turn to the diaries, could I just ask you, though, to

 2     look at a map which has been prepared.

 3             MR. JORDASH:  Please, could we have on the screen 1D05282.

 4        Q.   And what is going to come on the screen is a map with four

 5     locations marked.  And for your information, these are the locations of

 6     airfields which were referred to in the combat readiness and activities

 7     of the Army of the VRS in 1992 dated April of 1993.

 8             Now, as you look at that map, am I correct that you had a --

 9     played a role in drafting the combat readiness and activities analysis of

10     the VRS in 1992?

11             MR. JORDASH:  Which is, Your Honours, P386.

12             THE WITNESS: [Interpretation] May I?

13             MR. JORDASH:

14        Q.   Yes, please.

15        A.   As I'm looking at the map, I can see four airports:  Mahovljani,

16     which is an airport where combat aircrafts and helicopters were based;

17     next to it, in the direction of Banja Luka some 20 kilometres away, is

18     Zaluzani airport.  This airport was built before the war.  It was a

19     military airport and during the war this was a helicopter base; Prijedor

20     airport is exclusively a sports airport.  It still exists, and it is

21     intended for smaller aircraft, for example, a Cessna.  It was not a

22     combat airport; and then Bratunac airport is also a sports airport.  It

23     belongs to an -- a club.  During the war it was an auxiliary airport and

24     it could be used for combat activities but for very special aircraft;

25     there is another auxiliary airport missing from the map.  Before the war,

Page 15337

 1     the name of that airport near Glamoc was Ivo Lola Ribar and during the

 2     war we referred to it as only Glamoc airport and this was intended for

 3     forcible take-offs and landings of aircraft.

 4        Q.   Could I ask you please to indicate with a pen on the map where

 5     that other airport was, please, the one that you just mentioned?

 6        A.   I'm looking for Glamoc.  I can't see Glamoc in this part of the

 7     map.  I think that the map should be moved on the screen to the right,

 8     perhaps Glamoc will be there.

 9        Q.   Perhaps we can save some time, Mr. Milovanovic, and come back to

10     this.  Perhaps during a break we can give you map and you can mark that.

11        A.   Here, in the left bottom corner, there is a village called

12     Crni Lug.  I can no longer see it, actually.  Here it is, Crni Lug.

13     Ticevo and Glamoc should be somewhere around this area known as Nakovanj

14     in Bosnia-Herzegovina, in a valley where I'm pointing with a pen.

15     Currently, Glamoc is in the territory of the Federation of

16     Bosnia-Herzegovina.  It is no longer in the territory of

17     Republika Srpska.  And the second part of your question was whether I

18     participated in the drafting of the analysis of combat readiness for --

19        Q.   Before we move to that, could you just indicate with a round

20     circle the location of the airport that you've referred to, then we can

21     move from that first question.

22             JUDGE ORIE:  Mr. Witness, the right pen -- yes, I see.

23             THE WITNESS:  [Marks]

24             MR. JORDASH:

25        Q.   I can see three lines of pen on the map now.  Which --

Page 15338

 1             JUDGE ORIE:  I think the last one the witness marked is at the

 2     very left of the map.  He first referred to Crni Lug where there is a

 3     small marking, but the biggest marking just on the -- the one closest to

 4     Prijedor, south of Prijedor, is the one he marked as the location of the

 5     airport, I think.

 6             MR. JORDASH:  Thank you.

 7        Q.   Yes.  And the second question was:  Did you participated in the

 8     drafting of the combat report?

 9        A.   I was the Chief of the Main Staff during the war and all combat

10     reports and all the analysis of combat readiness had to go through the

11     staff, which means that I participated in the drafting of all those.

12        Q.   Right.  Thank you.  These five airfields, were these the five

13     airfields that were used by the VRS during the conflict in Bosnia?  Were

14     there any others that you were aware of?

15        A.   Prijedor airfield was not used in combat or for combat, I already

16     stated that.  Bratunac airport was used in the course of 1992, during the

17     first few months of the war, and only for propellor aircraft, and an

18     airfield near Glamoc was an auxiliary airport which was not used for

19     combat.  However, if the air force was active in Herzegovina and could

20     not reach Banja Luka this is where they would land to refuel.  For

21     example, aircraft of a Jastreb type with could not fly as far, whereas

22     the aircraft of Orao type could fly even further.  In any case,

23     Mahovljani airport was used for landing and take-off of air force.  And

24     let me just tell you that the air force of Republika Srpska was used

25     during the first part of -- first few months of the war after the

Page 15339

 1     decision was reached by the international community in London sometime in

 2     October 1992.  And then the air force was landed forever, we discussed

 3     the possibility of dismantling our air force or perhaps move it to

 4     Yugoslavia, and we decided that it would remain in Mahovljani but that it

 5     would be permanently grounded.

 6        Q.   Thank you.  You've asked a question or some questions that I was

 7     going to ask you.  Just so that we are clear, were there any other

 8     airfields which were in any way used by the VRS in relation to either

 9     combat supplies, or humanitarian supplies before the air force was

10     grounded?

11        A.   A sports airport existed in the vicinity of Bijeljina.  I don't

12     remember that it was ever used for combat, just like the one near

13     Prijedor.  I don't remember any other airfields.  The commander actually

14     transferred all the issues with -- regarding the use of air force to me

15     as his deputy.  We started building an airfield in Podromanija, at the

16     crossroads of roads between Rogatica, Sokolac and Pale.  But the land was

17     just marked and that was the end of all the works, and that's how the

18     situation is even today.

19        Q.   And so that never started operating; is that correct?

20        A.   It was never built.  It was never used, therefore.  It was only

21     designed.  I suppose that was an attempt on the part of the government of

22     Republika Srpska to compete with the Federation because the Federation

23     has two airports, one in Sarajevo the other in Tuzla, so I suppose that

24     the government of Republika Srpska wanted to build their own, but it is

25     by no means an easy task to build a fully operational airport.

Page 15340

 1        Q.   And each of the airfields that you referred to as being used by

 2     the VRS were under the - let me put it differently -- were owned and

 3     secured and used by the VRS; is that correct?

 4             THE INTERPRETER:  Could all unnecessary microphones please be

 5     switched off.  Thank you.

 6             THE WITNESS: [Interpretation] Only Mahovljani and Zaluzani

 7     airports and the auxiliary airport near Glamoc.  They were under the

 8     military administration.  Zaluzani airport before the war belonged to the

 9     JNA, but it was slowly abandoned after Mahovljani airport was constructed

10     because Mahovljani airport was a combined airport for military and civil

11     aircrafts.  Since civil aircrafts disappeared at the beginning of war in

12     the territory of modern Republika Srpska, Mahovljani remained exclusively

13     a military airfield.

14             MR. JORDASH:

15        Q.   Thank you.  When the no-fly zone was imposed by the

16     United Nations, your, as you've said, air fleet was grounded.  Am I

17     correct that the only flights thereafter in VRS territory were

18     helicopters being used to air-lift wounded from the front lines to

19     hospitals?

20        A.   When no-fly zone was imposed, medical helicopters were excluded

21     from the decision.  They had to be clearly marked with a red cross.  And

22     also we were allowed to transport materials but all such flights had to

23     be previously announced with UNPROFOR.  I know that immediately after the

24     decision was made in London, UNPROFOR placed its monitors in Mahovljani

25     airport to observe the no-fly zone agreement.

Page 15341

 1        Q.   Thank you.  When was the no-fly zone imposed and when did it

 2     become effective in the way you've just described?

 3        A.   Discussions about imposing the no-fly zone on Republika Srpska

 4     started in October 1992.  And I believe that on the 31st of March, 1993,

 5     a resolution of the Security Council was passed and according to that

 6     resolution, the decision was implemented.  I don't remember the number of

 7     the resolution, but I know that it became effective on the

 8     31st of March, 1993.  And that decision also prescribed all the other

 9     possible uses of aircraft.

10        Q.   Thank you.  Let me move to another subject.  I just want to touch

11     on your interaction with Mladic so we can understand perhaps a little

12     more about these notebooks.  When you were first promoted, you - is this

13     right? - went to the Assembly of the RS on the 12th of May with Mladic;

14     correct?

15        A.   What rank do you have in mind when you have that I was promoted

16     into a rank?  What rank would that be?

17        Q.   Well, I'm asking you about what happened on the 12th of May when

18     you went to Banja Luka and you were promoted; is that right?

19             MR. GROOME:  Could we have a year, please.

20             MR. JORDASH:

21        Q.   1992, sorry.  Major-general.

22        A.   I became major-general on the 26th April 1992.  At that time I

23     was in Nis.  And then pursuant to an order, I was transferred to the

24     2nd Military District in Sarajevo on the 8th of May, 1992.  However, I

25     never arrived in Sarajevo.  I arrived in Han Pijesak on the

Page 15342

 1     11th of May, 1992.  And that same afternoon I met with Mladic and the

 2     other members of the future Main Staff.  On the 12th there was a session

 3     of the Assembly in Banja Luka which I did not attend, and thank you for

 4     the materials that you left with me yesterday, it was only last night

 5     that I managed to read Mladic's speech at that session of the Assembly.

 6     General Mladic, Colonel Tolimir, Colonel Gvero and General Djukic went to

 7     that session which means that almost all Mladic's assistants but me went

 8     there, and I stayed behind to organise the work of the Main Staff.

 9             On the eve of that day we assembled for the first time, so I was

10     told to organise communications with our subordinated units that we had

11     at the time and to start receiving reports from the field.  Effectively,

12     on the 12th of May, the war actually started for the Serbs in

13     Bosnia-Herzegovina.

14             JUDGE ORIE:  I got the impression that you wanted to know whether

15     the witness went with Mr. Mladic on the 12th of May to the Assembly.

16     I've approximately two and a half minutes of information which seems to

17     be a long no-answer, we know what he did all this time.  Could you please

18     try to keep the witness to what you really want to know.

19             MR. JORDASH:  Sorry.

20             JUDGE ORIE:  Yes.  Perhaps you said you didn't attend the 12th of

21     May Assembly session, Mr. Milovanovic.  Did you go together with

22     Mr. Mladic on that day to Banja Luka where that -- was it in Banja Luka

23     that the Assembly was held?  Yes.  Did you go with Mr. Mladic to

24     Banja Luka on that day?

25             THE WITNESS: [Interpretation] I did not.

Page 15343

 1             JUDGE ORIE:  Then in your previous answer, if you just have

 2     answered I didn't go to the Assembly session, I didn't go to Banja Luka

 3     on the 12 of May, that would have been one line where we now read 20

 4     lines; perhaps useful information, I do not know, perhaps Mr. Jordash

 5     knows, but certainly not an answer to the question.

 6             Please proceed.

 7             MR. JORDASH:

 8        Q.   You mentioned there in your answer that you were left behind and

 9     were left behind, in part, to take charge of establishing communication

10     with subordinate units.  Was that a task which was yours from that time

11     onwards in 1992 and 1993?

12        A.   Chief of any staff is always responsible for the functioning of

13     communication in any military.

14        Q.   Did you understand that in that role you were to pursue certain

15     VRS goals, one of those goals being to protect the Serb people and

16     territory, and the other was to deal with paramilitaries, to name just

17     two for the moment?

18        A.   Yes.

19        Q.   And which subordinates would report directly to you in that role?

20        A.   When it comes to the establishment of communication, the person

21     responsible and who reported to me was Colonel Radomir Role a member of

22     the Main Staff.  As for the paramilitaries, the entire Main Staff was

23     responsible, including the commander.  I was the one who drafted orders

24     and submitted them to subordinated officers, and in the field it was the

25     commanders in every particular area that were responsible for that.

Page 15344

 1        Q.   Thank you.  Were you told by Mladic at this point in time that

 2     the VRS consisted of about 80- to 90.000 personnel with arms?

 3        A.   Yes.

 4        Q.   In terms of how often from that time onwards you saw Mladic, did

 5     you have meetings with him on a daily basis?

 6        A.   In Crna Rijeka where the Main Staff was based, Mladic and I

 7     shared an office due to the scarcity of space.  We practically shared one

 8     desk, we had two chairs, which means that we saw each other every day

 9     when he was in the office because we worked in the same office.

10        Q.   And you would have morning meetings which would be attended by

11     Mladic and certain commanders and their assistants; is that correct?

12        A.   Every morning between 6.00 and 7.00 the Main Staff received

13     reports from subordinates.  It would be either General Mladic or myself

14     who received them.  And then from 7.00 onwards we had our regular

15     Main Staff briefings.  And we also had meetings of the inner Main Staff

16     which means Mladic and the seven of us assistants.  We analysed the

17     developments that took place the previous days and we made plans for the

18     following day, which means that we met twice a day.  If Mladic was there,

19     he would head those meetings.  If he was absent, it would be myself, and

20     vice-versa.

21        Q.   So you would receive daily combat reports from subordinated units

22     from within VRS territory on a daily basis?

23        A.   Yes, we received those reports before 2000 hours.  However, since

24     the reports provided an overview of the situation as of 1700 hours, the

25     commander of the brigade would submit reports to the corps commander.

Page 15345

 1     The corps commander would read reports from all the brigades, and then he

 2     would compile his own report for the Main Staff, and then the

 3     subordinated commanders reported by telephone after 2200 hours to provide

 4     updates on the written reports.  Based on those reports, the Main Staff

 5     had to submit a written combat reports of the Army of the

 6     Republika Srpska to the Supreme Command or the supreme commander,

 7     President Karadzic, before 2400 hours each day.

 8        Q.   And just so we are clear, you would receive reports about the

 9     full range of VRS activities and activities within VRS territory; is that

10     correct?

11        A.   Yes.

12        Q.   Including logistics, personnel issues, training issues, combat

13     operations?  You received reports on all of those things on a daily or

14     regular basis; correct?

15        A.   Yes, yes.  There is a regulation based on which reports are

16     compiled.  The first set of information is on the enemy.  The second part

17     is on what the subordinated corps did, what the plans are for the

18     following day, the following part is about issues and problems.  I

19     believe that there were seven different items to cover and the last item

20     would be requests upon the superior command regarding fuel, ammunition,

21     and similar things, as well as report on casualties, i.e., the number of

22     wounded, the number of missing, the number of dead.

23        Q.   Thank you.  And in terms of Mladic and his note-taking, how

24     regular did it seem, to you at the time, that he was taking notes?

25        A.   I think I spoke about that even the last time.  Every officer,

Page 15346

 1     when he graduates from the military academy and comes to a unit, receives

 2     a so-called work notebook where he writes every day the tasks that he had

 3     been given so as not to forget anything more important that happened in

 4     his unit especially if he commands the unit, as every clerk would do, and

 5     it's not just a habit but an obligation of every officer to keep notes.

 6     Mladic and I did the same, although we shared a desk, and every soldier

 7     in the Army of Republika Srpska did the same.  Those are not war diaries.

 8     It's something different.  Those are notes that helped remind you of a

 9     task you received or a proper way to solve a problem.

10        Q.   So that's what we are talking about in relation to the Mladic

11     diaries that you've seen -- that you saw on this here before coming to

12     court today, and also that you looked at when you attended this trial

13     before?  We are talking about his -- sorry, Mr. Groome is on his feet.

14             JUDGE ORIE:  I do not know whether Mr. Groome wants to wait until

15     you have finished your question or whether -- Mr. Groome, is that ...

16             MR. GROOME:  Well, now that -- I am sorry to have interrupted,

17     but I think there's a risk of confusion.  I think the witness's last

18     answer shows this.  There are two documents:  One is called "notebooks"

19     and one is called "diaries."  The books that have been given to the

20     witness, I believe, I have not seen what was given last night, but are

21     notebooks and not diaries.

22             MR. JORDASH:  That is what I was about to ask the witness just to

23     clarify that.  Yes, and the witness is nodding.

24        Q.   So the Mladic material that you've looked at, that we are all

25     talking about, are his personal notebooks from what you can see from

Page 15347

 1     looking at them?

 2        A.   Yes.

 3        Q.   And did you notice then with him a continuous habit of writing in

 4     this notebook?

 5        A.   Well, I didn't have to notice it during the war but I did see

 6     those notebooks when they were given to -- for me to see in court, and I

 7     had to see that he apparently did it every day.

 8        Q.   Well, that's not my question.  My question is:  Did you notice

 9     him doing it?  Would you have noticed if he had stopped doing it?

10             JUDGE ORIE:  Let's take it step by step, is it, Mr. Jordash.  Did

11     you see Mr. Mladic on a regular basis writing in his notebook?

12             THE WITNESS: [Interpretation] Yes, I did.  I saw him either

13     writing in it or reading from it.  If he had prepared for a meeting in

14     advance then he always did that in that work notebook and from it he

15     would read to us the tasks that he was going to give us.  And if he

16     wasn't reading, he was writing in it.

17             JUDGE ORIE:  And if you say if he wasn't reading he was writing,

18     did you mean that you saw him writing on a daily basis in those

19     notebooks?

20             THE WITNESS: [Interpretation] Yes.

21             JUDGE ORIE:  Yes.  And as long as you were close to him, you

22     would, therefore, have observed if he would not have done that anymore,

23     of course, if he was away you couldn't observe anything, but did he do

24     this as -- during all the time you were close to him able to observe what

25     he was doing?

Page 15348

 1             THE WITNESS: [Interpretation] Throughout the war, I sat to the

 2     left of Mladic, shoulder to shoulder, and I was always able to see

 3     whether he was writing or not.  And when we were apart he was usually at

 4     a meeting, either at the Supreme Command or somewhere else, or meeting

 5     with a subordinate unit.  And he kept notes everywhere, and on his

 6     return, he would always inform the Main Staff, or if not the Main Staff,

 7     then me, reading from his notebook all the notes that he had taken at

 8     that meeting.

 9             JUDGE ORIE:  Please continue, Mr. Jordash.

10             MR. JORDASH:  Thank you.

11        Q.   Now, I appreciate from what you've told us before that you were

12     not with him during the events in Srebrenica in 1995, during the

13     massacres there; is that correct?

14        A.   Beginning with the 28th of October 1994 until 15 October 1994, I

15     was not with Mladic all the time.  I was in the west in Drvar and

16     Banja Luka, whereas Mladic remained in Han Pijesak and all that happened

17     around Srebrenica.  I was not with him around Srebrenica.

18        Q.   Can you think of any reason, though, why from your communication

19     with him around that time he might not have made any notes about those

20     events?

21        A.   I don't know why he didn't.  I don't remember.  He didn't even

22     talk to me about Srebrenica.  When I returned, it was some sort of secret

23     around the Main Staff.  He didn't discuss it, and whether he had kept

24     notes there, I don't know.

25        Q.   Okay.  Thank you.  Now, before we turn to the diary, I just want

Page 15349

 1     to ask you how you went about in May of 1992 and thereafter subordinating

 2     the paramilitaries?

 3        A.   I think I spoke about that in my last testimony, but I'll repeat

 4     it briefly.

 5        Q.   Mr. -- I don't want you to repeat what you've said, I just want

 6     to know -- let me ask more specific questions.  Was there a clear plan

 7     laid out to subordinate paramilitaries within VRS territory?

 8        A.   No plan was made.  It was a decision of the Main Staff that read,

 9     roughly speaking, I can't quote it verbatim but approximately, call in

10     for a discussion all the commanders of the military forces of the Serbian

11     Republic of Bosnia-Herzegovina -- sorry, of the paramilitary forces, and

12     offer them the following:  to become part of the VRS in their respective

13     territories.  If they do not want to integrate with the VRS because most

14     of these paramilitaries were from outside the territory of

15     Bosnia-Herzegovina, then return to where they came from.  If they want to

16     integrate with the VRS, their fighting men can individually join units of

17     the VRS.  Those who refuse both, that means to leave the BH territory or

18     to join the VRS on an individual basis, will be expelled.  Those who

19     offer armed resistance, will be destroyed.

20             That meeting occurred just after the session in Banja Luka and

21     General Mladic and Tolimir, as chief of the security and intelligence,

22     attended as well as General Gvero, who was in charge of moral guidance

23     and religious affairs.  Major Ljubisa Savic, known as Mauzer, who was

24     commander of the Panthers, a volunteer brigade, integrated the VRS first

25     under the command of the Main Staff, then the Eastern Bosnia Corps.

Page 15350

 1     Arkan with his Tigers refused, and he went back to Serbia, and from there

 2     I don't know where else.  Many border municipalities had their own TO

 3     units established by the ruling party, the SDS.  All of those units, I

 4     believe there were 92 of them, 92 brigades, integrated with the VRS.

 5     There was one group around Zvornik commanded by a certain Zuca and Crni

 6     and Captain Dragan, that I spoke about last time, that did not join the

 7     VRS.  We expelled and arrested those men, broke them up, in any case.

 8             On the 28th of June, an order by the Main Staff was written and

 9     signed by General Mladic, I believe I wrote it personally, and in that

10     order all that we had previously agreed and tried to carry out ...

11        Q.   You said 28th of June, did you mean the 28th of July?

12        A.   June.

13        Q.   Sorry, my mistake.  When do you say, from what you recall, that

14     all -- let me rephrase that.  28th of July -- sorry, 28th of June, 1992;

15     is that correct?

16        A.   Yes.

17        Q.   What date would you suggest was the date when all paramilitaries

18     that remained within Bosnia were fully and finally integrated into the

19     VRS?

20        A.   Which day of the week it was, I don't know, but I know the

21     28th of June is a Serbian religious holiday, Vidovdan, and it's the

22     patron saints day for the VRS.  We had to get legal grounds for breaking

23     up that group around Zvornik and several groups around Sarajevo.

24        Q.   Mr. Milovanovic, I've got a lot of material to get through, so if

25     you could answer more directly, that would be great.  What date do you

Page 15351

 1     say was the date when all existing paramilitaries had left or were

 2     integrated into the VRS?

 3        A.   Paramilitary units started disappearing from the 12th of May

 4     until 28th of June.

 5        Q.   I'm asking quite a specific question.  What date do you say, if

 6     you know, was the date when all existing paramilitaries had left or were

 7     integrated into the VRS?

 8        A.   I cannot give you the date.  Mauzer joined the VRS as soon as he

 9     made a contact with General Mladic.  Now, I don't know when

10     General Mladic, Tolimir or Gvero spoke to the next commander of the

11     paramilitary unit, that is to say Arkan.  At the time when they spoke to

12     Arkan and he refused to join the VRS, he was ordered to leave the

13     territory of Republika Srpska and he did.  I cannot now remember any

14     other paramilitary unit.  After Zuca and Crni around Zvornik were spoken

15     to, they didn't want to leave Republika Srpska either because they were

16     natives of that territory, nor did they want to join --

17             JUDGE ORIE:  Mr. Milovanovic, you are describing the whole

18     history.  The only thing Mr. Jordash asked you is:  Can you give me a

19     date on which those who did not want to be integrated had left and the

20     others had been subordinated, integrated into the VRS.  Can you give a

21     date for that?

22             THE WITNESS: [Interpretation] Your Honour, I can't tell you the

23     date because I don't know when Mladic spoke to each of them.

24             JUDGE ORIE:  The simple answer is no, I can't give you a date.

25     It's as simple as that, Mr. Milovanovic.  Why you can't give a date is

Page 15352

 1     another matter, if Mr. Jordash wants to know, he will ask you, but the

 2     simple answer is:  No, I can't give a date for that.

 3             Please proceed, Mr. Jordash.

 4             MR. JORDASH:

 5        Q.   Thank you.  And just so that we are clear, when you say

 6     integrated into the VRS, integrated means they are subordinated to and

 7     receive their supplies from the VRS, does that sum up what you mean by

 8     integrated?

 9        A.   Yes, they joined and integrated into the VRS in all aspects.

10        Q.   Thank you.

11             MR. JORDASH:  I notice the time, Your Honour.  I don't know --

12             JUDGE ORIE:  Yes, we'll take a break and resume at 4.00.

13                           --- Recess taken at 3.33 p.m.

14                           --- On resuming at 4.04 p.m.

15             JUDGE ORIE:  Mr. Groome, one short observation.  The dead-line,

16     having moved to the 15th of December, was communicated to the parties in

17     an e-mail sent, I think, on the 2nd of December.  It was not put on the

18     record yet.  That's where we stand, I think.

19             MR. GROOME:  Yes, Your Honour, I thought that you meant to when

20     you were discussing it at that time, that's why I didn't see it, that's

21     why I brought to your attention.

22             JUDGE ORIE:  Yes.  It is hereby on the record, and the parties

23     were informed on the 2nd of December in an informal communication by

24     e-mail.

25             Mr. Jordash, we have now -- for a long time we have a marked map

Page 15353

 1     somewhere which is not tendered, I don't know what you want to do with

 2     it.

 3             MR. JORDASH:  May I tender it, sorry.

 4             JUDGE ORIE:  Yes.  Madam Registrar, the number would be?

 5             THE REGISTRAR:  The number would be D559, Your Honours.

 6             JUDGE ORIE:  And is admitted into evidence.

 7             Mr. Milovanovic, could you try to focus your answer on what is

 8     specifically asked.  If we need further explanation, then we will ask you

 9     for further explanation or further details.  So if someone asks you

10     whether you arrive here by a red car, then don't tell us that

11     approximately 10 per cent of the cars are red in the Netherlands and

12     that, apart from being red, it had four tires and that it drove at a

13     speed of, et cetera.  Just answer yes, it was red.  Yes?

14             Please proceed.

15             MR. JORDASH:  Could we have on the screen, please, 65 ter 5599.

16     And page 285 of the English and 293 of the B/C/S.

17        Q.   We are turning now to the Mladic notebooks and I --

18             JUDGE ORIE:  Yes, there has been a discussion on what to show,

19     isn't it?  The handwritten or the transcribed portion, is that ...

20             MR. JORDASH:  Yes, there has.

21             JUDGE ORIE:  Yes.  Now, has that been resolved?

22             MR. JORDASH:  I'm not sure to anyone's satisfaction, but --

23             JUDGE ORIE:  Because under those circumstances, I wonder why we

24     couldn't show both the transcript and the original handwriting and that

25     we consult the English version to the extent we need to do that, then you

Page 15354

 1     have everybody happy, isn't it?  Well, I can't forecast who will be happy

 2     when, but -- if you take a solution-oriented approach, then you don't

 3     quarrel about whether to show A or B but to see whether you can show A

 4     and B so that -- and then of course the problem is that we don't have a

 5     translation, and due to our perfect e-court system, we can have on our

 6     other screen the English version.

 7             MR. GROOME:  That's acceptable to the Prosecution, Your Honour.

 8             JUDGE ORIE:  Yes, and also especially since it's very much date

 9     oriented, if we have the right document, but let's give it a try.

10             MR. JORDASH:  Thank you.  Could we have page 285 and 293.

11        Q.   Which deals, Mr. Milovanovic, with Monday the 11th of May, 1992.

12     And I want to pick up approximately where we left off with the issues we

13     were discussing before the break with a few additional issues as we go

14     along.

15             MR. JORDASH:  One moment, please.  We only have the page

16     references for the typed copies, that's the only problem.

17             JUDGE ORIE:  If you then be clear on dates, then that might

18     assist.  So what we would then prefer to have -- oh, you have only the

19     English transcribed pages.

20             MR. JORDASH:  Yes.  The English and the B/C/S, I beg your pardon,

21     sorry.

22             JUDGE ORIE:  If you have the B/C/S pages and if you have the

23     originals then I wonder -- I don't know whether they go one on one or

24     whether there's ...

25             MR. JORDASH:  The English is approximately one on one with the

Page 15355

 1     B/C/S typed, not always though, unfortunately.

 2             MR. GROOME:  Yes, Your Honour, and in the process in an effort to

 3     make them more easily used they have attempted to file the format of the

 4     handwritten notes to include some of the markings and to include the same

 5     pagination or roughly the same page.

 6             JUDGE ORIE:  Let me now see -- the question is what to show to

 7     whom.  You would like to see the original handwritten version, isn't it,

 8     Mr. --

 9             MR. GROOME:  Your Honour, it's not that we would like to see the

10     original handwritten version.  We thought that Mr. Milovanovic would be

11     aided by seeing the actual original handwritten page because there are

12     certain ways that the notes were written that may also import some

13     meaning into the actual text rather than the cold typewritten text.

14             JUDGE ORIE:  Then you have the page numbers ready, Mr. Jordash,

15     for the English transcript?

16             MR. JORDASH:  For the English and the B/C/S typed.

17             JUDGE ORIE:  Okay.  If you would --

18             MR. JORDASH:  May, perhaps, I could just query one thing, there

19     is a page number on the top of the English typed and there's also a page

20     number on the bottom, I'm wondering if the page number on the top is a

21     number which appeared in the Mladic originals which we might use to guide

22     ourselves.

23             JUDGE ORIE:  Okay.  So let's start with one page and then I'll

24     look at all the three versions and see whether we can --

25             MR. JORDASH:  The page -- the English typed Monday the 11th of

Page 15356

 1     May, 1992, Grmec command post.

 2             JUDGE ORIE:  What page?

 3             MR. JORDASH:  Page 290 at the top.  But at the bottom, the

 4     English page 285 and the B/C/S page 293.  This is the one I can see on

 5     the screen in the English.

 6             JUDGE ORIE:  Let's get started on this.

 7             MR. JORDASH:

 8        Q.   The page, sir, I want to orientate you, Mr. Milovanovic, the 11th

 9     of May, and the Grmec command post, and I want to then turn to page 296

10     of the English and 304 of the B/C/S where Colonel Kovacevic is, or may

11     be, speaking, according to the notes.  This is the part of the same

12     meeting according to the date, or certainly, this is the date which

13     precedes the comments purportedly made by Colonel Kovacevic.

14             MR. JORDASH:  If we could go to page 296 of the English and 304

15     of the B/C/S, please.  I don't know if it's then possible to find the

16     original handwritten and perhaps if we --

17             MR. GROOME:  If I can be of some assistance.  The number at the

18     top of the page, Mr. Mladic numbered the pages in his notebooks so that

19     301 would correspond to the number page.  If you indicate which notebook

20     you are referring to, that page will be -- 301 will be the same page in

21     the original.

22             MR. JORDASH:  Well, it's 5599.

23             JUDGE ORIE:  Yes, there we have the one, and that is ...

24             MR. JORDASH:  If I then refer to both the number at the top and

25     the --

Page 15357

 1             JUDGE ORIE:  I would suggest that the numbering is relatively

 2     close.  For example, the English translation page 301 appears on a page

 3     which at the bottom reads 296, so very close.  If we try to orient

 4     ourselves very much on the numbering as we find it at the top of the

 5     pages in the original, which is reflected at least in the English, but

 6     let me have a look, I would say -- yes, 301, the numbering of the pages

 7     as written by the author do also appear both in the English version and

 8     in the -- and in the B/C/S version of the transcript.  So I suggest that

 9     we work then -- you can choose your page if you know which page to

10     choose, and then we'll have a look at the handwritten reference.  For

11     example, for page 301, that would be in the B/C/S transcript, is 304 out

12     of 406.  So it's all within a range of a couple of pages.

13             MR. JORDASH:

14        Q.   If you would read that entry just quickly, you probably have.

15     Did you know Colonel Kovacevic?

16        A.   Yes.

17        Q.   Was he responsible for weapons distribution, do you know, in the

18     ten months before this entry, as he apparently appears to have said?

19        A.   I don't know.  Ten months before this entry, I was in Skopje.

20        Q.   What about when you came into the Main Staff?

21        A.   When I came into the Main Staff, Kovacevic was appointed deputy

22     to General Djukic, who was assistant commander for logistical support.

23        Q.   Did you know what his previous history was in any way?  Is there

24     anything here which you would disagree with or have knowledge that would

25     make you disagree with his comments?

Page 15358

 1        A.   I met Kovacevic for the first time that evening on the

 2     11th of May and I knew about him only what General Mladic told us about

 3     each one of us, including General Kovacevic.

 4        Q.   How long did Kovacevic maintain his position as assistant

 5     commander?

 6        A.   He was deputy assistant commander.  He was not assistant

 7     commander.  He stayed there for a few months and then moved to another

 8     position to become minister of defence.

 9        Q.   Was Djukic and -- well, was Djukic responsible for the

10     distribution of weapons to the VRS during your time in Bosnia?

11        A.   General Djukic was responsible for procurement of weapons.  I was

12     responsible for distribution.

13        Q.   What did it mean to be responsible for distribution?  What was

14     the scheme in place?

15        A.   To procure weapons for the army is one problem, you can do that

16     by buying, borrowing, and distributing it means to give it to subordinate

17     units.  Chief of Staff knows best what to do, who needs more, who needs

18     less, and he is the one who distributes the so-call strategic materials

19     which are ammunition, which are weapons, fuel and food.

20        Q.   Thank you.  Let's move forward, please to page --

21             JUDGE ORIE:  Yes, Mr. Groome.

22             MR. GROOME:  Can I inquire what Mr. Jordash intents on tendering

23     these individual excerpts?  It seems to the Prosecution that the Chamber,

24     without the benefit of this in evidence, is left with a record that may

25     cause some confusion.

Page 15359

 1             MR. JORDASH:  I agree.  What we would hope do is tender the whole

 2     diary.  Perhaps there will be a few pages which we wouldn't tender, but,

 3     generally speaking, will be the whole diary, rather than lots of little

 4     excerpts.  We say the whole of the diaries are important because it

 5     demonstrates to Your Honours who was actually doing what.

 6             JUDGE ORIE:  And that's irrespective of the expert report of

 7     Dr. Brown who we are waiting for.

 8             MR. JORDASH:  Well, our position, as we've laid our previously,

 9     is that sections of the diary can be relied upon and some can't.

10             JUDGE ORIE:  Yes.  Because you say I want the whole of it,

11     virtually the whole of it to be admitted into evidence and then we'll

12     later find out what parts can be relied upon and which parts cannot be

13     relied upon.  I mean, if you -- if it's in evidence, it's in evidence.

14             MR. JORDASH:  Yes.

15             JUDGE ORIE:  And that's the reason why I asked you for what

16     purpose.  Well, you say that we know who was doing what more or less,

17     that suggests that you could rely on this to find out who was doing what

18     and if you say at the same time that, well, some portions you may rely

19     upon, others not, I'm a bit puzzled by what I'm supposed to do with it,

20     and perhaps my colleagues as well.  I see some nodding yes.

21             MR. JORDASH:  Well, in the same way that much of the evidence is

22     admitted that a party will suggest at the final close of the case that it

23     requires corroboration, some does and some doesn't, and that's our

24     position in relation to the diaries.  In relation to as I --

25             JUDGE ORIE:  I suggest, for very practical reasons, the following

Page 15360

 1     procedure:  You prepare a document, Mr. Jordash, which contains at least,

 2     I'm not saying exclusively, but at least all the pages we've looked at

 3     and what the witness testified about so that at least that is in

 4     evidence.  If you say no, we need even more, then you can expand on that

 5     and perhaps it would be good to discuss it with Mr. Groome.  Sometimes,

 6     for example, you would need other pages as well to have the proper

 7     time-frame.  For example, I see that on page 301, for example, there's no

 8     date mentioned at all.  We see that on the next page we have the 12th of

 9     May and the Assembly session.  So the next page would be an indication

10     that this, to the extent we can rely on it, preceded the 12th of May,

11     what is written here and there's also some -- there's also some relation

12     in substance because page 301 started for the Assembly which may well

13     refer to what is about to happen the next day.

14             MR. JORDASH:  I mean, I'm having difficulty explaining my

15     position in front of the witness because we do say --

16             JUDGE ORIE:  But the only thing I'm suggesting at this moment is

17     that we, in one way or another, create a document which will be admitted

18     so that we are not -- and that was the only concern Mr. Groome raised, I

19     think, is that if the witness tells us about certain matters without

20     having the underlying document in evidence, then it might be difficult to

21     understand his testimony.  That's --

22             MR. GROOME:  Yes, Your Honour, I don't believe it's necessary to

23     even to decide how much of the diaries or notebooks are ultimately

24     admitted into evidence.  I'm just suggesting that there needs to be a

25     proper record of what the witness was speaking about.  May I suggest that

Page 15361

 1     every page of the document has the ERN number, this J000 number.  If

 2     Mr. Jordash could simply include that reference in his question, then we

 3     will be able to reconstruct at a later time what it was the witness was

 4     making comments about, what specific entry the witness was speaking

 5     about.

 6             JUDGE ORIE:  Yes.  For you just to have on the record the

 7     necessary information which would allow us to later reconstruct what we

 8     actually talked about.

 9             MR. GROOME:  Yes, Your Honour, then make full submissions on what

10     should be admitted, what shouldn't be admitted.

11             JUDGE ORIE:  Mr. Jordash, is that a good practical solution.

12             MR. JORDASH:  Except for the full submissions.  We would want

13     most of the diary in and we don't need to -- it's -- there are good

14     reasons not to so ...

15             JUDGE ORIE:  But the only thing I think Mr. Groome is -- at this

16     moment, is suggesting that we have a clear record of what we have looked

17     at.

18             MR. JORDASH:  I agree with that.

19             JUDGE ORIE:  Okay.  Then he suggested that to be done by

20     reference to the ERN numbers which would, for the page we are looking at

21     this moment, be J000-3072.  At least if I'm -- that was the page 301

22     which is on my screen at this moment.  I'll be happy to assist you.  I'll

23     read every number that appears on what I see on the screen, Mr. Jordash.

24             MR. JORDASH:  I'm not disagreeing with anybody.

25             JUDGE ORIE:  Okay.  But Mr. Petrovic is on his feet.

Page 15362

 1             MR. PETROVIC: [Interpretation] Your Honour, maybe I may be

 2     allowed to contribute.  In practical terms, I agree with -- you and

 3     Mr. Groome have suggested with regard to the clarity of the testimony of

 4     this witness.  However, I would like to also support what Mr. Jordash has

 5     suggested, and that is that the diaries should be admitted in their

 6     entirety.  Why?  Because during our Defence case, certain parts of the

 7     diaries will be shown to some of the witnesses, some other parts will be

 8     tendered for admission from the bar table.  In other words, there will

 9     be --

10             JUDGE ORIE:  Let me stop you here.  If you want all of it in

11     evidence, if Mr. Jordash wants most of it in evidence, I don't know what

12     the position of Mr. Groome will be, sit together, say:  This is what we

13     would like, that's what we would like, make a short submission, OTP would

14     like this to have in evidence, Stanisic Defence for this and this reason,

15     95 per cent of that, you everything.  And then we have a kind of a bar

16     table submission which is linked to what we have seen already in

17     evidence, and at this moment then we'll not assign exhibit numbers but

18     we'll just clearly put on the record what pages we looked at and I -- the

19     page which is before us at this moment I read that out already.

20             Next question or next portion, Mr. Jordash.

21             MR. JORDASH:  Could we have, please, page -- page 319 of the

22     English, 327 of the B/C/S, and it's 324 at the top of the page.

23             JUDGE ORIE:  324, top of the page.

24             MR. JORDASH:  It's the same diary -- notebook, I beg your pardon,

25     5599.  It's an entry that relates to the --

Page 15363

 1             JUDGE ORIE:  We are looking at this moment at J000-3095.

 2             MR. JORDASH:

 3        Q.   And the date to orient yourself, Mr. Milovanovic, is the

 4     14th of May, 1992.  And there's a list there, as you can see, of items

 5     which were sent to the Territorial Defence of Bosnia from the Federal

 6     Secretariat of the National Defence.  Were you aware of these deliveries

 7     from the federal secretariat of the national defence?

 8        A.   No.

 9        Q.   Was the federal secretariat of national defence not making

10     regular supplies to the Bosnian Territorial Defence around this time?

11        A.   I wouldn't know that.

12        Q.   Wouldn't you know that in your position at the Main Staff,

13     especially given your particular tasks concerning supplies?

14        A.   Counsel, sir, the handwriting doesn't tell me that it was sent

15     from the federal secretariat of the national defence.  I can't see that

16     from the handwriting.  I can see it in the English version.  Second of

17     all, on the 14th of May, the -- in Bosnia-Herzegovina there were two

18     Territorial Defence troops.  The first one was of the Muslim and Croatian

19     coalition and the Territorial Defence of the Republika Srpska army which

20     became part of the Republika Srpska army.  I don't know who this was sent

21     to because at that time negotiations were underway between

22     Alija Izetbegovic on the one side and the General Staff of the SFRY, or

23     rather, the Federal Republic of Yugoslavia on the other hand.  And the

24     negotiations were about releasing recruits and officers from many

25     barracks in the Sarajevo garrison in exchange for infantry weapons.  And

Page 15364

 1     I know that the chief of the General Staff of the

 2     Federal Republic of Yugoslavia, General Panic, asked for me to let

 3     everything go to Sarajevo once it arrived on the Drina River.  He wanted

 4     to make sure that the soldiers of the Army of Republika Srpska would not

 5     requisition that.  I don't know when Mladic wrote that.  I don't know

 6     when.  You said that it was on the 14th, and I don't have any reason not

 7     to believe you.

 8        Q.   What does the title on the left-hand screen say?  Is that

 9     different or could you just read it?  Right at the top of the screen on

10     the left.

11        A.   It says:  "Sent to the Territorial Defence of

12     Bosnia-Herzegovina."  At that time we already bore the title the Serbian

13     Republic of Bosnia-Herzegovina.  That was our official title.

14             MR. JORDASH:  Okay.  Let's move on to page 344 of the English,

15     352 of the B/C/S, and 349 at the top of the page and it's J000-3120.

16        Q.   We can see there that Mladic has taken a number down there, the

17     Ministry for Serbs outside of Serbia.  Did you have dealings with the

18     Ministry for Serbs Outside Serbia?

19        A.   No, I did not.  I've never heard of that ministry before.

20        Q.   You can't cast light then on why Mladic would take down this

21     number?

22        A.   What number?

23        Q.   The number under the title "Ministry for Serbs outside of

24     Serbia," or the various numbers which seem to relate to that heading,

25     including a fax number.

Page 15365

 1        A.   This person Gojko Djogo, his name is at the top.  I know that he

 2     was a poet or something of the kind.  Simo Djuretic, I don't have a clue

 3     who he was.  And I know that at that time there were attempts, failed

 4     attempts to establish a committee in Belgrade headed by the retired

 5     general, Blagoje Adzic.  And that committee should have mediated their

 6     exchange of weapons between Republika Srpska and Republic of Yugoslavia

 7     or Serbia.  In the Republika Srpska, we inherited big military companies

 8     like Adzic and others.  I told you how we were supplied with ammunition.

 9     In Republika Srpska we made shells and then we sent them off to the

10     Republic of Serbia where they would be filled with charges.

11             JUDGE ORIE:  Mr. Jordash, we are looking at this moment at page

12     0668-3168.  Please proceed.  No, I'm now a bit confused, as a matter of

13     fact.

14             Mr. Groome, I see a number now in -- in e-court which is

15     J000-3120.  At the same time, I find a version in e-court where this

16     number does not appear on that same spot.  However, where another number

17     appears, but this is a black and white copy, perhaps that's the

18     difference.

19             MR. GROOME:  If I can just assist the Chamber.  The government of

20     Serbia originally provided the Office of the Prosecutor with a scanned

21     version that they had created and that is the other number.  When the

22     Prosecution received the original books, took the decision to re-scan

23     them and that is the original with the red J number, and the J prefix has

24     only been used for the material recovered from General Mladic's home.  So

25     it may even be sufficient for the Chamber to say J number 3120 but that

Page 15366

 1     will clearly indicate the page of the original document and not a

 2     previous scan.

 3             JUDGE ORIE:  Yes.  I see that, and that's the one because in

 4     e-court there are two originals, apparently.  That's the one you scanned

 5     and which bears the J000 numbers and the other numbers, apparently then,

 6     are the previously-sent scanned copies by the Republic of Serbia is

 7     that --

 8             MR. GROOME:  That's correct, Your Honour.

 9             JUDGE ORIE:  Yes, then I'm sorry for creating the confusion, but

10     two originals is always confusing me a bit.

11             But the matter is clear now.

12             Mr. Jordash.

13             MR. JORDASH:  Thank you.

14        Q.   You made reference then to a process whereby ammunition was being

15     sent to Republic of Serbia to be filled with charges.  How long did that

16     go on for?

17        A.   That went on throughout the entire war, but let me correct myself

18     with regard to my previous answer.  May I?

19        Q.   Of course.

20        A.   You asked me if I knew anything about the Ministry for Serbs

21     Outside Serbia.  When the SFRY broke up, the ministry of Serbs for Serbs

22     in diaspora was set up in the Republic of Serbia.  And that ministry

23     still exists in Serbia, I believe.  That ministry rallies around itself

24     the entire Serbian diaspora, not only those in Bosnia-Herzegovina or

25     Croatia, but in the United States of America, Australia and further

Page 15367

 1     afield, and that ministry still exists and functions.

 2        Q.   Do you know that in July of 1991, Bogdanovic, previous minister

 3     of the interior, took over as the minister of that organisation?

 4        A.   I don't know.  It's hard for me to remember the names of all the

 5     ministers in Republika Srpska, let alone Yugoslavia.

 6        Q.   What, then, in your mind or from your knowledge, did the minister

 7     of -- or Ministry of Serbs for Serbs outside of Serbia do in relation to

 8     the VRS?  What might that connection have been with Mladic?

 9        A.   They may have sought links with General Mladic because those

10     Serbs created their associations in America and Australia and donated

11     money to the Army of Republika Srpska.

12        Q.   Thank you.

13             MR. JORDASH:  Let's move to 65 ter 5600 and page 2 of the English

14     and the B/C/S.

15        Q.   This is the beginning of Mladic's -- a Mladic notebook which

16     begins at the 31st of May, 1992.  Was it -- when you see the page, have a

17     look at the page, what -- was it, as far as you know, Mladic's practice

18     to put important numbers, telephone numbers at the beginning of his

19     notebooks?

20        A.   That was common practice of all officers.  Just after the cover

21     page there are, I believe, 12 pages designed for you to enter important

22     telephone numbers and other such information.

23        Q.   And these would be numbers which would be important, presumably,

24     to the author of a particular notebook, these are the numbers that he

25     would be in contact with directly?  Was that the general practice?

Page 15368

 1        A.   Well, when you met somebody, when you talk to somebody, when you

 2     became friends or wanted to maintain business relations with them, we

 3     normally asked them for their telephone numbers and we would enter those

 4     numbers into the notebook.  That was common practice.

 5             JUDGE ORIE:  And we are looking at page J000-3178.

 6             MR. JORDASH:  Thank you, Your Honour.  Let's move forward, past

 7     through the telephone numbers to page 36 of the English and 36 of the

 8     B/C/S, and the entry is the 31st of May, 1992.  And then let's just,

 9     having orientated ourselves, let's move on to page 37 -- sorry, 38 of the

10     English and 38 of the B/C/S and 37 at the top.

11        Q.   And we can see that Mladic is apparently at Jahorina and having a

12     meeting with the leadership of the Serbian Republic of the BH.  It's a

13     long time --

14             MR. JORDASH:  And the original is J000-3213.

15        Q.   It's a long time ago.  Do you recall if you were present at this

16     meeting?

17        A.   No, I was not present there.

18             MR. JORDASH:  Let's move forward to page 41 of the English and 41

19     of the B/C/S and 40 at the top.

20        Q.   And it looks as though Karadzic may still be speaking.  And at

21     the top there is a comment there, "We cannot use aircraft any longer

22     except in extreme necessity."  And then down below reference to Mauzer,

23     who we were talking about earlier.  Are you able to comment on the

24     apparent assertion by Karadzic or someone who was at that meeting that

25     aircraft could not any longer be used except in extreme necessity.

Page 15369

 1        A.   I don't know what kind of comment you want me to make.  I don't

 2     want to mention the spare wheel on that red car.

 3        Q.   Well, was it the case that in May you saw that the VRS aircraft

 4     or aircraft in VRS territory could no longer be used except in extreme

 5     necessity?

 6        A.   In May?  No.  Discussions on air force started in October in

 7     London.

 8        Q.   In relation to Mauzer, do you confirm that there was discussions

 9     in the Main Staff and upwards towards Karadzic concerning Mauzer and the

10     need to subordinate him in May?

11        A.   May and June were the month when we discussed paramilitaries and

12     when we started a process to subordinate them under the command of the

13     Army of Republika Srpska.

14        Q.   And at this point in time had Mauzer been receiving his supplies

15     from the JNA supplies?

16        A.   I don't think so.  It was only when he became our member, when he

17     was subordinated to us that he started receiving supplies from them.

18        Q.   Where was he getting them before that?

19        A.   I wouldn't really know where paramilitaries got their supplies

20     from.

21        Q.   Wasn't the SDS distributing them to the likes of Mauzer at this

22     point before the commencement of the VRS?

23        A.   Every political party, I mean, the major stronger political

24     parties, had its own paramilitary of sorts and they provided the funding,

25     and if you have the money, it's not difficult to buy weapons and

Page 15370

 1     ammunition.  I believe the SDS funded Mauzer, although Mauzer himself, I

 2     believe, had his own political party.  I don't know who they were relying

 3     on, but they were not relying on anyone in Republika Srpska.

 4        Q.   Are you able to say in relation - now you've seen this diary

 5     entry - when it was that the VRS started to give Mauzer supplies?

 6        A.   I can't tell you the date.  I can tell you the time-frame.

 7        Q.   Yes, please.

 8        A.   In the course of the month of June.

 9             MR. JORDASH:  Thank you.  I don't think I said the number --

10             JUDGE ORIE:  We looked at J000-3216.

11             MR. JORDASH:  Thank you.  Let's go to page 60 of the English and

12     B/C/S and 59 at the top.

13        Q.   And we are at the same meeting.

14             MR. JORDASH:  Should be 59 at the top and 60 at the bottom,

15     please, of the English.

16        Q.   I want to ask you about the comment which goes:

17             "Send Major Radojcic from the Sarajevo training centre to Ozren."

18             What was the Sarajevo training centre in May of 1992?

19        A.   In the original, it doesn't say training centre, it says school

20     centre.  And a school centre for mechanised armour units was located --

21             THE INTERPRETER:  Could the witness be asked to speak more

22     slowly.

23             JUDGE ORIE:  Mr. Milovanovic, could you please slow down a bit

24     when you are speaking and perhaps I could invite you to repeat your

25     answer where you said:

Page 15371

 1             "In the original, it doesn't say training centre, it says school

 2     centre," and then you explained that "the school centre for," and could

 3     you please repeat from there.

 4             THE WITNESS: [Interpretation] It was a school centre for the

 5     training of NCOs officers and reserves officers in tank crews in

 6     Banja Luka.

 7             MR. JORDASH:

 8        Q.   Do you know why the major was sent to Ozren?

 9        A.   I don't know.

10        Q.   Are you able to confirm whether he, in fact, was sent to Ozren?

11        A.   I've never seen him in Ozren.  And I went there more than once.

12        Q.   And was there a VRS training centre there?

13        A.   No.  At Ozren there was a combat unit, an operative group called

14     Doboj.

15        Q.   And who were they subordinated to?

16        A.   They were part of the 1st Krajina Corps.

17        Q.   And who was the commander, please?

18        A.   General Momir Talic.

19        Q.   And was the operative group, the combat unit organising training

20     at Ozren?

21        A.   No.  Training centres of the VRS were in Banja Luka, Bijeljina,

22     and Bileca.

23        Q.   The training centre in Banja Luka, how big was that, please?  How

24     many men was it training, for example, a week or a month?

25        A.   I don't know how many but it was never the same number.  It

Page 15372

 1     depended on the population base from which recruitment was done.

 2        Q.   When was that set up, please?

 3        A.   It was established right at the beginning of the war when we

 4     received the first contingent of recruits in August 1992.

 5        Q.   And how long did it continue to operate, please?

 6        A.   The basic training of recruits in those centres lasted for three

 7     or three and a half months, after which they went on to the second stage

 8     of their training in combat units, but they could not be used in combat

 9     before having been in the army for eight months.

10        Q.   Can you give us a sense of how big this operation was, how many

11     personnel were involved in this training centre?

12        A.   I can't tell you how many people were working there, but I know

13     that these training centres were parts of corps:  One in Banja Luka was

14     part of the 1st Krajina Corps; the one in Bijeljina belonged to the

15     Eastern Bosnia Corps; and another in Bileca belonged to the Herzegovina

16     Corps.

17        Q.   And how significant were these training centres for the work of

18     the VRS?  Did most personnel who were with the VRS at this point go

19     through these training centres?

20        A.   Those that were the generation of 1972.  I don't know what the

21     growth was during the war.

22        Q.   Sorry, what does that mean, "those that were the generation of

23     1972"?  Could you just explain that answer, please.

24        A.   Well, recruitment covers men aged 18.  They usually called up

25     when they turn 18 and as a young man turned 18, they were sent to one of

Page 15373

 1     these centres.

 2        Q.   And what about those paramilitary groups or TO units who had been

 3     subordinated to the VRS from May of 1992 onwards?  Did they go through

 4     these training centres?  Were they expected to?

 5        A.   No, because children did not join paramilitary units.  It was

 6     military conscripts who failed to respond to the mobilisation in

 7     Republika Srpska that was announced on the 21st of May.

 8        Q.   As far as you were aware, were there any other training centres

 9     in Banja Luka at the time that the VRS was operating their training

10     centre?

11        A.   You mean centres for the paramilitary?

12        Q.   Any training centre, I mean, other than the VRS training centre?

13        A.   In the territory of Republika Srpska there was only one centre,

14     to the best of my knowledge, that was kept in Dragan centre in Divic near

15     Zvornik.

16        Q.   And how long did that last?

17        A.   Captain Dragan operated first in the area of the Knin Krajina,

18     then when the Vance Plan was signed for the stabilisation of relations,

19     or rather, the cessation of hostilities in Croatia, this self-styled

20     captain no longer could find any place for himself in Krajina, and not

21     wanting to go to Serbia or back to Australia where he had come from, he

22     stopped at the border at the Divic and started rallying some specialists

23     whom he trained himself, but with this order of the 28th of June we broke

24     up his group.

25        Q.   I'll come to Dragan in a minute, but just how long did this

Page 15374

 1     training centre exist?  That's all I want to know for the moment.

 2        A.   I don't think it existed for more than a month.

 3        Q.   Thank you.  Let's move on.  I will return to Dragan shortly

 4     because he does make an appearance in the notebook.

 5             MR. JORDASH:  Let's move now to page 151 of the English and --

 6     sorry, 151 of the English and 149 of the B/C/S, and it's 148 at the top

 7     of the page.  And the original is J000-3322.

 8        Q.   And so you can orientate yourself, perhaps we need to go back one

 9     page, and the date we are looking at is an entry on the 11th of June

10     which is at page 146 of the English and 144 of the B/C/S.  And we have an

11     entry there which is headed "Bijeljina," and then if we go over the page

12     we have the reference again to Mauzer, self-proclaimed major, got some of

13     Arkan's decorations or others, has a hold over half the municipal

14     Presidency in Bijeljina, et cetera.  The brain behind the whole team is

15     Jesaric, connected through business and relatives.  His unit is in the

16     barracks in Bijeljina.  He made Dencic appoint him to the duty of

17     commander for counter-intelligence affairs.

18             Were you aware of these details?  Were they accurate, as far as

19     you were aware?

20        A.   For me to be able to speak about it, you have to give me the

21     time-frame or the date.

22        Q.   I think it's the -- yes, it's Thursday, the 11th of June.

23        A.   I know this about Mauzer in that period:  When General Mladic

24     spoke to him, and this is what Mladic told me, Mauzer stripped his own

25     insignia of rank off and he wanted to return them to General Mladic

Page 15375

 1     because he had not received them from the VRS, which he was joining.

 2     Mladic took those insignia and then returned them to Mauzer and said:

 3     From now on you are a soldier of the VRS.  So I don't know whether he was

 4     a self-styled major or he actually got that rank from someone.

 5        Q.   And was he located in the barracks in Bijeljina at this point in

 6     time along with VRS personnel?

 7        A.   I don't know where he was based because I was not in touch with

 8     him.  I know that he set up that brigade himself before the war broke out

 9     in Bosnia and Herzegovina.  Now, what he had done with that brigade and

10     where before we arrived, I don't know.

11        Q.   How big was the VRS presence in the barracks in Bijeljina at this

12     point in time?

13        A.   I don't know their strength.  I know there were two or three

14     brigades from the Eastern Bosnia Corps at all times.  It was a large

15     barracks and it was probably used for R & R, rest and recreation.

16        Q.   How did the brigades that were there receive their supplies?  Was

17     there a logistics base in Bijeljina?

18        A.   There was a logistical base in Bijeljina but it was attached to

19     the Main Staff, not to the Eastern Bosnia Corps.

20        Q.   Did the Eastern Bosnia Corps receive logistics through the

21     Main Staff?

22        A.   Yes.

23        Q.   Do you know why Mladic hadn't subordinated Mauzer before June, in

24     the month of May, for example?

25        A.   I already spoke about that, he simply didn't have enough time.

Page 15376

 1     These paramilitary commanders first needed to be spoken to, then they had

 2     to be given time to make their decision, and then the order came down in

 3     June.  I don't know.  Maybe it happened in May, but I know that he was

 4     the first one that Mladic spoke to.

 5        Q.   Thank you.  Let's move to page 245 of the English and 243 of the

 6     B/C/S.

 7             JUDGE ORIE:  I don't think that we have a full record yet.  I

 8     think the page where who again was sent to Ozren, it was Colonel --

 9     Major -- you had forgotten to read the page number of that one.  That was

10     J000-3235.

11             MR. JORDASH:  I do apologise.

12             JUDGE ORIE:  I think the next one you read.  And we are now

13     moving to?

14             MR. JORDASH:  To page 245 of the English and 243 of the B/C/S,

15     with 242 at the top of the page.

16             JUDGE ORIE:  So we are now looking at J000-3416.

17             MR. JORDASH:

18        Q.   Before I ask you a question about that, could I just ask you who

19     is Dencic, Mr. Milovanovic?  There I'm referring to the earlier entry

20     where Mladic apparently writes that Mauzer made Dencic -- appointed him

21     to the duty of commander for counter-intelligence affairs.  Do you know

22     who Dencic is or was?

23        A.   Colonel Dencic, I forget his first name, was assistant for

24     logistics in the 11th JNA corps in Tuzla.  With the decision to withdraw

25     the JNA, the corps commander - I forget his name as well but I know he

Page 15377

 1     died recently - left Bosnia-Herzegovina, and Dencic, the assistant for

 2     logistics, stood in for the commander of the Eastern Bosnia Corps for

 3     awhile.  He was a man who did not do very well as corps commander, and we

 4     had to replace him very quickly.  He was the one, actually, who gave

 5     Captain Dragan approval for setting up that training centre in Divic.

 6        Q.   Against the command of his commander?

 7        A.   I don't know whose commander you mean, Dencic's commander?

 8        Q.   Who was Dencic's commander at the time Dencic gave Captain Dragan

 9     approval to set up the training centre?

10        A.   Dencic was acting commander of the Eastern Bosnia Corps, and his

11     superior was supreme commander Ratko Mladic.

12        Q.   Thank you.  Let's move on to the entry on the screen, J000-3416.

13     And I'm interested in the reference to the training centre

14     Captain 1st Class Markovic.  Are you able to cast any light on what that

15     might be a reference to?

16        A.   I don't know which Markovic that is because I know dozens of

17     Markovics in the VRS ranging from lieutenants to colonels, so I can't

18     tell you anything.  I can't answer the question.

19        Q.   Are you able to connect training centre with Zvornik?  Is there

20     any connection there?

21        A.   Counsel, sir, I can only give you my inferences and my opinions.

22     I don't think I should be doing that as a witness though.  There was a

23     Markovic in Knin.

24        Q.   Mr. Milovanovic, if all you can do is give your opinion -- if

25     you've got facts that might help the Court, please give them, but

Page 15378

 1     otherwise we'll move on.

 2        A.   No, no, I don't.

 3        Q.   Thank you.

 4             MR. JORDASH:  Let's go to 215 of the English, 213 of the B/C/S,

 5     and 212 at the top of the page.  And it's J000-3386.

 6        Q.   And a meeting apparently with the minister of defence,

 7     Colonel Subotic.  What was his precise role at this point in time?  What

 8     did it involve being the minister of defence?

 9        A.   Colonel Bogdan Subotic was the first defence minister of

10     Republika Srpska.  I know more about what is written here.  We found out

11     that in the bauxite mine in Milici, around Milici, there was some sort of

12     embezzlement or looting or something, and President Karadzic sent Subotic

13     as defence minister to find out what it was all about, to inquire.

14     Subotic went there, and after that he informed General Mladic about the

15     general situation in Milici.  Since this was on the 20th June, the major

16     problem for the army in Milici was this:  The president of municipality

17     of Milici was at the same time director manager of the bauxite mine and

18     he refused to carry out the mobilisation in Milici, the mobilisation that

19     was proclaimed on the 21st of May.  What made things worse, he was also

20     president of the Executive Board of the SDS, and in this -- on this party

21     ladder he was man number two in the Serbian Democratic Party and he

22     refused to carry out the mobilisation, and that's why the president sent

23     the defence minister to inquire.

24             JUDGE ORIE:  Mr. Jordash, I'm looking at the clock.

25             MR. JORDASH:  I'm happy to pause there.

Page 15379

 1             JUDGE ORIE:  Yes.  Then we resume at quarter to 6.00.

 2                           --- Recess taken at 5.18 p.m.

 3                           --- On resuming at 5.55 p.m.

 4             JUDGE ORIE:  Mr. Jordash, are you ready to continue?

 5             MR. JORDASH:  Yes, please.  Thank you.

 6        Q.   We were talking about Subotic and the situation in Milici.

 7             MR. JORDASH:  Can we go to the next page, please.

 8        Q.   And if -- this is J000-3387.  And Mladic apparently writes that a

 9     police officer from Zvornik was present who pointed out the problem of

10     the training centre formed by Captain Dragan in Divic village near

11     Zvornik, these men broken loose from any command.  Do you know whose

12     command they broke loose from at this point in time?

13        A.   According to Captain Dragan and what he said to General Mladic,

14     but this is the first time I saw that Captain Dragan met up with Mladic.

15     I saw it from the materials that you gave me yesterday.  I didn't know

16     about that.  Captain Dragan dreaded [as interpreted] around himself some

17     people who didn't want to join the army, as a matter of fact, either in

18     Serbia or in the Republic of Serbian Krajina while he was there, or when

19     he came to Republika Srpska.  Those were usually lads with a lot of

20     problems.

21        Q.   Sorry to interrupt, but the entry seems to suggest he was under a

22     command at one point.  Are you able to cast any light on that?

23        A.   I can't cast any light on that.  What I've just told you is

24     something that I saw in your materials, actually.  I know that Dencic

25     took him under his wing.  He was the commander of the

Page 15380

 1     Eastern Bosnia Corps and he allowed him to set up that training centre in

 2     Divic.

 3        Q.   And who was he training under that authority?

 4        A.   Those lads that he rallied around himself, and I don't know how

 5     he did that.  When I arrived at that centre for the first time with an

 6     intention to dismantle it, I found some 20 lads there.  They were idle.

 7     They didn't do anything.  Captain Dragan was not there.  And I arrived

 8     because General Mladic had ordered me to find a way to get rid of

 9     Captain Dragan, and I believe that I've already told you how that came

10     about.

11        Q.   So do I have this accurately, that as far as you are aware that

12     Captain Dragan trained some lads and before they actually did anything

13     they were removed; is that right?

14        A.   He stayed in Divic for a month or a month and a half, as I've

15     already told you.  He was never in any action with them because I was

16     responsible for eliminating him and this is what I did.  I gave him a

17     task knowing that he was not capable of carrying that task out.  We was

18     stringing me along for some four days and then we agreed to meet up in

19     Milici.  Allegedly he wanted me to personally give him that task

20     verbally.  I arrived in Milici.  He was not there.  I was told that he

21     had left for Zvornik 10 minutes before that.  Then I went to Zvornik, to

22     the command of the Zvornik Brigade, and I was told there that 10 minutes

23     before I arrived he left for Divic.  My security chief was against us

24     going back to Divic.  He was afraid that he would be ambushed.  Still, we

25     went there.  Dragan wasn't there.  He had fled to Belgrade in the

Page 15381

 1     meantime, and then I said to those lads:  Collect your things and leave.

 2     The lads left.  The training centre was dismantled.  Captain Dragan never

 3     showed up there after that.

 4             JUDGE ORIE:  Could I seek clarification of one of the answers.

 5     You said a minute ago that:

 6             "According to Captain Dragan and what he said to General Mladic,

 7     but this is the first time I saw that Captain Dragan met up with Mladic.

 8     I saw it from the materials that you gave me yesterday ..."

 9             That is an unclear reference for us because we have not gone

10     through all the materials, but it is not on the page we have just looked

11     at, was it?

12             THE WITNESS: [Interpretation] No, it is not.

13             MR. JORDASH:  Perhaps I can take Your Honours --

14             JUDGE ORIE:  I do not know whether you find it of any importance,

15     but I just wanted to make clear that it's a reference to a source which

16     is unknown to the Chamber.

17             MR. JORDASH:  I'll take Your Honours to it.  Page 264 of the

18     English and 262 of the B/C/S.  261 at the top.

19        Q.   It seems to be attached to a date, the 30th of June, 1992, which

20     is at page 246 of the English and 244 of the B/C/S.  Now, we are looking

21     at the screen at J000-3435.  We see there reference halfway down the page

22     meeting with Dragan at his request.  And then reading further down the

23     page we have, it seems -- well, we have an entry which says:

24             "I met Dragan when Colonel Ilic came," and this may be

25     Deputy Mijatovic stating this, "we both said what was good.  The blockade

Page 15382

 1     of the municipality and busting into the building with weapons is

 2     something that cannot be tolerated.  Nothing could be taken from Divic to

 3     be placed in the war reserves depot as war booty."  Now, was that a

 4     reference to Dragan or his men taking items and keeping them at Divic

 5     rather than -- as personal properties rather than as war booty?

 6        A.   Are you asking me?

 7        Q.   I certainly am.

 8        A.   First of all, let me answer the Presiding Judge's question.

 9     Mladic never told me that he had met up with Captain Dragan.  He arrived

10     back one evening and the only thing he told me was find a way to

11     eliminate Captain Dragan from Republika Srpska, and I found a way, and I

12     told you how I did it.  This is the first time that I realised that

13     General Mladic had ever met up with Captain Dragan.  And as for the

14     things that Mladic found in Divic, I didn't find them myself.  I saw in

15     your materials that Mijatovic had told Mladic that Captain Dragan was

16     nothing but a common thief and he had even stormed a Serbian municipality

17     and blockaded it.

18        Q.   You were unaware of that?

19        A.   I was unaware of that.

20        Q.   Now, at the bottom of the page it says:

21             "Zuca and Crni would even burst," and we go over the page, "into

22     the surgical theatre during operations."

23             Was Zuca and Crni working hand in hand with Dragan -- or were

24     they working hand in hand with Dragan?

25        A.   I don't think so.  I believe that the two were two separate

Page 15383

 1     organisations.  From time to time Crni would appear at Zuca's.  I don't

 2     know what Crni had or what he did.  I believe that he was an individual

 3     who operated on his own, a maverick.  I heard of him during the war.  I

 4     believe that he was removed together with Zuca.  I know that Zuca was

 5     convicted to a prison sentence of 15 years and that he died in the

 6     Sremska Mitrovica prison.

 7        Q.   How many men did Crni have at this point, do you know that?

 8        A.   I don't know.

 9        Q.   What was he doing?

10        A.   The first time I ever saw Crni was some time in the summer of

11     1992.  I believe that it was either in July or in August.  He arrived at

12     Mladic's office.  He arrived from Herzegovina.  Mladic talked to him and

13     then he called me from the place where he was billeted and he told me:  A

14     man is going to come to your office, can you listen to him for awhile and

15     then tell me what you think?  And then give him a helicopter tomorrow to

16     transfer him and another man, Captain Janic to Herzegovina.  And that

17     person indeed came.  He told me how he, on his own, had taken the

18     repeater over from Muslim on Leutar [phoen] mountain, the same repeater

19     that the Muslims had taken in 1993.  The Herzegovina Corps tried to

20     restore possession of that repeater for awhile, that was the hub of our

21     communication, and that happened.  And Crni bragged that it was owing to

22     him.  What he was doing in Herzegovina, I don't know.  Whether him and

23     Captain Dragan co-operated, I don't know.  I don't know who controlled

24     him, whether he was under anybody's supervision, whether he had any men

25     under him.  I don't even know his real name.  I don't know his first name

Page 15384

 1     or his last name, I don't know who he was.

 2        Q.   Is there any reason why you were not aware of the size of his

 3     group?  Does that suggest anything to you about the size of his group or

 4     the activities of his group?

 5        A.   I don't know anything about that.  As I've already told you, I

 6     believe that he was a maverick, an individual who operated on his own.  A

 7     lonely wolf.

 8        Q.   That's what I'm suggesting.  You don't know that he was

 9     subordinated within the JNA or the VRS and you don't know anything about

10     the size of his group, does that suggest that he was insignificant in

11     terms of war operations or in terms of criminality?

12        A.   As I've already told you, I don't know anything about him.  When

13     Mladic sent him to my office and when I talked to him, he told me that he

14     prevented the assassination of the commander of the Herzegovina Corps.

15     There was a skirmish between the commanders security detail or the

16     security detail of a brigade and the brigade's name was Ante Boro.  His

17     security detail conflicted with General Grubic's security detail.  One

18     man was dead as a result of that, and Crni bragged that he was the one

19     who managed to protect General Grubic, but it never occurred to me later

20     to check it with the general himself.  So as I've already told you, I

21     don't know who that man was.  I only saw him once and that's the long and

22     the short of the whole story.

23        Q.   Okay.  Thank you.

24             MR. JORDASH:  Let's go back, please, in the diary to -- still

25     sticking with 65 ter 5600, page 117 of the English and 116 of the B/C/S.

Page 15385

 1     Sorry, I should have said the number at the top of the page which is 115.

 2     Sorry.

 3        Q.   This is -- before I start that, this is J000-3289 and the title

 4     is:  "The Monday, the 8th of June request of the General Staff of the

 5     Army of the FRY."  And it concerns co-ordination groups, groups which

 6     purportedly co-ordinating such things as technical administration,

 7     quartermaster administration, air force and anti-aircraft defence.  Do

 8     you know anything about these co-ordination groups and what their

 9     significance, if any, was to Mladic and the VRS?

10        A.   First of all, let's look at the title.  I don't know whether

11     these are requests by the General Staff of the Army of Yugoslavia upon

12     the Army of Republika Srpska or whether it is Mladic's request upon the

13     General Staff of the Federal Army of Yugoslavia.  It's very difficult to

14     understand.  However, when it comes to that group, I know about that

15     group.  I started answering your question about the ministry for services

16     outside of Serbia.  I know that the retired General Adzic wanted to set

17     up a group.  They would co-operate amongst themselves and they would deal

18     with the production of ammunition.  Moreover, we had a lot of refugees,

19     military conscripts who were in Serbia.  It would have been a whole corps

20     strong of deserters in Serbia.  As far as I know, General Djukic was

21     supposed to join that group together with Mico Grubor, the head of

22     personnel in the Army of Republika Srpska.  I also know that that group

23     never really took off the ground.  In any case, General Adzic never took

24     the lead because there was a ban on his entering the General Staff of the

25     Republic of Serbia for some reason.  I don't know why.

Page 15386

 1        Q.   Thank you.

 2             MR. JORDASH:  Just have a moment.  Let's go, can we, please, 230

 3     of the English, 228 of the B/C/S and 227 at the top.

 4        Q.   This is an entry which relates to June the 24th, 1992, and it is

 5     a meeting of the collegium of the Main Staff of the Army of the RS.  I

 6     beg your pardon, it's a briefing of Colonel Zivanovic at 1330 hours at

 7     page 228 of the English and 226 of the B/C/S.  Have you read these

 8     entries concerning Skelani and the Bajina Basta dam and the torching of

 9     Serbian villages?

10        A.   Yes, I've read it.

11        Q.   And did you agree with its contents, from your own personal

12     knowledge?

13        A.   This is what Colonel Zivanovic reported to General Mladic because

14     Mladic had sent him to Eastern Bosnia, that is to say Skelani, to see

15     what the situation was there.  Then Colonel Zivanovic was acting as chief

16     of artillery of the Main Staff, and when he returned, he told this sorry.

17     I personally did not agree with that account of Colonel Zivanovic because

18     he glorified that battalion and we had a lot of problems with it.  First

19     of all, people had abandoned the newly-established municipality of

20     Skelani.  They ran away across the Drina, across Bajina Basta to Serbia,

21     so we had to send a battalion from the 1st Krajina Corps to deal with it

22     and they did so within 24 hours.

23             Colonel Zivanovic sang and ode of praise to that battalion and

24     the situation was not really like he depicted it.

25        Q.   What about the torching of the Muslim villages, was that accurate

Page 15387

 1     or not?  I beg your pardon, torching of the Serbian villages?

 2        A.   I don't know whether that was true.  In one of my appearances

 3     here, I don't know whether it was in this case or another, I said that by

 4     14 February 1993, that's to say between April 1992 until 14 February

 5     1993, around 156 Serbian villages and hamlets had been destroyed, looted

 6     and burned.

 7        Q.   That was in this trial so we don't need to go over it.

 8             MR. JORDASH:  Let's go to instead to page 246 of the English and

 9     244 of the B/C/S, and 243 at the top of the page.

10             JUDGE ORIE:  Mr. Jordash, the previous page you located in time

11     on the 24th of June, whereas I see the 24th of June appearing on page 217

12     at the top, or is it 219, whereas half a page before the briefing starts

13     it seems to say the 25th of June.

14             MR. JORDASH:  My mistake.  Thank you.

15             JUDGE ORIE:  Please proceed.

16             MR. JORDASH:  This is now J000-3417 and it's a meeting, it seems,

17     with Mladic and representatives of the Zvornik municipality.  And we can

18     see the list of those present.  Can we move then to page 247 of the

19     English and 245 of the B/C/S, and 244 at the top of the page.

20        Q.   And there's an entry there with Novak Tokanovic, commander of, it

21     seems, the Sekovici detachment, part of the Birac Brigade, speaking about

22     a unit called the guard operating under the JNA.  Do you know which unit

23     Tokanovic is referring to or appears to be referring to?

24        A.   I did not understand point this Tokanovic was the commander.  He

25     was a commissioner of the SDS for the municipality of Sekovici.  I know

Page 15388

 1     there was a period where there was some sort of ruckus in Sekovici,

 2     somebody had formed a paramilitary unit, but it was not given the status

 3     of a military unit but a police unit, and the commander of the

 4     Milici Brigade, Andric Svetozar, refused to accept that unit into his

 5     brigade.  That caused a conflict between the municipal authorities and

 6     the brigade command and Mladic went there to sort it out.  I believe that

 7     meeting was held in Vlasenica with the local municipal presidents of

 8     Milici, Sekovici, Vlasenica and I don't know who else was there.

 9        Q.   You can see the reference to the guard operating under the JNA.

10     Who might that have been?  Are you able to explain that?  Do you know

11     anything about that?

12        A.   Sorry, what date are we talking about?

13        Q.   The date on the screen now, which is --

14             JUDGE ORIE:  I think we are talking about the 30th of June.

15             THE WITNESS: [Interpretation] I can't see it on the screen.

16             MR. JORDASH:

17        Q.   No, the date isn't on the screen but it's the 30th of June.  And

18     there's a reference there, if you can see it, to the guard operating

19     under the JNA, according to Tokanovic.  The question is:  Do you know who

20     that might be?

21        A.   30th June which year?

22        Q.   1992.

23        A.   It couldn't have been the JNA because the JNA had left

24     Bosnia-Herzegovina on the 20th of May, 1992.  I think rather --

25             JUDGE ORIE:  I'm bit puzzled by your question.  You are referring

Page 15389

 1     to the guard and then you ask who that may be, and from the context it

 2     seems that it's a unit and so what -- I always refer -- who for me is a

 3     person that -- but perhaps that's my lack of understanding of the English

 4     language.  Say Mr. X, who is that; and I would say the unit, what is it,

 5     or not who is it.

 6             MR. JORDASH:  I'll make myself clear, Your Honour.

 7             JUDGE ORIE:  Yes.

 8             MR. JORDASH:

 9        Q.   The entry says:

10             "Before the arrival of the army, we had one unit that was called

11     the guard.  It operated under the JNA."

12             Do you know anything about that unit, Mr. Milovanovic?

13        A.   I don't.

14        Q.   Let's move on then.

15             MR. JORDASH:  Let's go to page 263 of the English, 261 of the

16     B/C/S, and 260 at the top of the page.

17        Q.   It's the same meeting we were looking at, the meeting of the

18     representatives in Zvornik.  And I'm interested in the comment made by

19     Mladic, it seems, or the statement written down that "one called Crni

20     gave your name as a reference."  It looks as though Jokic told Mladic

21     that.  Do you know anything about that?

22        A.   I know Jokic.  I told you before how I met Crni, Mladic had sent

23     him to me, and Crni must have dropped Mladic's name when he was seeing

24     Captain Jokic.  I don't know whether he referred to Mladic or not but

25     it's likely that he did because Mladic had sent him to me and he must

Page 15390

 1     have -- or he could have sent him to Jokic as well.

 2        Q.   Thank you.

 3             MR. JORDASH:  That's J-- I can't see the number, actually, on

 4     that.  J000-3434.  Let's move on to 316 of the English, 314 of the B/C/S

 5     and the top of the page is 313.  It's an entry for the Sunday,

 6     12th of July, 1992.  Now, it's a bit unclear what this is, in the sense

 7     it's a meeting or whatever, but it seems as though Major-General Gvero is

 8     there, and the president of Bileca municipality is present at some point.

 9     That's, Your Honours 317 of the English and B/C/S, 315.  And I'm

10     interested in page 318 of the English and 316 of the B/C/S, and the top

11     of the page is 315.  And the comment there situation in -- this is a

12     third of the way down the page:

13             "Situation in Gacko municipality fine.  Berkovici municipality

14     says there's disorder in the army - Arkan's Men who want to loot and want

15     the army to equip them before going into battle.  Wants the aim of the

16     war in Herzegovina defined."

17        Q.   Do you know anything about Arkan seeking for the VRS to equip him

18     in this municipality?

19        A.   It was 12 July 1992.

20        Q.   Yes.

21        A.   Arkan had been expelled by then from the territory of

22     Republika Srpska.  It's possible, however, that a smaller group of his

23     had gone to Herzegovina because they had not found a place for themselves

24     in Eastern Bosnia, and I remember this, General Mladic sent Gvero as his

25     assistant for moral guidance to Herzegovina to talk all or most of the

Page 15391

 1     situations there and size-up the situation, especially from the viewpoint

 2     of the attitude of the civilian authorities towards the army.  I have no

 3     other comment to make on this.  This is Gvero's report to Mladic.

 4     However, on the previous page, I just noticed at the bottom of the page a

 5     different pencil.  Could I also see it again to compare the handwriting?

 6     I want to see if it's the same handwriting.

 7        Q.   Yes.

 8             MR. JORDASH:  Let's go back, please.

 9             THE WITNESS: [Interpretation] No, there was a page where I saw

10     writing in blue.  There it is.  Sunday, 12 July.  It's St. Peter's day,

11     the Serbian holiday.  Same handwriting but I can't understand -- maybe he

12     ran out of ink and changed pens.

13             MR. JORDASH:

14        Q.   Okay.  Should we move on?  Is that all you wanted to say about

15     that?

16        A.   I don't have anything to say about this but I do have a comment

17     on the material given me yesterday.  An initial of General Mladic was

18     copied mistakenly.  Almost everywhere it's BM, whereas it should be RM

19     for Ratko Mladic because he wrote the letter B in a very specific way as

20     an open 8, so probably the person transcribing it misunderstood.  That's

21     the way Mladic wrote R.  Everywhere I saw it was written BM, and in his

22     work notebook, Mladic never put his initials.  Or maybe those were the

23     initials of somebody who transcribed it or copied it.

24             MR. JORDASH:  I don't think there's going to be any dispute about

25     this, that's Mladic's wife who signed the document when they were -- when

Page 15392

 1     they appeared -- when they were found at the apartment.

 2             THE WITNESS: [Interpretation] Bosa Mladic.  Then it's my mistake.

 3     I thought it was Mladic's initial.

 4             MR. JORDASH:

 5        Q.   Just for your information, she signed every page before the

 6     documents were handed over to the Serbian MUP.

 7        A.   Sir, I reviewed 23 of Mladic's notebooks, some in The Hague, some

 8     in Banja Luka.  Only in three of them did I find that Bosa put page

 9     numbers in green felt tip pen and on the back of these three notebooks

10     she wrote that she, Bosa Mladic, reviewed and put page numbers on the

11     pages 1 to 400 and the actual pages begin with number 13.  That's the

12     beginning of the actual writing space.  The first 12 pages are filled

13     with office phone numbers, calendars, agenda, et cetera.

14        Q.   Okay.  Let's move on.  Perhaps that's to be resolved at a later

15     stage.

16             MR. JORDASH:  Let's go to page 355 of the English, 353 of the

17     B/C/S, 353 at the top of the page.  It's entry 15th of July, 1992, and

18     it's a briefing of the organs of command of the Main Staff of the Army of

19     the Serbian Republic of Bosnia-Herzegovina.  And it's J000-3527.

20        Q.   Were you present during this briefing?

21        A.   I meant to say that the end of this examination what I reviewed

22     last night is one and a half of these binders.  I never found my name or

23     my title anywhere.  Whereas not a single briefing at the Main Staff could

24     have gone on without me because I'm the person who analysed combat

25     activities, evaluated the situation, and made proposals to the commander.

Page 15393

 1     In my prior review of some notebooks, I found my name, or rather, a

 2     reference to me in the letters NS, which stands for Chief of Staff.

 3     However, in what I reviewed yesterday, I did not come across my name

 4     anywhere.  Even here it begins with the General Tolimir, chief of

 5     security and intelligence, or perhaps we'll come across Petar Salapura,

 6     the first man in intelligence, followed by Chief of Staff or the

 7     operative officer, if there is no Chief of Staff, but I didn't even find

 8     Miletic here who briefs the commander about the military situation or the

 9     condition in the VRS.  And after a everyone has spoken, the

10     Chief of Staff takes the floor again and makes a proposal to the

11     Commander-in-Chief about employment of the army.  But that whole segment

12     is missing as if I was nowhere there in the army.  In the last half of

13     1992, I was there all the time.  I never moved out of that hutment

14     because that's the time when the army was being established.  I was only

15     absent for 24 hours on the 2nd of August to visit my mother in the

16     hospital.

17             JUDGE ORIE:  Mr. Jordash, before I give an opportunity to

18     Mr. Groome, you said it was an entry of the 15th of July, where it rather

19     clearly says the 20th of July, isn't it?

20             MR. JORDASH:  Sorry --

21             JUDGE ORIE:  Just above.

22             MR. JORDASH:  Yes, complete misspoke.

23             JUDGE ORIE:  Mr. Groome.

24             MR. GROOME:  Your Honour, Mr. Milovanovic on several occasions

25     now has made some observations about the materials that he reviewed last

Page 15394

 1     night, yet there is to clear record of what it was that he was given.

 2     Could I ask that Mr. Jordash be given an opportunity at the beginning of

 3     tomorrow's session to put on the record what it was that

 4     General Milovanovic was given, either orally or perhaps even a written

 5     demonstrative exhibit that is an index of the materials that

 6     General Milovanovic was asked to review.

 7             JUDGE ORIE:  Mr. Jordash.

 8             MR. JORDASH:  Yes, I will draft something and file it with

 9     Your Honours' leave.

10             JUDGE ORIE:  Yes.  And we'll then have a look at it.  At the same

11     time I think one of the last answers of Mr. -- of the witness was

12     approximately one page, and that all answering the question:  Were you

13     present during the briefing?  Now, it could be that you have hidden your

14     search for all this information in this question, but I really wonder

15     whether you are interested in it, and if so, then I would have put a

16     different question perhaps then to the witness.

17             MR. JORDASH:  Well, I wanted to know if he was presents, I didn't

18     expect him to answer.

19             JUDGE ORIE:  [Overlapping speakers]... yes, but then you should

20     interrupt him and say:  Were you present?  Not, if not then put a next

21     question to the witness instead of let him go a full page, unless it was

22     all exactly what you were --

23             MR. JORDASH:  No, I thought Your Honours might be interested in

24     any reflection that the witness had about the authenticity of the diary.

25     Notebook, I mean.  But I can move on, Your Honour.

Page 15395

 1             JUDGE ORIE:  Well, about the name and the way in which RM or BM

 2     was written, that's clear, but that's whether all that -- okay.  I leave

 3     it to you, Mr. Jordash.

 4             MR. JORDASH:  Yes, I take Your Honour's point and I'll step in

 5     earlier.

 6        Q.   20th of July, 1992.  Let's go to the next page, and I want to try

 7     to move swiftly because I'm running out of time, Mr. Milovanovic.  So try

 8     to focus your answers, if you would.  There's reference there to NATO

 9     stepping up reconnaissance activities.  Did they step up reconnaissance

10     activities around July of 1992 to prevent the VRS from using aircraft

11     within Bosnia?

12        A.   NATO reconnaissance sorties did start but I don't know why.

13        Q.   Did it prevent you using aircraft within Bosnia?

14        A.   No.  As I've already told you, our air force was grounded in

15     October 1992.

16        Q.   Were you aware through your own reconnaissance what air -- who

17     was in the air-space over Bosnia?  Which aircraft were using the

18     air-space in VRS territory?

19        A.   I don't know who they were.  I only know that it wasn't Iceland

20     because Iceland does not have an armed force and they are still NATO

21     member state.

22        Q.   Let's move on, perhaps we are both getting tired.

23             MR. JORDASH:  Let's go to page 357 of the English and 355 of the

24     B/C/S.  355 at the top of the page.  And it's the same meeting and it's a

25     comments by Colonel Lukic:

Page 15396

 1             "There are 110 recruits at the training centre, 295 in Bileca.

 2     They are to complete their training on the 30th of July."

 3        Q.   Do you know about that?

 4        A.   I know Colonel Lukic was head of personnel and he took charge of

 5     recruitment and the deployment of soldiers and officers.  I personally

 6     brought them over from Nis to join the Main Staff.

 7        Q.   Was the training as described in this notebook?

 8        A.   As I already told you, we had three training centres in

 9     Banja Luka, Bijeljina and Bileca, as you can see there's training in

10     Bileca, you asked me about the number of recruits, I didn't know, but it

11     says here 295, that was the first generation of recruits that we

12     recruited to serve in our army.

13        Q.   Do you agree with me that around this time and throughout 1992

14     training and the lack thereof was a problem for the VRS?

15        A.   We had a shortage of recruits and that was a problem.  As I've

16     already told you, in Serbia there was a corps strong of deserters.  The

17     children who were growing up at that time, those were the children of

18     parents who could not leave Bosnia and Herzegovina.  Everybody else did.

19     And also, we had the problem with military conscripts who remained in the

20     territory of Bosnia-Herzegovina because their specialties did not meet

21     the demands of the Army of Republika Srpska.  We had the biggest number

22     of infantry men so we had to retrain them to become artillery men, to

23     become members of our air force, and so on and so forth.

24        Q.   Yeah.  And the problem I'm suggesting that there was not just the

25     number of recruits but the amount of training that was being administered

Page 15397

 1     which led to extensive damage, for example, of combat equipment because

 2     the training wasn't adequate; is that fair?

 3        A.   That is a fair description.  That's why we had an obligatory

 4     military service of 8 months plus 8 months, which means that while they

 5     were in training for 8 months they could not be used in combat.  After

 6     that they could be deployed and used in combat.  Their service was not

 7     interrupted so as to allow them to be mobilised.  Their service was

 8     continuous which means that they had to stay in the army for 16 months.

 9        Q.   And a lack of training or a lack of adequate training meant that

10     there were a disproportionate number of deaths and wounded in the VRS; is

11     that also fair?

12        A.   This should be correct but it wasn't.  As I've already told you

13     several times, the first 8 months of training meant that recruits were

14     not used in combat.  And this was precisely with a view to reducing our

15     casualties.  We did not want untrained men to die in vain.

16        Q.   But that is what happened, though, in 1992, isn't it?  Men were

17     dying in vain because the training wasn't adequate?  I can take you, if

18     you want, to your VRS combat 1992 report.

19        A.   If you think this is necessary, be my guest.  Show it to me.

20        Q.   It's only necessary if you don't remember what is in it, or you

21     don't remember this as being a problem within the VRS?

22        A.   There are casualties in every war.  The task of the command cadre

23     is to reduce those losses to a minimum.  It would have been a crime to

24     use a new recruit and let him die because he was not well trained, and at

25     the same time the enemy was better trained than was able to locate such

Page 15398

 1     an untrained soldier and kill him.  That would have been a crime.

 2             THE INTERPRETER:  Could all unnecessary microphones please be

 3     switched off.  Thank you.

 4             MR. JORDASH:  Let's return to that tomorrow then and I won't

 5     delay things now by finding the reference but we'll return to that.

 6     Let's move on.  Page 377 of the English and 375 of the B/C/S and 375 at

 7     the top of the page.  And we've just looked at J000-3529.

 8        A.   I see 549.

 9        Q.   That's what we now have on the screen, J000-3549.  And this is an

10     entry dated the 27th of July, 1992, and it's at page 373 of the English

11     and 371 of the B/C/S, and it talks with Minister of the Interior,

12     Mr. Mico Stanisic and the deputy minister of the government,

13     Mr. Trbojevic.  And we see there -- perhaps we go back one page so we can

14     see how we get to this page.  Gavrilo Kukic, Crni from Bileca.  Did you

15     know him?

16        A.   That's the one and the same Crni of whom I spoke at length, but I

17     didn't know what his name really was, now I know.

18        Q.   He is the Crni who was refusing to subordinate himself and then

19     was sent by Mladic somewhere?

20        A.   I know that that is him because he also told me that together

21     with four lads he managed to restore the possession of the repeater.

22        Q.   Thank you.  Now, 377, let's go back to the next page, where he

23     appears to speak about some Red Berets, seven or eight of them are

24     working for them, all they care about is stealing a car.  Are they the,

25     from what you can see then -- the men you were referring to under Crni?

Page 15399

 1        A.   And what is your question?

 2        Q.   The question is:  Did that Crni refer to his group as the

 3     Red Berets?

 4        A.   He didn't mention them to me.  He just mentioned those four lads

 5     and I don't know whether they were Red Berets.  He just said four lads.

 6     He did not specify who they were, whether they were civilians or

 7     soldiers.

 8        Q.   Thank you.

 9             MR. JORDASH:  Let's move on to 65 ter 5601, please.

10        Q.   And again this notebook starts off, as we'll see, with a whole

11     range of numbers, telephone numbers of, it seems, Mladic's contacts at

12     that point in time, and the diary starts at the 2nd of August, 1992.

13     Could we go, please, to page --

14             MR. JORDASH:  Could we go please to page 22 of the English and

15     B/C/S and 21 at the top of the page.

16        Q.   And it's is a meeting on Sunday the 2nd of August, 1992, with the

17     Presidency of the Serbian Republic of BH.  And Karadzic appears to be

18     there and speaking, and he says, or so it appears, "There are strong

19     autonomous tendencies present in Banja Luka."  And then if we just stay

20     there for a moment, that's J000-2197.  Then if we go across the page to

21     the next page:

22             "The Red Berets must be put under control right away.

23     Lieutenant-Colonel Sajic has established a group of brigades that

24     constitute an autonomist army."

25             Is that something that you are aware of, Mr. Milovanovic?

Page 15400

 1        A.   As I've already told you, on that day I was in Vranje.  However,

 2     as for that story about the autonomous movement, I learned all that

 3     perhaps a day or two later.  The man whose name you mentioned and in the

 4     meantime I've forgotten, did you say Sajic?  I believe someone from the

 5     1st Krajina Corps came to the Main Staff, I can't remember who it was,

 6     and he told us that Karadzic's idea was to create one state comprising of

 7     the Republic of Serbian Krajina and the Republika Srpska, and to that

 8     effect a declaration was passed under the name of Prijedor declaration or

 9     something like that.  However, at the outset it didn't make too much

10     sense or perhaps Karadzic was afraid that the world would not accept that

11     solution.  That is why people from the two Krajinas, the Bosnian Krajina

12     from the river Zoklena [phoen] to the Una and the Republic of the Serbian

13     Krajina, meaning the Krajina of Knin, Kordun, Banija, Western Slavonia

14     decided that a Krajina state would be created from those provinces or

15     states, if you will.

16        Q.   Sorry to interrupt, I just want to focus on Red Berets.  Could

17     you get to that point, please, if you know anything about them?

18        A.   I don't know anything.  My only encounter with the Red Berets was

19     with Mr. Simatovic and another colonel when we greeted each other and

20     spent a couple of minutes next to each other, somewhere near Kladusa in

21     that Cazin Krajina.  I've already spoken about that and I've told you

22     that I saw those Red Berets on them.

23             JUDGE ORIE:  Mr. Jordash, I'm looking at the clock.  I don't know

24     whether this would be a suitable time to ...

25             MR. JORDASH:  Can I just ask one question.

Page 15401

 1             JUDGE ORIE:  One question, please.

 2             MR. JORDASH:

 3        Q.   Colonel Sajic, who was he?  Lieutenant-colonel Sajic?

 4        A.   I heard of him but I can't put the name to a face.

 5             MR. JORDASH:  Fair enough.  Thank you.

 6             JUDGE ORIE:  And also not to a position, may I take it?

 7     Sometimes you know what position someone holds without knowing his face?

 8             THE WITNESS: [Interpretation] I don't know what his position was.

 9     I don't know what he looked like.  I only heard his name as part of that

10     story about the creation of a common state.

11             JUDGE ORIE:  Yes.  Thank you for that answer.  I'd like to

12     instruct you that you should not speak to anyone about your testimony,

13     whether that is testimony you've given today or even testimony you've

14     given earlier in this case, and testimony still to be given because we'd

15     like to see you back tomorrow at 9.00.

16             Could the witness first be escorted out of the courtroom.

17                           [The witness stands down]

18             JUDGE ORIE:  Mr. Jordash, I'd just like to inquire where we are

19     in terms of time?

20             MR. JORDASH:  I think two hours should do it.

21             JUDGE ORIE:  Yes.  You would just remain within the time-limits.

22     So you are expected tomorrow to finish in two hours because you've used

23     three hours now, you would scheduled five hours.

24             MR. JORDASH:  Certainly.

25             JUDGE ORIE:  So shortly after the first break tomorrow morning,


Page 15402

 1     because we adjourn until tomorrow, Wednesday, the 7th of December, 9.00

 2     in the morning in this same Courtroom II.

 3                           --- Whereupon the hearing adjourned at 7.02 p.m.

 4                           to be reconvened on Wednesday, the 7th day of

 5                           December, 2011 at 9.00 a.m.