Page 15486
1 Thursday, 8 December 2011
2 [Open session]
3 [The accused entered court]
4 [The witness takes the stand]
5 --- Upon commencing at 9.03 a.m.
6 JUDGE ORIE: Good morning to everyone in and around this
7 courtroom.
8 Madam Registrar, would you please call the case.
9 THE REGISTRAR: Good morning, Your Honours.
10 This is case number IT-03-69-T, the Prosecutor versus
11 Jovica Stanisic and Franko Simatovic.
12 JUDGE ORIE: Thank you, Madam Registrar.
13 Mr. Petrovic, you've got until 10.00. Please proceed.
14 But before you do so, Mr. Milovanovic, I'd like to remind you
15 that you are still bound by the solemn declaration that you have given at
16 the beginning of your testimony.
17 WITNESS: MANOJLO MILOVANOVIC [Resumed]
18 [Witness answered through interpreter]
19 JUDGE ORIE: Mr. Petrovic will now continue.
20 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
21 Further Cross-examination by Mr. Petrovic:
22 [Continued]
23 Q. [Interpretation] Good morning, General, sir.
24 A. Good morning.
25 MR. PETROVIC: [Interpretation] I would like to call up
Page 15487
1 65 ter 5604. In B/C/S it's page 77. In English it's page 79. English
2 79, B/C/S copy 77. The handwritten version also page 77. We have the
3 correct English page but now we are waiting for the Serbian page to
4 appear. If it is my mistake, please tell me, we made a double-check
5 yesterday to make sure that we've got the right page. I thank you.
6 Q. Mr. Milovanovic, please look at the document about a meeting of
7 the Supreme Command. The meeting took place on the
8 21st of January, 1993. General, sir, here Radovan Karadzic speaks about
9 the axis to the Drina. It says the situation is tragic because they
10 control 60 kilometres of the Drina bank. If you remember the events,
11 could you please tell us what part of the Drina bank is Radovan Karadzic
12 talking about?
13 A. I don't know when I'm supposed to start talking. I don't have
14 the transcript on the left-hand side of the screen.
15 MR. PETROVIC: [Interpretation] Can the usher be of assistance,
16 please.
17 THE WITNESS: [Interpretation] Okay. First of all, I have some
18 doubts about the date, 21 January 1993, because the 21st January 1993,
19 Karadzic and Mladic were either in Geneva or in London; in any case, they
20 were abroad, which means that no session of the Supreme Command could
21 have taken place on that date. Second of all, on the 21st of January,
22 Vance Owen's plan was violated in Ravni Kotari when Croatia attacked the
23 area of the Serbian Krajina. I don't have anything against that session
24 or the contents of the words that Karadzic used but the date is wrong.
25 MR. PETROVIC: [Interpretation]
Page 15488
1 Q. Okay. But could you please answer my question: What part of the
2 river bank did Karadzic have in mind and what event did he have in mind
3 when he uttered those words?
4 A. I believe that Karadzic is referring to the central part of the
5 Drina around Visegrad because on that date Visegrad power plant was
6 attacked by the Muslims.
7 Q. Do you remember the attack on Skelani and Bajina Basta? Did it
8 happen in January 1993?
9 A. Yes. Skelani was attacked on the 16th of January and the attack
10 lasted until the 23rd of January.
11 Q. The attack that we are talking about, the attack on Skelani, and
12 you say that it took place on the 16th, what happened? Were Serb
13 villages attacked, plundered and torched around Bajina Basta and its
14 environs, as much as you remember?
15 A. I don't know whether the fire was open on the territory of
16 Serbia. I know that during the war two shells were fired on
17 Mali Zvornik, I don't know if that was a mistake or not. And as for
18 Skelani, about 20 Serbian villages and hamlets were attacked before the
19 Muslims reached Skelani. And those villages were completely destroyed
20 and the population was expelled across the bridge near Bajina Basta.
21 About 20.000 people fled. The unit that defended Skelani which was an
22 independent Skelani unit broke up. They were crushed. We could not deal
23 with the problem with our units from Podrinje. I spoke to the commander
24 of the 1st Krajina Corps and ordered him to send me reinforcement. He
25 sent two battalions, and as soon as those battalions arrived within 24
Page 15489
1 hours the situation was resolved.
2 Q. It is stated here, or rather, Karadzic says we had to take
3 decisive action. What does he mean when he says that?
4 A. I don't know. I don't know what he means. I'm sure that I did
5 not attend that session. I'm looking at the list of the participants and
6 what people said. I wasn't there.
7 Q. Very well.
8 MR. PETROVIC: [Interpretation] Can we look at the following page,
9 please. Page 78 in B/C/S, page 80 in English.
10 Q. General, sir, look at Karadzic's words at the bottom of the page,
11 both in Serbian and in English. Karadzic says somebody decided that
12 Skelani should be evacuated. Do you know who decided that and why?
13 A. I don't know what information Karadzic had about the evacuation
14 of Skelani. That was not done according to any plan. The population
15 simply fled. I know when that was happening, that was happening on the
16 17 and the 18th of January. I sent my deputy, Colonel Ilic, to try and
17 stop the population and the Skelani battalion. The colonel came to the
18 bridge. He opened fire into the air but to no avail.
19 JUDGE ORIE: Mr. Petrovic asked you, on the basis of this text,
20 whether you could tell us who decided to evacuate Skelani. If you know,
21 tell us. If you say, I don't know who decided, or even if you say, No
22 one decided, please tell us, but don't give us the whole story of Skelani
23 because you are not asked to bring that story.
24 Do you know who decided to evacuate Skelani two or three days
25 before this meeting?
Page 15490
1 THE WITNESS: [Interpretation] There was no decision to that
2 effect. People simply fled.
3 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
4 And can we now look at the following page in the same document,
5 B/C/S 79, English 81.
6 Q. This is about a meeting which took place in President Cosic's
7 office. According to the document, the date is the same,
8 21st January 1993.
9 MR. PETROVIC: [Interpretation] Now can we go to the following
10 page, please.
11 Q. The following page, General Panic - at the very bottom of the
12 page - at the meeting with President Cosic, he says that the situation on
13 the Drina River is very bad. My question to you, sir, is this: Why was
14 the situation on the Drina River considered at the highest level in the
15 Federal Republic of Yugoslavia and President Cosic's office? Why was
16 that situation so important to merit a discussion at such a high level?
17 A. Because on that day preparation started for the peace conference
18 in Geneva. The leaders of Republika Srpska, Karadzic and Mladic and some
19 other people, were also there.
20 Q. Do you agree that the situation and the flight of some 20.000
21 people, threat to the facilities along the border, do you agree that this
22 had a rather unfavourable effect on the security situation in the
23 Republic of Serbia, i.e., the Federal Republic of Yugoslavia?
24 A. Yes.
25 Q. Thank you, General, sir.
Page 15491
1 MR. PETROVIC: [Interpretation] And now can we look at
2 65 ter 5605. B/C/S page 336 --
3 JUDGE ORIE: Mr. Petrovic, before we continue, all three judges
4 are lost as far as the relevance of the line of this questioning is --
5 the questioning is. If you could assist, please do so.
6 MR. PETROVIC: [Interpretation] Your Honour, I can do that. The
7 events along the Drina River about which the General has testified caused
8 an operation by the government of the Republic of Serbia and the
9 Federal Republic of Yugoslavia, the engagement of the military and the
10 MUP of the Republic of Serbia. The accused in this case participated in
11 that operation to a certain extent which is why we would like to explain
12 the circumstances that led to the operation at that -- a number of
13 Prosecution witnesses mentioned in their testimonies as well.
14 JUDGE ORIE: So we are just talking about the background what
15 caused some operational activity and --
16 MR. PETROVIC: [Interpretation] Yes, Your Honour.
17 JUDGE ORIE: -- is there dispute about what triggered, whether
18 there was concern about the situation at the Drina River, for example,
19 something we listened to in the last one or two minutes and why it should
20 be discussed at a high level? Is there any dispute about such a worrying
21 situation at the Drina River?
22 MR. GROOME: We haven't address this particular issue, but with
23 respect to the issue in Skelani and along the Drina, that's -- we have
24 already agreed that there were attacks against Serbs there. There were
25 infiltrations. That's all a matter of agreement in the course of this
Page 15492
1 trial.
2 JUDGE ORIE: Therefore, Mr. Petrovic, why do we go through it
3 again? Let's focus on the matters which are really in dispute. Please
4 proceed.
5 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
6 Q. Witness, sir, please look at this entry of 23rd September 1993.
7 A. I've seen it.
8 Q. If I understand correctly, these are demands of the VRS from the
9 Army of Yugoslavia?
10 A. This is just a conversation between General Mladic and
11 General Perisic. And, yes, you are right, General Mladic is asking for
12 something but verbally, not in writing.
13 Q. Look at item 12 where it says "Issues of status of officers."
14 Could you explain briefly, if you know, what was General Mladic asking
15 from the Army of Yugoslavia regarding the status of officers?
16 A. I said yesterday that the Army of Yugoslavia, that is to say, the
17 leadership of Yugoslavia, took upon themselves the obligation to pay and
18 provide housing and other benefits to the officers of the
19 Army of Yugoslavia who either remained or went to Bosnia-Herzegovina.
20 Those are issues of their status. We did receive reserve officers but we
21 could not pay them according to their rank. Those issues were dealt with
22 by the Army of Yugoslavia.
23 Q. You mentioned yesterday seven and a half thousand officers and
24 NCOs that served in the VRS but were paid funded by the Army of
25 Yugoslavia, did I understand that correctly?
Page 15493
1 A. Yes, I said that it was an agreement with the Army of Yugoslavia
2 that was signed by Vice-President Nikola Koljevic.
3 Q. Concerning those seven and a half thousand officers, what was
4 provided except their salaries?
5 A. Their next salaries were paid, benefits, health and pension
6 insurance were paid directly to their accounts in Belgrade, housing was
7 provided to VRS personnel, just as to the personnel of the
8 Army of Yugoslavia, and medical insurance.
9 Q. How many officers in total served in the
10 Army of Republika Srpska, roughly, if you know?
11 A. How many officers? I can't tell you the figure but I can tell
12 you that 21 per cent of professional officers and 79 per cent of reserve
13 officers served in the VRS. The 21 per cent were paid by VJ, the 79 per
14 cent by the VRS.
15 Q. So if I understood correctly, all professional officers were paid
16 by the Army of Yugoslavia?
17 A. Yes.
18 THE INTERPRETER: Could the witness and the counsel not overlap
19 and give us a pause between questions and answers, please.
20 JUDGE ORIE: You are invited not to overlap, Mr. Petrovic. So
21 could you please repeat your last question, Mr. Petrovic.
22 MR. PETROVIC: [Interpretation] I apologise, Your Honour.
23 Q. General, members of the Main Staff of the VRS, corps commanders,
24 brigade commanders, commanders of lower tactical units, all those
25 officers were financed by the Federal Republic of Yugoslavia, that is,
Page 15494
1 the VJ; right?
2 A. No, it's not right because we had commanders from battalion level
3 to brigade level, and those are the 79 reserve -- 79 per cent reserve
4 officers. The VJ paid only professional officers who made up
5 21 per cent.
6 Q. Let's make things simpler in this way. The highest-ranking
7 officers in the VRS and the most responsible officers in the VRS were
8 paid by the Federal Republic of Yugoslavia, could we put it that way?
9 A. We would agree the most easily if we say the VJ paid officers,
10 graduates of military academies and graduates of middle military schools.
11 Q. All right. That's clear then.
12 JUDGE ORIE: Mr. Groome, is there dispute about the payment of
13 the high-ranking officers?
14 MR. GROOME: No, Your Honour. I was actually contemplating and
15 standing up and objecting to relevance. I am not sure what the relevance
16 is of this line of questioning.
17 JUDGE ORIE: Mr. Petrovic, there's no dispute about it.
18 Relevance?
19 MR. PETROVIC: [Interpretation] Your Honours, the relevance lies
20 in the measure of contribution to the joint criminal enterprise charged
21 against my client. I can elaborate on that, if necessary, but that is
22 the gist of it.
23 JUDGE ORIE: But there's no dispute about high-ranking officers
24 being paid not by the VRS but by the JNA or what used to be the JNA.
25 MR. GROOME: Your Honour, I would be unable to verify precise
Page 15495
1 percentages, but in general principle there's no dispute about that.
2 JUDGE ORIE: Why are you spending so much time on one simple
3 question? Is it true, Mr. Milovanovic - you can do that even without
4 that - a large number of high-ranking officers were paid by the VJ rather
5 than by the VRS? The answer will be yes and we move on to the next one.
6 Why -- please proceed, Mr. Petrovic.
7 MR. PETROVIC: [Interpretation] Thank you, Your Honour.
8 Q. Item 13 in this document we are looking at, the status of repair
9 shops. Orao and Kosmos what is this about? Why is Mladic discussing
10 this with Perisic?
11 A. The repair shops Orao or Kosmos were for military equipment; Orao
12 for aircraft, and Kosmos was a universal factory for the repair and
13 maintenance of some rocket systems for defence. There was a problem at
14 the outset of the war: Who was going to manage those companies, the
15 Ministry of Defence of Republika Srpska or the Main Staff? And I know it
16 was decided that all repair shops in the territory of Republika Srpska
17 and special-purpose industries, that is, those producing ammunition,
18 should be managed by the Main Staff and that's how it was done until the
19 end of the war.
20 MR. PETROVIC: [Interpretation] Could we now look at another
21 point in the same document. Page 338 in the manuscript or in the copy
22 and English page 330. Bottom of the page, please, where
23 General Novakovic is speaking.
24 Q. Tell us, please, what is VOJIN, just in one sentence?
25 A. Air observation notification and guidance.
Page 15496
1 Q. This VOJIN system in the Republic of Serbian Krajina and
2 Republika Srpska, was it integrated with the same system in the FRY?
3 A. All VOJIN systems were integrated within friendly countries in
4 one region; that is to say, the Republic of Serbian Krajina,
5 Republika Srpska, and the FRY.
6 MR. PETROVIC: [Interpretation] Page 387 in the copy and 389 in
7 English.
8 JUDGE ORIE: Mr. Groome.
9 MR. GROOME: Could I request that Mr. Petrovic read out the dates
10 of these entries, it would be much easier for us to follow where he is.
11 JUDGE ORIE: Would you please follow this suggestion,
12 Mr. Petrovic.
13 MR. PETROVIC: [Interpretation] I will, Your Honour. I will now
14 tell you the date. 19 October 1993.
15 Q. May I put my question, General?
16 A. Yes.
17 Q. General Perisic is saying that military conscripts and officers,
18 if I understand correctly, should be directed -- he says those who don't
19 want to serve in the RS and RSK should be expelled from the army. Should
20 be expelled full stop. Do you know that troops who did not want to serve
21 from -- serve in the RS and the RSK were indeed expelled from the VJ?
22 A. I know this was started just as Perisic became Chief of the
23 General Staff and he was very diligent about it.
24 Q. Thank you, witness.
25 MR. PETROVIC: [Interpretation] The meeting of the 21st October,
Page 15497
1 1993, page 389 in the copy, and in English it's 390.
2 Q. Witness, look at this meeting, please. You can see the beginning
3 on this page before us and then we should turn the next page.
4 MR. PETROVIC: [Interpretation] Next page, please.
5 Q. General, the verification of promotions into general, you said
6 something about it, but clarify it. Who promotes and who confirms the
7 promotion? Can people be promoted without being confirmed?
8 A. There is no confirmation without promotion. Its the
9 Supreme Command of Republika Srpska that promotes officers into generals
10 and it is verified by the Supreme Command; that is to say, the
11 General Staff of the VJ.
12 Q. From what moment on does a prospective general of the VRS become
13 a general, really?
14 A. I can explain this using my own example. I was promoted into
15 lieutenant-general by decree of the president of Republika Srpska on the
16 28th of June, 1994, and my rank was verified sometime on the
17 25th December, 1995. I received a salary in the meantime of a
18 lieutenant -- of a colonel, not lieutenant-general.
19 THE INTERPRETER: Correction: Of major-general, not
20 lieutenant-general.
21 MR. PETROVIC: [Interpretation]
22 Q. Now, look at this meeting.
23 MR. PETROVIC: [Interpretation] Page 391 in the copy and 393 in
24 English.
25 Q. You attended this meeting too.
Page 15498
1 MR. PETROVIC: [Interpretation] Next page, please.
2 Q. It says the discussion goes on at the session. Officers are
3 requested from the FRY for the Gatac Brigade. What we see here, was it
4 normal practice to request the return or the sending of officers from
5 some VJ units? It says lieutenant-colonels and colonels; one in Topola,
6 one in Podgorica.
7 A. Yes, that was the practice. When the initial agreements were
8 made for officers who were natives of Republika Srpska to come back, it
9 was agreed then that officers serving in Kosovo do not have to come to
10 Republika Srpska. It will be recorded as service in the war and
11 similarly exempted where officers serving in some units that couldn't be
12 spared. But as for Colonel Andzic, he was a native of Herzegovina and
13 they needed him to become commander of this Gatac Brigade and this
14 Milivoj Radovic was also requested. This Gatac Brigade used to be a TO
15 brigade and then it was renamed into an infantry brigade.
16 Q. Thank you, Witness. At the same meeting, on page 394 in B/C/S
17 and 396 in the English translation, there is a reference to the
18 activities that needed to be carried out, the shortening of the front
19 line as a way to fight Dudakovic's forces, and to assist Fikret Abdic.
20 My question is this: How is Fikret Abdic assisted by the shortening of
21 the front line?
22 A. Let's clarify one thing. I had the text in front of me a minute
23 ago but I don't see it anymore because it's too small. The 2nd Corps
24 should fight Drekovic's force, not Dudakovic's forces. Drekovic was
25 commander before Fikret Abdic. Konjic is mentioned here. Drekovic was
Page 15499
1 moved from Bihac and became the commander of the Muslim
2 Herzegovina Corps. I believe it was the 6th Corps. Drekovic was here
3 and there at the same time. However, in the first came [as interpreted]
4 when our 2nd Corps is mentioned, the person made a mistake and used
5 Drekovic's name.
6 Q. So my question is: How is Abdic assisted by the shortening of
7 the front line facing the corps in Cazina Krajina?
8 A. The shortening of the front line is a tactical operation. By
9 shortening the front line, you don't lose much territory but you liberate
10 some of your forces that you can use to assist Fikret Abdic. I already
11 spoke at great length about what was the army of Fikret Abdic, or not.
12 Q. Was this task ever implemented as it is stated here? I remind
13 you that that was in October 1993.
14 A. I don't know whether the operation was implemented. I know that
15 Karadzic signed an agreement with Fikret Abdic but that was just the
16 beginning of Fikret Abdic's career and I really can't say much about
17 that.
18 Q. Thank you.
19 MR. PETROVIC: [Interpretation] Can we now look at 65 ter 5606.
20 In B/C/S it's page 53 and the same page in English.
21 Q. This is the front page describing the meeting which took place on
22 the 13th of December, 1993.
23 MR. PETROVIC: [Interpretation] And can we now look at the next
24 page, please.
25 Q. General, sir, you obviously attended that meeting; right?
Page 15500
1 A. Yes.
2 Q. You say here that you wanted assistance on the right bank of the
3 Drina. Do you remember why you requested that? And that request was
4 addressed at the representatives of the FRY who were also participants in
5 the meeting.
6 A. Yes. I tried to seek assistance from the FRY in the central and
7 upper Drina region.
8 Q. A few lines down, Karadzic says General Milovanovic has talked
9 about slow moving things or side things. Why did he say that, if you
10 know?
11 A. He didn't say side things but slow moving things; i.e., things
12 that should follow in the future, at least that's what it says here. I
13 don't know what he said exactly but I know that he didn't agree with my
14 words, and this is why: He wanted to carry out an offensive around
15 Sarajevo before some peace talks that were supposed to start on the
16 21st and the 22nd in Geneva. He made use of Mladic's absence from the
17 front line and he consulted with me, and then he said that we should take
18 Zuc, Mojmilo and Sarajevo, as well as some features and facilities in the
19 town itself, that there should be encirclement around Sarajevo to
20 liberate the Praca valley that UNPROFOR had given to Muslims as a
21 corridor between Sarajevo and Gorazde. In that conversation which took
22 place on the 10th of December, I refused his proposals and I tried to
23 convince him that that was impossible, that our military was not prepared
24 to do that, and then he called me back again on the 12th on the eve of
25 the meeting, that is described here, he invited me to come to Pale.
Page 15501
1 Again, he tried to persuade me to ask assistance from the FRY, the
2 assistance in life force. Again, I refused his proposals, and that's how
3 I left for the meeting because Mladic and I could not both be absent from
4 the front line, that's why I went to the meeting. In the first part of
5 my discussion I uttered a sentence and I said that if we wanted to comply
6 with Karadzic's request, we had to rely only on our forces, that we
7 should not drag the FRY into war.
8 In my second discussion, I wanted help on the right bank of the
9 Drina, if FRY was, indeed, willing to be engaged, and I requested
10 whatever is stated here. I knew that in Leskovac and Vranje there were
11 two battalion -- tank battalions and I requested those tanks. Karadzic
12 didn't like that and that's why he said what he did, that I'm talking
13 about slow moving things or Weinguard [as interpreted] things.
14 MR. PETROVIC: [Interpretation] Thank you. Page 57 in B/C/S and
15 58 in English.
16 Q. In the middle of that page, it says: Badza. The forces that are
17 request are indeed need and I support that.
18 My only question to you is this: Who is Badza?
19 A. Badza was the general lieutenant in the police or
20 lieutenant-general in the police. He was killed in Belgrade. I really
21 can't remember his name. I believe that his family name was Stojicic. I
22 believe that he was responsible for the Special Police Units in Serbia.
23 Q. Thank you, Witness.
24 JUDGE ORIE: Mr. Petrovic, are you really serious in asking this
25 witness who Badza is? We've heard about Badza for a year now on a daily
Page 15502
1 basis. Do we need this witness to tell us who Badza is? Or is there any
2 dispute about this Badza being present at this meeting, then ask the
3 witness whether he knows whether the Badza mentioned here was present at
4 that meeting and who he is so that we -- and identify him. But to say we
5 see the name Badza, could you tell us what the name Badza, who you
6 considered him to be, is that really after a year that -- but please
7 explain yourself, don't take too much time for it because you have only
8 10 minutes left. Is it that this witness knows something about the
9 presence of this person and if --
10 MR. PETROVIC: [Interpretation] Your Honour.
11 JUDGE ORIE: Yes.
12 MR. PETROVIC: [Interpretation] Your Honour, I just wanted to see
13 what this witness knows about that person because I wanted to know what
14 the perception of Badza was in the eyes of this witness. I didn't put
15 the question to him because I thought that nobody here knows who Badza is
16 but I wanted to hear from a general in the Serbian army whether he knew
17 who that person was. I thought it was important but if Trial Chamber
18 thinks that this is not relevant at this point in time, I will not dwell
19 upon it.
20 JUDGE ORIE: Fine. But then ask a different question than "Do
21 you know who Badza is," because then we get the answer and no additional
22 information whatsoever, mainly that he thinks that he remembers the
23 family name which sounds rather familiar to us, unless there's any
24 dispute about this Badza.
25 MR. GROOME: Your Honour, if I could assist Mr. Petrovic,
Page 15503
1 General Milovanovic spoke about a meeting or an encounter he had with
2 Badza in his direct examination.
3 JUDGE ORIE: Well, now we know that what Mr. Milovanovic told us
4 on the very general question, the very general question being ...
5 MR. PETROVIC: [Interpretation] With your leave, I have just a few
6 more questions and that will be my cross-examination to an end. I will
7 not dwell upon this issue any longer.
8 JUDGE ORIE: Please proceed.
9 MR. PETROVIC: [Interpretation] Thank you, Your Honour. Can we
10 now look at page 42 in the same document, that's in B/C/S and in English.
11 Q. The meeting was held on the 22nd of November, 1993. General,
12 sir, you attended the meeting, if I am not mistaken, and you took the
13 floor. You spoke about the need to launch war production. You talked
14 about materiel and technical equipment, and the overhaul of the
15 equipment. First of all, tell us why is this mentioned at the meeting?
16 You were the one who spoke about that so I suppose that you know?
17 A. First of all, I'm not sure that I was present at the meeting on
18 the 22nd of November, 1993. However, here when General Mladic is quoted,
19 he is quoted as saying General Milovanovic has just informed us about
20 this or that or the other. It's possible that a day before on my
21 birthday I informed Mladic about that. I was not at that meeting in
22 Belgrade and you can see that Djukic and Mladic from the Main Staff
23 attended, the assistant commander for logistics and the commander
24 himself. I wasn't at that meeting. I told you yesterday that I was
25 responsible for the distribution of a strategic materiel, and here I just
Page 15504
1 suggested what the commander of the Main Staff should do and how he
2 should do that.
3 Q. Just tell us, please, materiel and technical equipment, were they
4 repaired in the FRY and what materiel and equipment was repaired?
5 A. Were they repaired in the FRY?
6 Q. Yes.
7 A. Sir, the Army of Republika Srpska inherited almost all the giants
8 in terms of repairs facilities of the former JNA, save for the company in
9 Cacak which is in Serbia. We had Hadzici for the repairs of heavy
10 artillery. We also had Kosmos for the repairs of rockets. We also had a
11 facility called Orao to repair airplane engines, and we, ourselves,
12 repaired the materiel and equipment belonging to the Army of Yugoslavia.
13 They paid us for that.
14 Q. Thank you, sir.
15 MR. PETROVIC: [Interpretation] And now can we look at just one
16 more document which is 5607, pages 34 and 35, but let's first look at
17 34 in B/C/S and 33 in English.
18 Q. It says here "Co-ordination." This is about a meeting which took
19 place on the 19th of January, 1994. What kind of a meeting was that?
20 That meeting bears the name co-ordination. What type of a meeting was
21 that, why is it called co-ordination?
22 A. I don't know. Because it would be General Djukic, the assistant
23 commander for logistics, that chaired this meeting, but when I look at
24 the contents, I can see that they are talking about recruits and about
25 the Republic of Serbian Krajina.
Page 15505
1 Q. Let's look at the following page, maybe that will help you shed
2 some light on who co-ordinated whom, what, and why.
3 JUDGE ORIE: Two minutes left, Mr. Petrovic.
4 MR. PETROVIC: [Interpretation]
5 Q. If you don't know, never mind, it's okay.
6 A. I can see that it was the co-ordination of logistics between the
7 Army of Republika Srpska, the Army of the Republic of Serbian Krajina and
8 Fikret Abdic's army.
9 Q. Thank you, General, sir.
10 MR. PETROVIC: [Interpretation] Thank you. And I have no more
11 questions nor witness.
12 JUDGE ORIE: Thank you, Mr. Petrovic.
13 Mr. Groome, are you ready to re-examine the witness.
14 MR. GROOME: Yes, Your Honour.
15 JUDGE ORIE: Mr. Milovanovic, you will now be further examined by
16 Mr. Groome who, as you know, is counsel for the Prosecution.
17 Mr. Groome, please proceed.
18 MR. GROOME: Thank you, Your Honour.
19 Further Re-examination by Mr. Groome:
20 Q. Good morning, Mr. Milovanovic. I do not have many questions for
21 you today. I do want to clarify some of the evidence you provide in
22 response to questions by Mr. Jordash and Mr. Petrovic this week. My
23 first question relates to a date. I will read a portion of Tuesday's
24 transcript, and I ask you to focus on the date and tell us whether the
25 transcript has correctly he recorded your evidence about this date. At
Page 15506
1 transcript page 15348, Mr. Jordash asked you the following question:
2 "Now, I appreciate from what you've told us before that you were
3 not with him during the events in Srebrenica in 1995, during the
4 massacres there; is that correct?"
5 The pronoun "him" was a reference to General Mladic. Your
6 response was, and it begins at line 14:
7 "Beginning with the 28th of October, 1994, until the
8 15th of October, 1994, I was not with Mladic all the time. I was in the
9 west in Drvar and Banja Luka ..."
10 And it continues on. Has the transcript correctly recorded your
11 evidence with respect to the transcript that you were in the Banja Luka
12 area?
13 A. Yes.
14 Q. So it seems somewhat illogical that you were somewhere from the
15 28th of October in the year 1994 until the 15th of October in the year
16 1994?
17 A. Sorry, it was 1995. You are right.
18 Q. So the transcript should read that you were there until the 15th
19 of October 1995; is that correct?
20 A. Correct.
21 Q. Now, at transcript page 15338 and following, on Tuesday,
22 Mr. Jordash asked you a number of questions regarding the military
23 airfields used by the VRS during the conflict. I would like to now ask
24 you some questions to clarify your evidence. As I understood your
25 evidence, you were referring to military air facilities under the control
Page 15507
1 of the VRS and not every air strip in Bosnia and Herzegovina; is that
2 correct?
3 A. Only the airfields used by the VRS. And speaking of airfields, I
4 meant to ask for a correction. When I was looking on the map, on the
5 non-existent part of the map, an airfield near Glamoc, I marked Crni-Lug
6 2 or 3 centimetres to the north, whereas it is actually to the south of
7 Crni-Lug village. I later looked and map, so it's not to the north of
8 Crni-Lug that Glamoc Polje airfield, it's to the south of Crni-Lug.
9 Q. Mr. Jordash may have another opportunity to ask you questions and
10 may seek to clarify the precise location.
11 Were there other places in Bosnia-Herzegovina where small
12 aircraft or helicopters could land, apart from the airfields that you
13 identified?
14 A. Helicopters were able to land anywhere. We had heliports in
15 Crni Rijeka, near Han Pijesak, for the Main Staff, a heliport at Pale for
16 the Supreme Command, another heliport in Kalinovik, in all major free
17 places near barracks. As for auxiliary airfields where aircraft could
18 take off and land, apart from these four, I don't know about any others
19 and because we didn't use them and there was no need for me to be
20 interested in them. It was Bratunac, Zaluzani, Mahovljani, Bijeljina and
21 the one in Glamoc Polje. Sorry, not in Bijeljina but Prijedor.
22 Q. General Milovanovic, if a helicopter was needed in an military
23 operation, is it possible to create an improvised landing area for that
24 helicopter?
25 A. Yes, it was only up to the pilot to choose a flat piece of land,
Page 15508
1 not to overturn the helicopter, and at night-time you do it by crossing
2 the headlights of four vehicles.
3 Q. So do I correctly understand your evidence that to create an
4 improvised airfield at night, you simply need to arrange four vehicles
5 with their headlights on and the intersection of the headlights indicates
6 the place where the helicopter should land?
7 A. Yes, he will, in fact, be able to see where he is landing.
8 Q. Now, in 1997 Frenki Simatovic, one of the accused in this case,
9 gave a speech recounting the history of the Red Beret unit in a ceremony
10 attended by senior officials of Serbia. A transcript of that narrative
11 is in evidence as P61. Mr. Simatovic said that the Red Berets acquired
12 helicopters in May of 1991 and landed those helicopters on a number of
13 improvised airfields in Bosnia. Are you able to say whether or not this
14 occurred?
15 MR. JORDASH: Sorry, I object to that. I think that the speech
16 aspects of what Mr. Simatovic actually said should be put to the witness.
17 Mr. Groome has actually, I think, mis-characterised it.
18 JUDGE ORIE: Okay. If there is any I dispute about what was said
19 [overlapping speakers] ... please.
20 MR. GROOME: I will quote, Your Honour.
21 Q. I'm going to read you the quote from that portion of the speech:
22 "In May 1991, an air helicopter squadron was formed which
23 transported tonnes of special shipments, equipment, troops, and machinery
24 from the improvised airfields of Medin Polje, Petrovac, Velika Popina,
25 Srb and Udbina and carried out numerous complex tasks while war
Page 15509
1 operations were ongoing."
2 Again, my question to you is: Are you able to say from your own
3 knowledge whether what Mr. Simatovic says about improvised airfields is
4 true or is not true?
5 A. I don't know. I was in Macedonia at the time. There was no war
6 at the time. It was 1991. The SFRY was at its full strength. Wherever
7 helicopters flew, it was legal.
8 THE INTERPRETER: And the interpreter didn't hear the last
9 sentence.
10 JUDGE ORIE: Could the -- the question has been answered by the
11 first four words, I don't know --
12 MR. GROOME: Yes, Your Honour.
13 JUDGE ORIE: Yes. Nevertheless, we need a full transcript,
14 unfortunately, so we'll have to ask the witness to repeat what he said,
15 although the answer is clear already. Could you please repeat the last
16 part after you said: "The SFRY was at its full strength. Wherever
17 helicopters flew, it was legal."
18 And what did you say after that?
19 THE WITNESS: [Interpretation] After that, I said I know that
20 Medin Polje World War II used to be a partisan airfield.
21 JUDGE ORIE: Please proceed, Mr. Groome.
22 MR. GROOME:
23 Q. General Milovanovic, Mr. Simatovic goes further in the speech to
24 say that the Red Berets' use of aircraft remained undetected by NATO.
25 Are you able to tell us how a helicopter might be used in a way that
Page 15510
1 evaded detection by a sophisticated military organisation such as NATO?
2 Is that possible?
3 A. It's possible. I also flew by helicopter and I was never
4 detected until General Morillon complained about it. It's called a
5 swiping type of flying where the helicopter flies according to the lay of
6 the land.
7 MR. GROOME: Now, could I ask that P2933 be brought to our
8 screen. It is a one-page entry from General Mladic's notebook. It is
9 dated 16th of December, 1991. And this is J000-3714.
10 Q. Now, General, yesterday at transcript page 15436, Mr. Jordash put
11 to you that there was no mention of Stanisic prior to the
12 2nd of July, 1993. I would like to show you an entry in the diary
13 related to when references can be found to the State Security of Serbia.
14 General, I ask you to look at the entry that's now on the screen before
15 you, again from the 16th of December, 1991. In it we see Mladic
16 recording information provided by a person he refers to as Rade Siptar
17 and records his -- that's information as:
18 "Dule Orlovic, Filipovic - Fica and Frenki," and after Frenki's
19 name in parentheses is the word "Serbian DB." "They want to give some
20 3.000 barrels to the Muslims in Bihac."
21 Now, my first question to you regarding this entry, General, is:
22 Based on your experience with General Mladic, when he wrote "3.000
23 barrels," what was that a reference to?
24 A. In the army when you say barrel, it means infantry weapons, it
25 could be a pistol, rifle, anything up to the 12.7 millimetres
Page 15511
1 machine-gun.
2 Q. Am I correct that the B/C/S word that Mladic used was "cevi,"
3 c-e-v-i? Is that the word that is used in the original of the diary?
4 A. I don't understand the question. That's what is written, "3.000
5 cevi," and I'm making my comment as an expert that it is -- that it means
6 infantry weapons.
7 MR. PETROVIC: [Interpretation] Your Honour.
8 JUDGE ORIE: Mr. Petrovic.
9 MR. PETROVIC: [Interpretation] Your Honours, I don't know where
10 further questions by my learned friend are going, but I'm concerned
11 because I don't know from which part of my examination or Mr. Jordash's
12 examination these questions follow concerning this part of the report.
13 If my learned friend is now leading new evidence, I don't think it's
14 right -- it's the right time and that should have been done a year ago,
15 not today.
16 JUDGE ORIE: Mr. Groome.
17 MR. GROOME: Your Honour, as I said, or as I prefaced my
18 question, on Tuesday at transcript 15436, I am sorry, it was yesterday,
19 Mr. Jordash put to the witness that there was no mention of Mr. Stanisic
20 in his diary until the 23rd of July, 1993. This is a clear reference to
21 the Serbian State Security Service much earlier than that date and
22 predates the commencement of the war.
23 MR. JORDASH: It's a reference to Frenki of the Serbian state
24 security. It's not a reference to Stanisic. And they are not the same.
25 [Trial Chamber confers]
Page 15512
1 JUDGE ORIE: The objection is denied.
2 Please proceed.
3 MR. GROOME:
4 Q. General Milovanovic, the word "barrel" in English can mean the
5 barrel of a gun, it can also mean a container to contain oil or some
6 other liquid. Is there any interpretation of the word "cevi" as used in
7 this sentence that can mean something other than the barrel of a gun or
8 an infantry weapon?
9 A. Serbian language is not very clear. It could be a tube, a pipe,
10 like a drain pipe or a smoke pipe or something in the middle of a sheet,
11 but Mladic wouldn't be talking about sewage or water-supply pipes,
12 something as -- as something in which the DB of Serbia would be involved.
13 It's barrels of a gun.
14 Q. Now, General, this is three and a half months before the outbreak
15 of the conflict in Bosnia, and Bihac is in Bosnia. Any idea why Frenki
16 would want to give 3.000 infantry weapons to the Muslims of Bihac?
17 A. I don't see that Frenki is providing "cevi" barrels. I can
18 understand it in two ways. Perhaps Frenki is providing barrels or maybe
19 Frenki discovered that somebody else is providing barrels. I believe
20 it's the seconds because political parties had started to arm the
21 citizens, the SDS is arming Serbs and the SDA is arming Muslims. I
22 cannot really be sure whether Frenki is providing guns or he discovered
23 somebody else was providing guns.
24 MR. GROOME: Your Honour, would that be a convenient place to
25 take the morning break?
Page 15513
1 JUDGE ORIE: That is a convenient moment. We'll take a break and
2 we resume at quarter to 11.00.
3 THE INTERPRETER: Just one correction from the interpreters. At
4 page 24, line 21, the proper translation of the type of flying is low
5 flying or hedge hopping.
6 JUDGE ORIE: Yes, I was just wondering whether following the
7 scape of the land, whether that would be at low altitude.
8 We resume at quarter to 11.00
9 --- Recess taken at 10.18 a.m.
10 --- On resuming at 10.49 a.m.
11 JUDGE ORIE: Mr. Groome, are you ready to proceed?
12 MR. GROOME: Yes, Your Honour.
13 JUDGE ORIE: Please do so.
14 MR. GROOME:
15 Q. General Milovanovic, I'd like to move to a different topic now.
16 On Tuesday Mr. Jordash asked you about establishing effective
17 communication with subordinate units of the VRS and you said at
18 transcript page 15342:
19 "I was told to organise communications with our subordinated
20 units that we had at the time and to start receiving reports from the
21 field effectively on the 12th of May."
22 Do I take from this that beginning on the 12th of May, 1992, you
23 began the process of building effective communications between the VRS
24 Main Staff and the military structures subordinate to it?
25 A. Yes.
Page 15514
1 Q. How long did it take before you established what you believed to
2 be effective communication with subordinate units?
3 A. I established the communications in the course of the 12th
4 because I had inherited the war time command posts of the former JNA
5 corps so I didn't have many technical issues to solve.
6 Q. Now, the VRS, like other military organisations, had several
7 levels from the Main Staff down to the commander of a company or tank
8 unit. When you said that you were able to establish effective
9 communications on the 12th, is it your evidence that you were able to
10 establish such communications between the Main Staff and all subordinate
11 VRS units?
12 A. Only between the Main Staff corps commands and the command of the
13 air force and air defence.
14 Q. Did it take longer to establish effective communication with all
15 the subordinate units?
16 A. Yes. That took around a month and a half.
17 Q. Now, when you use the word "communication," do you mean to
18 include both reports coming into the Main Staff and directives or orders
19 going out to the Main Staff to subordinate units?
20 A. There are several types of communications, radio communications,
21 wire communications, signals communications and courier communications.
22 Radio and wire communications were set up in the course of that day so we
23 were able, both verbally and in writing, to communicate with corps
24 commands using teletype.
25 Q. And how long before you had the full plethora of communications
Page 15515
1 up and running?
2 A. Concerning the first two type of communications, radio and wire,
3 that was done on the 12th, and the rest gradually. I can't tell you
4 exactly how long it takes to provide courier communications. Depends on
5 the distance between the correspondence. From the Main Staff to the
6 Drina Corps it took two hours, from the Main Staff to the 1st
7 Krajina Corps six hours, to another corps 12 hours, depending on how long
8 the courier takes to get there.
9 Q. Now, also in answer to Mr. Jordash's questions, you spoke about
10 the daily briefing, and you said:
11 "Every morning between 6.00 and 7.00, the Main Staff received
12 reports from subordinates. It would be either General Mladic or myself
13 who received them."
14 I will ask you in a few minutes about one of these particular
15 briefings but can I ask that you tell us now how it was decided whether
16 you would receive the briefing or whether Mladic would receive that
17 briefing?
18 A. The reports were supposed to be received by General Mladic. In
19 his absence, I would receive them as his deputy. I told you we shared an
20 office and it was not hard to see whether he was there or not.
21 Q. And if he was absent, would you take any steps to brief him about
22 what was the information you received at the morning briefing?
23 A. I did not have the obligation to call him. He had the obligation
24 to call me and inquire if there was anything new.
25 Q. And was it his practice do so?
Page 15516
1 A. Yes.
2 Q. And do you know approximately what time of the morning or the day
3 he would call to receive a briefing or an update about the morning
4 briefing of the Main Staff?
5 A. Depends on his location. If he was on the front line, that would
6 usually be in the morning and he would call me from one of the corps
7 commands. If he was outside Bosnia-Herzegovina, he would usually call in
8 the evening when all the conditions for communicating with me were there,
9 especially if he was outside of Serbia even.
10 Q. Now, I'd like to address a number of exhibits that Mr. Jordash
11 worked with over the course of the last two days. Yesterday at
12 transcript page T15409 Mr. Jordash showed you 65 ter 5602, pages 40 and
13 51, corresponding to ERN numbers J000-1170 and J000-1181 of the original
14 notebook. Both of these entries are from a meeting on the 15th of
15 September, 1992. I want to return to page 40.
16 MR. GROOME: And if I could ask that 65 ter 5602, e-court page 40
17 in the English be brought to our screens. I believe it's also page 40 in
18 the B/C/S. And it's J000-1170.
19 Q. Now, when Mr. Jordash showed you this yesterday, he referred you
20 to a portion where the commander of the Eastern Bosnia Corps is talking
21 about Mauzer. And I'll wait till we have that on the screen. Can you
22 see it now on the screen before you?
23 A. I see it.
24 Q. Now, Mr. Jordash didn't work with the continuation of the report,
25 particularly with respect to Mauzer.
Page 15517
1 MR. GROOME: Could I ask that we turn to the next page in both of
2 these versions, the translation and the original.
3 Q. I'd like you to read what the commander continued to say with
4 respect to point number 2, Ljubisa Savic. He says:
5 "The morale of our unit has been weakened from the moment of
6 engagement of the MUP of Serbia."
7 My question to you is based on your experience and work with
8 General Mladic, can you help us to understand what is meant by this
9 entry?
10 A. I don't know what he meant. I don't know where the MUP of Serbia
11 was engaged and why. Yesterday Mr. Jordash only asked me whether on the
12 previous page a reference to Ljubisa Savic was also a reference to Mauzer
13 to which I said yes.
14 Q. Would the fact that General Mladic wrote this comment under the
15 heading, point 2, "Ljubisa Savic," indicate whether he believed Mauzer or
16 Ljubisa Savic had some relationship to the MUP of Serbia?
17 A. I can only answer that by saying probably, but I'm not sure.
18 MR. GROOME: Could I ask that we go to e-court page 55 in English
19 and the same page in the original, and the J number is J000-1185.
20 Q. A bit later in the same entry on the page I believe you now see
21 before you, Branko Grujic, president of the Zvornik municipality, speaks.
22 He says:
23 "Under the command of Marko Pavlovic we did everything."
24 A few lines later he speaks about someone named Dzokanovic. And
25 that's D-z-o-k-a-n-o-v-i-c. And he says, "Dzokanovic is causing lots of
Page 15518
1 problems around Zvornik." You've given evidence about Zvornik over the
2 last couple of days. Are you familiar with this person Dzokanovic and
3 who he might be.
4 A. First of all, I don't have the handwritten B/C/S version which
5 exists in English. Now I have it. I don't know who that Dzokanovic or
6 Dukanovic was, and I also don't know who Marko Pavlovic was.
7 MR. GROOME: I've finished with that exhibit. Can I ask now that
8 P2543, another entry from Mladic's notebook, be brought to the screen.
9 It's date the November 22nd 1995. It appears to be a record of a
10 briefing meeting. Could I ask that General Milovanovic be shown the
11 first page so that he can orient himself to the date and the meeting.
12 The ERN of this page is J000-0195.
13 Q. General, if you let us know when you have finished reading that
14 page, I've few questions before I take you to a specific portion.
15 A. Does it start with General Tomic?
16 Q. The translators or the people who have transcribed it recorded
17 that as General Talic. Could it be General Talic?
18 A. Yes, yes, yes, you are right. Sorry.
19 Q. When you've read it if you indicate that and I'll ask you a
20 question before I turn the page.
21 A. Yes, I've read the page.
22 Q. General Milovanovic, just above the name of General Talic is the
23 text "briefing by the officers." Would this indicate that this entry is
24 a record of the Main Staff briefing of the 22nd of September, 1995?
25 A. Yes, but not at the Main Staff but at the forward command post of
Page 15519
1 the Main Staff which means that the briefing took place in Banja Luka.
2 Q. And is this the same daily meeting that you've referred to
3 earlier in your evidence?
4 A. No. It was something else but only the commanders of the Krajina
5 units were involved, the first and the 2nd Krajina Corps, the training
6 centre, the anti-aircraft defence and the air force. All those commands
7 were based in Banja Luka at that time.
8 MR. GROOME: Could I ask that we advance to e-court page 4 in the
9 original in English and the ERN is J000-0918.
10 Q. Now, in the intervening pages after the notes under Talic's name
11 we can see similar brief notes under the names of General Tomanic,
12 General Ninkovic, General Gvero, Colonel Djurdjevic, Colonel Kukobat, and
13 then your name, General Milovanovic, appears. Are we correct to conclude
14 that the text appearing under each name is the information that that
15 particular officer provided on that day?
16 A. I don't see my own name. The last name I see is
17 General Ninkovic. I am sorry, yes, General Milovanovic. I can see that.
18 General Mladic actually recorded what we said to him.
19 Q. Now, can I ask you to read what he recorded you as having said
20 that day, and it goes on to the next page, so when you've read this page,
21 please indicate that and I'll ask that we advance to the next page.
22 MR. JORDASH: Sorry, could I just inquire as to how this arises
23 during re-examination? Or from the cross-examination, I should say.
24 MR. GROOME: Could we ask perhaps the witness to take off the
25 earphones, I think is best.
Page 15520
1 JUDGE ORIE: Yes. Mr. Milovanovic, I don't know whether I ever
2 asked you, so you speak -- do you understand English?
3 THE WITNESS: [Interpretation] No.
4 JUDGE ORIE: Then could you take off your earphones. I might
5 have asked it before, but -- Mr. Groome.
6 MR. GROOME: Your Honour, yesterday, I think it was the day
7 before, Mr. Jordash spent a considerable amount of time eliciting that
8 there was an order in June of 1992 prohibiting paramilitaries from being
9 present on the territory under the control of the VRS. And if you look
10 in this particular entry, the entry that he is reading now and that I
11 will ask him about refers to a delegation of members of State Security
12 Service and the word paramilitary is even used to describe them. So I'm
13 using this to counter Mr. Jordash's suggestion that the order of
14 June 1992 prevented or did not permit members of the -- of Arkan's unit,
15 of Bozovic and others to be on the territory of the Republika Srpska.
16 MR. JORDASH: Well, the first thing is that the word
17 "paramilitary" is not used to describe them. I don't accept this arises
18 during -- from the cross-examination, but I withdraw the objection
19 because I think Mr. Groome having made that assertion, Mr. Milovanovic
20 might be able to deal with it.
21 JUDGE ORIE: Yes, then could you please put on your earphones
22 again, Mr. Milovanovic.
23 You may proceed, Mr. Groome.
24 MR. GROOME:
25 Q. Perhaps while we were speaking, you have already completed
Page 15521
1 reading the notes under your name. Have you done that?
2 A. Yes, I have read the page that is in front of me. I don't know
3 whether there is anything else.
4 Q. There is some. It continues on to the next page.
5 MR. GROOME: So if we could please advance to the next page.
6 Q. Indicate when you have completed reading the entry and then I'll
7 ask my question.
8 MR. GROOME: With respect to our conversation or our discussion
9 out of the hearing of the witness, it is the first line of this page that
10 I was referring to.
11 THE WITNESS: [Interpretation] I've read the page. It was quite
12 easy to read the first half of the page. The bottom part, however, is
13 somewhat less legible, so I'm not sure whether my understanding of it is
14 correct.
15 MR. GROOME: Your Honour, this is an important matter, and I have
16 a printed copy. If there's no objection, could we provide the witness
17 with a printed copy of this and perhaps ...
18 JUDGE ORIE: I hear of no objections, so please proceed as
19 suggested.
20 MR. GROOME:
21 Q. General Milovanovic, there's now a printed copy of that exhibit
22 before you. Perhaps you can advise us whether that's more legible than
23 the television screen?
24 A. This is not a printed copy. This is again handwriting, a
25 handwritten copy.
Page 15522
1 Q. I misunderstood you. So you would prefer to have what, a typed,
2 what a transcriber read from it?
3 A. Yes.
4 Q. That will take a few moments for us to locate. Perhaps I can ask
5 you some questions and if you are -- you may be able to answer them with
6 the portion that you are able to read, and if you think you would like to
7 read the other one, still, at the end of my question, we'll do our best
8 to get that as quickly as possible.
9 Now, my first question relates to the information that you
10 provide General Mladic that a team from the State Security of Serbia
11 appeared here. When you said they appeared here, did you mean that they
12 appeared at the forward command post in Banja Luka?
13 A. A day or two before that President Karadzic, who was in
14 Banja Luka as well to discuss the defence of Banja Luka, told me that
15 some people would arrive from the MUP of Serbia. He didn't say DB. He
16 told me that I should receive those units that would arrive from Serbia.
17 Those would be the Special Police Units that would help us to defend
18 Banja Luka. I know only too well that that Filipovic arrived as well as
19 the colonel whom I met near Kladusa. He was in the company of
20 Mr. Frenki. His name was Bozovic and he spoke with a Montenegrin accent.
21 They told me that they would arrive and they mentioned different
22 figures. First they mentioned three brigades and then the number was
23 reduced down to some 900 men. And they were looking for a place where
24 they would be billeted. Since they were police officers, I thought that
25 that was part of co-operation between the two MUPs, the MUP of
Page 15523
1 Republika Srpska and the MUP of Serbia. That's why I suggested that they
2 should contact our MUP. The MUP had some premises near Banja Luka. The
3 name of that facility was Rakovacke Bare. My suggestion was that they
4 should be billeted there. I don't know anything else about those police
5 officers. I don't think that they ever arrived, but as it says here,
6 Arkan appeared on the front line with 300 Tigers. He was chased away in
7 1992 and then he returned in 1995. I discovered his presence when I
8 learned that he had beaten up some Serbian officers. I asked for
9 Karadzic for a meeting to ask him who had approved Arkan's arrival
10 because I was firm in claiming that Arkan had entered my area of
11 responsibility without my approval. Karadzic finally after my ultimatum
12 organised a meeting with Arkan in Banja Luka in the temporary office of
13 the president of the state.
14 Q. General --
15 A. This is all I can tell you about this.
16 Q. There's a few very precise questions I'd like to ask you about
17 this entry. Do you know how they came, whether this delegation from the
18 State Security Service of Serbia came by road or by helicopter or some
19 other means of transportation?
20 A. I don't know. I never bothered to ask them. They appeared in my
21 office in the command of the 1st Corps. I used at the office of the
22 chief of the corps staff, General Lekovic. Our military police escorted
23 them to the building and since I knew that people from the MUP of Serbia
24 were supposed to arrive, I received them and I talked to them about the
25 topic that I just covered.
Page 15524
1 Q. General --
2 A. Filipovic was there and perhaps Bozovic was there as well, I
3 don't remember.
4 Q. Perhaps if we work through my questions one at a time, we'll be
5 able to understand your evidence a bit more clearly.
6 In this entry, you not only talk about the visit of this
7 delegation but you also, as you've just told us, you refer to the arrival
8 of 300 of Arkan's volunteers. My question to you is simply: Does the
9 fact that both of these --
10 MR. JORDASH: Sorry to jump up. Could Mr. Groome be careful
11 about leading on these issues, please.
12 JUDGE ORIE: Mr. Groome.
13 MR. GROOME:
14 Q. Does the -- does the fact that both of these entries are in the
15 same -- both of these -- both of this information, or all of this
16 information, is in the same entry indicate anything about the time
17 relationship between those two events?
18 A. Yes.
19 Q. Can you please explain?
20 A. First the two police colonels arrived, Filipovic and Bozovic.
21 Arkan did not arrive at that time. He simply appeared somewhere in the
22 vicinity of Kljuc and Prijedor. But that happened a few days later, or
23 perhaps even a month later.
24 Q. So am I correct in understanding from what you've just told us
25 that you reported the information about Bozovic and Filipovic
Page 15525
1 approximately a month after it occurred?
2 A. No. I reported the information about Rakovacke Bare to those men
3 immediately because they left and I never saw them again after that. And
4 as for Arkan, as I've already told you, he appeared somewhat later.
5 Perhaps even a months later he appeared on the frontline.
6 Q. Then can you explain to us how that would appear in this
7 particular entry, this entry of the 22nd of September?
8 JUDGE ORIE: Mr. Milovanovic, the text reads "300 Arkan's
9 volunteers arrived and were put into the RS MUP," which suggests that
10 when this was written that they had arrived already and that they were
11 already put into the RS MUP. That's what Mr. Groome's question is
12 focusing upon, Mr. Groome, if I understood you well?
13 MR. GROOME: That's correct, Your Honour.
14 THE WITNESS: [Interpretation] That was on the day when the
15 briefing took place and I suppose that I related to Mladic the history of
16 the events. I'm not saying that they appeared on the day when the
17 briefing took place. They had appeared earlier than that and the
18 briefing took place on the 22nd of September. I can't remember when
19 exactly they appeared, but, in any case, they appeared before the
20 briefing and Arkan also appeared before the briefing and I can claim that
21 in view of the fact that I was in a position to brief the commander about
22 the strength of his unit.
23 Arkan appeared on the 16th of September or a day or two later. I
24 know that because on the 16th of September we lost Kljuc. Kljuc fell
25 into Muslim hands and the first place where Arkan appeared was around
Page 15526
1 Kljuc, somewhere near Kljuc.
2 MR. GROOME:
3 Q. Now, General, how did you know that Bozovic and the others that
4 represented themselves to be members of the State Security Service of
5 Serbia, how did you know that they were, in fact, who they were
6 representing themselves to be?
7 MR. PETROVIC: [Interpretation] Your Honour.
8 JUDGE ORIE: Mr. Petrovic.
9 MR. PETROVIC: [Interpretation] I may be mistaken but I believe
10 that they introduced themselves -- according to the witness, the witness
11 said that they had introduced themselves as representatives of the MUP of
12 Serbia. That's the way I understood the witness.
13 JUDGE ORIE: At the same time we see in the document a team from
14 the Serbian DB state security appeared. So we have two versions of the
15 way in which they introduced themselves, one written and one as just
16 explained per the witness. I think everyone keeps that in its mind.
17 What seems to be the gist of the question put to the witness is that how
18 would he know that they were who they claimed they were, isn't it,
19 Mr. Groome?
20 MR. GROOME: Yes, Your Honour. Perhaps I can be a little more
21 precise in my question, if I can take another try at it.
22 JUDGE ORIE: Please do.
23 MR. GROOME:
24 Q. You've given us evidence that Mr. Karadzic had foretold of the
25 arrival of some people from the Serbian MUP. Now, can I take it that by
Page 15527
1 the time these men arrived at your office they would have had to have
2 gone through some security --
3 MR. JORDASH: Can we -- objection to the leading nature of the
4 question.
5 JUDGE ORIE: Let me see. Mr. Groome, you wanted to ask the
6 witness whether they had to go through any kind of security.
7 MR. GROOME:
8 Q. Yes, prior to arriving in your office, would this delegation have
9 had to have identified themselves to gain access to the compound where
10 you were, the forward command post?
11 A. The policeman from the centre post called me to tell me that
12 people from the MUP of Serbia had arrived. And since Karadzic had told
13 me only a few days before that that they would arrive, I received them.
14 It was not up to me to take their IDs. They introduced themselves as
15 Filipovic and Bozovic. I knew that they were supposed to arrive, and
16 they immediately started discussing the issue of billeting, those men,
17 that they were supposed to follow them. I did not check their identity.
18 Q. Do you know how you learned and in turn conveyed to
19 General Mladic that they were from the state security of the Serbian MUP?
20 A. Believe me, I really don't know how I conveyed that to
21 General Mladic. However, those men spoke about Special Police Units. I
22 knew intuitively that they were talking about the DB of Serbia. I really
23 don't know why it occurred to me to tie them to the state security, but I
24 did.
25 Q. Now, Mr. Jordash asked you a series of questions with respect to
Page 15528
1 the decision by the VRS Main Staff to expel paramilitaries in June of
2 1992. Were members of the Serbian MUP who were present in Bosnia engaged
3 in official work considered paramilitaries for the purpose of that
4 decision of June of 1992?
5 A. As far as I know, Serbian MUP was not engaged in that. As I told
6 you yesterday, the commander had talked to the commanders of those
7 militaries. The process lasted from the 12th of May to the 28th of June.
8 Then it was finalised by General Mladic's order on chasing the
9 paramilitaries away from the area.
10 Q. Now, what I'm asking you now is: Did that order include members
11 of the Serbian MUP who were present in Bosnia-Herzegovina on official
12 business?
13 A. No. Those were military organisations that were not part of the
14 Republika Srpska army.
15 Q. Now, my next question is: How would members of the VRS be able
16 to distinguish between people that came from Serbia who were Serbian MUP
17 officials on official business, and paramilitaries that had come from
18 Serbia and were to be expelled?
19 A. First of all, those who arrived on official business from Serbia
20 did not have to hide. Their ID was checked at border crossings. Their
21 arrival was announced. And as for the others, and I told you what
22 paramilitary units those were which were not within the system of the
23 VRS, they were Mauzer's Panthers, Arkan's Tigers, Zuca and Crni, and
24 several groups around Sarajevo. We knew very well who paramilitaries
25 were.
Page 15529
1 Q. Now, when you use the word "their IDs were checked," are you
2 speaking about a national identification card or a Serbian MUP
3 identification card?
4 A. Sir, it was only on the 27th of July, 1992 that we agreed how
5 border crossings would be controlled with the MUP of Serbia. Until then
6 it was the police of Republika Srpska that controlled border crossings.
7 As Chief of Staff, I was not duty-bound which of the politicians entered
8 the territory of Republika Srpska. It was the police of Republika Srpska
9 who had to control that. It was only after the 27th of July that we and
10 the then minister of the interior, Mico Stanisic, and the deputy prime
11 minister, Milan Trbojevic, agreed that at some border crossings there
12 would be mixed patrol, military and civilian police patrols, that is.
13 Q. If someone had a Serbian MUP identification cart on their person,
14 did that permit them to move freely in the area controlled by the VRS?
15 A. No. Nobody was able to move in the combat zone, and the person
16 coming was certainly not coming to inspect the army. He was coming for
17 negotiations with MUP or politicians, not the army.
18 MR. GROOME: Could I ask that we now see P2544. This is an entry
19 a week later from the 29th of September, 1995, and records a meeting
20 between Mladic and Karadzic. It is a single page that's been put on
21 e-court and it bears the number J000-0938.
22 Q. General, in this relatively brief entry there is a reference to
23 Jovica Stanisic which says:
24 "Jovica Stanisic is angry about something. (He gave 300 of his
25 men and the US is begrudging us for having advertised Arkan)."
Page 15530
1 As I said, this occurs one week after your briefing to General
2 Mladic that Arkan had arrived in the area. Can you help us understand
3 this entry?
4 A. I don't understand what you are asking.
5 Q. Well, let me ask you, the 300 that is recorded here, he gave 300
6 of his men, is this a reference to the Serbian MUP personnel that was
7 discussed a week earlier with you?
8 A. I said I don't know whether these policemen, promised me by
9 Filipovic and Bozovic, came at all, but I said that Arkan arrived with
10 300 of his men and I don't know who organised it. I don't know that to
11 this day, and I don't mind telling you that I look forward to testifying
12 in Karadzic so I can have it out with him. I still don't know who
13 approved Arkan's arrival. Karadzic doesn't admit it. Arkan said he came
14 at the written invitation of Karadzic, but when we expelled him from
15 Bosnia-Herzegovina, two days later he was given a sending-off ceremony by
16 the president, by the supreme commander with various decorations and
17 commendation, et cetera. The same president who never found the time to
18 inspect a single one of our brigades.
19 Q. General, you perhaps more than any other person in this courtroom
20 is familiar with General Mladic's writing and his way of conveying
21 information. Can you help us, when he says he gave 300 of his men, are
22 you able to tell us who is the "he" that Mladic is referring to?
23 A. This says literally Jovica ST, must be Stanisic, is a bit angry.
24 In brackets, he provided 300 men, and now there's a grudge against us
25 that we had advertised Arkan. I cannot draw any conclusion from this
Page 15531
1 sentence. This seems to mean that those 300 men were provided by
2 Jovica Stanisic and that Arkan showed up and he commanded those people
3 and we are giving high profile to Arkan instead of Jovica Stanisic. I
4 don't know that any policeman had come. I'm telling you again, but I
5 know that Arkan came with 300 men.
6 MR. GROOME: Can I ask that we look at just one other entry.
7 It's from the very next day, and it's P2545. And it's a meeting of the
8 30th of September, 1995. And the J number is J000-0939.
9 Q. And again could I ask you to read this entry before I ask you any
10 questions. In this -- in this -- this entry from the notebook it records
11 General Perisic as saying:
12 "Come on, Jovica, let's see what steps can be taken to have some
13 more crossover and to burn that thing."
14 Can you assist us given your knowledge about the time and what
15 was taking place at that time, what is "burn that thing" a reference to,
16 if you know? If you are unable to assist, just please indicate that.
17 A. I can't assist either you or myself. How can I know what Perisic
18 meant?
19 Q. The meeting --
20 JUDGE ORIE: Mr. Groome, I'm looking at this document, also
21 looking at the translation. Now, I remember that there was once an issue
22 about had embedded himself or was embedded. Now, my recollection doesn't
23 go so far that whether it was this portion or not. If it was this
24 portion, then, of course, we should use the new agreed translation, I
25 would think. That's one. And if it's a different portion, then I think
Page 15532
1 there would be a reason to carefully verify the translation here. That
2 came to my mind.
3 MR. GROOME: Your Honour, your memory is very accurate. A note
4 has just been handed to me that this is the old translation, not the
5 corrected one. I will not ask about that and I will see that the correct
6 version ...[overlapping speakers]
7 JUDGE ORIE: [Overlapping speakers] I saw that it was on our
8 screen and, therefore, I'm very much inclined to seek the highest level
9 of precision. Please proceed.
10 MR. GROOME:
11 Q. Now, the entry goes on and records a Jovica as saying:
12 "There is no command there, political conflicts, cities are
13 falling...," and it continues.
14 Can you assist us with the following: What location is a person
15 by the name of Jovica referring to as having no command and where cities
16 are falling, again based on your understanding of what was taking place
17 at the time?
18 MR. JORDASH: Sorry, that is just an invitation to speculate. I
19 mean, how could the witness possibly know?
20 JUDGE ORIE: Let's ask him whether he knows, and if he says he
21 knows what the source of his knowledge is.
22 Any clue, Mr. Milovanovic, that if Jovica says there's no command
23 there that you would know to what location or area he referred to?
24 THE WITNESS: [Interpretation] If it is Jovica Stanisic, in fact,
25 it doesn't matter which Jovica it is, this man is right. The period
Page 15533
1 concerned is the time of the defence operation of Republika Srpska
2 against the Croatian Operation Storm. After the fall of Glamoc and Knin,
3 cities continue falling one after another, Drvar, Kljuc, Petrovac,
4 Sanski Most. Fighting is going on for Novi Grad which is mentioned here.
5 There's fighting close to Manjaca and the Ugar River. The command of the
6 1st Krajina Corps is practically out of operation. Whoever said this is
7 completely right. The command of operative levels from corps down is
8 devastated.
9 JUDGE ORIE: Whether he is right or not wasn't the question. The
10 question was whether you could shed any light on what the their would
11 have been, and what you've told us now is that on the basis of your
12 knowledge on what happened in late September 1995, that an absence of any
13 command you knew that there was in the area that you described, and that
14 for that reason you consider it a possibility that the person, reported
15 to be speaking here, referred to that same area, that's more or less what
16 I understand your testimony to be; is that correctly understood?
17 THE WITNESS: [Interpretation] Yes. Briefly it's the area of
18 Novi Grad and Sanski Most.
19 JUDGE ORIE: Thank you. And we have the basis now, Mr. Jordash,
20 because you were concerned about speculation. I think we have the basis
21 for --
22 MR. JORDASH: Yes.
23 JUDGE ORIE: -- what the witness doesn't exclude as being
24 referred to.
25 Mr. Groome.
Page 15534
1 MR. GROOME: Could I now ask the Court Officer to call up to our
2 screens --
3 JUDGE ORIE: Before we do so, I would have one additional
4 question.
5 Mr. Milovanovic, looking at the time-frame and looking at the
6 text, Jovica saying we sent 400 people. Now, you earlier said what the
7 MUP people offered, that was an offer which never materialised, do you
8 have any explanation because it seems here, as Jovica is saying, that
9 they sent 400 people and that it helped at Sanski Most and in Novi Grad.
10 You said this offer from the Serbian MUP officials, well, that was the
11 last thing you heard about it and then we have other information about
12 300 of Arkan's Men arriving. But here Jovica says: We sent 400 people
13 and the comment is such that it could be interpreted as they were really
14 sent and had arrived because otherwise you would not say that it helped
15 at Sanski Most and Novi Grad.
16 Could you shed any further light on an offer without any
17 follow-up and now a report of an arrival of 400 men by a person Jovica?
18 THE WITNESS: [Interpretation] First of all, I believe I said I
19 don't know that they ever arrived. I never saw them. And these 400 men
20 mentioned by this Jovica, I never saw them. But he, himself, mentions
21 the areas of Sanski Most and Novi Grad. Nobody was able to help
22 Sanski Most. It fell. But we managed to keep Novi Grad. Twelve days
23 before this Kozarska Dubica was attacked by the regular Croatian army,
24 and the whole conglomerate was made in the Western Krajina and the whole
25 purpose of the Croats was to take Banja Luka.
Page 15535
1 JUDGE ORIE: Please proceed. I'm re-reading your answer on
2 previous questions, but please proceed meanwhile, Mr. Groome.
3 MR. GROOME: Your Honour, I'm moving to a different area but I'm
4 happy to return to it if the Chamber would like any assistance in
5 exploring it further.
6 Can I now ask that 65 ter 5603 be brought to our screens. If we
7 could go to e-court page 256 in the original and the English, and it is
8 J000-4671.
9 Q. Now, General, yesterday at transcript page 15416, you were shown
10 an entry from this notebook at e-court pages 253 and 254. The original
11 pages being J000-4672 and J000-4673. This was an entry from a meeting on
12 the 7th of December 1992 with the leadership of Bosanski Samac. I would
13 like to show you a page not shown to you by Mr. Jordash from the same
14 entry, the same meeting. On the page before you Stevan Todorovic states,
15 quote -- Sorry, I don't believe we have it yet, do we?
16 THE REGISTRAR: We need the e-court page, please.
17 MR. GROOME: My records indicate e-court page 256. And we are
18 looking at it on our internal systems on that e-court page.
19 JUDGE ORIE: I could just take the witness back. Earlier you
20 said, Mr. Milovanovic, you thought these were all MUP people and that
21 they should get in touch with the MUP, although the notebook says that
22 they should be incorporated not in the MUP but in a -- forgive me what
23 unit was mentioned, but clearly military unit, and then you say:
24 "I don't know anything else about those police officers. I don't
25 think that they ever arrived."
Page 15536
1 And then you moved on discussing Arkan.
2 That thought, that they never arrived, was that based on anything
3 specific?
4 THE WITNESS: [Interpretation] I said that before I saw this
5 transcript and the words of this Jovica. I said I don't know whether
6 they ever came. Now, I see this Jovica claims they did and I have no
7 reason to disbelieve it.
8 JUDGE ORIE: Mr. Milovanovic, that's not what you said. You are
9 now rephrasing your previous answer: "I said I don't know whether they
10 ever came." What you said is "I don't think that they ever arrived,"
11 which is not the same, and you are aware of that, I take it? The one is
12 a thought that something did not happen; the other is a thought that you
13 do not know whether something happened. Are you aware of the difference?
14 THE WITNESS: [Interpretation] I am. When I was talking a moment
15 ago, I said, according to your version, that I think they never arrived.
16 But a couple of minutes later, I saw on the screen a confirmation by some
17 Jovica that they did arrive, so I have to change my opinion. A few
18 minutes ago I thought that they had never arrived but now when I see this
19 on paper I have to change my view, and I believe that they did, they must
20 have.
21 JUDGE ORIE: Yes. And could you give us, then, perhaps -- at
22 this second entry, Jovica also says that I think there were -- let me try
23 to find that again. Yes, that it helped at Sanski Most and Novi Grad.
24 What happened in Sanski Most and Novi Grad where the 400 people sent
25 could have helped at that point in time? Was that combat? Was that --
Page 15537
1 THE WITNESS: [Interpretation] Yes, yes. Sanski Most and
2 Novi Grad were attacked. Novi Grad was preserved. The attacked was
3 repelled, but Sanski Most fell. We lost it.
4 JUDGE ORIE: Yes. And in view of the fact that the offer was to
5 incorporate them in a certain unit of the army, do you understand the
6 reference to Sanski Most and Novi Grad as having been helpful in the
7 military operations in those areas?
8 THE WITNESS: [Interpretation] Precisely. Those 400 men were
9 probably meant to reinforce one of the VRS units.
10 JUDGE ORIE: Please proceed, Mr. Groome.
11 MR. GROOME: I have one follow-up question with respect to your
12 answers to the Judge Orie's questions. But while I'm asking that
13 question, could I ask the two documents on the screen, could we reverse
14 one page on each one. Could we go to the page before the ones that we
15 see on the screen. The entry begins at the bottom -- or the portion I
16 want to work with begins at the bottom of the screen.
17 JUDGE ORIE: Mr. Groome, if you would then allow me already one
18 additional question. The operations in relation to Sanski Most and
19 Novi Grad, was the 1st Krajina Corps involved in those operations?
20 THE WITNESS: [Interpretation] Yes, the 1st Krajina Corps with one
21 staff unit, that is the protection regiment, because after Sanski Most
22 the 1st Krajina Corps ceased to exist.
23 JUDGE ORIE: Thank you.
24 Please proceed, Mr. Groome.
25 MR. GROOME:
Page 15538
1 Q. General, having listened to you answer the questions of
2 Judge Orie, can we take from this that it is possible that at this time
3 you were not fully aware of the full involvement of Serbian MUP personnel
4 in Bosnia-Herzegovina?
5 A. I've already said I wasn't aware of it at the time.
6 MR. GROOME: Now, if we could now turn our attention to
7 65 ter 5603, and I apologise to the Court Officer for some of the
8 confusion. The B/C/S, the original, was correct that just disappeared
9 from our screen. If we could return that. And with respect to the
10 English, it's e-court page 256. So it's B/C/S e-court page 264 and
11 English e-court 256.
12 Q. And, General, I want to focus on the entry beginning with Mladic
13 recording what Stevan Todorovic, the police chief of Bosanski Samac,
14 said. If you could read that short bit. When you have, indicate so and
15 I will advance to the next page. Now, on this page we are now looking at
16 e-court in the original 265 and in the English 257. Stevan Todorovic is
17 recorded as having said:
18 "Sent 18 men to Ilok for training, and on 18 April 1992, they
19 were transferred in three helicopters together with 30 volunteers from
20 Kragujevac, among them two members of the Serbian MUP, Dragan Djordjevic,
21 aka Crni, and Aleksandar Vukovic."
22 Do you have any direct knowledge about the transfer of
23 Dragan Djordjevic and Aleksandar Vukovic in three helicopters around this
24 time-period?
25 A. No, I don't.
Page 15539
1 Q. Would you be able to assist us in identifying what helicopters
2 might have been used? Would VRS helicopters have been used or possibly
3 used for such a task?
4 A. Could you just tell me the date. I forgot.
5 Q. This is -- talking about the 18th of April, 1992, so mid-April
6 1992, the transport of 30 volunteers and several others in three
7 helicopters?
8 A. No, they could not have been helicopters of the VRS because at
9 that time we had neither an army nor helicopters. JNA were still ruling
10 in Bosnia-Herzegovina.
11 MR. GROOME: Now, Your Honour, before -- this is the last
12 unadmitted Mladic notebook entry that I'm going to work with today.
13 Mr. -- or both Defence teams have tendered the entire series of
14 notebooks. I know that is a matter we'll discuss later, but I do want to
15 note that the Prosecution is interested in tendering this particular
16 excerpt and we'll raise it when we discuss the matter in full.
17 Could I ask that we go now to P2533 [Realtime transcript read in
18 error "P2433"]. It's a notebook entry, the 19th of December, 1993.
19 JUDGE ORIE: Mr. Petrovic.
20 MR. PETROVIC: [Interpretation] Your Honour, I apologise. Perhaps
21 I am a bit late with this. In the previous document there's reference to
22 General Bojic, but I believe that is a translation error. I think it's
23 General Bajic, but we can check that later. It's the previous document
24 we looked at. Page 1, it says "General Bojic," I think it's in fact a
25 reference to General Bajic.
Page 15540
1 JUDGE ORIE: I don't know exactly what the impact would be but if
2 the parties could agree on what person a reference to made to, then of
3 course the Chamber would consider that, and it might lead to a correction
4 of the transcript and the translation.
5 MR. GROOME: Can I just inquire whether Mr. Petrovic thinks it
6 would be helpful to have a person who is familiar with General Mladic's
7 handwriting look at and see -- look at the particular page and see
8 whether he can decipher it, or is it simple a matter of translation?
9 MR. PETROVIC: [Interpretation] I think it could be helpful. The
10 suggestion of my learned friend Mr. Groome is very constructive.
11 MR. GROOME: Could I ask that we return to 65 ter 5603. I
12 understood from Mr. Petrovic's intervention that it was on the first
13 page, if that's correct.
14 Q. General, you've been listening to Mr. Petrovic question the name
15 of one of the generals, perhaps it's a general that you know. Can you
16 see, can you find it on the first page of 65 ter 5603 and tell us what
17 the correct version of this person's name is, if you can tell. Sorry
18 that's the first page that I called up which is B/C/S -- e-court 264.
19 A. Am I supposed to be looking under Stevan Todorovic or a bit
20 further up?
21 MR. PETROVIC: [Interpretation] At the bottom of the page in B/C/S
22 under the name Stevan Todorovic.
23 THE WITNESS: [Interpretation] I believe that he was an air force
24 general. His name was Bajic, Ljubomir Bajic. This has to do with
25 helicopters and aircraft. As far as I know, Bajic was the commander of
Page 15541
1 the air force corps in Banja Luka and then after the war he was
2 commander, no, he wasn't the air force commander. In any case, he was
3 connected with the air force. I used to know a General Bojic who served
4 in Kosovo and he became general just before retirement. He was an
5 infantry man, therefore he didn't have --
6 MR. GROOME:
7 Q. General, can I take it, based on your experience, the name Bojic,
8 which we see on e-court page 256 in the English and 264 in the original,
9 you believe it to be Bajic, B-a-j-i-c; is that correct?
10 A. Yes. Yes.
11 JUDGE ORIE: Mr. Groome, I'm looking at the clock. Time for a
12 break unless ...
13 MR. GROOME: No, Your Honour, I'm very near -- I'm at the very
14 end, but I do have a two-minute audiotape to play and another document to
15 bring up. So I think.
16 JUDGE ORIE: That's it --
17 MR. GROOME: It probably makes sense, I think I will be finished
18 within the first ten minutes of the next session.
19 JUDGE ORIE: Yes. Then we take a break. We resume at 25 minutes
20 to 1.00, and then we expect you then to finish within the 15 minutes
21 after that.
22 --- Recess taken at 12.05 a.m.
23 --- On resuming at 12.39 p.m.
24 JUDGE ORIE: Mr. Groome, are you ready to proceed?
25 MR. GROOME: Yes, Your Honour, thank you.
Page 15542
1 Q. General Milovanovic, over the break I was reviewing your evidence
2 this morning, and there was one question that I had posed that you hadn't
3 given a complete answer to. I'd like to pose the question to you again.
4 It was at transcript 29 today. It was when we were talking about
5 communications of the Main Staff. And my question was: When you use the
6 word communication, do you mean to include both reports coming into the
7 Main Staff and directives or orders going out of the Main Staff to
8 subordinate units? In your answer you began to describe some of the
9 technical means for disseminating information or communications. Can I
10 ask you to focus on the part of the question, when you use the word
11 "communication," do you mean both reports coming in and directives and
12 orders going out or one or the other?
13 A. Both. It was two-way communication. Our subordinates reported
14 to us and we communicated with them.
15 Q. Thank you for clarifying that.
16 MR. GROOME: Could I ask that we go to P2533. It's the last
17 notebook entry that I will work with you during your evidence. It's an
18 entry dated the 19 of December, 1993.
19 Q. While that's being called up, yesterday at transcript 15369,
20 Mr. Jordash asked you about where Mauzer might have gotten supplies from,
21 and you did not have information about that, didn't know. I want to show
22 you this entry and see whether it refreshes your recollection about
23 Mauzer and his relationship with other organisations.
24 MR. GROOME: Could I ask that we focus on the bottom of the first
25 page.
Page 15543
1 Q. And right next to the number 1 is roughly where I would ask you
2 to begin reading. Now, here we see in this entry of the 19th of
3 December, 1993, Mladic list the names of four people, Predrag Jesuric,
4 Savo Kojic, Mauzer, and Dragan Micic. And immediately afterwards he
5 makes the observation:
6 "They have had strong contacts with Serbia's SDB until very
7 recently."
8 Based on your knowledge and work with General Mladic, can you
9 assist us in understanding what he means by this sentence?
10 A. I don't know what General Mladic meant. General Mladic arrived
11 from Knin long before me, I, myself, arrived only on the 11th of May,
12 when everything was already over.
13 Q. Having read this entry does it refresh your recollection to any
14 additional evidence you may possess with respect to who Mauzer may have
15 had relationships with?
16 A. Unfortunate I can't.
17 Q. Thank you, General. The last thing I want to ask you about in
18 your evidence today is about the tape that you are asked to listen to
19 last evening. Now, the government of Serbia provided the Office of the
20 Prosecutor not only with notebooks but with audiotapes recovered from the
21 Mladic home. The ERN of the number of the tape that you listened to
22 yesterday was T001-2432.
23 MR. GROOME: I see Mr. Jordash has an objection.
24 MR. JORDASH: Yes, I have an objection to the use of the fresh
25 evidence. Number one, it is new evidence. Number two, it doesn't arise
Page 15544
1 through re-examination. Dealing with the first point, it's new evidence
2 which the Prosecution should have led during their case. It will
3 require -- will prejudice the Defence and will require investigation.
4 And the investigation that it will require will be close examination of
5 this tape, and at the moment the transcript says the speakers are
6 unidentified. I know Mr. Groome wants to ask Mr. Milovanovic to identify
7 the speakers which will then give rise to all manner of investigations
8 which include tracking down those who allegedly are speaking on the tape
9 and ascertaining exactly who they are and trying to meet whatever point
10 my learned friend wants to make about this tape. This at the end of the
11 Stanisic Defence case. In relation to not arising during re-examination
12 did not touch upon anything to do with supplies of Pauk.
13 JUDGE ORIE: Mr. Groome, but first perhaps, Mr. Petrovic, do you
14 take the same position as Mr. Jordash or would you like to add ...
15 MR. PETROVIC: [Interpretation] Yes, Your Honour.
16 JUDGE ORIE: Mr. Groome.
17 MR. GROOME: Your Honour, just before I deal with the objection,
18 can I just note for the record at page 57.4 it lists the previous exhibit
19 that I worked with as "2433." It is "P2533." So in order to avoid
20 confusion.
21 Your Honour, during Mr. Jordash's examination of this witness he
22 spent some substantial time on pointing out that there was no entry in
23 the diaries of Mr. Stanisic until the 2nd of July, 1993, and then he
24 asked questions about was he -- was it a topic -- was Mr. Stanisic a
25 topic that was discussed at the Main Staff.
Page 15545
1 So I don't prejudice the witness's evidence but perhaps it might
2 be more prudent to ask the witness to remove his head set.
3 JUDGE ORIE: Could I invite you to take off your earphones for a
4 moment, Mr. Milovanovic.
5 MR. GROOME: I selected this particular audiotape of the many
6 audiotapes recovered from the home for the following reason, and I would
7 note that this audiotape was on our 65 ter list: In it we hear a
8 conversation between Mladic and other people, and it is true that we --
9 there are -- they have not been fully identified. But throughout that
10 conversation that are several references to Jovica Stanisic. There is a
11 discussion between Mr. General Mladic and others about Jovica Stanisic.
12 This directly contravenes the assertion put to the witness by Mr. Jordash
13 that he was not a topic of discussion with General Mladic. I also note
14 that there are several references to Manojlo, and as the Chamber knows
15 that is the witness's first name. It's perhaps likely that the witness
16 will recognise that this is a conversation that he is aware of. He
17 possibly could be one of the speakers, but certainly for the simple
18 reason that Mr. Stanisic is mentioned by name several times in a
19 discussion held by General Mladic and tape recorded by General Mladic is
20 a basis for asking the witness questions about it. I would also point
21 out, Your Honour, it's on the Defence 65 ter list as well.
22 JUDGE ORIE: Mr. Jordash.
23 MR. JORDASH: I would only add if it was on the Prosecution's
24 65 ter list then they had it in their possession and ought to have used
25 it at the appropriate time.
Page 15546
1 JUDGE ORIE: Yes, which is not an answer to that the questions
2 are triggered by what you addressed during your further
3 cross-examination.
4 MR. JORDASH: Well, my learned friends has rightly put it that I
5 suggested that Mr. Stanisic wasn't a subject of conversation in the years
6 before his first appearance with Mladic on the 2nd of July, 1993. This
7 transcript isn't dated but I'm pretty sure it's 1994.
8 JUDGE ORIE: Mr. Groome, any answer to that.
9 MR. GROOME: Your Honour, I believe it's still -- we don't know
10 the date. The witness may be able to assist us. I believe it's still
11 relevant for the reasons that I have stated. I do want to correct some
12 misinformation I provided. The audiotape is not on our 65 ter list, it
13 is on the Stanisic Defence 65 ter list.
14 JUDGE ORIE: And why was it not on your 65 ter list, is that to
15 do anything with the availability of the material when you drafted your
16 65 ter list.
17 MR. GROOME: I suspect that it has something to do with it,
18 Your Honour, but when the Chamber sees the contents of the audio, there's
19 not all that much relevant information in it. So it's not that the
20 substance is what is relevant or what is being advanced, it's simply the
21 fact that Mr. Stanisic is being discussed by General Mladic and possibly
22 other members of the Main Staff.
23 JUDGE ORIE: Let me just have a look. One second, Mr. ... so you
24 would say it's not primarily the -- until the 2nd of July but rather
25 whether Mr. Stanisic was a topic that was discussed irrespective of
Page 15547
1 whether it was before or after the first entry in the written notebooks
2 on the 2nd of July, 1993?
3 MR. GROOME: Well, Your Honour, I'd have to go back and check
4 exactly the question that Mr. Jordash put to the witness but I have a
5 distinct memory of the witness being rather emphatic that Mr. Stanisic
6 was not someone who was discussed among members of the Main Staff and I
7 understood his answer to be rather broad in temporal scope.
8 JUDGE ORIE: Could you give us some guidances. What is the
9 portion of -- was it the 6th or the 7th?
10 MR. GROOME: I believe -- one second, Your Honour. I have it in
11 reference to another question. It's at transcript 15436, which I believe
12 was yesterday, Your Honour.
13 JUDGE ORIE: The problem is that in e-court my 6th of December
14 transcript has not been replaced by the definitely one. Do you have one
15 or two words which would allow me to find the relevant place.
16 MR. GROOME: [Microphone not activated] ... Your Honour, uses --
17 I'll read the passage. It was the question that you had asked, actually.
18 It said:
19 "Judge Orie: The question was whether Mr. Stanisic and
20 Mr. Stanisic's co-operation with the VRS, whether that was something
21 discussed at meetings of the Main Staff. That was the question or was it
22 not."
23 And the answer was:
24 "There was never any discussion about Jovica Stanisic as chief of
25 the State Security of Serbia."
Page 15548
1 JUDGE ORIE: Now, the problem is if I try to find "co-operation"
2 in my WordWheel, it doesn't work.
3 MR. GROOME: Your Honour, if you WordWheel "irregularly," that's
4 three lines above it.
5 JUDGE ORIE: We are still talking about the 6th or about the 7th?
6 MR. GROOME: This is the 7th, Your Honour.
7 JUDGE ORIE: The 7th, yeah, then it's not a surprise that I don't
8 find anything on the 6th.
9 MR. GROOME: So i-r-r-e-g should bring this up, Your Honour.
10 JUDGE ORIE: Yes. Let me first get the transcript of the 7th on
11 my screen. Yes. It's at page 33 of the old version.
12 The objection is denied. The basis in the answers of the witness
13 gave in cross-examination is sufficient to allow the Prosecution to
14 proceed.
15 Please proceed, Mr. Groome.
16 MR. GROOME:
17 Q. General, can you hear me?
18 A. I can.
19 Q. General, last evening you were asked to listen to an audio
20 recording. It was ERN number T001-2432. A portion of that audio
21 recording has already been introduced into evidence as P2956. My first
22 question to you regarding that audio is: Did you have an opportunity to
23 listen to it before today?
24 A. No, I didn't hear it before.
25 Q. I'm inquiring now is whether the technical equipment worked and
Page 15549
1 were you able to listen to it yesterday evening?
2 A. I listened to it, but I would like to know from you whether the
3 contents of the tape are the same as the contents of the transcript that
4 you provided me with.
5 Q. A transcriber has listened to the tape and done what they believe
6 to be their best job at recording what was said. Do you ask that because
7 you notice that there were some important differences, or important
8 omissions?
9 A. No, no, I simply noticed that my name was mentioned in a
10 different number of times. At place it was mentioned 17 times and at
11 other places more times. However, the contents of the conversation
12 between Mladic and the person, the unknown person, what I could hear and
13 what was described is pretty much the same.
14 Q. Are you saying now that your name was -- appeared in the
15 transcript at a time when you could not hear it on the audiotape?
16 A. Precisely. It seems that the person who transcribed the
17 conversation had better listening conditions available to him so he could
18 hear the tape much better than I did. And that's why I asked you whether
19 the contents are the same.
20 JUDGE ORIE: Let's be very practical. Mr. Groome, do you want to
21 deal with the whole of the audio or with specific portions?
22 MR. GROOME: Going to ask some general questions about the time
23 and the participants and then I just have a 2 minute 30 second portion I
24 want to ask specific questions about.
25 JUDGE ORIE: Then we've heard from the witness that, here and
Page 15550
1 there, the transcript, as far as his own name is concerned, might not
2 be -- might even be more complete as he was able to verify in the audio.
3 If this affects in any way your answer to one of the questions that will
4 be put to you by Mr. Groome, Mr. Milovanovic, please don't hesitate to
5 address that matter.
6 Please proceed.
7 MR. GROOME: Your Honour, can I just inform the court that the
8 transcriber would have used professional equipment and the that copy
9 Mr. Milovanovic listened to was on a Dictaphone, obviously of less
10 quality. That may account for --
11 JUDGE ORIE: If there's any continuing disputes about this, I
12 take it that the parties will address that. Again, if it affects one of
13 your answers, please let us know, otherwise just answer the questions.
14 MR. GROOME:
15 Q. General, despite the diminished quality of the audio, were you
16 able to recognise the speakers on the tape?
17 A. From the tape I recognised Mladic's voice at the end because it
18 seems Mladic was recording and he was aware he was recording, so he was
19 talking in a whisper and only in the end he must have lost it and started
20 speaking more loudly, so I recognised his voice. The other person,
21 however, the other speaker, I couldn't recognise the voice but his speech
22 is characterised by volubility and plenty of profanity. The man doesn't
23 take a breath, talks all the time, and there's something in what he says
24 that makes me think it was the time of the counter-strike against Bihac,
25 and there are several indices that indicates it might be a person who was
Page 15551
1 in the government of Vojvodina who might have been deputy speaker of the
2 Assembly or vice-deputy prime minister. I think his last name is Stupar.
3 He came to see me twice in the area of Grmec. And I inferred that from
4 the fact that he tells Mladic is he a native of Bosanski Petrovac. He
5 talks about oil. Now, I don't know whether he was donating oil or
6 trading in oil but proof of that is that he says to Mladic that
7 Milovanovic is taking one-third -- sorry, not Milovanovic, but Manojlo,
8 out of 12 cisterns 4 go to Manojlo, and he will distribute 5.000 to
9 municipalities each. I don't know whether it's 5.000 Deutschemark or
10 5.000 litres of fuel.
11 Q. It's a rather long tape and if I could just focus on just a
12 couple of portions and ask your comment on. The references to a Manojlo,
13 do you believe them to be actually references to you or another person
14 with the same name?
15 A. I'm sure it concerns me because he is praising me to Mladic
16 saying that I'm a genius, that the troops love me, they obey me and he
17 asks Mladic at the end: How long till you get into Bihac, will it be
18 just a day or two? And that's how I inferred it must be the Bihac
19 operation.
20 Q. Now, you've referred or you have placed it in the time-period of
21 the Bihac operation. So the record is clear, can you give us the
22 approximate months and years that you are referring to?
23 A. It's the counter-attack at Bihac from 31st October, 1994, until
24 Carter's truce in -- on 24th December, 1994.
25 MR. GROOME: Could I ask now that Mr. Laugel play -- first of
Page 15552
1 all, can we maybe bring to the screens the transcript. It's
2 65 ter 06330.1. Copy of this 2 minute 30 second portion has been
3 provided to the booths.
4 General, I'm going to play just a short portion of that and then
5 ask you a question afterwards.
6 [Audio-clip played]
7 MR. GROOME:
8 Q. Now --
9 JUDGE ORIE: Mr. Groome, we have not -- we've not followed the
10 usual procedure which is that we receive an English translation.
11 Therefore, at the English transcript nothing now appears. At the same
12 time, of course, we have on the -- we have a transcript as part of the --
13 of what I take it you'll tender as an exhibit.
14 MR. GROOME: That's correct, Your Honour.
15 JUDGE ORIE: Now, can the parties live with that, that we have a
16 written -- the problem is that not all parts are well audible. I noticed
17 that there is a French translation, so the French transcript is complete.
18 That's why we had to wait for awhile to have it finished. At this moment
19 also looking at the clock, could the parties agree that we work on the
20 basis of the transcript which then should be also in written form and not
21 only as part of the video be filed as an annex to what may become an
22 exhibit.
23 MR. GROOME: Yes, Your Honour.
24 JUDGE ORIE: I'm looking at the other parties. No one disagrees,
25 although I usually prefer to have a full English transcript. I see that
Page 15553
1 we can live with it for the time being. Please proceed, Mr. Groome.
2 MR. GROOME:
3 Q. General, the reference in there about you getting four of
4 something and Jovica Stanisic getting eight of something, is that a
5 reference to the cisterns of fuel that you've referred to just a moment
6 ago?
7 A. As far as I'm concerned, these are cisterns of fuel. I don't
8 know about Jovica, I didn't even notice that. I believe I should explain
9 what that means.
10 Q. It's not all that important to us at the moment about whether
11 what those cisterns were. My question actually was going to be something
12 else. Near the beginning of that excerpt we hear one of the speaker say
13 "Jovica will come with his men," and my question is: Do you know what
14 that is a reference to?
15 A. I don't know what is meant. Jovica never came to see me at
16 Grmec. I found Jovica on the 8th of November at Slunj, that's the
17 Republic of Serbian Krajina.
18 Q. And the audio also records a comment about coming from Mirkovci.
19 Does that sound familiar to you, do you recognise that name, and, if so,
20 what can you tell us about Mirkovci?
21 A. Mirkovci is a village near Eastern Slavonia, if I remember
22 correctly.
23 Q. And can you tell us how far it is from another village by the
24 name of Djeletovci, if you know?
25 A. I can't. I don't know where either is but I know they are in
Page 15554
1 Slavonia.
2 MR. GROOME: Thank you, General. I have no further questions at
3 this time, Your Honour. There are two things that I would -- three
4 things. One is the Prosecution would tender that excerpt, that's
5 65 ter 6330.1, and, again, I note that another excerpt is in evidence as
6 P2956.
7 JUDGE ORIE: Any objections in addition to what was said already
8 to the use of the document?
9 MR. JORDASH: Same objections, Your Honour.
10 JUDGE ORIE: Yes. Then I think the ruling on the Prosecution
11 being allowed to use the document also answers the question about
12 admission.
13 Madam Registrar the number would be?
14 THE REGISTRAR: The number would be P3052, Your Honours.
15 JUDGE ORIE: And is admitted into evidence.
16 Mr. Groome, would you take care that there is a written -- that
17 is not part of the video, but a written transcript as part of --
18 MR. GROOME: Yes, Your Honour. I believe it may already be
19 uploaded, but I will check with Mr. Laugel to verify that. And the
20 second matter, Your Honour, is, if I could ask Madam Registrar --
21 MR. JORDASH: Sorry, the witness has got his hand up.
22 JUDGE ORIE: One second.
23 Yes, before I proceed with that, Mr. Milovanovic, is there a
24 matter you would like to raise?
25 THE WITNESS: [Interpretation] Yes, Mr. President. I don't want
Page 15555
1 the record to remain as it is because I don't know whether this man was
2 smuggling or trading in oil, and I don't want to appear on the record as
3 his accomplice. I had authorisation from the Supreme Command to approve
4 exemptions from customs tax to private oil dealers with the proviso that
5 the army keeps one-third. So out of these 12 cisterns of fuel, four
6 remained for the VRS, not for myself. That's the correction I wanted to
7 make and I don't know if this is the end of my testimony, but I have a
8 question to the Defence teams.
9 JUDGE ORIE: This is not the end yet of your examination.
10 Witnesses usually are not supposed to ask questions, but we'll later hear
11 from you because the examination of a witness is, as a matter of
12 principle, is a one-way traffic, but we'll see what you'd like to ask to
13 the Defence and then we'll decide whether this is a question
14 appropriately be put to the Defence.
15 Mr. Groome, I think first we should -- yes, admission into
16 evidence has been decided. There was a second matter you would like to I
17 raise.
18 MR. GROOME: Yes, Your Honour, also to make clear in light of the
19 witness's comment, the Prosecution has not presented that tape as any --
20 with any suggestion that General Milovanovic has done anything incorrect
21 and is in possession of no evidence that anything in that tape was
22 incorrect.
23 Now, with respect to the second matter, Your Honour, the there
24 have been many references to notebook entries over the course of the past
25 three days. If I could ask Madam Registrar to pass up to the Chamber the
Page 15556
1 printed sheet that I provided earlier.
2 MR. JORDASH: I am sorry to leap to my feet, it's just that I'm
3 noticing the time and I think --
4 JUDGE ORIE: If it is a matter which can wait until we have
5 excused the witness, Mr. Groome, then I would prefer to do that.
6 MR. GROOME: It can, Your Honour, I'm wait.
7 JUDGE ORIE: Then any further questions, it will be you first,
8 Mr. Jordash.
9 MR. JORDASH: Your Honour, yes, and I fear that I may not finish
10 because Mr. Groome has opened up the whole of the Sanski Most crime base
11 which I need to deal with. In effect, it's a de facto opening of the
12 Prosecution case on this issue, so I would like a little time to deal
13 with that. In addition, I would --
14 JUDGE ORIE: You should try to finish. I don't know whether
15 Mr. Petrovic has any specific matters?
16 MR. PETROVIC: [Interpretation] Your Honour, not at this moment
17 but I'm trying to locate a reference, and if I do I may have a few
18 questions to put to the witness with your leave.
19 JUDGE ORIE: Mr. Jordash, try to finish within the time
20 available. And be focused. I have commented quite a couple of times,
21 both Defence teams, on being focused on matters in dispute that took
22 altogether six hours. Let's try to see where we can come.
23 MR. JORDASH: Could we have on the screen please P2546.
24 Further Cross-examination by Mr. Jordash:
25 Q. I want to return to the issue of Sanski Most, Mr. Milovanovic.
Page 15557
1 It's a Mladic notebook dated the 3rd of October, 1995.
2 MR. JORDASH: And I want English page 1 and English page --
3 B/C/S -- sorry, B/C/S page 1.
4 Q. Now, we went through -- or you went through with Mr. Groome a
5 number of entries in Sanski Most, but you didn't go through perhaps one
6 that might have assisted you. In fact, there's two or three which I want
7 to remind you of to see if it helps with your recollection of events in
8 Sanski Most. First of all, this one which appears to be a meeting with
9 Filipovic, aka Fica, and Bozovic. Please take a moment to read.
10 A. I've read the page.
11 Q. Did you know that Filipovic was suggesting that Arkan was under
12 the control of Pecanac at the beginning of October 1995?
13 A. I knew that they were close to each other. I saw it on TV.
14 Q. What did you see to indicate that they were close?
15 A. I saw them together at an observation post near Kljuc.
16 Q. Thank you. Now, in relation to the comment which seems to be
17 attributed to Bozovic, or the comments that he was from General Bozovic's
18 house and they had been given a task to replace the RS police who would
19 then go to the forward defence line and its suggested by Mladic there
20 that this was agreed with Karadzic and yourself. Do you know anything
21 about that? Does that trigger your memory about what Bozovic and the
22 Serbian MUP were supposed to be doing?
23 A. Bozovic and Filipovic came to see me together, and that was my
24 only meeting with Bozovic. As I have already told you, I don't know. I
25 was not even sure that they ever came back. I never saw Bozovic again at
Page 15558
1 the command of the 1st Corps.
2 Q. So you don't know whether there was an agreement between Karadzic
3 and Bozovic that the Serbian MUP would replace the RS MUP so that the RS
4 MUP could go into combat?
5 A. Before the first break I said that Karadzic told me that people
6 would arrive from the MUP of Serbia, and indeed Filipovic and Bozovic did
7 arrive.
8 Q. Now, when you were being questioned by Mr. Groome and the learned
9 Judge, you indicated that you thought that probably the Serbian MUP had
10 been in combat in a couple of towns. Am I correct though that you don't
11 recall them forming part of the 1st Krajina Corps? You didn't issue any
12 instructions or orders in relation to them or see them in combat?
13 JUDGE ORIE: I think that question has been clearly answered
14 already by the witness, isn't it, Mr. Jordash.
15 MR. JORDASH: I'll move on.
16 JUDGE ORIE: Please proceed.
17 MR. JORDASH: Let's go to 65 ter 5611, please. It's page 91 of
18 the English, 100 of the original scanned version.
19 Q. And we are moving forward from the beginning of October to the
20 15th of October, 1995, and a meeting with security organs at 12.30. This
21 was not shown to you, so take a moment to read it. You there?
22 A. The only thing that I can actually discern is Pero Jakovljevic.
23 I see a reference to Arkan, but I really can't make out head or tail of
24 the whole thing. I'm maybe tired.
25 MR. JORDASH: I think let's have the typed copy, if we can,
Page 15559
1 please, of the B/C/S which I think is page 91.
2 THE WITNESS: [Interpretation] Let's not waste time. I can read
3 some things. Yes, but can this be zoomed in, please.
4 MR. JORDASH:
5 Q. Do you have it?
6 A. Yes.
7 Q. Did you know this Colonel Jakovljevic?
8 A. Yes, I knew him. He was the head of the 410th Security Centre
9 and the security organ. He died a few years ago.
10 Q. Did you know that he as a security organ was querying along with
11 others who had brought Arkan in the middle of October?
12 A. I already said that early this morning. Everybody in the
13 military wondered that and I'm still wondering to this very day.
14 Q. Yes, and you said you wanted to take that up with Karadzic. So
15 am I correct then it follows, doesn't it, that --
16 A. Yes.
17 Q. It follows, doesn't it that no one in the military was connecting
18 Arkan with the Serbian DB, everyone was querying, and for you, you want
19 to take up the issue with Karadzic?
20 A. Yes. I requested those meetings that I already spoke about when
21 the meeting did take place he -- Arkan said that he had an order from the
22 Supreme Command. I asked him to fetch that order but then he changed his
23 mind and he said that he did not have any orders, and then I asked
24 Karadzic before the entire Supreme Command: Plavsic, Koljevic,
25 Krajisnik. And there were three generals: Talic, Koljevic and myself.
Page 15560
1 And Karadzic didn't say a word. And then two days later I saw him being
2 escorted from Bijeljina. I still have my doubts about Karadzic having
3 invited him. He did not engage immediately but he started being violent
4 towards the officers of the Army of Republika Srpska, and then I
5 concluded and I said that to Karadzic that Arkan came to discipline the
6 Army of Republika Srpska. They were after the former soldiers of the
7 Republic of Serbian Krajina who were fleeing across our territory and
8 when they caught them they would detain them at Manjaca.
9 Q. Looking at the entry:
10 "At the Assembly that they will demand that you are replaced,
11 that Talic take over the Main Staff and Arkan or Lisica take over the
12 1st Krajina Corps."
13 Were you aware of this news or these rumours that --
14 JUDGE ORIE: Could we first ask who "you" is in this context.
15 MR. JORDASH:
16 Q. Who do you think "you" is in this context?
17 A. Colonel Jakovljevic reported to Mladic, so it is Mladic who was
18 supposed to be replaced. All that came to a head once on the 4th of
19 August, 1995, after the fall of Knin. All the generals of the
20 Army of Republika Srpska wrote to the Assembly to overturn that decision.
21 According to that decision, I was supposed to take over the leadership of
22 the army and Mladic was supposed to be appointed as a special advisor,
23 but the generals rejected the decision of the Supreme Command, and the
24 Assembly was in favour of the generals and Mladic was not replaced. Here
25 a security officer reports to Mladic there's something brewing again
Page 15561
1 about his replacement. Talic was supposed to be the head of the
2 General Staff. General Lisica was supposed to be appointed as chief of
3 the 1st Krajina Corps but he was then pensioned off in 1994. I would say
4 that this is a bit far-fetched on the part of the security organ. Talic
5 was my senior in terms of rank, the senior -- than me, so it would only
6 have been logical for him to replace Mladic, not me.
7 Q. Thank you. Certainly at this point in time there was open
8 conflicts between Karadzic and Mladic with Karadzic wanting to get rid of
9 Mladic; is that right?
10 A. There were never open conflicts between Karadzic and Mladic.
11 Nothing was displayed at meetings. I don't know what happened behind
12 closed doors. However, there was a conflicts between the views of the
13 military and the representatives of politicians. Karadzic represented
14 politicians, Mladic represented the military, and there were conflicts in
15 terms of how to wage that war in the future.
16 MR. JORDASH: Thank you. Let's go to 65 ter 5611. Page 111.
17 Page 120. And we are moving forward to the 25th of October, Banja Luka,
18 a meeting of the inner circle of the General Staff of the VRS and the
19 commanders on the western part of the front line.
20 Q. I'm interested in the entry which is the first item and what you
21 are purported to have said.
22 THE INTERPRETER: Could the counsel please switch off his
23 microphone, thank you.
24 THE WITNESS: [Interpretation] I don't know, my concentration
25 fails me here. I can't read the handwriting. The only thing I can see
Page 15562
1 here is that I'm complaining that nothing has arrived from Serbia but
2 that's it.
3 MR. JORDASH: Can we have on the screen, please, the typed copy,
4 which is 111.
5 Q. I think it's important that you see it and read it to remind
6 yourself since it's a long time ago.
7 A. I've read it.
8 Q. Did you say that the Serbian MUP has probably put the border
9 under its control after Arkan was chased away?
10 A. Yes. You can see here that for four days there have been no
11 flows of people and goods across the border. This made me conclude that
12 the Serbian MUP closed the border because we had chased Arkan away. But
13 that was not the biggest problem. The biggest problem was our own
14 police, the police of Republika Srpska, after Arkan was chased away.
15 Tomo Kovac did not accept our order on the use of the military police
16 there. We wanted to use the military police on border crossings and
17 there was a deterioration after an RS delegation visited Milosevic which
18 means that somebody from the sphere of politics went to see Milosevic to
19 talk to him about something because Mladic and I were the ones who were
20 behind the decision to chase Arkan away.
21 That night when I had the meeting with Arkan and it was agreed
22 that I would chase him away from Manjaca and Mladic would chase him away
23 from Kotorsko village near Doboj.
24 Q. Were you presuming the Serbian MUP had put the border under
25 control to keep Arkan out of the region, out of Banja Luka? Is that what
Page 15563
1 you were saying there?
2 A. No, I realised then and there at that meeting that the Serbian
3 MUP closed the border for the traffic of people and goods, which means
4 that we couldn't receive anything from them and send anything to them. I
5 know that the generals and politicians could not move across the borders.
6 There was a ban on their travels.
7 Q. Okay. And Tomo Kovac was not pleased about Arkan being chased
8 away, is that what we should take from this?
9 A. Tomo Kovac was angry with the army for having chased the army
10 away which means that Arkan was under the patronage of the MUP of
11 Republika Srpska, and it was well known who was in command of the
12 Republika Srpska MUP.
13 Q. If there had been Serbian police officers in towns carrying out
14 crime prevention activities, would you necessarily have known that?
15 A. No, I would not have known. All I cared about was warfare and
16 those were not just ordinary policemen but special police officers, those
17 who could be and were engaged in combat. I was not interested in public
18 law and order.
19 Q. Was it ever reported to you that Stanisic had said that Arkan had
20 embedded himself in Banja Luka?
21 A. Nobody ever told me that. The only thing I found out was that
22 Arkan had a room at the hotel Bosna, whereas his mob was scattered all
23 over Bosnian Krajina.
24 MR. JORDASH: Thank you. I'd like to refer to P61 now.
25 Q. It's a different subject. It's the subject of airfields and
Page 15564
1 combat flights.
2 MR. JORDASH: And could we have, please, page 11 of the English
3 and page 8 of the B/C/S.
4 Q. Now, while that is coming up, Mr. Milovanovic, this is a speech
5 that Mr. Groome referred to, a speech by Mr. Simatovic, and I want to
6 make sure that you understand what was actually being suggested by
7 Simatovic and ask you to comment on it, please. I want to focus on the
8 section which begins, I think, actually, we need to go to the B/C/S
9 page 9 because I'm going to deal with the airfields point first. And I
10 want to deal with the claim that in 1992 they, i.e., the Serbian DB,
11 began building and securing a network of small airfields in
12 Bosnia-Herzegovina and also forming a combat squadron. If you would read
13 that, please. And if you would read down to the sentence just before the
14 sentence dealing with the Captain Dragan's Fund.
15 A. I don't have that page in front of me in B/C/S. Stop. No, no.
16 I can see that, actually, but the counsel mentioned the year 1991, so
17 shall I read the portion starting with the year 1992?
18 Q. "Also in 1992," start with that, please.
19 JUDGE ORIE: While the witness is reading, how much time would
20 you still need, Mr. ...
21 MR. JORDASH: I could -- well, I don't know what the witness is
22 going to -- I want to take him through just some small sections on this
23 speech which will take about 10 minutes, and then the problem is I would
24 also like to take him into the subject of this audiotape and I don't know
25 what he is going to say because I have no idea what it all means. So I
Page 15565
1 think maybe 30 --
2 JUDGE ORIE: Mr. Petrovic, how much time would you still need?
3 MR. PETROVIC: [Interpretation] Your Honour, five minutes, let's
4 say.
5 JUDGE ORIE: As matter stands now, Mr. Groome?
6 MR. GROOME: Nothing, Your Honour.
7 [Trial Chamber and Registrar confer]
8 THE WITNESS: [Interpretation] I've read the entire text.
9 JUDGE ORIE: The total of the time still needed would amount to
10 approximately 20 to 25 minutes, and where otherwise would have to keep
11 the witness here until Tuesday afternoon, I am just looking at the
12 possibility and I first have to confer with my colleagues whether we
13 could extend this session with some 20 to 25 minutes, and then I would be
14 very strict on timing and I add to this that if the time used during the
15 first six hours of examination would have been used more focused then we
16 would have avoided this problem.
17 [Trial Chamber confers]
18 JUDGE ORIE: Mr. Jordash, if we get the approval of all those
19 assisting us, and I'm not the master of their time, then you would have
20 from now on exactly 17 minutes which brings us to three minutes past
21 2.00, then five minutes for Mr. Petrovic and that would be it.
22 Mr. Groome, as matters stand now, of course then --
23 MR. GROOME: Can I just ask that we go briefly into private
24 session.
25 JUDGE ORIE: We briefly move into private session.
Page 15566
1 [Private session]
2 (redacted)
3 (redacted)
4 (redacted)
5 (redacted)
6 (redacted)
7 (redacted)
8 (redacted)
9 (redacted)
10 (redacted)
11 (redacted)
12 (redacted)
13 (redacted)
14 (redacted)
15 (redacted)
16 (redacted)
17 (redacted)
18 (redacted)
19 [Open session]
20 THE REGISTRAR: We are in open session, Your Honours.
21 JUDGE ORIE: Thank you, Madam Registrar. And may I take it that
22 you have verified with support staff and officials. We provisionally
23 proceed on this basis and if there are major -- if there's major
24 opposition we would hear that.
25 Mr. Jordash.
Page 15567
1 MR. JORDASH: Thank you, and I'm very grateful to everyone.
2 JUDGE ORIE: Please proceed.
3 MR. JORDASH:
4 Q. You, in response to questions from Mr. Groome, who put to you a
5 part of what Mr. Simatovic had said, you said "as for auxiliary airfields
6 where airfields can take off and land," apart from the four that you
7 mentioned in your testimony," I don't know any others because we didn't
8 use them and there was no need for me to be interested in them." And I
9 want to ask you, therefore, about what Mr. Simatovic said. Did you
10 observe at any point a network of small airfields being run by the
11 Serbian DB in VRS territory during the conflict?
12 A. No, I didn't notice that.
13 Q. Given the equipment and surveillance units you had under your
14 subordination, do you think you would have noticed a network of small
15 airfields and the DB running thousands, or hundreds even, combat,
16 humanitarian, reconnaissance, and transport flights?
17 A. It would have been impossible for anybody to be flying apart from or next
18 to the air force of Republika Srpska because those airports - Sokolac,
19 Rogatica - simply did not exist. The airport I'm talking about, we just
20 marked the air strip, and it has not changed to this day, it is not
21 operational. And in Bratunac, the air strip was a bit longer but it was a
22 macadam air strip so only propellor aircraft could land. We had one of
23 those transport planes -- we had a pet name of it -- for it, Old Vujadin,
24 and that was the only thing that landed. I think it was the AN2 type plane.
25 And as for the other air forces, there were none in Republika Srpska because
Page 15568
1 on the 31st of March, 1993, the no-fly zone resolution of the Security
2 Council was imposed and I'm sure that people from Yugoslavia had not been
3 so crazy as to send their aircraft our way, into the jaws of NATO.
4 MR. PETROVIC: [Interpretation] Your Honour, I apologise on
5 page 81, line 18 and 19, the witness mentioned another two airfields
6 which did not exist and still they are mentioned in this entry.
7 JUDGE ORIE: Could you please, where you referred to the Bratunac
8 air strip, did you make reference to any other air strips?
9 THE WITNESS: [Interpretation] I mentioned the airfield at Bratunac or
10 in brackets -- Skelani. That's the airport between Bratunac and
11 Skelani. Before the war there was only two municipalities, Bratunac and
12 Srebrenica. Skelani as a municipality did not exist before the war.
13 JUDGE ORIE: Mr. Milovanovic, you are not invited to repeat your
14 evidence but just say what other air strips you mentioned. Mr. Petrovic,
15 the matter has been -- otherwise you can ask for a correction of the
16 transcript on the basis of --
17 MR. PETROVIC: [Interpretation] [Overlapping speakers] ... no
18 Your Honour, no.
19 JUDGE ORIE: Please proceed, Mr. Jordash.
20 MR. JORDASH: Thank you, Your Honour.
21 Q. Mr. Simatovic said that in mid-spring of last year, which would
22 have been 1995, the DB retreated from these parts with complete equipment
23 and machinery, helicopters, and aircraft. Did you observe the Serbian DB
24 doing that, and would you have, if they had?
25 A. Sir, I'm totally confused now. What year are we talking about?
Page 15569
1 What speech are you talking about? You are talking about Simatovic's
2 speech from the year 1991 and you put before me some events that took
3 place in 1992.
4 Q. No, I'm asking you about a speech which was made in 1996. This
5 speech was made in 1996. And, I beg your pardon, 1997. And I'm asking
6 you whether you saw the DB in -- well, 1996 or 1995 or any year, removing
7 equipment detailed, helicopters and aircraft, and so on, the type of
8 equipment that would be used in an airfield? Did you see that?
9 A. No.
10 Q. What a -- you gave evidence about your helicopter being detected
11 by General Morillon. How often were you using that helicopter before he
12 detected you?
13 A. What? What happened to my helicopter?
14 Q. You testified, when Mr. Groome was asking you questions, about
15 flying your helicopter and you were never detected until General Morillon
16 complained about it. Do you recall that?
17 A. Yes. I used the helicopter whenever I needed. NATO radars could
18 not detect me. Morillon, however, did detect me. I was supposed to meet
19 him between Srebrenica and Bratunac when he had been captured by
20 Naser Oric. I was supposed to be involved in negotiations. I used a
21 helicopter. He asked me how I had arrived. I said I used the helicopter
22 to fly into Bratunac, and then a few days later, he complained before the
23 Security Council that I had used the helicopter and that I violated the
24 no-fly zone agreement.
25 JUDGE ORIE: I take it that this answers your question.
Page 15570
1 MR. JORDASH: Yes, thank you.
2 JUDGE ORIE: Please proceed.
3 MR. JORDASH:
4 Q. Did Morillon or any other international authority from NATO, or
5 otherwise, complain to you about the DB flying with helicopters or
6 aircraft?
7 A. No.
8 Q. Did any of your security organs report that to you?
9 A. No. Yugoslav helicopters did not fly over the territory of
10 Bosnia-Herzegovina. It was only once that General Perisic flew over the
11 Drina River near the village of whose name I forget now. He entered the
12 Serbian territory in the depth of 50 metres. Milosevic sent him to talk
13 to me and to butter him up so I would be prepared to accept the
14 Contact Group plan.
15 Q. Thank you. If your security organs had observed that, would you
16 expect them to have put that into written reports?
17 A. I can't answer the question. I don't know.
18 Q. Let me try again. If a entity other than the VRS was flying
19 hundreds of flights in VRS territory, supplying military organisations,
20 wouldn't you expect your security organs to record that in one report at
21 least?
22 A. No. The commander of the air force and anti-aircraft defence of
23 the Army of Republika Srpska informed me about that. He would have been
24 the one to brief me about that.
25 Q. And they didn't, did they?
Page 15571
1 A. They informed me regularly about the number of sorties, the type
2 of aircraft when NATO aircraft flew over Bosnia-Herzegovina and
3 especially when they bombarded us. They informed me about all sorts of
4 flights, reconnaissance flights, combat flights and all types of flights.
5 Q. Belonging to NATO, but no other entity?
6 A. Nobody else flew over Bosnia-Herzegovina.
7 Q. Thank you. Let me now just take you to another part of the
8 speech.
9 MR. JORDASH: If we can go to page 8 of the B/C/S and page 11.
10 Q. Let me deal with this more swiftly. Simatovic also claimed that
11 there was -- the DB ran training camps in Banja Luka, Doboj, Samac,
12 Brcko, Bijeljina, Trebinje, Visegrad, Ozren, and Mrkonjic Grad. Did you
13 see them, would you have seen them if they existed?
14 A. I didn't see them. I was in no position to see them from Skopje.
15 Q. I'm talking about training camps allegedly in existence in --
16 well, it's unclear, we haven't been given dates, but let's just say 1992
17 to 1995?
18 A. This speech was delivered in May 1991. And it says that the -- I
19 did not.
20 JUDGE ORIE: The speech was not delivered in May 1991. Did you
21 ever hear of training camps Mr. Simatovic in the speech claimed to exist
22 in Banja Luka, yes or no?
23 THE WITNESS: [Interpretation] No.
24 JUDGE ORIE: Doboj? Any in Doboj? Any of the DB-ran training
25 camps in Banja Luka, Doboj, Samac, Brcko, Bijeljina, Trebinje, Visegrad,
Page 15572
1 Ozren and Mrkonjic Grad. Did you ever hear about DB-run training camps
2 between 1992 and 1995 in these places?
3 THE WITNESS: [Interpretation] You mean the State Security of
4 Serbia?
5 JUDGE ORIE: Yes, I mean that.
6 THE WITNESS: [Interpretation] I heard about a training camp in
7 Doboj. I heard that in -- from somebody's testimony, but I don't know
8 when and I didn't see it.
9 JUDGE ORIE: Do you have any additional knowledge about this
10 training camp apart from what you heard in someone else's testimony?
11 THE WITNESS: [Interpretation] No, I don't.
12 JUDGE ORIE: Please proceed, Mr. Jordash.
13 MR. JORDASH: Thank you, Your Honour.
14 Q. Given the resources that would be needed to set up a training
15 base, would you have expected to have seen some trace, the delivery of
16 supplies, the movement of men, and so on, if those training bases had
17 existed and been under the supervision of the DB?
18 A. Well, only if I had ventured into the area by chance to see some
19 traces of what, boots or something else? No, I didn't see anything like
20 that.
21 JUDGE ORIE: Mr. Jordash, last minute.
22 MR. JORDASH:
23 Q. Let's just deal very quickly with the section of the tape that
24 you listened to. Did you understand what this tape was saying? Did it
25 make sense to you? Did it trigger off any recollections, the tape you
Page 15573
1 listened to overnight?
2 A. That was an insignificant document for me. It may be of some
3 interest for you because one of those men hailed from outside of Serbia.
4 He lives in Novi Sad, to be more specific. He mentions Zeleni, I don't
5 know in what context, I didn't understand that. He was born in Petrovac.
6 I don't know what his purpose was, whether he came back to his -- to the
7 place where he was born, how he was involved in the trade of fuel, I
8 don't know. For me that tape and that document was totally
9 insignificant.
10 Q. Did you ever, as far as you know, share supplies with Stanisic?
11 A. No.
12 Q. Supplies of oil or any other supplies of military type logistics?
13 A. No. I did not have enough to distribute among my men let alone
14 some to Stanisic.
15 JUDGE ORIE: Mr. Jordash, the answer to the first question was
16 clear: You never shared supplies with Mr. Stanisic. Then to say: Did
17 you never share oil, did you never share vehicles, I mean no supplies and
18 then you start continuing. Okay, that's -- I gave you 17 minutes.
19 You've had them.
20 MR. JORDASH: Yes, I can't in the time go through this tape, so
21 I'll leave it at that.
22 JUDGE ORIE: I think Mr. Groome said he was not primarily
23 interested in the contents of the conversation.
24 Mr. Groome, is that correctly understood.
25 MR. GROOME: That's correct, Your Honour.
Page 15574
1 JUDGE ORIE: Mr. Petrovic.
2 MR. JORDASH: But I'm not sure that means what that means
3 legally, I mean, not primarily means he will use the contents but it may
4 not be his primary concern.
5 JUDGE ORIE: Mr. Petrovic now has an opportunity to put further
6 questions to the witness.
7 MR. PETROVIC: [Interpretation] Your Honour, two or three
8 questions.
9 JUDGE ORIE: Please proceed.
10 Further Cross-examination by Mr. Petrovic:
11 Q. [Interpretation] Witness, just awhile ago you said that it is
12 well known who was in charge of the MUP of Republika Srpska. You didn't
13 give us any names. Who did you mean?
14 A. At what time?
15 Q. In the autumn of 1995.
16 A. Tomo Kovac.
17 Q. Thank you. Earlier today you answered questions about the
18 establishment of a communication system within the
19 Army of Republika Srpska after the 12th of May, 1992. Up to that time
20 was there a communication system established by the Yugoslav People's
21 Army in the territory of Bosnia-Herzegovina?
22 A. Yes, it existed and there were 13 hubs that remained in the
23 territory of Republika Srpska. I said earlier today that I inherited all
24 those communication hubs from the war command post from the former JNA.
25 Q. Thank you. One more question, sir. We all spoke at length about
Page 15575
1 those police officers from Serbia who either arrived or did not arrive in
2 Republika Srpska in the autumn of 1995. Let's leave that aside, do you
3 know anything about possible policemen from Serbia possibly be -- having
4 been engaged in combat in Republika Srpska? I'm talking about autumn
5 1995.
6 A. I didn't know anything about that at the time.
7 MR. PETROVIC: [Interpretation] Thank you very much.
8 Your Honours, I have no further questions for this witness.
9 JUDGE ORIE: Thank you, Mr. Petrovic, for staying within the
10 time-limit. The first question could have easily answered by an
11 agreement. The second question you put to the witness, at least the
12 answer he gave, he gave already earlier. And on the third question we
13 now know that he didn't know anything about it.
14 Mr. Groome.
15 MR. GROOME: No questions, Your Honour.
16 JUDGE ORIE: No questions. Which means...
17 [Trial Chamber confers]
18 JUDGE ORIE: This means that this concludes your evidence,
19 Mr. Milovanovic. I'd like to thank you very much for not only coming
20 once but even coming a second time. We'll not keep you here until the
21 20th of December. Instead, we wish you a safe return home again. You
22 may follow the usher. There was a matter you said at the end you would
23 like to raise, if you can briefly do that, if there's still need. You
24 said you wanted to ask something to the Defence, but first address me.
25 THE WITNESS: [Interpretation] I need to ask the Defence what to
Page 15576
1 do with the materials that tormented me for three nights? I would love
2 to keep those materials because I'm working on a project and I could use
3 them.
4 JUDGE ORIE: You'll receive instructions given by the Defence to
5 the -- on a request of the Defence to the Victims and Witness Section
6 what to do with that material. I'm specifically addressing Mr. Jordash.
7 Any confidentiality matter which may be involved?
8 MR. JORDASH: Yes.
9 JUDGE ORIE: You'll take care of that, I take it.
10 MR. JORDASH: Yes.
11 JUDGE ORIE: Then you'll receive further information about that,
12 Mr. Milovanovic.
13 Could you please follow the usher.
14 THE WITNESS: [Interpretation] Thank you.
15 [The witness withdrew]
16 JUDGE ORIE: Mr. Groome, I'm wondering whether there's any way to
17 either sit together or deal with the matter of scheduling of next week's
18 witnesses because we have received the Simatovic Defence e-mail of the
19 6th of December stating that Simatovic Defence witness DFS-001 will be
20 replaced by DFS-014. Is there any way we can deal with that perhaps out
21 side of this setting because the interpreters, technicians, but me,
22 myself, as well we have other hearings this afternoon.
23 MR. GROOME: Your Honour, I'll send an e-mail informing the
24 Chamber and Defence counsel my position and perhaps we can then formally
25 deal with it first thing Tuesday.
Page 15577
1 JUDGE ORIE: Yes. Does that mean that you would oppose
2 replacement because it has a, of course, a very ...
3 MR. GROOME: I can state my position in about 30 seconds,
4 Your Honour.
5 JUDGE ORIE: 30 seconds would be good.
6 MR. GROOME: The Prosecution is opposing -- does not oppose the
7 rescheduling of the witness, does oppose the Prosecution be required to
8 begin its cross-examination. The witness testified in over nine days, in
9 two cases, over 750 pages of transcript. We don't have any of the
10 exhibits documents translated and the lawyer scheduled to do this
11 cross-examination leaves tomorrow on annual leave. We don't oppose the
12 witness to come begin direct examination. But we will be unable to begin
13 our cross-examination next week.
14 JUDGE ORIE: That was 31 seconds, Mr. Groome, but nevertheless
15 very close to the target. We will adjourn, and I'll apologise to all
16 those who are assisting us giving you perhaps far too heavy burden on
17 your shoulders, but we'll resume Tuesday, the 13th of December, 2011,
18 quarter past 2.00 in this same Courtroom II.
19 --- Whereupon the hearing adjourned at 2.14 p.m.
20 to be reconvened on Tuesday, the 13th day of
21 December, 2011 at 2.15 p.m.
22
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24
25