Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11924

 1                           Tuesday, 29 March 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.18 p.m.

 5             JUDGE FLUEGGE:  Good afternoon to everybody.

 6             The Chamber is seized of the Prosecution's urgent motion for

 7     leave to amend its 65 ter exhibit list with five additional exhibits.

 8             I would like to ask the Defence if you are in a position to

 9     respond to this motion orally.

10             Mr. Gajic.

11             MR. GAJIC: [Interpretation] Mr. President, we have no objection

12     to the Prosecution's request to amend their 65 ter exhibit list with the

13     five additional exhibits.  Thank you.

14             JUDGE FLUEGGE:  Thank you very much.

15             We noticed, Mr. McCloskey, that we have now three different

16     procedures to amend the 65 ter exhibit list.  One is by a little star in

17     the list of documents to be used with a witness and with a note, "with

18     the leave of the Chamber."  The second is without any comment.  And the

19     third is -- the second was to -- a motion submitted orally.  And the

20     third is now in written form.

21             I think for the future it would be sufficient just to address the

22     Chamber orally in court.  It's not necessary to file a written motion of

23     that kind.

24             The Chamber will consider this present motion.  Just a moment.

25                           [Trial Chamber confers]

Page 11925

 1             JUDGE FLUEGGE:  The Chamber has considered the motion and grants

 2     leave to add these five documents to the 65 ter exhibit list.

 3             Mr. McCloskey.

 4             MR. McCLOSKEY:  Thank you very much.  Good afternoon,

 5     Mr. President, Your Honours, and everyone.

 6             Yes, thank you for clarifying the procedure.  I had a little

 7     extra time so we did it that way, but it's much -- I think it's much

 8     better the way you've noted, especially for documents like this that were

 9     part of the testimony of this witness before.

10             The witness is ready.  And I would ask that the witness be given

11     a caution, if you could.

12             JUDGE FLUEGGE:  Thank you very much.

13             The witness should be brought into the courtroom, please.

14             MR. McCLOSKEY:  Oh, and, Mr. President, we do -- this witness is

15     celebrating his -- the -- the memoriam of his mother's death beginning on

16     Saturday and so that's obviously a very important family event, and so we

17     should -- we should have plenty of time under the guide-lines, but I just

18     wanted to inform you of that.  We hope to get him travelling on Friday.

19     But I think it looks like we should be fine.

20             JUDGE FLUEGGE:  Thank you.

21                           [The witness entered court]

22             JUDGE FLUEGGE:  Good afternoon, sir.  Welcome to the Tribunal.

23     Would you please read aloud the affirmation on the card which is shown to

24     you now.

25             THE WITNESS: [Interpretation] Good afternoon.  I solemnly declare

Page 11926

 1     that I shall speak the truth, the whole truth, and nothing but the truth.

 2                           WITNESS:  LJUBOMIR OBRADOVIC

 3                           [Witness answered through interpreter]

 4             JUDGE FLUEGGE:  Thank you very much.  Please sit down and make

 5     yourself comfortable.

 6             On the request of the Prosecution, I would like to give you a

 7     caution.  You know in our Rules of Procedure and Evidence, Rule 90, we

 8     have a specific rule about this caution and I would like to read out

 9     paragraph (E) of Rule 90.  I quote:

10             "A witness may object to making any statement which might tend to

11     incriminate the witness.  The Chamber may, however, compel the witness to

12     answer the question.  Testimony compelled in this way shall not be used

13     as evidence in a subsequent prosecution against the witness for any

14     offence other than false testimony."

15             Sir, did you understand what I was reading to you?

16             THE WITNESS: [Interpretation] Yes.

17             JUDGE FLUEGGE:  Thank you very much.

18             Mr. McCloskey is now commencing his examination.

19             Mr. McCloskey.

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

21                           Examination by Mr. McCloskey:

22        Q.   General, good afternoon.

23        A.   Good afternoon.

24        Q.   And can you state your full name for the record, please.

25        A.   I am Ljubomir Obradovic.  I was born on the

Page 11927

 1     30th of January, 1950.

 2        Q.   In Visegrad, I believe.

 3        A.   Yes.

 4        Q.   Okay.  And you were -- you've been here before; you were called

 5     as a Defence witness in the Miletic trial a few years back; is that

 6     right?

 7        A.   Yes.

 8        Q.   And have you had a chance to listen to your testimony in that

 9     trial and review the exhibits that were shown to you in that trial by

10     both sides?

11        A.   Yes.

12        Q.   And if you were asked the same sorts of questions, would your

13     answers be the same?

14        A.   Yes.

15        Q.   All right.  And is it fair to say that, as you -- you grew up in

16     Bosnia, you went on to be a career military officer, first with the JNA?

17        A.   Yes.

18        Q.   Well, can you tell us -- let's get to the period when the war in

19     Bosnia and Herzegovina starts, in the spring of 1992.  Can you tell us,

20     did you -- what your position was when the war broke out?

21        A.   I was stationed in the Derventa garrison.  I was the Chief of

22     Staff of the 327th Motorised Brigade.  And I was acting as the commander

23     of the brigade, which means that I was, at that time, performing both

24     functions.

25        Q.   And throughout the period of 1992 and 1993, did you retain that

Page 11928

 1     position?

 2        A.   Yes.

 3        Q.   And can you tell us what -- what corps that brigade was in?

 4     Derventa is not a town that we here much about in this case.

 5        A.   The 327th Motorised Brigade was within the 17 Corps of the JNA.

 6     After some officers left the brigade for Slovenia, Croatia, Macedonia,

 7     and Montenegro, it was mostly the Serb officers from the territory of

 8     Bosnia and Herzegovina who stayed, voluntarily.  Not all of them but most

 9     of them stayed.

10        Q.   And that brigade became part of the VRS during 1992; correct?

11        A.   Yes.

12        Q.   And what was the name of the brigade in the VRS scheme?

13        A.   It changed its name during the war.  It used to be the

14     327th Infantry Brigade, and it also used to be called the

15     27th Infantry Brigade.

16        Q.   And which of the corps of the VRS was it in?

17        A.   After the reorganisation and after the East Bosnian Corps of the

18     VRS was formed, this brigade was within the zone of responsibility of the

19     1st Krajina Corps.

20        Q.   And what was your position in 1994?

21        A.   In 1994 I was the Chief of Staff.

22        Q.   Of -- of that brigade.

23        A.   Yes.

24        Q.   So did they finally bring in a commander?

25        A.   Yes.

Page 11929

 1        Q.   All right.  And in 1994 were you transferred to another

 2     responsibility?

 3        A.   On the 1st of September, 1994, I received the order which

 4     transferred me into the Main Staff of the VRS, where I was the chief of

 5     the operative detachment in the operations and training administration.

 6        Q.   And what was your rank when you first came to the Main Staff?

 7        A.   I was lieutenant-colonel.

 8        Q.   And was your duty station the -- the base at Crna Rijeka?

 9        A.   Yes.

10        Q.   And at some point were you assigned to go out into the field

11     under General Milovanovic?

12        A.   My first assignment was two or three days after I arrived.  I

13     went with the Chief of Staff, General Milovanovic, General Tolimir, and

14     Colonel Magazin to the Panorama hotel in Pale.  We had a meeting with the

15     Chief of Staff of UNPROFOR.  I think his name was Briquemont.

16        Q.   And can you describe, just very briefly, your basic assignments,

17     whether it was at Crna Rijeka or out in the field.

18        A.   As the chief of the operative department, my job was to follow

19     the operative situation and the situation in the battlefield, also to

20     write orders, warnings, reports, plans.  And I also had to follow the

21     operative log-books.

22        Q.   General, I'll get into a little more detail on what your actual

23     job was.  Right now I just want to get whether or not you went out into

24     the field on any lengthy field assignments after you were first assigned

25     to the Main Staff.

Page 11930

 1        A.   Yes.  In mid-November 1994, after the offensive of the

 2     5th Muslim Corps, in the area of Bihac, which was directed towards Krupa

 3     and Donji Vakuf, the commander of the Main Staff decided to establish a

 4     forward command post of the Main Staff in order to stabilize the front in

 5     that area.

 6             General Milovanovic was sent to perform that task together with a

 7     certain number of officers, and that was in the second half of

 8     October 1994.  After about a month, he requested to be sent an operative

 9     man by the chief of administration and that operative man was me, so I

10     went to the forward command post.

11        Q.   All right.  At some point during the war, was your brother taken

12     prisoner in Gorazde?

13        A.   Yes.

14        Q.   And was he able to be exchanged or released?

15        A.   In the negotiations, the Muslim side procrastinated.  And

16     whichever variant of the exchange there was, my brother was always the

17     last on the list to be exchanged.  He was exchanged after almost two

18     years, two years less ten days.  He was captured on the

19     16th of October, 1992, and he was exchanged on the 6th of October, 1994.

20        Q.   And did you tell me a short time ago that General Tolimir

21     assisted in -- in getting your brother exchanged?

22        A.   General Tolimir frequently went to meetings with

23     Professor Koljevic.  He tried to make the exchange agreement on the

24     principle all for all.

25        Q.   And so did he, in your view, assist in getting your brother

Page 11931

 1     released?  General Tolimir, that is.

 2        A.   Well, yes.  My brother and all others who were exchanged during

 3     the period that he was active.

 4        Q.   And could you very briefly tell us who Koljevic is?  You

 5     mentioned his name, that General Tolimir went with him.  Just, who was

 6     he, what was his position?  Very briefly.

 7        A.   Professor Koljevic was, if I'm not mistaken, the vice-president

 8     of Republika Srpska.  The second vice-president was Biljana Plavsic.  He

 9     was involved in humanitarian work.

10        Q.   All right.  And at some point while you were on this field

11     assignment, did you break your leg?

12        A.   Yes.  I broke a leg in Jasenica on the 27th of January, 1995.

13        Q.   And you said that was on the ice.

14        A.   Yes.

15        Q.   And where did you go to recover from that?

16        A.   I was transferred to the clinical centre in Banja Luka.  I was

17     treated there and then, later on, I was transferred to my place of

18     residence in Derventa.  After the initial treatment, they put the blaster

19     on, in Doboj, and then all the rest of that time I spent in Derventa.

20        Q.   And where did you next go when you got better?

21        A.   After my sick-leave, I returned to the Main Staff on the

22     17th of July, 1995.

23        Q.   And were you promoted to colonel in June of 1995?

24        A.   Yes.

25        Q.   All right.  And what position did you go back to?

Page 11932

 1        A.   I went back to my previous position, which was the chief of the

 2     operative department within the operative -- operations and training

 3     administration.

 4        Q.   Okay.  And I'm sure you recall testifying about the -- some of

 5     the formations and structures of the -- of the Main Staff from your

 6     previous testimony.  And were you able to just make a rough drawing of

 7     some of those positions from your memory for me a day or two ago?

 8        A.   Yes.

 9        Q.   All right.

10             MR. McCLOSKEY:  And if we could have 65 ter 7295.  And,

11     Your Honours, this is not designed to be an exact replica of the rough

12     drawing that the witness gave us, but it's -- it's roughly similar.  And

13     if I could just hand him his rough drawing.  It's a big document, so it's

14     hard to get a feel for it.  As you can see, it's hard to see from the

15     screen.  And if I could hand him this so he just has a --

16             JUDGE FLUEGGE:  Could we -- is it possible to have that on the

17     ELMO?

18             MR. McCLOSKEY:  I actually have hard copies for Your Honours

19     and -- and I've given hard copies to the -- to the General and Mr. Gajic

20     of -- of his diagram.  And I have hard copies of the English.  But, of

21     course, it's also possible to put it on the ELMO.

22             JUDGE FLUEGGE:  That would be -- it's not necessary if we can

23     receive a hard copy of that, and the Defence.

24             The Court Usher will assist you.

25             Mr. Gajic and Mr. Tolimir indicate that they have the drawing but

Page 11933

 1     not the English version of it, I think.

 2             MR. McCLOSKEY:  Yes.  We're passing over the English -- the

 3     English version of it over to Mr. Gajic.  So as I say, it's not exact.

 4     It's not meant to be exact.  But we tried to --

 5             JUDGE FLUEGGE:  Mr. McCloskey, can you help me.  We received now

 6     a printed version.  Is this exactly the printed version of the hand

 7     drawing of the witness?

 8             MR. McCLOSKEY:  No.  It is based on that.  But this was a rather

 9     rough item that he did and some of the positions he told us about but

10     didn't draw them in, and one of the positions he -- he just mentioned to

11     me yesterday that he had forgotten.  So we had -- we've tried to make

12     this to be a reflection of it, but it's really just meant to be a

13     testimonial guide at this point, with the witness's help.

14             JUDGE FLUEGGE:  I would like to understand your -- your procedure

15     now.  The witness has a copy of his hand -- the sketch he drawed.  Is

16     that ...

17             MR. McCLOSKEY:  Yes, he does.

18             JUDGE FLUEGGE:  And the Defence is in possession of that as well;

19     yes?

20             Do we have hard copies for the Chamber of that hand drawing?

21             MR. McCLOSKEY:  Yes.  Yes, I have some extras.

22             JUDGE FLUEGGE:  It would assist us --

23             MR. McCLOSKEY:  It's --

24             JUDGE FLUEGGE: -- to understand your examination of the witness.

25             MR. McCLOSKEY:  It's Cyrillic.  I don't know how good your

Page 11934

 1     Cyrillic's getting.  Mine has never gotten very good, but ...

 2             This is -- it's really, Your Honour and -- Mr. President,

 3     Your Honours, I wanted you to first see the whole team, as it were, and

 4     then we'll zero in on the different units, and that's mostly what I'm

 5     concerned about, is not so much the structure diagram at this -- at this

 6     point.

 7             JUDGE FLUEGGE:  Thank you very much.  Please carry on.

 8             MR. McCLOSKEY:

 9        Q.   Now, General Obradovic, the diagram you did, it roughly has

10     the -- the commander, the Chief of Staff, the assistant commanders of the

11     various branches, and the corps, and a few other units; is that correct?

12        A.   Yes.

13        Q.   And that was your memory of -- of the important parts of the

14     Main Staff; is that right?

15        A.   Yes.

16        Q.   And so you know, we -- we put in the corner, you can probably see

17     it in the English, the 67th Communications Regiment that you had

18     mentioned to me yesterday.  Where does that connect to?  We didn't put

19     any connecting line to it.  But who -- where do they fit into the unit?

20        A.   The 67th Communications Regiment is a unit attached to the staff.

21     In this case, the Main Staff.  Its main task is to organise the

22     communications, to satisfy the communications needs of the Main Staff.

23     It is attached to the commander.  In performing its professional duties,

24     it is attached to the arms within the staff sector.

25        Q.   All right.  And while we're on that, I might as well just --

Page 11935

 1     you're referring to the staff sector that's the Chief of Staff and

 2     deputy commander General Milovanovic is noted in the diagram; correct?

 3        A.   Yes.

 4        Q.   All right.  We'll get to that.  But let's start with just a brief

 5     explanation for us of the commander, Ratko Mladic.

 6             Can you -- can you just tell us, in the most fundamental form,

 7     what is his position as the commander of the Main Staff and his basic

 8     duty?

 9        A.   The commander of the Main Staff commands the Army of

10     Republika Srpska and institutions through the commands of units and

11     institutions.  It is his task to take care of the organisation and the

12     building of combat readiness of the entire army.  He commands by issuing

13     directives, orders, instructions, warnings, advice, and so on.

14        Q.   Okay.  And let me ask you: The next person, the deputy commander,

15     Chief of Staff, was that General Milovanovic in 1995?

16        A.   Yes.

17        Q.   And, in fact, General Milovanovic was the Chief of Staff and

18     deputy commander throughout the war; is that correct?

19        A.   Yes.  General Milovanovic was chief of the staff sector all the

20     time.  And due to the -- his position in the establishment, he was at the

21     same time commander of the Main Staff.

22        Q.   I think that should be Chief of Staff but at the same time

23     deputy commander of the Main Staff?

24        A.   Yes.  Chief of Staff.  The sector that he immediately was in

25     charge of was the staff sector, and, simultaneously, he was

Page 11936

 1     deputy commander of the Main Staff.

 2        Q.   All right.  That's -- that's important.

 3             Can you -- can you tell us how that job worked?  What was the

 4     difference, just fundamentally, between his position as deputy commander

 5     and position as Chief of Staff?

 6        A.   The Chief of Staff does operative work, work concerning the

 7     services of the armed forces, and he has subordinate units that are in

 8     charge of these kinds of work.  He -- he organises the work of the

 9     commands of the Main Staff by planning, monitoring the situation.

10        Q.   All right.  And how about as deputy commander?

11        A.   He's deputy commander if the commander himself should be absent

12     for any period of time.  Then he takes over during the commander's

13     absence but can only issue orders in the spirit of the directives and

14     decisions that had previously been passed by the commander.

15        Q.   And how was the term "absent" defined?  We -- for example, we see

16     General Mladic going to Serbia, going to Belgrade.  Would that be

17     considered an absence or would he still be the commander in full command

18     and Milovanovic would still be Chief of Staff?

19        A.   He would temporarily stand in for the commander during the

20     commander's absence.

21        Q.   Would going to Serbia be considered absent?

22        A.   It doesn't depend on the whereabouts of the commander but it

23     depends on the duration of absence.

24        Q.   While you were at Main Staff in 1995, were you aware of Mladic

25     being absent, where someone else had to be the deputy commander?

Page 11937

 1        A.   I personally do not know.  When the commander goes somewhere, he

 2     appoints one of his assistants to stand in for him during his absence.

 3     And his assistants were, apart from General Milovanovic, the chief of the

 4     morale, religious, and legal affairs; the chief of the logistics sector;

 5     the chief of the organisational, mobilisation, and personnel issues; then

 6     the chief of the intelligence and security sector; then the chief of the

 7     planning, development, and finance administration; and the chief of the

 8     air force and anti-aircraft defence administration.

 9             These persons are the assistants of the commander of the

10     Main Staff and they are directly organisationally linked with him.

11        Q.   All right.  Can you tell us, was General Tolimir an assistant

12     commander?

13        A.   Yes.

14        Q.   And which branch?

15        A.   The intelligence and security sector.

16        Q.   And General Gvero, which branch?

17        A.   General Gvero was chief of the morale, religious, and

18     legal affairs sector.

19        Q.   General Skrbic?

20        A.   General Skrbic was chief of the organisation, mobilisation, and

21     personnel affairs sector.

22        Q.   And General Djukic?

23        A.   The late General Djukic was chief of the logistics sector.

24        Q.   General Jovo Maric?

25        A.   The late Jovo Maric was chief of the air force and air defence

Page 11938

 1     administration.  He was a pilot.

 2        Q.   And can you explain briefly and -- in 1995, as best you can

 3     recall, just how did General Milovanovic interact with the assistant

 4     commanders and the -- the -- the staff sector?  Can you just give us just

 5     a rough idea of how that worked.

 6        A.   General Milovanovic was at the forward command post for a

 7     significant part of 1995, that is, outside of Crna Rijeka.

 8        Q.   Can you tell us where that was?

 9        A.   While I was there, it was Jasenica.  That is south-west of the

10     town of Krupa on the Una River.  After that, there was an opportunity,

11     while I was still there, so that we moved on to Drvar from the forward

12     command post because of some other tasks.

13        Q.   All right.  And during the time-period when General Milovanovic

14     was at the Main Staff, both in 1995 and in 1994 when you were working

15     there, can you just describe basically his duties and how he interacted

16     with the assistant commanders.

17             You've described briefly about his position over the staff, but

18     what was his authority over the assistant commanders or -- and his

19     dealings with them?  Just briefly.  He'll be here to testify, we hope,

20     and we'll get into more detail about that.  But if we could just get a

21     rough guide line from you, it will help your testimony, I think.

22        A.   We must distinguish his work in the staff sector from the jobs

23     that he did in the command of the Main Staff.

24             In the staff sector, there was a training and operations

25     administration, an organ for the services.  Then a data processing organ.

Page 11939

 1     There was an office.  And there was a typists' bureau.

 2             In the operations and training administration, there was a

 3     department for operative work headed by me.  There was a department for

 4     training headed by Colonel Krsto Djeric.  And the operations centre

 5     wasn't manned.  We were not able to establish it the way it was supposed

 6     to be.

 7             General Milovanovic, in the staff sector, co-ordinated the work

 8     of the administrations organs, services, offices, and the part that

 9     belongs to the staff sector, according to the establishment; whereas, in

10     the Main Staff, he co-ordinated the work of the individual sectors.

11        Q.   Let me ask you, I have a -- a note that there is under the staff

12     sector something called a combat services, where the chief of

13     engineering, chief of artillery, and the armoured units and the chief of

14     communications are placed; are they also within the staff?

15        A.   They, all together, that is, the chief of infantry, chief of

16     artillery, chief of armoured and mechanized units, chief of

17     communications, chief of ABC defence, they all belonged to the staff

18     sector.  And the joint name for all these together is the services organ.

19        Q.   All right.  And you had mentioned, you described the work that

20     General Milovanovic did related to the staff sector.  And then you ended

21     by saying he co-ordinated the work of the individual sectors.

22             And can you tell us what sectors you're talking about and what

23     this coordination was.

24        A.   No, not the individual sectors, but he co-ordinated the sectors

25     themselves; that is, the coordination was between the sectors.  Because,

Page 11940

 1     if I may say, the functions of commanding are planning, organisation,

 2     giving orders, coordination, and control.

 3        Q.   And so can you remind us, there may be slight translation issues,

 4     what are the sectors we're talking about?  If you could just remind us,

 5     to clear that up.

 6        A.   There's the sector for morale; the logistics sector; intelligence

 7     and security; organisational, mobilisation, and personnel affairs.  And

 8     then there are the administrations: Planning, development, and finance,

 9     as well as air force and air defence.

10        Q.   All right.  Those are the assistant commanders that you spoke of

11     earlier.  So he coordinates the work of the assistant commanders, their

12     sectors.

13        A.   Yes.

14        Q.   Can you give us an example or just describe to us briefly what

15     this command function of coordination would entail?

16        A.   Coordination means the harmonized work of sectors.  It can mean

17     the work in the field among units that are at the same level.  None is

18     superior or subordinate to the other, and somebody should coordinate

19     that; whereas, it's the Chief of Staff who coordinates the work of the

20     sectors, when they perform the same task at the same time.  For example,

21     Directive 7/1 --

22        Q.   [Previous translation continues] ... We'll get to that but -- so

23     don't get into too much detail because I'm going to want the Court to see

24     that and all when we get to it.

25             I apologise for interrupting.

Page 11941

 1        A.   I only wanted to add to make -- something to make things clearer.

 2     If a task is supposed to be carried out by forces of three corps in the

 3     same area, such as the East Bosnia Corps, the Drina Corps, and the --

 4     another corps, then somebody must coordinate, which means that either a

 5     temporary command must be established which will be superior to the

 6     forces of all three corps and whose orders will be carried out by the

 7     commanders of all these corps.

 8        Q.   Okay.  And as an example of the coordination within the

 9     Main Staff, you have mentioned the directives.  And we'll -- we're going

10     to get to those directives soon, and we'll use that as an example and

11     just save that for now and so we don't have to back-track.

12             So, all right.  Now let's -- let's go to General Miletic.  We see

13     that he is the -- in the administration for operations and training.  So

14     where does he fit into -- into this staff that you're part of?

15        A.   He's in the staff at the head of the administration for

16     operations and training.  Subordinate to him there was the department for

17     operations, then the department for training and the training centre.

18     But the training centre never took off the ground.

19        Q.   So what subordinates, if any, did General Miletic have?

20             JUDGE FLUEGGE:  Just a moment.

21             Mr. Gajic, please.

22             One moment, please.

23             Mr. Gajic.

24             MR. GAJIC: [Interpretation] Mr. President, on page 18, line 16, a

25     training centre is mentioned.  I believe that the witness said something

Page 11942

 1     else.

 2             Could Mr. McCloskey please clarify this.  It's about a centre

 3     that never took off the ground, but I believe that I heard something

 4     else, something other than what's recorded.

 5             JUDGE FLUEGGE:  You mean in B/C/S?

 6             MR. GAJIC: [Interpretation] Yes, of course.  In the language

 7     spoken by the witness.

 8             JUDGE FLUEGGE:  Mr. McCloskey.

 9             MR. McCLOSKEY:

10        Q.   Yes.  General, can you clarify, what was this centre that you

11     said never got off the ground?

12        A.   An integral part of the administration according to the

13     establishment was the operations department headed by me, and I -- I was

14     also Miletic's deputy.

15             There was a cartographer in that department too, a

16     Lieutenant Micanovic.  But actually many more people were required than

17     the two of us, but we weren't manned.  Then it was Colonel Djeric who was

18     chief of the training department and then nobody else.  And the third

19     unit is the operations centre, which was envisaged as consisting of a

20     chief, two higher-ranking officers, such as a colonel or a

21     lieutenant-colonel, who could be shift leaders there.  But these

22     positions weren't manned, and we didn't have an operations centre but

23     only an operative duty officer in the Main Staff.

24        Q.   So it was the operations centre that never got off the ground?

25        A.   Yes.

Page 11943

 1        Q.   All right.  And you said it was envisioned to have a certain

 2     number of posts or position.  Can you tell us a bit about that?  It was

 3     envisioned by who?  And what military organisation envisions or would

 4     have signed the normal number of posts for something like this?  Who's

 5     doing the overall design of -- of this?

 6        A.   In the organisation, mobilisation, and personnel affairs sector,

 7     there's a department for formations, and it was tasked with forming

 8     formations.  Somebody envisaged the formation of the Main Staff.  I

 9     believe that the leadership of the republic appointed Mladic commander of

10     the Main Staff and that it was he who organised at least the inner circle

11     of his associates from the personnel available, and they were chiefs of

12     sectors.  The chiefs of sectors, probably, once officers become

13     available, they propose some persons for individual positions which is

14     then approved by the collegium of the Main Staff, because that body is

15     responsible for appointments, that is, for confirming appointments.

16        Q.   [Microphone not activated]

17             JUDGE FLUEGGE:  Now -- I think now it's working.

18             MR. McCLOSKEY:  Excuse me, yeah.

19        Q.   Under this design, how many people were envisioned to actually

20     work in the administration for operations and training?

21        A.   The operations and training administration headed by

22     General Miletic was supposed to have 18 officers, according to the

23     establishment, but there were only four of us.

24        Q.   And I think you have named Djeric as the sector for training.

25     You were the chief of the --

Page 11944

 1        A.   Chief of the department, yes.

 2        Q.   And you have one other on your list who was a cartographer as

 3     your fourth; who's that?

 4        A.   Micanovic.  He's not a cryptographer.  He's a cartographer.  It

 5     was Lieutenant Micanovic.  He graduated from military academy the -- and

 6     he was a trained surveyor.  He drew maps and made the topographic

 7     material that we used to work with.

 8        Q.   So I won't ask you about who the 14 other positions were that

 9     were envisioned, but we can see that that -- it was envisioned to have a

10     lot more than your four.  Was that low manning level typical throughout

11     the different sectors of the Main Staff?

12        A.   I don't think that any one was fully manned.  I cannot be more

13     precise than that though.

14        Q.   And who was your immediate superior?

15        A.   My immediate superior was General Miletic.  Radivoje Miletic.

16        Q.   And do you recall I asked you at the last trial that when you

17     drafted documents in -- pursuant to your position, were you responsible

18     for those documents?

19        A.   My responsibility was to produce documents conscientiously, and

20     it's the superior officer's responsibility to review it and, if it's all

21     right, sign it or possibly forward it to his commander to sign, depending

22     on the type of enactment or document.

23             So it was my responsibility to do my job conscientiously, but the

24     one who's legally responsible is the one who signs the document.

25        Q.   So Miletic was responsible for the documents that you did for

Page 11945

 1     him?

 2        A.   Yes, as my immediate superior.

 3        Q.   And as your immediate superior, was he responsible for your work,

 4     be it at the Crna Rijeka or out in the field, if you went out in the

 5     field?

 6        A.   Yes.  Every superior has that responsibility, the responsibility

 7     to monitor the work of their subordinates, to assess the quality of their

 8     work and the work they put in to accomplishing their tasks.

 9        Q.   You've used the term "monitor."  Can you tell us, is -- what does

10     that mean in the sense of a superior/subordinate?  Can you give a --

11     describe to it a little more?  Because we have -- you may recall there

12     was questions regarding following someone's work and monitoring someone's

13     work.  Can you tell us what the difference is?

14        A.   Well, it's one and the same or would be one and the same if we

15     are talking about the daily tasks.  On a daily basis, a superior has to

16     follow the work of their subordinates.  When they give them a task, then

17     they have to monitor how the task was carried out, whether that person

18     was skillful, whether the task was carried out conscientiously or whether

19     it was carried out superficially.

20        Q.   If you were given a task by, for example, Milovanovic when

21     Miletic was absent, would you be reporting back to General Miletic, and

22     would he be monitoring your work even though Milovanovic had given you

23     the order?

24        A.   In practice, when the second in command issues a task, I proceed

25     to carry the task out, but I have to report to my immediate superior as

Page 11946

 1     to what kind of task I had been given by the second in command or the

 2     second superior.  There were lots of problems with writing reports.  For

 3     example, General Milanovic [as interpreted] wanted me to give him

 4     reports, bypassing General Miletic.  And the other officers were the

 5     same.  They were not subordinated to Miletic.  In other words, General

 6     Milovanovic would be the one to inspect such reports and sign them.

 7        Q.   But did you go through Miletic as the -- what you've identified

 8     as the proper order, proper chain of following those orders?

 9        A.   However, if he was not present physically and if priority and

10     speed were required, then I would go directly to the person who had

11     issued the order in the first place.

12        Q.   I believe you started your answer with yes; is that correct?

13        A.   Yes, when he is present.  However, if he is absent, then I could

14     not give a report to him to inspect, and it was required from me to

15     submit it immediately.  But I would, nevertheless, inform him about the

16     tasks that I had been given and that I have carried out.

17        Q.   And how -- normally how soon would you have to inform Miletic in

18     such a situation where he wasn't immediately available?  I mean, was it

19     important to inform him as soon as possible?  Could you wait?  What --

20     how did that work?

21        A.   Usually those tasks were not that urgent.  I would only inform

22     him about what had happened during his absence, what tasks and duties had

23     been carried out and on whose request.  There were no tasks for which we

24     would have had to report to him immediately without any delay.

25        Q.   When you were, as you've testified earlier, you were sent to the

Page 11947

 1     forward command post with -- the Main Staff forward command post with

 2     General Milovanovic, did you have any responsibilities to report back to

 3     General Miletic when you were in that forward command post?  I think that

 4     was over in the ...

 5        A.   Not regularly.  But we did speak to each other at certain

 6     intervals and we exchanged information.

 7        Q.   Were you still responsible to him?

 8        A.   I was responsible to him in general terms.  More specifically,

 9     when it comes to my work at the forward command post, I was responsible

10     to General Milanovic [as interpreted], because there I also worked as an

11     operative.

12        Q.   All right.

13             JUDGE FLUEGGE:  I would like to clarify the last name.  I heard

14     Milanovic in the interpretation but it is written General "Milovanovic"

15     in the transcript.

16             Please clarify with the witness what he said.

17             MR. McCLOSKEY:

18        Q.   Can you clarify who you said you were working under?  Which --

19     just the name.  We didn't quite catch the name.  When you were out at the

20     IKM.

21        A.   At the IKM, Your Honours, at the IKM, whatever I had to do at the

22     IKM I received my tasks from General Milovanovic.  In general terms, my

23     immediate superior who was responsible for my overall work was

24     General Miletic, but he was not there.  He was in Crna Rijeka at the main

25     command post.

Page 11948

 1        Q.   But did he remain, in general terms, responsible for your work as

 2     well; correct?

 3        A.   Yes.  He was the one who evaluated my work, who followed my work,

 4     who was responsible for my work.

 5        Q.   Can you explain that, just so we can try to understand.  The

 6     military is perhaps different from the rest of the world.  How is it that

 7     a -- General Miletic -- well, how is it a subordinate is so

 8     responsible -- or the superior is so responsible for the work of the

 9     subordinate?

10        A.   When we're talking about the doctrines of militaries and

11     Warsaw Pact, this is very pronounced.  There is less independence in

12     decision-making at lower levels than was the case in our military,

13     according to our doctrine documents.

14        Q.   All right.  Let's go briefly over to the -- General Gvero's

15     sector:  Morale, legal, and religious.  Do you remember any subordinates

16     that he had working under him?

17        A.   I know people who were there, but I don't know what positions

18     they had been appointed to.  I wouldn't go into that.

19             That sector had a department for morale and religious affairs, a

20     department for information, and a department for legal affairs.

21             In the legal affairs department, there was

22     Lieutenant-Colonel Supic.  As for the information department and

23     department for religious affairs, whether Colonel Savo Sokanovic was

24     there ...

25        Q.   Okay.  And was --

Page 11949

 1        A.   I don't know any others.

 2        Q.   Was General Gvero responsible for the work of those subordinates

 3     as you have described Miletic was responsible for your work?

 4        A.   Yes.

 5        Q.   All right.  And in the intelligence and security affairs, you

 6     have noted two different administrations.  Can you tell us what they are?

 7        A.   The intelligence administration and the security administration.

 8        Q.   And who was the chief of the intelligence administration?

 9        A.   Colonel Salapura.  Petar Salapura.

10        Q.   And who was the chief of the security administration?

11        A.   Colonel Ljubisa or Ljubo Beara.  I don't know what his real name

12     is.

13        Q.   And was General Tolimir responsible for the work of those two

14     people as General Miletic was responsible for your work and General Gvero

15     was responsible for the work of his people?

16        A.   Yes.  General Tolimir was the chief of the sector for

17     intelligence and security.  That was made up of the two administrations

18     that you have just mentioned.

19        Q.   All right.  Now, we've mentioned briefly about the Main Staff

20     forward command post.  Can you tell us what the purpose of -- of that

21     was, why the Main Staff would have its own forward command post in some

22     of these operations?

23        A.   Forward command posts are formed with a view to establishing a

24     more immediate contact and with a view to having ability to monitor

25     combat operations and exert influence on the course of those combat

Page 11950

 1     activities.

 2             The area in question was covered by two corps.  There had to be

 3     coordination in that part of the front and an opportunity had to be given

 4     to the Main Staff to exert a more immediate influence on the course of

 5     the events.

 6        Q.   Why not rely on the -- the corps or the brigade forward command

 7     post?  Why create a Main Staff forward command post?

 8        A.   The area where the events were taking place was not suitable for

 9     organising a forward command post, either of the 1st or the 2nd Corps,

10     because they were too far from each other.

11             In principle, when things like that are organised, an IKM of a

12     superior unit can be an IKM of a subordinated unit.

13        Q.   Did General Mladic prefer having a Main Staff officer involved in

14     operations when it was possible?  I mean, you obviously talked about

15     Milovanovic on that very important front.  Is that something

16     General Mladic did on a regular basis?

17        A.   When General Milovanovic went on field missions, that was done on

18     the order of the commander.  When operations are carried out involving

19     several different corps, then a forward command post is established to

20     coordinate the work and to carry out uniformed command in such

21     operations.

22             There were cases when the commander sent officers from the

23     Main Staff to certain areas, when some extraordinary situations occurred,

24     when positions were lost, when there was -- desertion.  That was done to

25     help a subordinated command or this was done to satisfy the function of

Page 11951

 1     control on behalf of the Main Staff.

 2        Q.   Okay.  Now I want to go to another area that you had spent some

 3     time talking about.  And that is --

 4             JUDGE FLUEGGE:  Before you do that, I would like to put a

 5     question to the witness to understand --

 6             MR. McCLOSKEY:  Please.

 7             JUDGE FLUEGGE: -- more correctly your description of the sector

 8     headed by Manojlo Milovanovic.

 9             You told us that General Miletic was the administration chief for

10     operations and training and you have been his deputy; is that correct?

11             THE WITNESS: [Interpretation] Yes.

12             JUDGE FLUEGGE:  What about the other three officers?  I would

13     like to know the level of their posts and the relation to General Miletic

14     and, if there was, a relation to you.  Can you explain that?

15             THE WITNESS: [Interpretation] By establishment, the chief of

16     operations was also the deputy of the administration.  And the second

17     organisational unit was the department for education and training.

18     Colonel Krsto Djeric was in charge of that.  And the third unit was the

19     operations centre, for which we did not have an officer because it was

20     simply not organised.

21             In my department, we had Lieutenant Micanovic who was a

22     cartographer, together with some desk officers who were supposed to be

23     members of the department that I worked in by formation -- by

24     establishment.

25             JUDGE FLUEGGE:  Who was the direct superior of Colonel Djeric?

Page 11952

 1             THE WITNESS: [Interpretation] General Miletic.

 2             JUDGE FLUEGGE:  Was he also a deputy of General Miletic?

 3             THE WITNESS: [Interpretation] No.  But establishment, the chief

 4     of the operations department was also General Miletic's deputy, the chief

 5     of the administration.

 6             JUDGE FLUEGGE:  That was you; correct?

 7             THE WITNESS: [Interpretation] Yes, correct.

 8             JUDGE FLUEGGE:  Thank you very much.

 9             Mr. McCloskey.

10             Sorry, Judge Mindua has another question.

11             JUDGE MINDUA: [Interpretation] Yes, indeed.  Before you remove

12     this chart, I would like to know the following.  Witness, I followed, of

13     course, with great attention your testimony concerning various functions

14     of the Main Staff personnel, VRS structure Main Staff.  But I do have one

15     concern regarding various ranks and the way they're called.  Because, as

16     you know, of course, in every country, the hierarchy of these ranks are

17     very important.  And, of course, it's always important that these ranks

18     correspond with the functions of officers.  But I noticed that in many

19     documents that we see there's a great confusion, according to me, with

20     respect to the way the ranks are called.  Maybe it's just a matter of

21     translation or interpretation.  I can just imagine how confusing that can

22     be.

23             But if we look at this chart, 65 ter 7295, titled: "Main Staff

24     VRS Structure July 1995," it would seem to me that there's also this --

25     the same confusion is also there.  We see, for instance, commander

Page 11953

 1     Ratko Mladic, and his rank is lieutenant-colonel general; right?  Because

 2     I'm trying to translate into French for myself.  And it would seem that

 3     his deputy would be Manojlo Milovanovic.  But he had the -- he has the

 4     same rank; he's also a lieutenant-colonel general.  Now, that can happen,

 5     I understand.  It's not really a problem.  However, the subordinate of

 6     Milovanovic, whose name is Radivoje Miletic, his rank is -- is the rank

 7     of a -- he is a general.  So to me that is a bit strange.  Is it possible

 8     at all?

 9             I can also notice that the assistant commander was

10     Zdravko Tolimir, and he also bore the same rank, the rank of a general.

11     And we're in July 1995.  While his superior bears the rank of

12     lieutenant-general, whereas we know that lieutenant -- that Mr. Tolimir

13     was a lieutenant-general during the period -- major-general, rather.  So

14     I would like to know, since you belonged to a category of superior

15     officers, I would like to know what was the rank between the general

16     officers of the VRS?  What was the hierarchy in July of 1995?

17             So going from the smallest general up to the highest general,

18     what was the hierarchy and what were these ranks called?

19             THE WITNESS: [Interpretation] Your Honour, that was the situation

20     then.  General Mladic became a lieutenant-colonel thereafter.  However,

21     it was not just the ranks that matter but also the positions.  And our

22     rule -- rules allowed for the officers sharing the same rank to occupy

23     positions either of a superior or subordinate.

24             I don't see a problem here.  For a while I was the chief of the

25     operations department as a lieutenant-colonel.  And then, at the same

Page 11954

 1     time, Colonel Krsto Djeric was the head of a different department.  Still

 2     I was Colonel Miletic's deputy.  And Colonel Miletic became a general in

 3     June when I became a colonel.  Those were our conditions at the time.

 4             Those officers who volunteered, because they hailed from

 5     Bosnia-Herzegovina, they were assigned to various positions based on

 6     their educational background and inclinations.  The fact that they didn't

 7     have the same ranks or perhaps had the same rank and were subordinated to

 8     each other doesn't really matter.

 9             JUDGE MINDUA: [Interpretation] [Previous translation

10     continues] ... very much.  Thanks, yes, I understand.

11             But let's go back to this chart that we have before us.

12             In July of 1995, what did this rank of Ratko Mladic mean,

13     lieutenant-colonel general?  So if compare this rank to -- to

14     Mr. Tolimir, who is superior?

15             THE WITNESS: [Interpretation] There's a mistake here.

16     General Tolimir, that's like a general term, but he was major-general.

17     So would be lower in rank than lieutenant-colonel.  But the word "major"

18     is missing here.

19             JUDGE MINDUA: [Interpretation] Very well.  Thank you very much,

20     Witness.

21             So in July of 1995, according to this chart as we see it here,

22     it's actually not exactly correct when it comes to the ranks?

23             JUDGE FLUEGGE:  Is that statement correct?  That was a question

24     for the witness.

25             JUDGE MINDUA: [Interpretation] Yes, indeed.  I was asking the

Page 11955

 1     question.  I put the question to the witness.

 2             So I wanted to know if this structure of the Main Staff of the

 3     VRS in July of 1995, is it incorrect according to the way the ranks are

 4     written here.  Is it -- is it false?  Yes or no?

 5             THE WITNESS: [Interpretation] Yes.  The people's name are

 6     correct, but their ranks are not complete.

 7             JUDGE MINDUA: [Interpretation] Thank you very much.

 8             JUDGE FLUEGGE:  Mr. McCloskey.

 9             MR. McCLOSKEY:  And thank you.  I think it's probably a good

10     idea --

11        Q.   Let's try to fix this.  So can you tell us, if you can recall,

12     and if you can't, don't worry about it, General Milovanovic, was he a

13     lieutenant-colonel general in July 1995?

14        A.   Yes.

15        Q.   And in July 1995, what was General Miletic?

16        A.   In July he was major-general.

17        Q.   All right.  And you've already clarified that General Tolimir was

18     a major-general.

19             How about Gvero?  Is Gvero lieutenant general -- sorry,

20     Lieutenant-Colonel General Gvero, as we have here?

21        A.   Lieutenant-colonel.

22        Q.   [Previous translation continues] ... that is what we have here,

23     okay.

24             How about Skrbic?  Do you recall what his --

25        A.   Major-general.

Page 11956

 1        Q.   All right.  And how about the late Djukic?

 2        A.   General Djukic was lieutenant-colonel general.  He was the oldest

 3     among all these officers.

 4        Q.   And how about Jovo Maric?

 5        A.   Major-general.

 6        Q.   And Tomic?

 7        A.   Major-general.

 8        Q.   And on that similar point, when you were a lieutenant-colonel

 9     working as Miletic's deputy, could you -- were you superior to

10     Colonel Djeric?

11        A.   Yes.  By position, I was his superior, although my rank was

12     lower.  And that was before July.

13        Q.   So could you, if you were acting as Miletic's deputy, issue an

14     order to Djeric even though you weren't equal to his rank?

15        A.   Yes.  My establishment post was the chief of the operations

16     department and at the same time the deputy of the commander.

17             THE INTERPRETER:  The chief of the administration, the

18     interpreter's correction.

19             MR. McCLOSKEY:  One last question from me, Mr. President.

20        Q.   And that is: Do you know if General Tolimir had a deputy?

21        A.    Don't know whom he appointed to deputize for him, when he was

22     absent, of the two chiefs of administrations.  I don't know who it would

23     have been by establishment.  You would have to consult the establishment

24     papers.

25        Q.   Thank you.

Page 11957

 1             JUDGE FLUEGGE:  I would like to put an additional question.  And

 2     then again Judge Mindua.

 3             What was your rank in July 1995?

 4             THE WITNESS: [Interpretation] Colonel.

 5             JUDGE FLUEGGE:  And the rank of Mr. Djeric?

 6             THE WITNESS: [Interpretation] Colonel.

 7             JUDGE FLUEGGE:  Thank you.

 8             Judge Mindua.

 9             JUDGE MINDUA: [Interpretation] Witness, I thank you because now

10     we do have the complete names of the various officers' ranks in the

11     chart.

12             But you forgot to answer one of my questions.  I was asking you

13     what was the hierarchy of the general officers' ranks within the BSA?

14     Because in French we have "général de brigade," which is major-general,

15     which is the lowest rank.  Then we have the colonel general --

16             THE INTERPRETER:  Correction of the interpreter:

17     lieutenant-colonel.

18             JUDGE MINDUA: [Interpretation] -- and then the -- which is, in

19     French, "général de corps d'armée."  And then we have the --

20             THE WITNESS: [Overlapping speakers] ...

21             JUDGE MINDUA: -- word which is, in French, "général d'armée."

22     I'd like to have the corresponding --

23             THE WITNESS: [Interpretation] [Previous translation

24     continues] -- of ranks, the lowest would be major-general.

25             JUDGE FLUEGGE:  I have to stop you because we lost most of the

Page 11958

 1     record.

 2             I think there was a problem with the interpretation channel.  The

 3     last question of Judge Mindua is not correctly recorded.

 4             Please --

 5             JUDGE MINDUA: [Interpretation] I resume my question because I

 6     hope this will be of help for us in the future part of your testimony, in

 7     order to better understand the ranks within the BSA.

 8             So I was saying that, Witness, you had not answered one of my

 9     questions, which was related to the hierarchy of the various

10     general staff generals' ranks within the BSA, and I did compare these

11     ranks with the French ranks, French army ranks.  As far as France is

12     concerned, at the lowest level we have the "général de brigade,"

13     brigadiers.  Then above him we have the "général de division,"

14     major-general.  Above him the lieutenant-general,

15     "général de corps d'armée," and above him the colonel general, "général

16     d'armée."

17             Could you help us, please, and give us the corresponding ranks in

18     the BSA.  And I hope that with the help of the French interpreters I will

19     be able to follow.  Thank you.

20             THE WITNESS: [Interpretation] The Army of Republika Srpska

21     adopted the organisation and the rules of service from the JNA.  In the

22     JNA, the ranks of general follow the -- the following hierarchy:

23     major-general, lieutenant-colonel general, colonel general.

24             In the former state and in the former military, there was also

25     the rank of a general of the army.

Page 11959

 1             JUDGE MINDUA: [Interpretation] Thank you.  This is very clear

 2     now.  Thank you very much.

 3             JUDGE FLUEGGE:  I take it in the VRS you had three ranks of

 4     generals?

 5             JUDGE MINDUA:  Four.

 6             JUDGE FLUEGGE:  I only --

 7             JUDGE MINDUA: [Interpretation] Four ranks.

 8             JUDGE FLUEGGE: [Previous translation continues] ... in the answer

 9     page 35, line 6, the -- the witness said we had "the following hierarchy:

10     major-general, lieutenant-colonel general, and colonel general."

11             And only in the former Yugoslavian army --

12             THE WITNESS: [Interpretation] Yes.

13             JUDGE FLUEGGE: -- you had army -- general of the army; is that

14     correct?  In the VRS you didn't have such a rank.

15             THE WITNESS: [Interpretation] We didn't, no.

16             JUDGE FLUEGGE:  I think now we have it quite clear and a common

17     understanding of the ranks.

18             We are over time now.  We must have our first break.  And we will

19     resume 20 minutes past 4.00.

20             Before we leave the courtroom, I would like to come back to a

21     request of the Prosecution of yesterday.  We were asked to sit in the

22     morning of the -- of Tuesday -- no, sorry, of Thursday this week.  And

23     the Defence was in agreement with that.  The Chamber is also fine with

24     the movement to the morning on Tuesday this week.  Again, on Thursday.

25     Thank you.

Page 11960

 1             We adjourn.

 2                           --- Recess taken at 3.52 p.m.

 3                           --- On resuming at 4.25 p.m.

 4             JUDGE FLUEGGE:  Yes, Mr. McCloskey.  Please continue.

 5             MR. McCLOSKEY:  Thank you.  I -- I realized I do need to stay

 6     with this chart a bit more.

 7        Q.   General, you -- can you tell us, have you heard of a unit called

 8     the 10th Sabotage Detachment?

 9        A.   Yes.

10        Q.   And can you tell us where it fit in the hierarchy or where it was

11     attached to?

12        A.   Like all other units from the first to the Herzegovina Corps, the

13     units attached to the staff and the 10th Sabotage Detachment were under

14     the command of the commander.  While professionally speaking, they were,

15     in a certain sense, subordinated to the intelligence administration.

16        Q.   This will be a term we'll hear more of.  Can you explain to the

17     Court what you mean when you say "professionally speaking"; "along this

18     professional line."  What does that mean as -- in relation to this 10th

19     being connected to the intelligence administration?

20        A.   I think that the full name was Reconnaissance Sabotage

21     Detachment.  And because of that reconnaissance tasks, it was attached

22     through the professional line to the intelligence administration.

23     Similarly, the communications regiment was professionally attached to the

24     staff, because the staff contained the communications organ, which

25     commanded and controlled, professionally speaking, those units who were

Page 11961

 1     in charge of organising the communications.

 2        Q.   Can you distinguish for us just perhaps a little bit more.  We

 3     now understand that the 10th Sabotage Detachment is under the command of

 4     the commander Mladic, like the corps are, like the other places.

 5     That's -- that's clear.  And now you say it's -- but it's professionally

 6     under the control of the intelligence administration.  What is it -- what

 7     do you mean by that?  How can this -- can it be under two -- two

 8     authorities at once?

 9        A.   This second jurisdiction does not entail the power to issue

10     orders.  The intelligence administration follows the training and the

11     materiel empowerment of the reconnaissance units.  That's the

12     professional line.  However, the line of issuing orders goes along the

13     line of subordination, which means from the commander.

14        Q.   Would the intelligence administration monitor the work of the

15     10th Sabotage, having been given an order by Mladic?

16        A.   In any case, they know, perhaps through certain proposals to use

17     the unit, and they have influenced the engagement of that unit.  So the

18     control of the unit is also possible because they are responsible for

19     this unit professionally speaking.

20        Q.   And when you say "they are responsible for this unit

21     professionally speaking," who do you mean?  Who is the top person in

22     intel and security who would be professionally responsible for the unit?

23        A.   The chief.  The chief of the administration.

24        Q.   And in this case, would be who?

25        A.   Colonel Salapura.

Page 11962

 1        Q.   And who would be responsible for Salapura and his use or control

 2     of the 10th Sabotage?

 3        A.   Well, the professional part.  Of course, the first superior of

 4     the Colonel Salapura is Major-General Tolimir.

 5        Q.   Okay.  Another box that you've got and we have down here is the

 6     65th Protection Regiment.  Can you tell us a bit about that and where it

 7     fits.

 8        A.   When it is about issuing orders, it is related to the commander.

 9     Bearing in mind the structure and tasks, by that I mean to say that it is

10     in charge of protection of the command post and the commander when it is

11     stationary and when he is on the way, it also contains a battalion of

12     military police.  The security administration contains a department which

13     is in charge for the work of the military police.  We can say that it is

14     actually a military department.  But if we wanted to phrase it in a more

15     precise way, we would say, department in charge of the military police

16     affairs.

17        Q.   And remind us who that would be in the security administration.

18        A.   You mean the intelligence?

19        Q.   I thought you said it was the security department that oversaw

20     the military police.

21        A.   The chief of the administration -- of the security administration

22     is Colonel Beara.

23        Q.   All right.  And do you know where that military police unit for

24     the 65th Protection Regiment was located?

25        A.   The regiment had two locations, I think.  It was deployed in two

Page 11963

 1     locations.  Those parts that provided security for the Main Staff were in

 2     the area of the Main Staff and the command.  Some other parts of it were,

 3     I think, in Zalukovik.

 4        Q.   All right.  Can you tell us who the commander of the

 5     65th Protection Regiment was in July, if you recall, 1995?

 6        A.   I think it was Lieutenant-Colonel Milomir Savcic.

 7        Q.   All right.  And one other department, you've noted it as

 8     department for civil affairs, we see it up at the top of ours connected

 9     to -- well, like all the rest, General Mladic, can you tell us what

10     the -- what the department of civil affairs, just fundamentally, did?

11     Just briefly.

12        A.   It wasn't a sector; it was a department.  In charge of the

13     liaison with the foreign military representatives and various other

14     organisations.  They were in charge of receiving information on the

15     movement of various UNPROFOR convoys, convoys with the humanitarian aid,

16     and, generally, for the contact with the peace force.

17        Q.   And you gave us, I believe, two names.  Can you tell us who --

18     who was in charge of that unit?

19        A.   This department was headed by Colonel Milos Djurdjic.  Another

20     person who was with him in that same department was Lieutenant-Colonel

21     Slavko Kralj.

22        Q.   All right.  And just to complete this -- the diagram, I -- let me

23     just briefly go over the corps and get their names for -- to see if you

24     agree.  And the 1st Krajina Corps was commanded by Momir Talic; correct?

25        A.   Yes.

Page 11964

 1        Q.   Will you know the ranks of the corps commanders?  General, I'm

 2     sorry to spring that on you, but that is, of course, an important topic

 3     today.  If not, don't worry about it.

 4        A.   General Talic was lieutenant-colonel general at the time.

 5        Q.   All right.  And the 2nd Krajina Corps, Radivoje Tomanic?

 6        A.   Yes.  Major-general.

 7        Q.   And the Eastern Bosnia Corps, Novica Simic?

 8        A.   Yes.  Major-General Novica Simic.

 9        Q.   And for the first part of July, 1995, Milenko Zivanovic?

10        A.   The Drina Corps.

11        Q.   And his rank?

12        A.   I think he was retired as a lieutenant-general.

13        Q.   And Drina Corps, after Zivanovic, Radislav Krstic?

14        A.   Major-General Radislav Krstic.

15        Q.   And Sarajevo-Romanija Corps, Dragomir Milosevic?

16        A.   Major-general.

17        Q.   And also, Stanislav Galic?

18        A.   The Sarajevo-Romanija Corps was commanded first by

19     Stanislav Galic and later on by Major-General Milosevic.

20        Q.   And the rank of Stanislav Galic?

21        A.   Major-general, if I remember it correctly.

22        Q.   And the Herzegovina Corps, Radovan Grubac?

23        A.   Major-General Radovan Grubac.

24        Q.   And do you recall anyone associated with the air force and

25     anti-aircraft defence?

Page 11965

 1        A.   The air force and anti-aircraft defence was commanded by

 2     Major-General Zivomere Ninkovic?

 3        Q.   And the military school centre, we see Rajko Balic [phoen] and

 4     Grujo Boric.

 5        A.   Major-General Grujo Boric.

 6        Q.   And Balic?

 7        A.   What did you say?

 8        Q.   Was Balic also associated with the military school?

 9             JUDGE FLUEGGE:  Perhaps you misspoke, Mr. McCloskey.  I see in

10     this sheet "Rajko Balac."

11             THE WITNESS: [Interpretation] The name of the school was

12     Rajko Balac, after colonel who commanded the school and was killed, in

13     the west.  So the school got its name after him.

14             MR. McCLOSKEY:

15        Q.   Thank you for that correction.

16             And then the box of the 1st Guards Brigade.

17        A.   I'm not sure.  I think it was Lieutenant-Colonel Lalovic.  But

18     I'm not sure, when we talk about the relevant time that we are discussing

19     now.

20        Q.   All right.  And what was this, very briefly, the

21     1st Guards Brigade?

22        A.   The 1st Guards Brigade is a unit attached to the staff.  However,

23     for the whole duration of the war, it was resubordinated to the

24     Herzegovina Corps.

25        Q.   All right.  And we'll get those corrections done, Mr. President,

Page 11966

 1     and out to everyone reflecting the witness's testimony.

 2             And, General, you -- going to another topic.  You testified

 3     previously about the importance of military reporting from both -- well,

 4     the brigades up to the corps, the corps to the Main Staff, and the

 5     Main Staff to the Supreme Command.  And I, first of all, wanted to ask

 6     you about:  Was there an order related to an oral reporting requirement

 7     for one particular unit?

 8        A.   Yes, there was.  There was an order related to the

 9     65th Motorised Protection Regiment.  To avoid writing written operative

10     reports, they were told that they should get in touch at certain

11     predefined times in the morning and in the evening to General Miletic.  I

12     think that that is the order that you showed me in my previous testimony.

13     I don't know the exact number and I don't know exactly who signed it.

14             MR. McCLOSKEY:  Can we see 65 ter 7260.

15        Q.   So, General, we see an order.  And we see that it comes from

16     Commander Milomir Savcic, and I won't go over it all, but it basically

17     says that:

18             "Based on a verbal order of the Chief of Staff of the

19     Main Staff ... that in the future regular reports will not be written but

20     the resident Chief of Staff will call Colonel Miletic on the telephone

21     every day at 0800 hours and 1900 hours."

22             Is this what you were referring to?

23        A.   Yes.  That's what you showed me when I testified in that other

24     case.  So the regiment commander is instructed to report orally, and this

25     is also referenced to the oral, verbal order by the chief of the

Page 11967

 1     Main Staff, instead of sending in a written report.  And also they are

 2     told at which time to do it.

 3        Q.   All right.

 4             MR. McCLOSKEY:  And could we also go to 65 ... yes, I would offer

 5     this in evidence.  Thank you, Ms. Stewart.

 6             JUDGE FLUEGGE:  It will be received.

 7             THE REGISTRAR:  As Exhibit P2140, Your Honours.

 8             MR. McCLOSKEY:  And while we're here, can we go to exhibit --

 9     65 ter 5679.

10        Q.   Now, we had just talked briefly about the

11     10th Sabotage Detachment and you'd said it was connected professionally

12     to the intelligence unit.  And we see here on 21 December 1994 from the

13     Main Staff from -- it says the chief, Major-General Zdravko Tolimir, and

14     it's entitled:  "Warning re:  The selection of the candidates for the

15     Main Staff of the VRS of the 10th Sabotage Detachment."

16             Is this the same 10th Sabotage Detachment that you spoke of

17     earlier?

18        A.   Maybe we should clear just one word.  Because you said that it

19     was "attached."  It wasn't really attached.  They are simply talking

20     about this professional line in relation to the selection of the

21     personnel for this unit.  That's the professional part for which it was

22     the administration.  It was an administration which was in charge of that

23     part, and by that I mean particularly a selection of the personnel.

24        Q.   Yes.  Thank you, General.

25             MR. McCLOSKEY:  And, Your Honours, in English the term "attached"

Page 11968

 1     and "resubordinated" are two different military terms that have a formal

 2     military significance and sometimes it gets translated that way.  And

 3     apparently the General just heard one of the formal military terms that I

 4     may have -- may have been translated.  So that's where that's coming

 5     from.  But I hope you understand what he's talking -- this professional

 6     connection that he's referring to.

 7        Q.   Now, we see General Tolimir warning the -- whoever he is sending

 8     this to, which is not precisely clear, that he wants people to select

 9     candidates for this unit.

10             Is General Tolimir's communication to the people to select

11     candidates for this unit, is that consistent with his professional

12     control over the unit that you've talked about, as opposed to the command

13     of the unit, which you've made clear was Mladic?

14        A.   The mobilisation and the manning, manning is within the

15     jurisdiction of the sector for mobilisation and personnel, they have a

16     department in charge of mobilisation and personnel within the sector.  So

17     it is possible to draw their attention to what kind of personnel they

18     should accept.  I don't see here to whom this document was sent, so what

19     I just said was simply an assumption of mine.

20        Q.   Is General Tolimir acting within his responsibility in this

21     document, as far as you know?

22        A.   Well, probably.  It was the proposal of the chief of the

23     administration for intelligence affairs, which contained the suggestion

24     about what kind of personnel should be selected for this unit.  And now

25     he is sending a memo saying what should be borne in mind while selecting

Page 11969

 1     the personnel for this unit.

 2        Q.   All right.  Now, can you just tell us, generally, how important,

 3     if it is, is receiving reports from subordinate units to the Main Staff?

 4     For example, receiving reports on what's going on in their area of

 5     responsibility from the corps to the Main Staff.  How important is this

 6     and why?

 7        A.   Reporting in the military is a very important thing because it is

 8     on the basis of a timely and accurate report that the superior command

 9     can react in an appropriate way to certain events.  If the reports are

10     inaccurate, then the decisions themselves are going to be wrong or

11     inappropriate.

12        Q.   All right.  Let's take a look at 65 ter 7259.

13             MR. McCLOSKEY:  And I offer this into evidence as well.  Excuse

14     me.

15             JUDGE FLUEGGE:  It will be received.

16             THE REGISTRAR:  As Exhibit P2141, Your Honours.

17             MR. McCLOSKEY:

18        Q.   Now, I know -- take a minute to look at it.  I think you were

19     shown this before.  It should have been in your packet.  But we can see

20     that it is from the Main Staff, dated 21 June 1994.  And we -- I can tell

21     that you that, from the second page, it is from the Chief of Staff,

22     Manojlo Milovanovic.  In fact, why don't we just show you the second page

23     so you can see that in B/C/S.

24             MR. McCLOSKEY:  Okay.  Let's go back to the first page now.  In

25     the B/C/S too, please.

Page 11970

 1        Q.   And we can see from the title of this report that it's regarding

 2     the poor utility of regular combat reports.  It's issued to all the corps

 3     that you've just gone over.  And we can see the criticisms.  Paragraph 2,

 4     that it's below the level of the commands.

 5             And the second paragraph in paragraph 2 says:

 6             "The Main Staff and the Supreme Command can make no use, for the

 7     purpose of taking strategic decisions and waging the war, of information

 8     which states only how many rifle grenades or bullets the enemy fired at

 9     our forces."

10             And then it goes on to further criticise it.

11             Now, can you tell us -- we know who the Main Staff is, now can

12     you tell us what is -- who is this Supreme Command?  What is that a

13     reference to, in 1994?

14        A.   The Supreme Commander is the president of Republika Srpska,

15     Dr. Karadzic, and the state organs that -- of which the Supreme Command

16     was composed.

17        Q.   All right.  Then we see the next paragraph.  It says:

18             "The Main Staff requires, under item 1, (the enemy), the

19     following information on the enemy: ... information on any enemy combat

20     activity on a larger scale, information on the enemy's future intentions,

21     information on the objective of forthcoming actions, ... information on

22     the possibility of the enemy attaining the objectives of his forthcoming

23     actions."

24             Now, that information of the enemy, what branch normally is

25     collecting information on the enemy?

Page 11971

 1        A.   It's the security and intelligence administration.  It's the

 2     intelligence people that collect information about the enemy, the area

 3     where combat operations take place, the time, and the armed forces.  The

 4     combat deployment, the grouping, the means of support of the enemy are

 5     analysed.  What kind of engineering support they have or whatever else

 6     they have by services.  In a word, everything that may be important for

 7     decision-making and the intentions of the enemy.  All this information

 8     must be part of the daily operative report under item 1 and be forwarded

 9     to all subordinate units.

10             Since our manning was at a low level and we didn't have trained

11     personnel, there were some weaknesses.  There were some shortcomings,

12     such as these pointed out here by General Milovanovic in this warning,

13     and there were even inaccuracies.  Corps commanders informed the

14     commander of the Main Staff in the afternoon or the evening, and in the

15     report, the corps commander requests for permission to take out a day or

16     two of leave; whereas in the report, it's stated that the commander was

17     present, although, we at the Main Staff knew that the corps commander was

18     absent at that point in time.

19             It would happen frequently that the subordinate commanders

20     sometimes would deliberately fail to faithfully depict the situation

21     which was bad for them because they lost a certain area or they failed in

22     their activities so they would only report about it a day or two later.

23     Sometimes it was deliberate.  Other times it was because the personnel in

24     question was not properly trained to do the particular -- their

25     particular jobs.

Page 11972

 1        Q.   And General Milovanovic suggests, in the paragraph 2, the second

 2     paragraph in paragraph 2, that -- that it's from these corps reports that

 3     the Main Staff and the Supreme Command may make strategic decisions on

 4     the waging of war.  Is that -- is that correct?  Is accurate information

 5     from the corps important for the strategic decisions that the Main Staff

 6     and the -- and President Karadzic make?

 7        A.   Yes.  Because the accuracy of information and forecasts are one

 8     thing, and counting the shells that landed are -- is -- is a task for

 9     journalists.  Professional soldiers are supposed to infer the enemy's

10     intentions for the coming period from their past actions and inform the

11     superior command about that.

12        Q.   Would the availability of a major unit, combat unit, having

13     finished up one task and being ready for another, would that be the kind

14     of information that would be important for the Main Staff to know?

15        A.   I'm afraid I don't understand.

16        Q.   Well, for example, let's use the 10th Sabotage Detachment.  If it

17     was done with one of its operations and there was a need someplace else

18     in the -- in the battle-front to use them, would the Main Staff need to

19     know that the 10th Sabotage was available?

20        A.   Well, the Main Staff must know because it's their unit.

21        Q.   Can you explain that?  Why must they know?

22        A.   Well, the Main Staff must know because it's a unit that is

23     directly linked to the command of the Main Staff.  No one corps can say,

24     I'll take the sabotage detachment and use it here or there; they can only

25     request the assistance of a unit that belongs to another formation or the

Page 11973

 1     Main Staff.  And then that request can either be approved or not

 2     approved.

 3        Q.   All right.  Now let's go to 65 ter --

 4             MR. McCLOSKEY:  I want to offer that into evidence, that last

 5     document.

 6             JUDGE FLUEGGE:  65 ter 7259 will be received.

 7             THE REGISTRAR:  As Exhibit P2142, Your Honours.

 8             MR. McCLOSKEY:  Now if we could go to P1215.

 9        Q.   And, General, this should be -- I'm not sure you've seen this,

10     but I wanted to show you an example of -- of a report from the Main Staff

11     to the president of the Republika Srpska.

12             And before we look into this document, can you explain how that

13     worked?  We've seen General Milovanovic say that those daily combat

14     reports from the corps had to be accurate.  Did the Main Staff have a

15     reporting requirement from the Main Staff to the president?

16        A.   There's reporting from all levels upward.  In the zone of

17     responsibility of the corps, the brigades that are subordinated to the

18     corps at certain time intervals, after 16- or 1700 hours, draft a report

19     about the current situation and send them to the corps.

20             At the corps level, all these brigade reports are integrated into

21     one report which gives a snap-shot of the situation at 1800 hours and

22     forward that to the Main Staff.

23             The Main Staff, based on all reports received from the 1st Corps,

24     2nd Corps, Eastern Bosnian Corps, Sarajevo-Romanija Corps,

25     Herzegovina Corps, military school centre, et cetera, integrates all

Page 11974

 1     these reports and forwards them to the president, or the supreme

 2     commander actually.

 3        Q.   All right.  And can you tell us what part of the Main Staff

 4     collects this information from the corps and puts it into a report to the

 5     president?

 6        A.   If we had had an operations centre, that would be the body who

 7     was supposed to do it.  But we didn't have one, so these would -- this

 8     information would come to us, to General Miletic's sector, and we would

 9     integrate the -- all these reports and forward them to the

10     Chief of Staff.  All these reports that went to the supreme commander we

11     also copied to the corps commands so that they be aware of the situation

12     in the entire theatre of war.

13        Q.   Okay.  Let's go to the last page of this report.

14             MR. McCLOSKEY:  I believe it's page 4.  It's the signature page.

15     Yes.  I believe it should be page 4 in the B/C/S as well -- yes, I've got

16     a -- you've got them both up there.  I just want to concentrate on the

17     bottom.

18        Q.   First of all we see some initials.  Not sure the interpreter

19     could make out the initials on the original, or the B/C/S.

20             Do you see those initials that are right before the signature

21     line?  I think it's "R Dj."

22        A.   I can see them.

23             JUDGE FLUEGGE: [Previous translation continues] ... [Overlapping

24     speakers] ...  I only read --

25        A.   These are my initials and the initials of the person who typed up

Page 11975

 1     this document.

 2             JUDGE FLUEGGE:  Are you referring to the left side of the left

 3     bottom part of the document?

 4             MR. McCLOSKEY:  Yes, Mr. President.

 5             JUDGE FLUEGGE:  It should be enlarged.  Thank you.

 6             MR. McCLOSKEY:

 7        Q.   Yes, can you -- now, this is dated 12 July, this document, and

 8     the initials seem to be --

 9        A.   If it's OLJ, then it's me.  But I wasn't at the Main Staff on the

10     12th.  So it may be another date.

11        Q.   Well, we do see the initials of R D, or Dj, I believe, is what

12     it's called.

13        A.   Yes.  Well, then it's Krsto Djeric.  You showed me a document

14     with my initials, OLJ.  But this must be Krsto Djeric then, and the

15     typist is MM.

16             JUDGE FLUEGGE:  Could --

17             MR. McCLOSKEY:  [Overlapping speakers] ... we may have a

18     glitch --

19             JUDGE FLUEGGE: -- this abbreviation be enlarged again.  For a

20     short moment we could see that.

21             So, sir, can you -- only the first letters, could you explain

22     again what you see now.

23             THE WITNESS: [Interpretation] M and Dj.

24             JUDGE FLUEGGE:  And this should be who?

25             THE WITNESS: [Interpretation] I can't reconstruct it now.  M Dj.

Page 11976

 1     Djeric's name is Krsto, but this is M.  Oh, yes, it's

 2     Mihajlo Djurdjevic [Realtime translation read in error

 3     "Mihajlovic Djordjevic"] from the engineers organ from the Staff.

 4     Mihajlo Djurdjevic, colonel.

 5             JUDGE FLUEGGE:  Thank you very much.

 6             Mr. McCloskey.

 7             MR. McCLOSKEY:  And then we see it says, "Standing in for the

 8     Chief of Staff, Major-General Radivoje Miletic."  Now, we spent a lot of

 9     time in the last trial about this issue.  I think if can you -- can you

10     just --

11        A.   Yes.

12        Q.   First of all, can you explain what "standing in" means in the

13     formal military sense?  And then explain whether or not in your view

14     General Miletic was actually standing in, as it suggests here, or whether

15     it was something else.

16        A.   Generally speaking, to stand in, strictly speaking and under the

17     Law on the Army of former Yugoslavia, the person who stands in for

18     somebody has all the powers of the establishment position in which he is

19     at the moment, from the status of the level at the payroll, any benefits,

20     et cetera, all the way through the power to impose sanctions or decide

21     about incentives.  And a person who stands in for somebody usually does

22     so because the other is absent due to illness or for any other reason

23     unable to perform his duties.

24             In order to stand in for somebody, you must have an order to

25     stand in.  You may remember that at the beginning I mentioned some

Page 11977

 1     details from my biography.  I said that in Derventa I was Chief of Staff

 2     and that I stood in for the commander.  The commander was not appointed.

 3     And I performed both duties.  I had the status elements of the commander

 4     while I was standing in for him.  Here, General Miletic signed as the

 5     person standing in for the Chief of Staff, but he didn't actually stand

 6     in for the Chief of Staff who was in the Republika Srpska and actively

 7     participated in tackling some issues in the theatre of war.

 8             So this is wrong.  He did not have the powers that go with the

 9     establishment position of Chief of Staff.

10             In my previous testimony I said that I roughly know when that

11     juncture was and when General Miletic starting signing as the person

12     standing in for the Chief of Staff.  If necessary, I can explain further.

13             JUDGE FLUEGGE:  Excuse me for a short moment.  In page 52,

14     line 1, it is not properly recorded the name of the drafter of this

15     document.

16             If I understood you correctly.  It was "Mihajlovic Djordjevic";

17     is that correct?

18             THE WITNESS: [Interpretation] It is Mihajlo Djurdjevic.  It is

19     not "Djordjevic," Mr. President.

20             JUDGE FLUEGGE:  This is what I said.  "Djurdjevic," with a U.  It

21     was not recorded properly.  I have -- again it's not correct.  I would

22     like to have the name corrected on the screen.

23             THE WITNESS: [Interpretation] Yes, it's an E instead of the O in

24     the last name.

25             JUDGE FLUEGGE:  Djurdjevic.

Page 11978

 1             MR. McCLOSKEY:

 2        Q.   Why don't you just spell it out and we'll get it right once.

 3     That should fix it.  Can you just spell it, the last name?

 4        A.   D-j-u-r-d-j-e-v-i-c.

 5             JUDGE FLUEGGE:  Now we got.

 6             MR. McCLOSKEY:  All right.

 7        Q.   You've just asked if you should explain how this standing started

 8     being used in this important Main Staff report and you'll agree with me

 9     that it was used quite a bit.  I mean, many we've seen, perhaps even

10     hundreds, of these reports, where it says "standing in."

11             Can you tell us how it started getting used and what it means in

12     this context?  You've described to us the formal process of standing in.

13        A.   When I was with General Milovanovic at the forward command post,

14     in the west of the Republika Srpska, Drvar more precisely, he, that is,

15     General Milovanovic, invited General Jovo Maric and me to coffee in the

16     morning.  Such a report was on the table, a report which was sent to the

17     supreme commander.  And at one point he said, Why is this Mico fucking

18     with me?

19             I apologise.  I send a report to myself, because in the signature

20     block when things are sent coded, it said "Chief of Staff,

21     General Manojlo Milovanovic."

22             After that time, this started appearing.  And when I came to

23     Crna Rijeka, they always used this signature block.

24        Q.   So this job of assembling all this critical information and

25     getting it up to the president would have been Milovanovic's job, had he

Page 11979

 1     been there; is that correct?

 2        A.   The reports don't only contain information about the enemy.

 3        Q.   Yes.  I'm just talking generally.  These reports, had Milovanovic

 4     been at the Main Staff in 1995, he would have done this, not Miletic;

 5     correct?

 6        A.   No.  We from the administration wrote -- drafted it and

 7     Milovanovic only reviewed it and signed.

 8        Q.   All right.  But reviewing it is rather important, as you've told

 9     us.  Would you agree with me?

10        A.   Yes.  But he was kind of precise about it.  He paid much

11     attention to detail.

12        Q.   And so the review and the signing off on these imports is an

13     example of something that Miletic was doing while Milovanovic was away?

14        A.   Yes.

15        Q.   All right.  All right.  Let's go to one of these -- another --

16             MR. McCLOSKEY:  And I'd offer this into evidence, please.

17             JUDGE FLUEGGE:  I think this is already an exhibit.

18             MR. McCLOSKEY:  Oh, okay.

19             JUDGE FLUEGGE:  P1215.

20             MR. McCLOSKEY:  Yes.  Now let's go to 65 ter 45.

21        Q.   General, this is the next day.  And the same report from the

22     Main Staff - it's the 13th July now - to the president.

23             MR. McCLOSKEY:  And if we can go to the last page.  It should

24     be 3, I believe, in both languages.

25             THE WITNESS: [Interpretation] No, it isn't on page three in

Page 11980

 1     Serbian.  Now we see it.

 2             MR. McCLOSKEY:

 3        Q.   Okay.  So again we see, "standing in," and then General Miletic's

 4     name.

 5             MR. McCLOSKEY:  Okay.  So let's -- let's go back to the front

 6     page now in both languages.

 7        Q.   And I -- I just want to, again pretty briefly -- we can see that

 8     it entitled "situation on the front line," and then it starts on this

 9     page with the 1st Krajina Corps, the 2nd Krajina Corps.  Then we go over

10     to the next page.  And we go down through the corps until we get --

11             MR. McCLOSKEY:  And if we could have page 3 in the English.  And

12     it's paragraph 6 in the B/C/S.

13             Yes, we get to the DK, which --

14        Q.   That's the Drina Corps; correct?

15        A.   Yes.

16        Q.   And I just want to go over this briefly.  As we see, under -- the

17     part about the enemy, and the third sentence says:

18             "The enemy from the former enclave of Srebrenica is in a state of

19     total disarray and the troops are surrendering in large numbers to the

20     VRS.  A 200- to 300-strong group of soldiers managed to break through to

21     the general sector of Mount Udrc ... where they are trying to break

22     through to the territory under Muslim control."

23             Skipping down a little bit to section (b):

24             "The situation in the corps.  Combat groups from other corps

25     units are in the final stages of preparations aimed at settling the issue

Page 11981

 1     of the Zepa enclave."

 2             And then:

 3             "Situation in the territory.  There's an organised and planned

 4     transfer of the population from Srebrenica to the territory under Muslim

 5     control."

 6             Okay.  Now, we know you're not back yet to the Main Staff, so I'm

 7     not going to ask you about these facts, but I just want to call

 8     everyone's attention to the paragraphs I just read, specifically the

 9     remark about "total disarray" and "breakthrough to the sector of

10     Mount Urdc" and "the Zepa enclave" and "the transfer of the population."

11             MR. McCLOSKEY:  And now if we could go to -- I'd offer that into

12     evidence, if it's not.

13             JUDGE FLUEGGE:  May I ask the witness:  We see here again an

14     abbreviation, NT.  And then an abbreviation for the typist.  Do you know

15     who that could be, NT?  If that is a correct translation in the English.

16             Yes, it is NT.

17             Do you know who is --

18             THE WITNESS: [Interpretation] I think it's

19     Nikola Trkulja [phoen].  I believe that his first name was Nikola.  He

20     was a colonel.

21             JUDGE FLUEGGE:  Thank you very much.  This document will be

22     received.

23             THE REGISTRAR:  As Exhibit P2143, Your Honours.

24             MR. McCLOSKEY:  All right.  And if we could go to P1601 now.

25        Q.   And I think you'll agree with me that this is a Drina Corps daily

Page 11982

 1     combat report to the Main Staff for that same day as the -- the last day,

 2     and so according to what you've told us this would one of the things you

 3     guys would be incorporating into your report to the president.

 4             And so I'd ask you to look at, under -- it should be the third

 5     paragraph under "the enemy."  And I won't read it all out but I'll

 6     briefly go over these -- the points that I hope we remember from the last

 7     document.  And it states:

 8             "The enemy from the former Srebrenica enclave are in total

 9     disarray and have been surrendering to the VRS in great numbers."

10             And then it says:

11             "One group of 200 to 300 enemy soldiers managed to cross over

12     into the general Mount Urdc sector with a view to getting onto the

13     territory under BiH control, BH control."

14             Then in combat readiness, the last sentence of that first

15     paragraph talks about combat groups from the other corps units are

16     carrying out last preparations for resolving the issue of Zepa.

17             And then under "situation" it talks about so far the transport of

18     15.000 Muslims from Potocari to Kladanj has been organised.

19             Those are the same four points, as I entitled, disarray, Mount

20     Urdc, Zepa, and the transport, that we saw going out to the president.

21     Is that part of how this was done?  You would take the information from

22     the corps and put it into the report to the president?

23        A.   Yes.  That was taken over from a Drina Corps report.

24             JUDGE FLUEGGE:  Mr. Tolimir.

25             THE ACCUSED: [Interpretation] Mr. President, the witness should

Page 11983

 1     be asked whether he was in a position to see this document.  He was not a

 2     member of the Main Staff when this document was issued.  This document

 3     was issued on the 30th of July, 1995, when he was not in the Main Staff.

 4             So the Prosecutor should ask him whether he was, indeed, in a

 5     position to see this document at the time.

 6             JUDGE FLUEGGE:  Firstly I note that there was a mistranslation, I

 7     think.  It's not the 30th of July, but the 13th of July.

 8             Mr. McCloskey.

 9             MR. McCLOSKEY:  Yes, I think you'll recall, Mr. President, I

10     acknowledged that, and the witness agreed with me, that he was not yet

11     back until the 17th.  And so we're just going over this in the context of

12     how the reports are done and whether or not this is the way to do it.

13             Yes, I am using these date, but I'm not -- as I think I've said,

14     I'm not going to be asking you about this information because you weren't

15     back yet.  That's exactly -- well, close to what I said.  I'm not sure

16     where I said it.

17             JUDGE FLUEGGE:  That is what I recall.

18             MR. McCLOSKEY:  So I understand the situation, but I think we've

19     covered that.

20             JUDGE FLUEGGE:  Continue, please.

21             MR. McCLOSKEY:

22        Q.   All right.  And in this Drina Corps report there's also a mention

23     that:

24             "In Konjevic Polje and also in Nova Kasaba reception of Muslim

25     civilians and soldiers who surrender is being carried out and [sic] taken

Page 11984

 1     in an organised fashion."

 2             Now I didn't -- as -- I don't recall, and I'm -- that that part

 3     about civilians being at that location was not mentioned in the report

 4     from the Main Staff to the president.

 5             Is it possible to mention all the details to the president?  Is

 6     this a choice that is being made, in your view?

 7        A.   I can't say.  We would have to go back to that document.  Maybe

 8     there is a bullet point covering the situation on the territory.  We

 9     would have to go back to the combined report by the Main Staff.

10        Q.   Fair enough.  Let's take a look.

11             MR. McCLOSKEY:  That is back -- oh, it has a number now.

12             JUDGE FLUEGGE:  P2143.

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

14             And it's that third page in the English, and paragraph 6 in the

15     B/C/S, under "Drina Corps."

16             THE WITNESS: [Interpretation] Yes, there is situation on the

17     territory.  And it says here:

18             "There is an organised and planned transfer of the population

19     from Srebrenica to the territory under Muslim control."

20             MR. McCLOSKEY:

21        Q.   Yeah, that -- correct, and I agree with you.  And that was -- was

22     noted in the other report.  But the -- the section that I -- I pointed

23     out that was not noted was that civilians and soldiers were showing up in

24     the area of Konjevic Polje and Nova Kasaba.  That is not anywhere

25     mentioned under the section of the Drina Corps.  Would you agree?

Page 11985

 1        A.   I would agree.  It is not there.

 2        Q.   All right.  But on that -- on that topic, let's go to another

 3     document, where we just were.  The 12th of July document, from the

 4     Main Staff --

 5             MR. McCLOSKEY:  It was P1215.

 6        Q.   -- to the president.

 7             MR. McCLOSKEY:  And it should be -- it's under, again,

 8     paragraph 6 for the -- under the Drina Corps.

 9        Q.   Okay.  And I would take us down to the bottom of the

10     paragraph under the Drina Corps.  And this one says:

11             "The enemy has been attempting to withdrew from the Srebrenica

12     enclave with women and children in the direction of Ravni Buljin and

13     Konjevic Polje."

14             So in this particular --

15             JUDGE FLUEGGE:  Can you please help us to find the relevant part.

16     And it should be enlarged, please, in the English version.

17             MR. McCLOSKEY:  It's at page 3 in the English.

18             JUDGE FLUEGGE:  Let's go back to page 3 and enlarge.

19             MR. McCLOSKEY:  And it's that last sentence on page 3.

20             JUDGE FLUEGGE:  Thank you.

21             MR. McCLOSKEY:

22        Q.   So, General, we see here in the day prior's report, your main --

23     or the Main Staff report to the president, there is a reference to women

24     and children heading in the direction of Konjevic Polje, and it's the

25     next day's report where they actually reported arriving.  So we do see it

Page 11986

 1     mentioned in this -- in this report, I guess, don't we?

 2        A.   Yes.

 3        Q.   All right.

 4             MR. McCLOSKEY:  And, Mr. President, we do not -- the collection

 5     does not contain the Drina Corps daily combat report from the

 6     12th of July, so -- otherwise, I would go look at it, but we don't have

 7     that.

 8        Q.   And, General, last time you told us that at the Main Staff there

 9     was normally a morning briefing.  Can you tell us what that was?

10        A.   When the commander was present at the Main Staff or when the

11     Chief of Staff needed to have a briefing, then we would have a morning

12     briefing.  If not, then we would do it for ourselves in the staff sector

13     every morning.  The formal ones took place from time to time on a -- a --

14     as required.  The formal ones were attended by chiefs of sectors and

15     heads of administrations.

16        Q.   All right.  And we'll get in a little more detail on this topic.

17     But from the 17th, after you arrived, did you pretty much stay at the

18     Crna Rijeka office and bedroom there near the office throughout the rest

19     of July?

20        A.   Yes.  I resided and worked at the same place.

21        Q.   And did General Miletic reside and work at the same place during

22     that same time?

23        A.   Yes.  Most of us were like that.

24        Q.   All right.  And I -- you also told the Court last time about some

25     communications issues.  You were asked about whether or not Milovanovic

Page 11987

 1     and Mladic were able to have contact while Milovanovic was out on the --

 2     the western front, as it's been referred to, during this -- during July.

 3     Were they -- did they have contact, as far as you know, in some manner?

 4        A.   Yes.

 5        Q.   And how was that?

 6        A.   Yes.  At the forward command post we organised all types of

 7     communications that existed in the -- at the main command post.  However,

 8     they are somewhat less developed.

 9             There was also a direct encrypted link by the 63 device.  And the

10     commander would call us from time to time to check what was happening in

11     the area of the 2nd Corps and in the west.  On several occasions, when

12     General Milovanovic was not back from the field, I had an opportunity to

13     report to the command of the Main Staff, although we wrote reports to the

14     Main Staff from the former -- forward command post in the same way as the

15     corps did.

16        Q.   All right.  Just try to clarify some of that.

17             You mentioned, I think, a device.  Something about 63.  Can you

18     tell us what that -- just that device is?  They may not have heard

19     everything you said.

20        A.   It's an encryption device which was made in 1963.  That was the

21     year of its make.  It is installed on a telephone line thereby making

22     that telephone line and connections established by it protected.

23        Q.   Have you referred to that as KZU 63?

24        A.   Yes.  That's the abbreviation, which stands for the cryptic

25     protection device dash 63, or encryption device, in other words.

Page 11988

 1        Q.   And was that encrypting the oral communications over the

 2     telephone, or was it some kind of encrypted fax thing over the telephone?

 3        A.   Both were coded.  If you used encryption, you had to use relay

 4     communications installed on telephones.  Many people are confused by

 5     that.  They think if you use a wire correction it must be protected, but

 6     that's not the case.  You have to use the device in order to be fully

 7     protected.  If you did not use encryption, then your conversations could

 8     be listened in, and that's why we have so many intercepted conversations.

 9        Q.   Yes, you've been shown a few intercepted conversation in the last

10     trial, and we'll get so some of those.  And that's why I'm asking about

11     this.

12             So this encryption is for voice communications over the phone; is

13     that correct?

14        A.   Yes.

15        Q.   And was -- were you able to communicate from Crna Rijeka out to

16     General Milanovic -- excuse me, Milovanovic with this machine so you

17     could speak secure voice to him?

18        A.   As I've already told you, we had all types of communications as

19     in the main command post.  However, only one line was protected.  So our

20     voice communication was protected and we could talk freely.

21        Q.   All right.  One last exhibit on that point.

22             MR. McCLOSKEY:  Could we have 65 -- excuse me, it should be P400A

23     in the English and I would think B in the B/C/S.  Sorry, we don't need to

24     do that anymore.  Okay, just 400A.

25             And, for the record, as the Court is aware, the -- the dates are

Page 11989

 1     not -- on -- on this part of the -- the transcript, so this is from

 2     17 July at 1950 hours between Krstic and Commander and, in parentheses,

 3     Mladic.

 4        Q.   And do you know if you're back at the Main Staff by 1950 hours

 5     that evening?  Are you at Crna Rijeka?

 6        A.   Yes.

 7        Q.   All right.  Well, just in looking at this intercept, Krstic and

 8     Mladic, which Krstic would this be, in your view, if this is a genuine

 9     intercept?

10        A.   Only the Drina Corps commander had that family name.

11        Q.   And do you recall that General Krstic, on the 17th of July,

12     was the -- leading the Drina Corps in the attacks on the Muslim forces

13     defending the Zepa enclave?

14        A.   I didn't know that at the time.

15        Q.   Did you learn it shortly after arriving on the 17th?  As you

16     know, this campaign went on for at least another -- well, at least

17     through the beginning of August --

18        A.   Maybe later.

19        Q.   All right.  And what I want to ask you about -- well, Mladic

20     says:  "Krle, can you hear me?"

21             Do you know General Krstic's nickname?

22        A.   Krle.

23        Q.   And then Mladic -- and Krstic then says:  "I can hear you."

24             Mladic says:  "Full steam ahead."

25             Krstic says:  "Understood."

Page 11990

 1             Mladic says:  "Get in touch with Miletic on the secure line, full

 2     steam ahead.  I didn't accept the Turks' conditions."

 3             So if General Krstic was in the field in the Zepa area, would he

 4     have been able to use this security line that you've talked to [sic] in

 5     order to contact Miletic who was at Crna Rijeka?

 6        A.   I could only speculate.  I am not aware either of Krstic's or

 7     Mladic's positions.  I don't know where they were.  However, the meaning

 8     of this is that he should talk to Miletic on a protected line so the

 9     information is not leaked.

10             I don't know why.  It is not specified in here.  But did he say,

11     "Full steam ahead; keep up."

12        Q.   Okay.

13             MR. McCLOSKEY:  I think we're past the break and so it's a good

14     time to stop.

15             JUDGE FLUEGGE:  Thank you.  Indeed.  We should have our second

16     break now, and we'll resume at quarter past 6.00.

17                           --- Recess taken at 5.48 p.m.

18                           --- On resuming at 6.17 p.m.

19             JUDGE FLUEGGE:  Mr. McCloskey, please continue.

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

21        Q.   General, you'll remember from last time you were asked about

22     Main Staff Extension 155.  We see that in intercepts and in other

23     documents.  Can you tell us, did -- was there an Extension 155 somewhere

24     at Crna Rijeka?

25        A.   Yes.

Page 11991

 1        Q.   And can you tell us where or whose extension it was?

 2        A.   It was the extension of the Chief of Staff.  But on the same line

 3     there was another telephone which was situated in our room.  It was a

 4     small room nearby.

 5        Q.   That would be the operations room is I think what you called it

 6     last time?

 7        A.   The operative -- the operations room, yes.

 8        Q.   And who was using the Chief of Staff's office and that extension

 9     while Milovanovic was away?  And I'm talking about the period after you

10     got back, 17 July.

11        A.   Nobody used it.  Nobody used that room.  It was simply a sort of

12     a living-room and also a sleeping room.

13        Q.   So who would pick up on Extension 155?

14        A.   The chief would pick it up.  And if he was absent, he would then

15     transfer the line to the telephone in the operations room so that we

16     could know if somebody called and then we would inform him about it.

17        Q.   And who was in the operations room?

18        A.   Most often it was me.

19        Q.   And where was General Miletic?

20        A.   He had his own room.  It was an office and a room.

21        Q.   And what was his extension number?

22        A.   I think it was 277.

23        Q.   And what was General Miletic's nickname?

24        A.   Some among the people who were of his own rank used to call him

25     Mico.

Page 11992

 1        Q.   And how about for General Tolimir?  What would those that

 2     could -- or those among his own rank or higher, did he have a nickname?

 3        A.   Quite often we would address him as Toso, the commander and also

 4     some other people who were in a position to afford something like that.

 5        Q.   Okay.  Now, also last time you spoke a bit about the directives.

 6     And I think earlier in the day you said that that was one of the

 7     commander's jobs, to make directives.  And we'll be looking at

 8     Directive 7 in particular.  But before we get there, can you tell us what

 9     a -- from your experience in the Main Staff, what were these directives?

10     We -- we see several of them up to Directive 7 and I believe there will

11     was a couple after that.  But what -- what is a directive?

12        A.   A directive is an act of command used by the highest echelons of

13     command.  A directive gives long-term tasks and assignments.

14        Q.   And who normally or in your experience was authored or signed off

15     on -- on these directives?

16        A.   The directives were signed by the supreme commander and the

17     commander of the Main Staff.

18        Q.   And we've seen in Directive 7, for example, that it says at the

19     end, "drafted by Miletic."  Can you tell us who drafts these things and

20     how that process happens?

21        A.   The process of drafting a directive is carried out in accordance

22     with the instruction on the work of commands and staffs.  It uses a

23     certain methodology.  You can have a full or complete method of work, an

24     abridged method of work, or a method of work which is called work without

25     consulting the organs and commands.

Page 11993

 1        Q.   Do you know which method of work was used for Directive 7?

 2        A.   The full or complete method.

 3        Q.   All right.  And can you explain the process of how a directive

 4     is -- is drafted, how it's put together?

 5        A.   The basis for drafting the Directive number 7 was the analysis of

 6     combat readiness of the Bosnian Serb army which was carried out for the

 7     previous year.  This analysis was completed at the end of January 1995.

 8             The following took place -- took part in this analysis: The

 9     commander of the Main Staff, as the presiding officer.  He opens the

10     discussion and then the corps commanders give their briefing, followed by

11     chiefs of sectors of the Main Staff.  And during the analysis conclusions

12     are made related to the level of the accomplishment of the tasks defined

13     for the previous year.  And then they proceed to define the tasks for the

14     following year.  And it is on the basis of this that the commander

15     formulates the basic principle, or the idea, after which all command

16     organs perform their assessments, put forward their proposals, which are

17     submitted to the commander.

18        Q.   [Previous translation continues] ...

19        A.   He then adopts the proposals, and those adopted proposals are

20     then unified into a single body by the operative organ.

21             So, the part that pertains to the enemy is the part that is

22     processed and then proposed as the finalized product by the intelligence

23     organ.  From the basic idea to the defining of the combat task and all in

24     between is defined by the staff.  By that I mean to say that the

25     proposals for the use of corps and subordinated units are put forward by

Page 11994

 1     the operations sector.  And whatever pertains to the arms is put forward

 2     by the organs in charge of arms.  And all is then unified into a document

 3     that constitutes a directive.  The communications organ is going to work

 4     out the communications.  The artillery organ, the artillery.  And the

 5     anti-biological, nuclear, and chemical measures are going to be processed

 6     by the appropriate organ.  Motorised units will be defined by the

 7     motorised artillery sector.  And all these elements are then unified by

 8     the operations and training sector, after which it is submitted for the

 9     signature to the appropriate commander.

10        Q.   So --

11             JUDGE FLUEGGE:  Mr. Gajic.

12             MR. GAJIC: [Interpretation] Mr. President, I think that if we

13     take into account the official translation that we have, we now face a

14     signal problem and I think we should clarify it.

15             For example, page 69, line 6 [in English]: Organs in charge of

16     arms.

17             [Interpretation] Now we have something translated as organs in

18     charge of arms as weapons, while he meant to say arms as arms of land

19     forces.

20             I have noticed that this particular word, "arms," of armed

21     forces, is translated and interpreted in various ways in the transcript.

22     I'm trying to draw your attention to the terminological confusion.  The

23     witness has simply said what he said.  But I think that the

24     interpretation into English that we received is something that needs to

25     be further clarified.

Page 11995

 1             JUDGE FLUEGGE:  I heard the word "arms" in the interpretation in

 2     English.

 3             Mr. McCloskey.

 4             MR. McCLOSKEY:  I think they're doing a pretty good job.  I'm not

 5     sure in particular where I can fix any of that, so if there's -- but I,

 6     of course, will work with Mr. Gajic and -- and the transcript on -- on

 7     some of these issues because it's not always clear when you're standing

 8     here what's -- what's essential and what isn't.

 9             JUDGE FLUEGGE:  The transcript will be checked at a later stage

10     in comparison to the tapes, and I hope during the process of reviewing

11     the transcript there may be a clarification in this respect.

12             Please carry on, Mr. McCloskey.

13             MR. McCLOSKEY:

14        Q.   You ended with that all these materials from the relevant organs

15     and people are unified by the operations and training sector and would

16     that -- that's General Miletic and you and the two other -- well,

17     fundamentally who is it?

18        A.   There was also Colonel Krsto Djeric in that administration.

19        Q.   And so is it you -- you three that worked on unifying all

20     these -- these different elements for this document?

21        A.   Your Honours, I have to clarify something.  I've explained the

22     general process of making a directive; however, I haven't took part in

23     drafting of any of the directives in the Main Staff.  I didn't take part

24     in any of them.

25        Q.   Yeah, thank you, General, for clarifying that.  Because we know

Page 11996

 1     you were not around there in March 17th, in that period.

 2             Do you know, have -- let me tell you, did you -- were you able to

 3     see Directive 7 after you got back on the 17th of July at some point?

 4        A.   Yes.  It was quite by accident that I had to get something from

 5     the closet of General Miletic.  And that's when I saw it and I looked at

 6     it.

 7        Q.   And I believe last time you said you got it from his strong-box.

 8     I don't know how that's translated.  But was there some sort of a locked

 9     cabinet or box where you were able to get Directive 7?

10        A.   It's a metal closet and General Miletic was in the possession of

11     its key.  I needed to take something else from it at the time, and that's

12     when I saw this document and I simply browsed through it.

13        Q.   Do you know -- in your absence, General Miletic was present in

14     March; his name is on it as "drafted by."  Do you know who would have

15     helped him back in those days, around March, when this thing was drafted

16     and signed?

17        A.   I don't know who it was from other sectors who drafted their

18     representative parts of this document.

19             I forgot to tell you one thing a moment ago.  For instance, the

20     logistics support was one item in the directive, but it was most often

21     done by the operations/logistics organ.  However, the chiefs of services

22     would definitely take part in wording the items that would affect their

23     services.  Logistics support, traffic service, infirmary, anything that

24     would come within the purview of their sector within the logistics.

25             So I don't know exactly who took part in drafting the

Page 11997

 1     Directive 7.

 2        Q.   We have translated for us something called the operations

 3     logistic organ.  What is that?

 4        A.   That's a sector for logistical support.  Part of it was

 5     operations logistics organ, then chief of the technical service, then

 6     chief of the quartermaster service, then chief of the medical service,

 7     then there was also the veterinary service.  So all these things come

 8     within the purview of the logistics support.

 9        Q.   Yes, thank you.  I just wanted to make sure that the operations

10     logistics is separate from the operations and training branch that you're

11     from; is that correct?

12        A.   Yes.  That's within the logistics sector.  That's where you can

13     find the operative logistics organ.

14        Q.   All right.  And I understand, as you've described it, that all

15     these other organs contributed to this document.  But I was just -- the

16     people that unified it under General Miletic's drafting is what I was

17     interested in.  Since you weren't there, do you know, besides

18     General Miletic, who worked on the drafting of the -- the unification of

19     the drafting?

20        A.   I don't know.  But you can see in the directive that it was

21     drafted by General Miletic and typed out, if I'm correct, by Z ... and I

22     forgot the other letter.  It usually contains the initials.  Or maybe, in

23     this case, the full name?

24        Q.   Yeah.  Let's -- I think it's a good time to get this exhibit.

25             MR. McCLOSKEY:  Should be Exhibit P1214.

Page 11998

 1             Now, I think the B/C/S version has to be -- B/C/S in page 23 in

 2     e-court because there's a cover letter that I think somehow got put in

 3     the back of the B/C/S version.  So could we see if page 23, the last

 4     part, of the B/C/S version I'm hoping is this cover letter.  Yes, there

 5     it is.

 6        Q.   And, General, is this -- is this a cover letter that -- that went

 7     out with Directive 7?

 8        A.   Yes.  Judging by the contents.  It is signed by the

 9     Chief of Staff.  And the cover letter was dictated by Krsto Djeric.  I

10     don't know who the typist may have been.  The initials are SZ.

11             Then there's the stamp of the command of the 1st Krajina Corps,

12     confirming the reception on the 21st of March, 1995.

13        Q.   So should the other corps have received an identical copy of --

14     of Directive 7 just, perhaps, with different cover letters?

15        A.   I think that the cover letter had the same contents only the

16     letterhead must have been different, that is, the address line.

17             So whatever was sent to the 2nd Corps or the East Bosnia Corps

18     must have had the same contents.

19        Q.   Okay.  And drawing your attention to up in the left-hand corner

20     under "very urgent," it says:  "Directive for upcoming operations."

21             So is this a directive for upcoming operations, like it says?

22        A.   I don't know why the one who processed it, Djeric, stated that.

23     Basically it is about upcoming operations, but the serial number is 7.

24        Q.   Okay.  And we see that.  And, in fact, since you mentioned

25     numbers, let me ask you about this, the third line from the top of this,

Page 11999

 1     it's strictly confidential number 03/4 ...

 2             Does that 03/4 have any particular meaning?

 3        A.   Well, since Colonel Djeric is a member of the operations and

 4     training administration, he registered this document in the log-book of

 5     the operations and training administration.

 6        Q.   Is 03/4 a number indicating operations and training sector?

 7        A.   Yes.

 8        Q.   And how about the /434.  What's the last three digits mean, if

 9     anything?

10        A.   That's the entry number for the document in that log-book, so

11     it's number 4 -- 434.

12             MR. McCLOSKEY:  Okay.  Let's go to the first page of Directive 7.

13     I think we have it in the English.  We just need to go back to where we

14     were.

15        Q.   All right.  And we notice here the date of 8 March.  The cover

16     letter was March 17th but the actual document is dated 8 March.  And it's

17     from the Supreme Command of the Armed Forces of Republika Srpska.  And

18     you've told us that that involved Radovan Karadzic.  And without going to

19     the end, I can -- do you remember that this particular directive was

20     signed off by Radovan Karadzic?  And we'll get there in a minute.

21        A.   I think it was.

22        Q.   All right.  We'll get there.

23             And we see that, like you've said, it's addressed to the -- to

24     all the corps and some of the other area -- some of the other units we've

25     talked about.  And it's entitled: "Directive for further operations,

Page 12000

 1     OP point number 7."  And it starts with:  "The main characteristics of

 2     the international military and political situation."

 3             I don't want to get into that, but do you know what -- what

 4     branch of the Main Staff would have drafted this particular subject?

 5        A.   The intelligence administration and possibly the sector for

 6     morale would be the ones.  But with emphasis on the intelligence

 7     administration.

 8        Q.   And -- all right.

 9             MR. McCLOSKEY:  And let's go to the next page.

10             THE WITNESS: [Interpretation] I apologise.  I wanted to add

11     something.

12             Since this is a directive by the supreme commander, possibly one

13     of his organs, that is, organs of the republic, were involved in the

14     assessment of the political situation, because this is both political and

15     military.

16        Q.   Okay.  Thank you.  And I think after we read this we can see that

17     you're absolutely correct on that.  But I don't -- we don't need to take

18     time, for these purposes, to read it.

19             MR. McCLOSKEY:  Could we get to the second paragraph.  It should

20     be number 3 in English.  Actually, it's -- yeah.  It's fine in English.

21     And, yeah, now we see it on the -- it's entitled:  "Muslim/Croat

22     coalition forces."  And it goes on and talks about the Federation forces

23     and the Muslim armed forces.

24        Q.   What branch would be putting in that information?

25        A.   Since the intelligence organs at all levels are duty-bound to

Page 12001

 1     monitor or follow the activities of the enemy side constantly, the

 2     intelligence administration of the Main Staff collects information from

 3     its subordinate organs and analyses the information and, in this manner,

 4     drafts such a -- such a review, or such a presentation.

 5             MR. McCLOSKEY:  Excuse me, one second.

 6                           [Prosecution counsel confer]

 7             MR. McCLOSKEY:  Thank you.  Can we go to page 7 in the English.

 8     It's paragraph 3 in the B/C/S.  Entitled: "The task of the Republika

 9     Srpska army."

10             That's page 11 in e-court.

11        Q.   Now, General, if could you just skim over this, these -- this

12     task, because I don't want to ask you about all these tasks, but I do

13     want you to -- and I want everyone to get a little feel for what is in

14     there.

15             MR. McCLOSKEY:  And then we need to go on to the next page in

16     English.  And it's the last sentence before paragraph 4.

17             And after listing a bunch of tasks, it says:

18             "Number 4 ... create the optimum conditions for the state and

19     political leadership to negotiate a peace agreement and accomplish the

20     strategic objectives of the war ... "

21        Q.   Does this anticipate that -- that a peace agreement could

22     actually happen this year, 1995?

23        A.   Well, probably at that level, where the situation is assessed and

24     conclusions are drawn from all peace talks.  The tasks were taken from

25     the analysis I was speaking about, based on the information and

Page 12002

 1     conclusions of the commanders for their own units.  And then at this

 2     level this was integrated into a -- into more or less general or specific

 3     tasks.

 4             It is the duty of the army to create as favourable conditions as

 5     possible for politics to have a stronger stand in -- in negotiations.

 6        Q.   Do you recall, back in July, was it -- was -- was there a feeling

 7     that this war was going to end, or what was the feeling in regarding of

 8     that?  I mean, when we look at this, it's talking about a negotiated

 9     peace, but was that actually something that, at the time, you felt was

10     realistic?

11        A.   Well, I can speak about myself.  When I arrived and got some

12     insight, the situation for the Sarajevo-Romanija Corps was very

13     unfavorable because the Muslim side launched a general offensive and it

14     went on pretty long.  Later on I learned that some officers were sent to

15     the Sarajevo-Romanija Corps.  The situation was bad at Mount Vlasic,

16     then around Doboj.  Not to speak about the 2nd Krajina Corps.  The -- a

17     difficult situation had prevailed for quite some time.  And when I

18     arrived there, I wasn't really an optimist.  Not at all the way you are

19     interpreting this.  Or maybe this was drafted in an optimistic manner.

20     Possibly at that point in time I had too little general knowledge to be

21     an optimist and conclude that the end was near.

22        Q.   Let me show you what you said in the Popovic trial.

23             MR. McCLOSKEY:  It's at page 28344.

24        Q.   And since it's in English, I will -- I'll need to read this to

25     you, and I would think it would be able to come up, but --

Page 12003

 1             JUDGE FLUEGGE:  I think we need the document number.  You only

 2     referred to a page.

 3             MR. McCLOSKEY:  Just one -- one second.  I surprised myself with

 4     this, but we'll get -- get to it.

 5                           [Prosecution counsel confer]

 6             MR. McCLOSKEY:  So if -- I believe Ms. Stewart will show this on

 7     Sanction so we can see this page.

 8             JUDGE FLUEGGE:  We would like to have the document number for the

 9     sake of the record.

10                           [Prosecution counsel confer]

11             MR. McCLOSKEY:  It's the transcript, and I don't think it has an

12     actual number yet.  But it's the --

13             JUDGE FLUEGGE:  Of course not because this is a viva voce witness

14     and therefore his testimony in that case is not part our documents.

15             MR. McCLOSKEY:  That's -- that's right.

16             And I see the section we're looking -- I'm looking at.

17             JUDGE FLUEGGE:  But we see on the top of this page that it is the

18     transcript of the testimony of Witness Ljubo Obradovic, in open session,

19     cross-examined by Mr. McCloskey.

20             MR. McCLOSKEY:  Yes, we're repeating a little history and then it

21     will be over tonight.

22        Q.   And I read you a section.  And I'm not sure right now where that

23     particular section is.  I -- let me -- but let me read this again and

24     I'll find it.

25             But the section I read to you was, and I quote:

Page 12004

 1             "'And thus by force of arms impose the final outcome of the war

 2     on the enemy, forcing the world into recognizing the actual situation on

 3     the ground and ending the war.'"

 4             And then I asked you:

 5             "So it fair to say that the time this was written, the -- there

 6     was actually a belief that the war may end, that the planning for the end

 7     of the [sic] war is actually happening?"

 8             And you answer:

 9             "Yes."

10             Now, of course, this is different from the paragraph I just read

11     to you, so I'm sorry about that.  Having that section I just read to you

12     and seeing your answer, do you stand by your answer that you gave in the

13     Popovic case?

14             And, General, I'm sorry.  Let me just interrupt you.  I see the

15     section that I just read.  It was right above the one I actually read.

16     So it's in that paragraph right above paragraph 4, as we can all -- well,

17     we'll see if we go back to Directive 7.

18             JUDGE FLUEGGE:  Just for the sake of the record again, you were

19     reading the lines 15 through 21.

20             MR. McCLOSKEY:  Yes, thank you, Mr. President.

21             JUDGE FLUEGGE:  The beginning of your quotation was a quote from

22     a different document, not part of your question.

23             MR. McCLOSKEY:  Actually, can we -- I'm sorry, can we go back to

24     Directive 7.  P1214.

25        Q.   And if we look in that -- in the middle of the paragraph,

Page 12005

 1     before "-- I hereby decides [sic]," it says -- yeah, just before point 2.

 2     The section I read at trial is right there.  So I'll read that.

 3              "'... inflict as much damage on his troops, equipment, and

 4     materiel as possible and thus by force of arms impose the final outcome

 5     of the war on the enemy, forcing the world into recognizing the actual

 6     situation on the ground and ending the war.'"

 7             What I read to you earlier today was the last sentence:

 8             "... to create an optimum conditions for the state and political

 9     leadership to negotiate a peace agreement and accomplish the strategic

10     objectives of the war."

11             Now, based on that paragraph and your answer to my previous

12     question, one last answer, General, and we'll break for the evening, do

13     you stand by what you said in Popovic?

14        A.   Yes, but I must explain.

15             The beginning of this paragraph with all these activities listed,

16     it begins:  "In case of an end of a -- the four months' truce and a

17     continuation of the war," and then it goes on, what should be done.  But

18     the condition for all that is that the four months' truce is interrupted

19     and the war extended, or continued.

20        Q.   Thank you, General.

21             MR. McCLOSKEY:  This would be a good time to break,

22     Mr. President.

23             JUDGE FLUEGGE:  Indeed.  We have to adjourn for today, and we

24     will resume tomorrow in the afternoon; 2.15 in this courtroom.

25             You should be reminded that it is not allowed to have contact

Page 12006

 1     with either party during the break, sir.

 2             We adjourn.

 3                           [The witness stands down]

 4                            --- Whereupon the hearing adjourned at 7.02 p.m.,

 5                           to be reconvened on Wednesday, the 30th day of

 6                           March, 2011, at 2.15 p.m.