Tribunal Criminal Tribunal for the Former Yugoslavia

Page 3592

 1                           Monday, 23 November 2009

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The accused Zupljanin not present]

 5                           --- Upon commencing at 9.03 a.m.

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

 7     IT-08-91-T, the Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 8             JUDGE HALL:  Good morning.  May we begin by taking the

 9     appearances today, please.

10             MR. HANNIS:  Thank you, Your Honours.  Tom Hannis and

11     Crispian Smith on behalf of the Office of the Prosecutor.

12             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

13     Slobodan Cvijetic, and Eugene O'Sullivan appearing finish

14     Stanisic Defence.  Thank you.

15             MR. KRGOVIC:  Good morning, Your Honours.  Dragan Krgovic and

16     Eric Tully for the Zupljanin Defence.

17             JUDGE HALL:  Thank you.

18             There being no preliminary matters, could we have the witness

19     returned to the stand, please.

20             MR. HANNIS:  While he's coming in, Your Honours, I just wanted to

21     advise you, the only thing I propose to do with him further on direct is

22     to ask him a couple of questions and then tender -- I propose to tender

23     two documents, they're both Assembly sessions of the RS National

24     Assembly, one is from November 23rd and 24th, 1992; and the other one is

25     from -- it's a portion from September 1993.  But that one is a

Page 3593

 1     retrospective where there are discussions about what happened in 1992 and

 2     I think it's relevant.

 3             JUDGE HALL:  Thank you, Mr. Hannis.

 4             MR. HANNIS:  And although this witness speaks at both Assembly

 5     sessions, I want Your Honours to see the entire Assembly session.  I

 6     think it's the only way you can make sense out of it.  If I try to give

 7     you just two pages or five pages --

 8             JUDGE HARHOFF: [Microphone not activated]

 9             MR. HANNIS:  Well, one of them is 566 pages.  And the first one,

10     I'm not sure, is much shorter.  It's only 123 in English.  But if

11     Your Honours will be patient --

12             JUDGE HALL:  We appreciate the idea of context, Mr. Hannis, but

13     if we're going to get such a large chunk, it may be useful to indicate by

14     highlighting or some other means what -- where to put in the context of

15     the entire session the bit on which you're relying.

16             MR. HANNIS:  Okay.  Your Honour, I will -- what I thought of

17     doing with this witness was just to have him read a couple of paragraphs

18     that are of particular interest to me at this point this morning.  I'll

19     tender the documents, and I certainly would be willing to highlight

20     before the end of our case those portions that we think are most

21     pertinent to you.  But again, I guess I'll save that argument for later

22     on, and maybe I can persuade you further, but if not we'll certainly

23     highlight what we think is important, and the Defence, I'm sure, will

24     highlight what they think is important.

25             JUDGE HALL:  Thank you.

Page 3594

 1                           [The witness takes the stand]

 2                           WITNESS:  DRAGAN DJOKANOVIC [Resumed]

 3                           [Witness answered through interpreter]

 4                           Examination by Mr. Hannis: [Continued]

 5        Q.   Good morning, Doctor.  Welcome back.

 6             I wanted to ask you, during 1992 --

 7             JUDGE HALL:  Mr. Hannis.

 8             MR. HANNIS:  Yes.

 9             JUDGE HALL:  Let me remind him that he's still on his oath.

10             Good morning, Dr. Djokanovic.

11             Yes, please continue, Mr. Hannis.

12             MR. HANNIS:  Thank you.

13        Q.   Doctor, in 1992 and 1993 by virtue of the positions you held, did

14     you have occasion to regularly attend the sessions of the

15     National Assembly of the Serbian people in Bosnia in the

16     Republika Srpska?

17        A.   I attended almost every session, perhaps I missed one, two, or

18     three.

19        Q.   And I would like to show you now exhibit -- it's 65 ter

20     number 933.  First we'll bring up the cover page, and I would indicate,

21     Doctor, that this is a tape-recording or the transcript of the

22     22nd Session of the RS National Assembly held on two days, the 23rd and

23     the 24th of November.  Do you recall attending this session?

24        A.   That session was held in Zvornik.  I attended it, and I also made

25     some remarks at the session.

Page 3595

 1        Q.   And if we could go to page 107 of the English and 103 of the

 2     B/C/S.  Doctor, I hope these pages are what I think they are, and it

 3     should show you as a speaker.  And you're talking about the work of the

 4     war commissioners.  Do you recall addressing that subject during this

 5     session?

 6        A.   This was toward the end of the session, where I spoke, and there

 7     was a lot negative said on the day before regarding this issue.  So then

 8     I took occasion to say a few words about the function of the war

 9     commissioners and that the main task was to introduce the civilian

10     authorities, practically to establish the state in the field, as it were,

11     and to also introduce by name the people who would be responsible for

12     things happening at that time and also for the future.

13        Q.   Thank you.  And do you recall this being the session where the

14     resignation of Prime Minister Djeric was discussed?

15        A.   Yes, yes.  This was the session where Prime Minister Djeric

16     submitted his resignation, although this entire matter was a bit

17     disputable.  He really wanted the deputies to actually cast a vote of

18     confidence on his role, but he actually tripped on this because the

19     Assemblymen did not -- they refused to vote.  They just accepted his

20     resignation.  However, he was given until the end of that session to

21     actually withdraw his resignation, which he didn't do, so that at that

22     session his resignation was actually adopted.

23        Q.   Thank you.  And I would now like to go to page 21 of the English

24     and page 17 of the B/C/S.

25             And, Doctor, in a moment I'm going to ask you to read from the

Page 3596

 1     B/C/S for us because I want to be sure that my English translation is as

 2     accurate as possible.  And I will tell you that the speaker in this

 3     section is Mr. Mico Stanisic, and he's addressing some remarks that had

 4     been made by and concerning the prime minister.

 5             MR. HANNIS:  And in the English, Your Honours, we're going to

 6     start from about eight or nine lines up from the bottom.

 7        Q.   And for you, Doctor, if you could from the bottom of the B/C/S

 8     page go up about 11 lines.  There's a sentence that in B/C/S begins with

 9     the words [Interpretation] "For that reason we therefore ..."

10             [In English] You find it, Doctor?

11             MR. HANNIS:  If it would assist, Your Honours, I can hand him a

12     hard copy of the portion I'm interested in.

13             THE WITNESS: [Interpretation] Well, I can't really make out all

14     the letters.  Some of them are darker and some are less.  So if you can

15     perhaps just blow it up a bit.

16             MR. HANNIS:

17        Q.   Or perhaps the usher can give you my hard copy, and I think maybe

18     it's easier to read.

19             Could you read the portion that's been highlighted there.

20        A.   "Therefore, we insisted that no one can just say, "You're not

21     doing a good job because I feel that you're Radovan's man.  That is no

22     argument for me.  I would like - and we tried to do because we had

23     reservists in the police at the beginning - we wanted them to defend the

24     country.  We took on board thieves and criminals, and we even had a Ph.D.

25     who held a gun in his hand.  And he did not come out to defend his

Page 3597

 1     country nor any other intellectual, but our priority task was we had the

 2     best of intentions, But perhaps we made a mistake there.  Maybe I made a

 3     mistake, too, I allow that.

 4        Q.   Thank you.

 5             MR. HANNIS:  Your Honours, based on that reading, I see some

 6     differences between what was just translated and what's in the English

 7     translation.  I will submit this portion of the document for a revised or

 8     final translation from CLSS.  But I would like to tender Exhibit 933.

 9             JUDGE HALL:  Admitted and marked.

10             THE REGISTRAR:  As Exhibit P400, Your Honours.

11             MR. HANNIS:  Thank you.

12        Q.   And, Doctor, one last document is 65 ter number 3399.  And this

13     is part of a session, I believe it's the 34th Session, during 1993 which

14     extended over something like five or six days on three different -- at

15     three different locations.  Do you recall attending this session of the

16     Assembly?

17        A.   Yes, I remember this session of the Assembly.  It started at the

18     end of August and ended toward the end of September 1993.

19        Q.   And if we could go to page 277 of the English, and I believe it's

20     320 in the B/C/S.

21             What post did you hold at this time?

22        A.   At this time I was the minister of veteran's affairs in the

23     Government of Republika Srpska.  The entire -- the full name was the

24     Ministry for Issues Relating to War Veterans and Victims of the War.

25        Q.   And you should see now on your screen that the page where you are

Page 3598

 1     shown to be a speaker, and in my English the very first line you seem to

 2     be calling on your legislative immunity, in that you're reminding

 3     everybody of your protection when you're speaking in the Assembly from

 4     being arrested or punished for expressing your opinion.  Can you tell us

 5     briefly why you did that and what you were discussing in the session at

 6     this point.

 7        A.   This was the time when a unit of the Republika Srpska army in

 8     Banja Luka took over power, and we - when I say "we," I mean members of

 9     the government and the deputies and of course members of the Presidency

10     as well as the top brass of the army - they informed us that there was

11     fighting in Banja Luka, that there was destruction, and that this was

12     practically an assault on Republika Srpska.  On this session

13     Radovan Karadzic ordered Ratko Mladic, and he was supported by almost all

14     of the deputies, he was also supported by a member of the Presidency,

15     Mrs. Biljana Plavsic, to resolve this military situation in Banja Luka.

16     Practically he ordered Ratko Mladic to use the army to quell this

17     rebellion.  I recalled my immunity as a member of the government and

18     warned Radovan Karadzic that he should not do that, that he should not

19     push Ratko Mladic, as it were, into a conflict with a portion of his own

20     army.  Of course this entire session was practically a plot by

21     Radovan Karadzic to actually settle accounts with a new government and

22     also with the top personalities.  I warned Mr. Karadzic explicitly that

23     he should not do that, that these were special conditions, wartime

24     conditions, that this republic was not his fiefdom, and that the Serb

25     people and all its politicians and members of government were part of it.

Page 3599

 1     Of course after this he launched an attack on me -- or rather, a number

 2     of deputies stood up and spoke against me.  And at this session the

 3     then-president of the Executive Board of the SDS and a deputy from

 4     Zvornik, Jovo Mijatovic, he harangued against me, and he actually

 5     misquoted me.  He misquoted something that I had said in June in Zvornik.

 6     Jovo Mijatovic then said, "Mr. Dragan Djokanovic said in Zvornik that

 7     Brano Grujic and the municipal leadership of Zvornik would be accused of

 8     genocide."  He actually turned my words around.  I said at the time, "You

 9     might be called on or accused of genocide," and I -- it was by way of

10     warning.  But in this conflict with me he said that Dragan Djokanovic had

11     said that they would be charged with genocide.  Of course, after this --

12     these comments of his, I spoke again and I replied in response to what he

13     said and also the vice-president of the Assembly, Branko Simic, and the

14     president of the republic, Radovan Karadzic, because the three of them

15     had actually launched this attack on me.  And I explained that the worst

16     that Jovo Mijatovic quoted, that actually what I had done was warn them

17     about the possibility of being charged of genocide, that I didn't

18     actually say that they would be charged, and I also stated that there had

19     been no genocide in Zvornik, that the Serbian people is not prone to --

20     not genocidal in its character, and that it never wanted an ethnically

21     clean territory, but that some day it will be discovered who were the

22     perpetrators of that programme.

23        Q.   Thank you.  And this entire session, is it fair to say that there

24     was a lot of discussion about what had happened in 1992 and who was

25     responsible for some of the events in 1992, even though this is in

Page 3600

 1     September of 1993?

 2        A.   This session of the Assembly as well as the one of November 1992

 3     was an occasion where war crimes could be discussed; however, both these

 4     opportunities were lost.  And in this Assembly session in Zvornik, one

 5     deputy said even, "Had we listened to you, we wouldn't have turned

 6     Prijedor into a Serbian city.  Had we listened to you, Radovan Karadzic

 7     and the leadership."  And this was his way of saying that he was

 8     completely independent in that respect.  In the Assembly session, in the

 9     hall where the Assembly was held, everybody stood up applauded.  Now,

10     when this issue was opened of possible charges for genocide, members of

11     the Presidency and the deputies just remained quiet and failed to

12     actually take part in this discussion.

13        Q.   Thank you.

14             MR. HANNIS:  Your Honour, there's another portion at page 274 of

15     the English, and I think it would be 317 of the B/C/S, that I would just

16     like to bring to your attention.  It relates to some discussion by Mr. --

17     Dr. Karadzic about having asked Mr. Stanisic to create a particular

18     secret service, if you will, and I think that's relevant to some

19     testimony heard last week from the videolink witness.  And with that I

20     would like to tender Exhibit 3399, and I will highlight those portions

21     that the Prosecution feels are relevant and probative to the issues in

22     this case.  And with that, I have no further questions for this witness.

23             JUDGE HALL:  Admitted and marked.

24             THE REGISTRAR:  Exhibit P401, Your Honours.

25                           [Trial Chamber confers]

Page 3601

 1             JUDGE HALL:  Cross-examination?

 2             Yes, Mr. Cvijetic.

 3                           Cross-examination by Mr. Cvijetic:

 4        Q.   [Interpretation] Mr. Djokanovic, good morning.

 5        A.   Good morning.

 6        Q.   I assume you know I am attorney Cvijetic, and I'm the co-Defence

 7     counsel in the team of Mr. Stanisic.  I studied a lot that has to do with

 8     you, with your political work from 1990, 1991, 1992, all your statements,

 9     articles in the newspaper, I looked at the web site of your party,

10     testimony in the Krajisnik case, and also the things you told the

11     Prosecutor's office.  I saw that in the period that I referred to, 1990,

12     1991, and 1992, you had quite a substantial period of political activity.

13     Would you agree with me?

14        A.   Well, events kept overtaking one another with great speed.

15        Q.   You attended in that period all the key meetings and

16     gatherings --

17             THE INTERPRETER:  Interpreter's note:  There's a lot of

18     background noise going on.

19             MR. CVIJETIC: [Interpretation]

20        Q.   [Previous translation continues]... regardless of their nature,

21     public large rallies, political rallies, and political meetings that were

22     in an inner circle, circle of the chosen.  You were also at some meetings

23     in front of the stage and also behind the stage, behind the scenes.  I

24     believe that if -- perhaps you were not the best-informed person about

25     the events, you are certainly a very well-informed person about those

Page 3602

 1     events.  Would I be correct?

 2        A.   Yes, I think that I was very well informed.

 3        Q.   Yes, I agree.  That is why I put the question to you like that.

 4     Before I put a specific question to you, can you just tell me this:  What

 5     do you think, how did you manage to secure access in order to attend

 6     these important meetings?

 7        A.   In 1990 I was the first one to appear on the Bosnia-Herzegovina

 8     political scene as somebody who wanted to introduce democratic changes in

 9     Bosnia and Herzegovina, but I did appear as an exclusively Serbian

10     politician - this was in early May 1990 when I registered the party - and

11     Dr. Karadzic appeared in 1990 but two months later.  Those two months,

12     from the time that I appeared until Karadzic appeared, I was very busy to

13     secure permits, to be able to register the Serbian national party because

14     there was a problem at the time in the law in Bosnia-Herzegovina.  This

15     was not permitted, the legal -- the Assembly of citizens on an ethnic

16     national basis was forbidden.  So when the attempts were made to legalise

17     the party, I supported the establishment of the Serbian Democratic Party

18     of Dr. Radovan Karadzic, and then this work --

19        Q.   I'm going to interrupt you a little bit, and perhaps I can give

20     you a cue so that we can help for a joint explanation.  This political

21     party of this democratic federalist party which was in favour of the

22     continuation of the Yugoslav Federation with its remaining four members,

23     was that political platform something that drew all the other political

24     subjects to enable you access for you to be able to attend such important

25     meetings?

Page 3603

 1        A.   The democratic party of federalists was registered in Bosnia and

 2     Herzegovina, and in its first programme objectives it was in favour of

 3     the constituting of a multi-party federal parliament, the democratisation

 4     of the federal Yugoslavia, and our party's desire was for this socialist

 5     federation to transform into a democratic federation.  Of course we

 6     wanted it to be a six-member federation, and if this was not possible we

 7     were willing to accept whatever was possible.

 8        Q.   And this concept was accepted by the Serbian Democratic Party and

 9     the socialist party of the Republic of Serbia, and if I'm not mistaken at

10     one point of time it was accepted by Mr. Izetbegovic, too, at a meeting

11     which you attended too, in Sarajevo when he was offered the option of

12     being the first president of this four-member federation and one of the

13     founders of his party to be the president of the council.  However, you

14     said that he actually withdrew that acceptance of his actually during the

15     day, later on, or actually in the early evening -- well, you talked about

16     that and you testified.

17        A.   Yes, Izetbegovic accepted the concept of a federal Yugoslavia in

18     mid-February, and the offer for him to be the president of this truncated

19     Yugoslavia was in October 1991.

20        Q.   Well, this is something that he then later rejected.

21        A.   Yes.  He was exposed to a lot of pressure so he couldn't really

22     follow-up on what he was up supporting for.

23        Q.   Well, there was also the Cutileiro Plan, which he accepted, and

24     then after being exposed to pressure he withdrew from the plan.

25        A.   Yes, in Lisbon, Dr. Izetbegovic accepted Cutileiro's plan.

Page 3604

 1        Q.   Had he stuck to the plan, according to you, you asserted that

 2     there would have been no war in Bosnia-Herzegovina.

 3        A.   I still believe that if Izetbegovic had adhered firmly to

 4     implementation of the Cutileiro Plan, Bosnia-Herzegovina would have

 5     remained peaceful.

 6        Q.   And probably there would have been no court, and we would not

 7     have met here; is that correct?

 8        A.   Had there been no war in Bosnia-Herzegovina, then there would

 9     have been no people from Bosnia-Herzegovina in this court or before this

10     court.

11        Q.   All right, Mr. Djokanovic, I'm not going to dwell on this

12     political aspect of it anymore.  I'm going to tell you something else

13     now.  Zvornik is a municipality which in the geographical sense can be

14     characterised as the doorway or the place of access into Bosnia and

15     Herzegovina.  Do you agree with that?

16        A.   Yes, I do.

17        Q.   Zvornik is a town that you're emotionally tied to and you worked

18     as a doctor there, if I'm not mistaken, on the basis of your CV?

19        A.   Yes, I worked in Zvornik as a young doctor.

20        Q.   However, Zvornik has a specific characteristic, it has a

21     government.  It doesn't have a classical Executive Council of the

22     Municipal Assembly, but it has a Crisis Staff but it also has a

23     government, and this is where it's different from other municipalities;

24     is that correct?

25        A.   The Zvornik Crisis Staff was called the provisional government --

Page 3605

 1             MR. HANNIS:  I'm sorry, may we have a date for this proposition.

 2             MR. CVIJETIC: [Interpretation]

 3        Q.   Mr. Djokanovic, do you know when Zvornik got this government?

 4        A.   When you were talking about the Crisis Staff in Zvornik, I assume

 5     that you're thinking about the beginning of the war.  The Zvornik

 6     Crisis Staff was called the provisional government.

 7        Q.   And that government had its president, did it not?

 8        A.   The government had its president, yes.

 9        Q.   And the Zvornik government issued its Official Gazette or some

10     sort of bulletin - I don't know the exact name - in which they published

11     their local regulations.  Is that correct?

12        A.   They did have a rounded-off legislature.

13        Q.   What does that mean?  Can you explain in a couple of sentences.

14        A.   It means that they were completely autonomous in adopting all of

15     their decisions.  At the top of this authority there was the provisional

16     government of the municipality of Zvornik.  And above them, up until the

17     time that I came to Zvornik and the formation of the war commission,

18     there was no one above that government.

19        Q.   The Zvornik government also had its commander of the Territorial

20     Defence staff, which commanded over the military as well as the

21     paramilitary formations in Zvornik; isn't that correct?

22        A.   Yes, Zvornik did have a secretary for people's defence.  I don't

23     know whom he was in command of.

24        Q.   We're going to prove this with other witnesses, and I think we

25     already did that, but at least we would agree about who it was - this was

Page 3606

 1     Mr. Marko Pavlovic, was it not? - and at the time even they didn't know

 2     what his real name was.  Is that correct?

 3        A.   Well, there was such suspicions about Marko Pavlovic, and that

 4     Marko Pavlovic was not his real name.

 5        Q.   All right.  Are you aware that this local government -- or the

 6     government, actually, didn't consider itself a local government.  It

 7     considered itself as a government in a kind of city state, if you would

 8     agree with that?

 9        A.   Well, they felt that they were a mini-state.

10        Q.   That local government also called and financed - and we presented

11     evidence on this - the paramilitaries to come to this area.  Do you know

12     anything about that?

13        A.   I remember a municipal session where this was discussed, where

14     the Presidency member Biljana Plavsic stated that she had sent a dispatch

15     to Seselj, Arkan, and Jovic, and called upon all other Serbs outside of

16     that area of ours to come and to fight for Serbdom.  In June I didn't

17     form the impression or I didn't know that the municipal leadership or

18     that that temporary government in Zvornik was in any kind of connection

19     with those paramilitary groups that had come to the municipality area,

20     and I didn't know particularly that there was some kind of financial

21     arrangement there.

22        Q.   Did you find out anything about that later?  We have evidence

23     that I can show you, but I'm asking you if you found out anything about

24     that later.

25        A.   After a few years I did find out and I read about how they had

Page 3607

 1     actually provided money to those paramilitary groups.

 2        Q.   I wanted to hear that from you because then I don't have to bring

 3     in evidence that I had already presented before.  This is why I'm doing

 4     this.

 5             Mr. Djokanovic, you noticed another problem there.  You noticed

 6     that the local police station and the local chief of the police station

 7     were not functioning, were not doing their work.  Are you aware that up

 8     until the time that you arrived, all the police chiefs and the commanders

 9     were appointed either by the local government or by the Crisis Staff.  To

10     tell you the truth, I'm not even sure myself how to call them.  Did you

11     establish that fact?

12        A.   They appointed all the commanders at the police station, the

13     chief of the police also, they even appointed the commander of the

14     Zvornik Brigade.

15        Q.   However, the first time you came you heard that there were other

16     ugly things going on in Zvornik.  That first time when you came, like you

17     said, you didn't have any specific information about what this was, but

18     you noticed that the town was empty, that the civilian population was

19     leaving town, and you saw that something was not quite right.  Is that

20     correct?

21        A.   Yes, that is right.  It's just that I wouldn't agree about it

22     being something; it was evident what it was.

23        Q.   All right.  What I'm interested in now is how you explain the

24     fact - I'm not going to draw anything from what you said, I want to hear

25     that from you - how do you explain the fact that information about this

Page 3608

 1     was not reaching Pale or you as an exceptionally well-informed person,

 2     but that you had to see these things only by personally going there.  And

 3     if I'm not mistaken, you also proposed that commissioners be in

 4     communication with the areas in the field.  Is that correct?

 5        A.   Until -- when I came to Pale, Dr. Karadzic --

 6             MR. HANNIS:  Your Honours, I object to the portion of the

 7     question regarding -- at line 18 "how do you explain the fact that

 8     information about this was not reaching Pale ..."

 9             That assumes facts in evidence that are not in evidence, and it

10     calls for speculation by this witness.  He would not know whether or not

11     the information may have been reaching others in Pale, such as

12     Dr. Karadzic or Mr. Stanisic; he only knows it wasn't reaching him.  He

13     can't speak to that.  So I would ask the question to be reformulated.

14             MR. CVIJETIC: [Interpretation] Your Honours, I think that the

15     witness understood my question like that, how was it that he didn't get

16     this information in Pale but had to find this out by personally going to

17     Pale.

18        Q.   Am I correct?

19        A.   Karadzic informed me in Pale that people from outside were not

20     coming to Pale and that he didn't have information about what was

21     happening out in the field.  I would like to actually say a few things.

22     Some things need to be clarified.

23        Q.   Just slow down, please.

24        A.   When I'm talking about the field, I'm talking about

25     Republika Srpska.  When we refer to "the field," we meant the entire

Page 3609

 1     Republika Srpska; however, de facto we're talking about the area that is

 2     east of Brcko here, the area that the government or that the Presidency

 3     of Republika Srpska in that period of 1992 was attempting to establish

 4     control over.  This is the territory of today's eastern Republika Srpska.

 5     The western part of Republika Srpska, west of Brcko, was practically

 6     outside of the reach of government or the Presidency in Pale; and for the

 7     sake of truth, it has to be said that the deputies from the western area

 8     of Republika Srpska did attend Assembly sessions regularly, and probably

 9     there was communication or an agreement from before about the cooperation

10     of municipal organs of the Serbian Democratic Party with

11     President Karadzic.

12        Q.   When you say "western part," we need to say that this is the

13     Republic of the Serbian Krajina, when you're talking about the western

14     part.

15        A.   I'm thinking about the Autonomous Region of the Krajina, the ARK.

16        Q.   All right.  I apologise.  Okay, so you are going to Brcko, you

17     went to Brcko personally.  On the basis of information -- I'm sorry, what

18     I mean to say is Zvornik.  On the basis of information that you

19     reached -- that you were given that the local authorities were not

20     cooperating with the central authority and you are giving an idea to

21     President Karadzic to establish this kind of communication by means of

22     commissioners.  Is that the main purpose of these commissioners' offices?

23        A.   After the decision to form the War Presidency, this decision

24     actually was not implemented at all because he didn't have the option of

25     establishing communications with the local authorities, and they didn't

Page 3610

 1     show any desire to cooperate with the Presidency in Pale.  I saw what the

 2     problem was, and I said that it was necessary to have a man or people who

 3     would go out in the field from the Presidency, then these commissioners

 4     would find deputies, they would organise a constitutive session of the

 5     Municipal Assembly, which would in turn elect an Executive Board and the

 6     president of the municipality or confirm the term of office of the

 7     previous pre-war president of the municipality.

 8        Q.   All right.  Perhaps we'll re-visit this visit on War Presidencies

 9     at the end of this examination, but I would now like to follow things

10     chronologically.  For the purpose of shedding some light on the situation

11     in Zvornik, you initiated a very important meeting that was held in early

12     July 1992 in Zvornik where all the commissioners of the region

13     attended - and I believe that you were in charge of this region - and you

14     also ensured that Mr. Karadzic was present as well as Commander Mladic.

15     Correct?

16        A.   This was a meeting of all the persons named as you named them,

17     but this was toward the end of June 1992.

18        Q.   Well, I do allow for the possibility of making a mistake by a day

19     or so.  However, this was an occasion where the state leadership was able

20     to find for themselves in the field what the situation there was.

21     However, you claim that this meeting was mined -- or undermined by

22     Mr. Pavlovic when he took the floor, and then he discussed topics that

23     weren't really important or matters of priority, whereby he actually

24     squandered the time that Mr. Karadzic and Mladic had, and they had to

25     leave.  Is that correct?

Page 3611

 1        A.   Well, yes.  He was just basically trying to somehow use up the

 2     time of the meeting.

 3        Q.   Well, you also attacked him at this meeting and -- but the

 4     meeting did not -- was not successful and did not proceed the way that

 5     you had envisaged; correct?

 6        A.   Yes, it was not very successful.

 7        Q.   If I remember correctly, you remained in Zvornik and then you

 8     were able to learn some more specific information as to what was going on

 9     there, and you concluded, among other things, that the local chief of the

10     police station was not actually doing his job properly and that this was

11     not a good personnel decision.  Am I correct?

12        A.   Well, on these several visits to Zvornik, I was able to observe

13     certain matters, and then if the local officials who are there all the

14     time provide information that is contrary to that, that would point to

15     their being incompetent.  And the only chance here was for someone to

16     come from Pale - and I mean a member of the Presidency or someone from

17     the police - that they should find a good man to go to Zvornik and who

18     could then observe and note what was happening there and inform the

19     president and the government thereof.

20        Q.   Well, please slow down.  I have to tell you, we speak the same

21     language, and if we speak too fast, then the translation will not be well

22     done.  All right, let's go back to this.  So you went back to Pale,

23     informed Mr. Karadzic that the problem, among other things, was also in

24     how the local police station was operating.  And he then told you to

25     discuss this with Mr. Stanisic and seek for -- and seek a solution;

Page 3612

 1     correct?

 2        A.   Yes.

 3        Q.   You then went to see Mr. Stanisic, and if I'm not mistaken you

 4     went there together with Professor Koljevic.  And you said that

 5     Mr. Stanisic listened very carefully to you -- to what you had to say and

 6     that he pointed out to you that even at the ministry where he was

 7     positioned in Pale itself he did not have sufficient staff or personnel

 8     to fill all the positions, but he did promise that he would try and find

 9     the right solution for Zvornik, the right choice; but also stating that

10     this will be very difficult, especially if he tried to find someone from

11     outside the area who would then go and try to make some order there.

12     Have I paraphrased this correctly?

13        A.   Very well.

14        Q.   When you informed him that there were also paramilitary forces

15     there and that he had already taken some steps and sent a dispatch to

16     Serbia or maybe the Federal Republic of Yugoslavia - I don't know which

17     it was at the time - because most of these paramilitary forces actually

18     came from that part and he asked for them to be prevented from coming,

19     crossing over from there.  And this actually left you with the impression

20     that he was prepared to do something about this.

21        A.   Well, Mico Stanisic said that he had sent the -- this dispatch to

22     a minister of the interior, the federal minister of the interior, in this

23     sense that they should try and prevent the paramilitary forces from

24     crossing over, and, yes, he did leave the impression that he was a man

25     who was trying to solve this problem.

Page 3613

 1        Q.   Thank you.

 2             MR. CVIJETIC: [Interpretation] Now I would like to show the

 3     witness document number 192 -- 65 ter 192.  Let's wait for that to come

 4     up.  I see that -- all right.  Now we have both versions.

 5        Q.   Here we are.  On this first page, sir, Mr. Djokanovic, I just

 6     want you to see who actually prepared this document, this communication.

 7     It actually comes, this communication comes from the department for

 8     intelligence and security affairs, and they actually prepared a report on

 9     this particular subject that we were discussing; in other words, a report

10     on paramilitary formations in the territory of the Serbian Republic of

11     Bosnia and Herzegovina.

12             And as you can see on this first page, they're providing here the

13     names of the groups, the paramilitary groups that were there, present.

14     And then if you go further down the page you will also see how these

15     groups are qualified by this department, and their intelligence service

16     characterised most of these groups - not all of them - as criminal groups

17     and that in some cases they had committed genocide.  Can you see all of

18     that?  Are you following what I'm saying, and is this true, what I've

19     just said?

20        A.   Yes.

21        Q.   Well, I wanted to broach this topic and I've already used this

22     document as an exhibit, but I would like to point you to page 3 of the

23     B/C/S version.

24             MR. CVIJETIC:  [Interpretation] And perhaps Mr. Zecevic can

25     find -- help me locate the English corresponding text.  I think it might

Page 3614

 1     also be on page 3 or maybe a little further, page 4.  There we have it.

 2     Just a moment, I'd like to find the portion that I would like to point

 3     out.  In English it may be on the previous page -- no, no, no, just --

 4     that's right.  Let's just see the top of this page.  That's fine.  We

 5     found it.

 6        Q.   That's the first paragraph in the English version and it begins

 7     with the word "at."  And then please read for us the second paragraph.

 8        A.   Well, perhaps you can give me a hard copy of this, it would be

 9     easier for me to read.

10        Q.   Well, perhaps you can just read from the -- from the screen.

11        A.   "At the moment there are about 60 paramilitary groups in the

12     territory of the Serbian Republic of Bosnia and Herzegovina, totalling

13     between 4 and 5.000 men.  Here we list the most important."

14        Q.   Please read the following line.

15        A.   Could you please just blow it up a bit.

16             "A paramilitary unit with about 170 members" --

17             JUDGE HALL:  [Previous translation continues]...

18             MR. CVIJETIC: [Interpretation] Yes, we do have a hard copy, but I

19     won't really insist.  This is enough for my purposes, Your Honours.  I

20     won't need to use this document anymore.

21                           [Trial Chamber and Registrar confer]

22             JUDGE HALL:  Mr. Cvijetic, if you could record -- to the

23     particular paragraph in the original, it would be easier for the Registry

24     to point that out to the witness.

25             MR. CVIJETIC: [Interpretation] Your Honour, we did point it out

Page 3615

 1     in the B/C/S version, that's the second paragraph.

 2             THE WITNESS: [Interpretation] Well, I did see it, but I need a

 3     hard copy.

 4             MR. CVIJETIC: [Interpretation] And in the English, that's the

 5     first paragraph beginning with "at" and then following on to the next

 6     paragraph.  That's all.

 7        Q.   But I can provide a hard copy if you like.  Can you actually read

 8     it from the screen, or would you prefer to have a hard copy?

 9        A.   Well, I really would prefer to have the hard copy.

10        Q.   Here, please take a look at the second paragraph, and please

11     don't read too fast so the interpreters can follow.

12        A.   "At the moment there are about 60 paramilitary groups in the

13     territory of the Serbian Republic of Bosnia and Herzegovina, totalling

14     between 4 and 5.000 men.  Here we list the most important:

15             "A paramilitary unit with about 170 members is located in the

16     area of Zvornik, under the command of a certain self-styled

17     Major Zuca ..."

18        Q.   Thank you.  That's all I wanted to use.  Now I need to get back

19     my hard copy -- well, actually, Mr. Djokanovic, will you please turn to

20     the next page where you can see that there is a portion relating to

21     Teslic.  Can you see that?  Have you found that, where they've found a

22     group of some 80 men; correct?

23        A.   That's correct.

24        Q.   Well, I just wanted to point out these statistics to you.  I

25     didn't really want you to assess them in any way.  But my question was or

Page 3616

 1     is:  Did you, Mr. Djokanovic, at this time when you visited Mr. Stanisic

 2     and when he told you these things about the problem, were you aware how

 3     widespread the use of paramilitary formations was at the time?

 4        A.   You're referring to the meeting in early July, I believe, up to

 5     the 5th of July, one of those days?

 6        Q.   Yes.

 7        A.   And as far as I can see, this document was prepared, this report

 8     was prepared toward the end of July, the 28th of July.  Well, we did not

 9     discuss paramilitary units in specifics, how many men they number or what

10     they are, we just discussed this in general terms.  Mr. Stanisic said,

11     "Mr. Djokanovic, we have major problems with paramilitary units."

12        Q.   Thank you.  I just wanted to point out what -- how big this

13     problem was, and I just wanted to lay a foundation for my next question.

14             Now, you would agree with me, Mr. Djokanovic, wouldn't you, that

15     in addition to some honourable men, many of them were honourable men who

16     came here to help the Serbian people and many of them were killed in

17     fighting, but there was also a large number of them who actually took

18     advantage of the status and the chaos there, the various uniforms that

19     were used, the fear among the civilian population, and also the situation

20     in the police station.  So they actually took advantage of this and

21     committed crimes; correct?

22        A.   Yes, and whatever they did, this will be lasting damage to the

23     Serbian people.

24        Q.   Would you agree with me then that such units and such formations

25     and armaments that they used called for the ministry to create a very

Page 3617

 1     strong and large enough special unit, train them, prepare them, and

 2     organise one operation after another, which also means that that would

 3     take a certain time before it could happen.  Correct?

 4        A.   Well, I don't know exactly how many of these paramilitary

 5     formations actually accepted to be submitted to the command of

 6     General Mladic, but many of them just continued doing whatever it was

 7     that they were -- they pleased.  And of course the ministry had to

 8     prepare a special unit in order to fight these people, in order to have a

 9     show-down with them.

10        Q.   Well, all right, but let me just tell you that before this action

11     in Zvornik was undertaken - and we've shown here -- we've tendered an

12     exhibit to that effect - this intervention unit first intervened in Brcko

13     and then in Zvornik, which is something of which you have knowledge.  And

14     then after Zvornik it also went to Rudo and Visegrad, and so on.  So it

15     took time to reach all those towns and places, and you would agree with

16     me that this would call for major infrastructure to organise; correct?

17        A.   Yes, correct --

18             MR. HANNIS:  Well -- Your Honour, I wish counsel would try and

19     stop the witness when he sees me rising.  At this point it's really too

20     late, but I object because that question calls for speculation on the

21     part of this witness.  There's insufficient information in the question

22     he put to him about all these towns they went to and how many

23     paramilitaries they were dealing with, et cetera.

24             JUDGE HALL:  Mr. Cvijetic, I didn't specifically rule on

25     Mr. Hannis's last objection, but the -- as with the last objection the --

Page 3618

 1     it's a question, it seems to me, of formulating the question to the

 2     witness in a way which does not invite speculation and does not, as

 3     Mr. Hannis said on the previous occasion, assume facts that have yet to

 4     be established.

 5             MR. CVIJETIC: [Interpretation] Your Honours, I told the witness

 6     that this unit before it intervened in Zvornik had also intervened in

 7     Brcko, and we have an exhibit that has already been admitted by this

 8     Trial Chamber.  I didn't point this out to the witness, I didn't imply

 9     that the witness knew of this exhibit.  This is Exhibit Number P339.  But

10     I assumed that this witness had knowledge about the engagement of this

11     unit, and in any case he would have known about the -- their intervention

12     in Zvornik because this is something that he was familiar with.  And

13     that's all I want to discuss with him, and then when other witnesses come

14     we will discuss these other places.  That's all I wanted to touch upon

15     with this witness.

16             MR. HANNIS:  If I may, Your Honour, at line 20 Mr. Cvijetic said:

17     Your Honours, I told the witness blah.  That is part of my problem.  He

18     is telling the witness many things, some of which there may have been

19     evidence or a document about, but some which have not yet been.  And he's

20     testifying.  That's my problem with what my learned friend is doing.  And

21     I would ask that he and you keep an eye on that, and I will try to stand

22     up when I see it happening again.

23             JUDGE HALL:  And, if I may add, Mr. Cvijetic, it would be useful

24     if the witness could be interrupted from -- when you see an objection

25     being taken by the other side.  Let's proceed.

Page 3619

 1             MR. CVIJETIC: [Interpretation] All right.

 2        Q.   Mr. Djokanovic, I will now put to you three documents in a row,

 3     all related to the topic that you focused on mostly during your evidence,

 4     and that is the topic of war crimes.  I will give you these documents in

 5     the chronological order.

 6             MR. CVIJETIC: [Interpretation] Could we now see 1D00-0509.

 7     Right.  This is the document.  Fortunately it's a one-page document and

 8     we just need to enlarge it enough so that the witness can see well.

 9        Q.   Mr. Djokanovic, please look at the heading.  This document is

10     dated the 5th of June, 1992.  This is a letter from the Ministry of the

11     Interior.  It was drafted by the Assistant Minister For Prevention and

12     Detection of Crime, Dobro Planojevic, you can see his signature.

13        A.   Yes, I see that it's Dobro Planojevic.

14        Q.   Would you please read it to yourself.  It's quite brief.  And

15     then I will put some questions to you about it.

16        A.   What I have seen in the beginning is that Planojevic says that

17     there is an increase in crime and war crime.

18        Q.   Yes, and it says here in the middle that special attention is to

19     be paid to uncovering perpetrators of war crimes, to documenting the

20     criminal activities of individuals and groups, their apprehension, and

21     ensuring that they are taken before responsible organs.  Have you found

22     that?

23        A.   Yes.

24        Q.   And then towards the end, the penultimate sentence, it's longish,

25     says:

Page 3620

 1             "Since in wartime you will encounter numerous obstacles in

 2     combatting crime and will on occasion be unable to take adequate

 3     measures, in such cases record all information in official notes for

 4     subsequent measures, necessary measures, i.e., criminal prosecution."

 5             Have you found that?

 6        A.   Yes.

 7        Q.   Mr. Djokanovic, I will put the other two documents to you as

 8     well.  But the problem that you were aware of is something that the

 9     Ministry of the Interior had also been aware of.  And as a result, they

10     sent an instruction to the CSBs on what needed to be done.  Do you agree

11     with that?

12        A.   Yes --

13             JUDGE HALL:  Just a moment, Mr. Cvijetic.

14             MR. HANNIS:  Your Honour, I object the attempt to try to put this

15     document in through this witness unless we have some further information

16     that he knows who Mr. Planojevic was, he knows whether indeed this

17     document was transmitted.  It does not appear on its face that it was

18     transmitted.  There's no delivery information indicating it was actually

19     sent.  We don't know whether it was just a draft.  I think this is not

20     the appropriate witness to get this document in through.

21             JUDGE HALL:  Well, before Mr. Cvijetic moved on from this

22     document the question I was going to ask for my own edification, is, to

23     whom -- is there any evidence to whom it's addressed?  We know who it's

24     purportedly signed by.

25             MR. CVIJETIC: [Interpretation] Your Honours, in the heading it

Page 3621

 1     says to whom it was sent.  Is that clear now?

 2             JUDGE HALL:  Yes, thank you.

 3             What about Mr. Hannis's objection?

 4             MR. CVIJETIC: [Interpretation] Your Honours, I do not intend to

 5     tender this document into evidence through this witness.  I'm using these

 6     documents to show the witness what action was taken, what practical

 7     measures were taken by the ministry in order to prevent the problems that

 8     this witness pointed out --

 9             JUDGE HALL:  Just a moment.

10                           [Trial Chamber and Registrar confer]

11             JUDGE HALL:  I understand this document is already a Defence

12     exhibit.

13                           [Defence counsel confer]

14             MR. CVIJETIC: [Interpretation] I apologise.  My colleague just

15     told me that, yes, that's true.  I can't mention the name of the witness

16     through which it was introduced.

17             THE REGISTRAR: [Previous translation continues]...

18             MR. CVIJETIC: [Interpretation] This makes it easier,

19     Your Honours.  I don't need to justify why I'm showing this document to

20     the witness.  It's already in evidence, but I've told you what my line of

21     questioning was.  1D84.

22             Your Honours, my next document, I have the number, is again the

23     exhibit number, so it's already been admitted.  Could we see P190.  I

24     think that's the right number.

25             THE WITNESS: [Interpretation] I apologise, may I comment on this

Page 3622

 1     document?

 2             MR. CVIJETIC: [Interpretation]

 3        Q.   Forgive me, but there was an objection so I couldn't ask you

 4     whether you knew anything about this.  Please go ahead.

 5        A.   Mr. Dobro Planojevic is a policeman, a professional policeman,

 6     and he drafted this document according to the rules that apply to

 7     professional policemen.  But why did Dobro Planojevic disappear from the

 8     police infrastructure after this?

 9        Q.   Mr. Djokanovic, he will come here as a witness so he can tell us

10     about that himself.

11             MR. CVIJETIC: [Interpretation] Do we have the document now?  We

12     do.

13        Q.   Mr. Djokanovic, you can see from the heading the nature of this

14     document, this is a letter and this is exhibit already admitted.  And

15     here we see that the problem that you informed Mr. Stanisic of and

16     something that he's been informed of by Dobro Planojevic as well, we see

17     here that he now in his turn informs Mr. Djeric of it and that he asks

18     for political support for resolving this problem.  Political support is

19     the same term that you used.  Is that clear from the text?

20        A.   Yes.

21        Q.   So you agree with what I put to you?

22        A.   I do.

23        Q.   All right.  I will put to you now another exhibit, and we can see

24     how the chronology evolved.  The previous document was dated 18th of July

25     and the next one is 19th of August, 1D63, again an exhibit in this case.

Page 3623

 1     All right, we have it now.  Again, you'll have trouble reading this,

 2     since in the Serbian the text is on the first page and the second page is

 3     a form.  Could we either enlarge it -- or rather, I'll give you a hard

 4     copy.  That would be the best way to proceed.

 5             Now, before the break I will ask you to read this.  And could we

 6     scroll down to the bottom of the page on the screen, please, and see the

 7     attachment that was sent with this letter of the minister.  Yes, we have

 8     the attachment.  You have seen this attachment too, haven't you,

 9     Mr. Djokanovic?

10        A.   Yes.

11        Q.   How did you understand this letter of Mr. Stanisic?  Or would you

12     agree with me that this is yet another step towards a practical

13     implementation of the goal that we described, which was fighting against

14     war crimes and war criminals?

15        A.   Yes, this instruction and this form are indeed a practical

16     implementation of that.

17        Q.   All right.  Let me just see the transcript.  However, that is not

18     enough.  Practical steps needed to be taken as well, they needed to

19     intervene wherever it was necessary.

20        A.   Yes.  Practical steps were needed as well, but all of that needed

21     to be prepared by politicians, otherwise there would have been no results

22     without that.

23        Q.   I will get to that, Mr. Djokanovic.  I will get to the

24     politicians and politics.  I wanted to show you before that what

25     Mr. Stanisic had done.

Page 3624

 1             MR. CVIJETIC: [Interpretation] Your Honours, this is a different

 2     topic.  Would you rather that I begin before the break?  I have finished

 3     showing the documents to the witness, and I would like to turn to

 4     something else.

 5             JUDGE HALL: [Overlapping speakers] We still have another

 6     8 minutes to go before --

 7             MR. CVIJETIC: [Interpretation] All right.  I thought that the

 8     break was at 10.20.

 9             JUDGE HALL:  It's 10.25.

10             MR. CVIJETIC: [Interpretation]

11        Q.   All right.  Mr. Djokanovic, you are aware, aren't you, that after

12     all of these instructions, orders, documents with information and so on,

13     Mr. Stanisic ordered that an operation be carried out in Zvornik,

14     inter alia.  I told you that we have evidence that an operation in Brcko

15     preceded the one that you know of, so an operation was carried out in

16     Zvornik in which 54 members of the Yellow Wasps were arrested, and they

17     were arrested, prosecuted, expelled, and that this is how this group was

18     broken down.  Are you aware of this --

19             MR. HANNIS:  Objection.  I think that assumes facts in evidence

20     when he says 54 members were arrested, prosecuted, expelled.  I don't

21     think we have evidence that 54 members were prosecuted, et cetera.  And

22     this question is much more complicated and compound than it needs to be.

23     The question could be, were you aware that there was an operation to

24     arrest these men and Zvornik?  And then we could go step by step.  But

25     Mr. Cvijetic tries to put too much into his question.  And I think that

Page 3625

 1     makes it difficult for the witness, and it makes it difficult for you as

 2     the triers of fact to know exactly what he has answered yes to.

 3             MR. CVIJETIC: [Interpretation] Your Honours, I am relying on the

 4     statements that the witness gave to the OTP and on his evidence in

 5     Krajisnik.  I know that this witness knows this.  It's not by accident

 6     and without reference that I'm asking him this.  And I will put reference

 7     to him in the next document that I will ask to be tendered.  He doesn't

 8     need to know of the exact number of these members.  I will prove that

 9     through the document that I have and the question that I put to him in

10     the end:  Do you know anything about this, are you aware of this?  So the

11     witness can say whether he is or he isn't.

12             MR. HANNIS:  Aware of what, though, that 54 members were

13     arrested?  That 54 members were prosecuted?  That 54 members were

14     expelled?  What?  We have to break it down.

15             JUDGE HALL:  Break up the question, Mr. Cvijetic.

16             MR. CVIJETIC: [Interpretation]

17        Q.   Mr. Djokanovic, do you know of things I that mentioned in my

18     question, save for the figure?  Do you know that?

19        A.   I know that an operation was carried out.  The special police of

20     the Ministry of the Interior of Republika Srpska entered Zvornik, and

21     then for a while after that they were stationed in Zvornik.

22        Q.   I think that you told us that part of that unit was present when

23     this Assembly session was held and that the session was held without any

24     incidents.

25        A.   You mean the November session?

Page 3626

 1        Q.   Yes, yes.  I think that they had their accommodation in the Drina

 2     hotel.

 3        A.   Yes, you're right, but why don't you put to me the document that

 4     you showed me the other day about what the police investigation had

 5     shown -- carried out --

 6             THE INTERPRETER:  The interpreter didn't hear the name of the

 7     person.

 8             MR. CVIJETIC: [Interpretation]

 9        Q.   I was about to put that document to you.  That was the next

10     document I intended to put to you, and I wanted to broach that topic.

11             MR. CVIJETIC: [Interpretation] So, Your Honours, I have several

12     documents I want to put to this witness in a row, and I think it would be

13     better if we did that after the break.

14             JUDGE HALL:  So we take the break now and return in 20 minutes.

15                           --- Recess taken at 10.22 a.m.

16                           --- On resuming at 10.44 a.m.

17             MR. CVIJETIC: [Interpretation] May I continue, Your Honours?

18             JUDGE HALL:  Yes, yes, Mr. Cvijetic.

19             MR. CVIJETIC: [Interpretation] Could the witness please look at

20     document from the 65 ter list 296.

21        Q.   Mr. Djokanovic, this is document --

22             MR. ZECEVIC:  I apologise.  We are not receiving the LiveNote on

23     our computers.

24             MR. CVIJETIC: [Interpretation] I hope I can begin now.

25        Q.   Mr. Djokanovic, you had an opportunity to look at the document a

Page 3627

 1     little bit during this break.  It's information drafted after the

 2     operation and the action against the Yellow Wasps on the 4th of August.

 3     And where you see what you see.  I'm not going to read from it.  You've

 4     seen when the monitoring of that group began, May/June 1992.  The reason

 5     I wanted to show you this information actually is the last passage.

 6             MR. CVIJETIC: [Interpretation] Can we please look at page 3 of

 7     the Serbian version.  Yes, it's the last page in both versions, so be it

 8     as it may.  In the English can we please enlarge the last passage, the

 9     last passage, down there, down there.

10             THE WITNESS: [Interpretation] I can see it.

11             MR. CVIJETIC: [Interpretation]

12        Q.   All right.  Can you please read that part.

13        A.   Yes.

14        Q.   So other than general crime for which this group was prosecuted,

15     in the last paragraph it says that a person who perpetrated a war crime

16     against Muslim civilians was placed at the disposal of the military

17     police and the military forces for further processing in cooperation with

18     the national security service of the MUP of Republika Srpska, which was

19     gathering all of this information for that purpose.  You would agree with

20     me that perhaps this would be in the line of anticipated acts in the way

21     that you would expect them to take place, don't you think so?

22        A.   Yes.

23        Q.   However, along this line of action, I have to show you the

24     following document and that is 65 ter exhibit 2739.

25             MR. CVIJETIC: [Interpretation] All right.  That is that document.

Page 3628

 1     Let's just check that --

 2             MR. HANNIS:  I'm sorry, Your Honour, I'm not finding it in the

 3     list of documents that I was advised would be used with this witness.

 4             MR. CVIJETIC: [Interpretation] There was an e-mail about it this

 5     morning, 2739.  You have it.  There is an e-mail.  You found it?  Okay.

 6             MR. HANNIS:  No, I'm not sure.  Can you give me the page number,

 7     the 1D page number.

 8                           [Prosecution counsel confer]

 9             MR. HANNIS:  I --

10             MR. CVIJETIC: [Interpretation] I checked this morning.  I think

11     it's there.  Okay?

12             MR. HANNIS:  Thank you.

13             MR. CVIJETIC: [Interpretation]

14        Q.   Mr. Djokanovic, the next logical move, you would agree with me,

15     would be the processing, the realisation of the information acquired by

16     the police, and these would be criminal charges against this group.

17     Isn't that right?

18             MR. HANNIS:  I'm sorry to interrupt.  The reason I couldn't find

19     it apparently is this already has an exhibit number in evidence as P322.

20             MR. CVIJETIC: [Interpretation] Your Honours, this is the second

21     document that I failed to secure, but it's easier than for me to explain

22     why we're having it.

23        Q.   Mr. Djokanovic, it's not yet time for you to answer.  So the

24     practical implementation would be in the processing, in the issuing of

25     the criminal charges?

Page 3629

 1        A.   [No interpretation]

 2             THE INTERPRETER:  The witness's answer was not heard.

 3             MR. CVIJETIC: [Interpretation] Can we please look at page 2 in

 4     both versions.

 5        Q.   I apologise, Mr. Djokanovic, your answer was not registered when

 6     I asked you about the practical realisation you answered.  Can you please

 7     repeat your answer.

 8        A.   This was after the arrest, a logical step, criminal charges in

 9     terms of the prosecution.

10             MR. HANNIS:  Could we have clarification.  Prosecution for which

11     crimes?  Car thefts or crimes against non-Serb civilians?

12             MR. ZECEVIC:  Again, the intervention in the transcript, it

13     wasn't translated as the witness said.

14             MR. CVIJETIC: [Interpretation]

15        Q.   Can you please repeat one more time, Mr. Djokanovic, for the

16     third time.  Please don't be mad.

17        A.   After the arrest of the members of the Yellow Wasps, the next

18     logical step was to issue criminal charges from the Ministry of the

19     Interior sent to the prosecutor's office.

20        Q.   Very well.  In light of the objection by my learned friend the

21     Prosecutor, can we please look at page 2 of the criminal charges.  Ah,

22     it's already there.  I apologise.

23             So after 11, paragraph 11, can we please scroll up.  Scroll up if

24     it's on that page, and I think that it is.  And let's see if it's on that

25     page, and I think it is, where it says "the individual named under number

Page 3630

 1     9 ..."  So that would be the second paragraph after the number 11

 2     paragraph.  Mr. Djokanovic, do you see it?  Can you read it, please.

 3        A.    "The individual named under 9 is currently remanded in custody

 4     at the Stepa Stepanovic military barracks in Bijeljina; the military

 5     organs decided that he be remanded into custody."

 6        Q.   Can we go back now to see who is number 9.

 7        A.   This is Vuckovic, Dusko, a.k.a. Repic.

 8        Q.   I'm going to remind you of the last paragraph of the previous

 9     document where it is stated that the same was handed over to the military

10     organs in cooperation with the security for -- service for national

11     security.  And this is actually what it practically says in this

12     document, that this individual was remanded in custody.

13        A.   Yes.

14        Q.   I'm not going to test your knowledge about jurisdiction and

15     whether he was under the jurisdiction of the military organs because of

16     the nature of the crime, it being a war crime.  But I'm going to tell

17     you, and I can even show you, that against him and his brother, criminal

18     procedures were initiated for a war crime in the Republic of Serbia.  I

19     can show you --

20             MR. CVIJETIC: [Interpretation] Can we please place on the monitor

21     criminal charges for the war crime, and this is Exhibit 1D00-5858.

22             Yes, that's it.  Can we scroll it up a little bit?  We haven't

23     got it in the English version, but then when we do we can do the same

24     thing.

25        Q.   Mr. Djokanovic, you can see here just who was charged.  You can

Page 3631

 1     see that the Vuckovic brothers were charged, and then at the bottom when

 2     we scroll up the Serbian version we can see why.  And it says:

 3             "On grounded suspicion that as co-perpetrators they perpetrated

 4     the criminal act of a war crime against a civilian person."

 5             Is that correct?

 6        A.   Yes.

 7        Q.   Let's go to the next page.  All right.  We can enlarge that part

 8     and you can continue to read, sir.  I don't know if you're familiar with

 9     the qualification of crimes and the law, but this is what I'm asserting

10     it says here precisely, and so on and so forth.  All right.

11             MR. HANNIS:  Your Honour, I have an objection to this.  Yes,

12     Mr. Cvijetic, is asserting several things, but the document speaks for

13     itself.  I don't know what comment we're trying to get from this witness

14     that's going to advance your job.  And if the document wants to be

15     admitted, it can't come in through this witness.  It's not -- he hasn't

16     seen it before, he's not a military person, he can't explain it, he can't

17     explain what the outcome of this was, if any.

18             JUDGE HALL:  Mr. Cvijetic, what is your question of this witness,

19     first of all?

20             MR. CVIJETIC: [Interpretation] Your Honours, I'm pursuing the

21     line along the things that the witness is confirming for me, and I'm also

22     following the line of the Prosecutor who's asking that I establish

23     whether the Yellow Wasps were prosecuted for general crimes and for war

24     crimes.  I'm not asking him to know exactly the contents of these -- all

25     right, well, let me tell the Prosecutor I'm not going to tender this

Page 3632

 1     report through this witness.  I'm asking him.  All right, now, I'm asking

 2     him whether he knows whether the Vuckovic brothers or Dusko Vuckovic,

 3     a.k.a. Repic, was prosecuted in Serbia for a war crime.  Here, I'm going

 4     to ask him whether that was true or not.

 5             MR. HANNIS:  Okay.  That -- I agree, that's an appropriate

 6     question.  But to ask this witness to read something that's a document

 7     and say:  Is that what it says?  That's not a good use of our time,

 8     Your Honour.

 9             JUDGE HALL:  I think Mr. Cvijetic has taken your point on that,

10     and he has formulated his question.  So let's proceed.

11             MR. CVIJETIC: [Interpretation]

12        Q.   Mr. Djokanovic, there's nothing else left for you to do but to

13     reply for this last question.  I'm not going to deal with this last

14     document.

15        A.   I know from the media that the Vuckovic brothers were prosecuted

16     in Serbia for war crimes committed in Zvornik.

17        Q.   Thank you.  Mr. Djokanovic, now when we are pursuing, so to say,

18     this line that you as a commissioner also pursued from initial

19     information and if we parallelly follow this police line too, is this

20     what you expected to be done by the Ministry of the Interior?

21        A.   Yes, by the Ministry of the Interior.

22        Q.   Very well.  You anticipated my next question because on Friday

23     you finished your testimony with the words - I'm going to paraphrase as I

24     cannot remember every word - but the policies did not accompany this

25     action the way it should have done.  Have I more or less paraphrased

Page 3633

 1     correctly what you said?

 2        A.   Correct.

 3        Q.   I'm going to remind you of a small episode before I -- all right,

 4     I'm being told that I'm also going too fast.

 5             Yes, I'm being told that this thing about the policy is quite

 6     brief, but I'm going to actually show you documents where we will try to

 7     draw a broader answer to see what you meant to say.  So I'm going to put

 8     questions to you where you can actually say in a little bit more detail

 9     what you wanted to say.

10             I'm going to now put some questions to you in relation to an

11     episode with Prime Minister Djeric.  I think that you also discussed this

12     with him; is that correct?

13        A.   Yes.

14        Q.   And you assert that he discretely, between the lines, conveyed a

15     threat from the field, mostly from Zvornik, because you were talking a

16     little bit too loudly about war crimes.  Can you please explain in your

17     own words so that I don't have to talk about it, and as briefly as

18     possible so that you don't use up too much of my time.

19        A.   The then-Prime Minister Djeric after a regional meeting held in

20     Bijeljina, upon returning to Jahorina, told me that the local officer

21     from Zvornik --

22             THE INTERPRETER:  There is too much background noise,

23     interpreter's note.

24             THE WITNESS: [Previous translation continues]... said at that

25     meeting in Bijeljina that he was charged by Alija Izetbegovic for war

Page 3634

 1     crimes and genocide in Bijeljina -- in Zvornik, and that this is also

 2     being repeated by the Serbian functioner -- functionary Djukanovic [as

 3     interpreted].  Branko Djeric said that after those words were spoken much

 4     had changed as far as I was concerned and that I needed to pay attention

 5     to my security.  It says Djukanovic here, but actually it is Djokanovic.

 6             MR. CVIJETIC: [Microphone not activated]

 7             THE INTERPRETER:  Microphone.

 8             MR. CVIJETIC: [Interpretation]

 9        Q.   My microphone was off, so I have to repeat the question.  Did he

10     tell you specifically who it was who voiced this?  You said that he said,

11     "You have greetings from Zvornik."  Correct?

12        A.   Yes.

13        Q.   Well, explain it, please.

14        A.   Well, he said, "You have greetings from Zvornik."  I thought that

15     this was really well meant, these greetings, and I said to him, "Well,

16     yes, I used to work there as a doctor and I know those people."  However,

17     a few days later Branko Djeric came to see me at the Presidency in Pale,

18     and what he said earlier was on Jahorina.  So he came and he told me in

19     more detail about the meeting in Bijeljina, and he told me literally the

20     following.  "Dragan [as interpreted] Grujic said in Bijeljina that Alija

21     Izetbegovic had accused him of the crimes in Zvornik, but he was also

22     accused by a Serb official, Djokanovic.  And then Djeric told me, with

23     the best of intentions, that after such words had been said and spoken I

24     should take certain steps in order to ensure my own safety.

25        Q.   Could you please repeat the name of the person who -- the name

Page 3635

 1     did not enter -- the right name did not enter the transcript.  So could

 2     you please repeat the name.

 3        A.   This was Branko Grujic, who told -- who said in this meeting in

 4     Bijeljina that he had been accused of war crimes by the -- by

 5     Alija Izetbegovic, but also by a Serbian official Djokanovic.

 6        Q.   All right.  Thank you.

 7             Could you tell us other than a fear for your safety, did you

 8     observe that he, too, had certain concerns about his own safety,

 9     Mr. Djeric?

10        A.   Well, no.  We were discussing the re-shuffling of government, and

11     after this conversation that we had, he mentioned or offered me to be a

12     member of his government.

13        Q.   All right.  Thank you.  Now, within the context of your -- of

14     what you've told us about the lack of political support, I will now put

15     to you the document that had already been used by the Prosecutor, that's

16     65 ter 933.  And while we're looking for the document, let me just say

17     that this is a -- this document relates to the meeting of the 23rd and

18     24th of November, 1992.  You said that you attend -- you had attended

19     this session; correct?

20        A.   Yes.

21        Q.   Please bear with me a moment.  Let us just find that document.

22             MR. CVIJETIC: [Interpretation] Could we now have page 18 and then

23     19 in the B/C/S version, and in English that will be on page 23.

24             MR. HANNIS:  Just for the record, Your Honour, I think that's one

25     I referred to this morning, and we've marked it as P400, but I've since

Page 3636

 1     discovered that I think it already had a P number of 202.  So I'm not

 2     sure how we fix that, but it does have a P number.

 3                           [Trial Chamber and Registrar confer]

 4             JUDGE HALL:  We're advised that the previous number has fallen

 5     away so the number can remain.

 6             MR. HANNIS:  Thank you.

 7             MR. CVIJETIC: [Interpretation] I thank my learned colleague for

 8     following all these numbers, exhibit numbers.  Obviously I'm not as good

 9     with the numbers as he is, and I may have or might have brought

10     additional confusion with a third number that I would come up with.  I

11     think we have the right page -- or rather, no.  The B/C/S version I need

12     page 18, in other words the next page.  Just one page.

13             We do have the right page in the English.  Could we just scroll

14     up or down the Serbian version, the remarks by Biljana Plavsic.  This is

15     where it begins, and in English we can see that it's a longer portion.

16        Q.   Mr. Djokanovic, would you please just read the introductory

17     remarks by Mrs. Plavsic, and once you have done that could we please

18     scroll it to the next page.  So that would be on page 19 in the Serbian

19     version.  We don't have it yet.  I don't know what is going on.  So let's

20     just zoom in on the first paragraph.

21             Mr. Djokanovic, would you read the entire paragraph, please.

22        A.   I have read it, and I have to say I remember her remarks almost

23     in their entirety.

24        Q.   Very well.  What I will do now is paraphrase.  I don't want to

25     read through because we can all read what it says there.  But let me

Page 3637

 1     paraphrase.  You would agree with me that Mrs. Plavsic is actually

 2     defending herself here, defending against the rumours that she was the

 3     one who brought these volunteers, as it were, these paramilitary units.

 4     She -- her defence amounts to her publicly acknowledging this; correct?

 5        A.   Yes.

 6        Q.   And throughout her remarks, as she is discussing the rumours and

 7     what is being said, she's actually addressing a minister.  Can we now

 8     see -- is it possible to discern from her words whom it is that she's

 9     polemicising with?

10        A.   Well, speaking from there she was addressing everyone, but

11     primarily her words were directed at Stanisic.

12        Q.   Mr. Djokanovic, after these words of hers, as you could see there

13     was applause.  Now, I read your statements and I tried to figure out what

14     it was that you meant by saying that there was a lack of political

15     support.  Please correct me if I'm mistaken, but I believe that you've

16     said that unfortunately a discussion of this type was supported by some

17     members, the radical members, of the Assembly.  And unfortunately this

18     happened in an Assembly session.  Am I correct?

19        A.   Well, yes, but I would have to expand on that.

20        Q.   Yes, we will get to that, but just tell me is this --

21        A.   Well, let me tell you, this is not just a radical group in the

22     Assembly.  This relates to a majority of the deputies.  As you can see,

23     it says there that there was applause.  Had there been just a few

24     individuals applauding, I don't think that this would have been written

25     down in the notes.

Page 3638

 1        Q.   Thank you.  Now, if you meant that there was a lack of political

 2     support from this high position, lack of support from Mr. Stanisic and

 3     his colleagues, I would fully agree with you.  Was that what you were

 4     referring to, that there was a lack of general political support of this

 5     type?

 6        A.   Well, this session of the Assembly in Zvornik was supposed to

 7     inaugurate Mr. Branko Djeric as prime minister, as a person responsible

 8     for his entire cabinet, who would re-shuffle and replace some members in

 9     some ministries, but also who would get a free rein in putting together a

10     new government and taking full responsibility for the work of his

11     government.  We all expected then that Branko Djeric would not renege on

12     what had been agreed upon.

13        Q.   Mr. Djokanovic, please, I have to stop you.  Just tell me

14     specifically, was this discussion, the remarks by Mrs. Plavsic, were

15     these remarks in support of Mr. Stanisic's action or not?  Just in two

16     sentences.

17        A.   Well, I will continue with what I had started earlier.  At this

18     session Branko Djeric actually submitted his resignation, and then all

19     the dirty laundry came out.  In expecting that there will be a total

20     unravelling, Biljana Plavsic was addressing the matters that she felt she

21     was responsible for, and she was actually putting forth information that

22     she had sent requests to various parties for volunteers to be sent to

23     Bosnia-Herzegovina to take part in the fighting.  That is absolutely not

24     in support of the Ministry of the Interior and their work, at least as

25     far as the take-over of the public security station in Zvornik is

Page 3639

 1     concerned.  I'm not here referring to any other aspects of the police

 2     work.  So not one of the remarks that were made at this session, not by

 3     Biljana Plavsic or any other members of the Assembly, none of them felt

 4     that it was -- that it would be appropriate to pay any attention to what

 5     was happening in Zvornik.

 6        Q.   All right.  But the -- my question is actually referring to this.

 7     You say that this is something that gave you cause for your greatest

 8     concern; correct?

 9        A.   Well, yes, that's what I said, but at the end of the session when

10     I saw how things were going, I took the floor again and I said, "We have

11     to make a step forward.  We have to take some steps in order to

12     consolidate the situation, consolidate Republika Srpska, and to pursue

13     further activities in a positive way."  However, these were bad and dark

14     days for the Serbian republic.  The prime minister practically was

15     frightened off by all the things that were before him.  The government

16     was falling apart.  The deputies were applauding to these people

17     committing war crimes in the Assembly session.  So this entire situation

18     was really very bleak.

19        Q.   All right.  Thank you.  In the next government, if I'm not

20     mistaken, there were no posts for either Mr. Stanisic or for you; am I

21     correct?

22        A.   Well, in part.  Mr. Stanisic was not a member of the next

23     government, but I was.  I was assigned to this Ministry of

24     Veteran Affairs because problems had been piling up in that respect for

25     the past seven or eight months, so they actually handed me this hot

Page 3640

 1     potato to handle.

 2        Q.   All right.  I just have a few more questions.

 3             Again, something from your statement regarding the new minister

 4     of the interior.  Am I correct that you actually said that it seems that

 5     he neither could nor knew how to nor wanted to proceed and embark on new

 6     investigations and prosecution?  Am I correct?

 7        A.   Well, yes, you're completely correct.  I think this was a very

 8     wrong person for that post.

 9                           [Defence counsel confer]

10             MR. CVIJETIC: [Interpretation]

11        Q.   I've been told that part of my question was not fully

12     interpreted, so I will repeat it, although we have your answer.  I

13     reminded you of your claim that ...

14                           [Defence counsel confer]

15             MR. CVIJETIC: [Interpretation]

16        Q.   Mr. Djeric --

17             MR. HANNIS:  I'm sorry, if he's going to make a reference to his

18     statement, I assume he means his 92 ter statement which would be his

19     prior transcript.  If we could have a page reference, then we'd all know

20     exactly who he's talking about.

21             MR. CVIJETIC: [Interpretation] No, no.  I'm just reminding or

22     asking the witness to repeat this before this Trial Chamber,

23     Your Honours, whether this is correct.

24        Q.   The government actually had a new minister of the interior;

25     correct?

Page 3641

 1        A.   Are you asking me?

 2        Q.   Yes.

 3        A.   Well, yes, the government did get a new minister of the interior,

 4     and I remember my comments that I made and the statement that I gave to

 5     the investigators.  This was a man who in no way deserved to be appointed

 6     as minister of the interior.  He was not a policeman nor was he the right

 7     person for this post, and this was a responsible post, the post of

 8     minister of the interior.

 9        Q.   All right.  We both need to say what the name of this person was,

10     the minister, this new minister.

11        A.   Well, he was so significant that I can't even recall his name.  I

12     think his last name was Adzic.

13        Q.   Very well.  Although 1994 is not really relevant here, let me

14     just ask you this:  In this post as minister you actually witnessed the

15     situation where Mr. Stanisic was again co-opted into the government,

16     correct, as minister?

17        A.   Well, in 1994 I submitted a resignation, but in keeping with or

18     under the constitution of Republika Srpska, I was bound to remain at that

19     position and I continued to -- in that role.  And during that time when I

20     was still in that process, the new Minister Stanisic was appointed.

21        Q.   Very well.  Thank you.  Now, you said that this minister, whose

22     name you've just mentioned, did not wish, did not dare, or did not know

23     how to continue ...

24                           [Defence counsel confer]

25             MR. CVIJETIC: [Interpretation]

Page 3642

 1        Q.   Mr. Djokanovic, because part of my question has to do with the

 2     new minister whose name you have just mentioned, and I am told that it

 3     was not recorded in the transcript, his name was Adzic; correct?

 4        A.   Well, let's clarify that.  So when the new government was

 5     appointed, presided over by Vladimir Lukic, the minister of internal

 6     affairs was to be Adzic I can't recall his first name, who was in Ilijas.

 7        Q.   All right.  And now my next question.  He did not wish, dare, or

 8     know how to proceed and how to continue with the investigations and the

 9     prosecution that had already been initiated; am I right?

10        A.   Well, for the third time today, yes, you're right.

11        Q.   And you said - I'm not sure I heard that part - that you were

12     actually still in government when Mr. Stanisic was re-appointed; correct?

13        A.   Well, under the constitution I was obliged to remain there while

14     I was -- although I had already resigned, but I had to stay in that post.

15     And during that period awaiting the new appointment in my place,

16     Minister Stanisic was re-appointed, and he was in this new government

17     whose president was now Mr. Vladimir Lukic.

18        Q.   All right.  And now my question:  How true is it, something that

19     my client told me, that he attempted to continue some of those --

20             MR. HANNIS:  Objection.  If he's going to try and put in his

21     client's testimony through this question, I object.  His client can

22     testify if he wants to, but this is not an appropriate way to formulate

23     the question.

24             MR. CVIJETIC: [Interpretation] I accept the objection.  I will --

25     reacted before the Chamber did.

Page 3643

 1        Q.   Let me ask you this:  Did you give your support to Mr. Stanisic

 2     in this new cabinet?  Did you support his further activities and steps

 3     that he undertook?

 4        A.   Yes, Mico Stanisic knows that I was the single person who

 5     supported him within that government.

 6             THE INTERPRETER:  Could the witness please come closer to the

 7     microphone.  He is speaking very quietly.

 8             MR. CVIJETIC: [Interpretation]

 9        Q.   Can you tell us specifically whether that pertains to the

10     investigations that had been commenced?

11        A.   Yes, it does.  It pertains to the investigations for war crimes.

12     Mico Stanisic and I were the only ones in that government who were

13     interested in resolving that problem, and after that government the black

14     days were ushered for Republika Srpska.  The government was completely

15     under the influence of the SDS, and there was no justice and no desire to

16     fight crime any longer in that government.

17        Q.   Was that the reason why Mr. Stanisic resigned, or was that one of

18     the reasons?

19        A.   I don't remember that particular detail, that Mico Stanisic

20     resigned, but I know that they couldn't wait for the day when he will

21     cease being minister of the interior.

22        Q.   I understand that to mean - and you can correct me - that he by

23     continuing his action was actually in the way of these people, he was

24     bothering them?

25        A.   That was a problem in 1994, and neither he nor I figured in any

Page 3644

 1     of the personnel plans for the following government that were headed by

 2     Kozic and some other people.

 3        Q.   Was that because he didn't fit into those black days, as you

 4     called them, or bad days?

 5        A.   Mico Stanisic did not fit in those black days.

 6        Q.   Can you please clarify in two sentences what that means.

 7        A.   Mico Stanisic is a professional policeman and he applied police

 8     standards in his work.  The politics in Republika Srpska starting from

 9     1994 until the end of the war was engulfed in dirt, was drenched in dirt,

10     and this is what I mean when I say "black days."

11        Q.   Thank you.  And let me ask you this:  During those numerous

12     meetings that I attributed to you, if I may say so, the ones that you

13     attended, I never once saw that Mr. Stanisic was one of the attendees

14     except for occasions where he had to attend in his capacity of the

15     minister of the interior.  Am I right?  This applies to 1990, 1991, and

16     1992.

17        A.   Mico Stanisic never had any political statements.  I know him

18     from before the war, I knew him before the war as an athlete and after

19     that as well.  The Serb political circles did not have anyone -- a better

20     man than Mico Stanisic.  And before the war he was appointed head of city

21     MUP in Sarajevo, and then I think he was in that position when the war

22     started.  And throughout the time I've known him, he was a model

23     policeman - I'm referring to the -- that entire period throughout the

24     war.

25        Q.   And this is my last question, so it seems now.  This Assembly

Page 3645

 1     session and all of the evidence from that session will be in evidence in

 2     this case, and everybody will be able to read that, and everybody will be

 3     able to read the statement given on that occasion by Mico Stanisic.  And

 4     I hope you will agree with me that this Assembly session was an

 5     opportunity to come out with the dirty laundry, to air it?

 6        A.   After that operation of the Ministry of the Interior, this

 7     Assembly session had a good opportunity to start settling accounts with

 8     various criminals out in the field.

 9        Q.   There were mutual accusations among everyone, including

10     Mr. Stanisic, Djeric, Biljana Plavsic, and so on; and what they differ in

11     was something that they pointed out when addressing the Assembly, the

12     matters on which they differed.  Since you obviously know Mr. Djeric and

13     Mr. Stanisic, my question to you is:  Do they have anything in common,

14     anything in common that you see?

15             MR. HANNIS:  Objection, Your Honour.  This calls for speculation.

16     We need some further foundation before we're having this witness make a

17     comparison of the characters of the accused and a witness in this case.

18     First of all, it has to go to some issue that's specific.  If he has some

19     specific knowledge about specific instances regarding truthfulness,

20     perhaps that would be something he can ask about; but a general question

21     about reputation or comparing character isn't appropriate.

22             MR. CVIJETIC: [Interpretation] Your Honours, I can either explain

23     or reformulate.  It's no problem whatsoever.  I can ask the witness to

24     give his position or opinion or I can ask him specifically, it's fine.  I

25     will ask him.

Page 3646

 1        Q.   Mr. Djokanovic, do you know both Mr. Djeric and Mr. Stanisic from

 2     the period of time when you were acquainted with them, do you know them

 3     as honest people?

 4        A.   In the period before the war I knew both Mr. Djeric and

 5     Mr. Stanisic as well-known, well-regarded, honest citizens.  I don't know

 6     about the disagreements they had in the government.  I wasn't a member of

 7     the government at the time, so I know nothing about that particular

 8     problem.

 9        Q.   Thank you, Mr. Djokanovic.  I have no further questions.

10             MR. CVIJETIC: [Interpretation] Your Honours, I've concluded my

11     cross-examination.

12             JUDGE HALL:  Thank you, Mr. Cvijetic.

13             Mr. Krgovic?

14             MR. KRGOVIC:  We don't have questions for this witness,

15     Your Honour.

16             JUDGE HALL:  Re-examination?

17             MR. HANNIS:  Thank you, Your Honour.

18                           Re-examination by Mr. Hannis:

19        Q.   Mr. Djokanovic, this morning at page 13 Mr. Cvijetic asked you

20     about the provisional government in Zvornik.  Can you tell us, if you

21     know, how did the provisional government relate to or interface with the

22     Crisis Staff in Zvornik?  Do you know?

23        A.   What I know is that the Crisis Staff in Zvornik was called the

24     provisional government.  So Zvornik municipality did not have a

25     Crisis Staff, rather they had provisional government which performed the

Page 3647

 1     tasks that were normally performed by Crisis Staffs in other

 2     municipalities.  Or to be even more specific, the day I came to Zvornik

 3     the Crisis Staff in Zvornik was called provisional government.

 4        Q.   And who was the president of that provisional government?

 5        A.   The provisional government was headed by Branko Grujic.

 6        Q.   Do you know who the other members were?

 7        A.   I had some documents with first names and last names, and I had

 8     that document in front of me when I testified in Krajisnik.  I don't

 9     remember the exact names of people.  I know that there was Risto Vukovic

10     who was a secretary; then there was somebody called Radic; Jovo

11     Mijatovic; Jovo Ivanovic; Marko Pavlovic; Tomasevic, Slavoljub.

12        Q.   Branko Grujic was a member of which political party, or

13     Brano Grujic?

14        A.   Brano or Branko Grujic at the time was president of the Municipal

15     Board of the SDS.

16        Q.   And do you know whether or not he had a personal relationship

17     with Radovan Karadzic; and if so, what was the nature of that?

18        A.   I don't know what relationship he had with Radovan Karadzic.  I

19     can just say in general terms that upon my arrival in Pale, Karadzic told

20     me that he had problems with communication on the ground.  He didn't say,

21     "I have problems communicating with people in Zvornik and with Zvornik

22     municipality."  He just said in general terms, "I have problems with

23     communications."

24        Q.   Page 16, line 10, Defence counsel asked you:

25             "That first time when you came, like you said, you didn't have

Page 3648

 1     any specific information about what this was, but you noticed that the

 2     town was empty, that the civilian population was leaving town, and you

 3     saw that something was not quite right.  Is that correct?"

 4             Your answer:

 5             "Yes, that is right.  It's just that I wouldn't agree about it

 6     being something; it was evident what it was."

 7             What was it that was evident?

 8        A.   It was so obvious that two years later, two years and some three

 9     months later, a member of the parliament from that municipality, the

10     Assemblymen, in September 1993 still remembered my words that back then I

11     had warned Brano Grujic and the municipal leadership in Zvornik that in

12     the future when the war was over they could be charged with genocide.  He

13     later interpreted those words as though I could charge him with genocide.

14     And there was no dilemma in my mind either when I talked to members of

15     the Presidency in Pale or when I said to the minister of the interior at

16     Jahorina that the situation in Zvornik was grave indeed when it came to

17     war crimes and when it came to a possible charge of genocide.

18             JUDGE HARHOFF:  Can I just follow-up on this answer.

19             MR. HANNIS:  Certainly.

20             JUDGE HARHOFF:  Because, Mr. Djokanovic, you said that there was

21     a risk that members of the Assembly could possibly be charged with

22     genocide once the war was over.  For which incidents exactly did you

23     propose that the members of the Assembly could be charged with genocide?

24     And exactly which members were you thinking about, or were you having in

25     mind?

Page 3649

 1             THE WITNESS: [Interpretation] Your Honours, this is how it was.

 2     First of all, I talked to individuals in municipality of Zvornik.  There

 3     were two or three of them in that meeting, and I told them that the

 4     situation in Zvornik was such that after the war they could be charged

 5     with genocide and they had to be careful.  They couldn't justify by

 6     saying those were paramilitary formations.  No.  They -- there were

 7     people there who were in charge of the situation, who were known people,

 8     and who could control it.  And then I repeated these words in mid-August

 9     1992 at the constituent Assembly when responsible people were in

10     attendance.  First of all, I had to endure a number of offences by

11     Brano Grujic, and then I came out and I said that I came here on behalf

12     of Republika Srpska and on behalf of the constitution of

13     Republika Srpska.  Regardless of the fact that we do not belong to the

14     same political party, we plan to have Republika Srpska as a democratic

15     state, a multi-party state, in which all citizens regardless of their

16     ethnic, religious, or racial affiliation would be equal before the law.

17     And do not think that this war will not eventually come to an end; it

18     will end just like all other wars.  Then I repeated the same identical

19     words at the republican parliament in September of 1993 when all members

20     of the parliament could hear it at the republican parliament when I told

21     them that the Serbs were not a genocidal nation and that the war crimes

22     were not committed by Serbian nation, but rather by individuals, and that

23     all of those who did not intervene would be considered accomplices.

24             JUDGE HARHOFF:  So, if I understand you correctly, the criticism

25     that you expressed was that the members or the persons in Zvornik who

Page 3650

 1     were in control, that they should have intervened more actively and

 2     promptly to prevent the crimes that were committed by the volunteers.

 3     And because they did not take such counter action, they could be held

 4     co-responsible for genocide.  Is that your testimony?

 5             THE WITNESS: [Interpretation] Your Honour, when I came to

 6     Zvornik, in the local hotel in Zvornik the reserve police was stationed.

 7     The hotel was full of reserve police officers, and also there was the

 8     Zvornik Brigade.  I don't know what quality it was, but it did exist.  So

 9     the local leadership had enough military forces without the intervention

10     at the republican level.  They had the police and the military, and they

11     could have finished the job in the Zvornik municipality territory.

12     Nobody could have prevented them from doing that.  However, they did not

13     want to do that.  They would have had my support, and I'm sure that in

14     that particular action they would have had the support of some people in

15     the Presidency and some people in the government.

16             JUDGE HARHOFF:  Thank you, Mr. Djokanovic.  Do you imply that the

17     reason why the police officers in Zvornik did not intervene was that they

18     really supported the action taken by the volunteers?  They not -- they

19     didn't fail to intervene; they didn't intervene deliberately.  Is that

20     what you're saying?

21             THE WITNESS: [Interpretation] Your Honour, if you have the

22     military power - in this case both military and police forces - and you

23     have war criminals in the area and you do not make the decision to

24     resolve this in an adequate manner, then you are a co-conspirator and you

25     are not resolving the problem.  This is how I interpreted it.

Page 3651

 1             JUDGE HARHOFF:  Thank you, Mr. Djokanovic.

 2             Back to you, Mr. Hannis.

 3             MR. HANNIS:  Thank you, Your Honour.

 4        Q.   In connection with this you said you wouldn't agree about it

 5     being something, it was evident what it was.  Did you receive any

 6     specific details or information about what you referred to as ugly things

 7     happening in Zvornik in your conversations with the locals during your

 8     visit?

 9        A.   Already on the first day when I came to Zvornik, I noticed a

10     column of old people who were going from Zvornik to Mali Zvornik.  They

11     were crossing the old iron bridge.  These were elderly people.  I know

12     that they were Muslims because the women were wearing clothing specific

13     to that ethnic group.  They were wearing the pantaloons, and this is what

14     happened.  On Friday I said that I had the intention of going to Bratunac

15     right away, but I stayed in Zvornik for another day or two.  So I had the

16     opportunity to speak to citizens of Zvornik to go to the hospital where I

17     used to work, and even to ask about individual cases of persons of my

18     friends, my colleagues, where they were, and so on.  And in those

19     conversations I found out about extremely unpleasant things that those

20     people had experienced.  And I found out -- I mean, people spoke out of

21     fear.  Perhaps they were not able to speak out the correct words, such as

22     "war crimes" and things like that.  But they were talking about ugly

23     things happening in Zvornik.  There was no Muslim population.  When I was

24     asking about particular people, He escaped, he had to pay to get out of

25     Zvornik, and so on and so forth.

Page 3652

 1        Q.   I need to press you a little bit.  You said "extremely unpleasant

 2     things" and you said "ugly things," but can you be more specific.  Are

 3     you talking about somebody being assaulted in public or something more

 4     severe than that?

 5        A.   When I came to the Zvornik hospital, I asked about the director

 6     of that medical institution.  He was the director when I was working in

 7     Zvornik.  This is internist Muhamed Jelikic.  He's a very, very

 8     professional person and he spent the entire period of the war with the

 9     citizens of Zvornik and he served both Muslims and Bosniaks.  He has two

10     daughters; one of them is married to a Serb.  He had to - at least that's

11     what the people told me - had to pay to -- Marko Pavlovic to get out of

12     Zvornik, to beg him on his knees and to cry.  Then I asked about

13     Kamisalic, Mujo Kamisalic, who was the president of the municipality of

14     Zvornik; he also had to escape, and his old mother was thrown out of her

15     apartment and she spent the nights on the staircase and sleeping under

16     the stairs.  Then Drago [as interpreted] Dragutinovic, an elderly citizen

17     of Zvornik who practically knew everybody in Zvornik told me - he knew me

18     very well also from the time I was working in Zvornik - he said to me,

19     "Dragan, please help us, we Serbs cannot go out into the streets either.

20     Then you can imagine the kinds of things that are happening to Muslims.

21        Q.   Did you hear anything more specific about what was happening to

22     Muslims?  Did you hear about detentions, mistreatment and detention

23     facilities, killings?

24        A.   I spoke with people within the town.  Zvornik is a large

25     territory in terms of the area, but the actual town is very small.  So

Page 3653

 1     the people that I spoke to in that town area didn't give me any

 2     information about the detentions.  I don't think that they knew what was

 3     going on outside of Zvornik, Celopek, and all these other things that we

 4     found out about only later.

 5        Q.   [Microphone not activated]

 6             At page 19, line 9, you were asked about the meeting that

 7     occurred I think on the end of June in Zvornik attended by Mr. Karadzic,

 8     General Mladic.  Can you explain for me who or what was Marko Pavlovic

 9     that he could come, as I understand it, uninvited into this meeting and

10     waste the precious time of Karadzic and Mladic?  Why didn't anyone throw

11     him out of that meeting?  Do you have an idea?  Can you help us with

12     that?

13        A.   Marko Pavlovic was not invited to the meeting.  He could have

14     been invited to attend the meeting and to enter the conference room only

15     by Branko Grujic.  After all that talk by Marko Pavlovic, when I

16     interrupted him and raised my voice, then Branko Grujic stood up in his

17     defence and said, "Major Pavlovic is a Serbian mother."  And I was

18     practically speechless after that.  I assume that both Mladic and

19     Karadzic, if they felt that certain conclusions from this meeting were

20     important to them, should have intervened.  However, it was said later

21     that he immediately had to go to Pale for a meeting with UNPROFOR

22     representatives, and it's true that there was a helicopter waiting for

23     them at the Zvornik airport.

24        Q.   But I take it neither Karadzic or Mladic took your side when you

25     raised your voice to speak out against what Pavlovic was saying.

Page 3654

 1        A.   Radovan Karadzic never took my side in any public venue.

 2        Q.   Your answer about what Grujic stood up and said is translated as

 3     "Major Pavlovic was a Serbian mother."  Can you correct me.  That is -- I

 4     don't understand that.  Can you explain that, or was that what you said?

 5     And if so, what does it mean?

 6        A.   I was speechless when Branko Grujic said "Major Pavlovic is a

 7     Serbian mother."  That term "Serbian mother" is something that comes from

 8     the World War II and the then-prime minister in Serbia who was allegedly

 9     saving Serbian refugees from Bosnia and Herzegovina and helping them.

10     And that is why this nickname came about, "Serbian mother" for the

11     prime minister of the Serbian government.  So according to Grujic,

12     Marko Pavlovic was helping the Serbs, and he was like a Serb mother.

13        Q.   Thank you.  At page 21, line 14, you were asked about your

14     meeting with Mico Stanisic when you and Koljevic talked to him about the

15     situation in Zvornik.  And your answer was:

16             "Mico Stanisic said that he had sent this dispatch to the federal

17     minister of the interior ... that they should try and prevent the

18     paramilitary forces from coming over ..."

19             So I think you told us that this meeting was on the 3rd, 4th, or

20     5th of July?  Is that correct?  You have to answer out loud.

21        A.   [No interpretation]

22             THE INTERPRETER:  Could the witness please repeat his answer.

23             MR. HANNIS:

24        Q.   Could you please repeat your answer.  The interpreters didn't

25     hear you.

Page 3655

 1        A.   Yes, at that meeting in early July in Jahorina when Mr. Stanisic

 2     and I spoke was Mr. -- also attended by Mr. Koljevic.  Stanisic told me

 3     that we have major problems with those paramilitary formations.  I had

 4     already sent a dispatch to the federal secretary for internal affairs in

 5     Belgrade, and I think he did mention the name, Petar Gracanin was the

 6     secretary at the time.

 7        Q.   Thank you.  Did he indicate to you how -- for how long or how far

 8     back before the 3rd, 4th, or 5th of July that he had this information

 9     about paramilitary formations that caused him to send a dispatch to

10     Mr. Gracanin in Belgrade?

11        A.   Had I had the information that I have now, I would have asked

12     them at that point in time when he sent it, and I would have asked him

13     for a copy of the dispatch; but I didn't ask him that, and I don't know

14     when he actually sent that dispatch.

15        Q.   You were answering a question at page 30, line 20, about a

16     document that had the name of Mr. Dobro Planojevic on it.  You told us he

17     was a professional policeman, and you ask a question:

18             "But why did Dobro Planojevic disappear from the police

19     infrastructure after this?"

20             Do you know anything about that?  When did he leave and why?

21        A.   The report drafted by Dobro Planojevic entirely suits that man.

22     This is a professional policeman and a very proper person.  He was the

23     number two person in the national security service.  In June the man

24     disappeared.  I don't know where he disappeared.  Judging by all the

25     factors, that person should have gone up in the ranks; however, he

Page 3656

 1     disappeared from the police.

 2        Q.   At page 34, line 5, you were being asked about the special

 3     operation or the round-up of the paramilitaries in Zvornik at the end of

 4     July, and you said that you knew the special police of the RS MUP had

 5     entered Zvornik.  Were you aware of other formations that participated in

 6     that round-up, such as a special group from the federal SUP in Belgrade

 7     or any military police involved in the round-up, do you know?

 8        A.   I don't know who participated in that.  I know only that the

 9     Serbian police or that a unit of the Serbian police, a special unit of

10     the Serbian police, after the arrest moved in to the local hotel in

11     Zvornik.

12        Q.   At page 41 you were asked about what you knew concerning the

13     prosecution of the Vuckovic brothers for alleged war crimes in Zvornik.

14     Do you know when that prosecution occurred, approximately, what year?

15        A.   I don't remember the exact dates, but I know that this was in the

16     Serbian press that they were tried, I think in Sabac.  And my impression

17     overall was that the trial was a farce.

18        Q.   And Sabac is in Serbia; correct?

19        A.   Yes, Sabac is in Serbia.

20        Q.   Thank you.  Page 46, beginning at line 3, there was a long

21     discussion about the Assembly session where Ms. Plavsic had proudly

22     admitted that she had called for volunteers to come and help fight for

23     the Serb cause in the RS.  I think at the very end of your comment you

24     said - concerning the applause - that:

25             "None of them felt that it would be appropriate to pay any

Page 3657

 1     attention to what was happening at Zvornik."

 2             I take it you're referring to any of the attendees at the

 3     Assembly session.  Why do you opine that none of them felt like it was

 4     appropriate to pay attention to what was happening in Zvornik?  Can you

 5     explain a little further?

 6        A.   That Assembly session was when the deputy from Prijedor said that

 7     Prijedor would still be green had we not done what we did.  Had we

 8     listened to Karadzic, Prijedor would still be a green town.  We didn't

 9     listen to anyone, and Prijedor is no longer a green town.  And after that

10     there was applause.  Biljana Plavsic, in her address on calling in the

11     paramilitary formations, also was applauded.  A minister -- just a brief

12     digression.  After testifying in the Krajisnik case had time to organise

13     my thoughts, and I did write some things down so now I remember these

14     things much better.  One minister from the government when the personal

15     ID cards were discussed mentioned that we had expelled them, we expelled

16     them.  So -- and the deputy from Brcko said - regarding the

17     reconstruction of the government, because the reconstruction was my

18     becoming part of the government - said we prevented Mr. Djokanovic from

19     becoming a member of the government.  And then the vice-president of the

20     Assembly during the assembly session in 1993 said we prevented twice

21     Mr. Djokanovic from becoming a part of the government.  If I was the only

22     commissioner who managed to successfully complete the tasks in six

23     municipalities, why was this not good enough?  They didn't allow me to

24     get into the government because I wanted to create support for the

25     resolution of political crimes.  I wanted to give my all on that task.

Page 3658

 1     My political career was not that important to me.  The Serbian people

 2     was -- were important to me, but that leadership was not up to the

 3     historical tasks.  These were people who tended more towards crime rather

 4     than honest political work and the implementation of assignments for the

 5     benefit of the people.

 6        Q.   If I understand your comment correctly, are you saying that in

 7     the Assembly while there may have been some concerns about how it was

 8     achieved, that wasn't really a problem because they were happy with the

 9     results?  Prijedor is green, the Muslims are gone out of Zvornik, let's

10     not pay too much attention about how that came about.  Is that fair?

11        A.   They applauded that.

12        Q.   Thank you.  You were asked about the new minister of the interior

13     at page 50, line 20, and the answer was interpreted as Adzic from Ilijas.

14     Is that Ratko Adzic?

15        A.   Yes, that is Ratko Adzic, he was the president of the Ilijas

16     municipality.

17        Q.   Okay.  At line --

18        A.   I apologise.  I'm actually not quite sure.  There was a Ratko

19     both in Hadzici and in Ilijas.  I think that his last name was Adzic.  I

20     know him because he wore this funny Sajkaca hat.  I don't remember the

21     first and last name.  I think that he was the president of the

22     municipality in Ilijas, but I'm not quite sure about it.

23        Q.   Thank you.  At page 52, the end of page 51 and the beginning of

24     page 52, one of your answers was:

25             "Yes, Mico Stanisic knows that I was a single person who

Page 3659

 1     supported him within that government, the new cabinet."

 2             And you were asked:

 3             "Can you tell us specifically whether that pertains to the

 4     investigations that had been commenced?"

 5             You said:

 6             "Yes, it does.  It pertains to the investigations for war crimes.

 7     Mico Stanisic and I were the only ones in that government interested in

 8     resolving that problem."

 9             What specific investigations are you talking about?  And I take

10     it this is in 1994 with the new government.  Can you name some of the

11     specific war crimes that were being investigated?

12        A.   I understand the question.  I never mentioned specifically crimes

13     in 1994.  I don't know if there were any in 1994.  Mico Stanisic and I,

14     when he was appointed as minister in that government, now we're talking

15     about 1994, we talked about the problems of war crimes, those crimes that

16     happened in 1992 and the continuation, thinking of the continuation of

17     activities that the Ministry of the Interior headed by Stanisic undertook

18     in the course of 1992 until Branko Djeric resigned.  However, there was

19     no political support even then.  This is already the time when the

20     Serbian Democratic Party consolidated its ranks.  It was no longer the

21     Serbian Democratic Movement from 1990.  It was a firm political

22     organisation that was created in the war that came about in 1993 a few

23     days after the government of Vladimir Lukic was named, and that

24     democratic party placed itself as an opposition party in relation to that

25     government.  The government that was formed in 1993 was in a very

Page 3660

 1     difficult situation, at least for a number of ministers who had the

 2     opportunity and were interested in creating state structures.  However,

 3     the political support for activities of the Ministry of the Interior with

 4     this man who had just blundered into the government.  I have no idea how

 5     he managed to become the minister of the interior.  Because of him,

 6     nothing could be done in terms of the war crimes.  I was burdened with

 7     work regarding the disabled veterans and their families.  We had tens of

 8     thousands killed.  Nobody was doing anything about that.  I had to make

 9     lists of those killed, of those wounded, find the wounded in the

10     rehabilitation centres, create the regulations, create the

11     municipality -- the ministry, and then create municipal branches.  So I

12     couldn't specifically do anything about the war crimes dating from 1992,

13     but I did have the intention in the law, and the civilian victims of war

14     simply again introduced that problem in the Law on the Civilian Victims

15     of War.  I did prepare it when I was minister, but when I was minister

16     this law actually did not go into effect.

17             JUDGE HARHOFF:  How much more do you have?

18             MR. HANNIS:  I have two questions, Your Honour.  May I -- do you

19     want to recess now?  The thing is, the next witness has protective

20     measures including voice distortion, so I thought if I could finish this,

21     then we could use the break to set him up.

22             JUDGE HARHOFF:  Yeah, it was just that I didn't want to usurp the

23     interpreters once again.

24             MR. HANNIS:  Thank you.

25        Q.   You don't know what information Mico Stanisic may have had about

Page 3661

 1     the crimes alleged in this indictment in 1992 or 1993, do you?

 2        A.   No.

 3        Q.   And at page 53, line 14, you commented that "throughout the time

 4     I've known him, he was a model policeman.  I'm referring to that entire

 5     period throughout the war."

 6             But you were well aware, weren't you, of public allegations made

 7     in the Assembly and elsewhere that Mico Stanisic was allegedly involved

 8     in crime, yes or no?

 9             MR. CVIJETIC: [Interpretation] Your Honours, we already had the

10     opportunity about this, and I think the Trial Chamber intervened whether

11     these were war crimes or kind of dirty laundry or something like that.

12     Perhaps the Prosecutor can provide a reference for his question so that

13     we can first see what types of crimes we're talking about and whether

14     this is relevant to the matters that we are dealing with today.

15             MR. HANNIS:  May I respond, Your Honour?  His answer was he was a

16     model policeman.  I guess I could ask him if there's any kinds of crimes

17     that you would think would be okay for a model policeman to commit, but I

18     don't think that's necessary.  I would assume by "model policeman" he's

19     referring to someone who does not commit crimes.  But I can ask him a

20     particular question.

21        Q.   Were you aware of allegations that Mico Stanisic was involved in

22     the thefts of cars from the TAS factory in Vogosca?  Don't answer yet.  I

23     see Defence counsel on his feet.

24             MR. CVIJETIC: [Interpretation] Your Honours, if you recall, I

25     asked the witness about the dirty laundry and the stories and mutual

Page 3662

 1     allegations and accusations.  I'm not sure that the witness can give a

 2     specific answer on the basis of unofficial stories or that he knows what

 3     the Prosecutor is talking about.  This is all I wanted to say.

 4             MR. HANNIS:  Your Honour, it only goes to the weight of his

 5     opinion.  If he heard about it and he still has the opinion, then that

 6     undercuts his opinion; if he didn't hear about it, that may also undercut

 7     his opinion.

 8             JUDGE HALL:  It seems that we have reached the point where we

 9     must take the break, gentlemen.

10                           --- Recess taken at 12.10 p.m.

11                           [The witness stands down]

12                           --- On resuming at 12.30 p.m.

13             JUDGE HALL:  Yes, Mr. Zecevic.

14             MR. ZECEVIC:  There is one matter, Your Honour, I wish to raise

15     before the next witness comes in, the --

16             JUDGE HALL:  Yes.

17             MR. ZECEVIC:  Yes -- well, can I do it now?  We still have the

18     witness --

19             JUDGE HALL:  Yes, I'm aware of that.  What --

20             MR. ZECEVIC:  Well, whatever pleases the Court.

21             JUDGE HALL:  You're just alerting us that you intend to raise it?

22             MR. ZECEVIC:  Yes, I am.  Thank you.

23             JUDGE HALL:  Thank you.

24             Mr. Hannis, while the usher is escorting the witness back in, if

25     you insist on an answer for the last question that you asked,

Page 3663

 1     the - pause - it will have to be refined, it seems to me, to eliminate

 2     the argument which is inevitable, where the question includes matters

 3     which are highly in dispute, which is where we were -- the point at which

 4     we were when we took the break.  So it's a matter for you.

 5             MR. HANNIS:  Thank you, Your Honour.  I'll ponder it for the next

 6     couple of seconds and decide what question I can ask, if I ask one.

 7                           [The witness takes the stand]

 8             MR. HANNIS:  Thank you.

 9        Q.   Mr. Djokanovic, I'm going to try to rephrase a question I asked

10     you before the break, and I may have to do it in two or three steps.  Had

11     you heard about any allegations that Mr. Mico Stanisic was involved in

12     the thefts of cars from the TAS factory in Vogosca?  Just, had you heard?

13        A.   Throughout that summer of 1992, there were various rumours going

14     around about major crimes being committed in the area, around Pale,

15     Sarajevo, and towards Serbia.  And even the Zvornik Assembly -- at the

16     Zvornik Assembly the minister of finance, Mr. Pejic, mentioned that this

17     large-scale crime as far as the Vogosca factory thefts were concerned or

18     vehicles were concerned came up to 500.000 Deutschemarks.  And since I

19     was busy, I was in the field a lot then, I knew about these rumours about

20     the white crimes, and I knew that this was somehow -- that people somehow

21     in their minds linked these to the minister of justice and the minister

22     of the police.

23        Q.   Okay.  So in -- knowing that and nothing else, your opinion

24     remains the same that Mr. Stanisic was a model policeman?

25        A.   When I said that Mico Stanisic was a model policeman, I was

Page 3664

 1     referring to the period up until the beginning of the war which is the

 2     period when Mico Stanisic was the city chief of police.  From the start

 3     of the war and onwards, my communication and my contacts with

 4     Mico Stanisic were very infrequent.  I was in the field a lot and the

 5     only meeting that I had with him was the meeting on Mount Jahorina in

 6     early July, and the only thing we discussed at the meeting was the

 7     situation in Zvornik.  Up until the Zvornik Assembly, in other words up

 8     until November 1992, I had heard of the rumours about organised crime and

 9     this was the problem that the first government and Branko Djeric at its

10     head had the problem with and had to deal with.  So when Branko Djeric

11     asked me if I wanted to be a member of his government I asked him, "Well,

12     are you -- do you intend to resolve these crimes?"  And he said, "Yes, I

13     do."  And then I said, "Yes, I will, and I will support you, and I will

14     also provide two members of the Presidency as support."  I was referring

15     to Biljana Plavsic and Mr. Koljevic at the time, because both of them

16     were prepared to support this fight or struggle against organised crime.

17     So I'm not talking about war crimes, I'm just talking about white crimes,

18     the white-collar crimes, economic crimes.  And of course I had heard

19     rumours that -- to be more specific, that organised crime went all the

20     way up to the Ministry of Justice, the minister of justice, and that in

21     fact Karadzic and Krajisnik were behind that.

22        Q.   Let me try and clarify something.  At page 53 you said:

23             "And throughout the time I've known him, he was a model

24     policeman, I'm referring to that entire period throughout the war."

25             And just now on page 72, line 13 you said:

Page 3665

 1             "When I said that Mico Stanisic was a model policeman, I was

 2     referring to the period up until the beginning of the war ..."

 3             Can you tell us which it is, for what period of time did you

 4     consider him a model policeman?

 5        A.   When I say "Mico Stanisic was a model policeman," I'm referring

 6     to the period before the war, up until the war began.  No doubt about

 7     that.  The period up until he was dismissed.  So I'm referring to the

 8     government of Djeric, and I only had one meeting with him where we

 9     discussed the situation in Zvornik.  And in my view, he was a very decent

10     policeman.  I had no other specific information about him.  The new

11     minister of the -- up until the new minister of the interior was

12     appointed, a government which was headed by Lukic, Mico Stanisic in my

13     view remained a model policeman.  I had never heard by then any stories

14     about him participating in any crimes then.  And as for the period before

15     1992, I really don't -- and those stories that were going around, I don't

16     know what was true.

17        Q.   Have you read the indictment in this case?

18        A.   [No interpretation]

19        Q.   And did -- but you heard at some point prior to your coming to

20     testify that Mico Stanisic had been indicted by this Tribunal; yes?

21        A.   Of course I had heard.

22        Q.   And if any of those crimes were eventually to be proven true,

23     would that change your opinion about whether or not he was a model

24     policeman in 1992?

25             JUDGE HALL:  Mr. Hannis, did -- I don't understand the

Page 3666

 1     Prosecution's case to be that you called Dr. Djokanovic as a character

 2     witness in respect of Mr. -- of the accused Stanisic.  Why are you -- may

 3     I ask why are you persisting down this road.

 4             MR. HANNIS:  Because the Defence has turned him into a character

 5     witness for Mr. Stanisic, and I'm just trying to respond to that.

 6             JUDGE HARHOFF:  I think you've made your point.

 7             MR. HANNIS:  Thank you.  I'll stop.

 8        Q.   No more questions, Mr. Djokanovic.  Thank you.

 9             JUDGE HALL:  Dr. Djokanovic, we thank you for your assistance to

10     the Tribunal.  Your testimony is at an end, and you're now released as a

11     witness, and we wish you a safe journey back to your home.

12             THE WITNESS:  Thank you very much.

13                           [Trial Chamber and Registrar confer]

14                           [The witness withdrew]

15             JUDGE HALL:  Yes, Mr. Zecevic.

16             MR. ZECEVIC:  I see my friend, Tom Hannis, is standing.  Maybe --

17             MR. HANNIS:  I was just going to announce the next witness.

18             MR. ZECEVIC:  Oh, yeah.  Well, Your Honours, we just received the

19     document from the Prosecution.  It is allegedly the diary of the coming

20     witness.  As you can see, it has probably more than 200 pages.  Now, the

21     Prosecution informed us late last night that they were made aware only

22     on -- at the time of the appearance of the witness when he came to

23     The Hague he said that he was apparently having a diary or something and

24     provided a copy to the Prosecution.  Now, I'm not objecting to the direct

25     examination, of course, nor do I want that the -- more time is lost.  But

Page 3667

 1     there might be a problem for us to conduct a proper cross-examination of

 2     this witness in light of late disclosure of this document.  Because,

 3     Your Honours, it will take us some time because it's in handwriting, so

 4     it's not easy to read, it's going to take some time for us to be able to

 5     read the document.

 6             Now, the Prosecution put us on notice that they intend to

 7     introduce two pages of the diary, and we're not objecting to go that.

 8     But again, what I'm saying is --

 9             MR. HANNIS:  I'm sorry, the pages of the diary that we're

10     proposing to introduce into evidence were pages that were disclosed long

11     ago.  This is a new diary for a different time-period.

12             MR. ZECEVIC:  Okay.

13             MR. HANNIS:  And I'm not intending to use any of it because it's

14     in B/C/S and I haven't read any of it and the fact that we gave it to you

15     so late, I'm not proposing to use it in my direct examination.

16             MR. ZECEVIC:  Well, I'm just putting the Trial Chamber on notice.

17     If this is not going to be used, then there might not be a problem at

18     all -- after all.  But I just wanted the Trial Chamber to -- and to put

19     it on the record, actually.  Thank you very much.  And I will inform the

20     Trial Chamber in case we experience some difficulties with that.  Thank

21     you.

22             JUDGE HALL:  [Microphone not activated]

23                           --- Recess taken at 12.43 p.m.

24                           [The witness entered court]

25                           --- On resuming at 12.50 p.m.

Page 3668

 1             MR. HANNIS:  Your Honours, our next witness is ST-121.  This

 2     witness has been granted the protective measures of a pseudonym, voice,

 3     and image distortion.  I'm not sure if Your Honours like to proceed next.

 4     I have a pseudonym sheet to show him, but I think that's after Judge Hall

 5     does the preliminaries or Judge Delvoie.

 6             JUDGE DELVOIE:  Can the witness please make the solemn

 7     declaration.

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

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

10                           WITNESS:  WITNESS ST-121

11                           [Witness answered through interpreter]

12             JUDGE DELVOIE:  Thank you.

13             Mr. Witness, we go into private session for a moment.

14                           [Private session]

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 3669











11 Pages 3669-3673 redacted. Private session.















Page 3674

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25                           [Open session]

Page 3675

 1             THE REGISTRAR:  We're are now in open session, Your Honours.

 2             MR. HANNIS:  Thank you.

 3        Q.   Witness, we've heard that you -- you're currently retired, having

 4     worked as a professional policeman from 1974 to 2000.  Can you tell us

 5     during your career what was your job, what kind of work did you do for

 6     the MUP?

 7        A.   For the most part I investigated complex crimes in the crime

 8     investigation department.  I worked on the most complex and difficult

 9     cases, including armed robberies and murders, up until the war broke out

10     in my earlier place of residence.  If necessary, I can say that if we're

11     in closed session.  I worked in Tuzla, in a big centre, which numbered --

12     which had 19 municipalities.  It was a large regional centre, and there

13     was not a single municipality where I did not leave a good impression in

14     discovering and shedding light on these heavy and serious crimes.

15             When the war broke out, after I spent 33 days in the Army of

16     Republika Srpska, I was transferred to the Republika Srpska MUP where I

17     was from the 3rd of July, 1991 [as interpreted], up until I was -- I

18     retired.  And I always worked on these difficult crimes, and I was in the

19     administration that dealt with personnel.  We handled -- at the ministry.

20     So we dealt more with the administrative aspects than with investigations

21     of crimes themselves, but if the minister so desired, then I could be

22     assigned to actual investigations.

23        Q.   And in your work --

24             JUDGE HALL:  Sorry, Mr. Hannis.

25             MR. HANNIS:  Yes.

Page 3676

 1             JUDGE HALL:  Before you continue, inasmuch as we're in open

 2     session, would a portion of the witness's last lengthy answer have to be

 3     redacted?

 4             MR. HANNIS:  Your Honour, I suppose a reference to the location

 5     where he worked, but several people worked in that location.  I don't

 6     know if it's necessary or not, but I would remind the witness that we are

 7     in open session.

 8        Q.   Witness, in your work were you a uniformed police officer, or did

 9     you wear plain clothes to work?

10        A.   I spent my entire career in plain clothes, and you can check

11     that.

12        Q.   And from -- you said from the 3rd of July, it was translated as

13     1991.  Was it 1991 or 1992?

14        A.   1992.

15        Q.   And where were you working in the RS MUP?  Could you tell us what

16     location.

17        A.   I worked in the MUP.  At the time there was a public security

18     centre established in Bijeljina in 1992.  I don't know exactly what date.

19     But soon thereafter certain administrations within the ministry were

20     established which had transferred from Pale to Bijeljina so that two

21     months later, after two months of actual practical work, I was actually

22     posted in one of those administrations, and there was a letter of

23     appointment appointing me as a crime inspector for general crime

24     prevention.

25        Q.   And can you give us a brief description of what a crime inspector

Page 3677

 1     for general crime does.  What kind of cases did you investigate and how

 2     did you go about doing that work?

 3        A.   Well, I will begin with the chain of command within the Ministry

 4     of the Interior.  So there are police stations, public security stations,

 5     the centre of security services, and the Ministry of the Interior which

 6     consists of a number of administrations.  The first administration is the

 7     police, the second administration is the crime administration, and the

 8     third analytics, and so on.  So from the start of the war in 1992 I was

 9     with the crime police administration, and my job dealt with educating and

10     controlling the work of police stations in Republika Srpska.  And of

11     course on orders from my superiors I visited all those stations that

12     required it.  Sometimes I also participated directly in the investigation

13     of major crimes, such as, for instance, the arrest of -- the case of the

14     arrest of the paramilitary unit Zuta Osa, or the arrest --

15             THE INTERPRETER:  The interpreter did not hear the name of the

16     person who was arrested.

17             THE WITNESS: [Previous translation continues]... and similar

18     cases.

19             MR. HANNIS:

20        Q.   The interpreters indicated that they did not hear the name of the

21     individual that you mentioned in connection with the Yellow Wasps.  Could

22     you repeat the name.

23             MR. ZECEVIC:  Actually, the reference was to the arrest in Samac.

24             MR. HANNIS:  Thank you, Mr. Zecevic.

25        Q.   Witness, disregard my last question then.  I will ask you in

Page 3678

 1     connection with the Yellow Wasps in Zvornik, how did you first become

 2     engaged in doing some work on that case?  Who contacted you or asked you

 3     or directed you to do that?

 4        A.   I was directed to do the work by Goran Macar who was my immediate

 5     superior.  At the time he was the chief of the administration.  He

 6     selected a number of individuals who would make up the team who would

 7     investigate.  There was some 80 people arrested, and we had to proceed

 8     promptly and produce a criminal report for the crimes that they had

 9     committed.  In other words, I was one of the seven to eight operatives.

10     I cannot name them all.  I can name a couple of them, two or three, who

11     were on this with me.  For instance, Ljubo Kovac, Nikola Milanovic,

12     myself.  There were a number of other operatives from the centre of

13     public security in Bijeljina, but I can't name them at the time -- right

14     now.

15        Q.   And did you physically go to Zvornik to take part in that

16     investigation, or were some of the arrestees brought to you in Bijeljina?

17        A.   All the arrested individuals, members of the Yellow Wasps,

18     together with their so-called commander, Vojin Vuckovic, a.k.a. Zuca,

19     were brought to the centre -- the security centre in Bijeljina on buses

20     after their arrest.  They were actually recorded on -- with a video

21     camera.  They were held in two detention rooms.  There were too many

22     people in these two rooms, it was summer, the end of July, it was very

23     hot, and these were difficult conditions for them and for us.  Then we

24     were issued orders from the chief as to who was to conduct interviews

25     with whom.  And it so happens that I was assigned to interview their

Page 3679

 1     commander, Dusan Vuckovic, a.k.a. Repic; a Filipovic; and there is no

 2     need to name all the others.  I think they're mentioned in my diary.

 3     There was some 10 to 15 individuals that I had to interview, and they

 4     all -- and each of the members of the team had such an assignment, to

 5     interview a number of people about robberies and other crimes that they

 6     committed -- had committed at the time in the area of Zvornik, Bijeljina,

 7     Brcko, wherever they went.

 8        Q.   In that answer you indicated you got orders from the chief as to

 9     who was to conduct the interviews.  Who are you referring to there when

10     you say "the chief"?

11        A.   I was thinking of the chief Goran Macar, who was my immediate

12     superior.

13        Q.   Thank you.  And before you began the interview process, was there

14     any kind of group meeting or briefing for all you inspectors who were

15     going to conduct the interviews?  Was there some kind of background

16     information you had, and was there an investigative plan that you agreed

17     upon?  Can you tell us about that.

18        A.   I think that there was a brief meeting before taking on the

19     duties of this post.  At the meeting the chief said the following - and

20     I'm thinking about Goran Macar - that attention should be paid to all

21     crimes which had at that time been registered at the police stations and

22     the security centre in Bijeljina, if they had been reported; then to

23     search apartments, vehicles, garages, because they had occupied a lot of

24     the apartments in Zvornik, throwing out the Bosniaks either by force or

25     people would leave of their own accord; and particularly to pay attention

Page 3680

 1     if during questioning some of the people arrested mentioned that he had

 2     committed a war crime of killing a member of the non-Serbian population,

 3     thinking of Bosniaks, Croats; and to record that interview on a special

 4     form or official report, and that that should be given to me and then I

 5     would send that on to the specialised national security service for

 6     further processing.  That service at the time headed by headed Kisic and

 7     his assistants was located in a private house in Bijeljina, and they

 8     would then deal with those things.  Our tasks were general crimes to

 9     monitor the robberies that had been committed, to find the vehicles, the

10     articles and other things involved in the crimes, and to document that.

11        Q.   Thank you.

12             Witness, I'd like to show you now an exhibit.  This is 65 ter

13     number 1439.

14             MR. HANNIS:  And, Your Honours, if I may, I have a hard copy

15     because it's about a 30-page, 35-page document.  If I could hand a hard

16     copy to the witness, it may be quicker and easier for him to work through

17     that.

18        Q.   Witness, if you could take a quick look and tell us if you

19     recognise what that is or what that's a copy of.

20        A.   This is a copy of a notebook of mine which I received when I

21     transferred from the military to the police.  I didn't have a diary or

22     anything, notepad, with me, so a colleague gave one to me to use.  And I

23     actually began it with the Yellow Wasps.

24             MR. HANNIS:  If we can go to page 2 in the English, and I think

25     it's page 3 of the B/C/S.

Page 3681

 1        Q.   For you, sir, it would be the page that is handwritten number 2

 2     on the bottom.  Do you recognise what's on that page?

 3        A.   I recognise my handwriting.

 4        Q.   And there's a list of some items.  What were these items, and how

 5     did you come to write them down?  Is this something that you agreed on or

 6     that you were directed to inquire about?

 7        A.   These are just questions that we were planning to ask to each of

 8     the individual persons that had to do with individual criminal

 9     activities.  And there was this first draft question:  Manner of

10     engagement in Zuca's unit, and this was way to cover how they came to

11     Zvornik, the connection with the local institutions, with individuals.

12     This is the idea.  Then the second question:  Depositing of stolen

13     goods -- do you need me to comment on that?

14        Q.   Let me take you through item by item for the ones that I'm

15     interested in.  Number 3 talks about their connections to the -- in the

16     Zvornik authorities and then lists some other municipalities.  I'm

17     interested about Sokolac and Pale.  Did you have some information

18     indicating that this group had connections in Pale and Sokolac; and if

19     so, where did that information come from?

20        A.   While talking to Vojin Vuckovic, the commander of that

21     paramilitary unit, he, himself, described how upon arrival in Zvornik and

22     while assembling that unit which was becoming larger every day, there was

23     a need to provide weapons, equipment, and everything that was needed for

24     war.  So he remembered with his escort to go to Pale one day, thinking

25     that somebody from the authorities of Republika Srpska would receive him

Page 3682

 1     there where he could discuss this matter.  He was primarily thinking of

 2     President Karadzic.  When he came to Pale, the chef de cabinet - I don't

 3     remember his name - perhaps just spoke with him briefly; and seeing that

 4     this was an unknown man, he did not get into contact with Radovan, the

 5     president, that day.  He stated the reasons why he had come there that

 6     day, and then the chef de cabinet sent him to see the chief of the public

 7     security station in Pale.  His name was Malko Koroman.  In some documents

 8     I saw that his name is Marko Koroman, but actually his name is

 9     Malko Koroman.  He is the first chief -- wartime chief of the public

10     security station in Pale after it was formed.  So he did go to see him,

11     and he saw him there and spoke with him about weapons.  He said who had

12     sent him, and then he was given a certain number of automatic rifles,

13     machine-guns, Zolja, weapons, things that could fit into a vehicle.  But

14     they continued to stay in touch in the following way.  When Zuco would

15     come to Zvornik, he of course distributed the weapons to members of his

16     formation, and they formed on their own without the knowledge of the

17     official authorities in Zvornik - I'm thinking of the police - a

18     check-point in the settlement of Karakaj so that they could inspect the

19     drivers, the people who were arriving from the direction of Romanija,

20     Pale, Sokolac, whether they had the proper papers, check their vehicle,

21     and so on.  If they liked the vehicle, they would confiscate the vehicle,

22     they would throw the passengers out, mistreat them, so that some people

23     who were well-known in the ministry of Republika Srpska or in the

24     government of Republika Srpska experienced some rough treatment.  I'm

25     going to mention Momcilo Mandic here and Mr. -- he was in the government,

Page 3683

 1     he was the prime minister.

 2        Q.   Let me interrupt you there.  What you were just saying in your

 3     answer sounded like information that you had received from Zuco,

 4     Vojin Vuckovic, and during your interview with him.  But my question is

 5     these items listed here, 1 to 4 and then I think 5 through 7 on the next

 6     page, appear to be topics that you planned to ask about before the

 7     interviews started.  Is my interpretation correct?

 8        A.   Yes, it is correct, yes.

 9        Q.   Okay.  And because item 3 says "their connections in Zvornik ..."

10     and so on, Sokolac and Pale, do you recall where you had information to

11     suggest that this group might have connections with authorities in

12     Sokolac and Pale?  Did that come from Goran Macar or from one of the

13     other investigators, or do you remember?

14        A.   I think that Vojin did say that.  I think also that Goran Macar

15     regarding this third question when we were talking how -- as to how to

16     begin the conversation, I think he suggested that I should ask him about

17     these circumstances.

18        Q.   Thank you.

19             Witness, if we could go to the next page in both the English and

20     the B/C/S.  This is items 5, 6, and 7.  Number 6 there's an item

21     underlined that says -- my English translation says:

22             "Liquidation of unwanted Serbs" -- "List for the liquidation of

23     unwanted Serbs."

24             Can you tell us, what was your information before starting the

25     interviews about such list, if you can remember?

Page 3684

 1        A.   I remember that his brother, Dusan Vuckovic, came to be

 2     interviewed first with me, and then Vojin came afterwards.  And he

 3     mentioned that he had made a list of undesirable Serbs, and he mentioned

 4     among others the name of Marko -- Malko Pavlovic.  That person was in

 5     Zvornik at the time under a pseudonym.  Later I found out that he used to

 6     work in the state security of Serbia.  How he came to be in this area, I

 7     really cannot say because I never spoke with that man.

 8        Q.   Let me ask you about the list.  Were there -- did you see during

 9     the course of your investigation any list for liquidation of unwanted

10     Serbs?

11        A.   I didn't see any list for liquidation of undesirable Serbs, but I

12     did see another list, a longer list, which is something that I can

13     explain now or when the time comes.

14        Q.   Yes, would you explain what this longer list was, where you first

15     saw it, and what that was about.

16        A.   When this paramilitary formation was arrested, the people who

17     carried that out headed by Milorad Davidovic and his associates, they

18     collected everything including several sacks.  And when they were

19     transported from Zvornik, from Bijeljina, they left those sacks in

20     offices thinking that the operatives, us, would be able to figure out

21     what was in the bag, what belonged to whom.  It was a bit chaotic, so

22     things were not done correctly from the start.  So we had to put in some

23     effort to figure out whose documents were there.  And so this list was

24     found there as well, a list containing some 600 to 700 Bosniak names.  On

25     one A4 format page there were 25 names each in two columns on each sheet.

Page 3685

 1     And, for example, you would have Mujo Alic or Iljaz Berberovic [phoen].

 2     It was not -- the other particulars about the person were not provided.

 3     And I remember that there was some 20 such pages containing 50 names

 4     each, more or less.  And then if you multiply it, you could then figure

 5     out what size the list was.  I talked with Dusan Vuckovic, a.k.a. Repic,

 6     about this list, who made the list.  And he said that he personally typed

 7     it, and this Filipovic who we could see on the screen a little bit

 8     earlier or Milan Timotic, the journalist from Loznica, one or two of them

 9     would do that every day in Celopek, this is a village in the municipality

10     of Zvornik.  And in the local commune, the former cinema hall, there was

11     some 650 to 700 Bosniaks detained there, and I saw that actually while I

12     was still in the army.  If you wish me -- for me to explain this, I will

13     be very brief.

14        Q.   Let me ask you a couple questions first before we go back to

15     that.  Your answer is translated here as Dusan Vuckovic, Repic, said that

16     he personally typed it.  And your answer then goes on to say:

17             " ... and this Filipovic," I think that's Sinisa Filipovic,

18     "... or Milan Timotic, the journalist from Loznica, one or two of them

19     would do that every day in Celopek ..."

20             Would do what every day in Celopek?  Work on the list?  Add names

21     to the list?  I wasn't clear what you were trying to say there.

22        A.   I asked him, "Why did you make this list?"  He said, "You know,

23     some others would come and they would take out five or ten people and

24     don't bring them back.  So in order to avoid this being ascribed to us,

25     that we had committed something bad."  I'm talking -- well, it's as if he

Page 3686

 1     was concerned to keep track of the numbers, to make the figures -- the

 2     numbers correspond.  And they were there in Celopek, Bijeljina, Ugljevik,

 3     in that area, for several reasons, especially in Celopek.  On the 12th of

 4     July, 1992, he described that to me quite, as you could say, quite

 5     realistically.  This is St. Peter's day, Serbian Slava.  One of them was

 6     celebrating the Slava, and they were roasting a pig according to the

 7     Orthodox customs.  They had lit a fire, they had brought a lot of drinks,

 8     and they had opened the door of the cinema where so many Bosniaks had

 9     been detained.  And those people were -- they needed air and water.  It

10     was hot, but they had to watch and observe what these people were doing.

11     Then when they got drunk, this is all that Repic told me, they took out

12     20 people, they lined them up in two columns, turning them to face each

13     other.  He took a knife.  He cut off the pigs ear, and he gave it to one

14     of those standing in the line first, and they gave it to him to eat it.

15     So the man had to eat this ear.  And then the person next to him, he took

16     the knife and cut this mans ear off, and then he said, "Now you eat

17     this."  The person ate and swallowed and ate and swallowed.  It was hard

18     for him to do it.  He did this with the next person, and then the person

19     said, "I cannot eat the whole ear.  Can you at least cut it into two or

20     three pieces so that I can swallow it more easily."  However, he didn't

21     do that.  He killed him on the spot.  They had already been quite drunk.

22        Q.   Let me --

23        A.   And after this bloody revelry, they were -- all these people were

24     looking at the -- what was going on.  They were some 15 to 20 metres away

25     from where this was going on.  They got a vehicle and they took the

Page 3687

 1     bodies and threw them in the River Drina.

 2        Q.   Let me --

 3        A.   This is what happened on that day.

 4        Q.   Okay.  And let me clear that up before I go back to my earlier

 5     question.  Where did that take place?

 6        A.   This happened in the village of Celopek in front of the old

 7     community hall, as people call it -- actually, it's a movie house.

 8     Before the war they would play movies there.  This is where those

 9     Bosniaks were detained.  They were kept there by the authorities in

10     Zvornik.  And people from the Eastern Bosnia Corps had to have known

11     about this, about all of this, because this was in their area of

12     responsibility.

13        Q.   Let me ask you, that building was referred to sometimes as

14     Celopek dome?

15        A.   Yes.

16        Q.   Yes.  And do you know who was guarding that facility at the time

17     this event occurred?  Was it police, TO, army?  Do you know?

18        A.   When I was in the army, if I can explain that part, and then I'm

19     going to actually say what I saw.  My engagement in the Army of Republika

20     Srpska dates from the 28th of May, 1992, until the 30th of June, 1992.

21     This is documented.  Sometime in early June my immediate superior was

22     Captain First Class Dusan Tanaskovic.  I worked in the military police in

23     a battalion that was corps protection unit.  The corps was situated in

24     Ugljevik.  I worked in the military police as a desk officer in the

25     criminal investigations department.  I was appointed to the job in order

Page 3688

 1     to work on some things that had happened in Ugljevik Lopar, because

 2     that's where the military administration was introduced at the time

 3     because the civilian authority was not functioning, the police station.

 4     So all the police station assignments were being carried out by the

 5     military police.  I was there and a few other people.

 6             So one day Pavic Rajko came to get me in the high school centre

 7     where I was billeted; he worked in the security service.  And he told me,

 8     "The chief ordered that you come with me to check something, and I'll

 9     tell you what it's about in the car."  All right.  He said "chief," he

10     meant Mr. Tanaskovic from whom we received orders.  I sat with him in the

11     car.  We were going from the direction of Ugljevik towards Bijeljina, and

12     then from Bijeljina towards Janja.  I didn't know where they were going.

13     I said, "Where are you driving me?  What is this all about?"  And he

14     said, "We received, or an order has arrived.  Some are going to face

15     God's truth."  I said, "What are you talking about ?"  And he said,

16     "You'll see, we're going to a village near Zvornik."  Well, you couldn't

17     really ask too many questions then; it was war.  You would draw

18     conclusions on the basis of words or some sentences.  I didn't know these

19     people, I didn't know this man.  He said we're going to see something.  I

20     said, "What?"  He said, "Well, the chief said because you worked on these

21     crimes tasks throughout the Tuzla region, you might recognise somebody in

22     these bunch of people who are detained in the Celopek hall; and if you do

23     recognise them, you should point them out to me and we will take them to

24     Ugljevik to prison."  "Why?"  He said, "That's what the order from

25     Tanaskovic says."

Page 3689

 1        Q.   I'm going to stop you there, witness.

 2             MR. HANNIS:  Perhaps this would be a good point to break for the

 3     day, Your Honour.

 4             JUDGE HALL:  Mr. Witness, we're about to take the break for the

 5     day.  You, having been sworn as a witness in this case, during the break

 6     you cannot communicate with the lawyers from either side.  And in such

 7     conversations as you may have with persons outside of the courtroom, you

 8     cannot discuss your testimony before the Tribunal.  Do you understand?

 9     Do you understand what I've just explained?

10             THE WITNESS: [Interpretation] I understand.

11             JUDGE HALL:  [Microphone not activated]

12             THE INTERPRETER:  Microphone, please.

13             THE WITNESS: [Interpretation] I didn't understand, in the morning

14     at 9.00 I will be informed.  I will be informed when they will bring me?

15             JUDGE HALL:  [Microphone not activated] Yes, those arrangements

16     will be made.

17             THE WITNESS: [Interpretation] Thank you very much.

18             JUDGE HALL:  [Microphone not activated] You should remain where

19     you are, because the usher has to escort you out.

20             My microphone wasn't on.  I'll say that again.  Please remain

21     where you are because the usher has to escort you out, having regard to

22     the protected measures that have been afforded you.

23                           --- Whereupon the hearing adjourned at 1.46 p.m.,

24                           to be reconvened on Tuesday, the 24th day of

25                           November, 2009, at 9.00 a.m.